CSRD, CBAM, ESPR updates
By Anna Palminger, LCA and Sustainability Manager at EandoX
Across frameworks like CSRD, CBAM and ESPR, expectations are gradually shifting from high-level commitments toward more structured, product-specific information. For companies working close to the data, this raises practical questions: What will likely be required? Where are the biggest uncertainties? And how can organizations prepare without overcommitting too early?
Below are some of the regulatory developments that manufacturers are closely watching as 2026 comes into view.
CSRD & CSDDD: moving closer to operational clarity
After an extended period of development and discussion, both the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) appear to be approaching a more stable phase.
What seems likely around 2026
- Greater clarity on scope and expectations: while some details may still be refined, companies can increasingly plan based on clearer guidance rather than drafts.
- An effort to balance ambition with simplicity: the EU has signaled an intention to reduce unnecessary administrative burden while still increasing transparency and accountability.
- Stronger links to product-level data: environmental disclosures are expected to rely more on information coming from products, suppliers, and LCAs, rather than high-level estimates.
- Closer alignment between reporting and due diligence: sustainability reporting and value-chain responsibility are becoming more connected in practice.
What this may mean for manufacturers
Rather than treating CSRD as a standalone reporting exercise, many companies are beginning to view it as something that draws on the same data used for EPDs, supplier collaboration, and internal performance tracking.
CBAM: from transitional reporting toward higher data expectations
CBAM continues to evolve, and while the transitional phase has allowed for some flexibility, manufacturers are preparing for a future where data quality and consistency become more important.
What companies are preparing for
- Reduced tolerance for generic assumptions over time
- More detailed emissions information from suppliers, especially for imported materials
- Increased alignment between CBAM calculations, LCAs, and EPD data
What this may mean in practice
Many manufacturers are starting to see value in maintaining one underlying emissions logic across multiple use cases, rather than recalculating similar figures in different contexts.
ESPR: Regulation (EU) 2024/1781 and new expectations for products
The Ecodesign for Sustainable Products Regulation (ESPR) entered into force in 2024, and several of its most tangible elements begin to affect companies from 2026 onward.
Noteworthy changes on the horizon
- Introduction of Digital Product Passports (DPPs) for selected product groups from mid-2026, potentially including textiles and footwear
- Passports are expected to contain structured information on material composition, environmental performance, reparability, and recyclability
- Access is planned via QR codes and a central EU register
- New reporting obligations, requiring companies to publish annual information on:
- Products withdrawn from sale
- Reasons products did not reach end users
- How products were managed (e.g. recycling, donation, resale)
- Restrictions on destroying unsold clothing and footwear
- Expected to apply to large companies from July 19, 2026
- Extended to medium-sized companies from July 19, 2030
- Micro and small enterprises are exempt
What this may mean for product data
These developments point toward a future where product information needs to be structured, updatable, and usable across multiple regulatory and commercial contexts — not just stored as static documentation.
The Ecodesign & Energy Labelling Working Plan (2025–2030)
In April 2025, the European Commission presented the Ecodesign for Sustainable Products and Energy Labelling Working Plan (2025–2030), offering insight into how product regulation may develop over the coming years.
While not all measures are defined yet, the plan:
- Signals which product categories may be prioritized next
- Emphasizes life-cycle thinking beyond energy efficiency
- Highlights data availability and standardization as enabling factors for circularity
For manufacturers, this provides an early indication of where regulatory attention is likely to move — even if timelines and details will continue to evolve.
Construction-related regulation: a broader life-cycle perspective
In the built environment, several regulatory developments are converging.
- The revised Energy Performance of Buildings Directive (EPBD) introduces life-cycle assessments for large buildings by 2028, with broader coverage planned by 2030.
- The Construction Product Regulation (CPR) places stronger emphasis on mandatory, harmonized environmental data for construction products, aligned with EPD standards and machine-readable formats.
- Enforcement is expected to roll out gradually, potentially starting around 2026 as harmonized standards are finalized.
Together, these changes suggest a continued shift toward whole-life carbon considerations and comparable product data in design and procurement processes.
EN 15804 & EPD Updates: gradual changes with practical implications
The EN 15804 standard, which dictates the calculation rules for construction product environmental data, remains the key reference point. While the resulting Environmental Product Declarations (EPDs) are technically voluntary, they are the established format for communicating this EN 15804-compliant data.
Technical Clarity: Distinguishing Mandatory Standards from Voluntary EPDs
When reviewing the new EU regulatory landscape, it is essential to distinguish between the mandatory technical standard required by law and the voluntary format used to communicate that data.
The EN 15804 standard remains the core reference for calculating environmental data for construction products in Europe. EU regulations such as the Construction Product Regulation (CPR) and the Energy Performance of Buildings Directive (EPBD) increasingly point to this underlying methodology.
Environmental Product Declarations (EPDs) are technically voluntary, but have so far been the most widely used and established way of communicating EN 15804-compliant data in a structured, third-party-verified format (like BREEAM, LEED, or national LCA tools).
At the same time, emerging mechanisms such as Declarations of Performance (DoCP) and Digital Product Passports (DPPs) introduce additional ways in which EN-15804-based data may need to be shared in the future. How these formats will interact with EPDs is still evolving.
What this may mean
Many companies are reassessing how EPDs are created and maintained, especially when updates are frequent and product portfolios are large.
What manufacturers are navigating right now
What stands out is not any single regulation — it’s how closely they are starting to connect.
Even though many details are still being clarified, the overall direction seems consistent: product data is becoming more central, more reusable, and more scrutinized. For manufacturers, this can feel overwhelming, especially when regulations evolve at different speeds. But it can also be an opportunity to step back and simplify — by focusing on the underlying data rather than each requirement in isolation.
At EandoX, we work closely with companies navigating exactly this transition: moving from fragmented, report-driven workflows toward structured product data that can support many needs over time. In a regulatory landscape that’s still taking shape, that kind of flexibility is becoming just as important as compliance itself.
