One thing is certain: the months ahead in 2025 will bring growing political risks for businesses worldwide, including within the European Union. New regulations—shaped by current political events—along with the enforcement of previously adopted laws, will have direct and sometimes drastic effects on business operations. Below, we’ve outlined key regulatory changes that we believe will significantly impact companies across various industries, as well as their reputation and public image in Poland, Europe, and beyond.

1. Ecodesign of sustainable products (ESPR)

In mid-2024, Regulation 2024/1781 of June 13, 2024, was published in the Official Journal of the European Union. This Regulation establishes a framework for setting ecodesign requirements for sustainable products, amends Directive 2020/1828 and Regulation 2023/1542, and repeals Directive 2009/125/EC. The Regulation aims to ensure appropriate product design so that products are, among other things, durable, reliable, reusable, and repairable. The goal is to minimize the number of new products and, consequently, the number of raw materials used for their production.

The Ecodesign for Sustainable Products Regulation (ESPR) covers significantly more product groups than the previous Ecodesign Directive, which applied only to energy-related products. ESPR applies to all types of goods placed on the EU market, except for defense and security-related products, most types of vehicles, as well as food, animal feed, and medicinal products.

The most important changes introduced by the Regulation include:

• Information requirements related to the so-called Digital Product Passport
• Ban on destroying unsold products, particularly clothing and footwear
• Ensuring compliance of product design and manufacturing with efficiency requirements

The Regulation has entered into force and must be applied. However, its requirements are general, and the European Commission is authorized to specify them through delegated acts issued for individual product groups.

2. Revised CLP Regulation

In November, Regulation 2024/2865 of October 23, 2024, amending Regulation 1272/2008 on the classification, labeling, and packaging of substances and mixtures, was published in the Official Journal of the European Union.

The Regulation introduces several changes, including new rules for classifying substances containing more than one component, updated requirements for physical labels to enhance their visibility, new Regulations for advertising substances and mixtures classified as hazardous, and additional labeling requirements for hazardous substances and mixtures supplied without packaging.

The Regulation came into force on December 10, 2024. However, the new requirements will be implemented gradually. The main obligations imposed on the industry will apply from July 1, 2026, while changes related to label formatting will take effect from January 1, 2027. Products placed on the market before these dates do not need to be relabeled or repackaged and may remain in circulation until 2028 and 2029.

3. New rules for industrial emissions (IED)

In July 2024, Directive 2024/1785 of 24 April 2024 amending Directive 2010/75/EU on industrial emissions (integrated pollution prevention and control) and Directive 1999/31/EC on landfill waste was published in the Official Journal of the European Union.

The amendment to the IED Directive tightens the rules for setting permissible emission levels in integrated permits and introduces various other changes, including extending the directive's scope to new installations, requiring operators to develop and implement environmental management systems and transformation plans, and increasing public participation in procedures for issuing or updating permits.

Member States are required to implement the Directive by 1 July 2026.

4. Carbon dioxide removal (CDR)

The European Union is intensifying efforts to develop carbon capture, storage, and utilization (CCS and CCU) technologies. In 2024, the EU published Regulation 2024/3012, which establishes a certification framework for the permanent removal and storage of CO2, setting quality criteria for such activities.

At the same time, under the Net Zero Industry Act, the EU has committed to achieving an annual CO2 injection capacity of 50 million tons by 2030 to support climate neutrality goals. Oil and gas producers will play a key role in meeting this target and will be able to enter into cooperative agreements with external entities to facilitate its achievement.

Poland's presidency of the EU Council in 2025 presents an opportunity to intensify efforts in this area, including the promotion of advanced CCS and CCU technologies.

5. The EU's Carbon Border Adjustment Mechanism (CBAM)

Regulation 2023/956 of May 10, 2023, establishing the Carbon Border Adjustment Mechanism (CBAM), came into force in 2023. However, the CBAM is being implemented gradually and will be fully operational starting in 2026.

With little time left to implement the new data collection and aggregation processes for CO2 emissions, we urge you to prioritize this in your planning. This is particularly important, as the reporting requirement applies to transactions starting from just 150 EUR.

6. EU Deforestation Regulation

By the end of 2025, Regulation 2023/1115 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010 will come into effect. Regulation introduces new obligations for businesses regarding placing products associated with deforestation and forest degradation on the market. The examples of products covered by the Regulation include timber, soy, palm oil, coffee, cocoa, and products derived from them, into the EU market or their export.

Businesses will be required to ensure that their products do not contribute to deforestation. They must implement due diligence procedures, including tracing the origin of raw materials, conducting risk assessments, and documenting compliance with regulations. Failure to comply with the new requirements may result in sanctions, including the prohibition of placing products on the EU market.

7. Changes in municipal wastewater treatment

On January 1, 2025, Directive 2024/3019 of November 27, 2024, concerning urban wastewater treatment came into force. The Directive imposes stricter requirements, including secondary treatment of municipal wastewater in all agglomerations with a population equivalent of 1000 PE or more by 2035, and tertiary treatment (removal of nitrogen and phosphorus) in wastewater treatment plants serving 150,000 PE or more by 2039.

Additionally, starting in 2033, a fourth level of treatment will be introduced, which will focus on removing microcontaminants from municipal wastewater (the percentage of microcontaminants removed will increase in the following years). To cover the costs of this treatment, extended producer responsibility, in the form of financial contributions, will be imposed on manufacturers of pharmaceutical and cosmetic products.

8. Non-financial reporting (CSRD)

On December 12, 2024, the President of the Republic of Poland signed the Act of December 6, 2024, amending the Accounting Act, the Act on Statutory Auditors, Audit Firms, and Public Oversight, and certain other laws, implementing the CSRD Directive into Polish law.

The new sustainability reporting requirements will be gradually implemented over the coming years. In 2024, they applied only to entities already subjected to financial reporting requirements based on the NFRD Directive, i.e., the largest public companies. The Act raises the size criteria for micro and small enterprises, meaning that starting in 2025, the reporting requirements will apply to additional entities that previously had no such obligations.

9. Launch of the deposit return system (SUP Directive and amendments to the Packaging and Packaging Waste Management Act and certain other laws)

On November 21, 2024, the Act of November 21, 2024, amending the Polish Packaging and Packaging Waste Management Act and certain other laws was signed. This legislation provides clarity on the operation of the deposit system. The requirement to implement this system was set by Directive 2019/904, which focuses on reducing the environmental impact of certain plastic products (SUP Directive). According to the Act, the deposit system in Poland will take effect on October 1, 2025.

The deposit system is designed to encourage recycling and promote the reuse of packaging. It will function through a partnership between beverage companies, retailers selling products in packaging, and a coordinating entity. Participating companies will be required to label packaging with special markings to indicate inclusion in the system and specify the deposit amount.

The amendment also brings changes to the logistics of reverse collection and packaging waste management. Entities that collect packaging under the deposit system but are not primarily engaged in waste management will be exempt from certain permit requirements. This change is intended to simplify logistics and make the deposit system more accessible for consumers. Additionally, the Act allows commercial entities to partner with specialized waste collection organizations.

10. General Product Safety Regulation (GPSR)

On December 13, 2024, the General Product Safety Regulation (GPSR) came into effect, replacing the General Product Safety Directive and the Directive on Products Imitating Food. This Regulation aims to ensure that all consumer products available on the EU market are safe. It requires the implementation of appropriate procedures, including internal risk assessments and the creation and updating of relevant technical documentation.

The GPSR applies to all non-food products, whether new, used, repaired, or refurbished, except for products regulated by other specific directives. It covers all entities placing products on the EU market, including manufacturers, importers, and distributors.

The Regulation introduces several obligations, including:

• Transparency regarding product origin
• Compliance with safety requirements
• Removal of unsafe products from the market

Additionally, the GPSR covers distance selling, ensuring that products sold online or through other remote channels also meet safety standards.

The GPSR also provides for new sanctions for businesses in case of violations, as well as legal protection measures for consumers. If a product is deemed unsafe, the manufacturer must offer consumers at least two of the following three solutions:

• Repair the recalled product
• Offer a safe alternative of the same value and quality
• Refund the product’s value, not less than the price paid by the consumer

In Poland, the GPSR will be complemented by a new Product Safety Act, which is currently in the Government Legislative Process. The current version of the draft mentions sanctions for manufacturers. Placing a product that does not meet general safety requirements on the market is subjected to a penalty of up to PLN 1,000,000, while failure to comply with the obligations imposed on manufacturers may result in a fine ranging from PLN 40,000 to PLN 200,000, depending on the violation type.

11. Right to Repair (R2R)

Directive 2024/1799, also known as the Right to Repair (R2R) Directive, published on 10 July 2024, aims to provide consumers with broader warranties regarding the repair of products both during and after the expiry of the warranty period, and to reduce the environmental impact of mass consumption. It is applicable to manufacturers, who are obliged to enable consumers to repair their goods. R2R is currently applicable to certain categories of products, which include large household appliances (washing machines, washer-dryers, dishwashers, tumble dryers), refrigeration appliances, electronic equipment (mobile phones, slate computers, electronic displays, servers and data storage products), hoovers, welding equipment and goods containing LMT batteries.

In addition to warranties, consumers will have access to a new set of rights and tools that will make repair an easy and accessible option:

• The right for consumers to request manufacturers to repair products that are technically repairable under EU law—such as washing machines or televisions. This will ensure that consumers always have someone to turn to when they choose to repair their products and will also encourage manufacturers to develop more sustainable business models.
• The obligation for manufacturers to inform consumers about which products they must repair themselves.
• An online repair platform that will connect consumers with workshops and sellers of refurbished goods in their area. The platform will allow users to search by location and quality standards, helping consumers find attractive offers and increasing the visibility of workshops.
• A European Repair Information Form, which consumers can request from any workshop, ensuring transparency regarding repair conditions and costs, as well as facilitating comparison of repair offers.
• A European quality standard for repair services will be developed to help consumers identify workshops that commit to higher quality. This "easy repair" standard will be open to all workshops across the EU that wish to commit to following minimum quality standards, such as based on product durability or availability.

The R2R Directive also requires member states to take at least one measure to promote repairs, for example in the form of repair vouchers. In Poland, consultations on the implementation of the R2R Directive, led by the Office of Competition and Consumer Protection, have just concluded.

12. Regulation on packaging and packaging waste (PPWR)

The Regulation on Packaging and Packaging Waste (PPWR) was adopted on December 16, 2024. This Regulation is applicable to packaging producers and covers the entire life cycle of packaging. Its aim is to reduce packaging waste by establishing mandatory reuse targets, limiting certain types of single-use packaging, and requiring companies to minimize the amount of packaging used.

The Regulation sets minimum recycling percentage targets for packaging products and introduces new rules concerning single-use plastic packaging (for products such as packaged fruits and vegetables, food and beverages consumed in hotels, bars, and restaurants, cosmetics, and plastic bags).

For example, it will be prohibited to use packaging that creates the impression of a larger product volume than it actually contains, including packaging with double walls, false bottoms, and unnecessary layers.

The PPWR also imposes restrictions on certain packaging formats. The following items will be prohibited:

• Films used for grouping products and shrink film, used at points of sale to group products sold in bottles, cans, metal boxes, jars, cups, and packs, designed as convenience packaging to allow or encourage consumers to purchase more than one item.
• Nets, bags, trays, and containers made of plastic, used as single-use packaging for storing packaged fresh fruits and vegetables weighing less than 1.5 kg.
• Trays, disposable plates, and cups, bags, boxes used in the HoReCa sector for on-site food consumption, single-use containers for sauces, jams, and coffee creamers.
• Single-use packaging for cosmetics, personal hygiene products, and toiletries used in the accommodation sector.
• Very light plastic shopping bags.

These measures aim to reduce unnecessary packaging waste and promote more sustainable alternatives across industries.

13. Cross-border shipment of waste

On May 20, 2024, the new EU Regulation 2024/1157, governing the rules for cross-border waste movement, came into force, replacing the previous Regulation (EC) No. 1013/2006. The new provisions prohibit the export of hazardous waste and certain plastics to non-OECD countries and require exporters to conduct audits at foreign waste management facilities. Within the EU, a ban has been introduced on the movement of waste intended for disposal, except in cases where specific procedures are followed, and exemptions have been provided for waste intended for laboratory testing with a weight of up to 250 kg.

14. Amendments to the Basel Convention on the Control of Transboundary Movements and Disposal of Hazardous Wastes

The EU Delegated Acts 2024/3229 and 2024/3230, aligning regulations with the amendments to the Basel Convention, came into force on January 9, 2025. The new regulations introduce new codes for hazardous wastes waste and allow the continued use of codes GC010 and GC020 for intra-EU shipments until December 31, 2026. Waste classified under these codes will be subject to a simplified notification procedure (contained in Annex VII).

15. PFAS: Planned Restriction on the Production, Marketing, and Use of "Forever Chemicals" in the EU

The European Commission plans to introduce a ban or significant restrictions on the production, marketing, and use of polyfluoroalkyl substances (PFAS) in the EU, thereby eliminating their use in consumer products. These changes are linked to the proven harmful effects of these substances on health and the environment.

The ban will likely not apply to products where the use of PFAS is essential (“essential use criteria”). A list of such products is currently being developed by the Commission, so the new regulations may come into force as early as next year.

16. REACH Revision

The revision of the Regulation on the Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) is scheduled for 2025, with the goal of enhancing chemical safety. The updated rules will impose stricter controls on hazardous substances, including PFAS. Instead of authorizing individual substances, broader restrictions will be introduced for entire categories of chemicals. Additionally, new requirements will be put in place to improve the identification of chemicals and better assess their impact on health and the environment.

17. Regulation on Batteries and Waste Batteries

In 2023, Regulation 2023/1542 on Batteries and Waste Batteries came into effect, directly applicable across all EU member states. Since the Regulation is being implemented gradually, starting in 2025, battery producers with annual revenues exceeding 40 million euros will be required to establish due diligence procedures. Under the Regulation, these producers will need to assess the environmental and social impacts of their supply chains for batteries containing cobalt, lithium, nickel, and graphite. They will also need to publish annual reports and undergo audits.

Additionally, by the end of 2025, recycling efficiency for nickel-cadmium batteries must reach 80%, and 50% for other waste batteries.

On January 10, 2025, the European Commission published guidelines for implementing the Regulation. These guidelines clarify the process for replacing portable batteries and LMT batteries, which are commonly found in consumer electronics. This is also relevant in the context of the Right to Repair Directive and product repair.

18. Environmental Crime Directive

The Directive of the European Parliament and the Council (EU) 2024/1203 of April 11, 2024, on the protection of the environment through criminal law, which replaces Directives 2008/99/EC and 2009/123/EC, entered into force on May 20, 2024. The Directive introduces new categories of environmental crimes, including illegal water extraction, significant violations of EU regulations regarding chemicals or mercury, and strengthens sanctions for severe environmental damage.

The Directive also provides for a penalty system that includes prison sentences and fines up to 40 million euros, depending on the turnover of the offender, which should be determined by each EU Member State.

19. The Critical Raw Materials Act (CRMA)

Regulation 2024/1252 of April 11, 2024, on establishing a framework to ensure safe and sustainable supply of critical raw materials, and amending Regulations (EU) No. 168/2013, (EU) 2018/858, (EU) 2018/1724, and (EU) 2019/1020, aims to ensure sustainable supplies of key raw materials essential for Europe's economy. These materials are particularly important in sectors such as renewable energy, digitalization, aviation, and defense.

In addition to introducing an updated list of critical raw materials, the Regulation streamlines the permitting procedures for mining, strengthens supply chain monitoring, and implements risk management measures for key industries. A Critical Raw Materials Council has also been established under the Regulation, tasked with overseeing the implementation of these provisions and fostering international cooperation in their execution.

20. ‘Green Claims Directive’ project

In 2023, a draft Directive on Environmental Claims (Green Claims) was published, aiming to give consumers confidence that products marketed as environmentally friendly actually live up to their claims. The draft establishes minimum requirements for environmental claims that businesses must meet and allows consumer organizations to take legal action to protect collective consumer interests. While the Directive is still under review, its importance is growing considering broader regulatory changes and the strengthening of consumer rights across the EU market.