Countdown to 2024: Reaching sustainability goals in the EU market

The countdown to the next European elections, planned for May 2024, has started, giving EU institutions a bit more than a year to meet the commitments set out in the European Green Deal in 2020 and to implement the ambitious objectives set out in the EU’s Circular Economy Action Plan. The Swedish Presidency of the Council of the EU, leading the work of EU Member States for six months until 30th June 2023, has made the green transition of the European economy a priority in its programme. As a result, European institutions will be busy working on a number of policies that will have an impact on the design, disposal, repairability, and labelling of all products sold in the EU market. Here is a breakdown of the main legislative files currently undergoing scrutiny.

What sustainability policy should businesses keep an eye on?

A key ambition of the European Union is to transition to sustainable and circular production, consumption, and business models with the aim to create a greener, more competitive market, that is resistant to global shocks. As one of the building blocks of the European Green Deal, the European Commission mapped out a plan to transform the EU market into a circular one. By adopting the Circular Economy Action Plan in March 2020, the EU pledged to ensure that the resources used in the EU are kept for as long as possible by both maintaining value and by limiting the creation of waste.  To implement these changes, the European Commission presented and will present various legislative initiatives, which could enable change from linear models to circular ones.

New Ecodesign requirements for Sustainable Products

First and foremost, the proposal for a Regulation on Ecodesign for Sustainable Products which was presented by the European Commission in March 2022, aims to make all products available on the EU market more durable, repairable, reusable, recyclable, easier to maintain, energy- and resource-efficient. It essentially extends ecodesign requirements for energy products to all products available on the EU market, including textiles, construction, and electronics. Under this regulation, all products will have a Digital Products Passport which would include information for consumers on the environmental impact of their purchases. This information will make it easier to repair or recycle products. The new rules will also foresee the introduction of measures to ban the destruction of unsold products, a practice that is very common in the textile or technology industries which releases new lines or devises every season or year. Organisations from a variety of sectors including the cosmetic and textile sectors have an opportunity to provide their input on what type of products and measures must be prioritised until 12th May 2023. Currently, the initiative prioritises intermediary products such as plastic, glass, paper, and chemicals, as well as provisions for durability, recyclability, and post-consumer recycled content, also known as used and recycled finished goods.

Green claims and empowering consumers in the green transition

As part of the Circular Economy Action Plan, the European Commission also presented new rules to empower consumers in the green transition. The new rules will ensure consumers are provided with information on how long a product is designed to last and on its repairability. The new proposal will also ban the use of generic environmental claims such as “green product” or “eco-friendly”. Products will no longer be able to display environmental concerns about the entire product when it only concerns a certain aspect. The European Commission is also due to present a proposal for a Directive on green claims on 22nd March 2023. This proposal is expected to give the mandate to EU national authorities to penalise companies making false claims. Similarly, companies sharing the positive impact of their product on the environment and climate will also be required to be transparent about their detrimental effects.

New harmonised rules on packaging and packaging waste

In the last quarter of 2022, the European Commission published a proposal to revise the Packaging and Packaging Waste Directive. A key feature of the proposal is the plan to turn the Directive into a Regulation, which means the obligations that organisations will have to comply with will be directly applicable in all Member States without the need to transpose it through national rules since the entry into force of the legislation. Under these new rules, organisations will be required to prevent the generation of packaging waste by reducing it in quantity, restricting unnecessary packaging, and promoting reusable and refillable packaging solutions. All packaging present in the internal market will have to be recyclable by 2030. The new rules will also require packaging to be labelled to guide consumers on how to recycle properly. Stakeholders are also invited to provide their views and evidence on the impact of the proposal on their sector via a public consultation open until 17th April 2023.

Food for thought FMCG organisations

Sustainability and green transition are now very much at the forefront of any policy change and are entirely multi-layered and cross-sectoral, meaning they have a cascading effect on a number of organisations operating in various sectors. The goal of these policies is two-fold: 1) ensuring consumers are able to become actors in the green transition by informing them on the most sustainable choice but also 2) increasing businesses’ responsibility in regard to their impact on the planet.

The ambition of European legislators is clear, however, pressure from Member States will make it hard for EU policymakers to easily agree on targets that businesses will have to comply with. Additionally, policymakers may set sustainability standards that are either too vague to police unsustainable practices or instead are too exclusive to allow for innovative green solutions to flourish. While all stakeholders agree that policymaking should be based on scientific evidence, the whole potential of science and innovation is yet to be uncovered. 

Looking at the environmental impact of a product has already become key to preparing for future regulatory changes. The objective of circularity is now wide-ranging across many European policies and this is a prime opportunity for organisations offering innovative and sustainable solutions to be at the forefront of these changes.

How we can support

The Whitehouse Communications team has extensive experience in sustainability matters that are at the forefront of the EU’s political agenda. We provide public affairs advice and political analysis to a wide range of clients who seek to engage with policymakers and member states of the European Union and beyond. With more than a year to go to the next European elections and a packed agenda for legislators to finalise, there are still plenty of opportunities for organisations to engage and shape policy. To learn more about how to get involved in these debates, please email Laura Contin (