Four instruments turned supply-chain knowledge into a legal duty

Amends the Unfair Commercial Practices Directive (2005/29/EC) to deal specifically with environmental claims. It converts several practices that previously required case-by-case assessment into outright prohibitions, listed in Annex I, meaning they are unfair in all circumstances, with no balancing test available.

Bans outright

Generic environmental claims (“eco-friendly”, “green”, “climate friendly”), where excellence in environmental performance cannot be demonstrated; claims that a product has neutral, reduced or positive environmental impact based on emissions offsetting; displaying a sustainability label that isn’t based on a certification scheme or established by public authorities.

Shifts

The burden of substantiation onto the trader making the claim.

Who is affected

Any trader making environmental claims to consumers in the EU, regardless of company size.

Why it bites

Enforcement against greenwashing was already producing multi-million-euro fines under the old framework. The per-se bans remove the arguments that previously made those cases contestable.

Reputation Index screens claims against this directive →

Requires in-scope companies to report sustainability performance using the European Sustainability Reporting Standards, including material information about their value chain, on a double-materiality basis. The first CSRD-compliant reports were published in 2025. Revised, shorter standards apply from financial year 2027 (Delegated Regulation (EU) 2026/1563).

Scope after Omnibus I

Directive (EU) 2026/470 limits mandatory reporting to EU companies with more than 1,000 employees and more than €450 million turnover, from financial year 2027, and to large non-EU groups from 2028. Listed SMEs are out of scope. The reporting duties themselves were not withdrawn.

The value-chain question

A company in scope reports on material value-chain information, so it asks suppliers that are not in scope for data. A value-chain cap now limits what it may request from partners with 1,000 or fewer employees.

What it demands operationally

Evidence about counterparties that is current, consistent, and traceable enough to survive assurance.

Goes beyond disclosure to duty. It requires the largest companies to identify, prevent and mitigate adverse environmental and human-rights impacts in their chain of activities, using a risk-based approach.

The shift

From “report what you know” to “find out, and act on it”.

Risk-based

Companies must prioritise where adverse impacts are most likely and most severe, which presupposes the ability to assess a chain systematically rather than anecdotally.

After Omnibus I

Applies from 26 July 2029 to companies with more than 5,000 employees and more than €1.5 billion turnover. The EU-wide civil-liability regime and the climate-transition-plan duty were removed, and fines are capped at 3% of worldwide turnover. The due-diligence duty itself remains.

Will require product groups named in delegated acts to carry a digital record of information set for each group, such as materials and composition. The EU registry has been live since July 2026; the first passports become mandatory for certain batteries on 18 February 2027, and steel and textiles are among the first product groups planned. It makes product data travel with the product rather than being produced on request.

What it presupposes

That a manufacturer actually knows its upstream chain, the same knowledge gap the other instruments expose, expressed as a data requirement.

Connection to circularity

Reuse, repair and recycling models cannot be designed without knowing where materials came from and where they end up.