EHS & ESG trends in Europe

Ongoing EHS and ESG regulatory developments are having a significant impact on the operations, practices, products, and processes of multinational companies. This article draws attention to the top regulatory developments in EHS and ESG in Europe, impacting the environment, worker health and safety, governance, and artificial intelligence. 

Watch the full webinar for an in-depth overview of the trends across Europe, the United States, and Asia-Pacific regions, from our Enhesa experts:  

• Rikke Vessia, Senior EHS and Sustainability Regulatory Consultant 

• Owais Talib Syed, EHS and Sustainability Regulatory Consultant 

• Jin Wang, Subject Matter Expert in Sustainability and ESG 

• Jordan Stone, our Regional Expert for the United States

EHS and ESG trends in the environment

Business operations and practices have a huge impact on the health of the environment, with harmful chemicals, poor waste management practices, and long-lasting materials polluting the land, air, and waterways. 

Below we detail the dominant regulation in Europe, as discussed by Rikke Vessia, aiming to combat environmental damage caused by ineffective recycling schemes and plastic packaging – the PPWR.
 

Packaging and Packaging Waste Regulation 

The EU Packaging and Packaging Waste Regulation (PPWR) entered into force on 11 February 2025, and will generally be applicable from 12 August 2026 (though there are some longer transition periods for certain requirements). 

The PPWR establishes significant changes to the regulatory framework for packaging in the EU, with the primary aim to reduce the amount of packaging waste generated in the EU and decrease the use of primary raw materials in products. Rikke highlighted the main features of the PPWR that businesses should be aware of, as it may affect their processes and distribution.
 

1. Wider scope 

The PPWR is broader in scope than previous EU packaging regulations, applying to all types of packaging (including packaged products) and covering the entire packaging lifecycle from its initial design to waste management and disposal. 

The PPWR replaces the 1994 Packaging and Packaging Waste Directive (PPWD) to harmonize the regulatory framework across EU Member States. As a Regulation, directly applicable in all Member states, it ensures a more streamlined approach and reduces national discrepancies, for example, for Extended Producer Responsibility (EPR) schemes.
 

2. Design 

The PPWR introduces stricter obligations for the design of packaging, such as: 

• From August 2026, all packaging must be manufactured to minimize the presence and concentration of substances of concern in the material, components, and waste management outcomes — in particular, restrictions on PFAS in food contact packaging is introduced (including ensuring that the concentration of any PFAS is below 25 parts per billion (ppb) 

• From August 2030, packaging must be recyclable within the performance grades A, B, or C as outlined in the PPWR, with a minimum percentage of recycled content required in plastic packaging (for example, 30% recycled content for contact-sensitive polyethylene terephthalate (PET) packaging)  

• From August 2030, packaging must be designed specifically to minimize its weight and volume to the minimum necessary to maintain functionality 

As of the PPWR’s implementation, companies must also fulfil prescribed reuse targets for transport and grouped packaging from January 2030 (including ensuring that 40% of used transport packaging is reusable within a reuse system. These targets are set to increase from January 2040.
 

3. Labeling 

From August 2028, companies must ensure that all packaging being placed on the EU market is marked with a harmonized label containing information on its material composition so consumers can effectively organize packaging for proper disposal or recycling. 

Additionally, plastic packaging must bear a label showing the share of recycled content.
 

4. Extended Producer Responsibility 

From August 2026, the PPWR mandates that Member States set up a national register for producers. Packaging producers must then register in the location where they make packaging available for the first time or unpack products without being their end-user. 

Furthermore, packaging producers must provide annual reports (on 1 June) on, among other responsibilities, the quantities of packaging placed on the market for the preceding year. 

The PPWR is introducing stricter sustainability, reusability, composition, registration, and EPR requirements for packaging that will undoubtedly affect companies producing, designing, and labeling packaging products for the EU market. Looking ahead, Rikke informs us that we’re expecting the EU to publish recycled content calculation methods in 2026 and standards for packaging minimization and reusability in 2027.

EHS and ESG trends in worker health and safety

Occupational health and safety is skyrocketing in the regulatory space as more employers become responsible for the safety of their employees in the workplace, including protection from hazardous chemical exposure, high temperatures, and harassment.  

In Europe, Rikke highlights the EU’s attention to occupational exposure limits and the EU’s proposed strategy on gender equality.
 

Occupational exposure limits 

There are currently two upcoming developments concerning occupational exposure limits in the EU: 

• Directive (EU) 2024/869 amending the Carcinogenic, Mutagenic and Reprotoxic Substances Directive 

• Directive (EU) 2023/2668 amending the Asbestos at Work Directive
   

Directive (EU) 2024/869 

Directive (EU) 2024/869 will require companies to comply with stricter occupational exposure limits and medical surveillance obligations for lead, its inorganic compounds, and diisocyanates, once the Directive is transposed in the Member States’ national legislation. The deadline for transposition is 9 April 2026.
 

Directive (EU) 2023/2668 

Directive (EU) 2023/2668 will mandate employers of any workers exposed, or at risk of exposure, to asbestos to comply with stricter preventative and protection measures, as well as strengthened training requirements. 

For example, employers will have to obtain special permits for asbestos removal and identify if asbestos is already present in buildings before demolition, maintenance, or renovation work can commence. 

This Directive will have to be transposed by EU Member States by 21 December 2025.

EHS and ESG trends in governance

ESG remains a primary focus in EU legislation, particularly concerning environmental and sustainability reporting requirements in the region. The European Commission has recently published its Omnibus simplification package in an effort to streamline reporting obligations.
 

Omnibus I Simplification 

The Omnibus I package establishes three main initiatives: 

1.EU ‘Stop the Clock’ Directive to delay obligations under the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) 

For large companies that were initially covered by the CSRD and CSDDD, this new ‘Stop the Clock’ directive delays these obligations by two years (CSRD) and one year (CSDDD).  

EU Member States will have to transpose the new directive by the end of 2025. 

2. Proposed “Content Directive” simplifying the CSRD, CSDDD, and the Taxonomy Regulation 

This proposal aims to simplify the disclosure obligations under the CSRD, CSDDD, and EU Taxonomy Regulation. For CSDDD, for example, it proposes removing the obligation to assess adverse impacts on indirect business partners and infringement systems. 

3. Proposed simplifying the Carbon Border Adjustment (CBAM) Regulation 

Thirdly, the proposed simplification of the CBAM Regulation would ease carbon accounting and reporting obligations on companies covered under this law.
 

European Deforestation Regulation 

The long-awaited European Deforestation Regulation (EUDR) has been supplemented with guidance documents to assist companies in complying with the due diligence obligations therein.  

Under the EUDR, companies placing products containing relevant commodities (including cattle, cocoa, coffee, palm oil, soya, and wood) are subject to due diligence obligations to ensure that these products are deforestation-free. After a one-year delay, the EUDR is applicable from 30 December 2025 for large and medium enterprises and 30 June 2026 for micro and small enterprises. 

In April 2025, the European Commission published updated EUDR guidance documents and a draft delegated Regulation that, in particular, simplifies obligations for companies covered by the EUDR. For example, it has been clarified that companies can reuse existing due diligence statements when re-importing goods that were previously on the EU market. The adoption of EUDR guidance documents showcases a different approach to simplification of due diligence obligations.

EHS and ESG trends in artificial intelligence

Artificial intelligence (AI) is soaring to the forefront of EHS and ESG regulatory trends. The technology is being leveraged across compliance and product development teams to help companies inform their strategy and make safer, more sustainable choices.
 

EU’s AI Act 

The EU’s Artificial Intelligence Act marks the first piece of legislation in the world to regulate AI. It aims to ensure safe, ethical and transparent use of AI by establishing a risk-based classification of AI systems.  

The EU’s AI Act entered into force in August 2024 and will be fully applicable in August 2026, with some exceptions (for example, prohibitions and AI literacy obligations apply from February 2025, and the requirements for high-risk AI systems embedded in products have an extended transition period until August 2027).    

Under the Act, AI system deployers and producers (including producers of products provided with AI systems) must comply with requirements for the safe and ethical use of AI systems depending on their risk-based classification. 

For example, employers using AI systems must take measures to ensure sufficient AI literacy among their staff and, as of August 2027, comply with requirements to ensure the safe and ethical use of high-risk AI systems (such as systems to make decisions affecting work-related relationships).