While the Brussels bubble may have deflated and business activity slowed during a very hot European summer, the regulatory calendar remained surprisingly busy. July and August brought several measures into force or application, alongside new guidance for industry.
Although many of these developments originated in Europe, their impact reaches much further. Products placed on the EU market often rely on materials, components and emissions data from suppliers around the world. Here are six developments worth catching up on.
| Development | Regulatory update | Next milestone | Who it affects most |
|---|---|---|---|
| DPP standards and Registry | References to six harmonised DPP standards were published; DPP Registry went live. | In effect now | Anyone preparing a digital product passport |
| Battery Passport guidance | 71 data points mapped by battery category. | 18 February 2027 | EV, light means of transport and industrial battery producers and their suppliers |
| Packaging and Packaging Waste Regulation | PPWR started to apply on 12 August 2026, including immediate PFAS restrictions for food-contact packaging. | From 2028: harmonised labelling. From 2030: recyclability, recycled-content, minimisation and reuse requirements. | Packaging manufacturers, suppliers, converters and brand owners |
| End-of-Life Vehicles Regulation | Entered into force; introduces the Digital Circularity Vehicle Passport and recycled-content targets. | 1 September 2028: general application. From 2032: passport and recycled plastic content. | Vehicle manufacturers and their material and component suppliers |
| CBAM | The Commission published guidance on embedded-emissions calculations, sector requirements, verification and accreditation. | January 2027: submission of the first verification reports for the definitive regime. | EU importers of cement, hydrogen, fertilisers, iron and steel, aluminium and electricity |
| China export-control reporting | New reporting mechanism for suspected export-control violations. | In effect since 1 July 2026 | Supply chains dependent on Chinese rare earths and strategic minerals |
1. Key parts of the EU Digital Product Passport system fell into place
Since the EU’s Digital Product Passport (DPP) journey began in 2024 with the entry into force of the ESPR, this July saw several key elements needed to support its rollout fall into place.
In the space of one week, the Commission adopted Implementing Decision (EU) 2026/1736, publishing the references to six harmonised DPP standards. Developed through the European standardisation process by CEN, CENELEC and ETSI, with CEN/CENELEC JTC 24 leading the horizontal DPP work, they cover unique identifiers, interoperability, data carriers, APIs, data-exchange protocols and decentralised data storage.
This was followed by the official launch of the Digital Product Passport Registry. Think of it as the EU’s check-in point for DPPs: the full product data remains decentralised, while the Registry records the identifiers and metadata needed to confirm that a passport exists and allow authorities to check it. Connecting to the Registry is therefore becoming part of DPP preparation, rather than a technical detail to address when the first deadlines arrive.
The ESPR also made itself felt elsewhere. From 19 July, large companies are prohibited from destroying unsold clothing, clothing accessories and footwear, except under specified circumstances. Businesses relying on an exemption must provide supporting evidence, publish annual information on discarded products and retain the relevant records for five years.
With the European Product Act next on the Commission’s agenda, these developments show how closely product information, traceability and market access are becoming connected. Businesses placing covered products on the EU market, wherever they are based, can now start mapping which data they hold, what must come from suppliers and how it will connect to their passport systems.
For those looking for a broader overview, a new central Commission DPP webpage is also available, bringing together guidance and the indicative rollout across batteries, iron and steel, textiles, aluminium, tyres, construction products, furniture and other product groups.
If you are new to how passports work in practice, our explainer on digital product passports covers the basics.
2. Battery Passport guidance became more concrete
Still with the DPP in mind, batteries, the first product group with a mandated passport from 18 February 2027, now have updated Battery Passport data-point guidance.
Covering electric vehicle batteries, light means of transport batteries and industrial batteries above 2 kWh, the guidance maps 71 data points and indicates, for each battery category, whether they are mandatory, optional, applicable only in certain circumstances or not required to be filled or displayed as of February 2027. Our guide to EU Battery Passport requirements provides a broader overview of the scope, responsibilities, data requirements and implementation timeline.
The responsibility for the passport rests with the economic operator placing the finished battery on the EU market, but much of the required information will originate with cell, component and material suppliers across multiple countries. With the deadline only a few months away, the time to identify those data owners and begin connecting the required information to passport systems is now.
3. The Packaging and Packaging Waste Regulation started to apply
From 12 August, the Packaging and Packaging Waste Regulation began applying across the EU, replacing a fragmented national landscape with one framework covering the full packaging lifecycle. The Regulation addresses packaging composition, safety, minimisation, recyclability, recycled content and reuse. One of its first immediate effects was the restriction of PFAS above defined limits in food-contact packaging.
Other major requirements will apply progressively over the coming years. Meeting them will depend on knowing more about the packaging placed on the market: what it contains, how much material is used, where that material comes from and what happens to it after use.
For global packaging suppliers, converters and brands, that information will often need to travel through several tiers before reaching the business responsible for the finished product. Traceability will be needed not only to meet the requirements themselves, but also to support recycled-content, recyclability and reuse claims with evidence.
4. The new End-of-Life Vehicles Regulation entered into force
On 13 August, the new End-of-Life Vehicles Regulation entered into force, replacing the previous Directive and bringing vehicle design, production and end-of-life treatment under one directly applicable framework.
From 2032, passenger cars and light commercial vehicles placed on the EU market will If you are new to how passports work in practicerequire a Digital Circularity Vehicle Passport. It will bring together information on the removal and replacement of parts, substances contained in certain components, recycled-content declarations and the vehicle’s official spare-parts catalogue, all in one place.
The Regulation also introduces recycled-plastic content targets and prepares the ground for future requirements covering steel, aluminium and other materials. For plastic obtained through non-mechanical recycling, recycled content will be calculated using mass-balance accounting.
In other words, more recycled material will need to enter vehicles, but the evidence must travel with it. Vehicle manufacturers will increasingly depend on traceable information from their global material and component suppliers to support both the passport and recycled-content declarations. We explored the Regulation in greater detail in this dedicated article.
5. CBAM guidance clarified the definitive regime
In mid-August, the Commission published ten guidance documents covering embedded-emissions calculations and sector-specific requirements for cement, hydrogen, fertilisers, iron and steel, aluminium and electricity.
Ten days later, separate guidance for verifiers and national accreditation bodies clarified the accreditation process, access to the CBAM Registry and the submission of verification reports from January 2027.
The guidance arrived while CBAM itself is under revision, with a possible extension to selected downstream goods and stronger anti-circumvention rules under discussion.
For goods already covered, however, the equation is fairly simple: actual emissions values require evidence that can be traced back to the non-EU installation where the goods were produced and withstand independent verification. Importers may submit the declaration, but the underlying data starts with producers abroad. With the first verification cycle approaching, monitoring plans and emissions-data flows cannot be left until reporting season.
6. China strengthened enforcement of strategic-mineral export controls
The EU was not the only place where regulatory changes occurred over summer. On 1 July, a new Chinese Ministry of Commerce reporting mechanism for suspected violations of strategic-mineral dual-use export controls took effect.
The mechanism covers unlicensed exports, shipments exceeding licence conditions, diversion through third countries, attempts to avoid controls by splitting goods into components and illegal transfers of controlled technologies. This is particularly relevant for rare earths, strategic minerals and critical raw materials, which feed into magnets, batteries, electronics and other key technologies. Compliance increasingly depends on knowing what is being exported, under which licence, through which route and to which final recipient.
For global supply chains dependent on Chinese materials, connecting origin, destination and end-use information is becoming essential not only for managing trade risk, but also for anticipating disruptions and strengthening supply-chain resilience.
Beyond the summer headlines
These six developments do not ask for the same information, nor do they place responsibility on the same actor. Yet they often reach into the same global supply chain. The business issuing a passport, declaring embedded emissions or substantiating recycled content will depend on data held by material producers, component suppliers, manufacturing sites and recyclers across different countries.
Preparing separately for every regulation would mean asking those partners for overlapping information again and again, then rebuilding the process each time the requirements change. The more practical route is to treat traceability as one system rather than six separate compliance projects. That is what Circularise is built for: one platform for traceability that connects data back to its original source, links each claim to the evidence behind it, and shares only what a given customer, authority or verifier is entitled to see.
The next step is not another regulatory reading list. It is choosing one product or material flow, tracing the required information back to its source and testing whether it can move reliably across the value chain without exposing commercially sensitive data. If you would like to work through that for one of your own product lines, our team is happy to help.