Five EU Policy Developments Product Manufacturers Need to Have on Their Radar in 2026

EU sustainability policy is entering a new phase. 

After several years of major legislative activity, many initiatives are now moving from adoption to implementation. For product manufacturers, this means the policy landscape is becoming more practical — and directly affecting their product design, materials, packaging, claims, water, biodiversity and end-of-use systems. 

Here are five EU policy developments product manufacturers should have on their radar in 2026. 

1. Packaging becomes part of product design 

Packaging is becoming a product design priority. 

The Packaging and Packaging Waste Regulation introduces harmonised EU requirements across the packaging lifecycle, including recyclability, recycled content, reuse, labelling and restrictions on certain substances. 

For brands and manufacturers, the practical message is clear: packaging choices increasingly influence circular product performance. 

Take a cosmetics brand. The bottle, pump, cap, label and carton all affect recyclability, material compatibility and the ability to keep packaging materials in circulation. A packaging redesign may require input from product development, procurement, marketing, compliance and sustainability teams. 

In Cradle to Cradle Certified®, packaging is assessed as part of the product, with dedicated certification also available for packaging products. This helps companies address material health, circularity and design choices from the start. 

2. Environmental claims must be verified 

Sustainability claims are becoming a matter of proof. 

The Empowering Consumers for the Green Transition Directive introduces clearer rules on environmental claims, sustainability labels, durability information and repairability. 

For companies selling products in the EU, broad claims such as “green”, “eco-friendly” or “environmentally friendly” will come under much stricter scrutiny. More specific claims, such as “recyclable”, “durable” or “made with recycled materials”, will also need to be accurate, clear and supported by robust evidence. 

Italy has already transposed the Directive. In Italy, the AGCM has also issued fines for misleading sustainability communication, including environmental and social responsibility claims. 

Denmark offers another important reference point. The Danish Consumer Ombudsman has been setting a high bar for environmental marketing for years, with detailed guidance on how companies should document green claims. This makes Denmark a useful example of the direction now becoming more harmonised across the EU. 

The trend extends beyond the EU. In the UK, the Advertising Standards Authority has banned ads from fashion companies over misleading recycled-content claims, as well as earlier ads using broad sustainability language without adequate substantiation. 

The message for companies is practical: sustainability claims need to be built on evidence. 

Cradle to Cradle Certified® has been recognised for more than a decade as one of the world’s most robust and holistic product sustainability standards. Companies with verified product certification can communicate from a stronger foundation: with clear evidence, structured data and substantiated performance. 

3. Fashion inventory enters the circularity conversation 

For fashion companies, circularity is becoming an inventory issue as well as a design issue. 

Under the Ecodesign for Sustainable Products Regulation, the EU is introducing rules to prevent the destruction of unsold apparel, clothing accessories and footwear. 

For brands, this puts greater focus on what happens when products do not sell. Unsold stock may need credible routes into reuse, resale, donation, repair or recycling. 

It also puts pressure on decisions made much earlier: assortment planning, material choices, durability, repair potential and recovery pathways. 

For example, a fashion brand with large seasonal overstock may need stronger systems for resale, take-back, repair or donation. A company designing products with more durable materials, clearer fibre composition and better recovery routes will be better placed to retain value when products do not move through the original sales channel. 

This connects to Product Circularity in Cradle to Cradle Certified®, which provides a methodology for designing products and systems that support durability, preserve value and enable next use. 

4. Water and chemicals move up the product agenda 

Water has quietly become one of the EU’s strategic sustainability priorities. 

The EU Water Resilience Strategy frames water as a resource linked to competitiveness, climate adaptation and economic resilience. In parallel, updated EU water rules revise the lists of pollutants in surface water and groundwater. 

The updated rules strengthen monitoring and controls for substances including certain PFAS, pesticides and pharmaceuticals. Member States must also monitor PFAS levels in drinking water under the recast Drinking Water Directive. 

PFAS remain politically and commercially sensitive. Broader restrictions on PFAS and other hazardous substances have faced delays and pressure in several contexts. The water legislation itself points towards greater monitoring, stricter controls and stronger attention to persistent chemicals. 

For product manufacturers, this matters because water impacts are connected to material choices, chemical inputs, production processes and wastewater. 

A textile company using water-repellent treatments, a packaging producer working with coatings, or a manufacturer using chemical additives may all face increasing pressure to understand how substances behave beyond the production site. 

This connects directly to Cradle to Cradle Certified®. The Material Health category assesses the chemical safety of materials and, starting at Bronze level, the standard restricts the use of PFAS, other organohalogen substances of special concern and functionally related substances of concern. Water & Soil Stewardship also guides companies in understanding and improving their impacts on water systems, soil and human and environmental health. 

5. Plastic pellet losses become a regulated material issue 

Plastic pollution is moving from broad ambition into more targeted requirements. 

The EU Regulation on preventing plastic pellet losses targets one specific source of microplastic pollution: pellets lost during production, transport, storage or conversion. 

For companies in the plastics value chain, the practical implications are concrete. The rules apply to economic operators managing installations in the EU that handle five tonnes or more of plastic pellets per year, as well as carriers transporting pellets within the EU and by sea. 

This includes manufacturers, recyclers, converters, stockists, logistics operators and other companies handling plastic pellets. These operators will need to take measures to avoid, contain and clean up spills or losses. The Regulation also introduces requirements around risk management plans, annual records and, for certain operators, certification or permits. 

A company manufacturing plastic components may therefore need to review how pellets are stored, handled, transported and cleaned up across its operations and suppliers. 

From a Cradle to Cradle Certified® perspective, this development connects to responsible material management, Material Health and Water & Soil Stewardship. It reinforces the importance of keeping materials in controlled systems and preventing losses that can affect ecosystems. 

Also on the radar 

Construction Products Regulation brings sustainability into product performance 

The revised Construction Products Regulation modernises the rules for placing construction products on the EU market and introduces stronger attention to digitalisation and sustainability information. 

The first CPR Working Plan sets out how implementation will develop by product family. Digital Product Passports are also part of the new framework, supporting access to information on performance, conformity, safety, use, repair, reuse, recycling and disposal. 

For manufacturers of construction products, sustainability information is moving closer to the technical language of product performance. A building product may increasingly need to communicate mechanical or fire performance alongside environmental information, material composition, durability, reuse potential and end-of-life pathways. 

This is highly relevant for Cradle to Cradle Certified® products in the built environment, where Material Health, Product Circularity and Clean Air & Climate Protection already support a more comprehensive understanding of product performance. 

For a manufacturer of flooring, insulation, acoustic panels or interior materials, the direction is clear: environmental data, material safety and circularity are becoming part of how product quality is understood in the construction market. 

Key details 

Type: EU Regulation, directly applicable across the EU 

Dates: Entered into force in January 2025; generally applicable from January 2026; implementation develops through the 2026–2029 Working Plan 

More on: European Commission – Construction Products Regulation 

https://single-market-economy.ec.europa.eu/sectors/construction/construction-products-regulation-cpr_en 

CPR Working Plan 2026–2029 

https://single-market-economy.ec.europa.eu/document/download/cad28304-4b49-4396-81a8-6a816d8f1a93_en 

Nature restoration brings biodiversity into national planning 

Nature restoration is moving into implementation. 

The Nature Restoration Regulation requires Member States to develop National Restoration Plans, showing how they intend to deliver on restoration targets and monitor progress. 

For companies, the most relevant effects are likely to emerge through national policies, land-use planning, sourcing expectations and wider market pressure around biodiversity and ecosystem health. 

The link to product manufacturing may be indirect, yet it is increasingly relevant. A furniture company sourcing timber, a textile company sourcing natural fibres, or a building product manufacturer relying on bio-based inputs depends on landscapes, soils, water systems and ecosystems that are now part of a wider restoration agenda. 

Cradle to Cradle Certified® addresses these issues through Water & Soil Stewardship, which helps companies understand, assess and improve their impacts on water, soil and surrounding ecosystems. 

Key details 

Type: EU Regulation, directly applicable across the EU 

Dates: Entered into force in August 2024; National Restoration Plans expected by September 2026 

More on: European Commission – Nature Restoration Regulation 

https://environment.ec.europa.eu/topics/nature-and-biodiversity/nature-restoration-regulation_en 

Textile EPR keeps moving towards EU-wide implementation 

Textile Extended Producer Responsibility is moving towards EU-wide implementation. 

The revised Waste Framework Directive introduces harmonised Extended Producer Responsibility requirements for textiles across the EU. 

Some countries are already ahead. France has operated a textile EPR system for years. The Netherlands introduced textile EPR in July 2023. Other countries are developing national schemes, meaning companies selling textiles across Europe may face different registration, reporting, fee and compliance systems while the EU moves towards greater harmonisation. 

Producers are expected to take greater responsibility for the products they place on the market, including collection, sorting, reuse and recycling at end of use. 

Eco-modulation is a key part of this shift. In systems such as the French textile EPR scheme, producer fees are already linked to environmental performance criteria. More schemes are expected to use similar logic, adjusting fees according to characteristics such as durability, repairability, recyclability and circular performance. 

For example, a mono-material T-shirt designed for easier recovery may be better positioned than a complex fibre blend that is harder to sort, separate or recycle. Design decisions made at the beginning of a product’s life can influence costs and recovery options at the end. 

Cradle to Cradle Certified® provides a structured methodology for designing products and systems that keep materials in use for longer and support effective recovery. For companies with certified products, circular design becomes a competitive advantage: a way to move ahead of the market and prepare for producer responsibility systems that increasingly reward better product design. 

Key details 

Type: EU Directive, implemented through national legislation 

Dates: Revised Waste Framework Directive entered into force in October 2025; transposition expected by mid-2027; textile EPR schemes expected by April 2028 

More on: European Commission – Revised Waste Framework Directive 

https://environment.ec.europa.eu/news/revised-waste-framework-directive-enters-force-2025-10-16_en 

A new way of making product decisions 

These developments point towards a major shift in how companies approach product-related decisions. 

Across the EU, sustainability policy is becoming more granular and more operational. It reaches into packaging formats, material choices, chemical inputs, product claims, recovery systems, water impacts, sourcing decisions, product development and production planning. 

For manufacturers, this changes the business context of product development and production. Sustainability needs to inform how products are conceived, assessed, communicated, manufactured, distributed and prepared for their next use. 

Cradle to Cradle Certified® provides a comprehensive framework that aligns with many of the product sustainability principles shaping the future EU policy landscape. By assessing products across Material Health, Product Circularity, Clean Air & Climate Protection, Water & Soil Stewardship and Social Fairness, the standard helps companies build a strong foundation for circular, responsible and verifiable product performance. 

For over a decade, Vugge til Vugge has been helping companies navigate this process and work towards Cradle to Cradle Certified®. Contact us to find out how we can support your certification journey.