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General Product Safety Regulation (EU) 2023/988 obliges
GPSR Risk Analysis Required

Mandatory for almost every product: According to the GPSR, producers must draw up technical documentation for the products they place on the market. The technical documentation must be based on an internal risk analysis.

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General Product Safety Regulation requires Responsible Person
EU Responsible Person Service for the GPSR and more

Since 16 July 2021, it is against the law to sell products with CE marking without a Responsible Person in the EU. In addition, a Responsible Person must also be specified in accordance with the General Product Safety Regulation (EU) 2023/988.

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Personal EU Batteries Regulation Training
Ready for the new Batteries Regulation (EU) 2023/1542

Find out which obligations the EU Batteries Regulation places on you and how to deal with them in your specific case. Receive comprehensive information on how to implement your obligations with regard to labelling, battery passport, EPR and due diligence obligations in the supply chain.

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Personal EU Batteries Regulation Training
Ready for the new Batteries Regulation (EU) 2023/1542

Find out which obligations the EU Batteries Regulation places on you and how to deal with them in your specific case. Receive comprehensive information on how to implement your obligations with regard to labelling, battery passport, EPR and due diligence obligations in the supply chain.

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Bureaucracy cutback coming?

Due diligence and sustainability reporting obligations are to be dropped for up to 90 per cent of SMEs, at least according to the EU Commission's Omnibus 1 draft. The CSRD, CSDDD and CBAM are affected. But beware, due diligence and other obligations are still contained in upcoming and existing EU legislation, for example in the EU Batteries Regulation.

The EU Commission wants to massively simplify sustainability obligations and thus save companies 6 billion euros in bureaucratic costs, according to reports from the Commission. The "Omnibus 1" draft (trade-e-bility reported), which was associated with great expectations for a reduction in bureaucracy, was published as planned on 26 February 2025 and contains concrete, far-reaching changes for sellers, producers and, above all, SMEs. Here are the most important aspects in brief:

1. Corporate Sustainability Reporting Directive (CSRD): Around 80 % of companies are to be excluded from the scope of the CSRD, which means that the sustainability reporting obligations will focus on those companies that have the greatest impact on people and the environment.

2. Corporate Sustainability Due Diligence Directive (CSDDD): The start date for the due diligence obligations is to be postponed to mid-2028 for the largest companies. Companies must focus mainly on their direct suppliers, with assessments to be carried out every five years instead of annually.

3. Carbon Border Adjustment Mechanism (CBAM): Importers that import less than 50 tonnes per year are to be exempted from the CBAM obligations, which could benefit SMEs in particular. The requirements for calculating emissions and reporting are to be simplified for affected companies.

Against this backdrop, some observant consumer media are already reporting on the end of the Green Deal. But beware: due diligence and sustainability obligations are still included in upcoming or existing EU legislation, for example in the EU Batteries Regulation (EU BattVO), EU Regulation on deforestation-free supply chains (EUDR), Conflict Minerals Regulation (EU) 2017/821, EU Regulation on combating forced labour or Waste Framework Directive, to name just a few examples.

In addition, two camps of affected companies have now established themselves in terms of political influence at EU level, which can be divided into those in favour of reducing bureaucracy and those advocating responsibility for sustainability and due diligence obligations, human rights and the environment. These include not only associations and initiatives, but above all companies such as the Cocoa Coalition, which have already made great efforts and investments to implement the comprehensive obligations and regard them as an integral part of their brand and sales strategy as part of their company's DNA. It remains to be seen whether the latter companies will in future impose their own standards when selecting their trading partners, which will be applied regardless of the cancellation of binding EU regulations – and have a corresponding impact on their suppliers.

The Commission's omnibus draft must now pass through Parliament and the Council in the usual trialogue procedure. The Commission has requested accelerated processing. Changes to the content are certainly to be expected. In addition, the EU Competitiveness Compass leaves room for further bureaucracy reductions of up to 35%, which have not yet been defined in detail. In this volatile situation, the question arises: How to deal with all the constantly changing regulations and ongoing uncertainty?

The trade-e-bility consulting team will be happy to answer any questions you may have via +49/40/750687-300 or sales@trade-e-bility.de.

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You can reach us from Monday to Thursday between 8 am and 4 pm and on Friday between 8 am and 3 pm. Just give us a call!

Oliver Friedrichs
Contact

Oliver Friedrichs
CEO

Phone: +49 40 75068730-0

sales@trade-e-bility.de