You sell into the EU. What is coming, and when?

Be able to answer quickly

If you sell into the EU, the reporting obligations arriving over the next few years mostly reach you through your customer rather than directly — as a purchasing condition, usually with a short deadline.

The practical advantage is not having a compliance department. It is being able to answer a data request in days with figures the customer can verify themselves.

One system, several formats

CBAM reporting, product passports, PACT-model exports and PDF footprint reports all come from the same inventory, so a new format request does not restart the data collection.

The plain calendar

CBAM — transitional reporting has been in force since October 2023; the definitive regime and the certificate obligation begin at the start of 2026. It does not bind you directly: the obligation sits with your importer in the EU, but they are also the one who will ask for the actual embedded-emissions figure. Without it, a default value applies and its cost attaches to your goods.

EU Digital Product Passport — the framework (ESPR) is in force and product groups open in sequence, with textiles among the first. The public registry infrastructure goes live in July 2026. In practice the date that matters is usually set not by the regulation but by the European brand's purchasing condition — and that arrives earlier.

CSRD — large EU companies are reporting and asking their suppliers for Scope 3 data, so the obligation reaches you through the chain. The wave dates were amended by the EU during 2025, which is why asking your own customer which wave they are in is more reliable than reading the general timetable.

What the three have in common: none of them asks YOU for a report. All of them ask your CUSTOMER. What is asked of you is to answer their question quickly and defensibly.