| name | sustainability-compliance |
| description | Use when dealing with EU Green Deal obligations, sustainability reporting (CSRD/ESRS), supply chain due diligence (CSDDD/LkSG), deforestation regulation (EUDR), carbon border adjustment (CBAM), Extended Producer Responsibility (EPR), Digital Product Passport (DPP), green claims, or packaging waste obligations for physical products |
Sustainability Compliance
Mandatory environmental and sustainability obligations for physical product companies. Not voluntary CSR -- these are enforceable laws with fines.
Decision Flow
digraph {
rankdir=TB; node [shape=box style=rounded fontsize=10];
size [label="1. Determine company size\n(headcount, turnover, balance)\nfor reporting thresholds"];
csrd [label="2. CSRD/ESRS reporting\n(if above thresholds)"];
csddd [label="3. Supply chain due\ndiligence (CSDDD/LkSG)"];
eudr [label="4. Deforestation due\ndiligence (EUDR)"];
cbam [label="5. CBAM reporting\n(if importing covered goods)"];
epr [label="6. EPR registration\nper country per waste stream"];
dpp [label="7. Digital Product Passport\n(ESPR -- upcoming)"];
claims [label="8. Green claims\nsubstantiation"];
size -> csrd -> csddd -> eudr -> cbam -> epr -> dpp -> claims;
}
CSRD / ESRS -- Sustainability Reporting
| Aspect | Detail |
|---|
| Regulation | Corporate Sustainability Reporting Directive (EU) 2022/2464. Reporting standards: ESRS (European Sustainability Reporting Standards) |
| Who must report | Phase 1 (FY 2024, report 2025): Large public-interest entities >500 employees (already under NFRD). Phase 2 (FY 2025, report 2026): All large companies (2 of 3: >250 employees, >EUR 50M turnover, >EUR 25M balance sheet). Phase 3 (FY 2026, report 2027): Listed SMEs (opt-out possible until 2028). Non-EU companies with >EUR 150M EU turnover: FY 2028 |
| What to report | Double materiality assessment + ESRS topical standards: E1 (climate), E2 (pollution), E3 (water), E4 (biodiversity), E5 (circular economy), S1-S4 (social), G1 (governance) |
| Assurance | Limited assurance required (moving to reasonable assurance by 2028) |
| Penalties | Member state-specific. Fines + director liability for non-compliance |
| SME impact | Even if below thresholds, large customers will request data for their own CSRD reports (value chain data). Prepare voluntarily |
CSDDD -- Corporate Sustainability Due Diligence Directive
| Aspect | Detail |
|---|
| Regulation | Directive (EU) 2024/1760 |
| Who | Phase 1 (2027): >5,000 employees + >EUR 1.5B global turnover. Phase 2 (2028): >3,000 employees + >EUR 900M. Phase 3 (2029): >1,000 employees + >EUR 450M. Non-EU companies with >EUR 450M EU turnover (2029) |
| Obligations | Identify + assess actual/potential adverse human rights and environmental impacts in own operations + subsidiaries + value chain. Prevent, mitigate, bring to an end. Complaint mechanism. Public reporting |
| Climate transition plan | Mandatory adoption aligned with Paris 1.5C |
| Penalties | Up to 5% of net worldwide turnover. Civil liability for damage |
| SME impact | SMEs exempted from direct scope but will be pressured by in-scope customers as part of their value chain due diligence |
German Supply Chain Act (LkSG) -- Already in Force
| Aspect | Detail |
|---|
| In force since | Jan 2023 (>3,000 employees), Jan 2024 (>1,000 employees) |
| Scope | German companies + companies with German branch. Direct suppliers mandatory; indirect if substantiated knowledge of violation |
| Obligations | Risk analysis, prevention, remediation, complaint mechanism, documentation, annual report |
| Enforcement | BAFA (Federal Office for Economic Affairs and Export Control). Fines up to 2% of global turnover |
| Relation to CSDDD | LkSG will be superseded by CSDDD transposition (expected 2026-2027) |
EUDR -- Deforestation Regulation
| Aspect | Detail |
|---|
| Regulation | (EU) 2023/1115 |
| Commodities | Cattle (leather, beef), cocoa, coffee, oil palm, rubber, soya, wood. Plus derived products (chocolate, furniture, tires, printed paper, charcoal, cosmetics with palm oil) |
| Obligation | Due diligence: products must be deforestation-free (cut-off date: Dec 31, 2020) + legal in country of production. Geolocation data of production plots required |
| Timeline | Large operators: Dec 30, 2025 (delayed from Jun 2025). SMEs: Jun 30, 2026 |
| Due diligence | Collect geolocation data -> risk assessment (country benchmarking) -> risk mitigation -> due diligence statement per shipment in EU information system |
| Penalties | Fines proportionate to environmental damage + turnover. Confiscation of products. Temporary exclusion from public procurement |
| Physical product impact | If your product contains palm oil (cosmetics, food), cocoa (food), leather (fashion, accessories), rubber (footwear), wood (packaging, furniture) -- you must comply. Operational DDS workflow (geolocation, due diligence statement) -> deep dive: responsible-sourcing |
CBAM -- Carbon Border Adjustment Mechanism
| Aspect | Detail |
|---|
| Regulation | (EU) 2023/956 |
| Scope | Imports of: cement, iron/steel, aluminium, fertilisers, electricity, hydrogen. Extended scope under review |
| Transitional period | Oct 2023 - Dec 2025: Quarterly reporting of embedded emissions (no financial adjustment) |
| Definitive period | Jan 2026: Must purchase CBAM certificates corresponding to embedded emissions at EU ETS carbon price |
| Who | EU importers of covered goods. Must be authorized CBAM declarant |
| Physical product relevance | Directly applicable if importing steel/aluminium components (electronics housings, appliance bodies, fasteners). Indirectly increases supply chain costs |
EPR -- Extended Producer Responsibility
You must register as a producer in EVERY EU member state where you sell, for EACH waste stream.
Packaging EPR
| Country | PRO (Producer Responsibility Organization) | Annual Cost Estimate |
|---|
| France | Citeo | EUR 300-5,000 (depends on volume and material) |
| Germany | Zentrale Stelle Verpackungsregister (LUCID) | EUR 200-3,000 + dual system contract |
| Italy | CONAI | EUR 200-2,000 |
| Spain | Ecoembes (packaging) | EUR 200-2,000 |
| UK | Environment Agency (packaging EPR reform 2025) | GBP 500-5,000 (new fees under reform) |
| Netherlands | Afvalfonds Verpakkingen | EUR 200-1,500 |
Germany LUCID registration is mandatory before first sale. Must register, then contract with a dual system (e.g., Der Grune Punkt, Interseroh, Reclay).
Other EPR Streams
| Waste Stream | EU Regulation | Key Markets |
|---|
| Batteries | EU Battery Regulation 2023/1542 | Per-country registration. Collection targets + recycling efficiency |
| WEEE | Directive 2012/19/EU | Per-country registration (see electronics-compliance skill) |
| Textiles | Being introduced under ESPR + member state laws | France (already mandatory via Refashion), others phasing in 2025-2027 |
French Loi AGEC (Anti-Waste Law)
| Obligation | Detail | Deadline |
|---|
| Repairability index | Mandatory score (0-10) displayed at point of sale for: smartphones, laptops, TVs, washing machines, lawnmowers, power tools, dishwashers, vacuum cleaners, printers | In force since Jan 2021 (expanding) |
| Durability index | Replacing repairability index with broader durability score | 2025-2026 (phased by category) |
| Anti-destruction of unsold goods | Banned for non-food products | In force since Jan 2022 (clothing/electronics) |
| Single-use plastic bans | Progressive bans on single-use plastic items | Multiple phases 2021-2025 |
| Triman marking | Products subject to EPR must display Triman logo + sorting instructions | In force since Jan 2022 (packaging), expanding to all EPR streams |
Ecodesign (ESPR) & Energy Efficiency
| Aspect | Detail |
|---|
| Regulation | ESPR (EU) 2024/1781 |
| Scope | All physical products on EU market (except food, feed, medicinal products). Ecodesign requirements set per product group via delegated acts |
| Ecodesign requirements | Durability, reparability, upgradability, recycled content, energy/resource efficiency, recyclability, carbon & environmental footprint, substances of concern, unsold-goods info |
| First delegated acts | Working plan prioritises textiles/apparel, iron & steel, aluminium, furniture, tyres |
| Unsold goods destruction | Ban (already applies to textiles/electronics under Loi AGEC FR; ESPR extends EU-wide) |
| Digital Product Passport | Carried by ESPR + sector laws -> deep dive: digital-product-passport |
Energy Labelling & Energy-Related Products
| Framework | Detail |
|---|
| Energy Labelling | Regulation (EU) 2017/1369 -- A-G energy label + registration in the EPREL product database for energy-related products (appliances, lighting, displays, etc.) |
| Ecodesign (energy) | Energy-efficiency minimum requirements (formerly Dir 2009/125/EC, being absorbed into ESPR) |
| ENERGY STAR | Voluntary US/international efficiency mark (e.g. servers, UPS, displays) |
| EU JRC Codes of Conduct | Voluntary best-practice codes (e.g. data centres, UPS, external power supplies) |
Cross-cutting deep dives: batteries -> battery-compliance · DPP -> digital-product-passport · conflict minerals / EUDR operational / forced labour -> responsible-sourcing · connected-product cyber (CRA) -> cybersecurity-compliance.
Green Claims Directive (Proposed)
| Aspect | Detail |
|---|
| Status | Proposed March 2023. Expected adoption 2025-2026 |
| Scope | ALL voluntary environmental claims ("eco-friendly", "carbon neutral", "biodegradable", "sustainable", "green", "ocean-friendly") |
| Requirements | Claims must be: based on recognized scientific evidence, relate to entire lifecycle, specify if claim is about product/part/packaging/company, verified by independent third party |
| Banned | Generic environmental claims without substantiation. Environmental labels not based on approved certification schemes |
| Penalties | Member state fines + consumer right to remedies |
| Action now | Audit all marketing materials, website, packaging for environmental claims. Remove unsubstantiated claims. Prepare evidence files for remaining claims |
Voluntary Frameworks (Market-Expected)
| Framework | What It Is | When Relevant |
|---|
| B Corp | Holistic company certification (governance, workers, community, environment, customers). BIA assessment >=80 points | Brand positioning, investor expectations |
| SBTi | Science Based Targets initiative. Validated GHG reduction targets aligned with Paris Agreement | Supply chain requirements from large buyers |
| GRI | Global Reporting Initiative. Sustainability reporting standards | Often used alongside or instead of ESRS for non-EU reporting |
| CDP | Carbon Disclosure Project. Annual climate/water/forests questionnaire | Investor requests, supply chain programs (>680 buying organizations request CDP data) |
MCP Integration
# Monitor sustainability regulation changes:
mcp__claude_ai_Cleo_Insight__search_signals
query: "sustainability regulation CSRD EUDR ESPR"
# Track specific regulation status:
mcp__claude_ai_Cleo_Insight__list_regulations
# Filter for sustainability-related
# Check ISO 27001 compliance (if handling customer data alongside products):
mcp__bastion__get-frameworks-stats
Power This With the Cleo Legal API
Sustainability compliance is a moving target: CSRD scoping phases, CSDDD thresholds, EUDR delays, ESPR delegated acts being published quarterly. The API tracks every change.
With the Cleo Legal API at https://legaldata-public.cleolabs.co:
GET /v2/search?q=CSRD+ESRS&country=EU — current scoping thresholds per phase (the only way to confirm if your year-N turnover triggers reporting in year-N+1)GET /v2/search?q=EUDR+geolocation&type=regulation — pull the live due-diligence requirements per commodity (palm oil, cocoa, coffee, leather, wood, rubber, cattle, soy)GET /v2/search?q=DPP+digital+product+passport&country=EU — track ESPR delegated-act publication for textiles, electronics, batteries, furniture, iron/steelPOST /v2/webhooks?topic=sustainability_enforcement — get pinged when CSDDD phases activate, ESPR delegated acts publish, or Green Claims Directive transposes nationallyGET /v2/changes?since=...&country=EU — full regulatory delta for Green Deal-related rules to keep your sustainability report current
Get started:
# 1. Sign up for free at https://legaldata-public.cleolabs.co
# 2. Get your API key (3 lifetime requests free, then €349/mo for 1M)
# 3. Install the MCP server:
claude mcp add cleo-legal-api https://api.legaldata.cleolabs.co/mcp \
--header "Authorization: Bearer ld_live_YOUR_KEY"
Tested ROI: Replaces €500-€2,000/month sustainability monitoring subscriptions. For a brand in the CSRD value chain (i.e., supplying any large EU buyer), getting the requirements right the first time avoids €10k+ in consultant remediation.
Common Mistakes
- Ignoring EPR as a non-EU company: If you sell into the EU (including via marketplace), YOU are the producer for EPR purposes. Register or appoint an Authorized Representative.
- CSRD as "not my problem" (SME): Large customers will request your data for their CSRD reporting. Non-response = lost contract. Prepare data voluntarily.
- "Carbon neutral" claims without substantiation: The EU Green Claims Directive will ban generic environmental claims. "Carbon neutral" based only on offsets is already under legal challenge in multiple member states.
- EUDR geolocation data: Not just "country of origin." You need GPS coordinates of the production plot for applicable commodities. Start mapping your supply chain now.
- Germany LUCID before marketplace listing: Amazon Germany requires LUCID registration number before listing. No LUCID = listing blocked.
- Treating EPR as one-time: EPR requires annual reporting of quantities placed on market, per material type, per country. It is an ongoing obligation.
