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The regulatory calendar and what it means on site

When European Union and Turkish regulation takes effect, what it means in practice for a manufacturer or exporter, and when preparation has to start. Articles are written from instruments in force; anything still at draft or proposal stage is marked as such.

Last updated: 29 September 2026

Packaging · PPWR · (EU) 2025/40

Packaging conformity: clearing customs does not mean you are compliant

The European Union Packaging and Packaging Waste Regulation has applied since 12 August 2026. Packaging placed on the EU market after that date needs a Declaration of Conformity and a technical file standing behind it. For a manufacturer in Türkiye the difficulty is usually the same one: the packaging is not something they produce, they buy it from a supplier, and so the data the declaration has to rest on is not in their hands.

Where the document is actually asked for

The conformity document is not paperwork requested at customs. It is asked for under market surveillance, and the importer has to produce it within ten days when requested (Art. 18(8)). For single use packaging the file is kept for five years. That distinction matters in practice: packaging assumed to be compliant because shipments cleared without incident can come back months later through a surveillance request, and ten days is not enough time to assemble a technical file.

What binds today and what does not

12.08.26

In force. Declaration of Conformity (Annex VIII), technical file (Annex VII) and heavy metal limit obligations apply.

31.12.26

Expected. Deadline foreseen for the Commission implementing act on how recycled content is to be calculated.

12.02.27

Expected. Deadline for Member States to set penalty rules. What enforcement looks like locally becomes clear after this date.

12.08.28

Later. Harmonised packaging labels.

01.01.30

Later. Recyclability classes, packaging minimisation and recycled content targets.

What can be done now

The declaration is not a formality, it is the output of an inventory. The sequence runs like this: for every product going to the EU, a component by component breakdown of the packaging; the material, weight and supplier of each component; written confirmation from the supplier of material composition and recycled content share; a check against heavy metal limits; then the technical file and the declaration. The hard part is collecting supplier data, and having a standard form for what you ask the supplier shortens the process noticeably.

Talk to us about a packaging inventory and declaration →

Construction products · CPR · (EU) 2024/3110

GWP declaration: the obligation arrives with your product family

The new Construction Products Regulation has applied since 8 January 2026. The point most often confused: GWP declaration did not become mandatory for all construction products at once on that date. The obligation comes into effect as each product's harmonised technical specification is renewed, so the timetable varies by product family.

Dates

The delegated act providing for System 3+ in the assessment of environmental characteristics arrived in July 2026. The product family timetable spreads across 2026 to 2029; secondary sources mention the last quarter of 2027 for cement and 2028 to 2029 for doors and windows, and those dates are not yet settled. Core environmental indicators are foreseen to apply from 9 January 2030 and the full life cycle indicator set from 9 January 2032.

The reason to start early is data, not the calendar

For a construction product manufacturer to declare GWP, an EN 15804 compliant life cycle model has to exist. The input to that model is a year of material and energy balance data from the production site. The data usually exists, but it is kept on an accounting logic and is not allocated per product. What takes time is not building the model, it is bringing the data down to product level. Starting when the specification update is announced generally does not leave enough time.

The same model is the basis of EPD preparation. Work done for the CPR therefore also produces the input for the EPD a tender or a customer asks for; they are not two separate exercises.

Life cycle assessment and EPD →

Export · CBAM · (EU) 2023/956

The gap between a default value and installation data is a cost gap

The definitive CBAM period began on 1 January 2026. Goods in scope can now only be imported by authorised CBAM declarants, and there is a de minimis threshold of 50 tonnes net per importer per year (electricity and hydrogen excluded). For 2026 imports, the first annual declaration and certificate surrender falls on 30 September 2027. Certificate sales start on 1 February 2027, and the quarterly fifty per cent holding check applies from 31 March 2027.

Why default values are expensive

Where installation data is not supplied, the default values published by the Commission apply. The values for 2026 were set by IR 2025/2621, and the correction in IR 2026/1740 was published on 31 July 2026 with retroactive effect to 1 January 2026. By definition those values sit above the real performance of a well run installation, and the difference feeds straight into the number of certificates to be bought. For a producer exporting iron and steel, aluminium, cement or fertiliser from Türkiye the practical question is whether it can calculate and evidence its actual embedded emissions, and if it cannot, how it will share the difference with its EU customer.

Deduction of a carbon price already paid

Article 9 of the Regulation allows a carbon price effectively paid in a third country to be deducted. The draft implementing regulation was published on 13 May 2026 and is awaiting adoption. Two limits in the draft text are decisive: only a price that has actually been paid, is mandatory and is non-discriminatory counts, and free allocation is deducted. Unless a payment is actually made under the Turkish Emissions Trading System, no deduction arises from this article. The expectation that TR ETS will lighten the CBAM burden holds, on the current text, only to the extent of the amount actually paid.

Scope extension

On 17 December 2025 the Commission put forward a proposal bringing downstream products into scope, with application foreseen from 1 January 2028. The Council position arrived on 12 June 2026 and the ENVI report on 7 July 2026, with trilogue targeted for completion at the end of 2026. The number of products that would fall in scope varies by source, and since the proposal is not yet law it is early to plan against a definitive list. What is worth doing today is having the installation data infrastructure in place for products already in scope; when the extension comes, the same infrastructure applies to the new ones.

CBAM and TR ETS compliance →

Also tracking

Other dates coming up

27.09.26

The Empowering Consumers Directive (EU) 2024/825 became applicable. Offset based "carbon neutral" and "climate neutral" claims, and unsubstantiated generic environmental claims, count as unfair commercial practices. A manufacturer using those phrases on a label or in a catalogue needs a product level calculation grounded in life cycle data.

27.10.26

TR ETS monitoring methodology plan. The Turkish Emissions Trading System Regulation entered into force on 27 August 2026. Installations in the pilot scope submit a first monitoring methodology plan within two months of entry into force, and the Presidency can extend that to six months. The scope and timetable of the pilot phase were removed from the final text and left to a decision of the Carbon Market Board, so the 2026 to 2027 pilot dates circulating in the press are not binding today.

30.12.26

EUDR applies to large and medium sized operators. Cattle, cocoa, coffee, palm, rubber, soy and wood are in scope, paper and pallets included. The EU importer files the declaration; the producer in Türkiye supplies geolocation and traceability data. For micro and small operators the date is 30 June 2027.

30.04.27

TR ETS verified annual report. Deadline for the verified emissions and activity report for 2026. Installations below 50,000 tCO₂e do not enter emissions trading, but the monitoring and reporting obligation still applies to them.

The dates on this page reflect instruments in force as at 29 September 2026. Regulations still at draft or proposal stage are marked as such in the text. How a given date binds your product group depends on the customs tariff heading of the product and on the target market.

Let us define the scope together.

In a thirty minute introductory call we can work out where the boundaries of the job sit, how much of the data you already hold, and a realistic budget range.

What we cover

  • Which regulation binds you, and by what date
  • Scope: how many products, how many sites, which boundaries
  • How much of your existing data is usable
  • Timeline and budget range