How the written rules of impact reporting are changing

In the previous edition, we looked at how the unwritten rules of impact reporting are changing. This final edition of 2025 looks ahead to changes in the written rules and their legal or financial consequences.

Some of these rules have recently been simplified, delayed and softened. Nonetheless, the EU and UK are making significant changes in 2026.

Rather than try to cover everything, we focus on the EU’s move to revise who falls under CSRD, the UK’s packaging EPR (pEPR) fees that turn design choices into costs, and the EU Deforestation Regulation (EUDR) that makes proof a condition of sale for wood and timber-linked products.

CSRD

The Corporate Sustainability Reporting Directive (CSRD) is the EU’s main framework for mandatory sustainability reporting. Under the original plan, 2026 was going to bring listed small and medium-sized companies (SMEs) into scope, using a simplified reporting standard.

Recently, what the EU calls an “Omnibus” package has reopened CSRD and proposed a much narrower scope. In the latest provisional agreement, listed SMEs would be removed from scope, and reporting would focus on much larger firms with more than 1,000 employees and a net turnover of over €450M.

This is a real change in who the rules would cover, presented as a competitiveness and burden-reduction measure. But Amnesty International’s Director of the European Institutions Office described it as "betraying people and the planet".

What to look out for

The Omnibus package still needs to pass formal approval steps, including Council sign-off in 2026. If listed SMEs remain out of scope, the biggest reporting burden may shift from ‘reporting’ to ‘responding’ for smaller suppliers. Watch for how procurement questionnaires change, and whether SMEs are asked for CSRD-style data without CSRD support.

What it might mean for creative work

• If you work in/with larger companies, sustainability communications become more structured, auditable and tightly governed, and they need progress on their impacts and risks.
• If you work in/with smaller companies, pressure is going to appear indirectly, through client requests and supply chain questionnaires rather than publishing reports externally.

EPR and pEPR

The UK’s Extended Producer Responsibility for packaging (pEPR) requires companies that place packaging on the market to pay for managing it as waste. In 2026, it should be clearer how fee modulation will work and what harder-to-recycle packaging will cost producers.

Throughout 2026, obligated producers must track where packaged goods are sold across the UK and how packaging waste is managed, and report it to inform future pEPR reporting and cost calculations.

What to look out for

Impact has a direct cost, and weak end-of-life design becomes a financial penalty rather than a line in a report.

What it might mean for creative work

If you work on packaging or product decisions, expect conversations about commercial risk:

• Choices about materials, labels, formats and composites affect cost.
• Trade-offs between function, shelf presence and recyclability become harder to avoid.
• Claims of “technically recyclable” become harder to defend without the capacity to process the material.

Designers should be asked to solve for real-world disposal even when there are trade-offs against other requirements. In this context, the timing of Design Skills for Circularity (the year-long pilot programme developed with CIWM, Design Council and WRAP) could not be better.

EUDR

Anyone placing certain products on the EU market must comply with the EU’s Deforestation-free Products Regulation (EUDR), adopted in 2023, but rescheduled to apply from 30 December 2026 for larger operators and traders, and from 30 June 2027 for small and micro firms.

EUDR makes market access conditional. Covered products must be deforestation-free against a 31 December 2020 cut-off, produced in line with local law, and backed by a due diligence statement.

What to look out for

Timber is one of several commodities in scope, alongside foods and materials linked to deforestation. EUDR applies to any business, in the EU or elsewhere, that places covered products on the EU market or exports them, including operators and traders.

What it might mean for creative work

Timber is just one part of it. The due diligence will have implications for food, fashion and other sectors:

• Materials that cannot be traced or evidenced become harder to specify.
• Print and packaging choices become more risk-managed, even where some printed items fall out of scope.
• Claims and storytelling are limited to what can be proven, with a greater emphasis on what is known and what is not.

Better constraints, more creativity

In the last edition, we argued it can pay to jump before you are pushed. The written rules arriving in 2026 change what that push looks like. In practice, they attach cost, liability, and market access to things that used to sit in sustainability copy and voluntary reporting.

This does not mean less creativity, but it does mean better constraints. Claims have to sit on evidence. Materials have to come with traceability. Packaging must work in real systems, not just in concept.

If you work with brands, products, or supply chains, the question for 2026 is simple. What precisely are you saying about sustainability, and how would you prove it if you had to?