SRS Group

The Circular Economy Action Plan aims to create a cleaner, more competitive Europe by working with various stakeholders. It accelerates the transformation needed for the European Green Deal, building on circular economy efforts since 2015.

This plan streamlines regulations for a sustainable future, maximizes transition opportunities, and minimizes burdens on individuals and businesses.

CBAM, or the carbon border tax, is a recent addition under the EU law, specifically Regulation (EU) 2023/956 dated May 10, 2023. This setup involves adjusting costs at the border, considering CO2 emissions. The main goal is to balance out the expenses tied to CO2 emissions for goods entering the European Union (EU) and EU-produced goods covered by the Emissions Trading System (EU ETS). This new tax is essentially a measure to prevent greenhouse gas emissions from moving out of the EU to countries with less strict climate and environmental policies.

During the transitional period (exempt from fees), lasting from October 1, 2023 to December 31, 2025, importers will be obliged to submit quarterly reports on the embedded greenhouse gas emissions of imported goods from the following categories: cement, cast iron and steel, aluminum, fertilizers, hydrogen, electricity.

ESG, short for Environmental, Social, and Corporate Governance, encompasses the evaluation criteria pertaining to the natural environment, societal impact, and corporate governance. These factors are instrumental in assessing your company’s non-financial performance.

Starting in 2025, the requirement to prepare ESG report for 2024 will extend to all large enterprises and companies deemed public interest entities, employing at least 500 people, with a balance sheet total exceeding PLN 85 million or annual revenues exceeding PLN 170 million.

In 2026, this group will be joined by companies meeting 2 of the 3 criteria: employing more than 250 people, having a balance sheet total exceeding PLN 85 million, or annual revenues surpassing PLN 170 million.

Subsequently, small and medium-sized enterprises listed on regulated markets that meet at least 2 of the 3 conditions—employing more than 10 people, having a balance sheet total exceeding PLN 1.5 million, and revenues above PLN 3 million—will also be required to submit a report for 2026.

EU rules address environmental and other issues caused by the growing number of discarded electronics in the EU. The aim is to contribute to sustainable production and consumption by

• preventing the creation of WEEE as a priority
• contributing to the efficient use of resources and the retrieval of secondary raw materials through re-use, recycling and other forms of recovery
• improving the environmental performance of everyone involved in the life cycle of EEE

Batteries are an important source of energy and one of the key enablers for sustainable development, green mobility, clean energy and climate neutrality. This Regulation sets out rules on the sustainability, performance, safety, collection, recycling and second life of batteries as well as on information about batteries for end-users and economic operators.

It applies to all categories of batteries, namely portable batteries, starting, lighting and ignition batteries (SLI batteries), light means of transport batteries (LMT batteries), electric vehicle batteries and industrial batteries.

The Regulation came into effect on February 18, 2024, marking a phased enhancement of battery management and recycling rates. Affected companies must adhere to regulations covering various aspects, including battery sustainability and safety, label information, battery due diligence, waste battery management, digital battery passports, and green public procurement.

This regulation applies the Ecodesign approach to a wide range of products to tackle their most harmful environmental impacts. It establishes a framework for setting ecodesign requirements aligned with sustainability and circularity goals outlined in the new Circular Economy Action Plan.

These requirements include product durability, reusability, upgradability, reparability, eco-friendly materials, energy and resource efficiency, recycled content, remanufacturing, and reducing carbon and environmental footprints.

When consumer products become defective, consumers often do not seek to repair them, but discard them prematurely, even though they could be repaired and used for longer. This leads to an increase in waste, and generate greenhouse gas emissions and more demand for valuable resources in the production of new goods.

To promote sustainable consumption, this Directive aims to increase the repair and reuse of viable defective goods purchased by consumers within and beyond the legal guarantee.