Getting Ready for the EU Green Deal with C2C Certified: What Companies Need to Know

In acknowledgement of the existential threat to our planet posed by climate change and environmental degradation, the European Commission has set high ambitions to overcome this threat and transform the European Union (EU) into a modern, resource-efficient and competitive economy through the European Green Deal, which aims for:

• no net emissions of greenhouse gasses by 2050

• economic growth decoupled from resource use

• no person and no place left behind

In this rapidly-changing landscape, numerous pieces of legislation are currently under discussion as part of the European Green Deal. Companies that sell goods in the European Union will have to comply with these regulations.

Cradle to Cradle (C2C) Certified® helps companies to position themselves ahead of the game in terms of compliance with EU regulations. The Cradle to Cradle design framework has always been at the forefront of sustainable innovation thanks to its forward-looking philosophy, and its approach is even more relevant today, inspiring business leaders and policy makers alike. 

Here’s what companies need to know regarding the EU regulatory landscape and upcoming deadlines, and how the C2C Certified methodology and certification already help companies to be ready for the expected changes. Below we have listed the next crucial texts in our sight that will be important for 2024/2025:

Due Diligence and Transparency

Three main pieces of EU legislation relate to this topic:

1. The Corporate Sustainability Reporting Directive (CSRD), that requires companies to start reporting in 2025 for their 2024 financial year on Environmental, Social and Governance data;

2. The Corporate Sustainability Due Diligence Directive (CSDDD), which reached a provisional deal earlier in December to enhance the protection of the environment and human rights in the EU. The provisional agreement should be formally adopted at the beginning of 2024.

3. The EU Taxonomy Regulation, that aims to direct investments to economic activities that are aligned with the Green Deal net zero objectives. The transition to a circular economy was detailed in the recent delegated act as one of the four additional environmental objectives to climate change mitigation and adaptation.The European Commission also recently launched a Taxonomy guiding tool (the Taxonomy Navigator) to facilitate its implementation.

How does C2C Certified help companies comply with due diligence and transparency regulations? 

Although the C2C Certified Product Standard is developed for products, it also takes company policies and practices into account throughout the value chain. Companies in the value chain of a certified product (group) until ‘final manufacturing stage’ (definitions are defined per sector) are proactively integrating the C2C Certified holistic approach to address all adverse impacts on people and planet. 

The standard takes four environmental and social impact categories into account and adds Product Circularity as a key driver to reuse and cycle resources, and make a positive impact. The General and Social Fairness categories of the C2C Certified standard embed the due diligence approach based on the internationally recognised UN Guiding Principles on Business and Human Rights and OECD Due Diligence Guidance for Responsible Business Conduct, that can be also found within the EU CSRD and CSDDD frameworks. C2C Certified ensures that after establishing where the highest environmental and social risks are in their value chain, companies need to cease, prevent and mitigate these adverse impacts, to then track the implementation and results to communicate it publicly with all stakeholders, including end consumers.

Transparency is one of the most crucial requirements of the C2C Certified standard. Data on greenhouse gas emissions, water use and effluent quality, management of human rights risks and adverse impacts addressed are publicly available to all stakeholders, demonstrating the company’s commitment to protecting the planet and people.

As a result, companies whose products are C2C Certified are ready to face the ever-changing regulatory landscape, because their business and supply chain have been assessed as going beyond carbon neutrality and proactively integrating the most comprehensive approach to address adverse impacts on people and planet.

Designing out waste, and shifting to circular systems

 The EU revision of the Waste Framework Directive aims to improve waste management in Europe by reducing waste generation and increasing the preparation for reuse and recycling by improving separate collection. This revision - expected to be adopted in 2024 - is in line with the waste hierarchy and the implementation and harmonization of Extended Producer Responsibility (EPR) schemes within Member States.

The Extended Producer Responsibility (EPR) concept requires that manufacturers and importers of products must assume a significant degree of responsibility for the environmental impacts of their products throughout their life cycle, including the upstream impacts inherent in the selection of materials for products, the impacts of the manufacturers' production process itself, and the downstream impacts of product use and disposal.

The revision sets minimum requirements to promote harmonization, transparency, cost-effectiveness, accountability, and robust enforcement of EPR obligations at the national level. The eco-modulation of EPR fees based on product design will become mandatory, aiming to enhance stronger decision incentives for producers to reduce their environmental impact.

Simultaneously, the proposal for a new Ecodesign for Sustainable Products Regulation (ESPR), published on 30 March 2022, is the cornerstone of the Commission’s approach to more environmentally sustainable and circular products, aiming for products to last longer and be easier to repair, upgrade and recycle. Under this new regulation, companies will no longer be able to destroy unsold consumer products. The sustainability requirements for materials and products including textiles, furniture, steel, iron, aluminum, paints, tyres, lubricants and chemicals will be prioritized as the directive takes effect.

The Regulation on Deforestation-free products is also related. Having come into force in summer 2023, this regulation will apply from 2025, requiring any operator or trader to prove that their products do not come from forests that have been recently deforested or have contributed to forest degradation. Operators and traders have until the end of 2024 to comply with the new rules.

How does C2C Certified provide a head start towards designing out waste, and shifting to circular systems?

C2C Certified products are already designed with circularity in mind, having passed the circularity category requirements of the C2C Certified Product Standard, across the three pillars of sourcing, design and systems. The related steps that companies undertake are further explained below:

1. Circular Sourcing. Before looking at designing out waste, the first step when selecting materials with low environmental impact is decisive. Cradle to Cradle Certified products are first and foremost designed with circularly sourced materials as a result of the increased use of recycled or renewable materials, helping to close the loop and advance the circular economy. The negative impacts of virgin material use are also minimized.

2. Circular Design. As a second step, products need to be designed to be compatible for one of the cycling pathways - either the biological or technical cycle. Products are designed in a way that they can be Reused, Refurbished, Remanufactured, Repaired or Recycled if they are meant for the technical cycle. As for products made for the biological cycle, each material should degrade in specific conditions to meet biodegradability or compostability requirements and provide tests to demonstrate their compatibility. Each material needs to be easily disassembled into distinct materials that are compatible to be cycled after use. 

3. Circular Systems. Companies are constantly challenged to address any barriers to material recovery and processing to actively cycle their materials for their next use. The materials they choose must be compatible with existing recycling systems, or a cycling plan must be drawn up to meet the challenges posed by the lack of cycling infrastructure for the product at the end of its first use. Better waste management systems on national or EU level, including improved take back, sorting and cycling systems, will make it easier for companies to close the loop.

Communications

With regards to communications, two main directives address this topic:

1. The Empowering Consumers Directive, which entails restrictions on the use of generic sustainability claims, and is likely to be adopted in 2024 for implementation in 2026.

2. The Substantiating Green Claims Directive (SGCD) that aims to tackle greenwashing and protect consumers, and is likely to be adopted in 2025 for implementation in 2027. National requirements already exist in France, The Netherlands, Norway and Denmark.

Also relevant to communications is the “Digital Product Passport”, which is part of the ESPR and will provide information about products’ environmental sustainability. This information will be easily accessible by scanning a data carrier and it will include attributes such as the durability and reparability, the recycled content or the availability of spare parts of a product. It should help consumers and businesses make informed choices when purchasing products, facilitate repairs and recycling and improve transparency about products’ life cycle impacts on the environment. The product passport should also help public authorities to better perform checks and controls.

C2C Certified as enabler of specific and substantiated communications

Companies with products that are C2C Certified have third party validation for their sustainability claims, substantiated by the certification. Products are awarded an achievement level from Bronze to Platinum for each of the five C2C Certified impact categories, so companies are able to communicate product specific achievements based on the requirements met per impact category. 

Moreover, for every certification awarded in accordance with C2C Certified Product Standard Version 4.0, companies receive a “Circularity data report & cycling instructions” in order to understand the design intent and cycling instructions for consumers, sorters, repair centers and cyclers. This information provides essential data points for the Digital Product Passport requested under the ESPR.

Lastly on communications, companies are required to communicate internally and externally about their environmental and human rights policies according to the General Requirements and Social Fairness category of the C2C Certified Product Standard. These requirements go beyond their own operations, and also apply to their supply chain and potentially affected communities to understand how negative impacts are dealt with. Stakeholder feedback is to be regularly collected and used to shape the implementation strategy for environmental and human rights policy, management systems and related operations.

 ______

At the Cradle to Cradle Products Innovation Institute we are continuously updating our work and products to ensure alignment with these legislations. 

Look out for more guidance and updates from us regarding the new regulations and how C2C Certified can help you meet the requirements in the new year.