Sustainable products and supply chains

Supply chain sustainability involves the management of environmental and social impacts throughout the entire lifecycle of goods and services. Due diligence plays a key part in helping organisations to identify, evaluate, and subsequently manage ESG risks in their supply chain.

Any business, irrespective of where they are based, which trades with consumers in the EU or places goods on the EU market will need to ensure that their products and practices are compliant with EU rules on supply chain sustainability and product sustainability as a condition of market access. These requirements may be generalist and determined by the size and nature of the entity concerned (such as those imposed by the EU Corporate Sustainability Due Diligence Directive (CS3D)) or may be product-specific.

Key developments

  1. EU Environment—horizon scanner — Sustainable products and supply chains—this Practice Note is a horizon scanner tracking key future developments in EU environmental law. It provides details of key dates for your diary (including forecasted dates where possible) and relevant commentary in relation to legislation-in-progress, legislation subject to future application dates or transposition deadlines, new consultations and calls for evidence,

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Commission launches consultation to revise the EU Cybersecurity Act and strengthen the EU cybersecurity framework

The European Commission launched a call for evidence to support the preparation of a legislative proposal to revise the EU Cybersecurity Act. The initiative aims to strengthen EU cyber resilience, update the mandate of the EU Agency for Cybersecurity (ENISA) and improve the effectiveness of the European Cybersecurity Certification Framework. The Commission noted that the cybersecurity landscape has become significantly more complex and threat‑intensive since the Act’s adoption in 2019, while subsequent EU legislation has expanded ENISA’s tasks beyond its original mandate, creating the need to streamline, simplify and supplement the existing framework to ensure coherence, reduce administrative burdens and improve implementation for businesses and users. The initiative focuses on measures to support a secure and resilient Information and Communication Technology supply chain and the EU cybersecurity industrial base, addresses shortcomings in the certification framework such as slow adoption, unclear roles, limited agility and insufficient clarity on covered risks, including non‑technical factors, and considers alignment with newer instruments such as the Cyber Resilience Act. The Commission outlined policy options ranging from non‑legislative measures to targeted or comprehensive regulatory revision, stating that EU‑level action is required to prevent internal market fragmentation and to secure long‑term economic and social benefits through greater harmonisation, stronger cybersecurity and resilience, more efficient incident response and enhanced protection of fundamental rights, including personal data. The call for evidence will run until 20 June 2025.

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