ROHS Compliance

European Union member states have approved major revisions to the Corporate Sustainability Due Diligence Directive, significantly narrowing the scope of corporate sustainability obligations following industry and geopolitical pressure. 

Key Changes 

Scope Limited to Largest Companies 
The directive will now apply only to EU companies with more than 5,000 employees and €1.5 billion in annual turnover. Non-EU companies generating equivalent turnover within the EU are also covered. This substantially reduces the number of companies subject to supply chain due diligence requirements. 

Compliance Deadline Extended 
The compliance timeline has been pushed to mid-2029, giving companies additional time to prepare governance and oversight systems. 

Climate Transition Plan Requirement Removed 
The obligation for companies to adopt climate transition plans aligned with global temperature goals has been dropped, weakening alignment with the Paris Agreement. 

Sustainability Reporting Threshold Raised 
Changes also affect the Corporate Sustainability Reporting Directive. Reporting will now apply only to companies with more than 1,000 employees and €450 million in annual turnover, up from the previous 250-employee threshold. This reduces the number of companies required to disclose ESG data. 

Strategic Implications 

The revisions reflect concerns that regulatory burdens could undermine European competitiveness, particularly amid pressure from foreign governments and energy security considerations. 

For corporations, compliance pressure is eased but remains significant for large multinationals. For investors, fewer reporting entities may reduce ESG data availability and comparability. 

Overall, the EU’s recalibration signals a shift toward balancing sustainability ambitions with economic competitiveness and geopolitical realities.