May 2026 is an important month with three key consultations ongoing in the EU in the field of product sustainability:
- Batteries Regulation – list of products exempted from the general removability and replaceability requirements. Open for comments here until 26 May 2026
- Digital Product Passport Registry. Open for comments here until 27 May 2026
- Deforestation – proposal to amend and simplify the rules and make technical fixes to Annex I. Open for comments here until 1 June 2026.
Products exempted from removability and replaceability requirements under EU Battery Regulation
According to Article 11 of the EU Battery Regulation, portable batteries, incorporated into products, have to be removable and replaceable by the end users. At the same, to ensure the safety of end users, certain products are exempted from this rule (removability and replaceability by end-users). In addition to the products already mentioned in the Regulation, the Commission has drafted a new list. The European Commission has opened a public consultation on the proposed list of products, whose battery can be removed and replaced only by independent professionals.
All stakeholders can share their opinion on the matter until 26 May 2026.
Arrangements for the Digital Product Passport Registry
The Ecodesign for Sustainable Products Regulation sets the requirements for the Digital Product Passport (DDP). The DDP provides access to digital information related to a product’s sustainability, circularity, and legal compliance. All information included in the product passports will be stored in a registry maintained and set up by the European Commission.
All stakeholders can share their opinion on the DDP Registry until 27 May 2026.
Proposal to amend and simplify the EU Deforestation Regulation
The European Commission is seeking views on the proposed delegated act which incorporates targeted amendments to the EUDR product scope. Among others, the proposal includes additions of certain downstream products, such as soluble coffee and certain palm oil derivatives. In addition, the draft has several exclusions from the scope of the EUDR, such as leather or retreaded tyres, as well as exemptions such as product samples, certain packing materials, used and second-hand products, and waste.
All stakeholders can share their opinion on the simplification of the EUDR until 1 June 2026.
- Q&A on EUDR: main provisions for operators and traders
- What is the digital product passport?
- Products exempted from removability and replaceability requirements under EU Battery Regulation
- EU Battery Regulation: removability and replaceability requirements explained
- New EU rules on products’ sustainability: ecodesign requirements
Do you have any questions? Ask us here or write us at prodlaw@obelis.net.
References:
European Commission (2026). Commission publishes simplification review of EU Deforestation Regulation. Retrieved on 06/05/2026.
EUR-Lex (2025). Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010. Retrieved on 06/05/2026.
EUR-Lex (2025). Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries, amending Directive 2008/98/EC and Regulation (EU) 2019/1020 and repealing Directive 2006/66/EC. Retrieved on 06/05/2026.
EUR-Lex (2024). Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products, amending Directive (EU) 2020/1828 and Regulation (EU) 2023/1542 and repealing Directive 2009/125/EC. Retrieved on 06/05/2026.
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