The European Green Deal: state of play and what it means

The European Green Deal is not a law but a political programme dating from 2019. It has, however, produced a large body of binding legislation: the European Climate Law, the Fit for 55 package, and rules on packaging, deforestation and sustainability reporting. Since 2024 the course has been adjusted. The emphasis now lies on competitiveness and simplification. The Omnibus I package, which entered into force in March 2026, has narrowed the reporting obligations considerably. The underlying objectives have not been withdrawn.

The short answer

The Green Deal is an agenda from December 2019 aimed at climate neutrality in 2050.
The European Climate Law fixed that objective in law, together with at least 55% emission reduction in 2030 compared with 1990.
In December 2025 the Council and Parliament reached agreement on a target of 90% net emission reduction in 2040.
The Omnibus I package substantially relaxed the CSRD and the CSDDD.
The CSRD now applies to companies with more than 1,000 employees and more than EUR 450 million net turnover.
The first report covers financial years from 1 January 2027.
The proposal for a Green Claims Directive has been withdrawn. Stricter consumer rules do apply to sustainability claims from 27 September 2026.

What the Green Deal is

The European Commission presented the Green Deal on 11 December 2019. It is an overarching growth strategy. The ambition is a climate-neutral Union in 2050, while preserving economic growth and employment.

A political communication creates no obligations for companies in itself. Legal effect arises only through regulations and directives. By now there are a great many of those.

Which legislation has come out of it

The main building blocks are as follows.

European Climate Law, Regulation (EU) 2021/1119. This fixes climate neutrality in 2050 and the interim target for 2030 in law.
Fit for 55. A package which, among other things, revised the emissions trading system, raised the share of renewable energy and tightened CO2 standards for vehicles.
CBAM, the carbon border adjustment mechanism. The definitive period began on 1 January 2026. Importers of steel, cement and fertiliser, among other goods, need an authorisation and must purchase CBAM certificates. A threshold of 50 tonnes per calendar year applies to small importers.
Sustainability reporting. The CSRD and the Taxonomy Regulation require large companies to report in standardised form. See also our pages on the CSRD, ESG reporting and the Taxonomy Regulation.
Circular economy. The Packaging Regulation (EU) 2025/40 and the revised Waste Framework Directive, Directive (EU) 2025/1892, impose new requirements on producers.
Nature and deforestation. The Nature Restoration Regulation (EU) 2024/1991 entered into force on 18 August 2024. The Deforestation Regulation has been postponed and simplified.

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What has been adjusted since 2024

The political wind has turned. Since 2024 the Commission has placed greater emphasis on competitiveness and reducing burdens. Four developments matter most in practice.

1. Omnibus I

The Omnibus I package entered into force in March 2026. The CSRD has since applied to companies with more than 1,000 employees and more than EUR 450 million net turnover. The first report covers financial years beginning on or after 1 January 2027. The CSDDD has also been relaxed, and reporting under the Taxonomy Regulation has largely become voluntary for companies below the threshold.

This means that many Dutch companies preparing for the CSRD are no longer subject to a reporting obligation. They will often still receive the questions, through customers, banks and tenders.

2. The Clean Industrial Deal

On 26 February 2025 the Commission presented the Clean Industrial Deal. It links decarbonisation to industrial policy: affordable energy, demand for clean products, financing and access to raw materials. In its wake, the State aid framework for the Clean Industrial Deal was adopted. March 2026 brought a proposal to accelerate investment in strategic sectors.

3. Initiatives announced and dropped

Not every proposal announced reaches the finish line. The proposal for a regulation on the sustainable use of plant protection products has been withdrawn. The proposal for a Green Claims Directive has likewise been withdrawn. A Circular Economy Act has been announced, but the proposal has not yet been published.

4. Postponed application dates

The Deforestation Regulation applies to large companies from 30 December 2026 and to micro and small companies from 30 June 2027. The emissions trading system for buildings and road transport has been postponed by a year to 2028.

Why the course has shifted

The adjustment since 2024 has two causes. The first is economic. European producers face higher energy costs than competitors outside the Union. The second concerns feasibility. Companies and regulators ran up against the sheer scale of the reporting obligations.

The Commission’s answer has been simplification rather than abolition. Thresholds have been raised, dates have moved and the number of data points has been reduced. The underlying objectives, such as climate neutrality in 2050, remain unchanged.

In practice this means you should not assume that obligations will disappear altogether. If you see an obligation move, you gain time, not an exemption.

The 2040 climate target

On 10 December 2025 the Council and Parliament reached agreement on a binding target of 90% net emission reduction in 2040 compared with 1990. From 2036, high-quality international carbon credits may be used, up to a maximum of 5% of net emissions in 1990. The European Parliament approved the amendment to the Climate Law in early 2026.

What this means for Dutch companies

Subject	What to watch
Reporting	Check whether you exceed the new CSRD thresholds. If not, expect questions from the value chain all the same.
Sustainability claims	Stricter rules against misleading claims apply from 27 September 2026 under Directive (EU) 2024/825.
Imports	Check whether your goods fall under CBAM or the Deforestation Regulation.
Products and packaging	The Packaging Regulation imposes requirements on design, composition and documentation.
Permits	Environmental and planning requirements are shaped in part by European law. See environmental law.
Financing	Banks ask for substantiated energy and emissions data when granting credit.

Contractually, the value chain deserves attention. Many obligations are passed on through purchasing terms, warranties and information clauses. Assess whether you can meet those obligations before you accept them.

Frequently asked questions

Has the Green Deal been abolished?
No. The objectives are set out in binding legislation, including the European Climate Law. A number of reporting and value chain obligations have been relaxed, however, and some proposals have been withdrawn.

Does my company still have to draw up a sustainability report?
Only if you exceed the thresholds of more than 1,000 employees and more than EUR 450 million net turnover. For other companies, reporting is in principle voluntary, although contractual arrangements may still create obligations.

May I still call my product sustainable?
Only with supporting evidence. General environmental claims without demonstrable excellent performance are prohibited from 27 September 2026. Read more about greenwashing and environmental claims.

Would you like to know which European obligations apply to your company and how to cover them contractually? Please contact the lawyers of Law & More in Eindhoven or Amsterdam. We work in Dutch and in English and are glad to think through the issues with you.

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The European Green Deal: state of play and what it means