# EU Product Regulation Action Radar: What Applies Now and What to Do

Source: https://activatedigital.ai/knowledge/regulation/what-applies-today
Last verified: 20 September 2026
Summary: Sources rechecked to 20 September 2026.

## In 60 seconds

As at 20 September 2026, the most immediate cross-regulation actions span six regimes. They are the live ESPR ban on destroying unsold apparel and footwear for large enterprises, PPWR now applying while major labelling specifications remain dependent on implementing measures, Cyber Resilience Act Article 14 reporting now live for manufacturers of in-scope products with digital elements, national implementation of the Right to Repair Directive, environmental-claims rules applying from 27 September 2026 and EUDR preparation for 30 December 2026 using Annex I as amended by Regulation (EU) 2026/2102.

- The ESPR ban on destroying unsold apparel and footwear applies from **19 July 2026** for large enterprises. The prohibition is size-sensitive.
- EUDR applies from 30 Dec 2026 for relevant operators and traders and from 30 Jun 2027 for natural persons and micro and small enterprises.
- The Right to Repair Directive transposition deadline of 31 Jul 2026 has passed. The answer now depends on each Member State's implementing law.
- Textile EPR under Directive (EU) 2025/1892: transposition by 17 Jun 2027 and schemes established by 17 Apr 2028 at the latest.
- The Green Claims Directive is still a proposal with no application date established.
The key discipline is **status before date**. A date can mark entry into force, application, national transposition, an implementing-power milestone or a future category duty. Those are not interchangeable. Use the Radar to decide what needs action now, then follow the specialist owner for the legal detail.

## Changed since last verification

Three changes matter immediately for returning readers:

- **EUDR:** Regulation (EU) 2026/2102 was published on 17 September and entered into force on 18 September 2026. Annex I is now amended. Re-run scope decisions against the operative Annex rather than continuing to watch the July adopted act as unpublished.
- **Cyber Resilience Act:** Article 14 reporting has applied since 11 September 2026. In-scope manufacturers need an operating workflow for actively exploited vulnerabilities and severe incidents now, even though most CRA obligations apply from 11 December 2027.
- **Vehicles:** Article 13(6) of Regulation (EU) 2026/1738 has applied since 14 September 2026. That opens the implementing-act path for technical DCVP details. It does **not** start the manufacturer DCVP obligation, which remains 1 September 2032.

## Status legend

- **APPLIES NOW:** the relevant duty is currently applicable.
- **STAGED OBLIGATION:** a specific duty applies before the wider instrument reaches its main application point.
- **IMPLEMENTATION DEPENDENCY:** the law is in place but part of the operating detail still depends on an implementing or delegated measure.
- **DIRECTIVE / COUNTRY LAYER:** the EU measure needs national implementation or must be checked country by country.
- **FUTURE DUTY:** adopted law has a later application date.
- **PROPOSED:** not law yet.
- **NOT ESTABLISHED:** the evidence checked does not establish the point. This is not the same as saying there is no rule or exemption.

## The current action Radar

| Regulation / event | Legal state | Exact date and date type | Who or what is affected | What changed / implementation dependency | Business action | Specialist owner |
|---|---|---|---|---|---|---|
| ESPR unsold apparel and footwear destruction ban | **APPLIES NOW** | **19 Jul 2026 - application for large enterprises**; **19 Jul 2030 - application for medium enterprises** | Large enterprises, and medium enterprises from 19 Jul 2030, placing apparel, clothing accessories and footwear within the covered product scope. Micro and small enterprises are exempt | The prohibition is live for large enterprises. Size matters: Article 25(5) of Regulation (EU) 2024/1781 applies it to medium enterprises six years after entry into force. | Confirm enterprise-size treatment, product coverage and the evidence retained for unsold-stock decisions. | [ESPR and unsold goods](https://activatedigital.ai/knowledge/regulation/destroying-unsold-stock) |
| Packaging and Packaging Waste Regulation | **APPLIES NOW / IMPLEMENTATION DEPENDENCY** | **12 Aug 2026 - main application** | Businesses placing packaging on the EU market | PPWR applies, while some labelling and technical detail still depends on later measures. | Apply the rules that are already operational and keep dependency-sensitive labelling logic configurable. | [PPWR](https://activatedigital.ai/knowledge/regulation/packaging-ppwr) |
| Cyber Resilience Act Article 14 reporting | **APPLIES NOW (STAGED OBLIGATION)** | **11 Sep 2026 - Article 14 application** | Manufacturers of in-scope products with digital elements | Mandatory reporting of actively exploited vulnerabilities and severe incidents is live through the Single Reporting Platform. Most CRA obligations generally apply from 11 Dec 2027. | Establish 24-hour and 72-hour escalation/reporting workflows, assign SRP ownership and validate platform access. Do not infer that the CRA's full product-security regime already applies. | [CRA Article 14 reporting](https://activatedigital.ai/knowledge/regulation/cyber-resilience-act-reporting) |
| Right to Repair Directive | **DIRECTIVE / COUNTRY LAYER** | **31 Jul 2026 - transposition deadline** | Businesses affected by national measures implementing Directive (EU) 2024/1799 | The EU transposition deadline has passed. The operational answer now depends on the relevant Member State implementation. | Check each destination country's implementing law and operating requirements rather than treating the Directive alone as the complete answer. | [Right to Repair](https://activatedigital.ai/knowledge/regulation/right-to-repair) |
| Environmental claims rules | **DIRECTIVE / COUNTRY LAYER** | **27 Sep 2026 - application** | Traders making covered business-to-consumer environmental claims in the EU | The rules have applied since 27 September 2026. | Complete claim, label and substantiation review now and keep the separate Green Claims proposal out of the current-law answer. | [Environmental claims](https://activatedigital.ai/knowledge/regulation/eu-environmental-claims-27-september-2026) |
| EUDR | **FUTURE MAIN APPLICATION / SCOPE NOW UPDATED** | **30 Dec 2026 - main application for relevant operators and traders**; **30 Jun 2027 - application for natural persons and micro and small enterprises** | Operators and traders dealing in relevant commodities and relevant products within Annex I, subject to the Regulation's role and timing rules | Two acts, two jobs. Regulation (EU) 2025/2650 set the application dates, 30 Dec 2026 and 30 Jun 2027 for natural persons and micro and small enterprises. Regulation (EU) 2026/2102 amended Annex I, published 17 Sep and in force 18 Sep, so the amendment is no longer a pending lifecycle item. | Re-run CN scope decisions against the amended Annex, record the Annex version used and collect plot/supply-chain evidence for products within the 30 Dec 2026 scope. Separate additions expressly deferred by the amendment to 30 Dec 2027. | [EUDR scope](https://activatedigital.ai/knowledge/regulation/eudr-scope) and [Annex I change history](https://activatedigital.ai/knowledge/regulation/eudr-annex-i-change) |
| Textile EPR under the amended Waste Framework Directive | **DIRECTIVE / COUNTRY LAYER** | **17 Jun 2027 - transposition deadline**; **17 Apr 2028 - Member States to establish the EPR schemes** | Member States and textile producers as implemented nationally | Directive (EU) 2025/1892 sets both dates: transposition by 17 Jun 2027 and the schemes established by 17 Apr 2028 at the latest. The operating obligations still depend on national scheme design. | Map Member State exposure and producer-role assumptions rather than using one EU-wide operational rule. | [Textile EPR](https://activatedigital.ai/knowledge/regulation/textile-epr) |
| Green Claims Directive proposal | **PROPOSED** | No application date established | Businesses making environmental claims | The legislative file remains a proposal. | Do not build compliance claims as though the proposal were adopted law. Track the procedure separately from current consumer-law duties. | [Green Claims status](https://activatedigital.ai/knowledge/status/green-claims-directive) |
| Critical Raw Materials Act permanent-magnet information | **ADOPTED / IMPLEMENTATION DEPENDENCY** | Later operating detail depends on Commission measures | Products containing covered permanent magnets where Article 28 is triggered | The Regulation establishes the framework but implementation detail still matters. | Identify candidate products and required source data, but keep implementation-dependent fields configurable. | [CRMA permanent magnets](https://activatedigital.ai/knowledge/regulation/permanent-magnets) |
| Vehicle circularity / Digital Circularity Vehicle Passport | **FUTURE DUTY / IMPLEMENTING POWER NOW LIVE** | **14 Sep 2026 - Article 13(6) applies; 1 Sep 2032 - manufacturer DCVP obligation** | Vehicle manufacturers within the Regulation's eventual DCVP scope | Article 13(6) now applies and empowers implementing acts on technical details. It does not move the 2032 passport duty. | Prepare governed vehicle data and neighbouring-passport interoperability. Do not hard-code unsettled carrier, Registry, storage or access architecture. | [Digital Circularity Vehicle Passport](https://activatedigital.ai/knowledge/vehicle-passports/digital-circularity-vehicle-passport) |

### Qualifier fields for the current Radar

Current row values at **20 September 2026** should be read with destination market, business size and legal role in mind.

| Regulation / event | Destination market | Size / role qualifier to preserve |
|---|---|---|
| ESPR unsold apparel and footwear | EU | The current destruction prohibition is size-sensitive. Do not generalise the large-enterprise application point to every business. |
| PPWR | EU | Check the actor's role and the specific obligation. Do not treat a pending implementing detail as if the underlying Regulation were not applicable. |
| Cyber Resilience Act Article 14 | EU | **Size-specific penalty treatment is not a reporting exemption.** Article 14 applies to in-scope manufacturers. Article 64(10)(a) limits administrative-fine treatment for micro and small manufacturers for failure to meet specified 24-hour early-warning deadlines. |
| EUDR | EU | Scope, role and timing all matter. Classify against the current Annex before deciding which evidence duties follow. |
| Directives | Relevant Member State | The EU directive and the national implementing law answer different parts of the question. |

## Vehicle circularity and the DCVP

**Status: in force, future DCVP obligation.** Regulation (EU) 2026/1738 entered into force on **13 August 2026** and generally applies from 1 September 2028. The Digital Circularity Vehicle Passport itself is adopted but does not apply until **1 September 2032** for vehicles within Article 13 scope.

At this page's 6 September 2026 evidence date, the Commission's Article 13(6) implementing-act provision **applies from 14 September 2026**. That provision opens the technical implementation path for access, storage, updates and the carrier or other identifier. It should not be described as if the manufacturer DCVP duty already applies in 2026.

**Action now:** govern the fixed vehicle information territories and interoperability dependencies, but do not hard-code a final QR, VIN-as-passport-ID, Registry or access architecture.

See [EU Digital Circularity Vehicle Passport (DCVP): What Changes for Cars and Vans from 2032?](https://activatedigital.ai/knowledge/vehicle-passports/digital-circularity-vehicle-passport)

## Market first, size second, role third

A product regulation answer becomes unreliable quickly if it starts with the date and skips the commercial facts. Before using a row, establish:

- **Where is the product being placed on the market?** EU rules do not answer every UK or other market question.
- **What is the business size where the instrument makes size relevant?** A verified size treatment should be stated precisely, not inflated into a general exemption.
- **What legal role is the business performing?** Manufacturer, importer, distributor, operator and trader are not interchangeable labels.
- **What is the product's actual classification?** For scope lists such as EUDR Annex I, material presence alone is not enough.

## What businesses can act on today

Four patterns matter more than the number of instruments.

### 1. Live duties can arrive before a Digital Product Passport

Do not organise readiness only around DPP launch dates. Product destruction, packaging, cybersecurity reporting, claims and due-diligence obligations can require data, evidence and operating controls before a category passport becomes mandatory.

### 2. A rule can apply while technical implementation still phases in

PPWR is the clearest current example. Later implementing measures do not suspend every obligation in the Regulation. Separate what the law already fixes from what remains dependent on a later act.

### 3. Directives need a country layer

An EU transposition deadline is not the same thing as one harmonised operating rule across every Member State. After the deadline, the question becomes which national law applies in the destination market and what that law requires.

### 4. A staged application date can create a live duty before the rest of the Regulation

Treat staged application dates as operating dates, not footnotes: Cyber Resilience Act Article 14 reporting already applies, so an in-scope manufacturer's reporting workflow needs to exist now, before most CRA obligations apply ([what the CRA does not require yet](https://activatedigital.ai/knowledge/regulation/cyber-resilience-act-reporting#what-most-of-the-cra-still-does-not-require-yet)).

The one action that serves every row here is knowing what your own record already holds, and you can [check your own product record against these dates](https://activatedigital.ai/dpp-readiness-checker) in your browser.

## What not to infer from this Radar

- **Adopted** does not mean **applicable now**.
- **In force** does not automatically mean every obligation applies.
- An **implementing-power provision** becoming applicable does not mean the eventual technical architecture has been settled.
- A standard being published or adopted does not make it a legal obligation in its own right.
- A missed statutory deadline remains a missed deadline until the required legal event occurs. Do not invent a replacement date.
- **NOT ESTABLISHED** does not mean “no exemption”, “no obligation” or “nothing applies”. It means the checked evidence did not establish the point.
- An EUDR-relevant input does not automatically make a finished product a relevant product. Annex I and CN classification control the scope question.

## Watching and next triggers

- **EUDR, 30 December 2026.** Annex I has now been amended by Regulation (EU) 2026/2102. The next check is operational readiness against the amended scope, including any further Commission guidance or information-system changes before the main application point.
- **DPP horizontal standards.** Six references are cited in the Official Journal under Decision (EU) 2026/1736. EN 18239 and EN 18246 have advanced within the European standards set, but no later OJ decision citing them was located in the evidence checked to 20 September 2026. Keep this in the implementation watch layer, not as a new product duty.
- **CRA.** Watch operational guidance and the path to the wider 11 December 2027 application point while running the Article 14 reporting process now.
- **Vehicle DCVP.** Watch the implementing acts made under Article 13(6). Do not pre-commit to QR, VIN-as-passport-ID, Registry, storage or access architecture before those acts establish the answer.
- **Category passports.** Some categories have their own passport timing: [what the Construction Products Regulation already sets for passports](https://activatedigital.ai/knowledge/digital-product-passport/construction-products), [Toy DPP requirements from 1 August 2030](https://activatedigital.ai/knowledge/digital-product-passport/toys), [detergent passport requirements](https://activatedigital.ai/knowledge/digital-product-passport/detergents) and [the iron and steel delegated act, indicative timing Q4 2026](https://activatedigital.ai/knowledge/digital-product-passport/iron-steel).

## What would change this page

This Radar should change when a tracked legal event changes the action a business should take: a new application point, adopted delegated or implementing act, national transposition event that materially affects the EU-level summary, operative scope amendment, or an implementation dependency being legally resolved.

Minor guidance edits that do not change the action belong with the specialist owner or change log rather than forcing a full Radar rewrite.

## Related

- [What changed in EUDR Annex I and which version applies now?](https://activatedigital.ai/knowledge/regulation/eudr-annex-i-change)
- [Is my product in EUDR scope?](https://activatedigital.ai/knowledge/regulation/eudr-scope)
- [Cyber Resilience Act Article 14 reporting](https://activatedigital.ai/knowledge/regulation/cyber-resilience-act-reporting)
- [Digital Product Passport regulatory change log](https://activatedigital.ai/knowledge/status/dpp-regulatory-change-log)
- [Every dated EU product obligation in one table, with JSON and CSV](https://activatedigital.ai/knowledge/data)
- [Digital Circularity Vehicle Passport](https://activatedigital.ai/knowledge/vehicle-passports/digital-circularity-vehicle-passport)

## Keep exploring

The questions this page usually raises next.

- [CompareNext questionEU Ban on Destroying Unsold Textiles: What Applies from 19 July 2026Large enterprises can no longer destroy covered unsold apparel and footwear under ESPR.→](https://activatedigital.ai/knowledge/regulation/destroying-unsold-stock)
- [CompareNext questionDoes Packaging Need a DPP? PPWR QR Codes and the Single-Carrier RulePPWR is not a packaging DPP. Understand Article 12 QR/data-carrier rules, phased dates and when one carrier must serve product and…→](https://activatedigital.ai/knowledge/regulation/packaging-ppwr)
- [CompareNext questionCyber Resilience Act Article 14 Reporting: What Manufacturers Must Do NowCyber Resilience Act Article 14 reporting has applied since 11 September 2026.→](https://activatedigital.ai/knowledge/regulation/cyber-resilience-act-reporting)
- [CompareNext questionEU Right to Repair Directive: What Businesses Need to Do After 31 July 2026The Right to Repair transposition deadline has passed. See which products are covered, what businesses must do and why national…→](https://activatedigital.ai/knowledge/regulation/right-to-repair)
Also worth reading

- [What to do nextSmall businessDigital Product Passport Readiness for Small Businesses: What to Check FirstSmall product business? Use the SME readiness path after establishing what applies today.→](https://activatedigital.ai/knowledge/guides/small-business-dpp-readiness)

## Related

- [EUDR: Dates, Geolocation Data and What Product Teams Actually Need](https://activatedigital.ai/knowledge/regulation/eudr) — EUDR product data
- [Where Do I Start With a Digital Product Passport?](https://activatedigital.ai/knowledge/start) — Where to start, and the six routes through Knowledge

## Primary sources

- [Regulation (EU) 2024/1781 establishing the Ecodesign for Sustainable Products Regulation](https://eur-lex.europa.eu/eli/reg/2024/1781/oj) EU law
- [Regulation (EU) 2025/40 on packaging and packaging waste](https://eur-lex.europa.eu/eli/reg/2025/40/oj) EU law
- [Regulation (EU) 2024/2847, Cyber Resilience Act](https://eur-lex.europa.eu/eli/reg/2024/2847/oj)
- [European Commission, CRA reporting obligations](https://digital-strategy.ec.europa.eu/en/policies/cra-reporting)
- [Directive (EU) 2024/1799 on common rules promoting the repair of goods](https://eur-lex.europa.eu/eli/dir/2024/1799/oj) EU law
- [Directive (EU) 2024/825 on empowering consumers for the green transition](https://eur-lex.europa.eu/eli/dir/2024/825/oj) EU law
- [Regulation (EU) 2023/1115, EUDR](https://eur-lex.europa.eu/eli/reg/2023/1115/oj)
- [Commission Delegated Regulation (EU) 2026/2102 amending EUDR Annex I](https://eur-lex.europa.eu/eli/reg_del/2026/2102/oj)
- [Directive (EU) 2025/1892 amending the Waste Framework Directive as regards food and textile waste](https://eur-lex.europa.eu/eli/dir/2025/1892/oj) EU law
- [Regulation (EU) 2024/1252, Critical Raw Materials Act](https://eur-lex.europa.eu/eli/reg/2024/1252/oj) EU law
- [Regulation (EU) 2026/1738 on circularity requirements for vehicle design and management of end-of-life vehicles](https://eur-lex.europa.eu/eli/reg/2026/1738/oj)