Does This Apply to Me?
EU regulations affect your business differently depending on your company size and how much you export to Europe. This guide helps you quickly understand which rules matter for your products.
Regulatory Obligations Comparison Table
Large EU Company (>1000 employees, >€450M annual turnover)
| Regulation | Applicable | Scope | Timeline |
|---|---|---|---|
| CSRD (Corporate Sustainability Reporting Directive) | ✓ Mandatory | Full sustainability reporting (Scope 1, 2, 3 GHG; water; waste; social impact) | First report: 2025 (for 2024 data) |
| REACH | ✓ Mandatory | All chemical substances in products must be compliant; SVHC reporting required | Ongoing; test updates every 12 months |
| CSDDD (Corporate Sustainability Due Diligence Directive) | ✓ Mandatory (if >5000 employees or >€1.5B EU turnover) | Supply chain human rights & environmental due diligence; grievance mechanism | First compliance: 2027 |
| GHG Accounting | ✓ Mandatory | Scope 1, 2, and 3 emissions required; third-party verified | Required for CSRD reporting |
| DPP (Digital Product Passport) | ✓ Mandatory (when ESPR active) | Product-level passports with full environmental/sustainability data | Phase-in: 2026-2030 depending on product category |
| Green Claims Directive | ✓ Mandatory | No unsubstantiated environmental claims; third-party verification required | Enforcement: 2026 onwards |
| Waste Packaging Directive | ✓ Mandatory | Packaging must be recyclable/reusable; take-back obligations | Ongoing |
| Forced Labour Ban | ✓ Mandatory | Due diligence on forced labour in supply chain; import bans enforced | Ongoing |
Key Obligations:
- Publish annual sustainability report per CSRD
- Conduct supply chain due diligence (human rights, environment)
- Maintain REACH compliance documentation
- Prepare for Digital Product Passport implementation
- Third-party verification of sustainability claims
Large Non-EU Company (substantial EU sales, >€450M EU turnover)
| Regulation | Applicable | Scope | Notes |
|---|---|---|---|
| CSRD | ✓ Applies if >€450M EU turnover | EU operations and sales; may exclude non-EU revenue depending on legal structure | Must report if substantial EU market presence |
| REACH | ✓ Mandatory | All products imported to EU must comply; EU importer has legal liability | Non-compliance = product seizure/fine |
| CSDDD | ✓ Applies if >€1.5B EU turnover and substantial operations | EU supply chain due diligence required | Unlikely for most Indian exporters unless very large |
| GHG Accounting | ~ Partial | GHG reporting likely expected by EU buyers (Scope 1-3); not legally required unless CSRD applies | Buyer-driven requirement |
| DPP | ✓ Mandatory (when ESPR active) | All products sold in EU require DPP | Same as EU companies |
| Green Claims Directive | ✓ Mandatory | Claims made in EU marketing must be substantiated | Applies to marketing to EU consumers |
| Forced Labour Ban | ✓ Mandatory | Products must not contain forced labour; import screening enforced | All products subject to border checks |
Key Obligations:
- Ensure all EU-imported products meet REACH standards
- Prepare sustainability data disclosures for EU buyers (CSRD trickle-down)
- Implement Digital Product Passport before ESPR enforcement
- Document forced labour due diligence
SME / Smaller Company / No EU Presence
| Regulation | Applicable | Scope | Notes |
|---|---|---|---|
| CSRD | ✗ No | Not required if <€450M annual turnover | No legal obligation to report |
| REACH | ✓ Mandatory (via importer) | All products on EU market must comply; EU importer liable, not exporter | Non-compliance = importer faces fines/seizure |
| CSDDD | ✗ No | Not required if <€1.5B turnover or <5000 employees | May face buyer-driven requirements |
| GHG Accounting | ✗ No legal requirement | However, buyers increasingly request sustainability data | Buyer-driven, not regulatory |
| DPP | ✓ Applies (when ESPR active) | Products sold in EU require DPP, regardless of company size | No exemption for SMEs |
| Green Claims Directive | ~ Applies to claims | If making environmental claims in EU marketing, must substantiate | Limited exposure if no direct-to-consumer marketing |
| Forced Labour Ban | ✓ Applies | Products subject to import screening and forced labour declaration | Applies to all suppliers |
Key Obligations:
- Ensure REACH compliance (via EU importer coordination)
- Prepare for Digital Product Passport implementation
- Provide sustainability data to EU buyers (even without legal requirement)
- Maintain forced labour due diligence documentation
Decision Tree: Does This Apply to Your Company?
Are you headquartered in the EU?
├─ YES
│ ├─ >1000 employees AND >€450M turnover?
│ │ ├─ YES → LARGE EU COMPANY (All regulations apply)
│ │ └─ NO → SME (REACH + DPP + Green Claims + Forced Labour Ban only)
│ └─ <1000 employees OR <€450M turnover?
│ └─ YES → SME (See SME row above)
│
└─ NO (You are outside the EU)
├─ Do you export to the EU?
│ ├─ YES
│ │ ├─ >€450M annual EU sales?
│ │ │ ├─ YES → LARGE NON-EU COMPANY
│ │ │ └─ NO → Your EU buyers are the importers liable for REACH
│ │ └─ Sell via distributors/importers?
│ │ └─ YES → Importer liable for REACH; you must provide compliance data
│ │
│ └─ NO → Your home country regulations apply (REACH not directly applicable)
Practical Implications
For Large EU Companies
- Budget: Significant compliance infrastructure needed (dedicated teams, audits, systems)
- Reporting: Annual public sustainability reports; investor scrutiny expected
- Supply Chain: Complete due diligence required; supplier documentation critical
- Timeline: Immediate implementation; no exemption period
For Large Non-EU Companies (E.g., Major Indian Exporter)
- REACH Liability: EU importer bears legal liability; however, you must provide compliant materials
- Buyer Pressure: Large EU buyers will require CSRD-level data from you
- DPP Preparation: Must participate in Digital Product Passport implementation
- Opportunity: Size means you're a strategic supplier; buyers invest in your compliance
For SMEs / Smaller Exporters
- No CSRD Burden: However, buyers may request sustainability data voluntarily
- REACH Compliance: Must still comply; liability falls on EU importer, but non-compliance risks your business relationship
- DPP Participation: All suppliers required to support DPP, regardless of size
- Strategic Risk: Lack of documentation may cause buyers to delist you or choose larger, more compliant suppliers
Regional Nuances: EU vs. UK
Post-Brexit Note: UK regulations have diverged from EU in some areas.
| Regulation | EU | UK |
|---|---|---|
| CSRD | Yes | Not yet (UK FCA considering similar rules) |
| REACH | Yes | UK REACH applies (similar but separate from EU) |
| CSDDD | Yes (2024 onward) | Not adopted (no equivalent) |
| DPP (ESPR) | Yes (2026+ rollout) | Not adopted |
| Green Claims Directive | Yes | Not adopted (Greenwashing codes underway) |
| Forced Labour Ban | Yes | Yes (Modern Slavery Act) |
Implication: If you sell to both EU and UK, you must comply with both sets of rules. They are similar but not identical. UK REACH is slightly less stringent but still comprehensive.
What You Need to Do
If You Export Large Volumes to the EU (>€450M annual EU sales)
Your EU buyers will expect CSRD-level compliance data from you. They need your sustainability metrics to meet their own reporting requirements. Start measuring energy, water, and GHG emissions. Prepare for Digital Product Passport requirements.
If You're a Mid-Sized Supplier
REACH compliance is mandatory — your products must pass chemical safety tests. Sustainability data is increasingly expected by buyers, not optional. Build your compliance infrastructure now.
If You're a Small or New Exporter
REACH compliance is non-negotiable to enter the market. Sustainability documentation is becoming standard. Start small but start now. Compliance investment pays for itself through premium pricing and long-term customer retention.
Quick Summary
| Requirement | Your Responsibility | Why It Matters |
|---|---|---|
| REACH (Chemical Safety) | Test and verify your products | Non-compliance = product seizure at EU border |
| Labelling | Accurate fibre composition, country of origin | Required for every product entering EU |
| Sustainability Data | Measure energy, water, GHG, waste | Buyers need this; increasingly required for market access |
| Digital Product Passport | Prepare structured product data | Mandatory from 2026 onwards for textiles |
| Labour Practices | Document fair wages, safe conditions | EU buyers audit this; non-compliance = delistment |
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