Supply chains, trade and due diligence: what changes in 2026

A number of key laws affecting supply chains and trade move into force or advance significantly in 2026, increasing compliance, reporting and traceability requirements for organisations importing into or operating within the EU.

Key laws going live in 2026 include legislation on the Circular Economy and the Carbon Border Adjustment Mechanism (CBAM) Carbon Tax. 

From January 2026, CBAM enters its full definitive phase. This requires EU importers of carbon-intensive goods (steel, aluminium, cement, fertilisers, hydrogen, electricity) to register, submit annual declarations detailing embedded GHG emissions (direct & indirect), and purchase CBAM certificates priced according to the EU Emissions Trading Scheme (ETS), to cover the carbon cost. This replaces free ETS allowances to level the playing field with EU producers. Data must be verified by accredited parties.  

In 2026, the long-awaited Circular Economy Act is due, aiming to create a genuine Single Market for secondary raw materials, aided by Digital Product Passports providing green credentials. Digital Product Passports (DPPs) will be implemented in Ireland as part of the EU's Ecodesign for Sustainable Products Regulation (ESPR). The rollout starts in 2026, targeting batteries, with textiles, iron, steel, furniture, and tires following by 2027-2029. Companies operating in Ireland must prepare for mandatory data sharing on product composition, repairability, and lifecycle to enhance circular economy compliance. 

The ambition of Ireland’s Second Whole-of-Government Circular Economy Strategy 2026-2028 (closed for consultations in November 2025) is to:

• Raise Ireland’s circular material use rate by circa 2 % every year with an aim of reaching the EU average of 12% by 2030.

• Key targets will focus on construction, bioeconomy, retail (reuse/repair), packaging, textiles, consumer electronic products and renewable energy technology with over €27 million government investment to support.

Under Omnibus I, the Corporate Sustainability Due Diligence Directive (CSDDD) has been simplified and now only applies to companies with >5000 employees and >€1.5 bn turnover. Transposition has been deferred to 26 July 2028, and it will apply from 26 July 2029 for in-scope companies.

The EU Deforestation Regulation (EUDR), requiring supply chain due diligence across timber and six key agricultural commodities (cattle, cocoa, coffee, oil palm, rubber, soy) and their products (beef, furniture and chocolate), has also been delayed to start in Dec 2026.

In the automotive sector, the original ban on fossil-fuel cars from 2030 has been replaced by the Automotive Clean Mobility Package. This requires a 90% tailpipe emissions reduction target by 2035, with the remaining 10% emissions to be compensated using low-carbon steel made in the EU, or from e-fuels and biofuels. This will allow plug-in hybrids (PHEV), range extenders, mild hybrids, and internal combustion engine vehicles to still play a role beyond 2035, in addition to full electric (EVs) and hydrogen vehicles. To support battery manufacture in the EU, an €1.8 billion “Battery Booster” aims to accelerate the development of a fully EU-made battery value chain. 

Organisations are now facing increasingly complex supply chain challenges spanning across macro-economic, geopolitical, governance, reputational, and environmental domains. As a result, the demand for end-to-end traceability is growing as companies aim to manage compliance and reputational risk and to allow for imports into Europe to continue.