December 2025
Consumer, Competition and Sustainability
European Commission proposes targeted measures to ensure the timely implementation of the EU Deforestation Regulation
On 21 October 2025, the European Commission proposed targeted measures to implement the EUDR, prioritising IT system readiness and simpler reporting.
Downstream operators and traders would not file due diligence statements, with a single submission at first placement covering the supply chain. Micro and small primary operators from low-risk countries would make a one-off declaration, including via Member State databases.
The application will start on 30 December 2025 for large and medium companies, with a six-month enforcement grace period, and on 30 December 2026 for micro and small enterprises. Adoption by the European Parliament and the Council is required. The Commission is preparing contingencies and expects a 30% administrative burden reduction.
Learn more about the EU Deforestation Regulation (EUDR) from DR Martin Rothermel, Sebastian Runz and Louis Warnking here.
European Commission issues preliminary findings on TikTok and Meta DSA transparency breaches
On 24 October 2025, the European Commission published its preliminary findings that found both TikTok and Meta were in breach of their obligation to grant researchers adequate access to public data under the Digital Services Act (DSA). The Commission also preliminarily found Meta, for both Instagram and Facebook, in breach of its obligations to provide users simple mechanisms to notify illegal content, as well as to allow them to effectively challenge content moderation decisions.
The Commission indicates Facebook, Instagram and TikTok impose burdensome processes that leave researchers with partial or unreliable public data.
For Meta, Facebook and Instagram allegedly lack user-friendly notice-and-action tools, use deceptive interface designs, and provide appeals that do not allow users to add explanations or evidence.
Facebook, Instagram and TikTok now have the possibility to examine the documents in the Commission's investigation files and reply in writing to the Commission's preliminary findings. If confirmed, the Commission may issue a non-compliance decision with fines up to 6% of worldwide annual turnover and periodic penalty payments.
Find out about the Digital Services Act from multiple authors at Taylor Wessing here.
UK Government publishes The Producer Responsibility Obligations (Packaging and Packaging Waste) (Amendment) Regulations 2025
On 3 November 2025, the UK Government laid the draft Producer Responsibility Obligations (Packaging and Packaging Waste) (Amendment) Regulations 2025, amending the 2024 Extended Producer Responsibility Regulations.
This amends the UK packaging producer responsibility regime. It updates legal obligations applicable to entities involved in placing packaging on the UK market.
The draft Regulations enable the appointment of a producer responsibility organisation to support PackUK (the scheme administrator for the UK’s pEPR programme), allow producers to deduct tonnage of recycled food grade plastic collected directly from consumers and reprocessed in closed loop systems, and clarify obligations to improve scheme efficiency.
The changes update regulators’ charges, refine local authority cost modelling, and close loopholes. Non-compliance remains subject to civil sanctions and criminal prosecution. The draft Regulations enter into force on 1 January 2026.
Find out more about the Packaging and Packaging Waste Regulations from multiple authors at Taylor Wessing here.
