Critical ESG Regulation Deadlines for Manufacturers to Watch Over the Next Five Years

As U.S. manufacturers, importers, and other businesses are no doubt well aware, environmental regulations are on the rise worldwide. ESG—which first appeared two decades ago in a report requested by the United Nations—has evolved from a buzzy catchword to a powerful framework with transformational influence over how nations hold corporations accountable for their human and environmental impacts. 

With multiple sustainability directives entering into force in the coming years, the European Union continues to grow into a dependable global leader on policies that implement and actualize ESG’s three central pillars. Other state and national governments—including Australia and California—have begun to follow suit with their own regulations aimed at enhancing climate-related reporting and supply chain transparency for the businesses operating there. 

Considering critical developments like these, it’s hardly an overstatement to say that the 2020s have already established themselves as a watershed decade for sustainability regulations. The second half, though, is poised to be even more densely packed with key dates ushering in new ESG reporting requirements for businesses. Below, we take a look at some of the most important deadlines for these directives over the next five years. 

U.S. Regulations 

EPA TSCA PFAS Reporting Requirements 

In October 2023, the EPA published a final rule under the Toxic Substances Control Act, a 1976 law that gives the agency the authority to require businesses to provide information on chemical use. The rule, Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances, mandated that all covered companies submit a onetime report to the EPA outlining their use of PFAS substances. Businesses in the scope of the EPA PFAS directive are responsible for reporting on their use of the chemicals over a 12-year timeframe: from January 1, 2011 to December 31, 2022. 

While the six-month EPA PFAS reporting window was initially set to open on November 12, 2024, the agency recently pushed the start date to the summer of 2025. 

Key Deadlines (2025-2030)

• July 11, 2025: The window for PFAS reporting to the EPA opens. The electronic reporting portal will remain open until January 11, 2026 for most businesses. 

• July 11, 2026: Deadline for U.S. businesses that qualify as smaller manufacturers to submit PFAS reports to the EPA. 

California Climate Corporate Data Accountability Act (CCDAA)

Originally introduced in January 2023 by a group of California lawmakers, State Bill 253 was officially signed into law by Governor Gavin Newsom the following October. Also known as the California Climate Corporate Data Accountability Act (CCDAA), SB 253 requires U.S. businesses with annual revenue exceeding $1 billion operating in California to begin reporting on their scopes 1, 2, and 3 emissions over the next few years. 

While SB 253 was able to draw on its predecessor in the European Union, the Corporate Sustainability Reporting Directive (CSRD), the CCDAA represents the first of its kind to be codified into law in the U.S. In a statement issued by the Greenhouse Gas Protocol—the organization responsible for publishing the global standards for emissions reporting—Director Pankaj Bhatia spoke to the powerful implications of SB 253 passing in America. “This landmark legislation will have ripple effects far beyond California’s borders and can serve as a model for national and subnational governments to follow,” Bhatia said. 

Key Deadlines (2025-2030)

• 2026: Businesses operating in California with annual revenue over $1 billion must begin disclosing scope 1 and 2 emissions for the prior year. Disclosures must be assured by an independent third party. 

• 2027: Businesses operating in California with annual revenue over $1 billion must begin disclosing scope 3 emissions for the prior year. All disclosures must be assured by an independent third party. 

California Climate-Related Financial Risk Act (CRFRA)

Having moved through the California State Assembly alongside SB 253, the Climate-Related Financial Risk Act (CRFRA)—also known as SB 261—was likewise signed into law by Governor Newsom in the fall of 2023. While SB 253 exclusively functions as a GHG emissions reporting mandate, though, the CRFRA imposes a more comprehensive set of climate-related requirements. 

Under SB 261, U.S. companies doing business in California with annual revenue of at least $500 million must develop and submit biannual climate-related financial risk reports. These reports must carefully detail the company’s susceptibility to threats related to climate change, including potential disruptions to supply chains, workforces, and infrastructure, as well as the possible impacts to shareholders. SB 261 utilizes a reporting framework that draws from the Task Force on Climate-Related Financial Disclosures, and organizations interested in researching their impending obligations can consult the TCFD’s recommendations. Finally, companies must also include in their reports the measures they’ve taken to mitigate and adapt to the risks they’ve identified. 

Key Deadlines (2025-2030)

• January 1, 2026: The deadline for in-scope businesses to submit their first climate-related financial risk reports. 

European Union Regulations 

Corporate Sustainability Reporting Directive (CSRD)

Developed to serve as a successor to the European Union’s Non-Financial Reporting Directive (NFRD), the CSRD was initially proposed by the European Commission in the spring of 2021. It would enter into force less than two years later, in January 2023, with the express objective of raising the standard of sustainability disclosures in the EU to the level of financial reporting. 

The CSRD imposes reporting requirements based on the European Sustainability Reporting Standards (ESRS), a set of 12 categories encompassing the ESG pillars of environmental, social, and governance. These categories cover areas such as climate change, pollution, and biodiversity, as well as more human-centric concerns like the well-being and fair treatment of employees and other workers distributed along a business’s value chain. 

Under the CSRD, in-scope firms must report on the effects of climate change on their business using the model of “double materiality.” This requires firms to make a clear delineation between “impact materiality” (potential positive or negative impacts on people and the environment) and “financial materiality” (the impact of climate change and sustainability measures on a company’s own financial health and performance). The specific requirements of the ESRS as they were laid out by the European Parliament are available in the Official Journal of the European Union. 

Key Deadlines (2025-2030)

• 2025: All public companies previously subject to the EU’s NFRD must submit reports for 2024 activities. This includes firms that fall under the EU’s definition of “large undertakings” and also have at least 500 employees and are publicly listed. In addition, non-EU businesses that meet the EU’s criteria for large undertakings, have at least 500 employees, and are publicly listed on a regulated EU market must also begin reporting. 

• 2026: All EU firms that meet the criteria for “large undertakings” must report on their 2025 activities. This includes businesses that exceed two of the following three thresholds: an average of 250 employees over the course of the prior year; a balance sheet of EUR 25 million; and annual revenue of EUR 50 million. 

• 2027: All EU businesses which meet the criteria for either “small” or “medium” and certain non-EU firms are required to start reporting on their 2026 activities. 

• 2029: All non-EU firms with an EU revenue of at least EUR $150 million over the previous two years and either have an EU subsidiary subject to the CSRD reporting, or have an EU branch which generates annual revenue of at least EUR $40 million, must begin reporting on 2028 activities. 

Corporate Sustainability Due Diligence Directive (CSDDD)

After a long and tumultuous legislative process over the first quarter of 2024—during which a number of EU nations questioned the reporting burden the directive would impose on businesses—the Corporate Sustainability Due Diligence Directive was finally approved by the European Parliament on April 24. The CSDDD requires in-scope businesses to carry out a number of due diligence responsibilities with respect to their own operations and those of their partners along the supply chain. 

The CSDDD’s requirements largely follow the Organisation for Economic Co-operation and Development’s (OECD) Due Diligence Guidance for Responsible Business Conduct. The OECD’s framework consists of six high-level steps. These include (but are not limited to): identifying and assessing adverse impacts arising from the company’s operations and those of its supply chain partners; implementing targeted measures to mitigate those adverse impacts; and continually monitoring the mitigation measures in order to track their efficacy. Crucially, EU member states have been given a full two years from when the CSDDD initially entered into force on July 25 to codify the directive into national law. 

​​Key Deadlines (2025-2030)

• 2027: EU companies with more than 5,000 employees and global revenue in excess of EUR 1.5 billion, as well as non-EU companies with EU revenue of at least EUR 1.5 billion, must begin carrying out the CSDDD’s due diligence obligations.

• 2028: EU companies with greater than 3,000 employees and global revenue exceeding EUR 900 million, and non-EU companies with EU revenue of at least EUR 900 million, are required to start complying with the CSDDD’s due diligence obligations. 

• 2029: EU companies with more than 1,000 employees and global revenue greater than EUR 450 million, along with non-EU firms with EU revenue of at least EUR 450 million, must comply with the CSDDD. In addition, both EU and non-EU companies that entered into franchising and licensing agreements, and meet certain thresholds specified by the European Commission, are obligated to adhere to the directive. 

EU Deforestation-Free Regulation (EUDR)

The European Union’s Deforestation-Free Regulation aims to impose accountability on EU businesses for their environmental impacts. Specifically, the EUDR will require EU firms to show that the production and/or extraction of their goods did not result in deforestation, forest degradation, or the violation of any local or national environmental laws. The EUDR applies to companies that sell or trade in the following commodities: cattle, soy, coffee, cocoa, palm oil, timber, and rubber, as well as all derivatives of these products. There are no de minimus exceptions to the EUDR, either: all businesses that sell any amount of these goods are considered within the scope of the law. 

​​Key Deadlines (2025-2030)

• December 30, 2024: All products in the above-mentioned categories placed on the EU market on or after this date are subject to the EUDR. 

Australian Regulations 

Climate-Related Financial Disclosure Law 

This past summer, the Australian Senate passed the Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Bill 2024. The bill was then approved by the country’s House of Representatives in September, making a formal assent the only remaining hurdle before it becomes law. 

The Treasury Laws Amendment obligates in-scope businesses—including large companies, firms with substantial carbon footprints, and certain financial institutions—to submit reports detailing their climate-related risks and opportunities. The report’s chief requirements include an official climate statement outlining internal governance processes, metrics and targets, and Scopes 1, 2, and 3 GHG emissions. The specific reporting responsibilities are established by the Australian Accounting Standards Board (AASB), in the form of the Australian Sustainability Reporting Standards (ASRS). 

​​Key Deadlines (2025-2030)

• January 1, 2025: The inaugural reporting period for climate-related financial disclosures begins for large companies that meet two of the following three criteria: at least 500 employees; gross assets totaling AU $1 billion or more; and consolidated revenue of at least AU $500 million. 

• July 1, 2026: The reporting window opens for “Group 2,” which includes companies that meet two of the following three criteria: at least 250 employees; gross assets totaling AU $500 million or more; and consolidated revenue of at least AU $200 million. 

• July 1, 2027: Reporting commences for “Group 3,” which includes companies that meet two of the following three criteria: at least 100 employees; gross assets totaling AU $25 million or more; and consolidated revenue of at least AU $50 million. 

Mastering the Ever-Expanding Environmental Compliance Landscape 

As the recent flurry of lawsuits stymying the U.S. Security and Exchange Commission’s efforts to implement a new climate-related disclosure law illustrates, the ascendant era of ESG reporting has been far from unopposed. Large, well-heeled businesses are fighting some of the more demanding sustainability directives tooth and nail, in some cases slowing their progress and in others watering down the requirements they impose. On the whole, however, regulations drawing on the ESG framework are gaining momentum throughout the world, and the next few years will see a host of new obligations for many firms operating in California, Australia, and especially the EU. 

Manufacturers that want to ensure they’re adhering to the most important environmental directives can employ supply chain risk management (SCRM) software to bolster their compliance efforts. Industry-leading SCRM tool Z2Data uses full material declarations (FMDs) and approved vendor lists (AVLs) to instantly analyze whether your products, components, and suppliers are compliant with regulations like RoHS, REACH, California Prop 65, and TSCA, among others. The result is a single, centralized command station to manage all the environmental laws that affect your business.

To learn more about Z2Data and the wealth of substantive compliance data the tool provides to customers, schedule a free demo with one of our product experts.