Environmental, social and governance | UK Regulatory Outlook September 2026
Published on 28 September 2026
UK updates: Mandatory digital waste tracking comes into force on 1 October 2026 in England and Wales | HMRC publishes guidance on mass balance approach for chemically recycled plastic in Plastic Packaging Tax | EU updates: European Commission publishes ten guidance documents on EU CBAM implementation for non-EU operators | Delegated regulation under EUDR updating covered products published in the Official Journal | European Commission publishes guidance on Digital Battery Passport data requirements | European Commission publishes Notice setting out guidelines on the Forced Labour Regulation
UK
Mandatory digital waste tracking comes into force on 1 October 2026 in England and Wales
The Digital Waste Tracking (England) Regulations 2026 (SI 2026/729) and the Digital Waste Tracking (Wales) Regulations 2026 (SI 2026/105) both come into force on 1 October 2026, introducing the first phase of a UK-wide digital waste tracking regime under the Environment Act 2021.
Operators of permitted facilities receiving controlled waste must record specified information in a digital waste record and confirm it has been entered into the digital tracking system by the end of the second working day after the load is received, replacing reliance on paper waste transfer notes and hazardous waste consignment notes for this purpose. Failure to comply is a criminal offence, and the Environment Agency can also impose civil sanctions such as a fixed monetary penalty.
Businesses operating permitted waste receiving sites in England or Wales should confirm which sites are in scope and are registered for the digital tracking system ahead of the deadline.
HMRC publishes guidance on mass balance approach for chemically recycled plastic in Plastic Packaging Tax
See sustainable products section.
EU
European Commission publishes ten guidance documents on EU CBAM implementation for non-EU operators
On 14 August 2026, the European Commission published ten guidance documents to help non-EU operators, third-country installation operators, declarants and verifiers implement the EU Carbon Border Adjustment Mechanism (CBAM) during its definitive phase, which began on 1 January 2026.
The series comprises four general guidance documents (covering an introduction to CBAM concepts, roles, responsibilities, exemptions and deadlines; a quick guide for non-EU operators; calculation of embedded emissions and related monitoring and reporting obligations; and calculation of the adjustment for free allocation under the EU ETS) and six sector-specific guides, each including worked examples (covering cement, hydrogen, fertilisers, iron and steel, aluminium and electricity).
The guidance is intended to help affected businesses prepare for the verification of emissions data, understand the changes to embedded emissions calculations compared with the transitional period, and correctly apply default values and the free allocation adjustment for their 2026 imports.
Delegated regulation under EUDR updating covered products published in the Official Journal
The delegated regulation updating the list of covered products under the EU Deforestation Regulation (EUDR) was published in the Official Journal on 17 September 2026. This removes cattle hides, skins and leather, re-treaded tyres, soybeans for sowing, articles of vulcanised rubber, conveyor and transmission belts and aircraft and motor vehicle seats, while adding soluble coffee, certain palm oil derivatives, and frozen cattle tongues from 30 December 2027.
Separately, the European Commission has proposed removing French Guiana from the EUDR's territorial scope, using the special legislative procedure under Article 349 TFEU. The EUDR, which covers cocoa, coffee, palm oil, soybeans, livestock, rubber and timber, is due to start applying on 30 December 2026 following two earlier delays. The Commission points to French Guiana's geography, with around 95% of its territory covered by Amazon rainforest, and its porous land border with Brazil and Suriname, as justifying tailored treatment for the outermost region.
Under the proposal, trade in EUDR-covered products between French Guiana and Brazil, and products produced and consumed within French Guiana, would fall outside the regulation's scope, while goods shipped from French Guiana to the rest of the EU would still need to comply. Because the proposal relies solely on Article 349, the European Parliament has only a consultative role, and any amendments sought by member states during Council negotiations would generally require unanimity unless incorporated into the Commission's own proposal.
European Commission publishes guidance on Digital Battery Passport data requirements
See products section.
