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EU Green Deal advisory: which rules reach you, and when.

The EU Green Deal is not one law — it is a set of instruments that reach companies inside and outside the EU through prices, customers and banks. Habitat's EU Green Deal advisory maps which of them apply to you, the dates that matter, and the single data set that answers most of them. For companies in the Western Balkans and the US selling into the EU, and for EU firms with non-EU suppliers.

The instruments

Four rules, one data set.

InstrumentWho it reachesKey date
CBAM — Regulation (EU) 2023/956EU importers of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen — and through them, non-EU producersFirst annual declaration due 30 September 2027 (2026 imports)
CSRD — after Omnibus I (Directive (EU) 2026/470)Undertakings with more than 1,000 employees and more than €450 million net turnover — and their value chainsWave 2 reports in 2028 on FY2027
VSME — Commission Recommendation (EU) 2025/1710Non-listed SMEs asked for data by banks and large customersAvailable now (voluntary)
ETS2 — Directive (EU) 2023/959Fuel suppliers for buildings, road transport and small industry; costs pass through to fuel pricesFully operational in 2028

Sources: EUR-Lex texts named in the table; European Commission CBAM and ETS2 pages. Status as of late 2026.

Outside the EU does not mean out of scope

CBAM's legal obligation sits on the EU importer, but the regulation defines exactly what that importer needs from you — installation-level emissions data. CSRD works the same way through value chains. The request arrives through your customer, with a deadline attached.

FAQ

Frequently asked.

What is the EU Green Deal?
The EU Green Deal is the European Union's programme to reach climate neutrality by 2050. For companies it shows up as concrete instruments — the carbon border adjustment mechanism (CBAM), the corporate sustainability reporting directive (CSRD), the voluntary SME standard (VSME) and a second emissions trading system (ETS2), among others.
Does the EU Green Deal apply to companies in Kosovo, Serbia or the US?
Indirectly, yes. Non-EU producers of CBAM goods are reached through their EU importers' data requests, and suppliers of large EU companies through CSRD value-chain questionnaires. See CBAM in the Western Balkans.
Which rule should we prepare for first?
Usually the one with a customer attached. For exporters of steel, aluminium, cement or fertilisers that is CBAM; for suppliers to large EU groups it is the CSRD questionnaire; for bank borrowers it is VSME.
Do we need a separate data set for each rule?
No. A greenhouse-gas inventory to the GHG Protocol, with installation-level detail where CBAM goods are involved, answers most of them.
Talk to Habitat

Know which EU rules reach you before your customer tells you.

Tell us what you sell, where it goes and what you have been asked for.