Key ESG developments across the EU and Baltics: Q3 2026 update

Publication / 29 September 2026 / Vitalija Impolevičienė, Agita Sprūde, Carolin Simona Laurits, Santija Veselova, Annika Kask

In this quarter’s ESG update, we highlight the latest developments shaping sustainability policy across Europe and the Baltic States. This edition focuses on recent EU initiatives, including the proposed reform of the EU Emissions Trading System, the adoption of the revised European Sustainability Reporting Standards, developments in green claims regulation and entry into application of new EU packaging rules.

We hope this overview helps you stay informed about the rapidly evolving ESG landscape. Our team remains available to support you with practical guidance and tailored solutions to help address your sustainability priorities.

Legislative news and ESG initiatives in Estonia, Latvia and Lithuania

Lithuania

Amendments to the Law on the Prohibition of Unfair Commercial Practices to Consumers, introducing stricter rules on environmental and sustainability claims made to consumers, entered into force on 27 September 2026. The new framework aims to combat greenwashing by restricting misleading environmental claims and introducing stricter requirements for sustainability labels and future environmental performance claims. The changes may affect environmental marketing, sustainability communications and product-related information provided to consumers. For a detailed overview of the new requirements and their practical implications, read our article.

In July 2026, the Lithuanian Parliament (Seimas) adopted amendments proposed by the Ministry of Environment to the Law on Waste Management, the Law on Pollution Tax, the Environmental Protection Law and the Code of Administrative Offences, transposing updated EU rules on the management of battery waste, waste shipment and electronic equipment waste. The substantive requirements for managing battery waste are now set directly by the EU Batteries Regulation (Regulation (EU) 2023/1542). A fine from EUR 5,500 to EUR 13,750 may be imposed for every tonne of waste from portable batteries or small vehicle batteries that is not collected. Supplying portable or small vehicle batteries to the Lithuanian market without registration may result in a fine from EUR 13,750 to EUR 27,500 for every tonne of batteries. Submitting incorrect data in battery accounting can result in a fine of up to EUR 6,000 – the total depending on the quantity of unrecorded batteries. The amendments also transpose changes to the EU Electronic Equipment Waste rules, extending producer and importer responsibility to equipment categories not previously covered, such as photovoltaic panels, and setting out simplified conditions, in line with the EU Waste Shipment Regulation, for transporting non-hazardous waste between member states.

With a view to transposing the provisions of Directive (EU) 2026/470 into national law, on 26 August 2026 the Ministry of Finance submitted to the Government of the Republic of Lithuania for consideration draft amendments to the Law on the Accounting of Companies and Groups of Companies and other related laws (Draft Law amending Article 10 of the Securities Law No. X-1023; Draft Law amending Article 10 of Law No. XIV-2813 amending Articles 2, 12, 13, 14, 22, 27 and 37 of…; Draft Law amending Articles 2, 11, 18, 19, 29, 49, 50, 53, 55, 81 and 82 of the Law on the Audit of…; Draft Law amending Articles 4, 16 and 17 of the Law on State and Municipal Enterprises No. I-722; Draft Law amending Article 11 of the Law on Agricultural Cooperatives No. IX-1804.)

Latvia

On 17 September 2026 the Latvian Parliament (Saeima) adopted on the third reading a law amending the Unfair Commercial Practices Prohibition Law, which adds Latvijas Banka as the supervisory authority for unfair commercial practices in the financial‑services sector and includes transitional rules, forming part of a broader legislative package alongside related draft laws such as (but not limited to) the Amendments to the Consumer Rights Protection Law (26‑TA‑744), Amendments to the Financial Instrument Market Law (26‑TA‑728) and Amendments to the Law on Alternative Investment Funds and Managers Thereof (26‑TA‑719).

Estonia

On 15 September 2026, the Estonian Parliament (Riigikogu) began examining a draft act prepared by the Ministry of Finance, amending the Accounting Act and the Auditors Activities Act, transposing Directive (EU) 2026/470 (Omnibus I, amending the CSRD) into national law. The amendment focuses on large undertakings whose net turnover exceeds EUR 450 million and which have an average of more than 1,000 employees. Its purpose is to reduce the administrative burden associated with sustainability reporting, making the reporting obligation more proportionate to a company’s size and impact, while supporting business competitiveness and preserving the objectives of the sustainable economy. The draft still requires adoption by a majority vote in the parliament before it can enter into force; the EU transposition deadline is 19 March 2027, though the drafters intend for the law to take effect sooner – ideally by autumn 2026 – to give affected companies legal certainty.

EU-level news

European Commission adopts revised, simplified ESRS

On 3 July 2026, the European Commission adopted revised European Sustainability Reporting Standards (ESRS) and a voluntary reporting standard for smaller companies, as part of the Omnibus I simplification package that streamlines sustainability reporting in the EU and reduces the number of companies in scope of the Corporate Sustainability Reporting Directive (CSRD). The revised standards are shorter and clearer, add new flexibilities and streamline key processes: they reduce the number of mandatory data points by over 60% and the total number of data points by over 70%, changes expected to reduce reporting costs by more than 30% per company, in line with the Commission’s target of a 25% reduction in reporting-related burdens. The revised standards take into account EFRAG’s technical advice, informed by stakeholder input gathered in spring 2025, a public consultation on EFRAG’s drafts in summer 2025, and a further Commission feedback call in spring 2026. The voluntary reporting standard offers a single, proportionate reference framework for companies outside the scope of the CSRD, making it easier for them to respond to sustainability information requests from large financial institutions and companies, and establishes a value chain cap under which CSRD-scoped companies cannot require more information from value chain companies than the voluntary standard covers. Both delegated acts have now been sent to the European Parliament and the Council of the EU for a two-month scrutiny period, extendable by a further two months, after which the measures will apply.

New EU packaging rules enter into application

From 12 August 2026, new EU rules on packaging started to apply across the EU. The Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, PPWR) establishes a harmonised framework for packaging and packaging waste in the single market and replacing fragmented national requirements with a common set of rules covering the entire packaging life cycle. A key measure entering into application on that date is a restriction on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging: food-contact packaging containing PFAS above strict limits, such as takeaway containers, fast-food wrappers, microwaveable popcorn packaging, wrapping paper from bakeries, and pizza boxes, can no longer be placed on the EU market. Further measures will become applicable in stages: a harmonised labelling system for packaging to facilitate waste sorting will apply from 2028, while measures to reduce packaging waste generation, including new limits on empty space, restrictions on certain single-use plastic packaging, reuse targets, mandatory use of recycled plastic content in new plastic packaging, and a requirement that all packaging be recyclable, will apply from 2030. Notably, in March 2026, the Commission published guidance to support implementation of the PPWR, including practical information on the new PFAS restrictions for businesses, national authorities and other stakeholders.

End-of-life vehicles regulation

On 13 August 2026, the Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles entered into force. The new rules establish, among others, standardised requirements to facilitate dismantling, repair, reuse, recyclability and recoverability; a mandatory target of 15% recycled plastic content from 2032, scaling to 25% from 2036 for new vehicles; a framework for the Commission to introduce recycled-content targets for steel and aluminium, applying from 2033; and rules for manual and mechanical treatment to recover high-quality steel, aluminium, copper, and rare earth elements for re-entry into EU supply chains.

Prohibition on destroying unsold clothes, clothing accessories and footwear

A ban on destruction of unsold clothes and shoes entered into application. This ban on destruction of unsold apparel, clothing accessories and footwear and the derogations started to apply to large companies from 19 July 2026. Medium-sized companies are expected to follow in 2030. The rules on disclosure under the ESPR already apply to large companies and will also apply to medium-sized companies in 2030. The rules were introduced by the Ecodesign for Sustainable Products Regulation. Businesses must prioritise keeping products in use by selling them (including through discounts or alternative markets), donating them to charities or social enterprises, or preparing them for reuse (repairing, refurbishing or remanufacturing). Destruction is to be allowed only under specified circumstances and must be carried out in accordance with the waste treatment hierarchy, giving priority to recycling.

The Sorainen ESG newsletter presents key sustainability policy updates across the EU and Baltic states, focusing on legislative changes, new regulations, and initiatives shaping the ESG landscape. Subscribe here to receive ESG‑related newsletters directly in your inbox.

Our ESG team is at your disposal, should you need advice on any legal issues you are facing. Contact the authors: