Regulations •

The EU Omnibus packages: what actually changed — and what did not

Omnibus I, the CBAM simplification, the Digital Omnibus and Omnibus IV explained: which thresholds and deadlines really fell away, why product law is moving in the opposite direction, and why the digital product passport comes out of the simplification agenda more important, not less.

Author: myDPP Team

The EU Omnibus packages: what actually changed — and what did not

Since early 2025, one word has shadowed every discussion of EU regulation: Omnibus. In board meetings, supplier calls and trade press it has become shorthand for “Brussels is walking back what it passed”. There is a kernel of truth in that reading — and it becomes actively misleading the moment the subject turns to products.

The Omnibus packages did very different things. For corporate sustainability reporting they cut the scope dramatically. For the carbon border mechanism they removed nine importers out of ten. For the deforestation regulation they moved deadlines. In product law, however, they went the other way: more digitalisation, made mandatory, with the digital product passport designated as the place where the declaration of conformity and the instructions for use are to be held.

This article sorts the packages apart, states the thresholds and dates that actually apply, and draws a clean line between what genuinely fell away and what still stands.

Key takeaways

  • “Omnibus” is not a single law but a drafting technique: one act that amends many existing acts at once. There are now several Omnibus packages with completely different content.
  • Omnibus I (in force 18 March 2026) covers sustainability reporting: CSRD now applies only above 1,000 employees and EUR 450 million turnover (roughly 80% of previously covered companies drop out), CSDDD only above 5,000 employees and EUR 1.5 billion turnover (from about 13,000 companies down to roughly 6,000).
  • The CBAM simplification, Regulation (EU) 2025/2083, introduced a de-minimis threshold of 50 tonnes per importer per year — around 90% of importers are exempt, while those remaining still account for roughly 99% of embedded emissions.
  • The EUDR postponement is not part of Omnibus I. It came through its own act, Regulation (EU) 2025/2650 of 19 December 2025, setting the deadlines of 30 December 2026 and 30 June 2027.
  • The Digital Omnibus (in force 27 July 2026) postponed the AI Act’s high-risk obligations: Annex III to 2 December 2027, Annex I to 2 August 2028.
  • Omnibus IV runs in the opposite direction. The provisional agreement of 9 June 2026 amends around 20 pieces of product legislation towards “digital by default”: digital declaration of conformity, digital instructions for use, a mandatory digital contact point, and electronic-only communication with authorities.
  • The passport is upgraded by Omnibus IV, not weakened. Where another Union act already requires a DPP, the information from the declaration of conformity and the instructions is to be held there, instead of being duplicated.
  • Untouched: the ESPR and its delegated acts, the Battery Regulation, the Toy Safety Regulation, the PPWR, the GPSR and CE marking.
  • “Let’s wait for the Omnibus” is not a strategy for product data. The simplifications addressed company-level reporting; the per-product data requirements remained, and Omnibus IV is about to make them digital by default.

What “Omnibus” actually means in EU law

An omnibus act is a collective amendment. Instead of revising five regulations one at a time, the Commission bundles the changes into a single proposal that touches all five simultaneously. The technique is old and politically neutral — on its own it says nothing about whether obligations grow or shrink.

The term became loaded only through the simplification agenda the Commission opened in early 2025 with the Competitiveness Compass. Since then several packages have run in parallel, and in practice they are constantly confused with one another. When people say “the Omnibus”, they almost always mean Omnibus I — reporting — and then silently extend its relief to everything else.

That extension is the expensive mistake. The packages have different legal bases, different addressees and different directions of travel.

The packages at a glance

PackageCoversDirectionStatus
Omnibus ICSRD, CSDDD, TaxonomyReliefIn force since 18.03.2026
CBAM simplification (EU) 2025/2083Carbon border mechanismReliefIn force, definitive phase since 01.01.2026
EUDR amendment (EU) 2025/2650Deforestation RegulationDeadline shiftIn force since December 2025
Digital OmnibusAI Act, data lawDeadline shiftIn force since 27.07.2026
Omnibus IV~20 product law actsMore digital dutiesProvisional agreement 09.06.2026

That last row is the one missing from most summaries — and the one that matters most to manufacturers.

Omnibus I: reporting shrinks

The Omnibus I package was adopted by the European Parliament on 16 December 2025, signed off by the Council on 24 February 2026, published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026. Member States have twelve months to transpose it.

For the CSRD, the new thresholds are more than 1,000 employees and over EUR 450 million net turnover, replacing the earlier mark of 250 employees and EUR 50 million. They apply to financial years beginning on or after 1 January 2027. First-wave companies that already reported for financial year 2024 remain in scope. A separate “stop the clock” directive had already pushed the later waves back by two years in spring 2025.

For the CSDDD, the thresholds sit at more than 5,000 employees and over EUR 1.5 billion in worldwide net turnover, or for non-EU companies EU turnover above EUR 1.5 billion. The number of directly covered companies falls from around 13,000 to roughly 6,000. Transposition by 26 July 2028, application from 26 July 2029.

On top of that, the ESRS revision of 3 July 2026 cut the number of data points and introduced a value-chain cap limiting what reporting companies may demand from suppliers that are not themselves in scope. Our article on the ESRS standards covers this in detail.

The effect on mid-sized companies is real but bounded: they fall out of the direct obligation while continuing to receive their large customers’ data requests.

CBAM: the 50-tonne threshold

The carbon border simplification arrived as its own act, Regulation (EU) 2025/2083. It replaced the old de-minimis rule of EUR 150 per consignment with a mass threshold of 50 tonnes net per importer per calendar year. Below that, no authorisation, no declaration and no certificates are required. Electricity and hydrogen are excluded from the threshold.

The effect is strikingly asymmetric: roughly 90% of importers fall out, while those remaining still account for about 99% of embedded emissions. The sale of CBAM certificates was also moved from 1 January 2026 to 1 February 2027, and the first annual CBAM declaration is due on 30 September 2027, covering imports made in 2026.

For companies above the threshold the obligation actually hardened rather than loosened: without authorised declarant status, the goods do not enter free circulation at all. See our article on CBAM registration.

EUDR: a postponement, but not an Omnibus

The deforestation regulation is routinely filed under “Omnibus”. Legally that is wrong: the change came through Regulation (EU) 2025/2650 of 19 December 2025, a standalone act and the second — and explicitly final — change of dates.

The deadlines are 30 December 2026 for large and medium companies and 30 June 2027 for micro and small ones. Substantive simplifications were made: the due diligence statement is submitted only by the first party placing the goods on the market, a new downstream operator role was created, and printed books, newspapers and paintings left the scope. The three core conditions, the 31 December 2020 cut-off date, geolocation and the seven commodities all remained unchanged. Details in our article on the EUDR delay.

The Digital Omnibus: AI Act dates moved

The Digital Omnibus was approved by Parliament on 16 June 2026, finally adopted by the Council on 29 June 2026, and entered into force on 27 July 2026. It postpones the AI Act’s high-risk obligations: Annex III (biometrics, critical infrastructure, recruitment, credit scoring and others) from 2 August 2026 to 2 December 2027, and Annex I — AI embedded in products already covered by sectoral product safety law — to 2 August 2028.

The Article 50 transparency duties remain in substance; the deadline for marking synthetic content is 2 December 2026. Any internal documentation still working to 2 August 2027 needs checking.

Omnibus IV: in product law the arrow points the other way

On 9 June 2026 the Council and Parliament reached a provisional agreement on Omnibus IV. The package introduces a new size class — the small mid-cap, which gains certain SME reliefs without being an SME — and amends around 20 product law acts towards “digital by default”. Among those affected are the Machinery Regulation, the RoHS Directive, the Recreational Craft Directive, gas appliances and pressure equipment; on the regulation side, the ESPR (EU) 2024/1781 and the Battery Regulation (EU) 2023/1542.

Four measures hit manufacturers directly:

  • Digital declaration of conformity. The EU declaration of conformity is digitalised, and exchanges between economic operators and authorities are to take place electronically only.
  • Digital instructions for use. Instructions may be supplied digitally. Safety information must still be provided on the product or in printed form, and consumers keep the right to request a free paper copy within a set period.
  • Mandatory digital contact point. An up-to-date, accessible electronic channel — with no registration requirement and no app download — must be given on the product and in the declaration of conformity, alongside the postal address.
  • The passport as the repository. Where another Union act already mandates a digital product passport, the information from the declaration of conformity and the electronic instructions is to be held in the passport rather than kept in parallel.

Omnibus IV does not change the start dates of the existing passports: battery passport 18 February 2027, detergents passport 23 September 2029, toy passport 1 August 2030.

One caveat on reliability: 9 June 2026 produced a provisional political agreement. Formal adoption and publication in the Official Journal were still pending at the time of writing, and the final text may differ in detail. The direction is settled; individual deadlines are not.

What the Omnibus did not touch

This list is the real substance of the topic, because it is almost always missing from the summaries:

  • The ESPR and its delegated acts. The timeline, data requirements and product groups of the 2025-2030 working plan are unchanged. Iron and steel from 2026; aluminium, textiles and tyres in 2027; furniture in 2028; mattresses and electronics in 2029. Foundations in our article on the ESPR regulation.
  • The ban on destroying unsold clothing and footwear, which has applied to large companies since 19 July 2026.
  • The Battery Regulation and its battery passport on 18 February 2027.
  • The Toy Safety Regulation (EU) 2025/2509 and its product passport.
  • The PPWR (EU) 2025/40, applicable since 12 August 2026, including the declaration of conformity for packaging.
  • The GPSR and the duties of the responsible economic operator.
  • CE marking and conformity assessment under the New Legislative Framework.

Put differently: simplification happened where reporting is about the company. Where data has to be maintained about the product, nothing fell away.

Why waiting is expensive when it comes to product data

In many companies the Omnibus triggered an investment pause. For a CSRD reporting project that is understandable — falling out of scope saves real money. For product data the same decision backfires, for three reasons.

First, the deadlines are closer than the debate suggests. The battery passport is less than eighteen months away. The December 2026 EUDR deadline already bites in procurement today, because supplier data takes lead time to collect.

Second, Omnibus IV moves conformity documentation from “may be digital” to “digital as the default”. A declaration of conformity kept as a PDF in a folder is a file, not a data model — and a passport requires structured fields, not attachments.

Third, supply chain demand does not disappear along with scope. The value-chain cap limits what large customers may ask for, but it does not stop them asking. Companies that maintain structured product data answer in hours rather than weeks.

What to do now: five steps

1. Separate company duties from product duties

Draw up two lists. On one goes everything reported about the company (CSRD, CSDDD, Taxonomy) — this is where the Omnibus genuinely delivered relief. On the other goes everything evidenced per product (CE, declaration of conformity, passport, substance data, carbon figures). That second list is unchanged.

2. Check the thresholds instead of estimating them

1,000 employees and EUR 450 million for CSRD, 5,000 and EUR 1.5 billion for CSDDD, 50 tonnes for CBAM. Record whether you are affected indirectly as a supplier — that is the most common misreading.

3. Correct outdated dates

Internal roadmaps, training decks and customer briefings often still carry the old AI Act dates (2 August 2026 / 2027) and the superseded EUDR deadlines. A single pass through the compliance documentation is worth the time.

4. Move the declaration and the instructions into a data structure

Not as a PDF, but as fields: model and type designation, legislation applied, harmonised standards, notified body, date of issue, signatory. These are precisely the fields Omnibus IV will require digitally. Our article on the EU declaration of conformity sets out the mandatory entries.

5. Set up the digital contact point

A permanently reachable electronic channel, with no registration and no app — on the product and in the declaration of conformity. It is the technically simplest of the new duties and the one most often overlooked.

Frequently asked questions

Has the Omnibus abolished or postponed the digital product passport?

No. Neither Omnibus I nor Omnibus IV changes the passport’s timelines, data requirements or scope. Omnibus IV in fact assigns it an additional function: where a passport is already required, the information from the declaration of conformity and the instructions for use is to be held there too.

How many Omnibus packages are there?

Several, and they are substantively independent. The ones relevant to manufacturers are Omnibus I (reporting), the CBAM simplification, the Digital Omnibus (AI Act) and Omnibus IV (product law). The EUDR postponement is often counted alongside them but is a separate act.

My company is now out of CSRD scope — do I still have to supply anything?

Out of the direct reporting duty, yes; out of the supply chain, no. Customers still in scope continue to need emissions, materials and origin data for their inputs. The value-chain cap in the ESRS revision limits how far those requests can go, but it does not end them.

Does Omnibus IV apply yet?

Not fully. The provisional political agreement dates from 9 June 2026; formal adoption and publication in the Official Journal are still outstanding. The direction — digital by default — is settled, but individual deadlines may still shift in the final text.

Does the Omnibus change anything about CE marking?

Nothing about the obligation or its preconditions. Omnibus IV changes the form of the documentation: digital declaration of conformity, digital instructions, digital contact point. Which products need CE marking, and which conformity assessment procedure applies, is unchanged.

Sources

Back to Knowledge Base