In short
- EUDR's application date has been amended twice, so almost all published guidance carries a date that never took effect.
- The PPWR empty space figure in circulation is wrong on both the number and the year: it is 50 percent, from 2030 at the earliest.
- Two widely quoted items do not exist at all: a EUR 225 million CSRD balance sheet limb, and sector-specific ESRS due in June 2026.
Six dates and thresholds circulate widely in sustainability guidance and do not match the primary sources. Two are superseded because the law moved and the guidance did not. Two are wrong twice over, on both the number and the year. One describes a scheme as arriving two years after it actually arrived. And one is a threshold that does not appear anywhere in the enacted text. Each entry below states the version in circulation, the position we verified, and the instrument to check it against.
No publishers are named here. Most of these errors were correct when they were written, and several we have made ourselves.
Which dates are wrong, at a glance?
- The version in circulation: EUDR applies from 30 December 2025
The verified position: 30 December 2026, and 30 June 2027 for a narrow group of small operators
Where to check: Reg. (EU) 2025/2650, replacing Article 38 in full - The version in circulation: PPWR caps empty space in parcels at 40 percent from 2026
The verified position: The maximum empty space ratio is 50 percent, from 1 January 2030 at the earliest
Where to check: Reg. (EU) 2025/40, Article 24(1) and 24(2) - The version in circulation: The CO2-Prestatieladder's new handbook arrives in 2027
The verified position: Handboek 4.0 was published 14 January 2025. January 2027 is the end of the transition
Where to check: SKAO Overgangsregeling 3.1 to 4.0, v1.1 - The version in circulation: The Dutch WPM norm of 96 g CO2 per passenger kilometre applies from 2025
The verified position: It sits in provisions never brought into force and could not bite before 2030
Where to check: Art. 18.12 Besluit activiteiten leefomgeving, and the April 2026 nota van toelichting - The version in circulation: CSRD scope is a two-of-three test including a EUR 225 million balance sheet
The verified position: Two tests, both must be exceeded: EUR 450 million net turnover and 1,000 employees
Where to check: Arts. 19a(1) and 29a(1) of Dir. 2013/34/EU as amended by Dir. (EU) 2026/470 - The version in circulation: Sector-specific ESRS are due on 30 June 2026
The verified position: The empowerment to adopt them was deleted. Only non-binding guidance remains possible
Where to check: Dir. (EU) 2026/470, deleting the third subparagraph of Art. 29b(1)
Why is the EUDR date the worst one?
Because it moved twice, four days short of two consecutive Decembers, so both wrong versions had time to become the consensus.
Article 38(2) of Regulation (EU) 2023/1115 originally read 30 December 2024. Regulation (EU) 2024/3234 of 19 December 2024 replaced it with 30 December 2025. Regulation (EU) 2025/2650 of 19 December 2025 replaced Article 38 in full and set 30 December 2026. Neither of the first two dates ever took effect. A narrow deferral runs to 30 June 2027 for operators who are natural persons or micro or small undertakings established as such by 31 December 2024, and that deferral excludes products covered by the Annex to the old EU Timber Regulation.
The volume problem is that anything published before late December 2025 describes a date that no longer exists, and that is most of what a search returns. Two secondary errors travel with it: that another delay is coming, which the Commission's simplification review of 4 May 2026 declined to deliver, and that EUDR requires a carbon calculation, which it does not. It asks for the geolocation of plots and evidence of legal production, and never for an emissions figure.
Why is the packaging figure wrong twice?
Because the number and the date both come from somewhere else in the regulation.
The claim in circulation is that PPWR caps empty space in e-commerce parcels at 40 percent from 12 August 2026. Article 24(1) of Regulation (EU) 2025/40 sets the maximum empty space ratio at 50 percent, and it applies from 1 January 2030, or three years from the entry into force of the implementing act adopted under Article 24(2), whichever is later. That implementing act is not itself due until 12 February 2028.
The date confusion has an obvious source: 12 August 2026 is real, and it is the date PPWR started applying. What began then is narrower than the coverage suggested, chiefly the PFAS limits on food-contact packaging and the heavy metal limits. Recyclability grading, recycled content, packaging minimisation, banned formats and reuse targets are 2030 obligations; harmonised labelling is 2028.
Why does the Dutch ladder keep arriving in 2027?
Because two dates share a day and a month, and the wrong one is the memorable one.
Handboek 4.0 of the CO2-Prestatieladder was published on 14 January 2025, and certifying bodies could audit against it from 14 July 2025. The transition period runs 24 months from publication, so it ends on 14 January 2027. A source that has seen "14 januari" next to "2027" reports a handbook landing in 2027, and every page that copies it inherits the error.
The correction matters because of what the wrong version implies. It tells a Dutch contractor there is time to do nothing, when in fact three quarters of the transition is already spent and the binding date is that contractor's own first audit after January 2027, not January 2027 itself. It also makes the Dutch market look two years less advanced than it is. The scheme is not new: ProRail has applied the ladder as an award criterion since 1 December 2010. What changes in 2027 is the handbook version, not the existence of the criterion.
Which Dutch norm has never been in force?
The 96 grams of CO2 per passenger kilometre that gets described as arriving "vanaf 2025".
The figure is real and it is written into Article 18.12 of the Besluit activiteiten leefomgeving as an emission limit value for business mobility. The relevant provisions have never been brought into force. The ministry's own April 2026 explanatory note puts the earliest possible bite at 2030 and says the value would most likely have to be revised first. The 2022 Green Deal Duurzame Zorg text still carries the "vanaf 2025" framing in a footnote, which is one route by which it entered general circulation.
What WPM actually requires today is a reporting duty, not a cap: employers file kilometres by travel mode and fuel type, and the ministry converts them into CO2 itself to monitor a sector-wide ceiling. No individual employer is subject to a CO2 norm under it.
Which CSRD numbers do not exist?
A EUR 225 million balance sheet limb, and a two-of-three scope test to put it in.
Since Directive (EU) 2026/470 of 24 February 2026, Articles 19a(1) and 29a(1) of Directive 2013/34/EU apply to undertakings that exceed a net turnover of EUR 450 000 000 and an average of 1 000 employees during the financial year. The conjunction in the enacted text is "and": both tests must be exceeded. There is no balance sheet criterion in it at all. The two-of-three structure belongs to a different definition, the "large undertaking" test in Article 3(4) of the same directive, whose balance sheet limb is EUR 25 million.
The practical effect of getting this wrong is large in both directions. A company with EUR 2 billion of turnover and 600 employees is out. A company with 4,000 employees and EUR 300 million of turnover is also out. Anything written against the pre-2026 thresholds overstates scope substantially, and listed SMEs were removed from the regime entirely.
The related error is the one about standards. Sector-specific ESRS are still described as due on 30 June 2026. Directive (EU) 2026/470 deleted the third subparagraph of Article 29b(1), which was both the empowerment to adopt them and the source of that deadline. The Commission may issue non-binding sector guidance instead, and none is promised on a date.
What should you do with a date you have been given?
Three habits, and they are cheap.
Ask which instrument it came from. A date without an act behind it is a date somebody copied. For EU regulations, look for the amending act, because the original text usually still shows the superseded date.
Date your own notes. Every entry above was true in some document at some point. What makes it wrong is being repeated after the amendment. A compliance calendar without a last-checked date on each row cannot tell you which rows have aged.
Recheck anything that has moved before. Both EUDR amendments landed days before the dates they replaced.
Where does this leave a compliance calendar?
Shorter than you expect. Three of the six corrections remove work rather than add it: the packaging cap is four years further out than advertised, the Dutch norm is not in force, and the CSRD thresholds exclude most companies that were preparing to report. That is a net reduction, and it is worth capturing before you budget against a list you inherited.
If you want to build the underlying inventory once and point several requesters at it, that is what the Hedgehog platform is for, and a free account needs no sales call. It reports 5,000+ users. One limitation to set expectations by: a small business reviewer on G2 in August 2026 noted there is no forecasting, and that Hedgehog had said it was on the development list. If the questions are arriving from customers rather than regulators, the value chain cap on ESG questions explains what you may decline, and the VSME standard is the report-once format built for it.
Sources: Regulation (EU) 2023/1115, Regulation (EU) 2024/3234, Regulation (EU) 2025/2650 and Regulation (EU) 2025/40 as published in the Official Journal; Directive 2013/34/EU as amended by Directive (EU) 2026/470; SKAO Overgangsregeling 3.1 to 4.0 v1.1 and the ProRail supplier page; Staatsblad 2023 nr. 472, Article 18.12 of the Besluit activiteiten leefomgeving and the April 2026 nota van toelichting; COM(2026) 191 final of 4 May 2026. Hedgehog facts from the Hedgehog platform and Hedgehog on G2. Verified 28 August 2026, recheck due 28 November 2026.
Facts on this page were last verified on 2026-08-28.
