The EU Omnibus Regulation: Should Food Businesses Put Scope 3 Efforts on Hold?

The Foodsteps TeamThe Foodsteps Team
By
The Foodsteps Team
February 20, 2025
Articles
February 20, 2025
{1} min read

The European Commission is expected to unveil the Omnibus Regulation on February 26, 2025, in response to growing concerns about the complexity of ESG regulations. At first glance, food businesses may feel inclined to deprioritise compliance efforts or delay investment in reporting tools until clearer information is available. However, postponing action could be a costly mistake.

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The European Commission is expected to unveil the Omnibus Regulation on 26 February, 2025, in response to growing concerns about the complexity of ESG regulations. 

This proposal is anticipated to simplify sustainability reporting obligations, particularly under The Corporate Sustainability Reporting Directive (CSRD), The Corporate Sustainability Due Diligence Directive (CSDDD) and The EU Taxonomy.

At first glance, food businesses may feel inclined to deprioritise compliance efforts or delay investment in reporting tools until clearer information is available. However, postponing action could be a costly mistake. Here’s what food businesses need to know about the EU Omnibus Regulation and why delaying reporting efforts is not advisable. 

What is the EU Omnibus Regulation? 

The Omnibus Regulation is a forthcoming proposal aimed at simplifying and consolidating sustainability reporting obligations across three key EU regulations:

  • Corporate Sustainability Reporting Directive (CSRD): Requires companies to disclose environmental, social, and governance (ESG) impacts, risks, and management strategies.
  • Corporate Sustainability Due Diligence Directive (CSDDD): Mandates businesses to identify and mitigate adverse human rights and environmental impacts across their supply chains.
  • EU Taxonomy for Sustainable Activities: Defines environmentally sustainable economic activities to guide investors and businesses.

What changes might the EU Omnibus Regulation introduce?

While the exact details of the EU Omnibus Regulation are yet to be confirmed,  proposed changes may include timeline adjustments, revised compliance obligations, and a focus on material disclosures to ease administrative burdens, particularly for SMEs and mid-sized firms. Proposed changes include: 

  • Reduced reporting burden – The EU targets a 25% reduction for large companies and 35% for SMEs, which could mean fewer data points, reduced administrative costs or other measures. A 25% reduction is expected to cut recurring administrative costs by EUR 37.5 billion.
  • Simpler reporting for SMEs – Discussions suggest exempting smaller suppliers from certain due diligence requirements, shifting focus to highest-risk activities to simplify compliance.
  • New “small mid-cap” category – Lighter reporting has been suggested for firms with 250–1,500 employees and sales below €1.5B.
  • Potential compliance timeline shifts – Germany and France have pushed for a two-year postponement of CSRD and CSDDD, mainly to ease the burden on SMEs.

Can food businesses cut back on Scope 3 tracking in the meantime?

With uncertainty around regulations, some businesses may consider deprioritising Scope 3 to cut costs. But there’s no evidence that Scope 3 reporting requirements will change—and for food businesses, Scope 3 still accounts for up to 95% of emissions. Measuring remains essential, not just for compliance, but for making real progress on decarbonisation and Net Zero. Here’s why:

1. Compliance risks and inefficiencies still exist.

  • Regulations aren’t going away – CSRD rules still apply today, and even if the Omnibus Package introduces delays or simplifications, sustainability reporting requirements remain. Pausing efforts now puts your business at risk of falling behind.
  • Year-on-year reporting matters – Regulations like CSRD require reporting on past financial years. Gaps in data today will create inefficiencies in future disclosures, regardless of regulatory changes.
  • Global standards still demand strong ESG data – Even if the EU eases requirements, frameworks like ISSB and SEC rules continue pushing for robust sustainability disclosures.

2. Sustainability is a business advantage.

  • Customers, investors, and partners expect transparency – ESG remains a core focus. Scaling back efforts could damage trust and competitiveness.
  • Retailers and foodservice operators require supplier data – Delayed action risks exclusion from major supply chains.

3. The climate crisis won’t wait.

  • Global warming has already surpassed 1.5°C – The window for meaningful action is closing fast.
  • Delays are no longer justifiable – The best time for action was yesterday. The next best time is now.

How Foodsteps can help your business measure, report and reduce impact at scale

Measure emissions with unparalleled precision – Gain the most accurate view of your value chain impact with country-specific emissions factors and advanced modelling. Our system efficiently processes millions of data points, ensuring precise, scalable assessments.

Streamline reporting and compliance – Reduce reporting burdens with high-quality emissions data that enhances your primary data. Automate Scope 3 assessments, stay aligned with evolving regulations, and free up valuable time for your team.

Drive decarbonisation with confidence – Develop targeted, data-driven decarbonisation strategies with support from Foodsteps’ in-house scientists and professional services team. Track year-over-year progress with consistent, high-quality metrics to drive meaningful impact.

Interested in learning more?

Discover how Compass Group achieved a -9.4% emissions reduction while growing by 20% with Foodsteps' data-driven approach.

Download our Scope 3 whitepaper today.