01-12-2026 Article

“Reaching Sustainability”: EU Space Act (5) – Sustainability in Space and on Earth

The draft European Space Act (EUSA) covers the areas of space safety, resilience and sustainability. On sustainability the draft introduces progressive provisions not previously addressed in any national space law.

Space sustainability, as addressed in the EUSA, covers both, sustainability in space and sustainability on Earth. The provisions on sustainability in space aim to reinforce space debris mitigation measures and, for the first time, introduce rules on light and radio pollution. For sustainability on Earth, the EUSA for the first time introduces binding obligations to conduct life-cycle assessments of space activities through environmental footprint calculations.

These provisions aim to ensure the sustainable conduct of space activities and to create new opportunities through the definition of in-orbit servicing activities.

In summary:

Sustainability – in Space and on Earth

sustainability, as used in the EUSA, encompasses both sustainability in space and sustainability on Earth
sustainability on Earth means environmental sustainability and the preservation of Earth’s natural environment

Addressees – Who is addressed by the sustainability requirements?

Sustainability in space requirements directly apply to

Union launch operators
Union spacecraft operators to the extent not falling under the research and education exemption
Third-country space operators

Environmental sustainability requirements apply in addition to the above also to Union Launch Site operators, however, Union spacecraft operators are exempted until 31 December 2031 if they qualify as small-sized enterprises or if they fall under the exemption for research and education
Suppliers of any of the foregoing are also (indirectly) affected since

directly addressed stakeholders are required by the EUSA to require their suppliers to provide all necessary data for their EF calculation and declaration obligations
suppliers will need to adapt their products and services to meet new specifications and requirements imposed upon them by the direct Space operators subject to the EUSA

As a result of the foregoing, the entire supply chain is either directly or indirectly affected, not only the space operators and space service providers.

Requirements – What are the main obligations?

Sustainability in space requirements:

Union launch operators: limit planned release of debris into Earth’s orbit, ensure protection against fragmentation, manage end-of-life disposal, and submit a space debris mitigation plan
Union spacecraft operators: limit debris generation, limit accidental fragmentation, implement end-of life disposal measures, adopt a failure disposal plan, submit a space debris mitigation plan and submit a plan to mitigate light and radio pollution.
Third-country space operators: implement above-mentioned measures if not provided for otherwise in international contracts mandated by the EUSA or in case of an equivalence decision by the EC

Environmental sustainability requirements:

Union launch / launch service / spacecraft operators: calculate the environmental footprint (EF) of space activities along the value chain and obtain EF certificates for the authorization process
Third-country space operators: subject to the same requirements unless exempted under an international agreement or an equivalence decision

Emerging activities – In Space services and operations

In-space services and operations (ISOS) activities are, for the first time bindingly regulated in the EU
ISOS covers services performed on assets in space, including tasks such as inspection, rendezvous, docking, repair, refuel, reconfiguration, manufacturing, assembling and disassembling, re-use, recycling, removal and transport of operational, non-operational and debris in space.

EU Council so called “compromise text” as of 5 December 2025

A so called “compromise text” published on 5 December by the Danish Presidency of the Council of the EU introduces changes specifically regarding sustainability, such as:

removal of specific brightness magnitude threshold (≥7) as part of the light and radio pollution provisions;
removal of the requirement to demand adherence from suppliers;
EF verification is assigned to the Qualified Technical Body responsible for assessing technical requirements.
Launch site operators no longer fall within the scope of the EUSA or the environmental sustainability requirements.

In more detail:

I. Sustainability as used in the EUSA

The EUSA defines “sustainability” as sustainability in space and sustainability on Earth, however the text does not provide a definition for sustainability in space.

In light of the reference to UNOOSA Long-term Sustainability Guidelines (LTS Guidelines) in Preamble 7 EUSA, and the parallels between the provisions in the EUSA and the LTS Guidelines, it can be inferred that sustainability in space corresponds to the LTS Guideline description

“the ability to maintain the conduct of space activities indefinitely into the future in a manner that realizes the objectives of equitable access to the benefits of the exploration and use of outer space for peaceful purposes, in order to meet the needs of the present generations while preserving the outer space environment for future generations”.

Sustainability on Earth, on the other hand, is also termed environmental sustainability and consequently specifically targets the Earth´s natural environment (Art. 5/60 EUSA).

1. Union Launch Operators

A launch operator operates a launch vehicle to transport space objects (from Earth to) outer space.

a) Sustainability in Space

Launch operators shall comply with space debris mitigation measures and submit space debris mitigation plans for the launch activities listed in detail in Art. 61 EUSA, inter alia regarding the design of launch vehicles and deployment components with a view to the requirements reflected in Annex II, point 1.1.1 and with the aim to avoid fragmentation due to internal causes or collision.

Union launch operators must also submit space debris mitigation plans at the time of authorisation application, including a debris-control plan, and an end-of-life mission disposal plan.

b) Environmental sustainability requirements

Union launch operators shall calculate the environmental impact of their launch activities (environmental footprint) and submit both aggregated and disaggregated datasets related to this calculation to the EC “before” (with ?) the authorisation application.

The EC will specify the calculation and verification methods considering scientifically sound methods and international standards aligned with the Commission Recommendation 2021/2279 of 15 December 2021 on the use of the Environmental Footprint (EF) methods.

To carry out the EF calculation, the Union launch operator shall contractually require all necessary data needed from suppliers (Art. 96/3 EUSA). Small-sized suppliers are exempt from this contractual obligation until 31 December 2031 (Art. 96/8 EUSA). However, primes are on the other hand NOT exempted from requiring small-sized enterprises to provide such data if the SME is a supplier.

The EF calculation shall cover all stages of the launch activity, including design and development of the launch vehicle, its manufacturing, operation of the launch stage, and completion of the tasks of the launch vehicle orbital stage.

At the time of the authorisation application, the Union spacecraft operator shall submit the EFD, an EF certificate, the aggregated and disaggregated datasets related to the EF calculation and the proof of transmission of those datasets to the EC (e.g. receipt issued by the EC).

Small-sized Union launch operators are exempt from EF calculation and declaration until 31 December 2031.

2. Union Spacecraft Operators

“Spacecraft” means a space object carrying out a specific function in outer space, such as communication satellites, navigation satellites, or Earth observation satellites.

Although not expressly stated in the EUSA, space stations and space vehicles transporting small-sats, cargo, or crew shall also be regarded as spacecrafts, since space transportation and exploration are defined as space activities under the EUSA (Art. 5(13) EUSA).

The EUSA sets out sustainability requirements that must be satisfied prior to authorisation, and Union spacecraft operators are required to demonstrate compliance with these requirements and submit the relevant plans and certification at the time of the authorisation application.

a) Sustainability in space requirements

The Union spacecraft operators shall demonstrate compliance with space debris mitigation measures, and light and radio pollution limitation measures, and shall submit space debris mitigation plans and light and radio pollution limitation plan, in general (not in all detail) as launch operators, as detailed in Art 70 EUSA.

b) Environmental sustainability requirements

Union spacecraft operators shall calculate the environmental impact of their space activities (environmental footprint) and submit the aggregated and disaggregated datasets related to this calculation to the EC before (with?) the authorisation application.

In order to calculate the EF, the Union spacecraft operator is required to demand all needed data from its suppliers (Art. 96/3 EUSA), including, in its current version of the EUSA, from SMEs of all sizes. The EF calculation shall cover all the stages of the space activity that the spacecraft operator is planning to conduct including design and development of the spacecraft, manufacturing phase of the spacecraft, the operation and end of life of the spacecraft.

3. Union Ground Segment Operators

“Ground segment” means the segment of space infrastructure located on Earth, including ground stations, terminals, terrestrial equipment to communicate with space objects, mission control centres, test and assembly centres, launchpad and launch sites.

Union launch site operators are responsible for the operation, control and maintenance of facilities used in the launch process. Sustainability in space requirements on space debris mitigation are primarily directed at launch operators that are responsible for the operation, control and monitoring of the launch process of a space object.

Environmental sustainability requirements, however, are also applicable for launch site operators in addition.

Union launch site operators shall calculate the environmental impact of their space activities (environmental footprint) and submit the aggregated and disaggregated datasets related to this calculation to the EC before the authorisation application. The EC would transmit those datasets in the Union database and issue a proof of receipt to the Union launch site operator.

4. Third-country Space Operators

If no equivalence decision has been issued by the EC for the third-country from which a space operator intends to provide space services or space-based data into the Union, that third-country operator shall in general be subject to the EUSA sustainability requirements.

The following, however, stands out:

If a third-party space operator only provides ground station as a service to the Union spacecraft operator in accordance with the Art 19-c of the EUSA, it shall still be considered as the third-country space operator and subject to environmental sustainability requirements on the EF calculation and declaration.
A third-party space operator that solely provides ground station services to the Union spacecraft operator shall also share all necessary data with the Union spacecraft operator for its EF calculation and declaration.
A third-country space operator providing launch services (third party launch operator) may, upon request by a Member State, be exempted from space debris mitigation measures for launchers if the Member State demonstrates that access to and use of the third-country launch operator is in the public interest of the EU (Art. 19 EUSA).
Third-country space operators that are small-sized enterprises or research and education institutions are (as EU operators) exempt from EF calculation and declaration obligations until 31 December 2031 (Art 15/1,2, Art. 96 EUSA).

5. Indirectly Affected Stakeholders

The EUSA sustainability provisions extend to the Union ground station as a service provider, manufacturers of launch vehicle and spacecrafts, as well as indirectly, to their suppliers within the supply chain.

Union launch operators and Union spacecraft operators, that manufacture their own launch vehicles or spacecraft, are required to impose contractual obligations on their suppliers to ensure that the design and manufacturing of the components align with the EUSA. Accordingly, suppliers are obligated to adopt and remain compatible with the EUSA sustainability in space requirements (Art. 74 EUSA).

Although the EUSA does not explicitly state this, Union spacecraft operators, if they procure the spacecraft from a manufacturer, shall also initiate a contractual obligation with the manufacturer to ensure that the design and components of the spacecraft are EUSA compatible. In such cases, the spacecraft manufacturer and its suppliers must adopt and remain compliant with EUSA sustainability in space requirements.

Although third-country space operators are subject to the same sustainability-in-space requirements, they do not appear to be required to impose contractual obligations on their manufacturers or suppliers to ensure that launch vehicles, spacecraft, and components are EUSA-compliant. This point may require clarification.

Union launch operators, Union spacecraft operators, and Union launch site operators shall require data from their suppliers by contract (as Union space operators are manufacturers of their own launch vehicle/spacecraft) to calculate EF of space activities. In this case, suppliers are under contractual obligations to provide data necessary for the EF calculation (Art. 96/3 EUSA).

Even though this is not explicitly mentioned in the EUSA, if a Union space operator procures the space object from a third-party manufacturer, it shall require by contract from the manufacturer all data necessary for EF calculation. In turn, the manufacturer must also obtain data from its suppliers.

Lastly, the Union ground station as a service provider is not directly subject to the authorization obligation under the EUSA. However, the ground station of a spacecraft operation must be taken into account for EF calculation as part of the operational phase of the space mission. Therefore, it appears that the Union spacecraft operator that purchases ground station services from a Union ground station shall receive all necessary data for EF calculation and declaration.

II. Exemptions and Easements

The EUSA provides exemptions or lighter regimes for certain operators regarding sustainability provisions of the EUSA in Art 10, 62 and 96.

1. Exemptions applicable to Sustainability in Space

Union space operators conducting research and education missions (Union research and education spacecraft operators) are exempted from certain space debris mitigation and light and radio pollution requirements as reflected in Article 62.

The above-mentioned exemptions for Union research and education spacecraft operators also apply to third-country space operators conducting research and education missions.

A third-country space operator providing launch services (third party launch operator) may, upon request by a Member State, be also exempted from space debris mitigation measures for launchers if the Member State demonstrates that access to and use of the third-country launch operator is in the public interest of the EU (Art. 19 EUSA).

2. Exemption from Environmental sustainability requirements

Union spacecraft operators that are small-sized enterprises or research and education institutions conducting In-orbit Demonstration and Validation (IOD/IOV) missions are exempted from EF calculation and declaration obligations (Art. 10/4 EUSA). The EUSA does not provide either a reference or a parallel exemption for third-country space operators in this regard.

The Union spacecraft operators that are small sized enterprises or research and education institutions conducting space operations other than IOD/IOV are exempted from EF calculation and declaration obligations until 31 December 2031 (Art. 96/8 EUSA). By reference to Art. 96 in Art.15/1 for third-country spacecraft operators and in Art. 15/2 for third-country launch and launch site operators, third-country space operators that are small-sized enterprises or research and education institution are likewise exempted from EF calculation and declaration obligations until 31 December 2031.

III. Union Space Label Framework and Voluntary Measures for Sustainability

The EUSA announces that the EC will develop a Union Space Label Framework to promote adherence to high standards for the protection of space activities and will adopt an implementing act to govern the Union Space Label Framework by further legislative action.

1. Implementing Acts and Labelling Schemes

The implementing act is announced to cover a template for the elements and duration of the Union Space Label Scheme and provide the candidate scheme(s) or updates on the existing scheme(s). The Union Space Label schemes aim to harmonize and further develop standards, good practices, and behaviours in the space sector, and to incentivize space operators to adopt them. Holding a Union Space Label would be of particular value to space operators in the context of national public procurement procedures in the Member States (Art. 109/1 EUSA). It would likewise be used for promotional purposes and as evidence to investors of the implementation of sustainability in space and environmental sustainability measures.

The Union Space Label Framework will consist of Union Labelling scheme(s) addressing different requirements including sustainability.

The sustainability in space requirements of the Union Space Label Framework shall be related to the limiting the risks associated to space debris, reducing light and radio pollution, and enabling ISOS.
The environmental sustainability requirement of the Union Space Label Framework shall be related to contributing to the reduction of the environmental impacts of space activities.

The Union Space Label Framework may specify three levels of protection such as basic, substantial or high. All information shall be provided and updated on a dedicated website maintained by the EU Space Agency. The Union Space Labelling Schemes and the Union Space Labels shall also be publicised on the same website.

2. Addressees and procedure

The EUSA does not explicitly specify who the addressees of the Union Space Label are. It only refers to space operators that intend to obtain such a label. The Union Launch operators, the Union spacecraft operators and the third-country space operators shall submit their application to the EU Space Agency accompanied by a technical file showing the fulfilment of the requirements of the Union Space Label Scheme for which the Union Space Label is sought.

The EU Space Agency shall provide an assessment on the application to the EC and the EC shall take the final decision on the application. If the application is approved by the EC, EU Space Agency shall issue Union Space Labels to the applicant operators for a duration specified by the implementing act.

The EU Space Agency shall also supervise the use of the Union Space label by operators. As part of supervision, the Agency shall verify the compliance of the operator with the Union Space Label requirements either on its own initiative or upon receipt of a complaint.

Union launch operators, the Union spacecraft operators, and the third-country space operators that hold a Union Space Label shall inform the Agency in case they detect any irregularities on their labelled space mission that may affect compliance with the Union Space Label scheme(s) requirements.

Greenwashing in space operations is also prohibited by the EUSA. Any false or misleading advertising, or use of the Union Space Label or of a logo that may be confused with a Union Space Label, is not permitted. Member States are asked to adopt effective, proportionate, and dissuasive sanctions for breaches of this obligation, and notify the EC accordingly (Art. 31 EUSA).

IV. ISOS as an Emerging Activity for the Sustainability in Space

ISOS activities refer to services to actively remove a non-functional space object/space debris from the orbital environment. Moreover, this includes docking with a space object to extend its mission life, and examining the condition of the space object by approaching it with a servicing object (rendezvous). In the longer term, ISOS is expected to include in-orbit recycling, manufacturing, assembly, and disassembly of space objects within the orbital environment.

ISOS is defined as one of the disposal methods that a Union spacecraft operator or third-country space operator can use as part of their space debris mitigation measures. The EUSA further provides technical requirements for the authorisation and supervision of ISOS.

1. General principles on the performance of ISOS

To receive ISOS, the Union spacecraft operators or third country space operator’s spacecraft, namely the client objects, shall be equipped with dedicated Spacecraft Service Interfaces (SSI). (Art. 101/3 EUSA)
In order to provide ISOS to a client object, both the Union ISOS provider (servicer) and the client object operator shall conclude a dedicated ISOS contract, and the client object operator shall explicitly and unequivocally consent to the start of the agreed ISOS.

The ISOS contract shall include a dedicated service plan describing the mission concept and infrastructure of both, the client object and the servicer spacecraft.

The client object and servicer spacecraft shall be designed and manufactured, and the ISOS mission shall be designed in a way that limits collision risk.

At the end of the mission, both the servicer spacecraft and the client object shall be left in a sustainable state after the separation.

2. Coordination between the servicer spacecraft and the client object

The control centres of the servicer spacecraft and the client object shall share all necessary data for the ISOS activity in order to ensure coordination.

Unless the client object is a debris, the Union ISOS provider and client object operator shall identify which control centre will be responsible for the conduct of the joint operations for each phase of the ISOS.

3. Design of the servicer object

The design of a servicer object and the service concept of the ISOS provider shall be compatible with the client object, whether it is a functioning spacecraft or debris.

4. Due diligence obligations

The Union ISOS provider shall take all necessary measures to prevent interference with and disruption to a third-party space object. If the ISOS provider cannot prevent interference or disruption, it should adequately mitigate potential adverse impact of ISOS over third-party spacecrafts.

The ISOS provider shall define a safety zone in reference to a third-party space object that will trigger non-engagement or withdrawal of the ISOS mission.

In the event of adverse impact on a third-party space object, the ISOS provider shall immediately notify the operator of the affected object.

The Union ISOS provider shall closely cooperate with collision avoidance service providers, including during the operational phase.

5. Safety of operations

Safety measures for approach, service operation and separation phase are defined in Annex VIII.

For the approach phase, the Union ISOS provider shall set out standby or transit points.

For the service operation phase, the Union ISOS provider shall conduct a GO or NO-GO test at every appropriate sequence defined for the operation and only continue the operation when a GO condition is met.

At each phase (approach, service and separation), the servicer spacecraft shall be able to assess the collision risk between the servicer spacecraft and the client object and autonomously manoeuvre to avoid collision with the client object.

6. Prior testing

Union ISOS providers shall carry out in-orbit tests at least before engaging in the first service operation, or the first step of such an operation. These steps may only be conducted if the servicer object poses no danger to any space object. Before carrying out any irreversible operations (such as deorbiting, disposal manoeuvre, passivation, modification on the client object), the provider must ensure that the test results support safe execution.

V. The Compromise Version of the EUSA Published by the Council of the EU

On 5 December 2025, the Danish Presidency of the Council of the EU proposed a compromise text that proposes changes to the EUSA also regarding space sustainability and environmental sustainability provisions.

It should be noted that this proposal is not yet an official re- draft of the EUSA but an opinion of the (outgoing) Danish presidency of the European Council on the draft EUSA, which has been shared with the public and the European Parliament. A move, which is “special”.

The compromise text proposed changes to the EUSA, also some slight changes to the space debris mitigation measures for launchers, light and radio pollution, and supply chain engagement:

in Art. 61 regarding space debris mitigation measures for launchers, the obligation to design launch vehicles for demise during atmospheric re-entry and for uncontrolled re-entry is removed;
the brightness threshold for satellites under the light and radio pollution provision in Art. 72 is removed;
the obligation for Union space operators to require their suppliers by contract to ensure the conformity of satellites or components with the design and manufacturing requirements is removed (Art. 74).

Moreover, it seems that Union launch site operators are no longer within the scope of the environmental sustainability requirements, as “the launch site operator” is removed from the definition of space operator in Art. 5.

Exemptions and easements regarding sustainability in space and environmental sustainability remain the same; the only change is the redrafting of the provisions under a different chapter titled “Lighter Regime”, in a – allegedly - more compact form to avoid duplication.

VI. Conclusion

The sustainability pillar is the least developed of the three pillars of the EUSA, yet it represents a significant advancement when compared with existing national space laws of the Member States and in other spacefaring countries outside the Union. Light and radio pollution measures, environmental footprint calculation and declaration based on a uniform methodology, and the Union Space Label are provisions introduced to the space sector for the first time.

The mandatory sustainability measures in space and on Earth introduced in the EUSA, aim to ensure the sustainable conduct of outer space activities. The Union Space Label would incentivize good practices and responsible behaviour among space operators. Furthermore, the regulation of in-orbit servicing (ISOS) activities, which contribute to the removal of orbital debris, the extension of spacecraft lifetimes, and the promotion of a circular space economy, would likewise support the sector’s growth.

It should, however, be noted that, while the EUSA provides for bold and ambitious sustainability requirements in the space sector, the EU is in other contexts at the same time taking steps to simplify and reduce the scope of its Earth-related sustainability rules, most notably through the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), and the EU Taxonomy, all revised under the Omnibus package. These adjustments are particularly significant for SMEs, who are being exempted from mandatory reporting obligations, and the data requirements placed on them by companies within the CSRD scope are being reduced.

By contrast, the exemptions and easements on the sustainability requirements introduced under the EUSA for SMEs, remain very limited, and often apply only within a defined timeframe until 31 December 2031. Although the EUSA represents a significant step in integrating sustainability principles into the space sector, the potential technical, administrative, and financial burdens it may impose on operators, particularly SMEs, remain critical concerns. Consequently, it appears to be highly plausible that Omnibus-like easements will be introduced for the EUSA’s sustainability requirements, to strike a balance between ambitious policy objectives and the need to ensure that all SMEs can realistically meet them without being overburdened.

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