Partnerblog
Background
2025 was an interesting year for sustainability from a legislative and policy perspective. The European Commission’s (the « Commission ») focus on competitiveness and simplification has led to the publication of a number of omnibus packages, proposing to simplify existing legislation across several key areas – sustainability, agriculture, digitalisation, defence and chemicals. One such package was the Environmental Omnibus which was announced on 10 December 2025.
The package comprises six legislative proposals targeting simplification of certain EU environmental legislation in four main areas:
(i) industrial emissions;
(ii) circular economy and waste, including extended producer responsibility (EPR);
(iii) environmental assessments and permitting; and
(iv) geospatial data (INSPIRE).
In their Communication on this package the Commission also indicates that future simplification across other environmental legislation is forecast, mentioning in particular the EU Deforestation Regulation, their targeted revision of REACH chemicals legislation and upcoming guidance on the Packaging and Packaging Waste Regulation.
Key changes proposed
A. Industrial emissions
The Commission proposes significant simplification concerning environmental management systems (EMS) and transformation plans under the Industrial and Livestock Rearing Emissions Directive (IED):
- Simplification will allow companies to prepare a single EMS at the company level within a Member State, rather than for each installation. Three additional years will also be given to prepare an EMS and their content requirements will be simplified, removing the independent audit obligation.
- Reporting burdens for livestock and aquaculture operators will be eased, exempting them from certain reporting requirements and permitting Member States to submit information on their behalf.
The precise extent of this simplification will depend on the final legislative text and any implementing guidance. Operators subject to the IED (including energy-intensive and chemicals-adjacent sectors, as well as waste treatment/incineration and large industrial installations) should consider whether these changes, if adopted, would allow consolidation of EMS systems, reduced reporting duplication, and adjusted compliance roadmaps.
B. Circular economy and waste
Two key items under this section include a proposal to repeal the ‘SCIP’ (Substances of Concern in Products) database obligation under EU waste legislation, and a proposed adjustment to EPR authorisations for cross-border sales.
- Repeal of SCIP: the obligation to report to the SCIP database under waste legislation is proposed for repeal due to its limited effectiveness in informing recyclers and its high administrative costs. The Commission plans to address the database’s intended function through the One Substance One Assessment package and the forthcoming digital product passport, which will include information on substances of very high concern.
- Reduced EPR obligations: the proposed changes aim to reduce the administrative burden for producers under Extended Producer Responsibility (EPR) schemes, allowing those selling in other EU Member States to choose whether to appoint authorised representatives for waste management compliance. Existing arrangements can remain, and these steps pave the way for further simplification. The upcoming Circular Economy Act is expected to harmonise and digitise EPR requirements, reduce reporting frequency to once per year, limit the scope of product and waste data reporting and simplify compliance for third-country producers.
- Targeted changes for simplification: A series of targeted changes are proposed to a range of other instruments including the Batteries Regulation. In particular, the amendment of the legal definition of ‘producer’ to capture all selling techniques for distance sellers and to « ensure the right balance between safety and repairability for light means of transport (LMT) batteries and to simplify labelling regarding substances of concern ».
C. Environmental assessments and permitting
The Commission proposes an “umbrella” approach to speed up and improve environmental assessments used in permitting (including for industrial, waste, and chemicals-linked facilities and projects), with the stated aim of faster and more predictable decision-making. This intention had already been announced in the Chemicals Industry Action Plan on 8 July.
Key features include:
- Single points of contact and enhanced coordination between authorities, including for projects with cross-border impacts.
- Greater use of digitalisation and attention to authority capacity and staffing as part of making procedures workable in practice.
- A “toolbox” of measures intended to accelerate key projects (energy, digital, industrial decarbonisation and certain circular projects), including discussion of how to balance overriding public interest, potential forms of tacit approval for intermediate steps, and more expedient dispute resolution at Member State level.
For project developers (manufacturing, energy transition, waste infrastructure, circular projects), this may mean fewer procedural barriers, more structured coordination, and a potential reduction in permitting time. However, some legal and litigation concerns may come into play particularly if “acceleration” measures are perceived to constrain participation rights or environmental safeguards. Companies should expect close scrutiny in Parliament, and a strong focus on compliance with EU environmental principles and access-to-justice expectations.
D. Geospatial data: INSPIRE alignment with EU data rules
The Omnibus also proposes to amend the INSPIRE Directive (EU spatial data infrastructure) to align technical requirements with the Open Data Directive and more broadly, the Digital Omnibus Proposal and the Commission’s approach to data legislation.
Next steps and outlook
The package of proposals is now in the hands of the European Parliament and Council following the ordinary legislative procedure, meaning the content can (and likely will) change during ongoing negotiations.
The Omnibus is a clear signal of the Commission’s intent to deliver administrative simplification in environmental files; however, the legislative debate will likely focus on the tension between streamlining and weakening of environmental safeguards, with permitting acceleration and reporting simplification likely to attract the most attention.
Additionally, the Circular Economy Act (expected in Q3 2026) is intended to deliver simplification and harmonisation across circular activities, and to create a single market for waste and recycled materials. This will further build on proposals of the Environmental Omnibus, including those related to EPR.
Fieldfisher’s EU Regulatory and ESG Team will continue to monitor these developments carefully.
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