Industry Input Sought on Streamlining EU Environmental Legislation through Environmental Omnibus Regulation
On 22 July 2025, the European Commission (EC) launched a call for evidence [1] in preparation for an upcoming regulation—the Omnibus Regulation on Environment—which aims to simplify and streamline administrative requirements in key areas of environmental legislation, including waste, products, and industrial emissions. This initiative is part of the Commission’s broader effort to reduce administrative burdens while maintaining strong environmental protection standards.
This offers a unique opportunity for industry stakeholders to shape and simplify existing frameworks that may be too burdensome. Thus, companies now have a chance to contribute to the rationalisation of initiatives such as Extended Producer Responsibility (EPR) schemes and environmental reporting obligations. We strongly encourage businesses to seize this opportunity and are pleased to support organisations in preparing and submitting their contributions.
The feedback period is open until 10 September 2025, and the Commission is particularly seeking insights and proposals from stakeholders who interact directly with these regulatory frameworks.
Among the potential simplification measures under consideration (list is non-exhaustive) are:
- rationalising reporting/notification obligations, for example, the discontinuation of the SCIP (substances of concern in products) database under the Waste Framework Directive;
- harmonisation of the provisions for authorised representatives for extended producer responsibility (EPR) in each Member State where a producer sells a product falling under EPR rules, and on facilitation of EPR reporting;
- streamlining reporting obligations, removing double requirements to report, promoting further digitalization of reporting in the areas of circular economy, industrial emissions, and waste management, while maintaining the policy objectives;
- addressing permitting challenges relating to environmental assessments based on experience recently gained, such as under the Net Zero Industry Act.
We are available to assist companies in drafting and submitting their feedback to ensure their voices are heard in shaping future policy. Please feel free to contact Ales Bartl (bartl@khlaw.com), Hazel O'Keeffe (okeeffe@khlaw.com), Alejandra Martínez Perea (martinezperea@khlaw.com), or your existing contact at Keller and Heckman LLP.
[1] Call for evidence and feedback submission at the European Commission ‘Have Your Say’ Portal, available online at: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14794-Simplification-of-administrative-burdens-in-environmental-legislation-_en