Publication of the Environmental Omnibus by the European Commission

On 10 December 2025, the European Commission (EC) published its Environmental Omnibus package [1], comprising six legislative proposals aimed at simplifying administrative and regulatory obligations across EU environmental law. The package, which is the eighth in a series of omnibus initiatives under the Commission’s broader simplification agenda, seeks to enhance the competitiveness of the EU economy by reducing regulatory complexity and unnecessary administrative burden. The publication of the Environmental Omnibus follows a Call for Evidence on the simplification of administrative burdens in environmental legislation, launched on 22 July 2025, which closed on 10 September 2025.

The EC has framed the Environmental Omnibus as a targeted set of amendments to existing environmental legislative instruments, rather than a wholesale revision of environmental policy. Its stated objective is to streamline permitting processes, rationalise reporting and notification requirements, and improve regulatory clarity for both competent authorities and regulated entities, thereby facilitating more efficient implementation and enforcement of environmental law. The package includes a Communication (COM(2025) 980 – Communication: “Simplifying for Sustainable Competitiveness”) and a Staff Working Document, which provides the analytical basis for the package, including stakeholder input, impact considerations, and detailed explanations of the simplification measures proposed. The legislative proposals include:

1. Proposal for a Regulation amending Regulation (EU) 2023/1542 and Regulation (EU) 2024/1244 as regards simplification of some requirements and reduction of administrative burden [2]. This proposal streamlines administrative obligations for industrial operators, including more flexible Environmental Management Systems (EMS) under the Industrial Emissions Directive (IED), removal of transformation plan requirements, extended compliance timelines, and exemptions from certain reporting for farmers and aquaculture operators.
2. Proposal for a Regulation suspending the application of the rules on the appointment of an authorised representative for extended producer responsibility for batteries and waste batteries and packaging and packaging waste [3]. This proposal temporarily suspends the obligation for EU-based producers to appoint authorised representatives in other Member States under Extended Producer Responsibility (EPR) schemes until 2032 for batteries, waste batteries, and packaging, reducing cross-border administrative costs while further EPR streamlining is pending under the Circular Economy Act.
3. Proposal for a Directive suspending the application of the rules on the appointment of authorised representatives for extended producer responsibility for waste, waste electrical and electronical equipment and single use plastic waste [4]. This proposal extends the suspension of authorised representative obligations to additional EPR schemes, including WEEE and single-use plastics, simplifying compliance for producers operating across multiple Member States.
4. Proposal for a Regulation on speeding up environmental assessments [5] (accompanied by an Annex), which introduces simplified and accelerated procedures for environmental assessments, including single points of contact, digitalisation, defined timelines, and a toolbox for strategic sectors and projects contributing to decarbonization.
5. Proposal for a Directive on simplification of certain requirements for the establishment of the Infrastructure for Spatial Information [6], which simplifies geospatial data obligations under the INSPIRE Directive, aligning them with EU horizontal data legislation, removing complex technical requirements, and facilitating access to high-value geospatial datasets for both public authorities and private users.
6. Proposal for a Directive on simplification of some requirements and reduction of administrative burden [7] (accompanied by Annex 1 and Annex 2). This proposal reduces administrative burden across multiple environmental instruments, including the repeal of the SCIP database on hazardous substances in products, as its functions are to be replaced by digital tools such as the Digital Product Passport and the One Substance One Assessment package. Also streamlines reporting and procedural obligations for operators and authorities.

Under the ordinary legislative procedure (OLP), these proposals are now submitted to the European Parliament and Council of the EU for negotiation and adoption.

Further Simplification

Beyond the legislative proposals presented on 10 December 2025, the Commission has made clear that the Environmental Omnibus represents only an initial step in a multi-year simplification process. In this context, the Commission has announced that it will issue non-legislative guidance on the application of key environmental instruments, beginning in early 2026 with the Packaging and Packaging Waste Regulation (PPWR), as well as selected water and nature legislation.

Simplification has also been identified as a central pillar of forthcoming legislative initiatives, including the proposed Circular Economy Act – to be published in Q3 2026 – and the review of the REACH Regulation, both of which are expected to build on the principles articulated in the Omnibus. In parallel, the Commission intends to review and revise the Water Framework Directive, with particular emphasis on simplifying procedures, addressing implementation challenges, and facilitating circularity and access to critical raw materials in the EU.

If you have any questions about the Environmental Omnibus or any or the related proposals, please feel free to contact Ales Bartl (bartl@khlaw.com), Alejandra Martínez Perea (martinezperea@khlaw.com), or your existing contact at Keller and Heckman LLP.

[1] Available online at: https://environment.ec.europa.eu/publications/simplification-administrative-burdens-environmental-legislation_en
[2] Publicly available at the Official Journal of the EU (OJEU): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52025PC0981&qid=1765985380056
[3] Publicly available at the Official Journal of the EU (OJEU): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52025PC0982&qid=1765985452410
[4] Publicly available at the Official Journal of the EU (OJEU): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52025PC0983&qid=1765985588015
[5] Publicly available at the Official Journal of the EU (OJEU): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52025PC0984&qid=1765985780933
[6] Publicly available at the Official Journal of the EU (OJEU): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52025PC0985&qid=1765985835497
[7] Publicly available at the Official Journal of the EU (OJEU): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52025PC0986&qid=1765985892449