COMMISSION STAFF WORKING DOCUMENT Accompanying the document Communication from the Commission to the european Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Simplifying for sustainable competitiveness [Mandatory element]
Date: 2025-12-10
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, administrative formalities, circular economy, competitiveness, environmental impact, environmental protection, industrial pollution, simplification of legislation

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 10.12.2025  SWD(2025) 990 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document Communication from the Commission to the european Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Simplifying for sustainable competitiveness [Mandatory element] {COM(2025) 980 final}  
 
 
Table of contents 

INTRODUCTION ................................................................................................................................4 
1. 
STAKEHOLDER INPUTS .................................................................................................................5 
2. 
2.1.  OVERVIEW OF CONSULTATION ACTIVITIES .........................................................................5 
2.2.  CALL FOR EVIDENCE .....................................................................................................................6 
2.3.  BROAD STAKEHOLDER VIEWS ...................................................................................................6 
SCOPE OF THE PROPOSAL ............................................................................................................7 
3. 
4. 
SIMPLIFICATION MEASURES ......................................................................................................7 
4.1.  REPORTING OF CHEMICALS OF CONCERN (SCIP DATABASE).........................................7 
4.2.  WASTE REPORTING UNDER THE WASTE FRAMEWORK DIRECTIVE ............................9 
4.2.1. IMPLEMENTING ACT ON INDICATORS ON WASTE PREVENTION ...................................9 
4.2.2. DATA QUALITY REPORTS .............................................................................................................9 
4.3.  EXTENDED PRODUCER RESPONSIBILITY ............................................................................. 10 
4.3.1. AUTHORISED REPRESENTATIVES ........................................................................................... 10 
4.3.2. REPORTING BY PRODUCERS (REDUCING/HARMONISING THE FREQUENCY).......... 12 
4.4.  BATTERIES REGULATION ........................................................................................................... 13 
4.5.  REQUIREMENTS FOR ENVIRONMENTAL MANAGEMENT SYSTEMS UNDER THE 

IED ...................................................................................................................................................... 14 
4.5.1. DETAILED ANALYSIS OF COST SAVINGS ............................................................................... 15 

ERROR!  HYPERLINK  REFERENCE  NOT  VALID.15ERROR!  HYPERLINK  REFERENCE 
NOT  VALID.16ERROR!  HYPERLINK  REFERENCE  NOT  VALID.17ERROR! 
HYPERLINK REFERENCE NOT VALID.17ERROR! HYPERLINK REFERENCE NOT 
VALID.174.6.PERMITTING 
IRON 
IED ...................................................................................................................................................... 18 
4.7.  PERMITTING OF OXY-FUEL COMBUSTION ........................................................................... 18 
4.8.  PERMITTING OF HYDROGEN COMBUSTION ........................................................................ 19 
4.9.  TRANSITIONAL  PROVISIONS  FOR  CERTAIN  IED  PROVISIONS  APPLICABLE  TO 

PRODUCTION 

UNDER 

OF 

INDUSTRIAL INSTALLATIONS ................................................................................................... 19 

THE 

4.10.  SIMPLIFICATION FOR LIVESTOCK FARMS UNDER THE INDUSTRIAL EMISSIONS 

DIRECTIVE ....................................................................................................................................... 20 

4.11.  LIVESTOCK  AND  AQUACULTURE  OPERATORS  REPORTING  TO  THE 

INDUSTRIAL EMISSIONS PORTAL ............................................................................................ 20 
4.12.  BACK-UP GENERATORS............................................................................................................... 21 
4.13.  SPATIAL INFORMATION REQUIREMENTS ............................................................................ 22 
4.14.  ENVIRONMENTAL ASSESSMENTS STREAMLINING AND ACCELERATION ................ 24 
4.14.1. 
SECTORS FOR PRIORITY ACTION .................................................................................. 24 
4.14.2. 

“SINGLE  POINT  OF  CONTACT” AND  COMBINED  ENVIRONMENTAL 
ASSESSMENTS ................................................................................................................................. 24 
4.14.3. 
“REASONABLE ADMINISTRATIVE COSTS FOR PERMITTING” ............................. 25 
4.14.4.  MAXIMUM DURATION OF ASSESSMENTS, TIMELINES............................................ 25 
CROSS-BORDER DIMENSION ............................................................................................ 27 
4.14.5. 
DIGITAL SUBMISSIONS ....................................................................................................... 27 
4.14.6. 

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EFFECTIVE JUDICIAL PROCEEDINGS ........................................................................... 28 
4.14.7. 
PRIORITY FOR STRATEGIC SECTORS ........................................................................... 28 
4.14.8. 
4.14.9. 
ASSESSMENT OF IMPACTS ................................................................................................ 28 
4.15.  OVERALL IMPACTS ...................................................................................................................... 31 
ANNEX 1: PROCEDURAL INFORMATION ............................................................................................. 33 
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ................................................. 35 

ANNEX 3: LIST OF MAIN SUGGESTIONS FOR SIMPLIFICATION MADE VIA THE CALL FOR 

EVIDENCE.......................................................................................................................................... 52 
ANNEX 4: WHO IS AFFECTED AND HOW? ........................................................................................... 63 

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1.  Introduction  

The Political Guidelines 2024-2029 | European Commission highlight simplification and better 
implementation  of  EU  rules  as  core  to  making  business  easier  and  faster  in  Europe. The 
Commission  has  made  simplification,  reducing  the  reporting  burden  and  simplifying 
legislation its top priorities for the next five years. The Political Guidelines also underline that 
EU must and will stay the course on all of our goals, including those set out in the European 
Green Deal1. 

As  highlighted  in  his  report  on  ‘The  Future  of  European  Competitiveness’,  Mario  Draghi 
emphasised that the transition to a low-carbon, resource-efficient, and circular economy will 
also  be  essential  for  securing  the  EU's  long-term  economic  prosperity,  resilience,  and 
competitiveness.2 However, to unlock the full potential of this transition, a cohesive and well 
executed strategy will be crucial, including fostering the role of public and private finance in 
supporting  the  transition.  With  the  Competitiveness  Compass  for  the  EU,  the  Commission 
presented this strategy for the next five years.3 

The Compass identifies the policy changes that are needed for the EU to step up to the new 
realities  and  develop  novel  ways  of  working  together  to  increase  the  speed  and  quality  of 
decision-making. A pivotal  point to  achieve this will be the simplification of the regulatory 
environment and the reduction of burden. The Compass, therefore, sets the target of cutting 
administrative burden by at least 25% for all companies and at least 35% for small and medium-
sized enterprises (SMEs) without undermining the respective policy goals. 

Meeting the goal requires cutting recurring administrative costs by EUR 37.5 billion by the end 
of the mandate with dedicated measures for SMEs. Since February 2025, the Commission has 
put forward seven omnibus proposals and other simplifications proposals bringing over EUR 
10 billion annual administrative costs savings in areas of key interest for businesses including 
sustainability  reporting,  investments,  small  mid-caps,  agriculture,  defence,  chemicals  and 
digital. These  proposals  include  specific  measures  to  relieve  SMEs  and  are  currently  being 
negotiated by the co-legislators. 

The Commission is therefore pursuing an ambitious programme, to make Europe an even more 
desirable place to live, work and invest. This includes measures to lighten the regulatory load 
for people, businesses and administrations. This package is meant to ensure that environmental 
policies are easier and cheaper to implement, and so to ensure that they happen on the ground. 
Simplifying  and  improving  EU  policies  and  laws,  will  make  rules  clearer  and  easier  to 
understand and faster to implement.  

This Staff Working Document (SWD) accompanies a simplification Omnibus package related 
to  administrative  obligations  in  the  environmental  field,  and  managed  by  the  Directorate-
General  for  the  Environment,  and  covers:  (1)  the  input  and  feedback  received  from 
stakeholders during the consultation process; (2) the legislation covered; (3) the simplification 
measures  to  streamline  the  regulatory  framework,  while  maintaining  the  objectives  of  the 
legislation and removing unnecessary complexity, along with a quantification of the expected 
savings.  

1 The European Green Deal - European Commission 
2 The Draghi report on EU competitiveness 
3  Communication  from  the  Commission  to  the  European  Parliament,  the  European  council,  the  Council,  the 
European  Economic  and  Social  Committee  and  the  Committee  of  the  Regions,  COM  (2025)  30  final:  A 
Competitiveness Compass for the EU. 

3 

 
 
 
 
2.  Stakeholder inputs 

The need for simplification has been actively raised by many stakeholders both in the EU and 
outside, public authorities and business. The Commission engages with these stakeholders  - 
industry, and national authorities as well as NGOs - with a view to receiving their feedback and 
suggestions to improve the functioning of legislation. 

2.1. Overview of consultation activities 

The Commission is in frequent dialogue with stakeholders about new and existing legislation. 
Much of the legislation under the scope of this proposal has been subject to an evaluation or 
fitness check or an impact assessment, also based on public consultations, in accordance with 
the Commission’s Better Regulation agenda4. These are published together with the evaluation 
reports or proposals they accompany and can be accessed from the Have Your Say portal5. As 
the issue of simplification and reducing administrative burden has been subject to considerable 
discussion,  the  Commission  has  received  numerous  position  papers  and  inputs  including  as 
feedback to a call for evidence on simplification covering all legislation. 

This initiative is of potential interest to relevant industrial/economic actors, including SMEs, 
public bodies (e.g. administrations in charge of implementing environmental legislation), non-
governmental organisations (such as environmental groups or consumer bodies), international 
organisations,  and  academia.  The  consultation  activities  aimed  to  reach  all  interested 
stakeholder groups. 

The Commission has also considered the consultation activities carried out by the consultants 
working  on  the  ongoing  study6  on  environmental  reporting  and  other  administrative 
obligations. The study will be published in early 2026, while consultation activities as part of 
the study were relevant for this initiative and were taken into account. The study also includes 
analyses of some of the  measures  included in  this  proposal  and sets  out  the assumptions in 
further detail.  

The following consultation activities have been carried out to prepare this omnibus package: 

-  An online webinar on environmental reporting (carried out  by the consultant) on 13 
February 2025 and an online survey of the participants to the above webinar who had 
agreed to be contacted for its purpose. 

-  A call for evidence7  for the environmental omnibus  open for feedback from  22 July 

2025 to 10 September 2025. 

-  A high-level roundtable on simplifying environmental laws on 2 October 2025. 
-  An  Implementation  dialogue  with  Commissioner  Roswall  on  Environmental 
Assessment  and  Permitting  on  10 April  2025,  and  an  Implementation  dialogue  with 
Commissioner  Jørgensen  on  permitting  in  the  clean  energy  transition;  public 
consultations  for  the  Grids  and  Industry Accelerator  acts  (concerning  environmental 
permitting aspects). 

-  An online meeting of the EIA/SEA Expert Group on environmental assessments and 

permitting on 13 June 2025. 

4 https://commission.europa.eu/law/law-making-process/better-regulation_en  
5 https://ec.europa.eu/info/law/better-regulation/have-your-say_en    
All evaluations, fitness checks, and  impact assessments of  policy proposals by the Commission are published 
together with the results of the associated public consultations and  any policy proposal on the Have Your Say 
portal.  
6 Environmental Reporting and Simplification - Trinomics 
7 Simplification of administrative burdens in environmental legislation 

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-  A Call for evidence8 on the revision of the Inspire Directive (GreenData4All initiative), 

open for feedback from 26 February 2024 to 25 March 2024. 

-  A public consultation9 on the revision of the Inspire Directive from 05 February 2025 

to 30 April 2025. 

-  Meetings  and  exchanges  with  stakeholders  concerning  simplification  in  the  area  of 

environmental policy, reported in the EU Transparency Register. 

Overall, consultations about simplification of environmental legislation drew a lot of attention, 
including from the wider public, while the consultations on the Inspire Directive drew a more 
specialised audience. 

The online workshop held on 13 February 2025 had 500 registrants and more than 300 active 
participants10.  The  follow-up  targeted  consultation  led  to  more  than  500  inputs,  many  of  a 
specific nature. Several  of the proposed simplifications  in the omnibus respond to the input 
received.  

The call for evidence on environmental simplification drew considerable attention (see below).  

A detailed report on all consultation activities is provided in annex 2 (synopsis report). 

2.2. Call for evidence 

The Commission published a call for evidence on the environmental simplification package on 
the  Have-Your-Say  website:  Simplification  of  administrative  burdens  in  environmental 
legislation. The feedback period was from 22 July 2025 till 10 September 2025. As the call 
began during July  2025, the feedback period was extended from the standard 4 weeks to  7 
weeks  to  compensate for partially running in the Summer. All  feedback is published on the 
Have-Your-Say website. 

There were 190 998 contributions, of which 189 751 (99.3%) came from citizens with many 
of  these  prompted  via  campaign  websites  (mainly  linked  to  a  #handsoffnature  campaign). 
There  were  1 247  contributions  from  entities  other  than  citizens,  including  businesses  and 
business  associations,  non-governmental  organisations  (environmental  and  other),  public 
authorities and academics. There were 622 attachments, mainly position papers, attached to 
these submissions, which often included specific suggestions. 

2.3. Broad stakeholder views 

From  a  business  perspective,  there  is  support  for  less  burdensome  regulation  that  leaves 
business  with  flexibility  to  deliver  both  growth  and  sustainable  production.  There  is  a 
perception  of  administrative  obligations  that  are  too  prescriptive,  and  do  not  provide  value 
added.  Yet,  business  stakeholders  largely  underline  that  they  agree  with  goals  of  EU 
environmental laws but urge that they should be achieved in a simplified way. 

On the side of civil society, there is support for a simplification that makes it easier to protect 
the environment and human health standards and avoid deregulation, for example by removing 
redundancies and avoiding excessively detailed regulations. The numerous citizens expressed 
concerns  that  efforts  to  simplify  regulations  could  undermine  environmental  protections, 
emphasising the current legal framework's importance and success. They urged the EU to focus 
on enforcing  existing  laws rather than creating new simplifications.  Citizens  also expressed 

8  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13170-GreenData4All-updated-rules-
on-geospatial-environmental-data-and-access-to-environmental-information_en 
9 GreenData4All – updated rules on geospatial environmental data and access to environmental information 
10 Environmental Reporting and Simplification - Trinomics 

5 

 
 
 
concerns about transparency and democratic processes in regulatory simplifications, with calls 
for  transparent  decision-making,  adequate  consultation,  and  maintaining  rigorous  impact 
assessments.  

3.  Scope of the proposal 

This omnibus package covers legislation in the area of the environment, specifically: 

•  Directive  2008/98/EC  on  waste,  hereafter  referred  to  as  the  Waste  Framework 

Directive11, 

•  Regulation (EU) 2023/1542 concerning batteries and waste batteries, hereafter referred 

to as the Batteries Regulation12 

•  Directive 2010/75/EU on Industrial and Livestock Rearing Emissions13 as amended by 
Directive (EU) 2024/1785, hereafter referred to as the Industrial Emissions Directive14 
•  Regulation  (EU)  2024/1244  on  reporting  of  environmental  data  from  industrial 
installations, establishing an Industrial Emissions Portal 15, hereafter referred to as the 
Industrial Emissions Portal 

•  Directive (EU) 2015/2193 on the limitation of emissions of certain pollutants into the 
air from medium combustion plants, hereafter referred to as the Medium Combustion 
Plants Directive16 

•  Directive  2007/2/EC  establishing  an  Infrastructure  for  Spatial  Information  in  the 

European Community, hereafter referred to as INSPIRE17 

The environmental omnibus simplification package also includes a proposal for a Regulation 
on speeding up environmental assessments, that will speed up permitting and cut costs. 

4.  Simplification measures 

This section provides a description of the change being made, an analysis of the associated 
reduction in costs and the safeguards to environmental performance.  

4.1. Reporting of chemicals of concern (SCIP database) 

SCIP is the database for information on Substances of Concern In articles as such or in complex 
objects (products) established under the Waste Framework Directive (WFD)18.   

11  Directive  2008/98/EC  of  the  European  Parliament  and  of  the  Council  of  19  November  2008  on  waste  and 
repealing certain Directives as last amended by Regulation (EU) 2023/1542. 
12 Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries 
and  waste  batteries,  amending  Directive  2008/98/EC  and Regulation  (EU) 2019/1020  and  repealing  Directive 
2006/66/EC.  
13 Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial and 
livestock rearing emissions (integrated pollution prevention and control). 
14 Directive (EU) 2024/1785 of the European Parliament and of the Council of 24 April 2024 amending Directive 
2010/75/EU  of  the  European  Parliament  and  of  the  Council  on  industrial  emissions  (integrated  pollution 
prevention and control) and Council Directive 1999/31/EC on the landfill of waste.  
15 Regulation (EU) 2024/1244 of the European Parliament and of the Council of 24 April 2024 on reporting of 
environmental  data  from  industrial  installations,  establishing  an  Industrial  Emissions  Portal  and  repealing 
Regulation (EC) No 166/2006.  
16 Directive (EU) 2015/2193 of the European Parliament and of the Council of 25 November 2015 on the limitation 
of emissions of certain pollutants into the air from medium combustion plants. 
17  Directive  2007/2/EC  of  the  European  Parliament  and  of  the  Council  of  14  March  2007  establishing  an 
Infrastructure for Spatial Information in the European Community (INSPIRE).  
18 Article 9(1)(i) and 9(2) of the Waste Framework Directive, as amended by Directive (EU) 2018/851, mandates 
the European Chemicals Agency (ECHA) to establish a database of substances of very high concern. The Articles 
include a reference to Article 33(1) of the REACH Regulation. 

6 

 
 
 
The SCIP notification obligation for companies applies from January 2021 and was intended 
to help waste operators and recyclers to safely manage hazardous substances in products at the 
end  of  their  life. The  obligation  falls  on  an  enterprise  that  produces,  assembles,  imports  or 
distributes  an  article  that  contain  substances  of  very  high  concern  (SVHCs)  on  ECHA’s 
Candidate List in a concentration above 0.1 % by weight. In these cases, the enterprise needs 
to notify them to the SCIP database maintained by the European Chemicals Agency (ECHA). 
The data covers the concentration range and location of the Candidate List substances present 
in the article, and information that allows its safe use – notably information to ensure the article 
is  properly managed once it becomes waste. The information  in  the SCIP database is  made 
publicly available, in particular to waste operators and consumers.  

Stakeholders expressed doubts about the usefulness and effectiveness of the SCIP database for 
waste operators and consumers19. They note that relatively little use is made of the database, 
with the number of online ‘hits’ being low. This may reflect the data being too complex to be 
meaningful for the target audience and a perception that it provides little added value over and 
above  other  means  of  information  provision  (such  as  labels).  The  data  is  also  seen  as 
duplicating  REACH Article  33(1)  on  obligations  and  so  creating  disproportionate  burdens 
without benefit especially for space products and B2B transactions. It is noted that the database 
was not part of the Commission’s original proposal, and the amendment by the co-legislators 
was not subject to an Impact Assessment prior to its inclusion in the final legal text.  

Apart from the provision of data through REACH, there are also other changes that will provide 
this  information  better  in  the  future.  The  progressive  rollout  of  the  digital  product  passport 
under  the  ESPR  from  2027,  as  well  as  under  other  legislation  (e.g.  Toys  Regulation)  will 
provide some of this information in a more impactful manner.  With the adoption of the One 
Substance, One Assessment legislative package, work is ongoing to set up by 2030 a Common 
Data Platform on Chemicals. This will make information on substances of very high concern 
and  the  web  portal  for  data  in  the  digital  product  passport  easily  available. Thanks  to  data 
reported  by  the  Member  States’  authorities  and  by  businesses  this  information  will  also  be 
better organised and more easily accessible. The use of the digital product passports and in the 
future more comprehensive ESPR labels will further limit the future additional benefit of the 
database. Overall, the environmental and health impact of repealing the database seems 
negligible.  

Whilst not fully in operation or at full compliance yet, the number of submissions to the SCIP 
database  is  increasing.  Data  from  March  2022  showed  24  million  notifications  from  7  600 
entities,  with  a  small  number  of  companies  responsible  for  a  large  share  of  the  volume  of 
notifications. Around 500 000 entities could have to submit information to the SCIP database, 
though not every year. It is unclear how many notifications would be required as this depends 
on the use of chemicals by product, and speed of change in the market: a conservative estimate 
is that around 10 000 entities would annually submit data, each making notifications related to 
around 1 500 articles20. However, the number of notifications is uncertain and some estimates 
of the number of notifications per company are higher.  

Based  on  current  experiences  and  economies  of  scale  leading  to  improved  efficiency,  each 
submission can be assumed to take half an hour. The costs are estimated on the basis of business 
survey and feedback to be EUR 30 per hour and an average half an hour per submission, with 
this reflecting investment costs for enterprises in specialized software and dedicated teams or 
consultancy for data collection, formatting (XML/IUCLID), and submission processes. Some 

19 European Chemicals Agency, “First ex-post Evaluation of SCIP” 
20 Based on European Chemicals Agency, “First ex-post Evaluation of SCIP”, 2022 and subsequent analysis 

7 

 
 
 
companies  will  have  to  notify  fewer  articles  but  may  take  more  time  for  notification  while 
companies notifying many articles probably obtain some economies of scale. 

Companies  with  very  few  notifications  will  have  relatively  high  investments  costs  (costs 
related  to  IT  systems  integration  and  software  development  range  between  EUR  1,000  and 
EUR 250,000 per company) to put a management-system into place (with associated training 
costs), the direct notification costs are relatively low. With a growing number of notifications, 
the  investments  costs  for  the  management-system  will  constitute  a  shrinking  share  of  the 
overall  costs.  However,  the  direct  notification  costs  will  rapidly  with  the  number  of 
notifications. 

Overall, the  avoided cost for business  is  estimated to  be  EUR 225  million per annum but 
could be higher in future years. In addition, the costs for ECHA of running the SCIP database 
are already several million Euro, and likely to increase.  

4.2. Waste reporting under the Waste Framework Directive 

4.2.1.  Implementing act on indicators on waste prevention  

Article  9(7)  of  the  Waste  Framework  Directive,  as  amended  by  Directive  (EU)  2018/851, 
empowers the Commission to adopt implementing acts to establish indicators to measure the 
overall  progress  in  the  implementation  of  waste  prevention  measures  but  there  is  no 
requirement for the Member states to use the indicators. This empowerment will be deleted, 
and no implementing act will be adopted. 

This  will  have  no  environmental  impact,  as  the  Member  States  have  established  national 
corresponding indicators, and relevant data that is required will continue to be reported on the 
basis of the requirement in Article 9(3) of the Waste Framework Directive and collected by the 
European Environment Agency. Moreover, Article 9(3) would not have required the Member 
States to use the indicators specified in the implementing act.  

There will be a cost saving for public authorities from this rationalisation of reporting, but the 
amount saved will be  very low  as relevant  data  will continue to  be reported, but  a possible 
duplication is removed.  

4.2.2.  Data quality reports  

Several pieces of legislation21 require the Commission to review data reported and publish a 
report on the results of its review, for example, within a set number of months or with a set 
frequency.  In  practice,  this  provision  has  been  too  prescriptive  and  meant  that  analysis  is 
required at the wrong time and only covers part of the information. For example, a report may 
need to be published out of synch with evaluations undertaken in line with the Commission’s 
better regulation guidelines. In response, these requirements will be deleted and replaced with 
a more flexible requirement for the Commission to review information. 

This will have no environmental impact as the relevant data will continue to be collected and 
analysed and the Commission could decide to publish a report in a more flexible manner or 
make the same type of assessment in the context of the evaluation and revision processes.  

There will be a cost saving for the Commission and for public authorities from this proposal to 
rationalise reporting, but the amount saved will be very low as relevant data will continue to 
be reported. The data will be more flexibly reviewed which would allow for better use.  

21 For example, Article 37(6) of the Waste Framework Directive,  Article 76(4) of the Battery Regulation. 

8 

 
 
 
4.3. Extended Producer Responsibility  

Extended producer responsibility (EPR) stands for the responsibility of a producer to cover the 
costs of the product’s  management  at  its end of  life. Rules on EPR are based on the Waste 
Framework Directive, which contains general minimum requirements. Specific EPR rules per 
product  group  exist  in  the  Packaging  and  Packaging  Waste  Regulation,  the  Regulation  on 
batteries and waste batteries, the Waste Electronic and Electrical Equipment Directive on and 
the Single Use Plastics Directive as well the Directive on end-of-life vehicles (currently under 
review, co-decision ongoing). In addition to EU mandated EPR for certain products, Member 
States can have national rules on EPR for additional products, provided the rules comply with 
the minimum requirements in the Waste Framework Directive. 

4.3.1.  Authorised representatives  

An authorised representative for EPR, under these pieces of legislation, acts  on behalf of  a 
producer who sells products covered by EPR, in a Member State where the producer is not 
established.  The  precise  requirements  differ  across  Member  States,  which  impacts  on  their 
costs. The purpose is to ensure that the producer, who is not established in the Member States 
where  the  product  is  made  available,  complies  with  EPR  rules,  ensuring  that  the  costs  of 
managing  the  waste  from  these  products  are  covered.  The  logic  of  placing  products  on  the 
market in a single EU-27 jurisdiction is not mirrored in waste management legislation, where 
EPR obligations are circumscribed to the territory of each Member State where producers make 
available products.  
In the May 2025 Communication on the Single Market Strategy22, the Commission pointed out 
that complexity in the implementation of the EPR rules is one of the barriers to the internal 
market, in particular the possibility (and in some legislations) obligation for a producer for have 
an authorised representative for EPR. 

The  proposal  provides  flexibility  for  producers  established  in  the  Union as  to  whether  they 
appoint  an  authorised  representative  for  extended  producer  responsibility,  by  suspending 
provisions that make the appointment mandatory or leave a margin of discretion for Member 
States.  

Where the relevant legislation is a Directive (as opposed to a Regulation), Member States may 
have made use of Article 193 TFEU, which allows them to maintain or adopt more ambitious 
rules. This will affect the response to changes in the Directives, but the proposal encourages all 
Member States to suspend such obligations.   

The  administrative  burden  arising  from  the  appointment  of  up  to  26  different  authorised 
representatives for EPR for producers established in another Member State than the one where 
they  are  selling  products  will  be  alleviated  by  giving  such  producers  the  option  to  choose 
whether they appoint an authorised representative for EPR or to fulfil their EPR obligations by 
themselves.  

Producing an estimate of the cost saving from this increased flexibility is challenging. The costs 
of EPR vary considerably between product groups, the volume placed on the market, Member 
States, and the services offered. For example, the costs of EPR for batteries differ depending 
on the waste management approaches of each Member State, which may reflect the collection 
and  recycling  infrastructure.  The  cost  of  appointing  an  authorised  representative  may  be 
affected  by  these  differences  in  EPR,  which  affect  the  services  that  the  authorised 
representative  needs  to  provide.  Furthermore,  the  number  of  firms  using  an  authorised 

22  The  Single  Market:  our  European  home  market  in  an  uncertain  world  -  Internal  Market,  Industry, 
Entrepreneurship and SMEs 

9 

 
 
 
representative  is  unclear  as  companies  can  also  be  established  in  multiple  countries: 
accordingly, and as an example, in Germany, around 40% of batteries producers and around 
66% of WEEE producers use an authorised representative. At the same time, in Germany there 
would be a registration by producer per sub-category and brand with the average number of 
active registrations being 3 per producer or authorised representative.  

There  are  two  elements  to  be  taken  into  account:  fees  for  the  registration  of  the  authorised 
representative in the national register of a Member State, which are not always arising; and 
costs for the services provided by the  authorised representative, which are part of a private 
contract. Related costs to the overall financing of the EPR system in place in Member States 
might be impacted but are challenging to quantify.  

The fees paid as part of EPR schemes related to the environment in the EU is around EUR 15 
to 20 billion per annum23. The cost of authorised representatives would be much lower than 
this. Fees for individual firms to appoint an authorised representative will usually vary between 
several hundred Euro to several thousand Euro and across the EU total perhaps a billion or two 
billion Euro a year. This is based on uncertain estimates of the number of producers involved 
and the cost for each producer. 

This is based on survey results to questions about the annual cost of authorised representatives 
across  all  Member  States,  related  to  registration  and  membership  fees,  and  staff  resources, 
which give totals that range between 260 EUR (for a micro-enterprise) to EUR 400 000 for a 
large company with higher turnover.24 One firm, selling to 15 Member States, estimated they 
paid a total of EUR 6 000 Euro per year for authorised representatives. In feedback to the call 
for evidence a  figure of  EUR 2 000 was  quoted, for example,  for Spain  and Ireland.  Many 
companies offering authorised representative services advertise online, and their quoted prices 
usually  start  at  several  hundred  Euro  and  increase  by  size  and  depend  on  the  country  in 
question.  

This proposal will make the market for authorised representatives more flexible, offering EU 
producers a choice to make use of authorised representatives in the countries where they make 
their  products  available  by  suspending  the  obligation.  Companies  will  be  able  to  choose 
whether  to  do  the  tasks  themselves,  or  to  pay  the  authorised  representatives  to  fulfil  the 
administrative requirements including service provision and assumption of liability. Different 
companies will make different decisions in this context: a company may decide not to use an 
authorised representative and so save that cost at the expense of carrying out those services 
itself.  Clearly,  for  some,  it  will  be  easier  to  comply  with  EPR  obligations  through  an 
intermediary and so they will continue to use an authorised representative.  

The market value for authorised representatives for EPR is probably worth between one and 
two billion Euro a year. Against this baseline figure, the benefit of the improved flexibility is 
difficult to estimate. Notably, it depends on the decisions of Member States and the choices of 
businesses reflecting their savings from not using an authorised representative compared to the 
cost  and  difficulty  of  meeting  the  obligations  themselves.  For  example,  if  the  obligation  is 
removed  from  a  Directive,  Member  States  may  still  choose  to  require  an  authorised 
representative  in  their  national  legislation  ie  go  beyond  EU  requirements  in  line  with  the 
environmental legal base. Whilst the behavioural response of firms is unclear, the net savings 
for  business  (so  the  reduced  expenditure  on  authorised  representatives  but  the  increased 
expenditure by business on undertaking these services internally) could be one-fifth with 20% 

23 “EPR – Smart regulation or stealth tax? A global long-term view on Extended Producer Responsibility across 
key materials”, Roland Berger, 2025 
24 
CLEAN.pdf 

https://ecommerce-europe.eu/wp-content/uploads/2025/06/EPR-Administrative-Burden-Study_v5.0-

10 

 
 
 
of existing costs saved: this is based on feedback about the current value added of the authorised 
representative function, including feedback to the Call for Evidence. Based on the mid-range 
of the market size (i.e. EUR 1.5 billion annually) the benefits are estimated at EUR 300 million 
per annum.  

The  environmental  obligations  of  producers  will  remain  unchanged.  The  flexibility  about 
appointing  an  authorised  representative  could  create  some  concerns  that  it  will  hinder 
enforcement  but  is  already  the  case  for  many  other  producer  requirements  and  will  ensure 
proportionate requirements including for SMEs.  

Ensuring  traceability  and  enforcement  is  more  challenging  when  it  relates  to  producers 
established in third countries compared to those operating within the Union, as such producers 
fall outside the territorial scope of Member States’ enforcement powers and are not covered by 
the Union administrative and judicial cooperation mechanisms that enable the enforcement of 
obligations  and  judgments  within  the  internal  market.  The  existing  provisions  on  the 
appointment of an authorised representative for extended producer responsibility for producers 
established in third countries are therefore unchanged.  

EPR  requirements  are  unchanged,  and  so  in  principle  there  should  be  no  impact  on  the 
environment,  unless  freeriding  increases  and  enforcement  is  negatively  affected.    European 
producers,  falling  in  the  scope  of  EPR,  selling  in  multiple  Member  States  would  still  be 
required to have representation in each Member State where they sell by means of importers 
and  distributors.  It  is  possible  that  firms  taking  advantage  of  the  increased  flexibility  will 
primarily be SMEs.  

This measure is consistent with an option that will be considered in the impact assessment for 
the Circular Economy Act  (due in  2026), related to  harmonised EPR schemes and one stop 
shops.  

4.3.2.  Reporting by producers (reducing/harmonising the frequency) 

Producers are required to report on their sales volumes, notably to determine the extent of the 
EPR fees to be paid by the producer to cover the cost of the waste management of the product 
the  producer  has  sold.  In  waste  legislation  laid  down  in  Directives,  Member  States  have 
maintained  the  competence  to  determine  the  reporting  frequency. This  has  led  to  a  lack  of 
alignment in the reporting periods for EPR between Member States. 

Waste legislation laid down in Regulations, such as the Batteries Regulation and the PPWR, 
align the reporting frequency to once each calendar year. The proposal harmonises the reporting 
frequency  across  relevant  legislation  and  moves  towards  a  harmonised  date  for  the  yearly 
(preceding  financial  year)  reporting  obligations.  This  would  be  especially  valuable  for 
businesses that operate in multiple Member States and produce products falling into several 
waste categories  (hence  multiple reports). By limiting the  reporting frequency to  maximum 
once per year, the proposal will reduce the administrative burden and the adverse impacts on 
the  functioning  of  the  internal  market,  in  particular  for  producers  which  sell  products  in 
multiple Member States and for SMEs. 

This will have no environmental impact as there would only be a change in the frequency of 
reporting.  

There  will  be  a  cost  saving  for  producers  and  the  entities  concretely  reporting  from  this 
rationalisation of reporting. 

11 

 
 
4.4. Batteries Regulation  

The  proposal  clarifies  under  the  Batteries  Regulation  that  a  manufacturer,  importer  or 
distributor  or  other  natural  or  legal  person  that  sells  batteries  in  a  Member  State  and  is 
established in another Member State or in a third country, qualifies as a producer, irrespective 
of the selling technique used, including by means of distance contracts.  

This simplification addresses an unintended loophole in the producer definition in the legal text 
of the Batteries Regulation. The change is to include all selling techniques in the definition of 
producer under Art.3(47)(d), instead of only means of distance contracts and this ensures that 
economic operators established outside the Member State where they make batteries available 
on the market qualify as producers. In consequence, the obligations under Chapter VIII of the 
Batteries Regulation apply to such producers. This ensures that batteries placed on the Union 
market will be collected once they become waste and are treated according to the provisions in 
Chapter VIII of the Regulation.    

This  simplification  will  provide  regulatory  clarity  and  ensure  a  level  playing  field,  with  a 
clearer and fairer sharing of costs and some savings for EU producers. The increased clarity on 
responsibilities will lead to environmental benefits through avoiding negative environmental 
impacts of batteries which become waste. 

Furthermore, Article 13 of the Batteries Regulation requires that batteries should bear a label 
indicating the presence of hazardous substances. However, the definition of those substances 
for labelling is unclear since the corresponding recital specifies that batteries should be labelled 
with the amount of certain hazardous substances present. Therefore, the proposal adds further 
precision on the scope of the substances that need to be labelled by referring to substances of 
very high concern identified in accordance with Regulation (EC) No 1907/2006 and Regulation 
(EC) 1272/2008. As a result, a much reduced number of chemical substances will need to be 
reviewed for being labelled under the Batteries regulation. 

More  specifically,  from  the  end  of  2027  an  obligation  for  labelling  would  have  applied  to 
potentially more than 20 000 hazardous substances. Doing so would be impractical, costly and 
also not an efficient means of communicating risk. The change will lead to battery labelling for 
Substances of Very High Concern, a smaller and more focused set of substances, not exceeding 
1000 chemicals.  

4.5. Requirements for Environmental Management Systems under the IED  

Directive 2010/75/EU on Industrial and Livestock rearing emissions (the Industrial Emissions 
Directive)25 covers large industrial installations and intensive livestock farms, with the revised 
directive expanding its scope to include more installations like large-scale battery production 
and mining of metals26.  

The IED requires operators to have an environmental management system (‘EMS’) for each 
installation in the scope of its Chapter II. Article 14a(1) specifies a range of requirements that 
the EMS must comply with, and with a view to simplifying such requirements and reducing 
the induced administrative burden while maintaining high standards as regards the protection 
of human health and the environment, the following changes are proposed to this Article: 

25 
Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial 
and  livestock  rearing  emissions  (integrated  pollution  prevention  and  control)  (Recast)  as  last  amended  by 
Directive (EU) 2024/1785; OJ L 334 17.12.2010, p. 17.  
26 Following the 2024 revision of the IED, 37,000 industrial installations and 38,500 pig and poultry farms will 
be in scope, once the transposition period has ended (1.7.26). 

12 

 
 
 
a.  Allowing several installations in the same Member State, either under the control of the 
same operator or belonging to the same company, to be covered by a single environmental 
management  system.  It  will  have  a  negligible  environmental  impact,  while  reducing 
administrative  burden  for  industrial  operators  with  associated  annual  savings  between 
EUR 12 million to EUR 90 million with central estimate of EUR 24 million. 

b.  Repealing the requirement to include in the EMS a chemical inventory of the hazardous 
substances present in or emitted from the installation, a chemical risks of the impact of 
such substances on human health and the environment, and an analysis of the possibilities 
for substituting them with safer alternatives or reducing their use or emissions. This risks 
an  environmental  impact  but  most  substances  are  already  covered  by  similar 
requirements under other legislation. It will reduce administrative burden for industrial 
operators with associated annual savings of EUR 50 million on average. 

c.  Repealing the empowerment for the Commission to adopt an Implementing Act on which 
information  from  the  EMS  is  relevant  for  publication.  This  will  have  a  negligible 
environmental impact since the requirement to make the relevant information set out in 
the EMS available on the internet would stay untouched. 

d.  Repealing the auditing requirement for EMS. This will have a negligible environmental 
impact  as  other  environmental  management  system  schemes  such  as  EMAS  or  ISO 
14001  already  contain  provisions  regarding  regular  internal  and  external  auditing. 
Stakeholders had also identified a lack of auditing capacity that may make compliance 
difficult.  It  will  reduce  administrative  burden  for  industrial  operators  with  associated 
annual savings between  EUR 10 million to EUR 44 million with central estimate of 
EUR 24 million. 

e.  Repealing the requirement to develop installation-level indicative transformation plans 
to be included in EMS. This will have a medium environmental impact as transformation 
plans are indicative and do not contain mandatory targets. Moreover, similar plans are 
required at corporate level under other EU law, e.g. CSRD. The associated savings are 
between EUR 20 million and EUR 50 million (one-off), without considering the savings 
associated to the implementation of the plans with central estimate of one-off savings 
of EUR 35 million. 

f.  Giving more time to operators to prepare and implement the EMS in accordance with 
the revised Article 14a, by postponing the deadline from 2027 to 2030. This measure 
will result in cost saving for industrial operators. 

Additionally,  repealing  the  requirements  to  include  a  chemical  inventory  and  the  indicative 
transformation  plan  would  align  IED  Article  14a  requirements  on  the  EMS  with  the 
requirements of Regulation No 1221/2009 (Eco-management and audit scheme – EMAS). With 
this  proposed  simplification,  IED  operators  who  are  already  EMAS-compliant  would  be 
automatically compliant with EMS requirements of IED Article 14a, and so contribute to the 
reduction of the administrative burden.  

The changes to Environmental Management Systems (EMS) under the IED (the deletion of the 
chemical inventory, the deletion of auditing requirements, and allowing operators to have only 
one EMS covering all their installations in the same Member States) leads to savings with the 
central  estimate  of  EUR  98  million  per  annum  plus  EUR  35  million  of  one-off  savings, 
equivalent in total to around EUR 100 million per annum. The environmental obligations 
remain unchanged. 

13 

 
 
4.5.1.  Detailed analysis of cost savings 

Simplification: Allowing for one EMS to cover multiple installations in a MS, under the 
control of the same operator or belonging to the same company 

The analysis of cost savings reflects: 

•  Number  of  installations  concerned  by  the  simplification  (i.e.  all  IED  installations, 
belonging  to  a  company  made  of  at  least  2  installations,  and  excluding  intensive 
rearing):  20 000  to  25 000  installations,  with  a  central  estimate  around  21 000 
installations 

•  Estimated costs saving resulting from the simplification (for industry): Annual savings 
are approximately EUR 12 to EUR 90 million per year (with a central estimate of EUR 
24 million). 

•  Number of installations concerned by EMS requirements: ~ 38 000 

The IED requires operators to have an environmental management system (‘EMS’) for each 
installation in the scope of its Chapter II. Article 14a(1) specifies a range of requirements that 
the EMS must comply with.  Under this measure, operators would be able to apply a single 
EMS across multiple installations in the same Member State. 

The methodology for estimating the number of IED installations belonging to the same 
company considers: 

➢  Regarding the available data from the dataset on industrial information: 

o  Most  of  the  information  contained  in  the  dataset  of  industrial  installation  is 

available at installation level only. 

o  Information regarding the grouping of two or more installation as belonging to 
the same facility, or the same company, is not reported consistently by MS. 
o  It is considered that the set of installations under the control of the same operator 
(i.e.  belonging  to  the  same  facility)  are  included  in  the  set  of  installations 
belonging  to  the  same  company.  Therefore,  it  is  sufficient  to  estimate  the 
number of installations belonging to the same company in order to evaluate the 
impact of this simplification. 

➢  Regarding the data analysis: 

o  The estimation of the number of IED installations belonging to the same facility 
or company was conducted using the data from a representative sample of ~ 28 
000 installations from 8 MS (DE, IT, FR, PL, ES, NL, BE, FI). 

o  These  installations  represent  ~75%  of  IED  installations  concerned  by  EMS 
requirements (i.e. intensive rearing activities, which are not required to establish 
and EMS, are excluded from the sample). 

➢  Caveats 

o  It  is  assumed  that  installations  belonging  to  companies  with  a  similar  name 
belong  to  the  same  company.  It  is  not  possible  to  verify  whether  these 
installations belong in fact to the same company or are under the control of the 
same operator. 

o  It is assumed that the sample taken is representative. It is not possible to ensure 

that the extrapolation to the rest of EU installations is exact. 

Simplification: Deletion of the chemical inventory requirement 

The analysis of cost savings reflects: 

•  Number of installations concerned by the chemical inventory requirement: ~ 32 000 
•  Total number of installations concerned by the simplification: ~ 20 000 

14 

 
 
•  Estimated costs saving resulting from the simplification (for industry): EUR 7M  in the 
cases where only inventories of chemicals are maintained by all installations to EUR 
130   million in the case of inventories, software packages and substitution assessments 
are performed for all installation on average each year (with a central estimate of EUR 
50  million  per  year  reflecting  a  mix  of  simple  inventories  for  smaller  users  and 
chemicals through to inventories, software packages and substitution assessments for 
major users / producers) 

The IED requires operators to have an environmental management system (‘EMS’) for each 
installation in the scope of its Chapter II. Article 14a(1) and (2) specify a range of requirements 
that the EMS must comply with.  This includes under 14(a)(2)(d) a chemical inventory of the 
hazardous substances present in or emitted from the installations, and a risk assessment of the 
impact of such substances on human health and the environment.  Additionally, an analysis of 
the possibilities of substituting hazardous substances with safer alternatives or reducing their 
use or emissions is required. Under this measure, this requirement would be deleted. 

The assessment considers: 

➢  Using data from the Industrial Reporting Hub from the EEA the installations for which 
a chemical inventory requirement has been included in BAT Conclusions already and 
for which removal of the obligation in the Directive would have no noticeable effect.  
This  includes  Ferrous  Metal  processes  (3 817  installations),  Slaughterhouses  (1 277 
installations),  smitheries  and  foundries  (1 660  installations),  and  textiles  (289 
installations). 

o  Most of the information contained in the dataset of industrial installations held 
by the EEA allows the identification of the approximate number of installations 
falling under the industrial activities noted above. 

➢  Also using the EEA data to distinguish between those installations that are involved in 
the  manufacture  /  production  of  chemicals  and  for  which  a  chemical  inventory    is 
expected  to  take  significant  effort  (between  EUR 1 090  and  EUR 18 736  per 
installation),  and  those  that  are  users  of  chemical  products  but  are  not  producers  of 
chemical products where the obligation would be less costly (between  EUR 335 and 
EUR 6 160 per installation). 

Simplification: Deletion of the obligation to adopt a delegated act on EMS information 
relevant for publication 

Article 14(a)(4) specifies that in relation to the relevant information to be made available on 
the internet in relation to EMS that the Commission shall adopt an implementing act on which 
information is relevant.  Under this measure this provision would be deleted. This would have 
no direct impact on IED installations. The deletion of the delegated act is a simplification for 
the  Commission  services  and  the  Member  States,  who  will  not  have  to  participate  in  the 
elaboration  of  the  act.  It  will  also  provide  flexibility  to  Member  States  to  determine  what 
information is required to be published online. 

Simplification: Deletion of the audit requirement 

The analysis of cost savings reflects: 

•  Total  number  of  installations  concerned  by  the  audit  requirement  and  by  the 

simplification: ~ 13 500 installations 

•  Estimated  costs  saving  resulting  from  the  simplification  (for  industry):  EUR 7.5 
million to 33 million on average each year (with a central estimate of EUR 18 million 
per year) 

15 

 
 
The IED requires operators to have an environmental management system (‘EMS’) for each 
installation in the scope of its Chapter II. Article 14(4) requires the EMS to be audited for the 
first  time  by  1  July  2027  and  then  at  least  every  three  years  by  an  accredited  conformity 
assessment body.  Under this measure the requirement for such audits would be deleted. 

The assessment considers: 

➢  The total number of IED installations taken from the Industrial Reporting Hub from the 

EEA. 

➢  The installations for which a certified EMS  has already been adopted and for which 
auditing is already required under those certification schemes, most notably ISO 14001 
(14 489  IED  installations  already  certified)  and  EMAS  (1 000  installations  already 
certified).  The savings for removing EMS auditing for such installations would be zero. 
➢  The installations for which BAT conclusions specify internal and external auditing of 
an  EMS  (being  FDM,  FMP,  SA,  SF, TXT  and  WI)  totalling  9  000  installations  but 
recognising that approximately half of these will have ISO 14001 or EMAS in place, 
thereby the actual total to discount is 4 500. 

➢  Distinguishing  between  the  complexity  of  the  audits  to  be  performed  –  limited 

complexity, medium complexity and highly complex. 

➢  Reflecting on the higher cost of a first audit and the lower costs of subsequent audits 

(2/3 cost of first audits). 

➢  Annualising the costs of the above. 

Simplification: Deletion of the transformation plans 

The analysis of cost savings reflects: 

•  The number of installations concerned by the simplification is the same as the number 
of  installations  concerned  by  EMS  requirements,  but  operators  had  already  the 
possibility to mutualise the transformation plan at company level).  

•  Total  number  of  installations  concerned  by  the  simplification:  20 000  to  25 000 

installations, with a central estimate around 21 000 installations 

•  Estimated costs saving resulting from the simplification (for industry): EUR 20 to 50   
million as a one-off cost.  The costs of implementing the transformation plan are not 
considered in this figure  

The IED requires operators to have an environmental management system (‘EMS’) for each 
installation in the scope of its Chapter II. Article 14a(1) and (2) specify a range of requirements 
that  the  EMS  must  comply  with.    This  includes  under  14(a)(2)(f)  a  transformation  plan 
containing information on how the operator will transform the installation during the 2030-
2050 period to contribute to the emergence of a sustainable, clean, circular, resource-efficient 
and climate-neutral economy by 2050. Under this measure, this requirement would be deleted. 
The costs are those reflected in the original IED impact assessment. 

4.6. Permitting of iron production under the IED  

Annex I of the Directive 2010/75/EU on Industrial and Livestock rearing emissions covers in 
activity 2.2, “Production of pig iron or steel (primary or secondary fusion) including continuous 
casting,  with  a  capacity  exceeding  2,5  tonnes  per  hour”.  Pig  iron  is  produced  through  the 
conventional  process  of  smelting  iron  ore  in  a  blast  furnace.  Several,  more  recent  and 
innovative iron ore processing techniques are not producing pig iron as such but lead to an 
intermediate product used to produce steel. 

Concerns and doubts have been raised on whether these other processes are covered by activity 
2.2 IED. Removing the word ‘pig’ in this activity would align the activity with the same activity 

16 

 
 
under  the  EU’s  Emissions  Trading  System  (ETS,  Annex  I  to  Directive  2003/87/EC)  and 
clarifies the scope of application of the activity under IED, thereby supporting the permitting 
of new and cleaner techniques expected to replace the conventional iron and steel production 
process steps, such as direct reduction plants. As such it would have a positive environmental 
impact.  

In  terms  of  cost  savings,  these  would  be  small  in  macro  terms  but  would  promote  more 
innovative iron ore processing techniques and would be material for the firms affected.  

4.7. Permitting of oxy-fuel combustion  

To support decarbonisation of industrial processes, the use of oxy-fuel combustion - whereby 
oxygen-enriched combustion air facilitates capture of carbon dioxide  - should be supported. 
The higher the oxygen content in the injected air used for combustion, the lower the volume of 
air needed; and the concentration of pollutants would therefore be increased even if the quantity 
of pollutant (in mass) is not higher than for combustion with air. The use of oxygen-enriched 
combustion  air  was  however  not  considered  at  the  time  when  limits  were  set  for  pollutant 
emissions in the Industrial Emissions Directive and the Medium Combustion Plants Directive, 
whereas such technology may be used to facilitate carbon capture. Concerns have been raised 
over  the  Industrial  Emission  Directive  and  the  Medium  Combustion  Plants  Directive 
hampering decarbonisation in relation to the use of oxy-fuel combustion.  

The  Commission  proposes  providing  competent  authorities  with  flexibility  to  assess 
compliance with emission limit values so as to ease permitting of installations using oxy-fuel 
combustion  covered  by  the  Industrial  Emission  Directive  and  by  the  Medium  Combustion 
Plants Directive. The proposal  would  facilitate permitting  of large  and medium  combustion 
plants using oxygen-enriched combustion air, which would facilitate capture of carbon dioxide, 
thereby lowering emissions overall. The cement sector would be the likely primary beneficiary 
of this proposal in the short term, while more sectors might benefit in medium-long term.  

The proposed simplification aims at removing the legal barrier to apply this technology, thereby 
contributing  to  decarbonisation.  There  would  be  a  positive  environmental  impact.  Overall, 
carbon emissions will be reduced and in a worst case scenario other pollutants will remain the 
same in terms of mass emissions, 

In terms of cost savings, these would be small in macro terms but would promote technological 
neutrality and could be material for the firms affected, which are growing in numbers. There 
would  also  be  cost  savings  for  competent  authorities  who  would  face  less  difficulties  in 
permitting these plants.  

4.8. Permitting of hydrogen combustion  

To support the transition towards clean energy and low carbon technologies, the deployment 
of hydrogen-based industrial processes should be supported, as hydrogen combustion does not 
produce CO2. However, when the hydrogen content of the fuel increases, NOx emissions also 
increase,  whereas  the  limit  values  for  NOx  emissions  currently  set  out  in  the  Industrial 
Emission Directive and the Medium Combustion Plants Directive do not take yet into account 
this increase of the use of hydrogen and the formation of NOx so induced. 

Stakeholders raised concerns over the directives as hampering decarbonisation in relation to 
the  use  hydrogen  as  a  fuel.  Creating  a  specific  exemption  from  compliance  with  certain 
emission limit values for combustion plants firing gas with more than 20 % (by volume) of 
hydrogen would ease permitting of installations within the scope of the  Industrial Emission 
Directive  and  the  Medium  Combustion  Plants  Directive  using  hydrogen  combustion.    The 

17 

 
 
inclusion of specific safeguards in respect to NOx emissions from hydrogen combustion will 
avoid the potential negative environmental impacts of such a change. 

The simplification removes the legal barrier to apply this technology, thereby contributing to 
decarbonisation and so should have a positive environmental impact.  

In terms of cost savings, these would be small in macro terms but could be material for the 
installations  affected  which  are  growing  in  numbers. There  would  also  be  cost  savings  for 
competent authorities who would face less difficulties in permitting these plants. 

4.9. Transitional  provisions  for  certain  IED  provisions  applicable  to  industrial 

installations  

Three provisions contained in Directive (EU) 2024/1785 trigger the need to start revising all 
IED  permits  in  July  2026  (as  this  is  the  deadline  for  transposing  this  directive  and  no 
transitional provision is applicable). 

•  The revised Article 14(1)(ab) of the IED requires Member States to ensure the permit 
includes the requirement to assess the need to prevent or reduce emissions of hazardous 
substances. This is a new requirement under the revised IED. 

•  The revised Article 16(2) of the IED requires monitoring at least once every 4 years for 
groundwater  and  9  years  for  soil,  thus  with  higher  frequencies  compared  with  the 
previously applicable ones (i.e. 5 years for groundwater and 10 years for soil). 

•  The revised Article 16(3) of the IED requires quality control of laboratories performing 
the monitoring to be based on CEN standards or, if CEN standards are not available, 
ISO, national or other international standards which ensure the provision of data of an 
equivalent scientific quality. This is a new requirement under the revised IED. 

Concerns  have  been  raised  on  the  lack  of  transitional  provisions  for  the  application  of  the 
revised Article 14(1)(ab), Article 16(2) and 16(3) IED. The Commission proposes to establish 
transitional provisions  so that the application of  the above-mentioned Articles can be better 
phased in as from July 2026. With the introduction of transitional periods, the above provisions 
would  apply  to  specific  installations  where  their  permits  are  updated  due  to  the  reasons 
specified in Articles 3(2) and 3(4) of Directive (EU) 2024/1785. 

In terms of environmental impact, the overall environmental standards and legislation would 
not be changed but more time would be allowed to meet the new requirements as with several 
other new provisions included in the revised IED.  

There would be a cost saving for both public authorities and for installations as without the 
new transitional provision, Member State authorities would need to update all relevant existing 
permits as from July 2026. However, a quantification is not possible since estimating the cost 
savings from avoiding a capacity constraint for public authorities is not straightforward.  

4.10. 

Simplification for livestock farms under the Industrial Emissions Directive 

Directive 2010/75/EU currently exempts organic pig farms from the scope of the Industrial 
Emissions Directive, while it includes organic poultry farms in its scope. It also establishes 
conversion rates for the calculation of the Livestock Unit level of installations, among which 
for the category “Piglets ≤ 20 kg” for which a conversion rate of 0,027 is established. 

Concerns have been raised on organic poultry farms being included in the scope and about 
unweaned piglets being counted in addition to the sows. 

The Commission proposes exempting organic poultry farms from the scope of the directive, 
with a view to ensuring a coherent approach for the organic livestock sector and given that 

18 

 
 
they are already subject to specific legislation. Given that unweaned piglets are only causing 
low emissions, it is appropriate to exclude them for the calculation of the installation 
capacity. 

In terms of environmental impact, the overall goals of the IED will not be affected, given the 
low number of organic poultry farms that will be excluded from the scope of the directive. 
The exclusion of unweaned piglets will also not negatively impact the environment, given the 
low emissions they produce. These changes will alleviate the burden of farmers. 

4.11. 

Livestock and aquaculture operators reporting to the Industrial Emissions 

Portal  

Operators under the scope of the IEPR are required to report to competent authorities data on 
the use of water, energy and relevant raw materials. It has been estimated that, after the latest 
revision, more than 38000 pig and poultry rearing installations will be subject to IED rules. 
Whilst Article  6(9)  allows  Member  States  to  report  on  behalf  of  livestock  and  aquaculture 
operators in respect of releases to air, water and land, the same flexibilities are not provided for 
the resource use measures.  This means that the burden on reporting on use of water, energy 
and  relevant  raw  materials  falls  directly,  and  arguably  unnecessarily,  on  the  operators 
concerned. 

Some Member States and stakeholders have questioned the feasibility of, and burden associated 
to, the requirement for livestock and aquaculture operators to report on the use of water, energy 
and relevant  raw materials. In response, the Commission  proposes exempting livestock and 
aquaculture operators from reporting on water, energy and materials use.  

Moreover, the Commission suggests allowing Member States to exempt operators of livestock 
production and aquaculture installations from reporting on off-site transfers of waste, off-site 
transfers  of  pollutants  in  wastewater,  production  volume  and  number  of  operating  hours, 
provided Member States gather this information on the basis of other data sources. As a result, 
Member States would be allowed to report more information on top of the information that 
they already provide now, i.e. on releases to air, water and land on behalf of individual livestock 
and aquaculture operators. 

There would be no environmental impact associated with this change which is about decreasing 
burden for livestock and aquaculture operators by relying more on Member States action for 
gathering relevant information and improving the process for reporting.  

The cost savings associated with the measure would be for livestock and aquaculture operators, 
who would face reduced reporting requirements and are expected to be of the order of EUR 70 
million per year for all livestock and aquaculture installations across the EU. Some of the data 
would be supplied by Member States who will have this information available through their 
standard agricultural analyses, so can provide it at no additional cost.  

This cost saving is based on analysis from the Industrial Reporting Hub from the EEA and the 
IED impact assessment, which gives a total of approximately 38 500 installations that would 
be affected by the measure.  Taking an estimated administrative cost of one hour per week per 
installation to record the information subject to this obligation leads to an average annual cost 
saving of EUR 1 852 per installation per year resulting from its deletion (adjusted for inflation 
from the original 2022 impact assessment that placed the value at EUR 1 700 per installation).  

19 

 
 
 
 
4.12. 

Back-up generators  

Under Directive (EU) 2015/2193, Member States are allowed to exempt certain existing or new 
medium  combustion plants  used only  occasionally as back-up generators during emergency 
situations and power outages and which do not operate more than a limited number of hours 
per  year,  from  compliance  with  relevant  emission  limit  values.  Under  those  circumstances, 
such back-up generators are still submitted to periodic measurements in relation to their SO2, 
NOx, dust and CO emissions, even if such measurements are not used to assess compliance 
against the relevant emission limit values. In addition, the periodicity of such measurements 
does not distinguish between more recent - and thus more energy efficient back-up generators 
- and older ones.  

In  order  to  reduce  the  administrative  burden,  the  Commission  proposes  removing  the 
requirement for operators of back-up generators to monitor SO2, CO and NOx emissions at 
least every 500 hours for the more recent back-up generators. Instead, it is proposed that they 
are subject to monitoring after every 1 500 hours of operation or every 5 years. 

Specifically, reporting requirements arising under Directive (EU) 2015/2193 in relation to SO2, 
NOX, dust and CO emissions currently apply to back-up generators.  In this measure we would 
reduce the monitoring frequency for  those back-up generators that have a rated thermal input 
equal to or greater than 20 MW, and that comply with emission limits values applicable to non-
road  mobile  machinery,  category  NRG  in  respect  of  Stage  V  controls,  set  by Annex  II  to 
Regulation (EU) 2016/1628 by two-thirds (every 1 500 hours of operation rather than every 
500 hours). 

This suggestion was made in the call for evidence by companies likely to operate large data 
centres. They identified an issue with unclear  legislation leading to testing requirements for 
data  centre  back-up  generators  that  vary  across  EU  member  states,  creating  an  inconsistent 
compliance environment for organisations operating across multiple Member States. 

In terms of environmental impact, the overall environmental standard and legislation would 
not be changed. The cost savings associated with the measure would be around EUR 3 million 
per year (EUR 3 551 per installation concerned). 

The analysis of cost savings reflects the total number of installations concerned being around 
2 560 and the following analysis: 

➢  The  IEA  estimates27  there  are  currently  more  than  8  000  data  centres  globally,  with 
about 33% of these located in the United States and 16% in Europe equating to 1 280 
data centres.  In its proposal for a Cloud and AI Development Act28 the Commission 
will propose the Cloud and AI Development Act, with the aim to at least triple the EU’s 
data  centre  capacity  within  the  next  5  to  7  years  and  fully  meet  the  needs  of  EU 
businesses and public administrations by 2035.  By 2032 this could, in theory, lead to 
an  additional  2  560  data  centres  being  installed  in  the  EU  in  comparison  to  today’s 
figures.    Those  installations  are  likely  to  install  back-up  generators  for  which  this 
measure would impact on some of those sites. 

➢  The  costs  for  periodic  measurement  of  combustion  gases  are  provided  in  the    JRC 
Reference  Report  on  Monitoring  of  Emissions  to  Air  and  Water  from  IED 

27 Electricity 2024 - Analysis and forecast to 2026 
28 Cloud computing | Shaping Europe’s digital future 

20 

 
 
 
Installations29.  The estimates are approximately EUR 700 for dust monitoring and EUR 
3 700 for the other pollutants concerned in total.  As these values are 2018 values, when 
adjusted for inflation the cost would be EUR 5 327.  The proposal effectively reduces 
these costs by two thirds (as monitoring would be required every 1 500 hours rather 
than  every  500  hours)  meaning  a  saving  of  EUR  3  551  over  every  three  years  (the 
averaging period concerned), meaning an annual saving of EUR 1 184 per installation 
concerned. 

➢  Note that this assumes a single measuring campaign for a single back-up generator.  In 
case  of  multiple  blocks  of  engines  the  costs  of  monitoring  (and,  therefore,  savings) 
would be higher. 

4.13. 

Spatial information requirements  

Directive 2007/2/EC of the European Parliament and of the Council (the INSPIRE Directive) 
was  adopted  to  establish  an  infrastructure  for  spatial  information  in  Europe,  building  upon 
infrastructures  for  spatial  information  operated  by  the  Member  States,  to  support  EU 
environmental  policies,  and  policies  or  activities  which  may  have  an  impact  on  the 
environment.  The  INSPIRE  Directive  has  improved  the  sharing  of  geospatial  data  and 
significantly contributed to the capacity building of Member States in managing such data. By 
introducing  common  standards  and  online  access,  the  INSPIRE  Directive  enabled  public 
authorities,  businesses,  researchers,  and  citizens  to  use  geospatial  information  that  had 
previously  not  been  publicly  available. This  has  led  to  better  cooperation  between  Member 
States.  and  the  development  of  new  tools  to  improve  environmental  monitoring  and 
protection.   

Despite  these  achievements,  the  technical  requirements  for  harmonisation  of  geospatial 
datasets have proven to be complex and expensive to implement. As a result, the system is less 
effective and more costly than intended.  

The evaluation  of the Directive and subsequent  analysis provide a good evidence base.  For 
example, only about 42% of spatial datasets documented in INSPIRE metadata are actually 
available  for viewing and downloading,  and geospatial  data makes up  just 8.8% of  all data 
currently  shared  under  environmental  rules. In  the  call  for  evidence,  stakeholder  feedback 
showed  that  75–85%  of  respondents  believe  that  aligning  INSPIRE  with  the  Open  Data 
Directive  would  reduce  administrative  burden  as  well  as  cost  and  make  more  data  more 
accessible. These figures highlight why simplifying the rules of the INSPIRE Directive and 
updating  the  technology  behind  INSPIRE  is  necessary:  the  current  framework  for  the 
infrastructure does not deliver the level of access or efficiency that was originally intended.   

To  address  these  issues,  the  European  Commission  is  proposing  amendments  to  Directive 
2007/2/EC (INSPIRE). The proposal aims to modernise the EU’s environmental data sharing 
framework by aligning it with more recent cross-cutting EU datal legislation such as the Open 
Data  Directive,  the  Data  Governance Act,  and  the  Interoperable  Europe Act.  Key  changes 
include  replacing  complex  harmonisation  requirements  with  more  flexible,  standards-based 
approaches, eliminating obsolete technical requirements and consolidating data access through 
a  single  EU  open  data  portal  (data.europa.eu).  Redundant  network  services,  outdated 
interoperability rules, and duplicative reporting obligations will be removed, while essential 
coordination mechanisms and metadata quality standards will be retained. Leveraging existing 

29 JRC Reference Report on Monitoring of Emissions to Air and Water from IED Installations - Industrial 
Emissions Directive 2010/75/EU (Integrated Pollution Prevention and Control) 

21 

 
 
 
 
open data infrastructure will reduce administrative burden and ensure that environmental data 
is accessible through a single, user-friendly portal, rather than parallel systems.  

The proposed amendments will benefit a wide range of stakeholders, including public sector 
data providers, national and regional authorities, businesses, research institutions, SMEs, and 
civil society organisations. Public sector data providers will see reduced administrative burden 
and simplified compliance, while businesses and data users will enjoy improved access to high-
value  environmental  data  through  open  licensing  and  modern  application  programming 
interfaces  (APIs). A  12-month  transition  transposition  period  is  proposed  to  allow  Member 
States to adapt their infrastructures and to maintain service continuity during the migration to 
the new framework. The annual baseline costs for INSPIRE implementation across EU-27 are 
estimated  at  EUR  4.967–48.926  million.  The  proposed  measures  are  expected  to  reduce 
administrative burdens by 24–64% compared to the current baseline. The lower bound of 24% 
reflects  the  more  conservative  estimates  derived  from  stakeholder  feedback  during  the 
validation workshop, which captured an immediate and pragmatic assessment of the potential 
impact.  In  contrast,  the  upper  bound  of  64%  corresponds  to  the  cost  reductions  identified 
through the full alignment scenario with the Open Data Directive (ODD). Taken together, these 
two assessments are considered to represent the realistic range of expected savings from the 
combined measures, particularly those linked to the annual update of harmonised datasets and 
the operation of publication and web services. This translates into annual savings of roughly 
EUR  6.36–16.96  million,  based  on  the  average  annual  cost  component  for  updating  and 
maintaining datasets and services under INSPIRE. On average across the projected range, this 
corresponds to approximately a 44% annual administrative cost reduction, or about EUR 12 
million in yearly savings. These savings are achieved by removing the complex harmonisation 
requirements, leveraging mainstream web technologies, and consolidating infrastructure. 

the  simplified  framework.  The  proposed 
Environmental  safeguards  remain  within 
amendments preserve the core function of a spatial data infrastructure for environmental policy, 
maintain  high-quality  metadata  standards,  and  ensures  cross-border  interoperability  through 
straightforward, simpler, technology-neutral approaches. Member States may continue to limit 
access  to  spatial  data  if  it  will  affect  the  protection  of  the  environment.    By  aligning 
environmental data sharing with horizontal EU data legislation, the proposal aims to ensure 
that  regulatory  simplification  does  not  compromise,  but  rather  enhances,  environmental 
objectives and policy effectiveness.  

4.14. 

Environmental Assessments Streamlining and Acceleration 

Stakeholders  outline  that  environmental  permitting  takes  too  long  and  is  not  sufficiently 
predictable.  This  concerns  environmental  assessments  required  under  the  Environmental 
Impact Assessment Directive (EIA), the Strategic Environmental Assessment Directive (SEA), 
the Habitats and Birds Directives and the Water Framework Directive during the permitting 
procedures. The Implementation dialogue on environmental assessments and permitting held 
with  Commissioner  Roswall  on  10 April,  the  implementation  dialogue  held  on  11  June,  on 
permitting  and  renewables  with  Commissioner  Jørgensen  as  well  as  recent  studies  on 
implementation of the EIA30 and the SEA Directives31 provide useful data and insights. Input 
from  stakeholders  was  also  received  in  response  to  the  call  for  evidence  on  environmental 
simplification, calls for evidence and public consultations concerning the Grids package and 
the  Industry  Accelerator  Act.  The  proposed  Regulation  will  streamline  and  accelerate 

https://environment.ec.europa.eu/law-and-governance/environmental-assessments/environmental-impact-

30 
assessment_en#publications 
31  Study  supporting  the  preparation  of  the  report  on  the  application  and  effectiveness  of  the  SEA  Directive 
(Directive 2001/42/EC) - Publications Office of the EU 

22 

 
 
 
environmental  assessments  procedures  for  all  projects,  and  include  measures  for  priority 
sectors, while maintaining the integrity of the environmental acquis.  

The  proposed  Regulation  focuses  on  six  core  elements  to  support  project  developers: 
prioritising sectors for fast permitting, establishing one-stop shops and combining assessments, 
limiting  costs  for  permitting  for  certain  operators,  establishing  timeframes  for  assessments, 
addressing the cross-border dimension and digital submissions. The following sub-sections set 
out the proposed changes. 

4.14.1. Sectors for Priority Action 

EU requirements on environmental assessments (notably Environmental and Strategic Impact 
Assessment Directives, Water Framework Directive, Habitats and Birds Directives.) provide a 
high standard of protection of the environment by ensuring that environmental considerations 
are taken into account before decisions to approve plans or projects are taken. These provide a 
framework for ensuring that environmental impacts of economic developments are assessed 
before authorisation, and that the various interests at stake are well balanced. 

Based on the need to speed up the roll out of projects in certain transformative sectors, which 
contribute  to  decarbonisation  goals,  the  proposed  Regulation  will  provide  for  further 
accelerations  in  strategic  sectors  at  EU  level,  in  particular  in  view  of  accelerating  the 
decarbonisation of European industry, support clean and digital transition while strengthening 
competitiveness.  

In itself, this measure will have no impact on costs or on the environment, rather these impacts 
are delivered through the subsequent components.  

4.14.2. “Single point of contact” and combined environmental assessments 

Previous  and  ongoing  initiatives  have  sought  to  require  Member  States  to  establish 
environmental “Single points of contact” (SPOC), and some Member States may have already 
established them on their own initiative, for project  developers to  facilitate and co-ordinate 
permit-granting processes as a whole.32 Where those initiatives do not already provide for such 
SPOC for the overall permit granting process, the proposed regulation will require Member 
States to establish a SPOC for all environmental assessments relating to a plan, programme or 
project. 

Moreover, an obligation regarding bundling or streamlining of environmental assessments has 
also been established in previous and ongoing initiatives. This could be made applicable across 
all sectors covered by the Act. It would aim at, following the Net Zero Industrial Act model, 
extending the current obligation under the Environmental Impact Assessment Directive (EIA)33 
by  obliging  Member  States  to  set-up  joint  or  coordinated  procedures  (respectively  with  or 
without  SPOC)  for  all  environmental  assessments,  including  the  EIA  Directive,  Habitats 
Directive  (HD),  Strategic  Environmental  Assessment  Directive  (SEA),  Water  Framework 
introduced  combined 
Directive 
(joint/coordinated) procedures for assessments under these EU directives.  

(WFD).  Several  Member  States  have  already 

This measure will reduce costs for business, and potentially also for public authorities.  

32 
Article 16(3) of European Renewable Energy Directive III (“Member States shall set up or designate one or more 
contact points. Those contact points shall, upon the request of the applicant, guide and facilitate the applicant during the entire 
administrative permit-application and permit-granting procedure”). 
(33) 
The  Strategic  Environmental  Assessment  Directive  (SEAD)  could  be  included,  although  it  would probably  have 
limited added value given that it relates to plans and programmes and not to projects. In NZIR, SEAD is added to the list. In 
CRMR it is not. 

23 

 
 
 
4.14.3. “Reasonable Administrative Costs for Permitting” 

In order to reduce costs for project developers across the covered priority projects, Member 
States  shall  endeavour  to  bear  the  administrative  charges  and  fees  associated  with  the 
environmental assessments for a given project for small and medium-sized enterprises (SMEs) 
and small mid-caps. The costs for the preparation of the EIA report or the assessments reports 
in the context of the Habitats Directive and/or Water Framework Directive would still be borne 
by the project developer. 

This is a measure that has not so far been included in any of the sectoral permitting legislations. 
It will target specifically SMEs as well as small mid-caps. This would be a measure that, where 
taken up by Member States, would reduce costs for developers, while not as such accelerating 
the assessments. 

This measure will shift costs from business to administrations. 

4.14.4. Maximum Duration of Assessments, Timelines 

Timelines  and  shortened  duration  of  different  procedural  steps  have  been  proposed  to 
streamline impact assessments. Rules and benchmarks for duration of the overall permitting 
process, as well as of various steps of environmental assessments have already been set out in 
a number of ways, across sectoral and environmental legislation.  

Overall, the average duration of the EIA process is estimated to be around 20.6 months based 
on information covering the period 2017-2023 in the implementation studies. Compared to data 
collected from Member States in 2010, the average duration based on current data is almost 
twice as high. It is important to note that the increase in the reported duration of the overall 
EIA  procedure  does  not  come  from  an  increase  in  EU  legal  requirements  between  the  two 
periods, or from an increase in the number of projects, which suggests an insufficient capacity 
at Member States level to process them efficiently.  

On Strategic Environmental Assessment (SEA), the 2025 implementation report assessed the 
different national timelines in each procedural step, including the scoping, screening, adoption 
of  environmental  report,  public  consultation  and  adoption  of  final  results  and  overall 
timeframes to conclude an SEA in different Member States. Based on these national regulatory 
timeframes, the proposal aims to set up maximum duration of each procedural step, while also 
setting a minimum timeframe for public consultations. 

The timelines proposed are based on an average defined relying on the time-frames established 
in Member States, using the information gathered via the EIA and SEA Implementation studies 
as referenced above.   

Recently  adopted/proposed  sectoral  legislation  has  established  maximum  timelines  for  the 
overall  permitting  process.  Critical  Raw  Materials  Regulation  provides  for  a  differentiated 
timeline  running  from  12  to  27  months34.  Net  Zero  Industry  Act  foresees  a  differentiated 
(extendable) 12 or 18 months 35. The revised European Renewable Energy Directive (state of 
transposition  here)  differentiates  between  renewable  projects  located  inside  or  outside 
“renewables  acceleration  areas”:  inside  12 months,  outside  2  years.  These  timelines  would 
normally include environmental assessments where  required, including those under the EIA 
Directive, Habitats and Birds Directives, Water Framework Directive. The duration is counted 
from  the  point  of  “acknowledgment  of  completeness”  of  a  permitting  application,  and  it 
excludes the preparation by the developer of an EIA report (this being outside the responsibility 

(34) 
(35) 

Article 11 (1) and (2) Critical Raw Materials Regulation. 
Article 9 Net Zero Industry Act  

24 

 
 
 
of  the  administration)36  differentiates  between  renewable  projects  located  inside  or  outside 
“renewables acceleration areas”: inside 12 months, outside 2 years. 

The proposed regulation introduces maximum timeframes for the specific steps for conducting 
environmental assessments under the EIA and in case of joint or coordinated assessments under 
the Strategic Environmental Assessments, Water Framework Directive, Habitats Directive and 
Birds Directive, such as: 

a.  for projects subject to screening, a maximum duration for screening of 60 days; and for 
changes or extensions of projects, a maximum duration for screening of 45 days;  

b.  an  opinion  on  the  scope  and  level  of  detail  of  the  information  to  be  included  in  an 

environmental assessment report within a period of maximum 30 days;   

c.  consulting the public of between at least 30 and a maximum of 90 days; 

d.  an acknowledgment of the completeness of the information by the authority within 30 
days,  and  within  a  reasonable  timeframe,  allowing  the  developer  to  provide  the 
necessary additional information, if needed; 

e.  a reasoned conclusion on the environmental assessment of the project within maximum 

90 days.  

As  regards  planning  and  strategic  environmental  assessments  specific  timeframes  are  also 
proposed  with  a  view  to  significantly  reduce  the  duration  of  the  planning  stage,  with  an 
ambitious target on average to conclude within a year, so almost halving duration.  

This  measure  will  significantly  reduce  costs  for  business.  Given  the  wide  range  of  average 
timeframes  found  between  Member  States  and  even  within  them  (e.g.  different  regions  in 
Germany or Poland show very wide differences in average times for similar projects), there is 
no indication that this speeding up of processes will have any negative environmental impact. 
On  the  contrary,  it  is  expected  that  this  measure  will  benefit  a  wide  range  of  stakeholders, 
including  project  promoters, national,  regional  and local  authorities, SMEs, and the general 
public.  

4.14.5. Cross-border dimension 

Particular  attention  should  be  given  to  plans,  programmes  and  projects  with  a  cross-border 
dimension. While this may not be an issue for most plans/projects, it is more likely to be an 
issue  for  electricity  grids  as  lines  are  often  built  through  at  least  two  countries,  as  well  as 
potentially for certain type of transport infrastructure projects.  

In those cases, divergent application of existing rules on environmental assessments may delay 
projects if the right mechanisms are not in place. As an example, a given project extending over 
the territory of two countries may be considered by a Member State as an Annex II project 
under the EIA Directive (only subject to a screening) whilst it may be considered to fall under 
Annex I in the neighbouring Member State (requiring full environmental assessment from the 
start). It would, however, be impossible to reach a level of granularity in project definition at 
legislative  level  to  avoid  such  situation  in  all  cases.  Moreover,  this  would  also  remove  all 
margin of manoeuvre for Member States to adapt the Directives to the national circumstances, 
and yet, some rules may be explored to ease the way forward when those situations arise. 

Therefore, increased harmonisation is especially relevant for plans and projects with a cross-
border dimension that are likely to have transboundary impacts, as developers and authorities 
of  different  Member  States  are  required  by  the  SEA  and  EIA  Directives  to  exchange 

36 Directive - EU - 2023/2413 - EN - Renewable Energy Directive - EUR-Lex 

25 

 
 
 
information and comply with (some of) their respective – and often differing – requirements. 
Developers  involved  in  transboundary  projects  would  be  the  first  to  benefit  from  a 
harmonisation of practices within the EU in relation SEAs and EIAs. The gap between national 
projects and transboundary ones, in terms of administrative and wider economic costs, would 
be reduced. 

Furthermore, the Commission would assume a facilitator role in case Member States would 
request such a facilitating role to be performed by the Commission. This is considered useful, 
in view of ensuring that the procedures are compatible with relevant EU rules and would build 
on available good practices in Member States.  

4.14.6. Digital Submissions 

Digitalisation has been raised in the Implementation Dialogue on Environmental Assessments 
and  Permitting  as  a  key  enabler  for  accelerating  environmental  permitting  and  permitting 
processes in general37. Some Member States have already introduced digitalised procedures for 
assessments under EU directives. The proposed Regulation specifies that project developers 
should  be  allowed  to  submit  their  applications  in  electronic  form  38.  Under  this  Regulation 
developers  and  the  public  will  also  have  an  online  access  to  certain  information  of 
environmental  assessments  such  as  the  designated  SPOCs,  the  progress  of  the  steps  of  the 
procedures and reports. 

This measure will reduce costs for business and could also be associated with reduced costs for 
public authorities.  

4.14.7.  Effective judicial proceedings  

The  proposal  governs  urgency  procedures  for  the  settlement  of  disputes  and  any  litigation 
concerning  the  environmental  assessment-related  processes  including,  where  applicable, 
alternative  dispute  resolution  mechanisms,  as  well  as  priority  treatment  of  such  procedure. 
Giving priority where such a procedure exists under national law is not considered to create 
additional burden, based on the assumption that the same resources can be utilised as the ones 
that are currently available, by giving priority to these cases and deprioritising other types of 
cases.  

The proposal also aims to accelerate and streamline judicial procedures by enabling Member 
States to preclude those substantial arguments from the judicial proceedings where there was 
also  an  opportunity  to  make  these  arguments  known  and  have  them  reviewed  during  the 
environmental assessment process already at the stage of the public consultation but that was 
not  done.  This  provision  could  potentially  reduce  the  number,  complexity  and  duration  of 
disputes that arise due to third party complaints about environmental assessment procedures. 
Legal disputes where the national procedures are slow and inefficient may lead to protracted 
legal proceedings, hence a reduced number of disputes and more effective management of such 
cases would translate into reduced legal proceeding costs both for developers and authorities.  

(37) 
Digitalisation of the overall permitting procedure is a general call by stakeholders across the board, e.g. also at the 
implementation dialogue on permitting by Commissioner Jørgensen. From exchanges in the EIA/SEA expert group we note 
that countries and projects with shorter timelines in their environmental assessments tend to be those with a high level of 
digitalisation of the process. 
(38) 
Article 6(4) of NZIR (“Project promoters shall be allowed to submit all documents relevant to the permit-granting 
process in electronic form.”). Article 9(6) of CRMR (“Project promoters shall be allowed to submit all documents relevant to 
the permit-granting process in electronic form.”). 

26 

 
 
 
4.14.8. Priority for strategic sectors 

This proposal establishes a toolbox for strategic sectors or categories. In certain cases, due to 
the strategic nature of certain plans, programmes and projects, the latter should be considered 
of public interest,and may be considered to have an overriding public interest when balancing 
the interests at stake, giving specific consideration to the strategic nature of the project They 
will  also  benefit  from  tacit  approvals  under  certain  conditions  and  priority  in  judicial 
proceedings.   

4.14.9. Assessment of impacts 

The  average  duration  of  the  EIA  process  is  estimated  to  be  around  20.6  months  based  on 
information covering the period 2017-2023. Compared to data collected from Member States 
in 2010, the average duration based on current data is almost twice as high. The increase in the 
reported  duration  of  the  overall  EIA  procedure  does  not  come  from  an  increase  in  EU 
requirements between the two periods, or from an increase in the number of projects. 

On  SEA  the  2025  Implementation  study  found  that  the  time  taken  to  prepare  the  final 
environmental report based on the SEA Directive varies greatly depending on the complexity 
of the plan or programme, from three to six months for simpler cases to several years for more 
complex plans.  

Therefore, the proposal sets out timeframes at planning and project level for strategic projects 
(for  screening,  scoping,  public  consultation  and  reaching  a  reasoned  conclusion  on  the 
environmental  impact)  would  reduce  the  costs  related  to  delays,  facilitate  investments  by 
providing a stable legal framework for investors to plan their investments ahead and reduce the 
likelihood of unforeseen delays. Moreover, clear  timeframes will improve governance, as it 
will  increase  the  transparency  of  the  overall  environmental  assessment  process,  allow  for 
sufficient  time  for  public  consultation  and  improve  the  visibility  of  developers.  Setting 
maximum  timeframes  improves  overall  visibility  over  the  SEA  and  EIA  process  and  helps 
developers better forecast the whole duration of the project lifecycle, reducing the likelihood 
of  unforeseen  delays.  This  contributes  to  improving  the  overall  economic  environment  for 
developers and constitutes a positive sign for investment. 

In addition, the introduction of coordinated or integrated/joint procedures for environmental 
assessments will reduce the delays resulting from the overall development consent (permitting) 
process.  

Making a clear estimate about the impact of the proposed Regulation is complex, but analysis 
of the implementation of the EIA39 identified an average of 6 000 EIAs per annum, and a typical 
cost of EUR 100 000, meaning the typical EU spend would be EUR 600 million per annum. 
The changes should both cut the cost per project and speed up each project, which is difficult 
to account for in monetary estimates. The study also points to the fact that project developers 
and competent authorities in several cases identified as factors having a significant impact on 
the costs and duration of EIA procedures the volume and complexity of the assessments to be 
carried out for the environmental report. The proposed solution of  single points of contact aims 
to alleviate this burden.  

Furthermore,  ongoing  discussion  in  the  context  of  data  centres  and  related  upcoming 
instrument  as  regards  simplification  of  permitting  procedures  finds  that  national  authorities 
face one-off adjustment costs to design and implement harmonised procedures, designate and 
staff a single point of contact and establish common workflows, however, it is considered that 

https://environment.ec.europa.eu/law-and-governance/environmental-assessments/environmental-impact-

39 
assessment_en#publications 

27 

 
 
 
restructuring of the available resources to also serve as single point of contact will not entail 
additional costs. This  analysis  also  found that  setting up an e-permitting  tool  servicing  data 
centres amounts to a one-off cost of EUR 2 million for each Member State. However, as the 
measures introduced  aim to  merge the different  procedures, while shortening  the deadlines, 
will not result in additional human resources costs. 

The costs associated with SEAs could be of a similar magnitude. The cost of an SEA varies 
depending on whether it is for a small or large plan (for example, local vs national level) and 
on the plan complexity. Broadly, there appear to be two categories of SEAs according to the 
implementation  studies  –  those  estimated  to  cost  less  than  roughly  EUR  20 000  and  those 
costing 10 times that amount.  

Given these different estimates, and the substantial speeding up of the process and significant 
improvements  to  efficiency,  a  careful  assumption  of  a  15  per  cent  efficiency  improvement 
implies savings for project developers would be EUR 180 million per annum, alongside 
savings  from  speeding  up  processes  and  increasing  regulatory  certainty.  Given  experience 
across the EU, this seems achievable.  

The EIA cost as a percentage of the total project cost did not exceed 0.5% in case studies. In 
their reporting, Member States also often reported estimates below 1%, suggesting that the EIA 
procedure represents a small part of the costs of the project development. The implication is 
that projects costing more than EUR 30 billion per annum will be sped up. 
An  analysis40  of  the  permitting  related  to  projects  under  Chapter  III  of  Regulation  (EU) 
2022/869  found  that  ‘streamlining  environmental  assessment  procedures  means  enhancing 
their  coordination  to  reduce  unnecessary  administrative  burden,  creating  synergies  and 
shortening  the  time  needed  to  conclude  the  assessment,  while  ensuring  a  high  level  of 
environmental protection in accordance with EU law’. The same study found that: 

- 

- 

‘establishing  a  digital  platform  for  electronic  submission  would  reduce  duplication, 
improve  coordination,  and  allow  authorities  to  monitor  progress,  speeding  up  the 
process. Early detection and correction of administrative errors would also help to avoid 
delays and ensure accurate information.’41 
establishing a joint procedure for all types of environmental assessments and adopting 
an  integrated  environmental  assessment  is  an  option  that  should  be  followed. While 
linkages between EIA and SEA or with other environmental assessments are indicative 
of an effort to streamline the process, this solution would foster greater streamlining.42 

As  described  also  under  the  SWD  on  the  Net  Zero  Industry  Act  as  regards  training  and 
resources,  the  increase  in  ambitions  for  speeding  up  and  making  permitting  more  efficient 
means  that  Member  States  will  be  required  to  allocate  sufficient,  and  possibly  additional, 
resources, as well as adequately qualified staff. This poses a challenge to many Member States 
and hence the EU will continue to support in these efforts.  

Recent  studies  and  impact  assessments  have  addressed  costs  and  related  burdens  related  to 
permitting  and  assessment  of  impacts.  For  instance,  the  Commission  Staff  Working 
Document/Impact Assessment  Report Accompanying  the  Proposal  for  a  Regulation  of  the 

40 page 71 under Study on national permit granting process applicable to energy transmission infrastructure 
projects with a focus on projects of common interest and projects of mutual interest under Chapter III of 
Regulation (EU) 2022/869 published in 2025 by Milieu Ltd (under Service Contract ENER/C4/2023-
61/SI2.904818) 
41 idem, page 71. 
42 idem, page 74 

28 

 
 
 
European Parliament and of the Council establishing a framework for ensuring a secure and 
sustainable supply of critical raw materials (CRM) and amending Regulations (EU) 168/2013, 
(EU) 2018/858, 2018/1724 and (EU) 2019/1020)43 found some shortcomings on permitting in 
a CRM context, but also relevant under the scope of the proposal: 

‘The  costs  and  time  associated  with  associated  procedures  and  the  likelihood  of 
obtaining  a  permit  are  key  considerations  underlying  CRM  investment  decisions. 
Currently, the unpredictability of the length of national permitting processes and of the 
criteria for the assessments and documentation required are often reported as barriers 
to increased investment.' 

‘One  reason  for  unpredictable  timelines  is  that  the  procedure  for  performing  the 
necessary environmental assessments is not consistently implemented. (...)’ 

‘The “one-stop shop” concept allows applicants to interact with a single authority and 
facilitates  efficient  coordination  among  authorities  (...).  Streamlining  permitting  for 
plans, programmes and projects will substantially reduce the administrative burden on 
companies  benefiting  from  those  measures.  The  provisions  around  single  point  of 
contact,  digital,  the  fixed  durations,  streamlined  environmental  assessments  and 
planning provisions have a direct impact on administrative cost reduction.’  

The single point of contact that coordinates the entire permit-granting procedures and avoids 
lengthy  and  costly  exchanges  with  many  other  authorities  involved  in  the  process.  The 
timelines regulated clearly and explicitly shall also provide a detailed schedule to the project, 
creating clarity from the start and reducing costs that would otherwise be spent by the project 
in planning the entire permitting procedure. Digitalisation means that national authorities have 
to accept documents digitally and need to provide projects falling under the scope with business 
support services and other relevant information on-line and in a centralised manner.   

Some of the savings for business would be offset by additional costs for public authorities. The 
EIA Implementation study found that ‘the main cost for project developers is the preparation 
of the environmental report, including all individual assessments that are required for various 
environmental  impacts.’  It  is  considered  that  with  the  several  proposals  to  improve  the 
environmental  assessments  and  where  possible  combine  them,  while  also  digitalising  will 
significantly improve the regulatory conditions for developers, consequently also reducing the 
costs incurred by them. 

Furthermore, the Commission would assume a facilitator role in case Member States would 
request  such  a  facilitating  role  which  would  entail  additional  resource  need  from  the 
Commission services, namely 4 FTEs.  

In terms of the environmental impact, the proposed Regulation should not affect the balance of 
interests, or weaken the environmental standards so is considered environmentally neutral.  

4.15. 

Overall impacts 

This  simplification  omnibus  is  implementing  on  the  overall  Commission’s  agenda to 
strengthen European competitiveness. It also delivers on the announcements of the Simpler and 
Faster  Europe Communication,  which  sets  out  a  new  approach  to  boost  prosperity  and 
resilience  and  unleash  new  opportunities,  innovation  and  growth.  The  Commission  is 
proposing  simplification  measures  in  the  area  of  environment  to  ensure  that  environmental 
ambitions are cheaper and easier to deliver. 

43 commission staff working document impact assessment-1_EN_impact_assessment_part1_v5.pdf 

29 

 
 
 
This Staff Working Document consolidates the analysis underpinning the different measures 
which  form  a  focused  set  of  adjustments  to  streamline  procedures  and  clarify  rules,  while 
maintaining a high level of protection for the environment. It forms part of the commitment to 
stress test the full set of laws and deliver simplification, not deregulation, that  improves the 
situation on the ground. 

The omnibus package is designed to be consistent with existing environmental standards and 
objectives  and  current  health  legislation.  It  focuses  on  removing  duplication,  streamlining 
environmental procedures and allowing for a more considered implementation.  

No measure is likely to pose significant risks to the environment, most are neutral and some 
are environmentally positive. The Commission has the requirement to assess the consistency 
of this proposal with the climate-neutrality objective set out in Article 2(1) and the Union 2030 
and 2040 climate targets. The proposal is considered consistent with towards these objectives, 
as well as towards ensuring progress on adaptation as referred to in Article 5. In particular, the 
permitting measures will be beneficial in supporting the transition to low carbon technologies, 
and the environmental assessment proposal will prioritise sectors central to the green transition. 
The other measures will not lead to further greenhouse gas emissions: for example, those on 
authorised representatives and the SCIP database are not relevant in this context.  

Overall, no measure is likely to pose significant risks to the environment, most are neutral and 
some are environmentally positive. Reflecting this, and the fact that environmental objectives 
are untouched, the environmental impact should be close to neutral. 

The estimate of cost savings is subject to uncertainty, especially where assumptions need to be 
made  about  behavioural  responses  and  the  impact  is  more  indirect.  Where  relevant, 
conservative estimates have been used, and where possible quantified estimates are provided: 

•  Repealing the SCIP database: at least EUR 225 million per annum 

•  Authorised  representatives  under  waste  Extended  Producer  Responsibility  schemes: 

EUR 300 million per annum 

•  Simplification  of  environmental  management  systems  for  industrial  operators:  EUR 

100 million per annum 

•  Simplification of reporting for livestock operators: EUR 70 million per annum  

•  Simplification of rules for back up operators: EUR 3 million per annum 

•  Simplification of data requirements under the INSPIRE Directive: EUR 12 million per 

annum 

•  Streamlining and accelerating environmental assessments: EUR 180 million per annum  

In  addition,  there  are  measures  that  are  not  quantified  in  monetary  terms  and  which  will 
collectively contribute many tens of millions of Euro in saving (related to batteries, permits 
etc).  Taken  together,  these  initial  estimates  amount  to  a  total  reduction  in  administrative 
burdens of around EUR 1 billion per annum for the full omnibus package. It will be up to the 
co-legislators to consider and adopt the proposals reflecting the need for regulatory certainty 
for business and for cost savings to be actioned rapidly. Doing so will allow for the realisation 
of a potential reduction of administrative burdens by up to EUR 3 billion under this mandate, 
depending on the date of adoption. 

30 

 
 
SMEs will benefit disproportionately, even if they are not explicitly targeted by the measures. 
For  example,  larger  companies  are  more  able  to  navigate  requirements  on  authorised 
representatives or to employ a team to fill in data in the SCIP database. 

As  well  as  the  direct  savings,  there  will  be  additional  benefits  such  as  an  acceleration  and 
simplification of environmental assessment, which will benefit projects with an investment 
value of EUR 30 billion per annum.  

Furthermore, specific suggestions made as part of the  consultation process for this omnibus 
will feed into the wider stress testing of environmental policy. For some of these suggestions, 
legislative  change  is  not  required,  rather  they  require  practical  implementation  support,  for 
example through harmonised guidance. For other suggestions, more analysis and consultation 
are needed allowing them to be included in other proposals, such as the Circular Economy Act 
in 2026.  

31 

 
 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

a)  Lead DG and internal references  

This omnibus on environmental legislation is led by DG Environment. It covers the following 
entries in the Agenda Planning (AP) system: 

-  PLAN/2025/1545, related to administrative burdens in general including the Omnibus 
on accelerating and streamlining environmental assessments for certain sectors of the 
economy 

-  PLAN/2021/11441,  related  to  the  revision  of  the  INSPIRE  Directive,  which  is 

subsumed into this proposal. 

An inter-service steering group (ISG) helped steer the file and included representatives from 
the  Directorate  Generals  for  Environment;  Agriculture  and  Rural  Development;  Climate 
Action; Competition; Energy; Eurostat; Employment, Social Affairs and Inclusion; Health and 
Food  Safety;  Humanitarian  Aid  &  Civil  Protection; 
Industry, 
Entrepreneurship and SMEs; Joint Research Centre; Justice and Consumers; Maritime Affaires 
and Fisheries; Mobility and Transport; Regional and Urban Policy; Recovery and Resilience 
Task  Force;  Research  and  Innovation;  Structural  Reform  Support;  Taxation  and  Customs 
Union; Trade; Service for Foreign Policy Instruments, International Partnerships, Publication 
Office, Digital Services, Communication, Migration and Home Affairs, Translation, Financial 
Stability,  Financial  Services  and  Capital  Markets  Union,  Human  Resources  and  Security, 
Enlargement  and  the  Eastern  Neighbourhood,  Communications  Networks,  Content  & 
Technology,  Office  for  the  Administration  and  Payment  of  Individual  Entitlement,  the 
European Anti-Fraud Office, the Legal Service and the Secretariat General. 

Internal  Market, 

b)  Better Regulation  

The proposed amendments will not affect environmental standards nor create additional new 
obligations  for  Member  States  and  there  is  no  consideration  of  alternative  options  to  the 
existing rules. As the targeted simplification measures reduce administrative burden and bring 
administrative efficiencies in the existing rules, without considering other alternative options, 
an  impact  assessment  is  not  deemed  necessary,  in  line  with  the  Commission’s  Better 
Regulation  Guidelines44.  Furthermore,  some  of  the  changes  relate  to  recently  adopted 
legislation,  where  an  Impact  Assessment  has  already  provided  a  strong  evidence  base  for 
decision-making.  Accordingly,  the  Commission  prepared  this  Staff  Working  Document 
assessing the impacts and including a summary of the stakeholder consultations. 

c)   Methodology and Analytical models used 

The  analysis  of  costs  has  been  undertaken  in  line  with  the  Commission’s  Standard  Cost 
Methodology45. 

Administrative costs are a type of compliance costs incurred by enterprises, public authorities, 
and  citizens  in  meeting administrative  obligations. When  a  measure  imposes  administrative 
costs on business, citizens or public authorities, the EU Standard Cost Model should be applied 

44 Better regulation: guidelines and toolbox 
45 Tool 58 of the Better Regulation toolbox. 

32 

 
 
 
to  the  extent  that  the  underlying  data  is  available.  The  model  assesses  the  net  cost  of 
administrative obligations imposed by EU legislation. Administrative net costs are assessed by 
multiplying the average cost of the required administrative activity (Price) with the number of 
activities  performed  per  year  (Quantity).  The  average  cost  per  activity  is  estimated  by 
multiplying a tariff (based on average labour cost per hour including pro-rated overheads) and 
the time required per action. 

Administrative costs consist of two different cost components: the business-as-usual costs and 
administrative  burdens.  The  business-as-usual  costs  correspond  to  the  costs  resulting  from 
collecting and processing information that would be done in the absence of any legislation. 
Administrative burdens stem from the part of the process which is done solely because of an 
EU legal obligation. The measures in this omnibus package reduce administrative burden.  

Estimates of the saving of administrative burden will be an underestimate of the impact of the 
proposal on economic growth, where there are additional benefits. This would be the case, for 
example, where faster environmental assessments led to quicker project approval. 

33 

 
 
 
 
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) 

This  synopsis  report  provides  an  outline  of  the  consultation  strategy,  consultation  activities 
undertaken, and the findings of consultation activities. 

This  annex  should  be  regarded  solely  as  an  overview  of  contributions  received  during  the 
stakeholder  consultation  activities.  It  cannot  be  regarded  as  the  official  position  of  the 
Commission or its services. Responses to the consultation activities cannot be considered as a 
representative sample of the views of the EU population. 

1  CONSULTATION STRATEGY ...............................................................................36 

2  CONSULTATIONS PERFORMED BY EXTERNAL CONSULTANT ..................37 

2.1 

2.2 

Online webinar on environmental reporting ............................................................ 37 

Survey on reporting cost .......................................................................................... 39 

3  CALL  FOR  EVIDENCE  ON  SIMPLIFICATION  OF  ENVIRONMENTAL 

LEGISLATION .........................................................................................................40 

3.1 

3.2 

General overview ..................................................................................................... 40 

Overview of feedback .............................................................................................. 41 

3.2.1  Citizens’ feedback ................................................................................................ 41 

3.2.2  Feedback from organisations ............................................................................... 42 

4  HIGH-LEVEL  ROUNDTABLE  ON  SIMPLIFYING  ENVIRONMENTAL 

LAWS (2 OCTOBER 2025) ......................................................................................45 

5 

IMPLEMENTATION  DIALOGUE  WITH  COMMISSIONER  ROSWALL  ON 
ENVIRONMENTAL ASSESSMENT AND PERMITTING (10 APRIL 2025) ......46 

6  AD HOC MEETING OF EIA/SEA EXPERT GROUP ON ENVIRONMENTAL 

ASSESSMENTS AND PERMITTING .....................................................................48 

7  CONSULTATIONS REGARDING THE INSPIRE DIRECTIVE............................49 

7.1 

7.2 

Call for evidence ...................................................................................................... 49 

Public consultation ................................................................................................... 50 

34 

 
 
 
 
 
 
Consultation strategy  
The main objective of the stakeholder consultations is to collect information, data, evidence 
and  opinions  on  whether  there  are  unnecessary  administrative  obligations  in  EU  legislation 
managed by DG Environment. 

This initiative is of potential interest to relevant industrial/economic actors, including SMEs, 
public bodies (e.g. administrations in charge of implementing environmental legislation), non-
governmental organisations (such as environmental groups or consumer bodies), international 
organisations,  and  academia.  The  consultation  activities  aimed  to  reach  all  interested 
stakeholder groups. 

This  synopsis  report  also  covers  the  consultation  activities  carried  out  by  the  consultants 
working on the ongoing study on environmental reporting and other administrative obligations. 
The study is expected to finalise early 2026, but part of the consultation activities is relevant 
for this initiative. 

The synopsis report covers the following consultation activities: 

-  An  online  webinar  on  environmental  reporting  carried  out  by  the  consultant  on  13 

February 2025. 

-  An online survey carried out by the consultant of the participants to the above webinar 

who had agreed to be contacted for its purpose. 

-  A call for evidence46 that was open for feedback from 22 July 2025 to 10 September 

2025. 

-  A high-level roundtable on simplifying environmental laws on 2 October 2025. 

Specifically for environmental assessments: 

-  An  Implementation  dialogue  with  Commissioner  Roswall  on  Environmental 

Assessment and Permitting on 10 April 2025. 

-  An Implementation dialogue with Commissioner Jørgensen on permitting in the clean 
energy  transition;  public  consultations  for  the  Grids  and  Industry  Accelerator  acts 
(concerning environmental permitting aspects). 

-  An online meeting of the EIA/SEA Expert Group on environmental assessments and 

permitting on 13 June 2025. 

Specifically for the revision of the INSPIRE Directive: 

-  A Call for evidence47 that was open for feedback from 26 February 2024 to 25 March 

2024. 

-  A public consultation48 from 05 February 2025 to 30 April 2025. 

It should be noted that the Commission is in frequent dialogue with stakeholders about new 
and  existing  legislation.  Much  of  the  legislation  under  the  scope  of  this  proposal  has  been 
subject  to  an  evaluation  or  fitness  check  or  an  impact  assessment,  also  based  on  public 
consultations,  in  accordance  with  the  Commission’s  Better  Regulation  agenda.  These  are 
published  together  with  the  evaluation  reports  or  proposals  they  accompany  and  can  be 
accessed  from  the  Have  Your  Say  portal.  As  the  issue  of  simplification  and  reducing 
administrative  burden  has  been  subject  to  considerable  discussion,  the  Commission  has 

46 Simplification of administrative burdens in environmental legislation 
47  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13170-GreenData4All-updated-rules-
on-geospatial-environmental-data-and-access-to-environmental-information_en 
48 GreenData4All – updated rules on geospatial environmental data and access to environmental information 

35 

 
 
 
received numerous position papers and inputs including as feedback to a call for evidence on 
simplification49https://ec.europa.eu/info/law/better-regulation/have-your-
say/initiatives/13990-Administrative-burden-rationalisation-of-reporting-requirements_en, 
covering all legislation.  

Consultations performed by external consultant 
An external consultant is currently carrying out a study on reporting and other administrative 
obligations in the environmental legislation50. In this context, various consultation activities 
were carried out. 

Online webinar on environmental reporting 
An online webinar for stakeholders on assessment of environmental reporting and the potential 
for simplification took place on 13 February 2025. The webinar’s primary objectives were to 
share and validate the study’s initial findings on business reporting obligations and to exchange 
views  on  the  principles  of  good  reporting.  It  also  aimed  to  gather  stakeholder  input  on 
legislative  acts  where  streamlining  reporting  requirements  could  lead  to  more  effective  and 
efficient regulation.  

The agenda of the webinar was structured around three sessions on the following topics: 

•  Session 1: Review of reporting obligations 

•  Session 2: Principles of good environmental reporting 

•  Session 3: Good and smart reporting – how to reduce burden and improve efficiency? 

During the webinar, different means of engagement were used to obtain as much information 
as  possible  from  the  audience  in  the  limited  time  available.  This  included  contributions  of 
“lightning commentators” for the substantive sessions to inspire contributions by the audience, 
participation in online polling through the Slido app, written contributions in the Q&A function 
of the webinar with some contributions responded to in writing and some orally, as well as oral 
contributions by participants.  

The webinar was open to everyone and was promoted on the websites of the Commission and 
of the consultant. A total of 319 participants (excluding the project team) attended the webinar. 
An overview of the workshop participants per stakeholder type is shown in the figure below. 

49 Administrative burden – rationalisation of reporting requirements 
50 Environmental Reporting and Simplification - Trinomics 

36 

 
 
 
Figure 1: Webinar one participants by type 

Session  1  reviewed  research  on  EU  business  reporting  obligations  (excluding  other 
administrative  obligations).  Initial  findings  from  the  study  were  presented  to  the  audience. 
Governance had the highest number of reporting obligations, followed by waste legislation, 
industrial  emissions,  and  then  products.  However,  audience  perception  differed,  with  most 
expecting industrial emissions and products to have the most obligations. 

SMEs were said to be particularly affected by high burdens from the Green Claims Directive 
and CSRD. Also, the lack of EU harmonization was mentioned. Key burdens in reporting were 
linked to data collection & aggregation (most time-consuming) and data storage costs. 

Key Takeaways from the session were the need for clearer reporting distinctions, better cost 
calculations, and support for SMEs. 

Session 2 focussed on the principles of good reporting. Participants suggested the following: 

-  Proportionality: Avoid overburdening SMEs with abstract/voluminous EU regulations; 

prefer EU-wide solutions over fragmented platforms. 

-  Once-only:  Prevent  duplicate  reporting  by  aligning  data  definitions/units  across 

regulations. 

-  Coherence & Necessity: Ensure reporting is non-redundant and data is collected only 

if unavoidable. 

Additional suggestions covered the integration of digital-ready legislation principles for data-
driven reporting, allowing SMEs to input data in their native language with localized interfaces, 
leveraging  AI  and  best-practice  operating  models.  The  session  underscored  the  need  for 
streamlined, standardized, and user-friendly reporting to support the Green Deal and effective 
environmental governance. 

Session 3 was dedicated to the question how reporting burden could be reduced and efficiencies 
improved.  Based  on  previous  stakeholder  input,  several  areas  had  been  identified  that 
stakeholders usually regarded as burdensome, such as:  

• unclear instructions for data collection and transmission;  

• lack of comprehension of the number of data points;  

• inefficient data or information transmission solutions;  

37 

 
 
 
• multiple reporting of the same data to different institutions;  

• frustration about the level of quality of data available to the user;  

• frustration about the burden associated with the collection of data;  

• feeling that the information required is not useful; and  

• failure to exempt businesses where it is disproportionate e.g., SMEs. 

On the question which legislative act stakeholders found most urgent to simplify, respondents 
reiterated  those  that  they  had  seen  of  priority  importance  to  them,  namely  the  EUDR  and 
REACH followed by CSRD, PPWR, waste legislation, and the IED. Overlapping plans (e.g., 
sustainability plans), the SCIP database and the Green Claims Directive were also mentioned. 

Survey on reporting cost 
Following the webinar the consultant launched a survey with a view to collecting information 
on business and Member States reporting costs as well as ideas for improving the efficiency 
and effectiveness of reporting. The survey was open from 24 February 2025 to 24 March 2025. 
The survey was distributed amongst registrants to the webinar who had granted consent to be 
contacted for additional consultation activities in the future. 

The  table  below  indicates  the  number  and  share  of  responses  per  stakeholder  category, 
including the totals. 

Table 2: responses received per stakeholder group to the Trinomics survey 

Category 
Public authority 
Business – SME 
Business – other 
Business representative 
(responding on behalf of multiple companies) 
Non-governmental organisation 
Private individual 
Total 

Count 
58 
64 
266 
103 

11 
3 
505 

Share 
11% 
13% 
53% 
20% 

2% 
1% 
100% 

The table shows the number of contributions; the same stakeholder could send more than one 
contribution, as the survey allowed one contribution per piece of legislation. 

Respondents typically seek simplification through digital consolidation, harmonised EU-wide 
standards,  and  proportionate  data  collection.  Stakeholders’  suggestions  aim  to  keep 
reporting effective  for  environmental  oversight while removing  unnecessary  administrative 
load, especially for SMEs and smaller operators. 

The  survey  collected  numerous  suggestions  for  simplification  covering  the  scope  of 
environmental legislation and even beyond. The consultant prepared a consolidated summary51 
of suggestions for simplification (which only encompasses those responses where owners have 
granted the right to publication). 

51 Environmental Reporting and Simplification - Trinomics 

38 

 
 
 
 
The survey results are still being analysed in the context of the ongoing study on environmental 
reporting and other administrative obligations. They serve to identify the main administrative 
burdens for environmental legislation and the most promising measures to alleviate this burden. 

In addition, the suggestions made during the survey have been compared to the suggestions 
advanced by stakeholders in their feedback to the call for evidence (see below) to establish 
their relevance for this simplification initiative (that aims to produce rapid results). 

Call for evidence on simplification of environmental legislation 

General overview 
The Commission published a call for evidence on the environmental simplification package on 
the  Have-Your-Say  website:  Simplification  of  administrative  burdens  in  environmental 
legislation. As the call began during July  2025, the feedback period was extended from  the 
standard 4 weeks to 7 weeks to compensate for partially running in the Summer. The feedback 
period closed on 10 September 2025. All feedback is published on the Have-Your-Say website. 

There was considerable interest in the call for evidence and the Commission received a high 
number  of  reactions  from  individual  citizens.  A  campaign  mounted  by  environmental 
organisations  WWF,  EEB,  ClientEarth  and  BirdLife  produced  187  612  replies  that  were 
channelled via a campaign website. At the closing of the feedback period, there was a backlog 
of 71 455 responses that the campaign website had received but had not been able to transmit 
to the Have-Your-Say website because of technical issues. The Commission services agreed to 
have these responses transmitted in a batch and added them to the Have-Your-Say website52. It 
should be noted that the contributions via the campaign website were not all identical responses 
(and hence not  necessarily  a “campaign” in  the sense of the Better Regulation Guidelines); 
while  the  campaign  website  suggested  (IA-generated)  text  with  similar  content,  many 
individual contributors chose to introduce their own (sometimes quite detailed) comments. 

The Commission received in total 190 998 contributions: 

-  189 751 or 99.3% came from citizens, and 
-  1 247 or 0.7% came from organisations other than citizens. 

Citizen replies 

187 612 of the 189 751 replies were received via campaign websites (mainly linked to the 
#handsoffnature campaign by WWF, EEB, ClientEarth and BirdLife). 

The geographical breakdown of the 189 751 citizen replies is as follow: 

Country 

Number of contributions 

Germany 
France 
The Netherlands 
Belgium 
Spain 
Italy 
Sweden 
Other EU Member States 

61 956 
30 394 
22 650 
18 944 
8 752 
8 414 
5 019 
31 772 

Percentage of total 
citizens 
32.7 % 
16.0 % 
11.9 % 
10.0 % 
4.6 % 
4.4 % 
2.6 % 
16.7% 

52 These 71 455 responses do not include 8 497 contributions that were invalidated because the text box was left 
empty (as acknowledged by WWF) 

39 

 
 
 
Non-EU citizens 

Total 

1 850 

189 751 

1.0 % 

100% 

Non-citizen replies 

The Commission received 1 247 contributions from organisations other than citizens. The 
breakdown is as follows: 

Organisation type 

Number of contributions 

Businesses and business 
associations 
NGO (environmental and other) 
Public authorities (national and 
regional) 
Academic 
Other 

Total 

Overview of feedback 
Citizens’ feedback 

853 

236 
40 

23 
95 

 1247 

Percentage of total 
organisations 
68% 

19% 
3% 

2% 
8% 

100% 

Citizens’ responses received through the campaign and directly on HaveYourSay are in essence 
quite  similar:  a  strong,  pan-European  rejection  of  any  dilution  of  existing  environmental 
safeguards. 

Comments  repeatedly  praise  the  EU’s  current  nature  conservation,  water-  quality,  air 
quality- and biodiversity directives — highlighting tangible successes such as thriving nature 
reserves, cleaner rivers, and improved public health. 

Citizens are worried that the simplification drive could weaken our environmental protection, 
they  find  that  the  existing  legal  framework  is  essential  and  successful.  They  prioritise 
implementation  over  new  simplifications:  the  EU  should  focus  on  enforcing  the  already 
existing legislation. 

Many  citizens  cite  specific  legislation:  of  specific  concerns  are  the  fates  of  the  Nature 
Restoration Law (keep it intact and apply it fully), the preservation of biodiversity (enforce the 
Habitats and Birds Directives), the EU Deforestation Regulation (apply fully without delays), 
the chemicals regulation REACH (preserve the precautionary principle, keep registration and 
restriction procedures strong; avoid “simplifying” that would let hazardous substances stay on 
the market), the freshwater and air-quality protection legislation and the waste legislation. 

Some citizens refute the claim that environmental regulation is a burden on business, arguing 
instead that it drives sustainable innovation and long-term economic stability. 

Some contributions also highlight worries about transparency and better regulation processes. 
Simplifying should not reduce transparency and not limit citizens’ ability to access information 
and take part in decision-making. Some complain about the expedited consultation or absence 

40 

 
 
 
 
 
 
 
 
 
 
of  consultation  for  the  various  simplification  omnibuses.  The  recurring  demands  are  for 
transparent, democratic law-making, targeted support for vulnerable actors, and the retention 
of rigorous impact assessments and precautionary principles. 

Feedback from organisations 

Feedback  from  businesses,  NGOs,  academic  and  public  authorities  is  more  heterogeneous, 
covering in scope the whole EU acquis and beyond. 622 attachments, mainly position papers, 
were attached to the submissions. 

The  graph  below  gives  an  overview  of  the  most  mentioned  topics  by  businesses,  NGOs, 
academic and public authorities. 44% of these submissions mentioned and/or discussed the EU 
Deforestation  Regulation  (EUDR).  Furthermore,  packaging  and  packaging  waste,  industrial 
emissions,  the  Waste  Framework  Directive,  Extended  Producer  Responsibility,  the  SCIP 
database, the REACH regulation and nature restoration are among the most cited topics of the 
submissions. 

Number of organisations and business contributions 
mentioning specific themes in feedback to the call for 
evidence

Air quality
Nitrates
Single-Use Plastics
Digital Passport
Batteries
Green Claims
Waste from electrical and electronic equipment
Urban Wastewater Treatment
Waste shipments
Water Framework Directive
Habitats & Birds
Permitting and environmental assessments
Digitalisation
Ecodesign for Sustainable Products Regulation
Nature Restoration Law
REACH chemicals Regulation
SCIP database
Extended Producer Responsibility
Waste Framework Directive
Concerns about the environment
Industrial Emissions
Packaging and Packaging Waste Regulation
EU Deforestation Regulation

0

100

200

300

400

500

600

Concerns about environmental protection 

Many submissions (146) in the “non-citizens” category expressed concerns about the initiative 
and the fear of lowering environmental standards, echoing the views expressed by most of the 
numerous individual citizens responding to the call for evidence. Such concerns were mainly 
expressed by non-governmental and environmental organisations and academics, but also by 

41 

 
 
 
 
 
some companies, business associations, public authorities and trade unions.  They argued that 
simplification  should  not  be  used  as  a  pre‑text  for  deregulation  and  that  weakening 
environmental  protections  would  breach  the  principle  of  non-regression,  create  legal 
uncertainty,  and  damage  the  EU’s  credibility  internationally.  Across  the  board,  these 
stakeholders  say  the real  problem  is  poor  implementation  and  therefore  call  for  better 
enforcement, digital tools, and better guidance.  

Combined with the overwhelming citizens feedback, these views convey the message that the 
present simplification initiative should clearly focus on administrative simplification that does 
not weaken the environmental standards and that also simplifies and strengthens enforcement 
of EU environmental law. 

Suggestions for administrative simplification 

Stakeholders made numerous suggestions for the simplification of administrative obligations 
in environmental legislation. A list of the main suggestions is given in annex 3. Suggestions 
cover almost all the environmental legislation: 

-  EU  Deforestation  Regulation  (EUDR): 

  Citizens  and  environmental  NGOs 
overwhelmingly  oppose  weakening  or  repealing  the  EUDR  and  call  for  timely 
implementation and stricter enforcement. Many small forest owners and SMEs view 
the EUDR as an instrument imposing a disproportionate administrative burden and call 
for  the  repeal  or  significant  simplification.  The  EUDR  has  been  addressed  by  a 
dedicated initiative. On 21 October 2025, the Commission proposed targeted solutions 
to ensure a smooth implementation of the EU Deforestation Regulation (EUDR)53. With 
the proposal, the Commission wants to make sure that the IT system is fully operational 
to address the EU's contribution to the global challenge of deforestation. At the same 
time,  the  proposal  will  simplify  reporting  obligations,  notably  for  micro  and  small 
primary  operators  from  low-risk  countries  worldwide,  while  maintaining  a  robust 
tracking  mechanism.  Moreover,  to  provide  clarity  and  simplify  compliance  for 
businesses and third countries, updated guidance and Frequently Asked Questions have 
been  published  to  support  implementation.  The  Commission  has  also  finalised  the 
country benchmarking system through an Implementing Act. 

- 

-  Extended Producer Responsibility (EPR): The Omnibus addresses the suggestions on 
Extended Producer Responsibility (EPR) by proposing to clarify the rules that apply to 
authorised representatives for EPR and limiting the reporting obligations linked to EPR 
to a maximum frequency of once every 12 months, for each full preceding calendar 
year. Further simplification and harmonisation will be considered as part of the Circular 
Economy Act. 
Industrial  emissions:  Several  suggestions  have  been  addressed  in  the  omnibus 
package, insofar they do not endanger environmental standards. The proposal contains 
targeted amendments to the Industrial Emissions Directive, Industrial Emissions Portal 
Regulation,  and  the  Medium  Combustion  Plants  Directive  that  concern  the 
Environmental  Management  Systems  (EMS),  the  chemical  inventory  and  the 
transformation  plans,  or  that  simplify  permitting  of  decarbonisation  and  innovation 
projects.  The  proposal  on  environmental  assessments  also  covers  some  of  the 
suggestions on industrial emissions (e.g. one-stop shop, clarification of the scope for 
livestock installations or specific timelines). 

-  SCIP database: the many comments on the SCIP database, in particular the request to 

repeal the database, are directly addressed in this proposal. 

53 Commission proposes targeted measures to ensure the EU Deforestation Regulation 

42 

 
 
 
-  Waste  Framework  Directive:  The  omnibus  targets  the  WFD  only  for  the  EPR 
provisions on authorised representatives (see above). Other suggestions, insofar they 
do not endanger environmental standards, are being considered in the ongoing Impact 
Assessment process for the Circular Economy Act54. 

-  Batteries:  The  proposed  environmental  omnibus  addresses  the  issue  of  Authorised 

Representatives under the Batteries Regulation (see above).  

-  Single  Use  Plastics: The  SUP  Directive  is  not  in  the  scope  of  the  omnibus  and  the 
suggestions made by stakeholders will be considered in the ongoing evaluation of the 
SUP Directive55. 

-  Environmental assessment/permitting: The suggestions are addressed in the omnibus 

package (see main part of this SWD). 

-  REACH: Apart from the comments on the SCIP database (see above), stakeholders also 
argue for simplification, for example, by streamlining the restriction and authorisation 
processes.  While  the  discontinuation  of  the  SCIP  database  will  be  included  in  the 
omnibus, the other suggestions are taken into consideration under the ongoing revision 
of the Regulation56. The revision aims at simplifying the legislation by streamlining the 
authorisation  process,  by  relying  less  on  authorisations  and  more  on  broader 
restrictions, early and transparent planning, lighter rules on information passed through 
the supply chain and by better enforcement. 

-  Nature Restoration Regulation (NRR): Most citizens and many organisations support 
effective and urgent implementation of the NRR, considering the level of deterioration 
of  key  ecosystem  services,  on  which  the  EU  economy  depends.  The  nature  of  the 
simplification  suggestions  advanced  by  stakeholders  goes  beyond  the  purely 
administrative  aspects  and  the  NRR  is  therefore  not  included  in  the  scope  of  the 
omnibus. 

-  Ecodesign  for  Sustainable  Products  Regulation  (ESPR): The  suggestions  made  by 
stakeholders (see annex 3) mainly relate to future delegated acts and will be considered 
in the preparation of such acts.  

-  Birds  and  Habitats  Directives:  Citizens  support  simplification  of  administrative 
processes but not at the expense of nature protection. Stakeholder groups representing 
interests  of  certain  economic  sectors  mainly  expressed  the  need  for  proportionate 
impact assessment procedures, flexible derogations, and the need for support to address 
the socio-economic impacts of implementation. 

-  Water  Framework  Directive:  Most  suggestions  relate  to  core  elements  of  the Water 
Framework Directive that go beyond mere administrative obligations. Moreover, as part 
of the just agreed revision of the Water Framework Directive, the Environment Quality 
Standard  Directive  and  the  Groundwater  Directive  (the  ‘water  pollutants  proposal’), 
simplification  elements  have  been  agreed  including  flexibility  elements  that  already 
address some of the issues raised by stakeholders57. 

-  Urban  wastewater  treatment:  Most  suggestions  made  go  beyond  the  administrative 

scope of the omnibus and touch upon core provisions of the Directive. 

-  Waste shipments: The Waste Shipments Regulation is quite recent (it entered into force 
in  May  2024)  and  most  suggestions  were  already  considered  in  the  context  of  the 
adoption and the implementation of the waste shipments regulation. 

54 Circular Economy Act 
55 Rules on single-use plastics and fishing gear (evaluation) 
56 Chemicals legislation – revision of REACH Regulation to help achieve a toxic-free environment 
57 Water pollution: Council and Parliament reach provisional deal to update priority substances in surface and 
ground waters - Consilium 

43 

 
 
 
-  Waste electrical and electronic equipment Directive (WEEE): The suggestions will be 
considered in the context of the revision of the WEEE as part of the ongoing impact 
assessment for the Circular Economy Act58. 

-  Nitrates Directive: Comments on the Nitrates Directive are considered as part of the 

ongoing evaluation of the Directive59. 

In  response  to  the  call  for  evidence,  stakeholders  also  sent  suggestions  regarding  pieces  of 
legislation which are outside the remit of the DG Environment (e.g. on sustainability reporting, 
emission  trading,  Digital  Passport,  etc.).  These  suggestions  have  been  transmitted  to  the 
responsible services for analysis but are not being considered for the environmental omnibus. 

High-level roundtable on simplifying environmental laws (2 October 
2025) 
On 2 October, Commissioner Roswall met with business representatives, civil society and think 
thanks  in  Brussels  to  discuss  the  results  of  the  call  for  evidence  on  an  environmental 
simplification package.  

Commissioner Roswall introduced the meeting, reiterating the Commission’s commitment to 
simplification  as  an  engine  of  our  competitiveness,  and  to  make  it  easier  and  simpler  for 
businesses to uphold our high environmental standards. This roundtable is part of the dialogue 
on the omnibus, following up on the large response to the Call for Evidence – ca190,000 replies 
from citizens, businesses, civil society, public authorities, academics and more. The purpose is 
to deepen the conversation and to gather stakeholders around the table – to hear views, to share 
expertise and ideas, and to discuss the best path forward. It was also stated that simplification 
is  not  only  about  the  Omnibus.  We  are  stress  testing  our  rules  and  when  proposing  new 
legislation, such as the Circular Economy Act, will be mindful of simplification.  

Participants  were  asked  to  identify  three  key  actions  to  reduce  administrative  burden  while 
maintaining environmental objectives. 

Overall, there was a convergence of views on the fact that simplification should not lead to 
deregulation but should be a support in the implementation.  

Business  representatives  called  for  simplification,  harmonisation,  digitalisation,  one-stop 
shops  across  themes  covering  authorised  representatives,  extended  producer  responsibility, 
packaging waste, industrial emissions and permitting. They pushed for pragmatic timelines and 
proportionate approaches to deforestation and nature restoration. 

Environmental  groups  on  the  other  hand,  warned  against  deregulation.  They  insisted  on 
implementing recently agreed laws (such as EUDR, NRR, IED). They supported digitalisation 
only as an enforcement/enabling tool, not to dilute environmental obligations. 

The following topics were discussed: 

-  Authorised Representatives (AR) in packaging and batteries regulations: businesses 
called for a simplification of the AR obligations, with suggestions for a single AR for 
the EU or a one-stop shop. 

-  Extended  Producer  Responsibility  (EPR):  businesses  expressed  the  need  for 
harmonisation for EPR, possibly a one-stop shop, and some saw the Digital Passport as 
a potential compliance enabler. 

58 Circular Economy Act 
59 Protecting waters from pollution caused by nitrates from agricultural sources - Evaluation 

44 

 
 
 
-  SCIP Database: while some business representatives called for the discontinuation of 
the  SCIP  database,  other  business  representatives  and  the  environmental  groups 
stressed the importance of the SCIP database for the information it makes available and 
they prefer to retain and improve the database rather than discontinuing it. 
Industrial emissions: businesses called for simplification, streamlined corporate-level 
compliance, longer cycles, faster permitting and harmonisation to avoid “gold-plating” 
by  Member  States.  Environmental  groups  were  opposed  to  reopening  the  Industrial 
Emissions Directive as it already provides flexibility reducing burden. 

- 

-  Deforestation  Regulation  (EUDR):  businesses  (incl.  farmers)  stated  that  the 
regulation is unclear, creates disproportionate burden (especially for low-risk areas) and 
conflicts with other laws. Member States struggle with implementation, funding, and 
inadequate  guidance  on  the  EUDR.  Environmental  groups  considered  that  the 
regulation should be implemented as agreed, unchanged. 

-  Nature  Restoration  Regulation:  representatives  of  farmers  and 

landowners 
considered  that  the  regulation  is  inconsistent  with  other  laws,  and  it  causes 
disproportionate  burden.  Environmental  groups  recalled  that  the  regulation  is  very 
recent and should now be implemented. 

-  Packaging  &  Packaging  Waste  Regulation  (PPWR):  business  representatives 
stressed  the  need  for  clear  and  harmonised  definitions.  The  reporting  is  said  to  be 
fragmented and needs to be streamlined across regulations. 

-  Digitalisation & Digital Solutions: there was a broad consensus among participants 
that digitalisation can help to reduce burdens while improving implementation. Topics 
mentioned  were  centralised  digital  permit  systems,  digital  reporting,  digital  product 
information via QR codes, digital one-stop shops and digital permitting procedures. 
-  Permitting/ environmental assessments: businesses called for faster, harmonised and 
digitalised  permitting  procedures,  strict  EU-level  timelines  and  exemptions  for  low-
impact  projects.  Environmental  groups  warned  against  weakening  environmental 
standards; the EU should address  the lack of administrative capacity in  the Member 
States and provide more funding for implementation. Centralized digital permit systems 
and interoperable reporting systems would also help. 

Commissioner  Roswall  thanked  the  participants  for  their  engagement.  Simplification  is 
important – need to stay the course – green transition and competitiveness go hand in hand. At 
the roundtable, the purpose was to listen and hear what needs to be done. The Commissioner 
noted that Single Market and harmonized rules are important, and there is pressure for more 
efficient  permitting,  including  by  responding  to  issues  at  the  national  level.  On  water, 
implementation is key. Furthermore, she noted the need for more use of digital tools.  

Implementation dialogue with Commissioner Roswall on 
Environmental Assessment and Permitting (10 April 2025) 
The Implementation Dialogue on environmental assessments and permitting featured an open 
and fruitful exchange with several stakeholders, including business and industry, civil society, 
public authorities and judges. 

All actors expressed the need to balance different interests including the need to advance on 
decarbonisation  objectives,  ensure  energy  security  and  a  high  level  of  protection  of  the 
environment and human health.  

45 

 
 
  
There was broad consensus on the need to step up efforts on implementation of existing EU 
legislation  in  this  area.  Participants  underlined  the  need  for  digitalisation  of  environmental 
assessments  and  permitting  procedures;  improving  data  quality  and  data  sharing  on 
environmental assessments to accelerate procedures and save costs. There was a broad call for 
the Commission to clarify certain aspects of environmental assessment procedures and permits 
by way of guidance documents, to further support Member States’ capacity building, including 
where possible through funding, and to facilitate dissemination of best practices across Member 
States’ authorities and stakeholders. 

Commissioner  Roswall  stressed  her  keen  intention  to  work  and  deliver  on  simplification 
objectives, considering the views of stakeholders, in close cooperation with Executive Vice-
President Séjourné and Commissioner Jørgensen, and their respective services as concerns the 
areas of their competence. 

The main findings can be summarised as follows: 

•  Potential for Implementation and Simplification 

-  There was broad consensus  among  the participants  on the need to accelerate 
permitting  procedures,  whilst  calling  for  caution  regarding  reopening  EU 
legislation and insisting on the need to maintain environmental safeguards.  
-  Most participants emphasised the need for better implementation of EU rules 
on the ground. Several challenges were flagged, such as delays in procedures.  

•  Best practices  

-  Best practices were shared by stakeholders including on digitalisation and one-
stop-shops.  Digitalisation  was  flagged  as  an  essential  element  to  speed  up 
permits and assessments, whilst allowing for cost sharing between public and 
private actors and across Member States and regions. The stage of scoping in 
environmental assessments was signalled as a key to reduce the duration of the 
overall procedure and address challenges along the permitting process. 

-  Most stakeholders underlined that focus should be on digitalisation, availability 
of  up-to-date  data,  including  access  to  existing  data,  addressing  shortage  of 
qualified  staff  and  experts,  deadlines,  and  poor  quality  of  application 
documents.  

•  Obstacles 

-  Some  business  stakeholders  mentioned  a  perceived  uneven  playing  field 
between different Member States, impacting competitiveness. Some felt that it 
was  too  easy  to  overturn  decisions  of  expert  authorities;  some  mentioned 
overlaps  between  different  rules  and  lack  of  clear  definitions  that  could  be 
addressed through guidance by the Commission. 

-  Public  authorities  and  civil  society  participants  cautioned  against  short 
deadlines  regarding  public  participation  during  environmental  permitting 
procedures, as this may lead to decisions that will be appealed and could prolong 
the process.  

•  For next steps and possible future initiatives, stakeholders suggested the Commission 

to act as regards: 

-  Support quality of data and data sharing across borders, ensuring accessibility 
of all businesses and public to environmental assessments and geological data. 

46 

 
 
 
 
 
-  Support specialisation in Member States for better application of EU rules and 
making  the  most  of  streamlining  and  acceleration  possibilities  within  the 
existing legal framework. 

-  Clarify  the  notion  of  “project”  for  purposes  of  environmental  assessments, 

including as regards energy grids infrastructures. 

-  Clarify  interaction  between  the  Industrial  Emissions  Directive  and  allegedly 

conflicting other permitting obligations. 

-  Provide more precise guidance on key legal terms from permitting legislation 
and on relevant developments of the case law of the Court of Justice of the EU, 
in all EU languages.  

-  Clarify the use of overriding public interest clauses used in EU legislation.    
-  Build  on  the  permitting  provisions  under  the  Net-Zero  Industry  Act  to  the 

industrial decarbonisation sector. 

Commissioner  Roswall  concluded  that  the  Implementation  Dialogue  showed  a  very  broad 
consensus  that  the  environmental  assessment  and  permitting  procedures  should  be  simple, 
effective  and  faster,  while  safeguards  on  environment  and  human  health  maintained.  An 
effective implementation of EU laws and, where necessary, simplification of their application 
is  key.  She  also  noted  that  stakeholders  asked  for  digital  solutions,  better  data,  addressing 
shortages  of  qualified  staff  in  competent  authorities  to  ensure  efficient  environmental 
permitting  as  well  as  for  more  guidance  from  the  European  Commission.  Commissioner 
Roswall, in cooperation with other Commissioners, with follow up with concrete actions to 
help  address  the  challenges  of  environmental  assessments  and  permitting  raised  by 
stakeholders at the implementation dialogue. 

Ad hoc meeting of EIA/SEA Expert Group on environmental 
assessments and permitting 
This meeting with national experts took place online on 13 June 2025. The meeting was called 
ad  hoc  to  discuss  possible  EU  measures  to  simplify,  accelerate  and  better  integrate 
environmental  assessments  and  related  permitting.  The  Commission  recalled  the  main  take 
aways from the Implementation Dialogue on this matter hosted by Commissioner Roswall on 
10 April  2025  where  broad  consensus  on  the  need  to  accelerate  permitting  procedures  was 
established, whilst calling for caution with regard to reopening EU legislation, and insisting on 
the need to maintain environmental safeguards.   

Member  State  experts  expressed  a  strong  interest  in  discussing  future  developments  of 
EIA/SEAs and permitting processes with COM:  

•  Most national experts expressed a preference for further guidance on certain definitions, 
such  as  ‘plans  and  programmes’,  indicating  that  legislative  amendments  on  this, 
including  the  consolidation  of  definitions  already  implemented  in  different  sectoral 
legislation, could be risky.  

•  They concurred on the need to adopt a holistic and horizontal approach with regards to 
environmental  assessments  rather  than  a  sectoral  approach.  Most  national  experts 
reported the use of EIA and SEA in the adaption to specific sectoral regimes that have 
been  introduced  through  new  legislation  (i.e.  RED  III,  NZIA,  and  CRMA).  They 
expressed  some  frustration  on  the  difficulty  to  know  which  rules  applied  when,  and 

47 

 
 
 
 
having  to  navigate  sectorial  legislation  to  perform  the  different  stages  of  the 
assessments. 

•  While  some  national  experts  currently  have  timeframes  for  certain  steps  within  the 
EIA/SEA  processes,  they  agreed  that  establishing  global  timeframes  for  the  entire 
process  could  have  a  negative  impact  and  cause  more  rejections  of  the  overall 
application;  the  consequences  of  potential  delays  would  remain  uncertain  (further 
litigation?).  

•  The  experts  agreed  that  legislative  amendments  to  OPI  related  provisions  are  not 

needed. The concept of OPI is sufficiently flexible.  

•  DG ENV presented possibilities for digital solutions and EU funding to be explored by 
Member States. Some national experts showcased their digital systems for conducting 
EIAs and permits and raised that a shared digital platform through EU funding could 
be beneficial.  

Consultations regarding the INSPIRE Directive 
The  revision  of  the  INSPIRE  Directive  within  the  environmental  simplification  omnibus 
constitutes the legal component of the GreenData4All initiative, which addresses the growing 
need for better sharing of environmental data. In line with the Commission’s focus on reducing 
administrative burden and streamlining regulation,  the initiative’s legal  component entails  a 
simplification of the INSPIRE Directive. The legislative framework governing environmental 
data will be modernised and aligned with the evolving horizontal EU data policy landscape. 
By  removing  outdated  obligations  and  technical  specifications,  the  revision  responds  to 
Member  States’  requests  for  a  lighter  implementation  model,  while  safeguarding  the 
Directive’s  essential  objectives  of  ensuring  the  accessibility,  quality  and  interoperability  of 
environmental  spatial  data.  This  proposed  revision  represents  the  first  phase  of  the 
GreenData4All initiative and provides  the foundation for subsequent  non-legislative actions 
and practical tools to support smart and efficient reuse of environmental data across the Union. 

Call for evidence on the INSPIRE Directive 
The Call for evidence60 was open for feedback from 26 February 2024 to 25 March 2024. Input 
was received from 61 respondents and is published on the Have-Your-Say website. 

The list below presents the main suggestions made by stakeholders. Modernization of the data 
sharing framework and ensuring data accessibility were the most emphasized takeaways. 

Include a wider range of environmental data. 

•  Modernize and simplify INSPIRE Directive. 
•  Ensure FAIR (findable, accessible, interoperable, reusable) data. 
• 
•  Establish clear governance and data ownership guidelines. 
• 
•  Leverage knowledge from EU-funded research. 
•  Address legal implications and protect property rights. 
•  Advocate for user-friendly data access. 
•  Align objectives with EU environmental legislations. 

Implement transparent processes. 

60 
geospatial-environmental-data-and-access-to-environmental-information_en 

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13170-GreenData4All-updated-rules-on-

48 

 
 
 
 
Public consultation on the INSPIRE Directive 
The Public Consultation61, which ran from 5 February - 30 April 2025, sought evidence and 
views on the issues identified in the evaluation of the INSPIRE Directive, the challenges of the 
fast-evolving  European  data  landscape  and  the  possible  ways  to  address  these  issues.  The 
Public Consultation received 375 valid responses, and primarily called for a simplification and 
modernisation of the INSPIRE Directive. 

The stakeholder composition was diverse: public authorities formed the largest group (40%), 
followed by EU citizens (30.1%), academic and research institutions (10.7%), companies and 
businesses (7.2%), environmental organisations (2.4%), business associations (2.1%), NGOs 
(1.9%), non-EU citizens (1.6%) and other actors (4%). Public authorities were mainly national-
level bodies, while among organisations, 61% were large entities with over 250 employees. 

In terms of geographical distribution, the majority of respondents came from Belgium (20.5%), 
followed by Germany (12.5%) and France (11.2%). Other countries with notable representation 
included Portugal (7.2%), Spain (6.9%), and Finland (6.7%). Several other EU Member States 
contributed smaller shares, such as Austria (3.7%), the Netherlands (3.5%), Sweden (3.5%), 
Denmark (2.7%), and Latvia (2.7%). The remaining respondents originated from a wide range 
of countries including Italy (2.1%), Czechia (1.9%), Croatia, Ireland, Poland, and Switzerland 
(each around 1.3%), as well as Hungary, Lithuania, Slovakia, and the United Kingdom (each 
around 1.1%). A small number of responses were also received from Greece, Iceland, Norway, 
Estonia, Romania, and several non-EU countries such as Colombia, Ecuador, and the United 
States.  

Respondents engaged with green data in multiple roles. A total of 258 identified as data users, 
195 as producers, and 143 as hosts or providers. Green data is primarily used for research and 
development  (188  mentions),  public  awareness  and  education  (185),  territorial  and 
environmental planning (183), policymaking (170), compliance and reporting (169), business 
decision-making (92), corporate due diligence (76), and sustainability reporting (35). The most 
accessed data types included land use and land cover (258), climate and weather data (209), 
water  quality  and  quantity  (181),  biodiversity  (181),  hydrology  (171),  forestry  (165), 
agriculture  (160),  and  soil  quality  (153).  Data  is  most  commonly  accessed  through 
downloading processed files (33.1%), viewing services (27.2%), and raw/API access (24.5%). 

Respondents overwhelmingly recognised the importance of making public environmental and 
geospatial  data  more  accessible:  89.1%  rated  improved  access  for  public  authorities,  civil 
society,  research,  and  business  as  very  important.  However,  perceptions  of  current  data 
availability and usability were mixed: 44% agreed that existing data meets their needs, while 
25.4%  disagreed,  and  26.1%  remained  neutral.  The  most  significant  barriers  to  reuse  were 
fragmentation  across  producers  (41.3%),  incompatible  formats  and  standards  (39.2%),  and 
incomplete  geographic  or  thematic  coverage  (33.3%). Additional  issues  included  metadata 
quality,  lack  of  comparability,  insufficient  machine-readability,  inconsistent  APIs,  and 
language barriers. 

Participants strongly supported prioritising improved access to water (221 mentions), climate 
(205),  land  (200),  biodiversity  (182),  air  quality  (173),  soil  (172),  agriculture  (163),  and 
hydrology  (161)  data. A  proposed  common  European  portal  or  marketplace  for  reference, 
monitoring,  thematic  and  analytical  data  was  viewed  as  very  beneficial  by  61.6%  of 
respondents and somewhat beneficial by 25.1%. Extending such a portal to include research 
data, non-open data, and citizen-generated data also received majority support, with over half 

61 Ibid 

49 

 
 
 
considering it very beneficial. Respondents also expressed strong demand for support services 
such as a central platform for datasets, data integration and harmonisation services, real-time 
access and APIs, visualisation tools, and secure exchange mechanisms. 

Among the 375  respondents,  227 continued to Part B, focused on revision of the  INSPIRE 
Directive. Regarding alignment between INSPIRE and the Open Data Directive (ODD), there 
was strong agreement that such alignment would promote wider accessibility and reuse (133 
strongly agreed), simplify data-sharing rules (128), and reduce administrative burdens (111). 
On  governance,  a  clear  majority  supported  integrating  INSPIRE  under  a  common  EU 
governance  framework  linked  to  horizontal  legislation:  33.5%  strongly  supported  this  and 
43.6%  supported  it,  while  only  9.7%  were  neutral  and  fewer  than  10%  opposed.  However, 
many emphasised the need to safeguard geospatial expertise, data quality, and interoperability 
standards. 

On the involvement of data intermediaries in the creation of harmonised High-Value Datasets, 
31.3%  viewed  it  as  very  beneficial  and  33.5%  as  somewhat  beneficial.  Respondents  saw 
potential benefits in standardisation, quality assurance and scalability through APIs and cloud 
services. Concerns centred on transparency, governance, accountability, security, and the need 
to  preserve public oversight  and  avoid  reliance on opaque private platforms.  Regarding the 
continued  value  of  INSPIRE  as  a  standalone  instrument  if  fully  aligned  with  horizontal 
legislation, views were mixed. While 40.1% considered it highly or somewhat valuable, 27.3% 
saw limited or no value, and 15.4% remained uncertain. Many noted that INSPIRE’s technical 
framework—metadata  standards,  harmonised  data  models,  interoperability  rules—remains 
essential to geospatial and environmental data governance. 

25 individual attachments supplemented the consultation, of which 22 were directly relevant. 
These  contributions  highlighted  persistent 
issues  such  as  uneven  portal  usability, 
inconsistencies  in  data  quality,  and  cross-border  access  barriers.  Many  advocated  for  a 
federated  but  coherent  European  platform  built  on  national  nodes,  cautioning  against 
commercialisation or paywalls. Divergent opinions were expressed on citizen-generated data, 
with support contingent on clear quality and validation frameworks. Contributors also stressed 
the  importance  of  funding,  capacity-building,  secure  exchanges,  and  maintaining  geospatial 
coherence  within  broader  EU  data  legislation  (such  as  the  Open  Data  Directive  and  the 
Interoperable Europe Act). 

In  conclusion,  the  consultation  shows  strong  demand  for  greater  coherence, 
interoperability, usability and quality in environmental data governance. Stakeholders 
support simplification and integration at EU level but insist on retaining core geospatial 
standards  to  ensure  that  future  frameworks  remain  both  practical  and  scientifically 
robust. 

50 

 
 
 
 
ANNEX 3: LIST OF MAIN SUGGESTIONS FOR SIMPLIFICATION MADE 
VIA THE CALL FOR EVIDENCE 

As mentioned in the synopsis report, stakeholders submitted numerous suggestions to simplify 
environmental legislation. This annex lists the main suggestions. Note that not all suggestions 
are purely of administrative nature and may touch upon core parts of the legislation and hence 
go beyond the scope of  the omnibus  initiative. This  list  does not  necessarily  imply  that the 
listed suggestions will indeed be considered for this or future proposals. 

Contents 

EU Deforestation Regulation (EUDR) .............................................................................. 53 

Packaging and Packing Waste Regulation (PPWR) .......................................................... 53 

Industrial emissions ...................................................................................................... 54 

SCIP database .............................................................................................................. 55 

Waste Framework Directive (WFD) ................................................................................ 55 

Extended Producer Responsibility (EPR) ........................................................................ 56 

Batteries ....................................................................................................................... 57 

Single Use Plastics ........................................................................................................ 57 

Environmental assessment / permitting ......................................................................... 57 

Nature Restoration Regulation (NRR) ............................................................................. 58 

Ecodesign for Sustainable Products Regulation (ESPR) ................................................... 59 

Birds and Habitats Directives ......................................................................................... 59 

Water Framework Directive ........................................................................................... 60 

Urban wastewater treatment ......................................................................................... 60 

Waste shipments .......................................................................................................... 60 

Waste electrical and electronic equipment (WEEE) Directive .......................................... 61 

Nitrates Directive .......................................................................................................... 61 

51 

 
 
 
 
 
EU Deforestation Regulation (EUDR) 

•  Proportionality 

-  Limit due diligence requirements to the first placer of a product on the market. 
-  Exempt SMEs from polygon mapping and allow collective reporting. 
-  Allow cadastral references instead of polygons; remove strict GPS requirements. 
- 
-  Recognise sectoral specificities (e.g. publishing, chemicals, cosmetics, automotive) 
- based on the argument that in these sectors, relevant commodities are negligible 
fractions. 
•  Risk-based differentiation 

Introduce a de minimis rule excluding small forest owners (e.g. <4 ha). 

-  Create a “zero-risk” category for countries with negligible deforestation risk. 
-  Accept national legality regimes in low-risk countries as proof of compliance. 
-  Reduce/eliminate  due  diligence  statements  for  primary  producers  in  zero-risk 

countries (minimal documentation duty only). 

-  Recognise certification schemes (PEFC, FSC) as valid compliance evidence. 
-  Shift from country-level to commodity-level benchmarking.  
-  Enable a use of regional reference numbers. 

•  Rollout and implementation 

Improve digitalisation, harmonised templates, and interoperable IT systems. 
Introduce phased rollout starting with high-risk products. 

- 
- 
-  Provide grace periods for SMEs and non-punitive enforcement in the first year. 

Packaging and Packing Waste Regulation (PPWR) 
Regarding Extended Producer Responsibility (EPR): 

•  Change the application date of the producer definition to 1 January 2027.  
• 

Implement  an  EU-reporting  portal  with  harmonised  reporting  intervals  and  one 
common language interface.  

•  Remove the requirement of appointing an authorised representative in each Member 
State and introduce an obligation for producers established in third countries to appoint 
an authorised representative in the EU. 

•  Provide  relief  for  micro-companies  through  de  minimis-limits  and  exemptions  from 

EPR obligations. 

Further suggestions made regarding PPWR: 

•  Definitions: Clarify definitions and obligations. 
•  National  flexibilities:  Remove  provisions  allowing  Member  States  to  maintain  or 

introduce national sustainability or information requirements. 

•  PFAS:  Issue  a  guidance  document  on  the  PFAS  restriction.  Exclude  pharmaceutical 

packaging. Adjust the restriction to only “intentionally added” PFAS. 

•  Recycled content: Add more flexibility for the use of un-recycled plastics. Align the 

methodology for minimum plastic recycled content in PPWR to the SUPD. 
•  Minimisation: Delete the maximum limit for most common packaging types. 
•  Waste  sorting  labels:  Provide  flexibility  for  industry  to  use  different  waste  sorting 

labels. 

•  Reuse  targets:  Make  more  lenient  re-use  targets  for  transport  packaging.  Provide  an 

exemption from the re-use targets for beverages if they are part of a DRS. 

52 

 
 
•  Declaration of conformity: Specify that technical documentation can be submitted only 
in English. Remove the requirement to draw up a written declaration of conformity for 
each packaging type or set a de minimis threshold. 

Industrial emissions 

•  Environmental management system (EMS):  

-  Delete  the  EMS  requirements  entirely  as  it  duplicates  other  regulatory 

frameworks within the EU without additional benefits.  
-  Recognise  existing  environmental  management 

systems 

that  meet 

internationally accepted standards like ISO 14001 or EMAS as sufficient. 
-  Align EMS requirements across existing legislation (IED, CSRD, CS3D, EU 

- 

ETS, REACH) to avoid duplication and high reporting costs. 
Introduce exemptions or simplified EMS requirements for small and medium-
sized enterprises (SMEs) to reduce compliance burdens.  

-  Remove  obligations  for  EMS  to  be  publicly  available  or  audited  every  three 

years by accredited verifiers. 

-  Permit site-wide or company-wide systems instead of requiring separate EMS 

for each installation, especially for multi-site companies. 

•  Chemical inventory: 

-  Delete  the  chemical  inventory  requirements:  some  stakeholders  propose 
removing the chemicals inventory requirement entirely due to it being seen as a 
redundant  and  costly  measure.  The  main  rationales  are  that  the  chemicals 
inventory  duplicates  existing  regulations  under  REACH  and  occupational 
health and safety rules, resulting in additional administrative burdens without 
improving environmental or employee health protection.  

-  Simplify  and  streamline  the  legal  requirements  concerning  the  chemicals 

inventory to reduce bureaucracy and operational burdens.  

-  Limit the scope of the inventory: limit the chemical inventory to substances of 
very  high  concern  only,  given  that  hazards  are  already  covered  by  other 
regulations.  

•  Transformation plans: 

-  Minimise the level of detail of the Transformation Plans, by ensuring alignment 
with  other  legislation  requiring  transition  plans  or  by  deleting  the  provision 
altogether. 

-  Align between pieces of legislation by making the IED to be the only piece of 

legislation to require a transformation plan. 

•  Other suggestions: 

-  Amend the scope of the revised IED in  relation,  e.g. to temporary storage of 
hazardous waste, semiconductors, production of pig iron and the farm sizes. 
-  Simplify the deployment of hydrogen-firing power plants by adapting existing 
requirements to this emerging low-carbon process; as well as the use of oxygen-
enriched combustion air, which facilitates capture of carbon dioxide. 

-  Speed  up  permitting,  including  by  putting  in  place  one-stop-shop,  digital 

permitting and specific timelines and better coordination with EIA. 
-  Adress specific monitoring issues for back-up generators in data centres. 
-  Use the entire BAT-AEL range instead of the lower end of the range. 

53 

 
 
 
 
 
- 

Intensive  agriculture:  delayed  implementation  of  the  uniform  conditions  for 
operating rules beyond 2030 and other suggestions aimed at deleting substantial 
requirements. 

-  Amend  derogation  requirements  in  view  of  enhancing  flexibility  (e.g.  by 

deleting Annex II of the IED or postponing its implementation). 

-  Make environmental performance levels not mandatory. 
-  Modify  monitoring  provisions  in  relation  to  compliance  with  environmental 

quality standards. 

-  Enable simpler, harmonised, and digital environmental reporting.  
-  On the Industrial Emissions Portal Regulation (IEPR), the main items covered 
by stakeholders’ suggestions are aimed at simplifying reporting by farmers and 
aquaculture operators under the IEPR by exempting livestock and aquaculture 
operators  from  reporting  on  water,  energy  and  materials  use,  and  allowing 
Member States to report more information than releases to air, water and land 
on behalf of individual farmers and aquaculture operators. 

SCIP database 

•  The  repeal  of  the  SCIP  database  (Substances  of  Concern  In  articles  as  such  or  in 

complex objects (Products)) 

•  Revision and improvement of the database’s usability (e.g., search functions, reporting 

requirements) or merging it with the DPP 

Waste Framework Directive (WFD) 

•  Address  inconsistent  waste  classification  and  List  of Waste  (LoW)  codes  across  EU 

Member States. 

•  Establish  a  unified  digital  platform  for  waste  traceability  (art.  35  WFD)  with 
standardized  documentation,  replacing  fragmented  national  systems;  harmonise  the 
‘transfer note obligations’ (art 35 WFD) across the EU. 

•  Standardize  waste  storage  durations  within  the  WFD  to  ensure  consistent  and 

environmentally sound waste management practices across Member States. 

•  Exempt from waste permitting for shredding data- and IP-bearing electronic equipment, 
aligning  with  GDPR  and  reducing  regulatory  burdens  while  ensuring  secure  data 
destruction. 

•  Address  overlapping  requirements  across  different  frameworks  such  as  the  IEPR, 
national annual waste declarations in certain Member States, and the Eurostat annual 
survey on packaging and packaging waste. 

•  Digitalise 

and 

further 

finetune  waste 

documents 

(in 

particular  R4 

Recycling/reclamation of metals and metal compounds). 

•  Recognise sludges and solid wastes from the processing of food, beverages and feed 
commonly used as input materials for digestate (and compost) and further incentivise 
under the EU Waste Framework Directive and the EU Fertilising Products Regulation. 
These waste streams are typically less contaminated and more consistent in quality than 
separately collected household biowaste, making them a reliable resource. Recognising 
their  comparability  would  help  promote  their  recycling  and  support  the  circular 
economy. 

•  Remove the 10% landfill target from the Landfill Directive (LD). 
•  Facilitate the reuse of materials on construction sites (WFD, Art. 3 & Art. 5 + European 

Protocol on Construction Waste Management). 

•  On end-of-waste criteria: 

54 

 
 
- 

-  Address  fragmentation  and  inconsistency  of  end-of-waste  and  by-product 
criteria (calling for mutual recognition of end-of-waste status and of national 
criteria, speeding up adoption process, create a list of products that are ‘deemed 
to be considered as by-products’ throughout the EU), as well as the different 
level of contaminants allowed for in types of so-called "green listed” waste. 
If the protection objectives for human health and environment  can be met  in 
substances or a product legislation, an end-of-waste statute should be granted 
quasi  “automatically”  (e.g.  if  materials  streams  have  been  registered  under 
REACH). 
Introduce harmonised time limits and simplified procedures for the recognition 
of  end-of-waste  status  (Article  6)  at  EU  level. Allow  the  launch  of  recovery 
operations  within  90  days  of  notification,  unless  objections  are  raised  by  the 
competent  authority,  and  provide  for  the  possibility  of  simplified  general 
authorisations for non-hazardous waste 

- 

Extended Producer Responsibility (EPR) 

•  Deploy a unified, interoperable EU level digital portal where producers register once, 
submit all EPR data (fees, volumes, material composition, etc.) and make payments a 
single time. The platform should use standardized templates, be machine readable, and 
automatically  share  data  with  national  authorities,  customs  and  enforcement  bodies 
while safeguarding confidential commercial information.  

•  Remove the obligation for producers to appoint separate authorised representatives in 
every Member State. Designate a single EU based authorised representative for all non-
EU  producers,  replacing  the  current  requirement  for  a  separate AR  in  each  Member 
State.  

•  Apply scaled reporting and fee obligations based on company size, turnover and risk 
profile, granting SMEs lighter duties (e.g., thresholds of 10–30 products per year per 
country).  

Other comments include: 

-  Establish a unified EU oversight body for EPR. 
-  Standardise EPR Reporting Formats and Timelines Across the EU. 
-  Establish Clear, Harmonised Producer Responsibilities and Obligations and Introduce 

a Digital, One-Stop-Shop for EPR Reporting. 

-  Harmonise EPR Fee Structures and Calculation Methodologies.   
-  Harmonise the definition of ‘producer’ across EU Member States. 
-  Align EPR Scope with the Polluter-Pays Principle and Proportionality, including for 

SMEs. 

-  Accelerate and Strengthen Implementation of EPR Systems. 
-  Assess the functioning of existing EPR and assess possible new ones. 
-  Protect Confidential Business Information Within EPR Reporting. 
-  Create a Unified Authorized Representative (AR) Regime for Non-EU Producers. 
- 
-  Ensure EPR Fees Are Reinvested Into Waste-Management and Innovation. 
-  Allow for Sector-Specific Adjustments Within a Harmonised EPR Framework.   
-  Do not allow PROs having an operational role in the same market that they operate and 

Integrate EPR Data with the Digital Product Passport (DPP). 

ensuring PROs to be not-for-profit. 

55 

 
 
Batteries 

•  Make more use of digital means to fulfil legal obligations in the Batteries Regulation, 

such as labelling. 

•  Postpone the date of application of specific Articles, such as Article 11 or the Battery 
Passport, or introduce amendments for specific legal obligations which are considered 
difficult to be fulfilled. 

•  Clarify  certain  obligations,  such  as  those  for  battery  modules  and  packs,  and  EPR 

obligations for reused batteries. 

•  Harmonise  due  diligence  obligations  across  the  Batteries  Regulation  and  related 

directives (DG GROW in the lead). 

Single Use Plastics 

•  Harmonize  the  Definition  of  “Single-Use  Plastic  products”  and  Plastic  Content 

Thresholds with Packaging and Packaging Waste Regulation (PPWR). 

•  Remove  the  Requirement  to  Reduce  the  Consumption  of  Single-Use  Plastic  food 

containers and cups for beverages. 

•  Remove the Requirement for a Separate Litter-Related Marking (the "Turtle Logo"). 
•  Remove Producers’ Liability for Litter Clean-Up Costs. 
•  Simplify the Calculation Method for Recycled Content Targets. 
•  Harmonize Definitions and Reporting Requirements Related to Recycled Content. 
•  Exempt chemically modified Natural Polymers that are Biodegradable from the Plastics 

Definition. 

Environmental assessment / permitting 
Streamlining/digitalization/administrative capacity 

•  Better  coordination  between  the  Strategic  Environmental Assessment  (SEA)  and  the 

Environmental Impact Assessment (EIA) procedures.  

•  Procedures  under  the  Industrial  Emissions  Directive  (IED)  should  be  completely 
exempt  from  the  EIA.  Or,  if  an  EIA  screening  shows  no  material  impact,  omit  IED 
permitting.  

•  Generalised one-stop shop for all permitting procedures, including one single permit 

application, and joint processing of permitting.  

•  Digitalization of permitting procedures, through the creation of electronic permitting 

systems.    

•  Address lack of resources and lack of knowledge on complex assessments regarding 
environmental legislation, at national authorities, as well as poor coordination between 
authorities and insufficient financial resources.   

Duration of procedures 

•  Target maximum duration for the permit-granting process and subsequent legal actions 
(maximum  2-3  years  in  total)  and  setting  clearer  timelines  for  responses  by  public 
authorities, e.g. for screening.   

•  Allow  for  sufficient  time  and  quality  in  early-stage  planning  and  environmental 

assessments. 

•  Tacit  approvals  for  environmental  permitting  procedures  in  case  of  smaller  projects 
with  no  expected  significant  environmental  impact  (certain  stakeholders  express 
caution against tacit approvals though).   

Access to justice 

56 

 
 
 
 
• 

Introduce  “substantive  preclusion”  in  EU  environmental  procedural  law,  i.e.  the 
applicant is no longer heard in the judicial proceedings with a specific argument, unless 
he has already submitted this in the administrative procedure.  

•  Member States should ensure that applicants have access to a straightforward /simpler 
dispute settlement process to prevent excessive delays caused by abusive litigation.  
•  Limit access to justice to public actually affected by the project (based on immediate 
local impact), and to a single initial phase of decision-making, preferably during zoning 
procedures. Initiation of a review should be a reasoned request (not an appeal) to the 
competent administrative authority.  

•  Limiting the right for late appeal under the Aarhus Convention. Allow minor procedural 

errors to be remedied without remanding the case.  

Prioritization of sectors/types of projects 

•  Recognize Energy Infrastructure as a matter of Overriding Public Interest; fast-Track 
Scheme for Critical (Energy) Infrastructure Projects with MSs taking the final decision 
to classify a project as critical; streamline the EIA process for hydrogen infrastructure, 
including hydrogen pipelines in Annex II of the EIA Directive; specific treatment for 
pumped hydro. 

Specific suggestions on EIA/SEA 

•  Require  Member  States  to  set  screening  only  through  specific  thresholds  or  criteria 
(such  as  the  location,  size  or  type  of  project)  instead  of  a  case-by-case  analysis,  to 
determine whether an EIA is needed.  

•  Extend  the  flexibility  for  Member  States  to  apply  exemptions  of  environmental 
directives  for  defence  projects  (e.g.  under  EIA,  SEA)  to  other  sectors  and  for  other 
Directives (e.g. Habitats, Birds, Water Framework)   

•  Assume that there will always be a baseline environmental impact for critical (energy) 
infrastructure projects avoiding years of data collection and assessments aimed at ruling 
out  any  likelihood  of  environmental  impact  and  focus  the  process  in  offsetting  the 
impacts it effectively.   

•  The EIA Directive should be amended so that an assessment in accordance with the 
directive is not necessary in cases where the assessment has already been conducted 
with sufficient accuracy as part of the SEA process. Avoid duplications between SEA 
and EIA.   

•  As  in  the  IED,  a  water  electrolysis  activity  should  be  introduced  and  a  production-
related threshold should be introduced in Annex 1 of the EIA Directive. The threshold 
should be based on the corresponding threshold set out in Annex 1 to the IED.   

Nature Restoration Regulation (NRR) 

•  Delay by one year the deadline for MS to submit National Restoration Plans, to ensure 
better stakeholder involvement and to consider lack of resources in Member States. 
•  Support  stakeholders  engaging  in  or  affected  by  restoration  measures,  notably  if 
property and land use rights are affected, and provide sufficient and dedicated funding 
for stakeholders (farmers, forest owners etc) and MS to implement the NRR. 

•  Allow for flexibility to take into account i) local ecological and economic conditions; 
ii) force majeure and natural disasters; iii) lack of data: iv) climate change impacts; v) 
overriding public interest. 

57 

 
 
 
 
 
•  Minimise  administrative  burden,  by  providing  guidelines  for  NRP  preparation, 
streamlining and digitalising reporting obligations, publishing guidelines to clarify and 
harmonise concepts and science-based methodologies, etc. 

•  Sector  specific  suggestions  (some  key  ones):  i)  review  peatland  rewetting  targets  to 
safeguard agriculture in certain regions; ii) take into account climate change trends in 
forest  management;  iii)  clarify  concepts  for  urban  ecosystems;  iv)  provide 
methodologies for restoration of extraction sites. 

Ecodesign for Sustainable Products Regulation (ESPR) 

•  Substances of concern (SoC): to harmonize reporting on substances of concern, avoid 
overlap with or give prominence to REACH and some suggest to remove the obligation 
to  provide  information  on  substances  of  concern  (SoC)  as  stipulated  in  the  ESPR 
Regulation (Article 5). 

•  Time predictability: Ensure clear and predictable timelines by setting a strict 36-month 
minimum  transition  period, instead of 18 months (Article 4 (4)) and  eliminating the 
option to shorten it “in duly justified case”.  

•  Ban on destruction of unsold goods: a) to align the application of Article 24’s reporting 
obligation  on  destruction  of  unsold  goods  with  the  implementation  timeline  of  the 
harmonised  disclosure  format  introduced  in  the  implementing  act,  for  instance  by 
postponing  the reporting obligation to  2027–2028, when the harmonised  format and 
product  categorisation  will  be  fully  applicable,  b)  inclusion  of  a  derogation  for  the 
recycling of unsold consumer products in cases where it represents the option with the 
least negative environmental impacts. 

•  Exclusion  of  some  products  groups/sectors  and  articulation  with  other  sectoral 
legislation: a) to remove components and subassemblies of finished products already 
regulated by delegated acts from the scope of ESPR, also when they are placed on the 
market as spare parts for finished products that are already regulated by delegated acts, 
b) to exclude packaging from the scope as packaging is already regulated by the PPWR, 
c) to exclude aerospace sector from the scope —including intermediate products and 
supply - chain elements - in line with the established exclusion of ‘means of transport’ 
under the previous Ecodesign Directive. 

•  Textiles: Life Cycle Assessment (LCA) and Product Environmental Footprint (PEF), 
require critical reassessment. LCA would focus narrowly on environmental harm and 
fail to account for the environmental impact delivered by natural fibres and sustainable 
farming systems, advantaging fossil-based textiles. 

Birds and Habitats Directives 

Stakeholder groups representing interests of certain economic sectors mainly expressed the 
need for proportionate impact assessment procedures, flexible derogations, and the need for 
support to address the socio-economic impacts of implementation. Among the suggestions, 
these are most prominent:  

•  Appropriate  assessments  under Article  6(3)  of  the  Habitats  Directive  should  be 
clearer, faster, and avoid unnecessary duplication with EIA/SEA procedures.  
•  Authorities and operators need clearer EU-level guidance on acceptable mitigation 

and compensatory measures under Article 6 of the Habitats Directive. 

•  There  should  be  better  financing  and  stronger  stakeholder  engagement  in  the 

management of Natura 2000 sites. 

58 

 
 
•  The  need  for  fair  compensation  and  incentives  for  farmers,  foresters,  and 

landowners managing Natura 2000 sites.  

•  The species protection regime should allow flexible derogations and clearer rules 
on  managing  wolves  and  other  species  to  balance  biodiversity  with  farming  and 
rural interests.  

Water Framework Directive 
While providing general support for the Water FD and its objectives some stakeholders suggest:  

• 
• 

• 

Introduction of a definition of “deterioration” to enhance legal clarity.  
Extending the deadline for achieving the objectives beyond 2027 (either by setting 
a new deadline or by amending the time-related extensions foreseen under article 
4(5).  
In  addition,  mining  and  metal  processing  industry  associations,  call  for  the 
possibility  to  allow  for  increasing  water  pollution  and  to  introduce  significant 
derogations to the principle of non –deterioration, to allow for:   

temporary deterioration. 
relocation of pollutants.  

▪ 
▪ 
▪  deterioration of chemical status.    

Urban wastewater treatment 

•  The  cosmetics  and  pharmaceutical  sectors  call  for  putting  on  hold/freezing  the 
implementation of the Extended Producer Responsibility (EPR) in articles 9, 10 and 
Annex III of the UWWTD, while re-assessing its cost and the toxic load of polluting 
sectors  and  afterwards  revising  the  Directive.  Some  suggest  setting  a  cap  on  EPR 
contributions.  

•  Chemicals companies/ associations call notably for common criteria for products not 
tax  per 
replacing 

the  EPR  system  by  a 

generating  micropollutants  and 
person/household.  

•  Chambers of commerce propose to restrict quaternary treatment to drinking water areas, 
call  for  a  fairer  cost  attribution  between  polluters  and  a  simplification  of  reporting 
obligations.  

Other suggestions by the above-mentioned stakeholders include: 

• 
• 
• 
• 
• 
• 

the change from a sector-based EPR to a substance-based scheme 
the development of a dynamic EU positive list of micropollutants 
the clarification of some definitions (e.g. micropollutants; non-domestic wastewater) 
the need to ensure a harmonised implementation of EPR  
the allocation of EPR contributions with a risk-based methodology 
the need to clarify the interface between the UWWTD and REACH 

On the other side of the spectrum, the water industry as well as cities and municipalities defend 
the EPR provisions, and the polluter pays principle.  They defend keeping the Directive as it is 
– they are against revising the Directive. They are keen to ensure its timely implementation and 
to  avoid  undermining  the  objectives  of  the  recent  Water  Resilience  Strategy.  They  also 
underline that, without EPR, investments in quaternary treatment would imply higher water 
tariffs, impacting public budgets. 

Waste shipments 
Simplification of the digital procedures and DIWASS (DIgital WAste Shipment System):  

59 

 
 
•  Postpone the mandatory use of electronic means/provide for +1 year transition. 
•  Ensure interconnection with corporate software and outside EU. 
•  Provide clear guidance and training to economic operators on the new regulations and 

digital tools to ensure compliance and ease of use. 

Stakeholders also propose simplification of the pre-consented facilities:  

•  Consent for shipments to a pre-consented facility up to 5 years (compared to 3 years 

now). 

•  Allow multiple waste producers in the case of pre-consented facilities. 
•  Establish  a  centralized  EU-wide  pre-consent  mechanism  for  recovery  facilities,  so  a 
single  approval  is  valid  across  Member  States,  eliminating  multiple  national 
procedures.  

•  Automatically  recognize  pre-consent  status  across  the  Union  once  a  single  Member 

• 

State grants it. 
Introduce  a  fast-track  notification  procedure  +  introduce  a  transparent,  step-by-step, 
EU-wide  procedure  for  revoking  pre-consent  to  reduce  uncertainty  and  safeguard 
business continuity. 

Waste electrical and electronic equipment (WEEE) Directive 

•  Guarantee coherence between the WEEE Directive and the future Circular Economy 

Act. 

•  Harmonise  various  European  systems  or  mutual  recognition  of  waste  electrical  and 

electronic equipment (WEEE). 

•  Build a single digital EU reporting portal for WEEE data using harmonized formats and 

annual reporting. 

•  Abolish the requirement for Authorized Representatives for WEEE.   

•  Adopt a single EU-wide definition of “placing on the market” for WEEE. 

•  Revise Annex VI of the WEEE Directive to differentiate used equipment from waste. 

Nitrates Directive 

•  Processed manure: Allow for RENURE products above the manure application limit, 
allow digestates without further treatment above the manure application limit, remove 
all processed manure from manure application limit.  

•  Derogations  from  manure  application  limit:  simplify  derogation  process,  replace 
separate allowances for manure and chemical fertilisers with one single overall limit. 
•  Reduce burdens on farmers without shifting core focus:  uniform reporting tools for 
nutrients to reduce burden and increase compliance, simplify regimes for some farmers 
and less prescriptive rules via technological tools and recognition of precision farming, 
reduce pace of change in national measures by aligning regulatory cycles of the Nitrates 
Directive with the investment horizons typical for on-farm improvements. 

•  Adapt measures to address issues such as calendar farming and the effects of climate 

change.  

•  Replace blanket measures with targeted actions in high-risk catchments. 
•  Streamline reporting by Member States.  
•  Focus  on  implementation  as  amending  the  directive  would  bring  unnecessary 
uncertainty. Many of the issues raised by stakeholders are related to implementation 

60 

 
 
rather than specific legal provisions. Many stakeholders underlined the need for better 
implementation. 

61 

 
 
 
 
 
 
 
ANNEX 4: WHO IS AFFECTED AND HOW? 

Summary of costs and benefits 

The following table presents a summary of the reduction in administrative burdens associated with the different measures. Not all of the measures 
included in the proposal are easily quantified, and so the estimate of savings needs to be considered as an initial and central estimate within a broad 
range. For example, the savings associated with the streamlining and acceleration of environmental assessments are based on an efficiency increase 
of 10 per cent, which is arguably conservative, ie an underestimate, of the likely savings. Also, a number of measures are relatively small individually 
in terms of cost savings and so were not quantified, but are still likely to be several million Euro per year and of particular relevance to the benefiting 
sectors. Reflecting this, the overall impact is likely to be higher than the sum of the measures that were individually quantified (EUR 890 million per 
annum), with the other measures assumed to provide many tens of million of Euro per annum of savings. Overall, the total estimated reduction of 
administrative burdens is estimated to be around EUR 1 billion per annum.  

The reduction in administrative burdens is relevant for the Commission’s one-in-one-out estimates.  

The impact on the environment is likely to be close to neutral, reflecting the climate consistency check and the analysis of other environmental 
impacts.    

The Commission has the requirement to assess the consistency of this proposal with the climate-neutrality objective set out in Article 2(1) and the 
Union 2030 and 2040 climate targets. The proposal is considered consistent with ensuring progress on adaptation as referred to in Article 5. In 
particular, the permitting measures will be beneficial in supporting the transition to low carbon technologies. The other measures will not lead to 
further greenhouse gas emissions.  

Overview of Benefits 

Description 

Amount 

Comments 

Overall benefits - consisting of the elements below  

Direct benefits – per annum values 

EUR 1 billion per annum of 
administrative burden reduction plus 
other benefits, notably speeding up of 
permitting 

62 

Overall benefits associated with the proposal, mostly for 
business but also for public authorities, which will 
generally be passed on to business 

 
 
 
 
 
 
Reporting of chemicals of concern (section 4.1) 

At least EUR 225 million per annum 

Benefits primarily for business 

Waste reporting (section 4.2) 

Not quantified 

Benefits primarily for public authorities 

Authorised representatives (section 4.3) 

EUR 300 million per annum 

Benefits primarily for business 

Methodology for digital packaging (section 4.4) 

Not quantified 

Benefits primarily for business 

Environmental Management Systems under the IED 
(section 4.5) 

EUR 100 million  

Benefits primarily for business 

Permitting of iron production under the IED (section 4.6)  Not quantified 

Benefits primarily for public authorities  

Permitting of oxy-fuel combustion (section 4.7) 

Not quantified 

Benefits primarily for business 

Permitting of hydrogen combustion (section 4.8) 

Not quantified 

Benefits primarily for business 

Transitional provisions for certain IED provisions 
applicable to industrial installations (section 4.9) 

Not quantified 

Benefits primarily for public authorities 

Simplification for livestock farms under the Industrial 
Emissions Directive (section 4.10) 

Not quantified 

Benefits primarily for livestock installations 

Livestock and aquaculture operators reporting to the 
Industrial Emissions Portal (section 4.11) 

EUR 70 million per annum 

Benefits primarily for livestock and aquaculture 
installations 

Back-up generators (section 4.12) 

EUR 3 million per annum 

Benefits primarily for business (large data centres) 

Spatial information requirements (section 4.13) 

EUR 12 million per annum 

Benefits primarily for public authorities and business 

Environmental Assessments Streamlining and 
Acceleration (section 4.14) 

Environmental impacts 

EUR 180 million per annum 

Benefits primarily for business 

The measures overall have an 
environmental impact close to neutral. 

63 

 
 
 
 
 
 
 
 
Application of the ‘one in, one out’ approach – Preferred option 

One-off 
(annualised total net present 
value over the relevant period) 

Recurrent 
(nominal values per year) 

Total 

Businesses 

New administrative burdens (INs) 
Removed administrative burdens (OUTs) 

Net administrative burdens* 

Total administrative burdens*** 

None 
EUR 1 billion per annum 
Reduction of EUR 1 billion per 
annum 

EUR 1 billion per annum 

Reduction of EUR 1 billion per annum 

Reduction of EUR 1 billion per annum 

Overview of relevant Sustainable Development Goals – Preferred Option(s) 
Relevant SDG 

Expected progress towards the Goal 

Comments 

SDG numbers 8 and 12 – related to 
sustainable industry, economic growth and 
responsible consumption and production 

The measures will support the competitiveness and productivity of 
European industry by reducing the administrative costs they incur during 
sustainable production.  

SDG numbers 12 and 13 – related to climate 
action and responsible production and 
consumption  

The measures will support the environmental performance of the EU by 
facilitating greener production and consumption. By making 
implementation easier and cheaper, without compromising overall 
standards, the environmental impact will be close to neutral.  

Climate consistency check undertaken. 

64