Earlier in the week, we posted that the European Commission would soon be launching an environmental call for evidence, as a step towards the introduction of an environmental omnibus simplification proposal. That call for evidence went out yesterday, as discussed in this post. Among other things, the call for evidence highlights possible areas of environmental simplification and the anticipated timing of the Commission’s proposal.
The call for evidence seeks input on how to simplify EU environmental legislation and reduce administrative burdens at the implementation level, including how to make EU environmental laws faster, easier and cheaper to implement. Among other things, the Commission uses calls for evidence to define an evaluation of an existing law or policy and/or a fitness check of a bundle of related existing laws and/or policies. A call for evidence describes the problem to be tackled and objectives to be met, explains why EU action is needed, outlines policy options and describes the main features of the consultation strategy.
According to the Commission, the environmental omnibus will put together a series of measures to simplify environmental legislation concerning the circular economy, industrial emissions and waste management. The Commission intends to introduce a legislative proposal during the fourth quarter of 2025.
Potential areas for simplification measures have been identified based on, among other things, stakeholder input collected through a previous call for evidence on the rationalization of reporting requirements, spontaneous stakeholder input and stakeholder meetings. In addition, as part of an ongoing study on environmental reporting, input was gathered from more than 300 participants in an online workshop on February 13 and via a follow-up survey.
Simplification measures cited by the Commission in the call for evidence may include streamlining administrative obligations, removing double obligations to report, promoting further digitalization of reporting and addressing permitting challenges. More specifically, the call for evidence indicates that, after stakeholder input has been gathered, simplification measures proposed may include:
- Rationalizing reporting/notification obligations, such as the discontinuation of the SCIP (substances of concern in products) database under the Waste Framework Directive;
- Harmonization of the provisions for authorized representatives for extended producer responsibility (EPR) in each member state where a producer sells a product falling under EPR rules and on facilitation of EPR reporting;
- Streamlining reporting obligations, removing double requirements to report and promoting further digitalization of reporting in the areas of circular economy, industrial emissions and waste management; and
- Addressing permitting challenges relating to environment assessments.
The Commission is screening environmental legislation to identify legislative acts with administrative simplification potential and will analyze suggestions gathered from the current and previous consultation processes. The list of measures may evolve based on stakeholder feedback and further analysis.
The call for evidence is open until September 10. It can be accessed here.
The Commission also will consult stakeholders through other consultation activities, such as expert groups and forums. Targeted consultations also may be undertaken.
For a discussion of possible changes to the EU Deforestation Regulation, see this Ropes & Gray post from yesterday: Seeing the Forest for the Trees: Further Changes to the EU Deforestation Regulation are Likely.
