European Commission Presents Environmental Omnibus: News For EPR, SCIP, Industrial Emissions, and Environmental Assessments

On 10 December 2025, the European Commission published the Environmental Omnibus package, which focuses on simplifying environmental legislation in the areas of industrial emissions, circular economy, environmental assessments and geospatial data. The package aims to reduce unnecessary bureaucracy for businesses while ensuring that the same environmental goals are achieved in more efficient, less costly and smarter ways. According to the European Commission, the Environmental Omnibus is expected to generate savings of approximately EUR 1 billion per year for businesses.

The Commission decided to simplify regulations and reduce administrative burdens for companies in pursuance of the priorities set out in the Draghi report on EU competitiveness published in September 2024, which highlighted the importance of transitioning to a low-carbon, resource-efficient and circular economy. In its Competitiveness Compass (published on 29 January 2025), cutting red tape was identified as one of the five main enablers of competitiveness. In the same document, the Commission set the objective of reducing administrative burdens by at least 25% for all companies, and 35% for small- and medium-sized enterprises.

In line with this overarching simplification objective, the Commission presented seven omnibus proposals throughout 2025, addressing areas such as sustainability, the common agricultural policy and chemicals legislation, among others. The present Environmental Omnibus is the eighth proposal intended to simplify the EU regulations.

Reflecting the results of the call for evidence published in July 2025, which generated almost 200,000 responses from citizens, businesses, civil society and think tanks, the Environmental Omnibus consists of six legislative proposals.

1. What are the Key Elements of the Proposal?

• Quicker environmental assessments: Environmental assessments are conducted as part of the permits delivery procedures to execute projects (including for chemicals manufacturing, waste treatment and incineration, etc.), as well as to implement plans and programmes. They are foreseen in various directives, including Directives 2000/60/EC (water policy), 2001/42/EC (assessment of the effects of certain plans and programmes on the environment), 2009/147/EC (conservation of wild birds), 2011/92/EU (assessment of the effects of certain public and private projects on the environment) and 92/43/EEC (conservation of natural habitats and of wild fauna and flora).

  The Commission proposes measures to accelerate and simplify the conduct of environmental assessments, with the goal of speeding up and streamlining the entire permitting procedures. This was already highlighted in the Chemicals Industry Action Plan of 8 July 2025.

  The proposal aims to ensure that businesses benefit from simpler and faster procedures. Key measures include the introduction of single points of contact and enhanced cooperation between authorities for environmental assessments with cross-border impacts. Digitalisation, as well as ensuring that permitting authorities have sufficient staffing and capacity, are also identified as priorities.

  The proposal also introduces a toolbox of further legislative measures to accelerate key energy, digital and industrial decarbonisation projects, including relevant circular economy projects. This toolbox includes: (i) a provision on how to balance overriding public interests to help projects; (ii) a possible tacit approval by competent authorities as regards intermediary administrative steps; and (iii) more expedient dispute resolution procedures in Member States for these projects. 

• Simplified Extended Producer Responsibility: The current legislation on batteries, packaging, electronic equipment, single-use plastic and waste requires EU companies selling products in Member States other than those where they are based to fulfil their obligations in relation to their Extended Producer Responsibility (“EPR”) for waste management requirements by appointing an authorised representative in those Member States. Under the new rules proposed by the Commission, while the streamlining of the EPR schemes under the Circular Economy Act (due for adoption by the Commission in 2026) is pending, the obligation to appoint authorised representatives will be suspended for EU producers. 
• Reduced administrative burdens under waste legislation: The Substances of Concern in Products (“SCIP”) database is a public database operated by the European Chemicals Agency (“ECHA”), containing information on hazardous chemicals in products sold in the European Union. The Commission concluded that the SCIP database has not been effective in informing recyclers about the presence of hazardous substances in products, and has imposed significant administrative costs on companies.

  Therefore, in light of the expectation that the Digital Product Passport will provide a more effective solution, the Commission proposes the amendment of the Waste Framework Directive to repeal the SCIP database. 

• Simplified industrial emissions standards: Under the current framework, the Industrial Emissions Directive (Directive 2010/75/EU; “IED”) requires companies to prepare and implement environmental management systems (“EMS”), a structured framework of processes, objectives, etc. to help companies manage and improve their environmental impacts.

  The current IED requires operators to have separate EMS for each installation falling under the IED. In the Environmental Omnibus, the Commission proposes to introduce greater flexibility by allowing companies to prepare the EMS at company level within the same Member State.

  Moreover, in addition to the current deadline of 2027 to prepare and implement their EMS, companies will be granted an additional three years (i.e., until 2030) to do so. The content of the EMS will also be simplified. 

• Reporting on spatial data: The INSPIRE Directive (Directive 2007/2/EC) was adopted to enable the sharing of environmental spatial information (i.e., information linked to specific locations about, e.g., roads, buildings, population) among public sector organisations, while the Open Data Directive (Directive (EU) 2019/1024) was adopted to promote the use of open data and stimulate innovation. The Commission considers that this system is currently not sufficiently effective and more costly than intended, so it proposes to align the technical data requirements of the INSPIRE Directive with those of the Open Data Directive. In practice, this alignment is expected to reduce compliance costs for public authorities and to facilitate access to high value geospatial datasets for both public and private users.

2. Next Steps, Future Simplification Plans

The European Commission's legislative proposals will now be submitted to the co-legislators—namely the European Parliament and the Council—for adoption. Of course, all the proposals are subject to possible changes. The Commission intends to continue pursuing its simplification agenda in 2026 as well. Simplification will be a cornerstone of the forthcoming Circular Economy Act and will play an important role in the review of the Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). This plan is currently expected for adoption by the Commission in early 2026. In addition, the Commission plans to review and revise the Waste Framework Directive.

How Can We Help?

Mayer Brown's EU Regulatory practice has extensive experience advising a broad range of companies and trade associations in connection with chemicals legislation, products legislation and safety and sustainability requirements. We help our clients prepare for legislative changes, ensuring that they keep up-to-date with regulatory developments and meet the challenges posed by an ever-shifting regulatory environment.

Our team stands ready to advise on the potential implications of the regulations on environmental assessments, industrial emissions standards, extended producer responsibility and waste, as well as other regulations that are part of the European Union's chemicals and products legislations impacting your companies' specific operations and products.