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OPINION (COM(2025)0986 – C100336/2025 – 2025/0394(COD))

On the proposal for a directive of the European Parliament and of the Council amending Directives 2008/98/EC, 2010/75/EU, (EU) 2015/2193 and (EU) 2024/1785 of the European Parliament and of the Council as regards simplification of some requirements and reduction of administrative burden

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Committee on Industry, Research and Energy · Rapporteur: Jüri Ratas

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The Committee on Industry, Research and Energy gives its opinion on the Commission proposal to simplify environmental directives. It proposes amendments to cut administrative burden, remove the environmental management system obligation, and simplify rules on best available techniques and derogations. The amendments delete the EMS obligation and related recitals, remove the chemicals inventory and transformation plan requirements, and extend permit reconsideration from 4 to 8 years. They introduce a presumption that costs are disproportionate where they exceed 10 % of total capital investment cost, and set a 10 % cost difference threshold for the strictest end of the BAT-AEL range. They also extend crisis derogations to six months, allow Member States 12 months to comply, and require a Commission evaluation by 30 June 2027.

Committee position. The committee proposes targeted amendments to simplify environmental legislation, reduce administrative burden, remove the EMS obligation, and introduce a presumption of disproportionality for derogations, while preserving environmental objectives.

Key points

  1. The rapporteur welcomes the Commission proposal but says it does not reach the ambition needed for the Union's simplification and competitiveness goals.
  2. The opinion aims to reduce administrative burden, simplify environmental management system requirements, remove duplicative obligations and allow flexibility in timelines, while preserving environmental objectives.
  3. It seeks to strengthen legal certainty by clarifying best available techniques rules and creating a presumption of disproportionality between costs and environmental benefits, drawing on the Net-Zero Industry Act.
  4. Amendment 1 adds to Recital 4 that digital solutions should be promoted to streamline procedures and reduce administrative burden.
  5. Amendments 2 to 8 delete the environmental management system obligation and related recitals, including the chemicals inventory, audit and transformation plan requirements.
  6. Amendment 11 requires the European Chemicals Agency to keep data accessible to waste treatment operators.
  7. Amendment 12 sets an eight-year review cycle for BAT reference documents, with each exchange of information not exceeding four years.
  8. Amendments 13 to 17 delete several points in Article 14 of Directive 2010/75/EU, including paragraph 4.
  9. Amendments 19 and 20 require emission limit values to take into account the entire BAT-AEL range and not exceed the lenient end, with a 10 % cost difference presumed unreasonable.
  10. Amendments 22 and 24 allow derogations where costs exceed 10 % of total capital investment cost, and extend crisis derogations to six months, renewable once.
  11. Amendments 26 and 28 extend permit reconsideration from 4 to 8 years and set indicative emission limit values for emerging techniques within 6 years.
  12. Amendments 30 and 31 give Member States 12 months to comply and require a Commission evaluation by 30 June 2027, including a review of environmental legislation's impact on competitiveness.

Who is affected

  • Operators, especially small and medium-sized enterprises, which face complex reporting and procedural requirements.
  • Competent authorities, which assess costs and environmental benefits and may rebut the presumption of disproportionality.
  • Member States, which must bring into force compliance laws within 12 months.
  • The European Chemicals Agency, which must keep data accessible to waste treatment operators.
  • The Commission, which must carry out an evaluation by 30 June 2027.

Figures and deadlines

  • 10 % cost difference for achieving the strictest end of the BAT-AEL range presumed unreasonable.
  • 10 % of total capital investment cost threshold for presumption of disproportionate costs.
  • Crisis derogation not granted for more than six months, renewable for a maximum of six months.
  • Permit conditions reconsidered within 8 years of publication of BAT conclusions.
  • Indicative emission limit values for emerging techniques within 6 years of publication of BAT conclusions.
  • Member States must comply with the Directive by 12 months from entry into force.
  • Commission evaluation by 30 June 2027.
  • Emission limit value not applicable to combustion plants firing gas with more than 5 % hydrogen.