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DRAFT 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

ITRE-PA-787849

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

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The Committee on Industry, Research and Energy's draft opinion responds to the Commission's proposal to simplify environmental legislation. It proposes amendments to Directive 2010/75/EU that remove the environmental management system obligation and related requirements, and introduce a presumption that costs of meeting BAT emission levels are disproportionate. The draft opinion also amends rules on setting emission limit values, extends the permit reconsideration interval from 4 to 8 years, and adjusts Annex II on derogation assessments.

Committee position. The rapporteur proposes targeted amendments to the Commission proposal to simplify environmental management system requirements, remove duplicative obligations, extend permit reconsideration timelines, and introduce a presumption of disproportionality for BAT compliance costs, while preserving core environmental objectives.

Key points

  1. The rapporteur welcomes the Commission's 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 by simplifying environmental management system requirements, removing duplicative obligations and allowing flexibility in implementation timelines, while preserving core environmental objectives.
  3. It introduces a presumption of disproportionality between costs and environmental benefits, drawing on the Net-Zero Industry Act, to ensure requirements remain realistic and economically viable.
  4. Amendment 1 adds to Recital 4 that digital solutions should be promoted to streamline procedures, improve data quality and reduce administrative burden.
  5. Amendment 2 changes Recital 7 to remove the environmental management system obligation under Article 14a of Directive 2010/75/EU.
  6. Amendments 3 to 8 delete Recitals 8, 9, 10, 11, 12 and 13, removing provisions on EMS organisational level, chemicals inventory, implementing act, auditing, postponement to 2030 and transformation plans.
  7. Amendment 9 inserts Recital 15a introducing a rebuttable presumption that costs of achieving BAT-associated emission levels are disproportionate to environmental benefits.
  8. Amendment 10 inserts Recital 20a to extend the interval for reconsideration of permit conditions under Directive 2010/75/EU.
  9. Amendment 12 changes Article 15(3) so emission limit values take into account the entire BAT-AEL range, with a cost difference of more than 10% for the strictest end presumed unreasonable.
  10. Amendment 14 inserts Article 15(5) subparagraph 1a: disproportionately higher costs are presumed where incremental costs exceed 10% of total capital investment cost, and the operator need not demonstrate disproportionality further.
  11. Amendment 17 changes Article 21(3) to extend the permit reconsideration interval from 4 to 8 years after publication of BAT conclusions.
  12. Amendments 19 to 31 amend Annex II to make assessments proportionate, allow simplified demonstrations where the presumption applies, and set out conditions for rebutting the presumption.

Who is affected

  • Operators of installations under Directive 2010/75/EU, especially small and medium-sized enterprises, benefit from reduced reporting and procedural requirements.
  • Competent authorities in member states gain flexibility in setting emission limit values and assessing derogations.
  • The environment and human health are affected by changes to emission limit values and derogation rules.

Figures and deadlines

  • A cost difference of more than 10% for achieving the strictest end of the BAT-AEL range vis-à-vis the lenient end shall be presumed unreasonable.
  • Disproportionately higher costs shall be presumed where incremental costs exceed 10% of the total capital investment cost of the transformation project.
  • The permit reconsideration interval is extended from 4 to 8 years after publication of BAT conclusions.