Consultations for the environmental omnibus
On July 22, 2025, the European Commission published a Call for Evidence in advance of a potentially forthcoming environmental omnibus package. The aim is to simplify and harmonize regulatory requirements in the environmental sector in the areas of waste, products, and industrial emissions, and to reduce the bureaucratic burden on businesses, without compromising the objectives pursued by the legislation. We provide an overview of the omnibus initiative and your opportunities to participate. What is a Call for Evidence and how does it affect EU policymaking? A Call for Evidence is a consultation tool used at an early stage of a legislative process by the European Commission to gather feedback from stakeholders before a legislative proposal is drafted. Unlike consultations at later stages, such a call focuses on the scope and direction of a proposal, rather than on detailed legal provisions. In this case, the Commission has issued a call for comments without an impact assessment, as the proposed initiative envisages targeted simplification measures to reduce administrative burden and increase efficiency, with little to no impact on the underlying policies. Furthermore, the amendments concern recently adopted legislation for which impact assessments have already been carried out. A reassessment is therefore not considered necessary. This clearly indicates that the Commission does not intend to change the content of the legislation but is focusing solely on administrative simplification. In addition to this initial call for comments, the Commission will also consult with stakeholders through expert groups and forums. Furthermore, targeted consultations may be conducted to provide the Commission with additional insights for its work on the initiative. Comments can be submitted until September 10, 2025. After this deadline, all contributions will be reviewed by the Commission's services and summarized in a report, which will be published alongside the forthcoming legislative proposal. The latter is expected to be published before the end of the year (Q4 2025).
What is the Environmental Omnibus?
The initiative is part of the European Commission's simplification efforts, in line with the President's Political Guidelines for 2024–2029 and the Competitiveness Compass. Both documents emphasize not only the implementation of adopted legislation but also the need for simplification. This aims to make EU law more effective and create a regulatory environment in which businesses can grow.
The Commission is currently reviewing environmental regulations to identify legislative acts with potential for simplification. The aim is to make the various regulatory frameworks more effective by reducing bureaucratic burdens and avoidable costs (especially for SMEs) without compromising the environmental objectives already agreed under existing legislation. The focus of the Environmental Omnibus is on environmental legislation in the areas of the circular economy, industrial emissions, and waste management. After evaluating stakeholder feedback, the Commission will adopt measures to simplify the rules in these areas. In its call for comments, the Commission mentioned several potential measures and indicated that the list may change depending on feedback and further review: Specifically mentioned are the abolition of the SCIP (Substances of Concern In Products) database under the Waste Framework Directive; the harmonization of rules for authorized representatives under Extended Producer Responsibility (EPR) and the simplification of EPR reporting obligations; the streamlining of reporting obligations and the elimination of duplicate reporting requirements; the promotion of further digitization of reporting in the areas of circular economy, industrial emissions and waste management; as well as addressing permitting challenges related to environmental impact assessments.
The Deforestation Regulation (EUDR) or the Regulation on the Prohibition of Products Produced Using Forced Labor (FLR) are not explicitly mentioned, although there has been past speculation that both could be part of the environmental omnibus.
How can stakeholders get involved?
All stakeholders, including businesses, SMEs, public bodies, NGOs, international organizations and academia, can submit written feedback via the Commission's Have your say portal by Submissions must be made by midnight (Brussels time) on September 10, 2025. All submissions will be published online. We strongly encourage all stakeholders to share their views and feedback in response to this call for comments. The Cattwyk team is happy to assist you.