Environmental Omnibus: The latest EU rollbacks and simplifications for 2026
In the latest Environmental Omnibus (published 10.12.25), the European Commission has announced potential rollbacks on many environmental regulations and protections.
This Omnibus packaging is expected to reduce administrative burdens by around €1bn per annum and aligns with the EU Commission’s target of cutting administrative burdens by at least 25% for all companies and 35% for SMEs while staying on course to meet its sustainability goals.
Closely aligned with Beyondly’s work and that of our members, the following areas have been highlighted for future simplifications in this Omnibus proposal.
Suspension of Authorised Representatives for EPR
Amending the PPWR, WEEE, Batteries, Single-Use Plastic Directive, and the Waste Framework Directive (for textiles and other future EPR schemes).
Under the current rules, producers in the EU who sell goods directly to end-users in another Member State may have to appoint an authorised representative to comply with some of their obligations under these regulations, including for EPR. These proposals would see the need to appoint authorised representatives become optional, allowing producers who have authorised representatives for EPR to keep their existing arrangements while removing the mandatory burden for those producers who do not wish to appoint an authorised representative.
For producers who are established outside the Union, the provisions to appoint an authorised representative are to be kept as they currently are, including for battery producers who supply by means of distance contracts from a third country.
This requirement will be suspended until 01.01.35 while we wait for further alignments of EPR schemes in the Circular Economy Act, due end of 2026. This is expected to expand on these proposals and include more simplifications such as a digital 'one-stop-shop' for EPR information, registration, and reporting under amendments to the WFD and therefore potentially removing the requirement for companies in the EU to appoint representatives in other Member States. Instead, they will be able to register and report themselves directly, along with other simplifications concerning producers outside the EU.
EPR reporting frequency
A proposed amendment to the WFD will potentially limit the reporting of EPR schemes in Member States to annually, rather than a multitude of reporting dates and frequencies. This is going to reduce the burden on producers while also looking to align with the EPR alignments in the incoming Circular Economy Act.
Packaging and Packaging Waste Regulation (PPWR)
To further support the incoming EU Packaging Regulation, the Commission will be releasing an FAQ and guidance on the most frequently raised points, including testing for PFAS, applications dates, labelling requirements, and reuse targets.
A draft Delegated Act was also released which will exempt pallet wrap and strappings from the 100% reuse targets for transport packaging, with future considerations (already provisionally laid out in the PPWR) for flexibility around targets for packaging formats where hygiene and food safety may prevent the meeting of said targets.
EU Batteries Regulation (EUBR)
There have been some updates and refinements of the EUBR in relation to distance sellers, substances of concern (SoC), and light means of transport (LMT) batteries.
There is a proposed update to the definition of ‘producer’, so that any legal person that sells batteries in a Member State, who is based in another Member State, is the producer irrespective of the selling technique used, and not just by means of distance contracts as is currently outlined.
Article 13 requires that batteries would bear a label indicating the presence of certain SoC. This has been updated in Annex VI Point 8 to add in ‘with a concentration equal or above 0.1%’ w/w, to add clarity on labelling and align with EU chemical regulation, REACH.
There was also an original requirement for LMT batteries to be removeable at cell level. There is a concern that this may lead to safety issues where batteries have been removed and replaced under improper circumstances; therefore, this is being updated to be removeable and replaceable by independent professionals at a module level to balance safety and repairability.
Waste Framework Directive (WFD)
Lastly, there is the plan to remove the Substances of Concern in Products (SCIP) database from the WFD. This has been considered because the database has had low hits, the data included is too confusing, it’s expensive to maintain, and it “has not been effective in informing recycler about the presence of hazardous substances in products”. The reporting of SoC should also be covered by future Digital Product Passport (DPP) requirements.
As with the previous Environmental Omnibuses, Beyondly will be keeping a close eye on these developments to see what further discussions take place and the final form of these amendments when they are signed into law.
Summary of key takeaways
- Companies in the EU supplying into other Member States can choose whether to appoint an authorised representative, or not
- Alignment of reporting frequency to annually, with future simplifications due in the Circular Economy Act
- More guidance and delegated acts due for PPWR
- Updates and clarifications for EUBR
- Closure of the SCIP to simplify SoC reporting, pre-empting DPPs.
The Commission has also announced simplifications in the areas of pesticides, environmental reporting for livestock and aquaculture, and the Industrial Emissions Directive, and will also stress-test the Birds and Habitats Directives.
Along with other simplifications and ‘rollbacks’, the WFF states that the estimated savings “come with no impact assessment and focus only on reduced compliance costs, ignoring the far larger price of pollution, ecosystem decline, and climate-related disasters.” This comes after the Ombudsman found the Commission at fault for ‘maladministration’ for the first omnibus, while the German centre-right MEP Pieter Liese stated that we “need to streamline environmental laws precisely because we want to preserve them. Bureaucracy and paperwork are not environmental protection.”
Beyondly is here to keep you informed!
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Source: Simplification of administrative burdens in environmental legislation - Environment
