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On December 10, 2025, the European Commission presented Omnibus Package VIII (Environment). The proposal aims in particular in particular to simplify environmental procedures, to streamline industrial and agricultural emission standards, to abolish a database for hazardous substances in products, and to suspend the mandatory appointment of an authorised representative for extended producer responsibility (EPR) in waste management.

AK welcomes some of the Commission's proposals, such as those concerning the consolidation of environmental procedures and ensuring adequate resources for authorities. However, the majority of the proposed changes are viewed very critically, particularly in the area of environmental procedures. For instance, the proposals include very short approval deadlines and exemptions from the ban on killing protected animal and bird species. The proposed changes to waste management law are also considered particularly problematic. They would undermine the system’s functionality. Abolishing the obligation for plant operators to submit transformation plans for their facilities starting in 2030, as set out in the Industrial Emissions Directive, would make it even more difficult to achieve climate targets.

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Judith Fitz

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Florian Wukovitsch (Brussels office)

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