Environmental Omnibus

The EU Commission is currently working to simplify environmental legislation and reduce administrative burdens via a series of measures across multiple environmental policy files.

This ambition stems from the EU Competitiveness Compass’s aim to cut red tape by 25% for companies and 35% for SMEs.

Why is it important?

The EPMF’s members comply with and implement the rules laid out in environmental policies. Overlapping requirements and administrative burdens can make implementation difficult and expensive.

The Environmental Omnibus may impact multiple files of relevance to the precious metals industry such as the Waste Framework Directive and Industrial Emissions Directive. Simplifying and/or streamlining requirements can help EU companies better comply with EU rules and fast-track their progress towards circularity and decarbonisation.

  • EPMF OPINION
  • Provide clearer, common technical guidelines on how to apply key principles and definitions across EU environmental policies to ensure a level playing field and predictability
  • Rationalise reporting obligations to remove double requirements, especially between different policies and directives, and ensure interoperability between national platforms and EU systems.  
  • Address permitting speeds by setting an EU-level requirement for time limits on granting new environmental permits and extend review cycles for environmental legislation to give industry more time to implement new standards
  • Ensure coherence and harmonisation between EU policies including the CRM Act, the Waste Shipments Regulation, the Waste Framework Directive, the Industrial Emissions Directive, the Ambient Air Quality Directive, and the Water Framework Directive.
  • On the Waste Framework Directive:
    • Harmonise WFD implementation and enforcement of rules (especially key definitions) across all the Member States. Streamline the procedures to avoid circumvention
    • Introduce automatic approval (binding tacit consent) whenever a competent authority fails to respond within 30 days to a complete waste shipment notification submitted under the PIC procedure.
    • Establish the Digital Waste Shipment System (DIWASS) as foreseen in the Regulation.
  • On the Waste Shipments Regulation:
    • Include new Green List codes in Annex IIIB of the WSR to facilitate shipments of waste for high-quality recycling.
    • Automatically recognize pre-consented facility status across the EU once a single Member State grants it and introduce a fast-track notification procedure.
    • Make the current intra-EU regime for green-listed e-waste permanent and expand it to all e-waste regardless of hazard classification. Introduce separate, well defined waste codes for non-hazardous e-waste to ensure regulatory certainty and harmonisation.
    • Uphold a risk-based approach vs. a hazard-based approach for waste shipments.
  • On the Industrial Emissions Directive:
    • Restrict the ability of Member States to set more stringent emission limit values than what is achievable under BATs. Ensure a sufficient level of flexibility to reflect local conditions by preserving exemptions
    • IED should remain the main tool for the development of environmental transition plans for non-ferrous metals industries
  • On the Water Framework Directive:
    • Address the interface between the Water Framework Directive and the Industrial Emissions Directive to simplify procedures and ensure consistency.
    • Ensure a risk-based approach to setting environmental quality standards and avoid introducing new environmental quality standards (EQS) where the risk is already well-addressed via national measures.
    • The prioritisation of substances and the derivation of EQSs must follow a pre-approved process, as well as the use of the best available science (e.g. bioavailability modelling) and guidance in doing so.

USEFUL RESOURCES:

  • Awaiting Update…