Focus on… simplification

Further proposals to simplify and reduce rules:

Single Market: Commission presents strategy to simplify rules and EPR
Sustainability reporting: Rapporteur proposes further cuts to scope
Environmental secondary legislation: Commissioner plans to cut by one third

Single Market: Commission presents strategy to simplify rules and EPR

On 21 May 2025, the European Commission published its long-term vision for the Single Market.

Such a strategy is not setting legal requirements, but outlining points that shall be addressed in future policy developments.

Dismantling barriers

Here, the Commission came up with a comprehensive strategy to strengthen the EU’s internal market by dismantling what it perceives to be the 10 most acute barriers to product and service flow.

The non-binding Communication emphasises the role of the Single Market as a key lever for competitiveness, innovation and resilience. It also outlines a comprehensive agenda to simplify rules and reduce bureaucracy.

The new strategy places strong focus on addressing “fragmented rules on packaging, labelling and waste, and announces several measures in the area of extended producer responsibility (EPR)”.

The Commission identifies fragmented national EPR schemes as a key barrier for businesses operating across borders, especially SMEs.

Producers face high administrative burdens due to multiple national registration and reporting requirements.

Harmonised and digitalised EPR

To address this, the Commission aims to harmonise and digitalise EPR compliance through a “one-stop shop” approach for information, registration and reporting.

The Commission also proposes to remove authorised representative requirements and reduce reporting obligations (including limiting them to an annual frequency).

Furthermore, the Commission announces its intention to ease the adoption of EU-wide end-of-waste criteria, particularly for priority waste feedstocks. Cross-border shipments of waste feedstocks for recycling shall also be facilitated.

While legislative changes for the removal and reduction of EPR requirements are foreseen under an Omnibus package later this year, the other proposals will be addressed in the forthcoming Circular Economy Act, expected in late 2026 (see article here).

Landbell Group is carefully monitoring these developments and will actively engage in the upcoming stakeholder consultations.

Sustainability reporting: Rapporteur proposes further cuts to scope

A drafted amendment by the European Parliament’s Economic and Monetary Affairs (ECON) Committee proposes a significant scale back in the scope of the EU’s sustainability reporting and due diligence legislation.

The draft even goes beyond the European Commission’s February Omnibus I simplification proposal.

The draft amendments have been proposed by Rapporteur Janusz Lewandowski who is responsible for coordinating the ECON Committee’s opinion on the file.

Raising the applicability threshold

MEP Lewandowski proposes to raise the applicability threshold for both the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) to companies with more than 3,000 employees and €450 million in turnover.

This would further reduce the number of companies subject to these rules, removing a substantial share of firms from compliance obligations.

The original European Commission draft had proposed limiting the CSRD to companies with over 1,000 employees and €50 million in turnover.

The draft opinion also calls for strict caps on the number of mandatory data points under the European Sustainability Reporting Standards (ESRS), limiting them to 100, with 50 voluntary points.

Additionally, it removes the CSDDD’s requirement for companies to adopt climate transition plans – arguing this is already covered under the CSRD.

Reaching negotiating positions

This proposal represents the opinion of the ECON Rapporteur, which will need to be negotiated with other Committee members.

Given the growing focus on competitiveness and streamlining bureaucratic requirements for companies, the ECON Committee’s position is expected to carry significant weight.

In the coming weeks, the Committee on Legal Affairs (JURI), which is leading the Parliament’s position on the file, will come forward with its position.

Once a position across Committees is found, it will need to be approved in Plenary before it becomes the Parliament’s official negotiating position in forthcoming negotiations with the Council of the EU.

In parallel, the Council is working on its position. Member States largely agree with the Commission’s proposal on CSRD scope. On CSDDD, however, Germany and France’s governments are calling to completely scrap all obligations, while Denmark is strongly rejecting Germany and France’s approach.

Given the divergencies, both in the Council and Parliament, it will take several weeks before both institutions reach internal positions, which can then serve as a basis for common negotiations.

Environmental secondary legislation: Commissioner plans to cut by one third

EU environment attaché Mathias Kirkegaard has announced Environment Commissioner Jessika Roswall’s intention to reduce the number of environmental secondary laws, such as delegated and implementing acts, by one third.

The proposal is significant as 99.2% of EU environmental laws adopted between 2019 and 2024 were secondary legislation.

While the initiative aims to cut red tape and lower compliance costs for businesses, it raises institutional and practical concerns.

Empowerments to adopt secondary legislation often serve as essential tools for reaching compromise in EU lawmaking. If not used as intended, technical issues could become politicised, making future agreements harder to achieve.

The proposal may also lead co-legislators to introduce more legal deadlines, which can pressure the Commission to rush complex files or risk breaching deadlines.

The Commission has not disclosed its criteria for selecting which laws to eliminate. Although simplification has merit, observers warn that removing rules that ensure market harmonisation could undermine the functioning of the internal market.

For example, the Packaging and Packaging Waste Regulation (PPWR) creates the mandate for the Commission to adopt over 80 implementing and delegated acts, without which it will not be possible to implement the law correctly and in a harmonised way.

The challenge lies in striking the right balance between cost savings and maintaining effective, coherent EU environmental policy.

Landbell Group is currently reviewing all mandates for implementing and delegated acts given to the European Commission in the Packaging and Packaging Waste Regulation (PPWR) and the Batteries and Batteries Waste Regulation, checking the potential for such reductions, and will then engage with the Commission.