The European Commission has published the Environmental Omnibus (Omnibus VIII) Package with targeted measures to simplify the Waste Framework Directive and the Packaging and Packaging Waste Regulation.

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MORE DETAILS

Yesterday, on 10 December, the European Commission published the Environmental Omnibus (Omnibus VIII) legislative package, aimed at reducing administrative burdens and simplifying environmental obligations. This publication follows FESI’s submission of its ​​​position paper​​​ in response to the September public consultations and its participation in the October roundtable with Commissioner Roswall.

The package, composed by different proposals, includes the following key points:

• ‍Suspension of the obligation to appoint an authorised representative for EU-based producers of packaging, textiles, and footwear when placing products on the market in another Member State until 1 January 2035.
• For third-country producers, the obligation remains, but Member States may use alternative means to ensure traceability and compliance.‍
• Repeal of the obligation to report to the SCIP database, due to overlaps with the future Digital Product Passport.‍
• Harmonisation of EPR reporting frequency, with a maximum of once per year across all Member States.
• In addition to this, the Commission announced a separate broader EPR reform in Q3 2026 under the Circular Economy Act.

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FESI Analysis

• FESI has drafted an analysis containing the main proposed legislative changes. This can be found in the attachment.
• The analysis is structured in four sections, that include:
• The main changes introduced by the proposal and advocated by FESI on its position paper, including:
• The elimination of the obligation for EU-based producers to appoint an authorised representative under the Waste Framework Directive (WFD) and the Packaging and Packaging Waste Regulation (PPWR).  
• The repeal of the obligation to submit data about articles containing substances of very high concern (SVHCs) to the SCIP database under the WFD.
• The harmonisation of the the annual reporting frequency under the WFD.  ‍
• Future legislative developments that separately will address related issues, such the expected Circular Economy Act, which may also reform the EPR systems under the WFD, or the revision of the REACH legislation.

• Points defended by FESI that remained unaddressed by the proposal.

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NEXT STEPS

• The legislative package will now be negotiated among the co-legislators following the Ordinary Legislative Procedure.

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