ClientEarth contribution to the European Commission’s Call for Evidence Simplification of administrative burden in environmental legislation

ClientEarth argues that environmental safeguards are constitutional obligations, not administrative burdens, and that the EU should address implementation bottlenecks—such as lack of staffing and poor digitalisation—rather than deregulating. The document specifically opposes the discontinuation of the SCIP database, the simplification of the EU Deforestation Regulation (EUDR), and the weakening of the Industrial Emissions Directive (IED) or Nature Restoration Regulation (NRR). It emphasizes that robust environmental assessments provide legal certainty and risk mitigation for investors.

• ClientEarth rejects the framing of environmental safeguards as an 'administrative burden,' asserting that these measures implement core constitutional obligations under the EU Treaties and the Charter of Fundamental Rights of the European Union.
• The document argues that the actual causes of administrative delays are not the complexity of EU laws, but rather failures in national implementation, including improper transposition of Directives, lack of administrative capacity, inadequate staffing, and insufficient funding.
• ClientEarth strongly opposes the proposed discontinuation of the SCIP (substances of concern in products) database under the Waste Framework Directive, stating that no functional equivalent exists and its removal would compromise circular economy goals and risk 'toxic risk-cycling'.
• The submission argues against simplifying the EU Deforestation Regulation (EUDR), noting that it is already proportionate, includes simplifications for SMEs and traders, and that EU producers benefit from a 'low risk' ranking that reduces due diligence and compliance checks.
• Regarding the Industrial Emissions Directive (IED), ClientEarth maintains that the new requirements for Environmental Management Systems (EMS), chemicals inventories, and transformation plans are essential for the EU's zero pollution ambition and are already designed with flexibility for operators.
• The document cautions against using the Net Zero Industry Act (NZIA) as a model for simplification because it creates a 'false equivalency' by granting similar preferential regulatory treatment to both low-risk renewables and high-risk technologies like nuclear and carbon capture and sequestration (CCS).
• ClientEarth asserts that the Nature Restoration Regulation (NRR) must be safeguarded, highlighting that it does not impose obligations directly on farmers or landowners and allows Member States significant flexibility through National Restoration Plans.
• The document claims that failure to properly implement environmental law costs the EU and its Member States between €180 billion and €325 billion per year.

APA

ClientEarth (2025). ClientEarth contribution to the European Commission’s Call for Evidence Simplification of administrative burden in environmental legislation. https://www.clientearth.org/media/r4adm3yh/clientearth-submission-call-for-evidence-environmental-omnibus.pdf

Chicago

ClientEarth. ClientEarth contribution to the European Commission’s Call for Evidence Simplification of administrative burden in environmental legislation. 2025. https://www.clientearth.org/media/r4adm3yh/clientearth-submission-call-for-evidence-environmental-omnibus.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=ClientEarth contribution to the European Commission’s Call for Evidence Simplification of administrative burden in environmental legislation |date=September 2025 |url=https://www.clientearth.org/media/r4adm3yh/clientearth-submission-call-for-evidence-environmental-omnibus.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2025clientearth, author = {{ClientEarth}}, title = {{ClientEarth contribution to the European Commission’s Call for Evidence Simplification of administrative burden in environmental legislation}}, publisher = {ClientEarth}, year = {2025}, month = sep, url = {https://www.clientearth.org/media/r4adm3yh/clientearth-submission-call-for-evidence-environmental-omnibus.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }