NNDKP Environment Flash No.1/2026
1. EU DEVELOPMENTS SELECTION
1.1. Key initiatives to promote carbon removal and carbon farming
On 1 December 2025, the European Commission announced the adoption of measures and initiatives aimed at preparing the implementation of the voluntary EU-wide certification framework for carbon removal and carbon farming.
The key initiatives focus on establishing a buyers’ club for the voluntary carbon credit market, creating a database of agricultural practices for carbon capture and storage, streamlining the reporting of scope 3 emissions, as well as adopting a methodology for carbon storage in buildings which will help building owners demonstrate their buildings’ carbon performance and align the construction sector with the principles of the circular economy.
More information on Regulation 2025/2358, which sets out the rules on certification schemes, certification bodies, and audits under Regulation 2024/3012, can be found in NNDKP`s Environment Flash No. 11/2025, available here.
1.2. A new step in combating environmental crime
On 3 December 2025, the EU signed the Council of Europe Convention on the Protection of the Environment through Criminal Law.
More information on the Convention can be found in NNDKP`s Environment Flash No. 5/2025, available here.
1.3. The EU regulation regarding the “stop-the-clock” mechanism for chemical substances was published in the Official Journal of the EU
On 3 December 2025, Regulation 2025/2439 amending Regulation 2024/2865 (that amended Regulation 1272/2008 on classification, labelling and packaging of substances and mixtures) regarding the dates of application and transitional provisions was published in the Official Journal of the EU.
More information on the “stop-the-clock” mechanism for chemicals can be found in NNDKP`s Environment Flash No. 9/2025, available here, and in NNDKP`s Environment Flash No. 11/2025, available here.
1.4. Measures to simplify environmental legislation
On 10 December 2025, the European Commission presented a package of measures to simplify environmental legislation in the areas of industrial emissions, circular economy, environmental assessments and geospatial data.
The package consists of six legislative proposals which, among others, seek to simplify environmental assessments required for permits, reduce the complexity of industrial emissions standards, improve digital tools for managing hazardous substances in products, and establish a more streamlined framework for extended producer responsibility.
The next steps involve submitting the legislative proposal to the European Parliament and the Council for adoption.
1.5. The OSOA package was published in the Official Journal of the EU
On 12 December 2025, the legislative package “one substance, one assessment” (“OSOA”), including Regulation 2025/2455, Regulation 2025/2457 and Directive 2025/2456, was published in the Official Journal of the EU.
More information on the OSOA legislative package can be found in NNDKP`s Environment Flash No. 6/2025, available here, in NNDKP`s Environment Flash No. 10/2025, available here, and in NNDKP`s Environment Flash No. 11/2025, available here.
1.6. Provisional agreement on new regulations on circular economy in the automotive industry
On 12 December 2025, the European Parliament and the Council reached a provisional agreement on new EU circular economy rules that will cover the entire vehicle lifecycle, from design to end-of-life treatment.
The new rules cover, among others, improved vehicle design and the use of recycled materials, the establishment of clear requirements for the transfer of ownership of used vehicles within the EU, stricter end-of-life management rules for vehicles, as well as strengthened regulations on the export of second-hand vehicles.
The provisional agreement must be approved by the European Parliament and the Council before the new rules can enter into force.
Other information on these rules can be found in NNDKP`s Environment Flash No. 6/2025 available here, and in NNDKP`s Environment Flash No. 9/2025 available here.
1.7. Public consultation to update rules safeguarding the marine environment
On 16 December 2025, the European Commission launched a public consultation and Call for Evidence on the revision of the Marine Strategy Framework Directive.
The revision aims, among others, to better protect the marine environment, simplify its implementation, and reduce administrative burdens.
Interested parties can submit suggestions on the legislative initiative by 9 March 2026.
1.8. Regulation to reduce microplastic pollution entered into force
On 16 December 2025, Regulation 2025/2365 on preventing plastic pellet losses to reduce microplatic pollution entered into force, with certain provisions becoming applicable from the same date.
More information on the regulation can be found in NNDKP`s Environment Flash No. 4/2025 available here, NNDKP`s Environment Flash No. 9/2025, available here and NNDKP`s Environment Flash No. 11/2025, available here.
1.9. Simplifying sustainability reporting and due diligence obligations
On 16 December 2025, the European Parliament approved a provisional agreement between MEPs and national governments to update rules on sustainability reporting and due diligence obligations.
According to the latest updates, the CSRD requirements for reporting on environmental and social matters will apply only to large undertakings with more than 1,000 employees and an annual turnover exceeding EUR 450 million.
As regards the CSDDD, the applicability requirements have not been amended compared to the legislative package approved by the European Parliament in November 2025.
The novelty lies in the timeline for application, as the CSDDD will apply as of 26 July 2029 to all companies within its scope.
The next steps include formal approval by the Council and publication in the Official Journal of the EU.
More information on simplifying proposals can be found in NNDKP’s Environment Flash No. 2/2025, available here and NNDKP’s Environment Flash No. 11/2025, available here.
1.10. The Soil Monitoring and Resilience Directive entered into force
On 16 December 2025, Directive 2025/2360 on soil monitoring and resilience entered into force.
More information on the directive can be found in NNDKP`s Environment Flash No. 4/2025 available here, NNDKP`s Environment Flash No. 9/2025, available here, and NNDKP`s Environment Flash No. 11/2025, available here.
1.11. Recent legislative developments and amendments regarding the CBAM
On 17 December 2025, the European Commission proposed a package of measures to strengthen the Carbon Border Adjustment Mechanism (“CBAM”) and on 22 December 2025, the following implementing regulations were published in the Official Journal of the EU:
- Regulation 2025/2548 laying down rules for the calculation and publication of the price of CBAM certificates;
- Regulation 2025/2547 laying down rules for the calculation methods of embedded emissions in goods;
- Regulation 2025/2550 amending and correcting the regulation regarding the CBAM Registry; and
- Regulation 2025/2549 amending and correcting the regulation laying down rules for the application of the CBAM regulation regarding the conditions and procedures related to the status of authorised declarant under the CBAM.
More information on the CBAM can be found in NNDKP`s Environment Flash No. 5/2025, available here, NNDKP`s Environment Flash No. 6/2025, available here, NNDKP`s Environment Flash No. 9/2025, available here and NNDKP`s Environment Flash No. 10/2025, available here.
1.12. The EUDR amending regulation was published in the Official Journal of the EU
On 23 December 2025, the Regulation 2025/2650 amending Deforestation Regulation (“EUDR”) as regards certain obligations of operators and traders was published in the Official Journal of the EU.
The regulation entered into force on 26 December 2025.
More information on the revision of the EUDR can be found in NNDKP’s Environment Flash No. 10/2025, available here, and NNDKP’s Environment Flash No. 11/2025, available here.
1.13. Pilot measures to accelerate the circular economy and strengthen environmental law in the EU
On 23 December 2025, the European Commission presented a set of pilot actions to accelerate the transition to a circular economy, with a focus on plastic recycling, aiming to reduce environmental impact and achieve EU sustainability goals.
The new measures include establishing criteria at EU level for end-of-waste status, harmonized rules for recycled plastic content, and strengthening the market monitoring and harmonization framework to ensure compliance with EU rules.
The European Commission also launched a public consultation on the evaluation of the Single-Use Plastics Directive’s impact, open until 17 March 2026, and a public consultation on end-of-waste criteria, open until 26 January 2026.
2. NATIONAL DEVELOPMENTS SELECTION
2.1. Proposal for regulating biowaste management regulation
On 3 December 2025, a draft law on the management of biodegradable waste was formally submitted to the Senate.
The draft law aims to establish the legislative framework for the management of biodegradable waste through recycling and recovery.
It establishes, among others, the conditions for the use of biodegradable waste in composting and anaerobic digestion operations, the codes of waste permitted for these operations, as well as the obligations of economic operators, the powers of the authorities involved, and the penalty regime.
2.2. Proposal to amend and supplement legislation on extended producer responsibility for packaging
On 8 December 2025, a draft law amending and supplementing the normative acts in the field of extended producer responsibility for packaging was submitted to the Senate.
The amendments introduced by the draft law concern, among others, the mandatory use of a minimum percentage of recycled material in beverage packaging, the right of first refusal for the purchase of recycled materials, the granting of bonuses for incorporating recycled material, and the setting of penalties for non-compliance with recycling targets.
2.3. Amendments regarding the organization and functioning of the National Environmental Guard
On 11 December 2025, the Government adopted the Decision 1076/2025 amending the Government Decision No. 1005/2012 on the organization and functioning of the National Environmental Guard.
The decision introduces a series of changes regarding the organization of the National Environmental Guard, including the dissolution of the “Danube Delta” Biosphere Reserve Commissariat, whose activities are taken over by the Tulcea County Commissariat.
More information on the amendments can be found in NNDKP`s Environment Flash No. 10/2024, available here.
2.4. Proposal to amend GO No. 2/2021 on waste storage
On 16 December 2025, a draft law amending GO No. 2/2021 on waste storage was submitted to the Senate.
The amendments introduced by the draft law concern, among others, the notification of authorities when the 75% capacity threshold of landfills is reached, the development and implementation of action plans to ensure municipal waste disposal capacities, and the establishment of penalties for non-compliance with these obligations.
2.5. Proposal for a legislative framework on the circular economy and sustainable use of resources
On 17 December 2025, a draft framework law on the circular economy and the transition to sustainable resource use was submitted to the Senate.
The draft law covers, among others, implementation and reporting obligations in the field of circular economy, the powers of the competent authorities, coordination and control mechanisms, and a system of penalties for non-compliance with the new requirements.
2.6. Draft Government decision on batteries and battery waste
On 22 December 2025, the Government launched for public consultation the draft decision establishing the institutional framework and measures for the implementation of Regulation 2023/1542 on batteries and waste batteries.
The draft Government decision aims, among others, to establish the institutional framework for the implementation of the regulation, to designate the competent authorities, and to set penalties for non-compliance with obligations regarding batteries and battery waste.
2.7. Draft GEO for the implementation of Regulation 2024/1781 on the eco-design of sustainable products
On 22 December 2025, the Government launched for public consultation the draft GEO on the implementation of Regulation 2024/1781, establishing a framework for setting eco-design requirements for sustainable products.
The draft GEO provides, among others, for the designation of competent authorities for the enforcement of the regulation and market surveillance, the introduction of the Digital Product Passport as a tool to ensure transparency and access to information, as well as reporting obligations for economic operators.
he Romanian version of this newsletter is available here.
