NNDKP Environment Flash No.11/2025
1. EU DEVELOPMENTS SELECTION
1.1. The EU intensified its efforts to achieve the 2030 climate targets
On 6 November 2025, the European Commission published its climate progress report, which shows that greenhouse gas emissions fell by 2,5% in 2024 compared to the previous year, keeping the EU on track to meet its target of a 55% emission reduction by 2030 compared to 1990 levels.
The progress was supported by the energy sector’s transition to renewable sources, the EU’s Emissions Trading System (“EU ETS”) and the Effort Sharing Regulation.
These have contributed to the reducing emissions from industry, transport, constructions, and agriculture.
1.2. The European Parliament approved the new climate target for 2040
On 10 November, 2025, the European Parliament adopted its position on amending the EU Climate Law by introducing a binding intermediate climate target for 2040: reducing net greenhouse gas emissions by 90% compared to 1990 levels.
The European Parliament supported carrying out assessments of progress towards achieving the intermediate targets every two year, with the possibility of adopting additional measures.
More information on the proposal for the new 2040 climate target can be found in NNDKP`s Environment Flash No. 7/2025, available here.
1.3. Support for SMEs provided by the European Chemicals Agency
On 11 November 2025, the European Chemicals Agency (“ECHA”) launched an updated multilingual hub designed to support small and medium-sized enterprises (“SMEs”) in the EU in complying with EU chemicals legislation.
Within this hub, interested entities can access online tools, ECHA guidance documents, guidance issued by EU Member States, a pilot AI-based virtual assistant, multilingual webinars, and other such guidance materials aimed at supporting compliance with EU chemicals legislation.
1.4. Funding programme for EU industrial decarbonisation
On 13 November 2025, the European Commission announced the launch of a Horizon Europe funding call to support the Clean Industrial Deal, aimed at research and innovation projects promoting a clean environment.
This call is expected to be launched in December 2025 as part of the Horizon Europe 2026–2027 work programme, with an indicative budget of approximately EUR 600 million to support projects developing clean technologies, net-zero energy systems, zero-emission power generation, advanced energy-storage solutions, and decarbonised industrial processes.
More information on the Clean Industrial Deal can be found in NNDKP`s Environment Flash No. 2/2025, available here.
1.5. The OSOA package was adopted by the Council
On 13 November 2025, the legislative package “one substance, one assessment” (“OSOA”) was adopted by the Council.
The legislative acts included in the OSOA package were published in the Official Journal of the EU and will enter into force 20 days after their publication.
More information on the OSOA legislative package can be found in NNDKP`s Environment Flash No. 6/2025, available here, and in NNDKP`s Environment Flash No. 10/2025, available here.
1.6. Simplifying sustainability and due diligence reporting
On 13 November 2025, the European Parliament approved the reduction of reporting obligations and due diligence requirements for companies, establishing clear criteria for applicability and simplification of standards.
Under the new amendments, only large companies with over 1,750 employees and an annual turnover exceeding €450 million will be required to report on social and environmental matters, while due diligence obligations will apply solely to very large corporations with more than 5,000 employees and an annual turnover above €1.5 billion.
Additionally, the proposal seeks to simplify reporting standards, make sectoral reporting optional, and protect small businesses from additional requirements imposed by larger partners.
The next steps include negotiations with EU governments to finalize the legislation by the end of 2025.
More information on the legislative package can be found in NNDKP’s Environment Flash No. 2/2025, available here.
1.7. The “stop-the-clock” mechanism for chemical substances has been adopted
On 17 November 2025, the Council adopted the regulation on the “stop-the-clock” mechanism for chemicals, as part of the “Omnibus VI” package, which postpones until 1 January 2028 the entry into force of certain provisions of the revised 2024 Regulation on the classification, labelling and packaging of chemicals (the CLP Regulation).
The Regulation shall enter into force on the twentieth day following its publication in the Official Journal of the EU.
More information on the proposal on the “stop-the-clock” mechanism for chemicals can be found in NNDKP`s Environment Flash No. 9/2025, available here.
1.8. Council, ready to negotiate revision of EUDR
On 19 November 2025, the Council adopted a negotiating mandate for the revision of the EU Deforestation Regulation (“EUDR”), with the aim of simplifying existing rules and postponing their application to allow operators and authorities to prepare adequately.
Under the new provisions, the Council proposed postponing the application of EUDR for all operators until 30 December 2026, with an additional six-month period for micro and small operators, removing the “grace period” initially proposed by the European Commission for large and medium-sized enterprises.
Subsequently, the Council initiated negotiations with the European Parliament to reach a final agreement on the proposal before the current EUDR application date, namely 30 December 2025.
More information on the proposed revision of the EUDR can be found in NNDKP`s Environment Flash No. 1o/2025, available here.
1.9. The Implementing EU Regulation for carbon removal certification schemes was published in the Official Journal of the EU
On 21 November 2025, Regulation (EU) 2025/2358 laying down rules on certification systems, certification bodies, and audits pursuant to Regulation (EU) 2024/3012 establishing a Union certification framework for permanent carbon removals, carbon farming and carbon storage in products was published in the Official Journal of the EU.
The Regulation clarifies the responsibilities of the parties involved in the certification process and sets strict rules throughout the entire process, ensuring a coherent and transparent framework for entities engaged in carbon removal and carbon capture-based agriculture.
1.10. The Regulation on data reporting, assessment methods and operational conditions concerning battery waste has been published in the Official Journal of the EU
On 21 November 2025, Regulation (EU) 2025/2289 laying down rules for the application of Regulation (EU) 2023/1542 as regards the format for the reporting of data as well as the assessment methods and operational conditions for the collection and treatment of waste batteries was published in the Official Journal of the EU.
The Regulation establishes, among others, the standard format for reporting data on batteries and waste batteries, clarifies how to report recycling and material recovery efficiency based on the chemical composition of batteries, and requires Member States to publish this data annually.
1.11. Regulation to reduce microplastic pollution was published in the Official Journal of the EU
On 26 November 2025, Regulation (EU) 2025/2365 on preventing plastic pellet losses to reduce microplastic pollution was published in the Official Journal of the EU.
More information on the regulation can be found in NNDKP`s Environment Flash No. 4/2025, available here, and in NNDKP`s Environment Flash No. 9/2025 available here.
1.12. The Soil Monitoring and Resilience Directive was published in the Official Journal of the EU
On 26 November 2025, Directive (EU) 2025/2360 on soil monitoring and resilience was published in the Official Journal of the EU.
More information on the directive, at the draft stage, can be found in NNDKP`s Environment Flash No. 4/2025 available here and NNDKP`s Environment Flash No. 9/2025, available here.
1.13. The new strategy for a competitive and sustainable bioeconomy
On 27 November 2025, the European Commission adopted a new strategic framework for a competitive and sustainable bioeconomy, aimed at accelerating the transition to a circular, decarbonized economy that is less dependent on fossil resources.
The new strategy intends, among others, to boost innovation, attract public and private investment, and develop lead markets for advanced biomaterials, in order to expand European biotechnologies and stimulate demand for bio-based products.
1.14. EU Member States agreed on new legal limits for seafloor waste
On 28 November 2025, the EU Member States adopted new limits for seafloor waste, setting for the first time clear thresholds to reduce marine pollution.
The new rules provide that areas where seafloor litter is monitored through trawl surveys must show no increase over time, while in visually monitored areas the density of litter may not exceed one item per 1,000 m², with current assessments focusing on waters up to 200 metres in depth.
To comply with the new thresholds, Member States must include in their marine strategies established under the Marine Strategy Framework Directive (“MSFD”) appropriate measures for biodiversity protection and pollution reduction.
2. NATIONAL DEVELOPMENTS SELECTION
2.1. Proposal to amend and supplement GEO No. 57/2007 on protected natural areas and biodiversity conservation
On 6 November 2025, a draft law amending and supplementing GEO No. 57/2007 on protected natural areas and the conservation of habitats, flora, and fauna was submitted to the Senate.
The amendments introduced by the draft law aim, among others, to introduce the condition that proposals for the establishment of protected natural areas may only be made by persons who can justify a legitimate public interest, as well as to establish a detailed procedure for the development and approval of management plans for protected natural areas.
2.2. CCR decision on the contribution owed by operators placing EEE on the market
On 10 November 2025, the Romanian Constitutional Court (“CCR”) Decision No. 161/2025 on the exception of unconstitutionality of the provisions of GEO No. 196/2005 on the Environmental Fund concerning the contribution owed by economic operators placing electrical and electronic equipment (“EEE”) on the national market was published in the Official Gazette No. 1039.
CCR found that the provision in question is constitutional, considering the contribution a legitimate fiscal remedy for correcting the inaccurate declaration of the quantities of EEE placed on the market and for promoting environmental protection and human health objectives by preventing or reducing the impacts associated with the generation and management of EEE waste.
2.3. Amendments to the legislation regulating the single industrial license
On 14 November 2025, GEO No. 61/2025 on certain measures for the implementation of Regulation (EU) 2024/1252 establishing a framework for ensuring a secure and sustainable supply of critical raw materials, as well as amending and supplementing GEO No. 140/2022 on the single industrial license was published in the Official Gazette No. 1051.
The Ordinance introduces, among others, an expansion of the powers of the Industrial License Office, which will also serve as a “single point of contact” for the authorization of projects concerning critical raw materials, as well as the establishment of specific deadlines for the resolution of applications concerning the single industrial license.
More information on the single industrial license can be found in NNDKP’s Environment Flash No. 7/2025, available here, and NNDKP’s Environment Flash No. 10/2025, available here.
2.4. Draft emergency amending the legislation on protected natural areas
On 19 November 2025, the Ministry of Environment, Water and Forestry (“MEWF”) launched for public consultation the draft GEO amending and supplementing GEO No. 57/2007 on protected natural areas and the conservation of habitats, flora, and fauna, and on 3 December 2025, a public debate was held on the draft legislation.
The proposed amendments concern, among others, the introduction of the concept of “biodiversity priority areas”, as well as the indication of the zones they may include and the rules governing their management.
2.5. Proposed amendments regarding the monitoring and control of olfactory discomfort
On 19 November 2025, a draft law amending and supplementing GEO No. 195/2005 on environmental protection was submitted to the Senate.
The proposed amendments concern, among others, the expansion of the definition of olfactory discomfort and the introduction of procedural rules for investigating and managing situations of olfactory discomfort.
2.6. GEO amending and supplementing certain normative acts in the forestry field
On 21 November 2025, GEO No. 63/2025, amending and supplementing certain normative acts in the field of forestry was published in the Official Gazette No. 1076.
More information on the draft GEO can be found in NNDKP’s Environment Flash No. 10/2025, available here.
2.7. Draft order amending the methodology for calculating the fees for DRS packaging
On 21 November 2025, the MEFW launched for public consultation the draft Order amending and supplementing Annex No. 1 to MEFW Order No. 2202/2024, which establishes the methodology for calculating the management and administration fees for packaging under the deposit-return system (“DRS”) and on 28 November 2025, a public debate was held on the draft legislative act.
The amendments proposed in the draft order aim, among others, to update the rules on the return of DRS packaging and to revise the methodology for calculating management and administration fees, including by clarifying the obligations of operators.
2.8. The MEFW launched the new revised form of the National Waste Management Plan for public consultation
On 27 November 2025, the MEWF launched for public consultation the second revised version of the National Waste Management Plan (“NWMP”).
During the consultation process, the interested public had the opportunity to submit new observations and comments on the strategic document.
More information on the previous version of the revised NWMP can be found in NNDKP’s Environmental Flash No. 8/2025, available here.
2.9. Draft GEO for the implementation of the Ecodesign for Sustainable Products Regulation
On 27 November 2025, the Ministry of Economy, Digitalization, Entrepreneurship, and Tourism published the draft GEO on the implementation of Regulation (EU) 2024/1781 establishing a framework for setting ecodesign requirements for sustainable products (the “Ecodesign for Sustainable Products Regulation”).
Among others, the draft establishes the national mechanisms necessary for the application of the Ecodesign for Sustainable Products Regulation, including the powers of the authorities, market surveillance procedures, the obligations of economic operators regarding compliance, as well as the penalty regime applicable in case of non-compliance.
More information on the Ecodesign for Sustainable Products Regulation can be found in NNDKP’s Environmental Flash No. 1/2024, available here.
The Romanian version of this newsletter is available here.
