NNDKP Environment Flash No.7/2025
1. EU DEVELOPMENTS SELECTION
1.1. Rules on the digital system for shipments of waste within the EU
On 2 July 2025, the European Commission adopted the rules governing the Digital Waste Shipment System (“DIWASS”), this system being one of the main objectives of the EU Waste Shipment Regulation.
The new system will apply to notified and green-listed waste ensuring a digitized and uniform flow of data between the competent authorities and the economic operators in all Member States.
The technical documentation and training of the authorities will be completed by the end of 2025, and the use of DIWASS will become mandatory from 21 May 2026 for all intra-EU waste shipments.
1.2. Evaluation of the EU Directive for the management of electrical and electronic waste
On 2 July 2025, the European Commission published its evaluation of the EU Waste from Electrical and Electronic Equipment Directive (“WEEE Directive”).
The evaluation shows that although progress has been made in treating this waste properly, almost half of the waste generated is not collected and the majority of Member States do not reach the collection target set out in the WEEE Directive.
The conclusions of the evaluation will be carefully examined by the European Commission in the context of the revision process of the WEEE Directive with the aim of improving the provisions of the legislative act.
1.3. EU proposes a new climate target for 2040
On 2 July 2025, the European Commission proposed an amendment to the EU Climate Law (Regulation 2021/1119), setting a new climate target for 2040, which calls for net greenhouse gas emissions to be reduced by 90% compared to 1990 levels.
The European Commission proposal is to be forwarded to the European Parliament and the Council for discussion and adoption.
1.4. New rules for measuring battery recycling efficiency and recovery of critical materials
On 4 July 2025, the European Commission adopted new rules on calculating and verifying the recycling and material recovery efficiency of used batteries, in application of the EU Regulation on batteries and battery waste.
The rules establish, among others, uniform methods for calculating the efficiency of recycling and material recovery, in particular for critical raw materials such as lithium, cobalt, nickel and lead, and introduce a uniform format for recyclers to report data to national authorities.
The new rules entered into force on 24 July 2025.
More information on the EU Regulation on batteries and battery waste can be found in NNDKP’s Environment Flash No. 1/2024, available here.
1.5. Roadmap for nature credits to support investment in ecosystem restoration
On 7 July 2025, the European Commission launched a roadmap for the development of nature credits, a voluntary instrument to attract private investment in actions that protect and preserve nature.
The credits will be available for activities such as wetland restoration or forest expansion, in return offering economic and reputational benefits to investors.
The European Commission aims to ensure that the system of nature credits is based on clear rules and independently verified certificates to guarantee the real effectiveness of projects and prevent greenwashing.
All interested parties can submit suggestions on this initiative until 30 September 2025.
1.6. New rules on circular economy in the automotive sector
On 7 July 2025, the Environment and Internal Market Committees of the European Parliament adopted a series of proposals on the End-of-Life Vehicles Regulation (“ELV Regulation”), which is currently in the legislative process.
The proposals establish, among others, new obligations for vehicle producers, including the use of at least 20% recycled plastic in new vehicles within 6 years of the entry into force of the regulation and an extended producer responsibility, covering the cost of the collection and treatment of their vehicles that have reached the end-of-life stage.
The regulation should apply to cars and vans one year after its entry into force, and to other categories of vehicles, such as buses and heavy trucks, after five years, with certain exceptions.
The next step is the adoption of the proposals in the plenary of the European Parliament, scheduled for the 8-11 September 2025 session.
More information on the ELV Regulation can be found in NNDKP’s Environment Flash No. 6/2025, available here.
1.7. Public consultation on CO2 emission standards and car labelling
On 7 July 2025, the European Commission launched a public consultation on the revision of CO2 emission standards for new passenger cars and light commercial vehicles, as well of the Directive regulating the labelling of passenger cars on the European market.
These initiatives aim to reduce greenhouse gas emissions and increase the use of zero-emission vehicles in the EU, in order to contribute to the path towards climate neutrality.
The interested parties can submit their arguments and opinions via the portal provided by the European Commission until 29 September 2025.
1.8. Public consultation on the rules regarding the recycled content from plastic bottles
On 8 July 2025, the European Comission launched a public consultation on the rules for calculating, verifying and reporting the recycled content, including chemically recycled content of single-use plastic bottles in order to meet the targets set by the Directive on the reduction of the impact of certain plastic products on the environment (the “SUP Directive”).
The proposed methodology is based, among others, on the “fuel-use excluded” rule, which means that waste converted into fuel or used for energy recovery will not be considered recycled content.
The interested parties can submit their arguments and opinions via the portal provided by the European Commission until 19 August 2025.
1.9. Transitional measures for European Sustainability Reporting Standards
On 11 July 2025, the European Commission adopted a set of amendments to the regulations for the first set of the European Sustainability Reporting Standards (“ESRS”).
According to these changes, for the financial years 2025 and 2026, wave one companies will be able to continue to omit the same information as in 2024, and companies with more than 750 employees will temporarily benefit from the same simplified reporting provisions currently applicable to companies with up to 750 employees.
According to the European Commission, this quick fix was necessary because companies in the first wave didn’t get the sustainability reporting delay offered by the “Stop-the-clock” Directive adopted in February 2025 as part of the Omnibus I package, which you can learn more about in NNDKP’s Environment Flash No. 2/2025, available here.
1.10. Postponement of due diligence requirements for batteries
On 18 July 2025, the EU Council adopted a new legislative act postponing by two years, until 18 August 2027, the application of the due diligence obligations for batteries.
The aim is to give battery producers and exporters more time to adapt to the new requirements and to support the EU’s industrial competitiveness.
In addition to the extra time given to companies, the postponement will also allow more time for the establishment of third-party verification bodies. The postponement is part of the Omnibus IV package.
The legislative act was published in the Official Journal on 30 July 2025 and entered into force on 31 July 2025.
1.11. The European Commission invites interested parties to submit suggestions on simplifying the environmental legislation
On 22 July 2025, the European Commission invited the public to express its views on amending the environmental legislation in order to simplify and reduce the administrative burdens arising from its implementation. The feedback period is open until 10 September 2025.
The initiative considers the upcoming omnibus proposal on the environment, which is expected to bring together measures to simplify the legislation on circular economy, industrial emissions and waste management.
The main purpose is to identify existing environmental policies at EU level that have real simplification potential for operators, without harming EU environmental objectives and the protection of human health.
1.12. The International Court of Justice issues an advisory opinion on obligations arising from the environmental law
On 23 July 2025, the International Court of Justice (the ”ICJ”) issued an advisory opinion clarifying that States have both an obligation to protect the climate system and the environment, and to cooperate across borders, preventing possible damage.
The ICJ expressly emphasized the high standard of due diligence required to prevent significant environmental damage, the importance of the principle of shared responsibility, cooperation and full reparation of the caused damage.
In addition, the opinion strengthens the legal grounds for recognizing ecocide as a possible international crime and marks an important step in treating environmental protection as a legal obligation based on existing international frameworks, not just policy.
More information on measures to combat environmental crime can be found in NNDKP’s Environment Flash No. 5/2025, available here.
1.13. Recommendation for a voluntary sustainability reporting standard for SMEs
On 30 July 2025, the European Commission adopted a recommendation on a voluntary sustainability reporting standard for small and medium-sized companies (“SMEs”) that fall outside the scope of the Corporate Sustainability Reporting Directive (“CSRD”).
The recommendation is an interim solution, pending the formal adoption of a delegated act on the voluntary standard, aimed at supporting SMEs in responding to sustainability-related information requests from large companies and financial institutions, facilitating their access to sustainable finance and improving their sustainability performance.
More information on the CSRD and the Omnibus I package can be found in NNDKP’s Environment Flash No. 2/2025, available here, and in NNDKP’s Environment Flash No. 6/2025, available here.
2. NATIONAL DEVELOPMENTS SELECTION
2.1. The Order approving the procedure for placing dams in conservation, post-use, or abandonment has entered into force
On 3 July 2025, the Order No. 1743/2025 approving the procedure for placing dams in conservation, post-use, or abandonment was published in the Official Gazette No. 628.
More information on the normative act can be found in NNDKP’s Environment Flash No. 1/2025, available here.
2.2. Proposal to amend the DRS
On 9 July 2025, the Ministry of the Environment, Water and Forestry submitted for public debate the draft decision amending Government Decision No. 1074/2021 on the establishment of the DRS for non-reusable primary packaging.
The proposal aims to eliminate the obligation that at least 50% of the material sent for recycling will be sold through the Romanian Commodities Exchange.
More information on the DRS can be found in NNDKP’s Environment Flash No. 1/2025, available here.
2.3. The Order approving the instructions on the endorsement procedure for obtaining the single industrial license entered into force
On 16 July 2025, the Order No. 178/2025 approving the Instructions on the endorsement of the procedures of the competent authorities for the issuance of the approvals necessary to obtain the single industrial license was published in the Official Gazette No. 665.
Among others, the Instructions require authorities to evaluate and adapt their authorization procedures for industrial activities, including by introducing the possibility to submit documents electronically via a digital platform, reducing the number of documents required, extending the validity of approvals and identifying industrial activities that can benefit from tacit approval.
Once the Instructions on the single industrial license have been published, the competent authorities have 30 days to submit their own procedures for approval.
2.4. Order on the establishment of state border crossing points for shipments of waste and secondhand goods
On 22 July 2025, the Order No. 1.887/106/2025 on the establishment of state border crossing points for shipments of waste and secondhand goods was published in the Official Gazette No. 684.
The Order shall enter into force 15 days after its publication in the Official Gazette of Romania, Part I. More information on this matter can be found in NNDKP’s Environment Flash No. 6/2025, available here.
Both EU and national developments are listed chronologically.
The Romanian version of this newsletter is available here.
