NNDKP Environment Flash No.8/2025
1. EU DEVELOPMENTS SELECTION
1.1. Preliminary initiatives regarding the upcoming Circular Economy Act
On 1 August 2025, the European Commission launched a public consultation for the upcoming Circular Economy Act.
The act is expected to be adopted in 2026 and will primarily seek to establish a Single Market for secondary raw materials, increase the supply of high-quality recycled materials, and stimulate demand for such materials within the EU, with the aim of accelerating the transition to a more circular economy.
Interested parties can submit suggestions on the legislative initiative by 6 November 2025.
1.2. Input request on the implementation of the Carbon Border Adjustment Mechanism
On 28 August 2025, the European Commission launched a call for evidence to collect feedback from all stakeholders regarding:
- the rules on the methodology for calculating the embedded emissions in goods covered by the Carbon Border Adjustment Mechanism (“CBAM”);
- the rules on the adjustment of CBAM certificates to reflect the free allocations under the EU Emissions Trading System (“EU ETS”);
- the rules on the deduction of the carbon price paid in a third country.
This initiative supports the European Commission’s broader objective of simplifying the CBAM Regulation and enhancing its cost-efficiency.
Stakeholders may submit their feedback and comments until 25 September 2025.
More information on the CBAM simplification proposal can be found in NNDKP`s Environment Flash No. 5/2025, available here and NNDKP`s Environment Flash No. 6/2025, available here.
2. NATIONAL DEVELOPMENTS SELECTION
2.1. The Ministry of Environment, Water and Forestry launched a public consultation on the revised form of the National Waste Management Plan
On 13 August 2025, the Ministry of Environment, Water and Forestry (“MEWF”) launched for public consultation the first revised version of the National Waste Management Plan (“NWMP”).
The NWMP aims to develop a general framework for a sustainable national waste management system that ensures compliance with European objectives and targets transposed into national legislation.
Among the general objectives of the NWMP are the transition to a circular economy and the prioritization of the waste hierarchy in every decision, investment, or plan, while the specific objectives include assessing the current waste situation, identifying management issues, setting objectives and targets, and determining investment needs.
During the consultation process, interested members of the public had the opportunity to submit observations and comments on the strategic document.
2.2. Amendments to the organization and functioning of the National Environmental Guard
On 18 August 2025, the Government Decision No. 660/2025 amending and supplementing the Government Decision No. 1005/2012 on the organization and functioning of the National Environmental Guard was published in the Official Gazette No. 768.
The normative act provides, among other things, amendaments concerning the organizational structure of the National Environmental Guard, the maximum number of positions allocated to the central apparatus and the territorial structures without legal personality, as well as the institution’s responsibilities and the procedure for carrying out control actions.
2.3. Legislative amendment regarding the deposit-return system for non-reusable primary packaging
On 18 August 2025, the Government Decision No. 659/2025 amending Government Decision No. 1074/2021 on the establishment of the deposit-return system for non-reusable primary packaging (“DRS”) was published in the Official Gazette No. 766.
More information on the amendment can be found in NNDKP’s Environmental Flash No. 7/2025, available here.
2.4. The National Environmental Guard has launched a package of practical guides for economic operators
On 20 August 2025, the National Environmental Guard published published 12 practical guides aimed at ensuring compliance with environmental protection requirements, in the context of Romania’s accession process to the Organization for Economic Cooperation and Development.
These materials contain centralized information intended to support economic operators in complying with the environmental regulations applicable to their activities.
The topics covered in the practical guides include, among others, activities such as waste transfer, the management of waste batteries and accumulators, fuel distribution, and cement manufacturing.
2.5. Initiative of the Ministry of Environment, Water and Forestry regarding the management of olfactory discomfort
On 22 August 2025, the MEWF launched for public consultation the drafts on the Methodology for establishing the level of olfactory discomfort and the Content of the olfactory discomfort management plan.
The two projects establish, among other things, the relevant definitions and measurement methods for determining the level of olfactory nuisance, as well as aspects related to the elaboration and minimum content requirements of olfactory nuisance management plans.
Interested parties may submit opinions, proposals, and suggestions within 30 calendar days from the publication of the two drafts.
2.6. Legislative amendments regarding the application of certain sustainability reporting requirements
On 22 August 2025, Ministry of Finance’s Order No. 1421/2025 regarding the dates from which certain sustainability reporting requirements apply was published in the Official Gazette No. 786.
The order postpones the application of sustainability reporting requirements for certain types of entities by two years, in accordance with the provisions of Directive (EU) 2025/794, also known as the “Stop the Clock” Directive, amending Directives (EU) 2022/2464 (the CSRD Directive) and (EU) 2024/1760 (the CSDDD Directive).
Further details regarding the “Stop the Clock” Directive are available in NNDKP’s Environmental Flash No. 4/2025, available here.
Both EU and national developments are listed chronologically.
The Romanian version of this newsletter is available here.
