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ClientEarth has submitted a detailed response to the European Commission’s Call for Evidence on “Simplification of administrative burden in environmental legislation.” Our position is clear: simplification must not mean deregulation. Strong environmental laws are essential for protecting public health, advancing the circular economy, and achieving the EU’s climate and biodiversity goals.
Key Messages:
Environmental protection is not a burden – Failure to implement EU environmental law already costs €180–325 billion annually. Lowering standards would worsen health impacts, pollution, and economic losses.
Tackle real bottlenecks – Implementation issues, lack of capacity, and poor digital infrastructure – not the laws themselves – slow progress. Solutions include technical assistance, interoperable digital reporting, and better enforcement.
Keep SCIP reporting – The SCIP database is vital for chemical safety and a non-toxic circular economy. Rather than discontinuation, we urge usability improvements and alignment with REACH reforms.
Net Zero Industry Act (NZIA) – Reopening NZIA risks legal uncertainty and undermines the energy transition. Its “one-size-fits-all” simplification approach should not become a model for other legislation.
Industrial Emissions Directive (IED) – IED 2.0 strikes a balance between ambition and administrative feasibility. Transformation plans, EMS, and chemical inventories are crucial to achieving the EU’s zero-pollution and climate targets.
EU Deforestation Regulation (EUDR) – This recently adopted law is fit-for-purpose and should not be weakened. Businesses have already invested in compliance ahead of its 2025 application.
ClientEarth calls on the Commission to prioritise smart digitalisation, consistent enforcement, and capacity-building – not deregulation – to make EU environmental law more effective and business-friendly while safeguarding Europe’s green transition.