Environmental Omnibus: Will simplification accelerate circularity?

The European packaging industry is entering a new chapter. With the European Commission (EC)’s new Environmental Omnibus now published, producers face both relief and responsibility.

The proposed reforms aim to cut years of complexity, but will simplification speed up circularity or dilute ambition? The answer lies in implementation.

What is the Environmental Omnibus?

The Environmental Omnibus is a set of proposed legislative updates from the European Commission designed to cut through layers of complexity in existing EU environmental law.

It’s the eighth simplification package under the current mandate, signalling a clear push toward harmonisation. Crucially, the Omnibus doesn’t aim to rewrite environmental targets, but focuses on trimming procedural and administrative requirements. The aim is to make compliance smarter by rationalising the rulebook, accelerating strategic projects, digitising reporting and easing the burden on SMEs and businesses operating across EU countries.

Most importantly, the Omnibus proposes to remove the need for European producers selling packaged products across EU borders to appoint authorised representatives in each member state to fulfil their Extended Producer Responsibility (EPR) obligations. This would remove a long-standing barrier to the Single Market if signed into law. With this change, producers would still have to meet all EPR obligations, with the goal being to streamline compliance without weakening environmental ambition.

Yet concerns remain, with the Omnibus proposal highlighting several areas of EPR legislation for future simplifications. Proposed flexibilities, such as exemptions for hygiene and food safety, could delay reuse targets and slow progress towards a truly circular packaging economy.

Simplification vs ambition

While the intent of the Omnibus is to streamline compliance, some industry voices argue that simplification could come at a cost. By introducing additional flexibilities, there is a risk that measures designed to accelerate reuse and recyclability may be relaxed, losing their original strength and purpose.

For example:

• Exemptions for hygiene and food safety could delay reuse obligations for the takeaway sector.
• Adjustments to PFAS restrictions or recycled content requirements could weaken environmental safeguards.

These concerns highlight a delicate balance: reducing administrative burden without eroding the ambition that underpins the PPWR.