From tangled to tidy: can the Environmental Omnibus simplify Europe’s green transition?
Position Paper
9 Sep 2025
Consumer affairs, Corporate sustainability, Environment, Energy, simplification

Europe’s environmental rules have become increasingly complex, creating contradictory and duplicative requirements that undermine the EU’s competitiveness globally. With the Environmental Omnibus, the EU has an opportunity to streamline its most complex rules. Tackling overlaps, inconsistencies and excessive reporting obligations would improve legal clarity, enhance predictability and strengthen the business case for investment and the clean transition. From permitting to product sustainability, waste, chemicals and beyond, learn why clearer rules will drive Europe’s competitiveness and accelerate the green transition.

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Industry calls for repeal of the SCIP database

AmCham EU has joined over 30 industry associations in calling on EU co-legislators to confirm the repeal of the Substances of Concern In articles as such or in complex objects (Products) (SCIP) database, as proposed in the Environmental Omnibus. SCIP costs companies around €225 million a year, yet its intended users, recyclers, barely use it. The Commission itself acknowledges that waste operators find the data unusable and most companies lack the resources to maintain millions of notifications. Repeal would remove a disproportionate reporting layer while keeping obligations for suppliers to inform customers about substances of very high concern. Any future approach should build on existing obligations, not add new ones.

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The Single Market is only as simple as its Member States make it

This blog is authored by Malte Lohan, CEO, AmCham EU.

What exactly is ‘single’ about a market where the same product needs different national markings, a cyber incident can require dozens of reports and a professional qualification may stop being recognised at the border?

These examples come from different sectors, but they point to the same contradiction. The EU creates common rules, yet companies still encounter national requirements that divide Europe into separate markets in practice.

The stakes are high for American companies invested in Europe. The United States is the largest single source of inward foreign direct investment (FDI) into the EU. In 2025, American companies invested more in Europe (53%) than they did the rest of the world combined. This has been the case for decades. Much of this appeal lies in the promise of a large, prosperous Single Market.

Yet there are signs that this position is coming under pressure. While Europe remains the leading destination for US investment, its share of total US outward FDI has fallen to its lowest level in more than four decades. More recent indicators point in the same direction too. EY’s 2026 European Investment Monitor found that 943 US companies invested in Europe last year, 16% below the annual average of 1,124 over the previous five years. To reverse these trends, Europe needs to make itself a more attractive place to invest, beginning with a more integrated Single Market.

That is why the simplification agenda cannot lose steam – in Brussels and national capitals. In her September State of the Union address, European Commission President Ursula von der Leyen highlighted the need for EU-wide coordination. ‘Simplification cannot be a one-way street’, she said. ‘All levels have to have skin in the game’.

As EU leaders check in on progress under the ‘One Europe, One Market’ roadmap at this week’s European Council meeting, they should look closely at how national choices affect companies operating across borders. That means addressing three related but distinct problems: gold-plating, uneven implementation and the national barriers that continue to fragment the Single Market.

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Europe has an opportunity to make its chemicals rules simpler without weakening the protection they provide. The Commission plans to simplify the Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) through secondary legislation. Rules that are proportionate, clearly scoped and grounded in evidence are easier to follow and easier to enforce. They also give companies the certainty they need to invest and keep producing in Europe. Read our recommendations for a REACH that is simpler to apply and better for competitiveness.

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