European Commission Seeks SME Evidence On Environmental Legislation

EU Environmental Legislation Survey Opens To Smaller Businesses

An EU environmental legislation survey commissioned for the European Commission's Directorate-General for Environment is open until 12 October 2026. The questionnaire seeks practical evidence from small and medium-sized enterprises, small mid-cap companies and their representative organisations.

The commissioned questionnaire is hosted on Alchemer rather than a Commission domain.

The study examines how environmental rules affect smaller businesses in practice. It asks about legal requirements, administrative procedures, interaction with authorities, thresholds, exemptions, simplified routes, guidance, digital tools and costs that may be disproportionate to company size.

The survey is evidence gathering, not legislation. It does not change any current environmental obligation, create a derogation or pause an application deadline. Businesses must continue to follow existing EU and national requirements.

What The Commission Study Is Examining

The questionnaire is designed to capture problems that may not be visible from legal texts alone, including duplicated reporting, difficult permitting processes, fragmented national implementation and information requests passed down by larger customers. Respondents do not need specialist legal expertise, and completion is estimated at 20 to 30 minutes.

The study is relevant to the EU's wider simplification agenda and the emerging small mid-cap category. Small mid-caps are intended to address the regulatory cliff edge that can occur when a growing business exceeds the European Union's small and medium-sized enterprise thresholds. However, the survey does not itself establish that category or guarantee a legislative proposal.

No particular environmental rule is suspended by participating. Companies should distinguish between describing a burden, proposing a proportionate alternative and arguing against the environmental objective itself. Evidence is likely to be more useful where it identifies a specific provision, process, cost, frequency, competent authority and practical remedy.

How Manufacturers Can Provide Useful Evidence

Manufacturers should coordinate environmental, legal, finance and operations teams before responding. A submission can quantify staff time, external-adviser cost, permit delay, recurring fees, duplicate data fields and the investment consequences of uncertainty. It should also describe company size and sector so the evidence can be interpreted correctly.

Trade associations can aggregate recurring issues while preserving commercial confidentiality. Importers, waste operators and downstream users should include burdens created indirectly through supply-chain requests, even where a larger company is the direct regulated entity.

What remains unchanged is the current body of EU environmental law, including permitting, waste, industrial-emissions, product and extended producer responsibility obligations. Any future simplification would require the appropriate legislative or administrative process.

Related Foresight coverage explains the proposed EU small mid-cap category, the Environmental Omnibus debate and the Omnibus I reporting changes.