Circular Economy
The European Commission ran a public consultation on the New Circular Economy Act initiative from 1 August until 6 November 2025. Euromines fed into this round of feedback as well as into the targeted consultation that followed. Euromines’ main asks (see our Position Paper) focused on the needs for a balanced approach between primary and secondary raw materials, to unlock permitting procedures, to make recycling a business case, and on the importance of the “no one-size-fits-all” approach (smart risk-based rules as the Extractive Waste Directive and the BREF for the Management of Extractive Waste should not be touched).
The legislative act will take the form of a Regulation aiming at enhancing resource efficiency and promoting the use of secondary materials. Commission adoption is planned for Q4 2026.
Water
The file related to the Protection of groundwater against pollution and environmental quality standards in the field of water policy (linked to the Water Framework Directive) is reaching near-adoption. The EU co-legislators found an agreement during the fourth trilogue that took place on 23 September (originally scheduled for 15 July). The provisional text will be put for final adoption by the EP on 19 January 2026 (tentative date), while the date of the Council vote is still to be announced. Once adopted, Member States will be required to transpose the directive by 21 December 2027. Despite intensive industry advocacy to raise awareness and improve the Water Framework Directive via this file, the trilogue agreement strengthens the “non-deterioration” definition and introduces only 2 very limited derogations.
However, Euromines’ advocacy efforts were echoed. The Commission’s RESourceEU Action Plan published on 3 December 2025 foresees the release of a guidance document in Q1 2026, to enable a simpler and more harmonised implementation in Member States of the EU law on environmental permitting, including aspects related to water and the mining sector. The Commission will also review and revise the Water Framework Directive by Q2 2026. Euromines is preparing input and outreach for both initiatives.
Soil Monitoring Law (SML)
After the co-legislators’ provisional agreement in April 2025, Council adopted the SML text on 30 September 2025. Ahead of the EP ENVI vote of 20 October, Euromines and other associations reached out to MEPs, pushing them to reconsider the SML in view of the EU simplification efforts. The text was eventually formally adopted in EP Plenary on 23 October and published in the EU Official Journal on 26 November. Member States will have three years for transposition into national legislation (until late 2028).
Overall, Euromines notes significant improvements in the SML compared to the initial proposal. It leaves more flexibility for implementation at Member State level, recitals clarify that permitting procedures will not be hampered, and provisions are more realistic (no one-out-all-out principle, non-binding sustainable target values at EU level, consideration of background concentrations and natural occurrence of metals). As for the next steps, Euromines will focus on the national implementation of the SML.
Metal Mining BREF (MIN BREF)
In accordance with the reviewed Industrial Emissions Directive, the drafting process of the Best Available Techniques (BATs) reference document (BREF) for the metal mining sector officially started in 2024. A BREF is the reference for setting emission limit values and issuing operating permits for industrial installations in EU Member States. It describes applied techniques, present emissions and consumption levels, techniques considered for the determination of best available techniques as well as BAT conclusions and emerging techniques. It is the result of the exchange of information carried within a Technical Working Group (TWG) composed of national authorities, ECHA, NGOs, industry, and led by the Commission (EU-BRITE).
During the second half of 2025, the MIN BREF process was fully dedicated to improving EU-BRITE’s questionnaire proposal. Over summer and until the beginning of November, Euromines provided 3 waves of comments on the first draft questionnaire while maintaining close engagement with the MIN BREF authors (EU-BRITE). The second draft proposal was released for comments on 12 November, and Euromines pushed its position during the workshop on questionnaire finalisation that followed (9-10 December).
In parallel, the second site visits took place in Austria in November 2025. Such field trips aim at providing on-the-ground insights to the TWG, by showing local conditions, emissions, techniques used and possible challenges. Representatives from EU-BRITE, European Commission (DG ENV), Member States (AT, ES, FR, HU, SE), NGOs (EEB), technology providers (CECE) and industry (Euromines) took part to the trip. The TWG was able to visit one Competent Authority along with 2 mines: Erzberg (Iron) and Mittersill (Tungsten). We trust that these visits gave valuable understanding of on-site realities to the TWG, and should be complemented with further visits showing other local conditions in different areas of the EU. We invite operators to get in touch with their national authorities and encourage them to organise such visits, to emphasise the diversity of the sector in the context of the MIN BREF.
Ongoing MIN BREF priorities relate to the identification of CBI fields in the questionnaire and KEIs for chemicals, supporting the drafting of the BREF descriptive chapters, and the preparation for the questionnaire testing period that will run from mid-January until mid-February. Euromines is contributing on all fronts, with the aim of obtaining a questionnaire that will reflect the diversity and complexity of the mining sector without increasing the data reporting burden on operators, to eventually collect appropriate data and draft a realistic MIN BREF document.
As for the next steps, the final questionnaire will be released to kick off the official data collection phase in the first half of March, for completion by selected operators by the second half of June. The ensuing data assessment phase will culminate in a workshop in Q4 2026, before the release of the first MIN BREF draft in Q1 2027.
Industrial Emissions Directive (IED) 2.0
A year and a half after the publication of the revised IED (15 July 2024), several aspects of the revision are still a work in progress, and the consequences of the new text are not all fully defined yet. While Member States are tasked to carry the implementation of the new IED by 1 July 2026, the Commission committed to delivering several implementing acts and decisions. After a consultation carried out earlier in 2025, which received Euromines’ feedback, the Commission released the reviewed draft BREF guidance on 19 December. Together with other associations, Euromines is currently reviewing the document and will provide its input during the upcoming Article 13 Forum (March 2026).
It is worth noting that the EU simplification efforts, and particularly the Environmental Omnibus of 10 December 2025, are impacting the task of the Commission. As the Omnibus foresees amendments regarding the Environmental Management Plan (EMS) (deletion of requirements for chemicals inventories, indicative transformation plans and obligation for independent audit), we can expect that the work on the EMS implementing act will now be able to move forward, and that the delegated act on the content of transformation plans content will be deleted.