Ministry of Environment of the Czech Republic

The Czech Republic wishes to underline the critical importance of the benchmark revision for the period 20262030. Timely finalization of the revised benchmarks is essential to ensure legal certainty and the smooth allocation of free allowances already for 2026.

Czechia generally welcomes the simplification initiative and all efforts to lower the administrative burden. Already during public consultation before the submission of the current proposal, we pointed out to a broad range of legislative acts where we identified space for simplification and lowering administrative burden and we submitted detailed proposals.

Implementation of DNSH principle is problematic, as guidance essentially establishes a sustainability assessment, which may be extensive as well as streamlined to the current climate and environmental legislative framework. There are several methodologies which overlap in their objectives, the scope of application is not coherent between the EU funds legislation.

Czech Republic would like to point out that as a general principle, it is necessary not to raise administrative burden and not to raise excessive requirements to sorting and recycling facilities. The recycling industry is currently under pressure already in Europe and we must make sure that newly emerging rules will support its competitiveness and regrowth.