Environmental Law 2025

INTRODUCTION  Contributed by: Tove Andersson, Anders Linnerborg, Sara Eriksson and Ellen Lewin, Setterwalls Advokatbyrå AB

the EU day-ahead electricity trading markets, moving trading intervals from hourly to 15-minute intervals, making the markets more dynamic and equipped for the growing share of renewable energy. It is clear that decarbonisation will require a portfolio of different measures on various levels. Over the past years, interest has grown in both cutting emissions and addressing those already released. Methods include both clean energy sources, including nuclear power, and CO₂ capture and storage solutions. Nuclear power and small modular reactors (SMRs) The increasing demand for electricity has made sever- al governments and industrial stakeholders turn their attention to nuclear power, providing a stable form of low-emission electricity and reducing dependence on fossil fuels. Although an increased interest, significant regulatory and market barriers persist, including high costs and long permitting and construction timelines. In the beginning of the year the IEA suggested that SMRs (see report, The Path to a New Era for Nuclear Energy), cutting the overall investment costs for indi- vidual projects, can play an essential role in change along with continued innovation and government support. Similar proposals have been made by the European Industrial Alliance on SMR, established in February 2024, which in September 2025 adopted its first Strategic Action Plan, including steps to simplify- ing regulatory frameworks. The European Commis- sion is one of the key partners of the Alliance and in implementing the strategy. The Commission’s sup- port to accelerate the development and deployment of SMRs has also been outlined in the Clean Industrial Deal, published earlier this year. Consequently, fur- ther policy and market initiatives concerning SMRs are expected in the years to come, not least in the EU. Carbon dioxide capture and geological storage (CCS) While discussing decarbonisation, technologies for CO₂ capture and storage should also be mentioned. As outlined in the Net-Zero Industry Act (NZIA), the EU has set a target of achieving a CO₂ injection capacity of at least 50 million tonnes per year by 2030. The regulation is designed to develop an EU market for CO₂ storage services and introduces obligations for

hydrocarbon producers, EU member states and the European Commission. Over the past year, the work with CO₂ storage has intensified in Europe. This is partly because, since December 2024, the member states of the EU are required to submit an annual report to the Com- mission detailing active CO₂ capture, transport and storage projects within their borders, along with the related needs for injection and storage capacity. They must also disclose any national support measures, strategies and targets adopted or planned for CO₂ capture. These reports are made publicly available by the Commission. Regulatory Developments on Sustainability The year 2025 marks notable advancements in the regulatory landscape concerning sustainability. The EU has introduced and updated several key regu- lations aimed at reducing waste, promoting circular economy principles and enhancing environmen- tal resilience. On the international stage, efforts to address plastic pollution continue through ongoing United Nations negotiations. Waste management During 2025, waste has continued to be an important issue within the EU. The Packaging Waste Regula- tion (PPWR), replacing the PPWD, and the revision of the Waste Framework Directive to reduce textile and food waste are examples of new regulation which have been relevant during 2025. The PPWR entered into force in February 2025, harmonising rules for packaging, with a focus on secondary raw materi- als, manufacturing, recycling and reuse. The aim is to minimise the quantities of packaging and waste gen- erated while lowering the use of primary raw materials and fostering the transition to a circular, sustainable and competitive economy. Most provisions will start to apply from August 2026. During 2025, the European Commission has also tak- en measures to implement the Waste Shipment Regu- lation, adopted in April 2024, by developing a Digital Waste Shipment System (DIWASS) to simplify waste shipments between member states. The DIWASS is currently under development but will be mandatory to

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