In the coming days, the Cabinet of Ministers of Ukraine will consider 2 bylaws – draft government resolutions – to Law No. 3855-IX “On Integrated Prevention and Control of Industrial Pollution”.
This was announced by Bohdan Semenenko, Director of the Department of Industrial Pollution Prevention and Climate Policy of the Ministry of Environmental Protection and Natural Resources, at the open dialogue “State of Implementation of the Industrial Pollution Prevention Reform.”
He clarified that these are draft resolutions that approve the procedure for developing and approving conclusions on the best available technologies and management methods (BATM), as well as the procedure for holding a coordination meeting on the issuance of an integrated environmental permit.
Svitlana Sushko, expert of the Reform Support Team at the Ministry of Environment and moderator of the meeting, said that in 2025 Ukraine should report on the steps taken towards the implementation of this law, as the document is a framework and provides for the development of about 20 regulatory acts to make it work. She also reminded that the Law on Industrial Pollution No. 3855-IX comes into force on August 8, 2025.
What work needs to be done
Bohdan Semenenko spoke in detail about the scope and types of work that must be done in order for the law on industrial pollution to be effective:
- To adopt subordinate legal acts (12 resolutions of the Cabinet of Ministers of Ukraine and 3 orders of the Ministry of Environment).
- Make changes to the existing legal acts so that they meet the requirements of Law No. 3855-IX on eco-modernization.
- Develop a system for issuing integrated environmental permits in electronic form (the Unified State Register of Integrated Environmental Permits).
- Provide translation of 26 NDTM reference documents and 21 NDTM conclusions. Approve the conclusions of NDTM.
Bohdan Semenenko noted that the ministry plans to finish work on the implementation of items 1-3 before the law enters into force on August 8, 2025.
Which is already ready
Currently, from the necessary documents already acceptedResolution No. 7 of the Cabinet of Ministers dated January 7, 2025 "On approval of the form and requirements for the content of conclusions regarding the issuance of an integrated environmental permit (amendments to it)". It, in particular, establishes a uniform form of conclusions to be submitted to the Ministry of Environment by the competent bodies defined by the Law.
What acts are in the final stage
In the coming days will be submitted2 more documents for consideration:
- Draft Resolution of the CMU "On approval of the order of development, approval of conclusions of the best available technologies and management methods, involvement of other executive authorities in their development and informing about them, as well as publication of reference reference documents on the best available technologies and management methods (BREFs)". It will define the procedure for developing draft conclusions of the best available technologies and management methods (BTM) based on EU legislation.
- Draft Resolution of the CMU "On approval of the Procedure for holding a conciliation meeting regarding the issuance of an integrated environmental permit". This document should establish the requirements for the procedure for holding a conciliation meeting, which will be convened by the Ministry of Environment to agree on the positions of the competent authorities regarding the issuance of an integrated environmental permit or making changes to it.
According to Bohdan Semenenko, more than 15 normative legal acts are currently in the works. For today undergo interdepartmental approval2 documents:
- Draft Resolution of the CMU "On approval of the procedure for organizing and holding public hearings in the process of issuing an integrated environmental permit (amending it)";
- Draft Resolution of the CMU "On approval of requirements for the form and content of the application for obtaining an integrated environmental permit (amendments to it)".
The director of the department classified the second of these resolutions as fundamental documents.
"It generally forms the format and content of everything that a business entity must submit to us as a permit authority to obtain the permit itself. We have already developed the form and content of the application. Now we are processing both the remarks and comments of the public and central executive authorities," he said.
High degree of readinessin the following legal acts:
- The draft order of the Ministry of Environment "On approval of requirements for the content and form of the report on public discussion in the process of issuing an integrated environmental permit (amendments to it)". This report will be filled out by the permitting authority and summarize the comments and suggestions received from the public.
- Draft Resolution of the CMU "On approval of the Requirements for the form and content of the integrated environmental permit".
As the second most important resolution, after the one that establishes the form and content of the operator's statement, Semenenko named the project on approving the requirements for the form and content of the integrated environmental permit. It forms a basic vision of what the environmental permit will be, says the official.
According to him, now in active development6 more normative legal acts – 4 draft resolutions of the CMU and 2 orders of the Ministry of Environment.
As EcoPolitic reported earlier, at the beginning of January, the government determined requirements for conclusions on the issuance of integrated environmental permits in Ukraine.
