Legal Alerts/24 Oct 2025

Finnish Government Proposes New Procedure for End-of-Waste and By-Product Decisions

The Finnish Government has proposed new legislation to reform the decision-making procedure for End-of-Waste (EoW) products and by-products. Under the current system, EoW or by-product status may be granted either through an environmental permit or by way of a non-appealable statement issued by a supervisory authority. The proposed reforms aim to enhance the commercialisation of recycled materials derived from waste and by-products, thereby supporting related business activities.

Key Features of the Proposal

Standalone Classification Decisions

Where a matter concerns only by-product or EoW status, a classification decision may be issued by the new Permit and Supervisory Authority. In such cases:

A public consultation period of at least 14 days is required
The right of appeal is limited to the parties concerned and the market surveillance authority
Decisions will be entered into a public register of recycled materials

Integration with Environmental Permits

By-product and EoW status may still be granted in connection with an environmental permit, notification decision, or amendment thereto, where the matter involves other operational issues requiring modification of the environmental permit. In such cases:

When the municipal environmental protection authority is competent for granting the environmental permit, it will retain jurisdiction over by-products and EoW products
Where the municipal environmental protection authority is competent, a statement must be requested from the Permit and Supervisory Authority
The Permit and Supervisory Authority may revoke decisions under certain conditions

Timeline and Transitional Provisions

The proposal will be submitted to the Parliament and is intended to enter into force in 2027. Under the proposed transitional provisions, products currently covered by supervisory authority statements must obtain a classification decision by 31 December 2029. If no decision is obtained by this deadline, the existing classification will expire.

If you have any questions concerning this Legal Alert, please contact the undersigned.