The mining industry asks the government to postpone new waste requirements

The National Association of Extractive Industries of Ukraine (NAEIU) has appealed to the Cabinet of Ministers to eliminate legal conflicts in the field of waste management in the extractive industry and to introduce a transition period for obtaining the relevant permits. The reason for this was the renewal, effective December 16, 2025, of the Procedure for Issuing Permits for Waste Treatment Operations for Extractive Waste without any adaptation period for enterprises. This is stated in the relevant letter dated January 26, 2025.

The association recalls that after the adoption of the Law “On Waste Management” in 2022, the government approved the procedure for obtaining permits, but in August 2024, extractive waste was excluded from its scope. The adoption of a separate law on waste management in the extractive industry was expected, but the relevant bill was not supported by parliament in 2025. Despite this, in December 2025, the Cabinet of Ministers re-extended the Procedure to the extractive industry.

As a result, companies found themselves in a situation where they risked being held liable for not having permits, which are physically impossible to obtain quickly without going through an environmental impact assessment procedure. NAEIU warns that this creates a threat of complications or even a halt to the work of mining companies.

The association proposes to temporarily reinstate the provision on the non-application of the Procedure to waste from the extractive industry until a special law is adopted, as well as to introduce a transition period of at least one and a half years. According to the industry, this will allow companies to go through all the necessary procedures without the risk of sanctions and will maintain the stability of subsoil use, which provides jobs, the raw material base of the economy, and budget revenues.

It should be noted that at the end of 2021, the Cabinet of Ministers approved a bill on the creation of a National Register of Industrial Emissions and Pollutant Transfers.

Earlier, the Cabinet of Ministers approved Ukraine’s updated nationally determined contribution under the Paris Agreement (NDC-2). The document provides for a 65% reduction in greenhouse gas emissions by 2030, to 35% of 1990 levels. To achieve this, Ukraine will need annual funding of about $10 billion.

In June 2022, the Verkhovna Rada adopted in the second reading and as a whole draft law No. 2207-1-d “On Waste Management.”