The increase of environmental fees is not related to the proven size of the resulting environmental impact

The Ministry of Climate has prepared a draft, which establishes new pollution fee rates for the discharge of pollutants into the outside air, water body, groundwater, and soil, as well as the disposal of hazardous waste and oil shale waste. The Chamber saw several problems with the planned draft and proposed to abandon the increase of environmental fees in 2024.  

In Camber's opinion, urgent processing of the draft is not justified 
The draft is processed as urgent, but according to the Chamber, the urgency of the draft is not justified, as it could not come as a surprise to the Ministry of Climate that the pollution fees raised by the draft have remained unchanged for a long time. In addition, there is no impact analysis or corresponding study that would justify increasing the environmental fees in the draft by specific amounts. According to the Chamber of Commerce, the amounts of environmental fees should be related to the proven size of the resulting environmental impact. In this situation, the reasons given in the explanatory letter of the draft show that the purpose of the changes is primarily to increase the state budget and not to fulfil environmental goals. 

According to the Chamber, the affected companies have not been essentially involved in the development of the environmental fees, and the draft was presented to the affected companies unexpectedly. Such situation creates a situation where, in the future, the state may also begin to set environmental fees arbitrarily, based on state budgetary needs and without consulting market participants, and without assessing the actual impact of companies' activities on the environment. Since the draft affects the cost base of companies in a long-time frame, the Chamber proposed to abandon the increase of environmental fees in 2024 and to develop a justified and long-term system of environmental fees in cooperation with the affected companies in the first half of 2024, which will be implemented from 2025. 

Environmental fees must flow to where pollution occurs  
According to the explanatory note of the draft, the main purpose of raising environmental fees is to increase the state budget. The Chamber considers that, taking into account the "polluter pays" principle, the sums resulting from the received environmental fees should also go to the region and to those local governments where the given pollution took place. Higher environmental fees must compensate for the damage caused, not increase the state budget.  

Fee rates must be established in the long term 
The new environmental fee rates are set to gradually increase from 2024 to 2027. The Chamber is of the opinion that new environmental fees for a short period do not provide companies with the necessary predictability to make new investments, as both the reduction of pollutants and other environmental changes require big investments from companies to introduce new technologies. We are of the opinion that in order to ensure greater stability and investment security for entrepreneurs, the fee rates established by the draft must remain unchanged at least until 2035. 

The changes will take effect on July 1, 2024. 

More information about the planned changes can be found HERE.