Updated Environmental Improvement Plan Published

In an early Christmas present to regulators and businesses alike, the Government published its updated Environmental Improvement Plan on 1 December 2025. 

The EIP sets targets which the Government will use to (i) ensure England is on track to deliver the targets and objectives set out in the Environment Act 2021 and (ii) drive progress towards 10 goals which will ultimately contribute towards its ‘apex goal’ of restored nature.  In order to focus minds, the EIP is formatted into four key chapters: 

• environmental quality;
• environmental security;
• access to nature; and
• circular economy, 

all of which feed into the central target of restored nature. 

The latest update to the EIP follows the Government’s Annual Progress Report which was published in July which assessed the progress that had been made against the 10 goals set out in the previous iteration of the EIP which was published in 2023. The Report indicated that some significant progress had been made in certain key areas such as mitigating land adapting to climate change, and managing exposure to chemicals and pesticides, however progress against some goals, such as the sustainable use of natural resources and thriving plants and wildlife had experienced deterioration. 

The Annual Progress Report followed a fairly bleak assessment from the Office for Environmental Protection (OEP) in relation to the progress made between 2023 – 2024, which noted that “while there have been some areas of improvement, very substantial challenges remain with less progress being made overall compared to the previous 12 months. Government is still largely off track to achieve obligations endorsed by Parliament to significantly improve the natural environment.”

It is in this context that the current Government has sought to refresh and reframe the EIP. 

Key updates 

The latest EIP refreshes a number of the targets which underpin progress towards the EIP’s 10 goals and seeks to draw together a number of different threads across the spectrum of environmental law.

We are still digesting the detail of the EIP and its practical application, but some of the key updates include: 

Nature Recovery 

• there is an updated interim target to restore or create a total of 250,000 hectares of a range of wildlife-rich habitats outside of protected sites by December 2030 (this has been increased from 140,000 hectares by 2028, compared to 2022 levels);
• the target to have an up-to-date condition assessment in place for all Sites of Special Scientific Interest by the end of January 2028 has been removed, and the target for 50% of SSSIs to have actions on track to achieve favourable condition by 31 January 2028 has been pushed back to December 2030;
• a reduced target in relation to the increase of England’s tree canopy and woodland cover – previously the target was a 2.1% increase by 2050, with an interim target to increase this by 0.26% by 31 January 2028.  The new targets are an increase of 0.33% of land area by December 2030 and the 2050 target appears to have been dropped.

Chemicals 

• the long-awaited Chemicals Strategy (which was previously a target in the 2023 EIP) has been shelved. This follows confirmation from DEFRA earlier in the year that the Strategy would not be brought forward but that other plans would be introduced instead;
• a PFAS Plan will be introduced in 2026, which will “set out a range of regulatory and non-regulatory interventions, measures and initiatives with specific actions and delivery milestones”.  This represents a greater focus on PFAS than was proposed in HSE’s current REACH Work Programme and suggests that a stronger regulatory approach to PFAS may be developed in due course. For further background on the current approach to PFAS, take a look at our article on PFAS as an emerging environmental risk here or listen to our podcast episode on the environmental impact and regulation of PFAS;
• the commitments around using UK REACH have been replaced with a commitment to reform UK REACH “to enable protections that address chemical pollution to be applied more quickly, efficiently and in a way that is more aligned with our closest trading partners, especially the EU, by December 2028”, which is likely to be good news for businesses operating across both territories. However, many of the other REACH commitments reflect activities which the Government has already undertaken or which are currently in progress;
• the focus on polychlorinated biphenyls (PCBs) has been replaced with a focus on mercury and other persistent organic pollutants (POPs).  Domestic legislation will be introduced by the end of this year to restrict the manufacture, import and export of additional mercury added products pursuant to the Minamata Convention on Mercury.

Water 

• the interim target to reduce phosphorus loadings from treated wastewater by 50% by the end of January 2028 has been pushed back to a 55% reduction by 2030;
• a new commitment to modernise the abstraction licensing system, including moving it into the Environmental Permitting Regulations (EPR) has been included (albeit it is notable that changes to abstraction licensing have been discussed for a number of years);
• new water efficiency and sustainability targets around the use of water by the public, in households and outside of households have been included;
• a new commitment to review the regulatory framework for sewage sludge spreading to agricultural land to ensure it effectively manages the risks to the environment and health has been included. Further details of the expected updates to the water sector can be found in our summary of the Cunliffe Review’s final report.

Waste 

• a number of the waste interim targets (which were originally due by 31 January 2028) have been retained, but pushed back to 2030, such as: 

  • the target to reduce residual waste (excluding major mineral waste) produced per person by 24%;

  • the target to reduce residual municipal plastic waste produced per person by 45%; and 

  • the target to reduce residual municipal metal waste produced per person by 42%;

• the implementation of a Deposit Return Scheme for plastic and metal drinks containers has been retained but pushed back from October 2025 to October 2027 (please refer to our previous update on the DRS here);

• a new goal has been introduced to implement the Design for Life roadmap, which aims to transition the medtech sector away from single use products and towards a circular economy;

• the target to eliminate waste crime has been retained, but supporting actions have been fleshed out (many of which have been previously publicised), including: 

  • removing certain permit exemptions and tightening several others, banning the ability for operators to use multiple exemptions on a single site or on sites with a permit, and introducing record-keeping requirements; and 

  • reforming the carriers, brokers and dealers regulations by transitioning these obligations into the environmental permitting regime;

• a new commitment to publish the Circular Economy Growth Plan in ‘early 2026’ has been introduced – we understand that this is the new name of the ‘Circular Economy Strategy’ currently being prepared by the Circular Economy Taskforce

Looking ahead

There are some interesting new targets and commitments within the revised EIP which, if implemented, may make the post-Brexit environmental regulatory landscape more efficient for businesses to operate within and provide greater progress towards the targets set out in the Environment Act.  However, there is limited detail in respect of how many of the commitments within the EIP will be delivered (and when) and so it remains to be seen (i) if these commitments will be delivered and (ii) how effective they may be in helping England meet its Environment Act targets. As a result, an assessment of the implications for compliance is difficult to make.

In light of the proposals set out in the EIP and wider regulatory reforms which are on the cards, it is clear that environmental regulation in England and the wider UK is entering a period of flux.  As a result, it will be important for businesses to keep apprised of the various changes as they come through.  In the new year, we will outline what businesses should expect in 2026 and beyond – keep a look out for updates on the Burges Salmon blog and for the launch of Season 3 of our Environment Matters podcast soon.  In the meantime, if you would like more information on any of the updates set out in this article or any associated environmental issues, please contact the Burges Salmon Environment Team via our website. 

Written by Helena Sewell

Achieving our environmental ambitions requires collective action from individuals, communities, and organisations across all sectors. We will work in partnership to achieve them.

https://www.gov.uk/government/publications/environmental-improvement-plan-2025/environmental-improvement-plan-eip-2025