2022/0105(COD) · In Force
42 submissions from 36 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 55 submissions on this file. Shown here: the 42 from organizations. Not shown: 8 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 5 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →
33 submissions from industry — companies and their trade associations — against 9 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 3.7 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
Self-declared to the EU Transparency Register (snapshot 14 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 27 Jun 2022 — it ran from 8 Apr 2022.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned.
Showing 25 of 42 submissions.
Contribution from FNSEA, French majority agricultural union The Fédération Nationale des Syndicats d’Exploitants Agricole (FNSEA), the leading French agricultural union, which brings together all the products of all the regions, makes the following observation: — The obligation to monitor emissions and the levels of environmental performance associated with farming rules, recording and processing the results to be…
Filed in French · English published by the European Commission
· · filed 27 Jun 2022 · source
The Finnish Forest Industries Federation (FIFF) supports transparency and availability of environmental information. According to an impact assessment the existing European Pollutant Release and Transfer Register (E-PRTR) has proven to be a pivotal knowledge base on emissions from EU industrial activities. It gives the public access to high-quality data, thereby supporting environmental decision-making.
EEB input to the public consultation on Proposal for a regulation - COM(2022)157 - Industrial Emissions Portal Regulation The EEB is the largest federation of EU citizens organizations & has been involved in following the regulation on industrial emissions (the Sevilla BREF process, the IPPC Directive and Industrial Emissions Directive), including the Regulations for reporting the pollution releases and transfers…
FNADE’s Position on reporting of environmental data from industrial installations and establishing an Industrial Emissions Portal (E-pRTR) June 2022 FNADE, the French association for waste management and environmental services welcomes the proposal of the European Commission for the Revision of the E-pRTR (European reporting data from industrial installations and establishing an industrial emissions portal).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Pollutant Release and Transfer Register E-PRTR (166/2006/EU) provides the framework for the reporting of large industrial emissions since 2006. An evaluation carried out by DG ENV showed that it is efficient, fit for purpose and has achieved its goals to a large degree. It has been reviewed and is intended for replacement via the new Industrial Emission Portal IEP by January 1, 2026.
Návrh nařízení o ohlašování environmentálních údajů průmyslovými zařízeními a o zřízení portálu průmyslových emisí – připomínky Hospodářské komory ČR Hospodářská komora ČR vítá příležitost vyjádřit se k aktualizovaným pravidlům týkajících se evropského registru úniků a přenosů znečišťujících látek.
Filed in Czech · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 23 Jun 2022 · source
Glass Alliance Europe is the European Alliance of Glass Industries. It has the unique feature of regrouping all the glass industries to work on common issues. It is composed of 14 national glass associations and of the 5 main sectors of the glass industries: container glass, flat glass, special glass, domestic glass and continuous filament glass fibres.
The Federal Association of the German Glass Industry (BV Glas) is a central point of contact for everything glass related. One of its most important functions is to provide key information about the German glass industry and about glass as a material not only to industrial users and decision-makers, but also the craft and retail trades, opinion leaders in the fields of science, research, politics and media, as well…
The steel industry in Germany promotes the objectives and contents of the existing Industrial Emissions Directive (IED) with its ambitious and clear rules for the permitting and operation of industrial installations.
• The proposal means that all Swedish farms with animals, including very small farms, will be counted as industry. • The proposal is based on incorrect/doubtful conditions. The Basel situation for current emissions is too poor because it is assumed that all those not covered by the IED currently do not have requirements or measures against ammonia losses, which is not the case.
Filed in Swedish · English published by the European Commission
Feedback to the Revision of the Regulation on the European Pollutant Release and Transfer Register (E-PRTR) FNADE, the French waste management and environmental services private companies’ association, welcomes the revision of the E-PRTR.
The European Lime Association (EuLA) welcomes the opportunity to provide its feedback to the European Commission on the inception impact assessment, Regulation EC 166/2006. It is only through these assessments that regulations, such as the European Pollutant Release and Transfer Register, can be designed fit-for-purpose.
· · filed 26 Oct 2020 · source
Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental non-governmental organization in Finland. We warmly welcome the E-PRTR and this work to develop it. This reporting system can help us to achieve EU environmental targets, SDGs etc. This type of reporting and monitoring is essential in this work.
Zero Waste Alliance Ireland (ZWAI), established in 1999, is a Non-Government Environmental Organisation (eNGO). ZWAI has prepared and submitted to the Irish Government and to State Agencies many policy documents on waste management, and continues to lobby Government on the issue of using resources more sustainably, and on the implementation of the Circular Economy.
· · filed 26 Oct 2020 · source
Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on inception impact assessment (IIA) of the Revision of the Regulation on the European Pollutant Release and Transfer Register (E-PRTR). AHD CR sees E-PRTR as efficient instrument to collect data from industrial activities covered by relevant legislation, especially Industrial Emission Directive (IED).
Cefic supports the European Commission aim of a revision of the Regulation on the European Pollutant Release and Transfer Register (E-PRTR). Annex I of it lists 20 chemical sectors being in scope of this directive, and close to 3,000 chemical installations are reporting under E-PRTR, making the chemical industry one of most important stakeholders of this directive.
EurEau represents both drinking water and waste water service providers from 29 countries in Europe. The protection of drinking water resources is one of our major concerns and the E-PRTR should be a key contributor to it. We support the revision of the E-PRTR to better empower EU citizens with environmental data.
EUROFER welcomes the opportunity to provide its feedback to the ongoing review of the E-PRTR Regulation. EUROFER considers the E-PRTR Regulation a valuable source of reported emissions of a given pollutant over time and appreciates the effort carried out by the European Commission to improve the reporting rules. Please find attached three key issues EUROFER believes should be carefully considered during this review.
The Spanish Steel Association, UNESID, in representation of the Spanish Steel Industry welcomes the opportunity to give feedback on the Inception Impact Assessment of the European Pollutant Release and Transfer Register (E-PRTR).
The Industrial Minerals Association-Europe (IMA-Europe) welcomes the opportunity to provide its feedback to the European Commission on the inception impact assessment, Regulation EC 166/2006. It is only through these assessments that regulations, such as the European Pollutant Release and Transfer Register, can be designed fit-for-purpose.
Europe’s non-ferrous-metals industry is committed to continually improve its production performance to prevent, control, reduce and as far as possible eliminate its pollution to the environment. We welcome the opportunity to provide feedback on the Inception Impact Assessment to the Revision of the Regulation on the European Pollutant Release and Transfer Register (E-PRTR) and would like to share several…
EUCOPRO ASBL Rue Vilain XIIII, 53-55 B-1000 Brussels Phone: [phone removed] Fax : [phone removed] EUCOPRO Interest Representative Identification number: 75111426376-95 26 October 2020 Revision of the Regulation on the European Pollutant Release and Transfer Register (E-PRTR) Inception Impact Assessment Eucopro comments Eucopro – the European Association for Co-processing regroups waste pre-treatment companies…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
BV Glas is the Federal Association of the German Glass Industry. We welcome the opportunity to give feedback to the revision oft he E-PRTR at this early stage. The reporting modalities are of huge practical relevance and our members informed us about problems and inconsistencies on this field.
The Portuguese Pulp and Paper Association (CELPA) welcomes the Inception Impact Assessment on the revision of the Regulation on the European Pollutant Release and Transfer Register (E-PRTR). We, in the paper industry, are firmly convinced that, with the help of the new European Green Deal, we can reduce our impact on climate change while increasing production in Europe.
EURACOAL cautiously welcomes the European Green Deal’s proposed zero-pollution ambition for air, water and soil, noting however that to reach zero may entail costs tending towards infinity. The European Pollutant Release and Transfer Register (E-PRTR) holds emission data for 91 pollutants at around 30 000 industrial facilities, including annual mass releases (and transfers) to air, water and land.
· · filed 26 Oct 2020 · source
Today, data are provided in a wide range of areas, both at national and EU level, such as ifm. NEC, EUROSTAT, climate data, etc. An essential element of the evaluation should therefore take into account the fact that a wide range of requested data can be found in more or less detailed data in other registers.
Filed in Danish · English published by the European Commission
The establishment of the European Pollutant Release and Transfer Register (E-PRTR) aims to facilitate public access to information on global environmental issues through an appropriate environmental information system.
Spanish Cement Association (OFICEMEN), welcomes the opportunity to comment on Inception Impact Assessments about the Revision of the Regulation on the European Pollutant Release and Transfer Register (E-PRTR). OFICEMEN is determined to contribute strongly to the EU’s vision for a carbon neutral society by 2050 and support the objectives of the European Green Deal.
[Full statement in PDF attached] CEWEP believes that IED provisions are a fundamental step forward for the reduction and elimination of pollutants arising from industrial activities. The pillars of the IED, in particular the integrated approach, the use of best available techniques and the public emission reporting are key for achieving results in terms of environmental performance of the plants.
CEMBUREAU, the European Cement Association (www.cembureau.eu), takes note of the Inception Impact Assessment and the opportunity to provide feedback to the European Pollutant Release and Transfer Register (E-PRTR) rules update. CEMBUREAU firmly supports the objectives of the European Green Deal and is determined to contribute strongly to the EU’s vision for a carbon neutral society by 2050.
Swedwatch welcomes the initiatives of the European Commission to improve the regulation on the European Pollutant Release and Transfer Register (E-PRTR) as a mean to empower EU citizens with access to environmental data to make informed decisions on environmental matters.
The VCI represents the politico-economic interests of around 1,700 German chemi-cal companies and German subsidiaries of foreign businesses. In 2019 the German chemical industry realised sales of over 198 billion euros and employed around 464,000 staff. Therefore, we welcome the impact assessment.
· · filed 23 Oct 2020 · source
First of all, HWE would like to underline the usefulness of the E-PRTR. There is a great merit for all parties in having a EU wide system for reporting pollutants emissions and waste generation. Yet, as suggested by the IAA of the Commission, there are areas for improvements, e.g.
· · filed 23 Oct 2020 · source
The Austrian Economic Chamber sees the PRTR revision as a unique opportunity to make EU environmental reporting obligations more meaningful and more targeted: • Yes to “improving coherence with related legislation in particular IED, water and waste legislation” in the sense of “data once only” and uniform, simple and harmonised EU standards for reporting obligations.
Filed in German · English published by the European Commission
· · filed 23 Oct 2020 · source
Health Care Without Harm (HCWH) Europe welcomes the opportunity to comment on the European Commission’s inception impact assessment on the European Pollutant Release and Transfer Register (E-PRTR) that aims to help achieve the objectives of the European Green Deal on biodiversity, circular economy, climate neutrality, and zero pollution.
The European Environmental Bureau (EEB) has already concluded in the previous 2015 REFIT that a fundamental overhaul of the E-PRTR and its parent PRTR UNECE protocol are necessary, we welcome the review initiative is finally going forward. We disagree with the statement that ‘in general, the overall structure of the E-PRTR appears to function well’.
FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the revision of the Industrial pollution – European Pollutant Release and Transfer Register as an initiative part of the European Green Deal, the new Circular Economy Action Plan and the recently published Commission Staff Working Document Evaluation of…
The European Panel Federation (EPF), welcomes the Inception Impact Assessment on the revision of the Regulation on the European Pollutant Release and Transfer Register (E-PRTR). The wood-based panels industry believes that all industrial sectors should contribute, in line with the Industrial Emissions Directive (IED), to ensure better control and reduce the impact of industrial emissions on the environment and on…
· · filed 18 Oct 2020 · source
ESPP (European Sustainable Phosphorus Platform) considers that the E PRTR is an important and effective tool for ensuring public access and transparency of environmental data. ESPP welcomes the Roadmap proposal to improve the contribution of E PRTR to Circular Economy objectives by including data on resource consumption.
· · filed 29 Sept 2020 · source
Dear European Commission, Dear Lady/Sir, We have read the text of the Initiative and we draw your attention to the following. It is expedient to take into account the existing Global and European environmental protection rules and regulations. To take into account their logic. The area of expertise of this Initiative is environmental protection and within that pollutant.
It is good that emissions from all Member States are recorded at European level and that these data are publicly available. In NL we found, inter alia through the work of the Committee, that methodologies suggest accuracy of methodologies and that the detail level of policy choices does not reflect the accuracy of the emission data.
Filed in Dutch · English published by the European Commission
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.