BDE Federation of the German Waste, Water and Circular Economy Management Industry

As BDE - Federation of the German Waste, Water and Circular Economy Management Industry - we welcome the Commissions approach to make the European industry more competitive whilst driving forward decarbonisation. In our view, however, the contribution of the circular economy is not integrated sufficiently enough into this process by the legislative draft.

For specific feedback, we would like to refer to our position paper from the last Consultation in December. We welcome some adjustments that have been made in the delegated acts on climate (EU) 2021/2139 and environment (EU) 2023/2485, e.g. the focus on post-consumer waste in plastic manufacturing (3.17 Annex I Climate DA) but also note that some important changes have unfortunately not been considered.

The BDE Federation of the German Waste Management, Water and Circular Economy Management Industry values the EU Taxonomy system as an important contribution to the transition of the European industry towards a sustainable and circular economy.

The BDE Federation of the German Waste Management, Water and Circular Economy Management Industry values the EU Taxonomy system as an important contribution to the transition of the European industry towards a sustainable and circular economy.

The BDE Federation of the German Waste, Water and Circular Economy Management Industry welcomes the European Commission's proposal for a Directive on the substantiation and communication of explicit environmental claims (Green Claims Directive). Combating "greenwashing" is indispensable for strengthening consumer confidence in sustainable products and ensuring fair competition.

The Federation of the German Waste, Water and Circular Economy Management Industry (BDE) welcomes the Commission's initiative to establish a Biotech Act II and underlines the crucial role of waste-derived biomass for the European bioeconomy. Decoupling the European economy from fossil raw materials must not be built on the expanded cultivation of primary agricultural feedstocks for biotechnological processes.

For specific feedback, we would like to refer to our position paper from the last Consultation in December. We welcome some adjustments that have been made in the delegated acts on climate (EU) 2021/2139 and environment (EU) 2023/2485, e.g. the focus on post-consumer waste in plastic manufacturing (3.17 Annex I Climate DA) but also note that some important changes have unfortunately not been considered.

The BDE (Federation of the German Waste, Water and Circular Economy Management Industry) welcomes the European Commission's initiative to introduce an Advanced Materials Act. From the perspective of the recycling and waste management industry, it is crucial that, in conjunction with novel high-tech materials, advanced materials from existing recycling streams are also covered.

The BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V. (Federation of the German Waste, Water and Circular Economy Management Industry) was founded in 1961 and is the German industry association for the private recycling and resource management sector.

Today, private waste management companies and other actors within the circular economy are confronted with an uneven level playing field when it comes to the taxation of economic activities in relation to public enterprises and manufacturers of the primary industry. This applies in particular to an unequal treatment with regard to VAT compared to public waste management companies.

We as BDE agree with the list of priority waste streams for CRM recovery that the Commission has presented in the draft. However in our view, in order to guarantee an efficient implementation in Member States legislation, we think that the Implementing Regulation should have a binding effect on Member States and not only should serve as a reference for the scope of the national measures as stated in Recital 2.

The BDE as the Federation for the German Waste, Water and Circular Economy Management Industries welcomes the draft implementing act laying down minimum requirements for the public procurement of net-zero energy technologies and appreciates the opportunity to provide comments on the draft.

The Federation of the German Waste Management, Water and Circular Economy Management Industry (BDE) welcomes the European Commissions Call for evidence to review the ecodesign measures on electric motors and variable speed drives.