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.
BFG
BDE Federation of the German Waste, Water and Circular Economy Management Industry
Industry association · Germany · EU Transparency Register 015415038748-78
27
positions filed
in the 665 files tracked
22
legislative files
of 665 tracked
19
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1518 trade and business associations on this site, they rank #131 by legislative files engaged, a count of participation, not a measure of influence.
5.8
declared lobbying FTE
self-declared
€600K+
declared costs / yr (floor)
2
EP accreditations
as declared to the register
2020
in the register since
Declares membership of
- https://www.bde.de/verband/netzwerk/
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade and business associations
- Registered as
- BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V. (BDE)
- Head office
- Berlin, Germany
- EU office
- Bruxelles
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
BDE Federation of the German Waste, Water and Circular Economy Management Industry filed 27 positions between 8 Feb 2019 and 17 Jun 2026, across 22 of the 665 legislative files tracked here, attaching a full position paper 19 times.
2019 · 1 filed2020 · 1 filed2021 · 2 filed2022 · 2 filed2023 · 7 filed2024 · 1 filed2025 · 7 filed2026 · 6 filed
What they argued
The BDE Federal Association of German Waste Management, Water and Extractive Industries (BDE) is the strongest association of the German waste management, raw materials, recycling and water industries, with around 750 member companies, and represents numerous members who produce valuable renewable fuels or electrical energy from waste and thus actively contribute to climate protection and a functioning circular…
Filed in German · English published by the European Commission
BDE Federation of the German Waste, Water and Circular Economy Management Industry and VOEB Association of Austrian Waste Management Companies welcome the Commission's Proposal for a Regulation on Packaging and Packaging Waste as a committed step towards a comprehensive circular economy in Europe.
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.
30 June 2023 BDE Federation of the German Waste, Water and Circular Economy Management Industry Statement on the European Commission's proposal for a Critical Raw Materials Act (COM (2023) 160 final) BDE Brussels Office Rue de la Science 41 1040 Brussels Tel: [phone removed] [email removed] The BDE Federation of the German Waste, Water and Circular Economy Management Industry was founded in 1961 and is the…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
25 November 2025 BDE Feedback: Announcement of a Proposal for a CRMA The BDE welcomes the Commission's initiative for a Critical Raw Materials Act as ground-breaking. The problem regarding Europe's increased dependence on raw material exports from third countries with autocratic and undemocratic structures was already expounded about 20 years ago on German national level.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Please find attached the BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V. (Federation of the German Waste, Water and Circular Economy Management Industry)'s detailed feedback on the Revision of the Waste Framework Directive.
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.
The Federal Association of the German Waste Management, Water and Raw Materials Management Association (Bundesverband der Deutschen Entsorgungs-, Wasser- und Rohstoffwirtschaft e.V.) is grateful for the opportunity to provide feedback on the Commission’s proposal (Ref. Ares (2019) 10/01/2019 141469).
Filed in German · English published by the European Commission
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.
BDE Statement on the European Commission's Proposal for a "Net Zero Industry Act” The BDE Federation of the German Waste, Water and Circular Economy Management Industry was founded in 1961 and is the Industrial and Employers' Association of the circular and resource economy.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Since neither steel nor recycling in Europe can exist independently, BDE advocates a holistic approach to safeguarding the entire value chain. Trade measures must be differentiated. BDE rejects export restrictions such as export duties unless other regions impose them. In that case, the EU should consider comparable steps to ensure fair competition (level playing field).
Since neither steel nor recycling in Europe can exist independently, BDE advocates a holistic approach to safeguarding the entire value chain. Trade measures must be differentiated. BDE rejects export restrictions such as export dutiesunless other regions impose them. In that case, the EU should consider comparable steps to ensure fair competition (level playing field).
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 Deutsche Entsorgungs-, Wasser- und Materialwirtschaft e.V. is the largest association of German waste disposal, raw material, recycling and water management, with around 750 member companies. For BDE member companies, the Waste Shipment Regulation is one of the main building blocks for a successful circular economy.
Filed in German · English published by the European Commission
The BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Rohstoffwirt— schaft e.V. agrees on key points with the results of the impact assessment. A functioning market for secondary raw materials is essential for a functioning circular economy. Secondary raw materials must be able to move within the EU while respecting high standards without major bureaucratic hurdles.
Filed in German · English published by the European Commission
BDE Feedback: Commission Proposal Revision of the UWWTD As far as the BDE is concerned, the central regulatory contents of the Commission's proposal for the revision of the Urban Wastewater Directive concern the introduction of a so-called quaternary treatment stage, the introduction of an extended producer responsibility in the wastewater sector, the achievement of energy neutrality in the wastewater sector, the…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V. (Federation of the German Waste, Water and Circular Economy Management Industry) has composed a statement on the call for feedback on the rationalization of reporting burden, which can be found attached.
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.
Feedback on the Proposal for a Regulation amending Annex IV and V of the POP-Regulation The BDE fully supports the objectives of the European Commission to protect human health and the environment from harmful effects of persistent organic pollutants (POPs).
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.
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