Bond Beter Leefmilieu wishes to express its concern regarding the gap between what the Circular Economy Act aims to achieve and what it proposes in terms of objectives and policy options. The problems the Act aims to tackle are defined as reducing our dependency on imported raw materials and increasing our resource efficiency, to reduce economic risk and ecological pressures.
BBL
Bond Beter Leefmilieu
Environmental organization · Belgium
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
5
positions filed
in the 665 files tracked
5
legislative files
of 665 tracked
1
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.
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Their record over time
Bond Beter Leefmilieu filed 5 positions between 24 Nov 2020 and 6 Nov 2025, across 5 of the 665 legislative files tracked here, attaching a full position paper 1 time.
2020 · 1 filed2023 · 1 filed2024 · 1 filed2025 · 2 filed
What they argued
Bond Beter Leefmilieu strongly calls for a Clean Corporate Vehicles Regulation with binding ZEV targets for large companies. The successful electrification of the corporate fleet in Belgium clearly demonstrates how regulation of the corporate market is ideal to boost electrification of fleets, with spillover effects towards the private market (e.g. expansion of charging infrastructure, electric second hand cars).
We strongly recommend that municipal waste (MSW) incineration is included in the upcoming review of the EU ETS. Evidence shows that municipal waste incineration has a growing negative impact on climate, yet because they are not part of the EU-ETS or any similar scheme to progressively reduce CO2 emissions, these incinerators are not compensating for the resulting climate damage.
Feedback by Bond Beter Leefmilieu (Flemish Umbrella organisation of Environmental Organisations) on the ECs initiative to revise the rules regarding the application of fertiliser products recovered from manure in the Nitrates Dir. We do not agree with the lack of proper assessment during the preparation phase and pre-empting the results of the ongoing fitness check evaluation of the Nitrates Dir.
A CO 2 target of -90% might seem close enough to full decarbonisation at first sight. But due to a number of shortcomings, the proposal would only reduce emissions from HDVs by 56% until 2050 (against 1990 levels). This both fails the EUs climate ambitions and Europes chance to retain its industrial leadership of the sector.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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