Bund für Umwelt und Naturschutz

In the Annex: Federal Government’s opinion on the revision of the EU public procurement directives: Directive 2014/23/EU on the award of concession contracts; Directive 2014/24/EU on public procurement; Directive 2014/25/EU on the procurement procedures of entities operating in the water, energy, transport and postal services sectors.

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The BUND represents more than half a million members and warmly welcomes this initiative. In principle, the use of resources must be significantly reduced. The current Waste Framework Directive does not take sufficient account of overall consumption or resource conservation aspects.

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The latest IPCC AR6 report that came out in March now made it very clear. We are far away from being on track to solving the accelerating climate crisis. Emissions need to go down as fast as possible. Climate finance need to increase to at least 3-6 times more. The era of fossil fuels and fossil fuels subsidies must end.

Eingabe BUND eV zur „Sustainable products initiative“ 22.06.2022 Als Umweltverband beschäftigt sich der BUND neben Umweltschutz auch mit Verbraucher*innenschutz. Mit der ToxFox App, welche Schadstoffe in Produkten (Kosmetik und REACH Art.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As an environmental association, we would like to draw your attention to the following opinions: A legal opinion by Dr Georg Buchholz concludes that the Commission’s proposal is contrary to the precautionary principle to such an extent that the regulatory discretion of the EU legislature would be exceeded if it were to adopt the proposal in this way: If the EU legislature were to adopt the regulation as proposed by…

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BUND strongly supports the objective of the European Ocean Act to improve coherence, coordination and effectiveness of EU ocean governance. However, the Act can only succeed if it unambiguously strengthens existing EU marine environmental legislation and puts ocean health at the centre of all maritime activities.

Friends of the Earth Germany (BUND) welcomes the possibility to comment on the IIA REACH revision. Regularly performing product testing to check for REACH compliance and encouraging consumers to use their right to know (Article 33), BUND sees the urgency for action, regarding enforcement of REACH compliance and revising Article 33. Please see our further remarks in attached document.

The Marine Protection Office of BUND welcomes the EU initiative to strengthen Member States resilience to climate change through an integrated framework. The ocean is vital for storing CO and heat and stabilizing climate, coasts, economies and health, yet it is severely threatened by climate change.

We, the Federation for the Environment and Nature Conservation, a German NGO with more than half a million members, warmly welcome the initiative. It is very urgent to regulate the millions of tonnes of microplastics that enter the environment every year in the EU. There is evidence that microplastics also enter the blood of people, to the most remote places in the world and are already detectable everywhere.

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The Federation for the Environment and Nature Conservation (BUND) welcomes the possibility to provide feedback on the draft Implementing Decision on the calculation, verification and reporting of the content of recycled plastic in single-use plastic beverage bottles. We represent more than 650.000 members and donors.

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We are a German nature conservation organisation and represent around 700.000 members. Together with other NGOs, we share feedback as an alliance Exit Plastic. At this point we want to once again, as an association, to criticise the concept of mass balancing as such. In our view, there is a risk to the protection of resources, so as to protect climate change and, in particular, to transparency for consumers.

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As a an environmental organisation with over 500.000 members in Germany, BUND strongly opposes the plans of de-risking and deregulating CO2-transport infrastructure in the EU, Instead of gambling on CCS, the EU must phase out all fossil fuels, fully and fast. +++Together with more than 100 organizations, experts, companies and citizens' initiatives we have expressed opposition to the German CO2 infrastructure law.

BUND - Bund für Umwelt und Naturschutz Deutschland (Friends of the Earth Germany) is an independent, federal NGO that has been dedicated to protecting nature and the environment since the mid-1970s. With over 674,000 members and supporters, 16 state organizations and 2,300 local and regional groups, BUND is one of the largest environmental associations in Germany today.

In principle, the Bund für Umwelt und Naturschutz Deutschland e.V. (BUND) welcomes the Commission’s proposals for stricter rules on pollutants in the air, surface water and groundwater and on the treatment of urban waste water. We see the proposals as an important step towards the zero-pollution ambition of the European Green Deal, i.e. a toxic-free environment by 2050.

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The association of European small-scale fishers, Seas At Risk, Bund für Umwelt und Naturschutz Deutschland and 12 other alliance partners published a vision for fisheries in Europe in 2025. Rethinking fisheries: A vision for fair and environmentally friendly fisheries in Europe has been developed in a bottom-up process for two years.

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The draft act amending Annex III to the Nitrates Directive (Nitrates Directive) provides for the increase of permitted fertiliser inputs of 170 kg N/ha per year, with a separate additional limit of 100 kg N/ha per year. As a voluntary-led association of members, the BUND points out that the text discussed has not been translated into EU languages. The participation of interested bodies is therefore very limited.

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Bund für Umwelt und Naturschutz Deutschland (BUND) welcomes the revision of the Marine Strategy Framework Directive (MSFD) as a crucial opportunity to safeguard Europes marine biodiversity and restore ocean health.

BUND (FoE Germany) welcomes the Commission's initiative to implement the principle of 'one substance - one assessment' that was declared in the ‘Chemicals Strategy for Sustainability’ within the framework of an omnibus regulation. Currently, the different legal provisions often lead to duplication of work and to different results and risk management measures.

In principle, the BUND welcomes the proposals for stricter rules on air, surface and groundwater pollutants, also as an important step towards the zero-pollution ambition of the European Green Deal, i.e. a toxic-free environment by 2050. A. The following points are particularly worth supporting: A1.

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Fusion energy is neither clean nor short-term or medium-term available in terms of resource use, energy needs, investment commitment and environmental impact. Accordingly, fusion is not a means against earth heating. For six decades, science has not been able to solve the technical difficulties associated with fusion and it appears that the list of problems is becoming longer than shorter.

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While welcoming the opportunity to provide feedback on the proposal to postpone the adoption of sector-specific European Sustainability Reporting Standards (ESRS), Bund für Umwelt und Naturschutz Deutschland e.V. (BUND) is deeply concerned about its wider implications. Please find our full response in the document attached.

The objective of Article 9 SUPD is the seperate collection of plastic bottles in order to ensure that they don’t end up littered in the environment. Putting an end to littering of SUP products is one of the main parts of the Plastic Strategy’s vision.

1. Low-threshold participation opportunities for civil society environmental associations The ERDF is a valuable funding instrument in Germany for nature-based climate change mitigation/adaptation, nature conservation and biodiversity protection. In the past, for example, blue green infrastructure or bog rewetting projects have already been financed by the ERDF (e.g.

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BUND strongly opposes the removal of the 5% rule from the multi annual plans for the Baltic Sea, the North Sea and the Western Waters. In addition to the rejection of the substantive justification of the proposal, BUND would like to express serious concerns about the process through which this proposal has gone through. We strongly disapprove the rushed and flawed procedure.