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AirClim’s response to the Energy Efficiency Directive (EED) roadmap The action taken in the next 10 years will determine if it will be possible to reach the 1.5°C objective. The EU's commitment to put energy efficiency first needs to be strengthened to enable this.

Deutsche Umwelthilfe (DUH) would like to stress that currently, the EED, like the other elements of the Clean Energy for All package, are inconsistent with the ambition of the Paris Agreement, as action in the next 10 years will be decisive in reaching the 1.5°C objective. We fully support the initiative to revise the EED and stresses that the ambition level needs to increase significantly.

Strengthening of the Energy Efficiency Directive DUH is calling for the adoption of a binding energy efficiency target of at least 45 % in the year 2030 (compared to the EU Reference Scenario 2007 or of at least 20 % in 2030 compared to the EU reference scenario 2020). This will help to achieve the 1.5°C target of the Paris Agreement, improve the energy security of the EU, create jobs, and reduce pollution.

Overall, AirClim strongly supported the adoption of ambitious measures to tackle the continuing problem of 'missing vehicles'. AirClim also supports stricter requirements on the export of used vehicles, to avoid used vehicles which are not roadworthy, generate air pollution and present health risks are exported from the EU to third countries.

DUH welcomes the EUs intention to ensure end-of-life vehicles (ELVs) are managed sustainably and re-quiring the car industry to adopt a sustainable design and production of cars as part of the Regulation on Circularity Requirements for Vehicle Design and on Management of End-of-Life Vehicles (VDEoL).

Deutsche Umwelthilfe e.V. (DUH), EU Transparency Register No 03506017714-81 The Deutsche Umwelthilfe e.V. (DUH) is grateful for the opportunity to comment. In substance, Deutsche Umwelthilfe e.V. strongly opposes the amendment of Annex III to the Nitrates Directive and calls on the European Commission to withdraw or revise the proposal.

Filed in German · English published by the European Commission

While there may be reasonable grounds for subjecting RENURE fertilisers to different regulations than untreated manure, it is perplexing why this change is being rushed through without a proper impact assessment and before the ongoing fitness check evaluation of the Nitrates Directive is completed. Moreover, it is unclear how this change facilitates achieving the overall objectives of the Nitrates Directive.