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The EEB welcomes the Commissions' objective to revise the ELV Directive, aiming at achieving reductions of negative social, economic and environmental impacts of the sector, and equally important to bring the sector closer to the approach of circular economy.

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.

Motor vehicles constitute a significant repository of valuable materials. This makes the automotive industry a pivotal player in saving resources and curbing carbon emissions through circular economy practices. In this context, the EEB welcomes the proposal for a Regulation on Vehicle Design and End of Life Management (VDEoL), notably: The extension of the scope to cover vehicles beyond passenger cars Requirements…

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.

The EEB would like to express its deep concern regarding the Commissions draft act for a Directive to amend Annex III of the Nitrates Directive. The proposal would allow the application of fertiliser products recovered from manure (up to 100 kg N per hectare and year) above the current legal threshold of 170 kg N per hectare and year set for livestock manure.

We welcome the goal to halve nutrient losses. It will have great benefits through improved air quality, improved water quality, biodiversity and reduced N2O emissions. Halving NH3 emissions alone would bring health benefits that would outweigh the costs for reducing emissions(1). In the Farm to Fork strategy, a reduction of fertilizer use by 20 % by 2030 is mentioned.

EEB welcomes the initiative for an EU action plan for integrated nutrient management (INMAP). The war in Ukraine has highlighted the EU’s dependency on imports of fertiliser and livestock feed, but even though our current food system is relying on limited raw materials and fossil gas, we are using these resources in a wasteful way with huge losses from field to plate.