Deutsche Umwelthilfe e.V.

The DUH welcomes the fact that, with the Green Claims Directive proposal (COM(2023) 166), the European Commission has launched comprehensive and cross-sectoral requirements for reconciling explicit and voluntary environmental claims.

Filed in German · English published by the European Commission

Deutsche Umwelthilfe (DUH) welcomes the European Commissions initiative to address CO2 mitigation regarding corporate vehicle fleets and recommends implementing a Clean Corporate Vehicles Regulation with a binding 100% BEV target in 2030 for corporate fleets.

The Renewable Energy Directive must serve as the foundation for the decarbonization of our energy system. The renewable Energy framework plays a crucial role in achieving the EUs climate targets and transitioning away from fossil fuels.

Environmental Action Germany (Deutsche Umwelthilfe e.V. DUH) is an independent environmental and consumer protection organisation committed to advancing waste prevention and promoting the efficient use of valuable resources within a circular economy. DUH welcomes the opportunity to provide feedback to the Call for Evidence on the evaluation of the Single-Use Plastics Directive (SUPD).

Statement by Deutsche Umwelthilfe on the Amendment of Regulation (EU) 2023/1115 with regard to the List of Relevant Commodities and Products Deutsche Umwelthilfe (DUH) supports a broad product scope that includes all major commodities associated with deforestation. A narrowing of the current scope would reduce the Regulations overall effectiveness and should be avoided. 1.

DUH acknowledges the general objective of simplifying and streamlining administrative requirements. In particular, we see potential in further advancing digitalization and in drafting regulations in a clearer and more precise manneran approach that should consistently guide legislative efforts.

We welcome the European Climate resilience and risk management initiative as an important step toward building resilience in the face of growing climate challenges. In this context, we see nature-based solutions as a key element for effective mitigation and adaptation.

Environmental Action Germany (Deutsche Umwelthilfe e.V. - DUH) welcomes the opportunity to provide feedback on the draft Implementing Decision laying down the rules for the calculation, verification, and reporting of recycled plastic content in single-use plastic beverage bottles.

Deutsche Umwelthilfe / Environmental Action Germany welcomes the opportunity to comment the EU Grid Package. We would like to draw attention to one specific concern: the role of electricity DSOs. While grid expansion and modernisation is indeed necessary at DSO level, it is time and money consuming.

The Arctic Ocean has so far been mostly protected from exploitation by its remoteness, sea ice and harsh conditions. The Nordic polar region is one of the areas most affected by climate change. The significant rise in temperature will have enormous impacts on people and nature in the Arctic. Changing landscapes and weather condition already open new economic opportunities and alter current ways of living.

Thank you for the opportunity to contribute to the consultation on the EU Strategy for Heating and Cooling. As a climate, environmental, and consumer protection organisation, we welcome the chance to provide input. Please find our detailed feedback attached.

Deutsche Umwelthilfe (DUH) strongly opposes any dilution or flexibilization of the EUs CO fleet regulation. These standards are essential to drive decarbonization in transport, and they must remain binding, rigorous, and free from loopholes. 1. Keep binding CO targets & trajectory: The 2030 and 2035 CO fleet targets must be maintained or strengthened.

The emission values and methodology of RED do not only dictate the criteria for national inventories but also underpin key decisions made by EU Member States and must therefore accurately reflect real-world climate impacts. In light of the climate crisis, assessments should adopt precautionary assumptions. Assumptions based on overly optimistic projections or omitting relevant emission sources must be avoided.

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

The EU should not allow the use of international carbon credits towards its 2040 climate target. Evidence consistently shows that such credits lack environmental integrity, with persistent issues of weak additionality, over-crediting, and conflicts of interest in verification. Their use risks undermining the EUs climate ambition and delaying necessary domestic emission reductions.

Many individual studies provide a gloomy picture of the state of Europe’s forests. The overwhelming majority of forests show medium to low ecosystem integrity, although at the same time the overall forest area is growing. In protected areas, according to the EEA, forestry is the biggest threat to protected habitats and species.

Filed in German · English published by the European Commission

Deutsche Umwelthilfe e.V. (DUH) essentially welcomes the proposal to revise the CMO. We particularly value the definition of fair, fair and short supply chains. Fair trade organisations should be closely involved in the process of implementing rules in order to avoid contradictions with well-established Fair Trade rules.

Filed in German · English published by the European Commission

Deutsche Umwelthilfe e.V. (DUH) essentially welcomes the proposals to revise the CMO. In our view, it is particularly welcome that the European Commission refers to the SDGs, which we have only a few years to achieve, but from which we are still far away. We are particularly important and well-assessed of the proposal to define the terms in fair, equitable or equivalent terms.

Filed in German · English published by the European Commission

DUH welcomes the Commissions draft act on the methodology for the calculation and verification of the carbon footprint of electric vehicle batteries. The most energy- and carbon-intensive part of battery manufacturing is the production chain of battery cells, responsible for as much as 75% of energy consumption.

We welcome the opportunity to provide feedback on the LULUCF Regulation. Most Member States, including Germany, are not on track to meet their LULUCF targets. As a result, the EU is currently missing its target of -310 million tonnes of CO2 emissions in 2030, according to official data. In recent years, carbon removal by ecosystems has been declining instead of increasing as planned.

Uniform labeling of the CO2 footprint can improve transparency regarding the environmental impact of batteries and provide consumers with a reliable basis for making sustainable purchasing decisions. At the same time, uniform labeling provides reuse operators, recyclers, and interested consumers with essential information on chemical composition, hazardous substances, and critical raw materials.

Deutsche Umwelthilfe would like to thank the European Commission for preparing this draft certification requirements in line with the F-Gase Regulation (EU) 2024/573, as well as for the possibility to comment. We see the enforcement of natural refrigerants instead of F-gases as an important milestone in achieving climate objectives while at the same time being environmentally friendly by avoiding regrettable…

Filed in German · English published by the European Commission

Deutsche Umwelthilfe e.V. (DUH) is grateful for the opportunity to comment on the mid-term review of the Common Agricultural Policy (CAP) 2023-2027. The DUH notes that, in its current funding period, the CAP does not sufficiently meet its own objectives or key societal expectations in the area of climate, environmental and animal welfare.

Filed in German · English published by the European Commission

We would like to support the draft Ecodesign and Energy Labelling regulations and particularly the new energy efficiency formulas, which are less linear and steep with capacity, thus avoiding the current encouragement to ever larger capacities. We also welcome the provisions to avoid programmes with too stretched durations, with a preference for the cap on duration in Ecodesign over indication on the energy label.

We welcome the opportunity to provide feedback on the draft implementing act setting annual GHG removal limits under the LULUCF Regulation for the period 20262029. Following up on this important pillar for carbon emission neutrality in the European Union is crucial. Setting the LULUCF target paths for 2026 to 2029 provides the necessary planning security and continuity for climate policy goals within this sector.

The Deutsche Umwelthilfe (DUH) opposes the proposal to remove Article 4(6)/(7) from the multi annual plans for the Baltic Sea, the North Sea and the Western Waters (hereafter the 5% rule). Moreover, DUH is concerned about the process of the proposal: There has been no public consultation before the presentation of the proposal, and no thorough impact assessment has been conducted to date.

DUH welcomes the initiative to review ecodesign and energy labelling requirements for electronic displays as this has the potential to decrease electronic waste and to set a new European standard when it comes to sustainability of devices. Up to 80 % of the environmental impact of those products is determined at the design phase.