Deutsche Umwelthilfe e.V.

Environmental Action Germany (DUH) notes that the RED has over the past 10 years stimulated the use of climate- and environmentally-damaging biofuels in the transport sector and biomass in electricity and heat generation, thus contributing to higher GHG emissions, biodiversity loss and deforestation.

To reach the Paris Agreement objective of limiting global warming to 1.5°C, EU Member States need to phase out fossil fuels and transition to a 100% renewables-based energy system by 2040. The current 2030 EU RES target of 27% is not in line with this effort.

Environmental Action Germany (DUH) welcomes the revision proposal for the Directive on packaging and packaging waste (94/62/EC), which has been in force since 1994, and its conversion into a Regulation, as an important step towards true and sustainable change in the packaging industry.

Improving the essential requirements of packaging placed on the EU market to ensure that plastic packaging is reusable or recyclable is crucial to reduce the packaging waste created in the EU. We therefore warmly welcome the Commission’s initiative to assess the expected impacts of the adapted essential requirements for packaging.

The German Environmental Aid (DUH) considers that the Critical Raw Materials Act (CRMA) must enable a reliable supply of raw materials with the materials needed for decarbonisation and green transformation. The CRMA aims to ensure that resource needs are minimised as much as possible and that raw material extraction and processing are carried out in the least environmentally and socially burdensome way.

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Environmental Action Germany (Deutsche Umwelthilfe) welcomes the proposed recast of the EPBD, which is a pivotal element of the Fit for 55 Package. We believe that with the current proposal, the European Commission has made a step in the right direction by including some important elements, such as mandatory minimum energy performance standards or considering a life-cycle approach.

Doubling the renovation rate is key for Europe to reach its increased climate targets, to kickstart a green recovery and to provide healthy and comfortable places to live and work. We therefore strongly endorse the Renovation Wave agenda. We welcome the upcoming EPBD revision, which is essential to reaching the Renovation Wave’s aims, complemented by a strengthened EED and RED.

Deutsche Umwelthilfe e.V. (DUH) welcomes that the Commission proposes to amend the Waste Frame-work Directive (WFD) and appreciates the opportunity to provide feedback on the proposal. Since DUH has been working intensively on food waste for years, we will focus on aspects related to food waste.

DUH welcomes the objective of the initiative to improve the overall environmental outcome of waste management in line with the waste hierarchy and the implementation of the polluter pays principle. Therefore, the introduction of further regulatory measures is inevitable. We would like to comment on the proposed policy options and make further suggestions regarding changes in the WFD.

Environmental Action Germany (Deutsche Umwelthilfe e.V. - DUH) strongly welcomes the initiative to propose legally binding targets to reduce food waste in the EU. Concerning the scope of the policy scenario, DUH urgently recommends to promote Option S1, establishing a target covering the whole supply chain from farm-level production to the final consumer.

Please find a more detailed version in German in the attachment. German Environmental Aid recognises the opportunity to comment on the EU Commission’s CRCF proposal and welcomes in the idea to create a mechanism to financially reward carbon removals through sustainable land management.

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Environmental Action Germany (Deutsche Umwelthilfe e.V. - DUH) is an independent environmental and consumer protection organisation that promotes waste prevention and the sensible use of valuable resources within the circular economy. DUH strongly supports the inclusion of municipal waste incineration and landfilling in the EU Emissions Trading System (EU ETS) as part of the review scheduled for July 2026.

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.

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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.

DUH welcomes the EU’s intention to make sustainable products the norm as part of the Sustainable Products Initiative and the Ecodesign for Sustainable Products Regulation (ESPR). To ensure that the initiative meets its objectives with respect to specific product groups, we would like to comment on general requirements, specific articles of the regulatory proposal and finally important eco design rules regarding…

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.

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.

Immediate social concerns and unclear climate benefits Environmental Action Germany (DUH) welcomes pricing in climate damage costs in the transport and building sectors, where emissions reductions are slow at best. We are concerned, however, that the introduction of a new emissions trading system is not the right instrument.

ETS reform as part of a package to collectively increase climate ambition Deutsche Umwelthilfe (DUH) notes that even with a 2030-climate target of 55%, Europe remains off track to reach the Paris Agreement 1.5°C objective. Emission cuts of at least 65% are required for the EU to fully honor its international commitments.

In the new CPR, art. 22(1) touches upon methodology but leaves the door open to the use of existing harmonised technical specifications, notably under EN 15804. The latter lays out the core rules of Environmental Product Declarations (EPDs), upon which product category rules are standardised and applied to cover product-specific aspects.

DEAR Sir or Madam, Environmental Action Germany (DUH) is a non-governmental environmental and consumer protection organisation in Germany. WE are politically independent, recognised as a non-profit organisation and entitled to bring legal action. DUH supports all sustainable ways of life and economic systems that respect ecological boundaries.

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Environmental Action Germany (Deutsche Umwelthilfe, DUH) notes that the many tax exemptions in the Energy Taxation have led to a very disparate and complex energy tax landscape in Europe, which also hinders the integration of the internal energy market.

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.

Deutsche Umwelthilfe e.V. (DUH) welcomes the opportunity to comment on the proposal for a regula-tion (COM(2023)411) on plants produced by certain new genomic techniques. As a recognized non-profit environmental and consumer protection organization in Germany, we ask that our position be taken into account in the further proceedings. Deutsche Umwelthilfe e.V. (DUH) rejects the EU Commission's proposal.

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).

The DUH supports the Commission’s efforts to propose a legal instrument setting binding EU targets for the restoration of nature. Given the failure to achieve the voluntary objective of restoring ecosystems to date, a legislative approach is needed.

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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.

Deutsche Umwelthilfe (DUH – Environmental Action Germany) is a recognised environmental and consumer protection association in Germany that has been actively campaigning for the preservation of natural resources and consumer concerns since 1975. DUH is politically independent, non-profit, has the right to sue and is active at national and European level.

Environmental Action Germany (Deutsche Umwelthilfe e.V. - DUH) - Feedback on Batteries - modernising EU rules The promotion of environmental-friendly batteries in the fast growing EU market is of crucial importance for a sustainable development and resource management.

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.

Deutsche Umwelthilfe e.V. calls for more ambition in the current proposal of the EU F-Gas regulation. Please find our detailed comments in the document attached. We would like to emphasize that this is the crucial moment to set the course for a genuine sustainable transformation instead of, again, replacing one problem with the next: First, ozone-depleting chlorofluorocarbons and hydrochlorofluorocarbons were…

The F-gas Regulation is a key and guiding part of the European Union (EU) climate legislation for the transition from the use of fluorinated gases such as hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6) to the use of natural refrigerants. Having been in force for five years, the Regulation is now being reviewed with a view to improving it.

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The European Ocean Act has strong potential to become an overarching legal framework that ensures coherence, accountability and ambition across EU ocean policies. To be effective, it must reinforce existing international and EU commitments and ensure that all marine activities operate within ecological limits, guided by an ecosystem-based and precautionary approach.

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).

The Net-Zero Industry Act (NZIA) must, in the view of the German Environmental Aid (DUH), set the framework conditions for an industrial policy geared towards immediate climate protection and planetary boundaries.

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The Deutsche Umwelthilfe e.V. (DUH) strongly supports the ambition in the Chemicals Strategy for Sustainability to introduce 1) endocrine disruptors, 2) persistent, mobile and toxic and 3) very persistent and very mobile substances as important categories of chemical substances of very high concern within REACH.

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.

DUH welcomes the opportunity to submit feedback on the European Commission (EC) proposal for revised car CO2 standards. Road transport emissions have been rising over the last 30 years. Without fast and significant reductions in passenger car emissions, the EU won’t be able to meet its own climate targets, let alone the 1.5°C limit.

The car CO2 standards represent the primary EU policy instrument driving the transition to zero-emission road transport. Current standards are not in line with the Paris Agreement, and several elements of the regulation limit its effectiveness. These shortcomings must now be addressed, and the overall ambition significantly increased to set road transport on a rapid path to zero emissions within the next few years.

Deutsche Umwelthilfe / Environmental Action Germany (DUH) welcomes the opportunity to consult on the gas market directive and regulation. In general, we are not pleased with the roles that low-carbon gases and green hydrogen are given with this reform. The broad allocation of hydrogen across many sectors is critical.

Deutsche Umwelthilfe / Environmental Action Germany welcomes the opportunity to comment on the initiative at this stage. This legislation is essential in leveling the playing field between natural gas, hydrogen, other gases and renewable electricity. Natural gas currently enjoys significant regulatory advantages. While green hydrogen, renewable electricity etc.

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.

Feedback by Deutsche Umwelthilfe e.V./ Environmental Action Germany As consumer protection and environmental organization working on the topic of food waste, Environmental Action Germany appreciate the upcoming revision of marketing standards in line with the Farm to Fork strategy.

The revision of the AFIR offers the opportunity to set an important course for a change of engines towards a sustainable transport sector. We support the rapid development of the infrastructure in order to enable a faster conversion to electric motor operation.

Environmental Action Germany (Deutsche Umwelthilfe e.V.) welcomes the opportunity to comment on the ReFuelEU initiative. Greenhouse gas emissions from aviation must be reduced urgently. The ReFuelEU inception impact assessment, however, neglects important aspects of sustainability and availability of alternative fuels for aviation.

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) welcomes the opportunity to consult on the revision of the TEN-E regulation. The roadmap reads as a step in the right direction to make EU infrastructure planning compatible with energy and climate goals. Energy infrastructure is rightly recognized as a key enabler towards the EU’s decarbonisation objectives for 2030 and 2050.

Environmental Action Germany (DUH e.V.) welcomes the Methane Regulation proposal as it will for the first time impose binding rules regarding methane leakage on operators of energy infrastructure within the EU. Particularly positive are the new provisions on Measurement, Reporting and Verification (MRV) of methane emissions, regular inspections by regulatory agencies, as well as the requirement of quarterly Leak…

Deutsche Umwelthilfe / Environmental Action Germany welcomes the opportunity to comment on the initiative at this stage. Regulating methane emissions in the oil, gas and coal sectors is indeed a powerful tool and necessary in mitigating GHG emissions and meeting climate targets.

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.

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The already adopted EU climate protection law with a net climate target enables the economy to compensate its emissions with natural sinks. DUH had already criticized the watering down effect for the 2030 target and called for the introduction of a separate target for the conservation and expansion of sinks.

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.

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On behalf of Deutsche Umwelthilfe (DUH, Environmental Action Germany), we welcome the revision of the Ecodesign Regulation for solid-fuel local space heaters/SFLSH (EU 2015/1185). Over a fifth of total PM2.5 in Germany comes from small combustion appliances however, as reporting does not include condensables (condensed particles), actual emissions from this sector are much higher.

DUH Opinion on EU electricity market design Article 19b – Direct price support schemes: The reform proposal provides for the use of bipartite CfDs as the only support instrument for the development of renewable energies (RES). We do not pose a very serious risk and advise against the rapid introduction of a support mechanism that potentially endangers RES and which has so far been largely unknown and tested.

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Environmental Action Germany welcomes the opportunity to comment on this EC initiative. We wish to make the following comments: 1. Crop biofuels are more damaging to the climate than fossil fuels. Crop biofuels must be phased out entirely and must not be incentivised for use in shipping. 2. Advanced biofuels based on wastes and residues are not automatically sustainable.

Deutsche Umwelthilfe welcomes the opportunity to comment on the revision of the emission standards for heavy duty vehicles. Summary of our key recommendations: 1. 100 % CO2 reduction target for new registrations of trucks and buses from 2030 2. Stringent intermediate targets before 2030 3. Zero emissions target for new city buses in 2027 4. Application of the standards to 100 % of fleet 5.

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Deutsche Umwelthilfe (DUH) welcomes the fact, that the revision process of the Ambient Air Quality Directives (AAQD) resulted in a proposal of the European Commission to strengthen air quality standards in the European Union. Unfortunately, the draft of the Commission lacks ambition.

The revision of the Ambient Air Quality Directives (AAQD) is urgently needed, as their adoption dates back more than a decade. Since then, evidence increased and new findings about correlations between air pollutants and health effects, especially resulting from exposure to concentrations below the limit values, have been confirmed.

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.

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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.

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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.

Deutsche Umwelthilfe / Environmental Action Germany welcomes the opportunity to consult on the gas market directive and regulation. In general, we are not pleased with the roles that low-carbon gases and green hydrogen are given with this reform. The broad allocation of hydrogen across many sectors is critical.

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.

The energy label is an important tool to provide consumers with relevant information for purchasing decisions of energy-efficient and more environmentally friendly products through a clearly visible, immediately noticeable label affixed to the product. The label is designed to be an easy-to-understand, standardized and quickly visible tool that can be used without additional technical or digital support.

We welcome the opportunity to comment on draft act of the delegated regulation on the methodology for the calculation and verification of cobalt, nickel, lithium and lead recycled content in certain batteries, and the format for the documentation of such recycled content as mandated by Article 8 (1) of Regulation (EU) 2023/1542.

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…

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Environmental Action Germany (Deutsche Umwelthilfe e.V. - DUH) is an independent environmental and consumer protection organisation that promotes waste prevention and sensible use of valuable resources in the field of circular economy.

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.

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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.

On behalf of Deutsche Umwelthilfe (DUH, Environmental Action Germany), we welcome the revision of the Ecodesign Regulation for solid fuel boilers/SFB (EU 2015/1189). Over a fifth of total PM2.5 in Germany comes from small combustion appliances however, as reporting does not include condensables (condensed particles), actual emissions from this sector are much higher.

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.

Set an effective price signal for an early coal phase-out Environmental Action Germany (DUH) stresses that the ETS is an essential tools to set an effective price signal for an EU-wide coal phase-out by 2030 and thus to achieve the Commission's own scenario of a coal-free electricity mix. To this end, the amount of certificates should ideally be reduced to 70% by 2030, rather than 61% as proposed.