ECOS

ECOS welcomes the recognition that reducing the EUs dependency on raw materials, improving competitiveness, and mitigating environmental pressures requires a strong circular economy. We support proposals to expand Extended Producer Responsibility schemes, establish mandatory criteria for circular public procurement, and increase attention on Waste Electrical and Electronic Equipment, and hopefully on waste…

Strategic by design: a new Public Procurement Act Call for evidence Brussels, 26 January 2026 Introduction ECOS welcomes the opportunity to provide input in shaping the revision of the Public Procurement Directives (PPDs). Public procurement represents a crucial lever for the EU to deliver on its decarbonisation commitments across sectors, while exploiting demand from large public buyers.

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

Decarbonise right ECOS inputs to the Industrial Decarbonisation Accelerator Act (IDAA) Contents Executive summary .......................................................................................................................................................................

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

ECOS welcomes the initiative of the European Commission to review the current Renewable Energy Directive 2018/2001 and align it with an increased climate ambition to 2030 as well as with the objectives set out in the Paris Agreement. The Renewable Energy Directive is a key policy tool to drive the European Union towards a zero-emission and fossil-free energy system.

ECOS (Environmental Coalition on Standards) welcomes the initiative of the European Commission to evaluate the Public Procurement Directives. Attached our feedback looking back at the implementation of the Directives in four key areas, as well as our most recent study (performed by Ramboll) on green public procurement in the construction sector.

We welcome the European Commission's suggestion to promote reuse and refill of packaging. However, the approach requires clarification and strengthening to ensure that they can deliver their full potential for waste prevention.

ECOS welcomes the opportunity to provide feedback to the European Commission on existing taxonomy criteria, in a view to foster their continuous improvement. The attachment to this response draws on the CSO and academic review published at https://science-based-taxo.org/.

ECOS calls for a Critical Raw Materials Regulation that is based on circular principles and promotes both sufficiency and resource efficiency. This can be achieved by adopting the following circular strategies, in order of importance: - Rethink and reduce: lower the demand for CRMs by promoting systemic change; - Circular design, repair, and reuse: extend the life of products to keep CRMs in use for longer; -…

ECOS welcomes the initiative to establish a European Critical Raw Materials (CRMs) Act. However, this must be based on circular principles and promote both sufficiency and resource-efficiency. This can be achieved by adopting the following circular strategies and measures: 1. Rethink and reduce demand through systemic change, promote access over ownership: o Set an EU-wide material footprint reduction target (incl.

ECOS welcomes the European Commission's proposal to revise the Energy Performance of Buildings Directive (EPBD), including the addition of many essential elements to improve the energy efficiency and energy performance of buildings. These include common Minimum Energy Performance Standards (MEPS) and increased criteria as part of Energy Performance Certificates (EPC).

The Environmental Coalition on Standards (ECOS) welcomes the expedient revision of the Energy Performance of Buildings Directive (EPBD) and sees it as a major opportunity to effectively drive improvements to the sustainability of buildings in Europe and deliver a major contribution to the EU ‘Fit for 55’ for 2030, and beyond to 2050.

Having assessed the Proposal for establishing a Union certification framework for carbon removals (CRCF), ECOS would like to highlight some fundamental features we consider highly problematic and that need to be taken into account to ensure the proposed framework is trustworthy and avoids greenwashing. 1. Prioritisation and definitions: a.

We welcome the opportunity to provide feedback on the call for evidence on the ETS1 review. In our view, the EU ETS is a key pillar of the EU climate and industrial policies, with the potential to serve as a strong driver of significant emission reductions and global competitiveness for European industry.

The Green Claims Directive is urgently needed, and ECOS supports its adoption. It represents a crucial initial step that can and should be strengthened further. Nonetheless, even in its current form, it will significantly enhance legal measures against greenwashing. Voluntary environmental claims are made because they give a market advantage to those who make them.

ECOS supports the provision of environmental information to consumers environmentally relevant, reliable, comparable and verifiable, through the development of an EU legal framework requiring companies to substantiate claims via the Environmental Footprint methods.

ECOS is a strong supporter of the European Commission’s efforts to make sustainable products the norm, and has long been calling for the extension of ecodesign requirements to all products. While our overall position on the proposal is detailed in the attached paper, we would like to focus here on the impact assessment accompanying the proposal: • Ecodesign criteria.

ECOS welcomes the Commission’s intention to make sustainable products and circular business models the norm by transferring the principles of ecodesign to all products on the EU market. For sustainable products to become the norm in the EU, the primary focus of the regulator must be on removing unnecessary, inefficient, toxic, wasteful and polluting products from the EU market, complemented with (and not driven by)…

We welcome the opportunity provided by the European Commission to give feedback on the public consultation on the Revision of the benchmark values for free allocation of emission allowances (2026-2030). As ECOS, we strongly believe in the added value of a solid EU ETS to contribute to a clean, competitive and climate neutral European industrial basis.

We welcome the opportunity offered by the European Commission to provide feedback on the public consultation on the Carbon Border Adjustment Mechanism (CBAM) downstream extension, anti-circumvention and rules on electricity emission.

ECOS welcomes the European Commission’s proposal to revise the Construction Products Regulation (CPR), in particular the effort to align with the environmentally sound principles put forward by the Eco-design Regulation for Sustainable Products (ESPR).

Revising the CPR for sustainability The construction sector has a significant global impact on the environment, including here in Europe. Business-as -usual is no longer an option, but the current regulatory framework is not sustainability-ready.

We welcome the opportunity to provide feedback on the draft implementing act outlining the rules for accounting for the carbon price paid in third countries under CBAM. This act is instrumental to the well-functioning and integrity of the EU CBAM, and by extent also the EU ETS due to the interconnection between both policies.

We welcome the opportunity to provide feedback on the different calls for evidence on the Carbon Border Adjustment Mechanism (CBAM). We strongly support a timely, effective and full implementation of the EU CBAM in 2026. In a challenging international context, regulatory stability and predictability are quintessential for a competitive and clean European industrial basis.

ECOS welcomes the European Commission’s proposal for a new Regulation on batteries and waste batteries (replacing the current Battery Directive) and is pleased to contribute to the consultation on this matter. Together with other European NGOs, namely the EEB (The European Environmental Bureau), Deutsche Umwelthilfe (DUH – Environmental Action Germany), and Transport & Environment, we have developed a joint paper…

Batteries are an essential product to ensure decarbonisation in the EU and its demand is set to grow substantially in the upcoming years. As an environmental civil society organisation, we strongly welcome the initiative of the European Commission to update the legislation that ensures a circular and sustainable value chain for all batteries produced in the EU and placed on the single market.

ECOS is an international NGO with a network of members and experts advocating for environmentally friendly technical standards, policies and laws. We ensure the environmental voice is heard when they are developed and drive change by providing expertise to policymakers and industry players, leading to the implementation of strong environmental principles.

The F-Gas Regulation is a landmark piece of European Union (EU) climate legislation for transitioning away from fluorinated gases such as hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6). As an environmental civil society organisation, ECOS strongly welcomes the initiative of the European Commission to anticipate the update of the legislation and calls for significant improvements to safeguard our climate…

ECOS recommendations on the European Commission's Roadmap towards Nature Credits: Ensuring a system that disincentivises nature destruction Europe is facing a biodiversity emergency: over 80% of habitats are in poor condition, while billions in harmful subsidies continue to cause their decline. Regulating and divesting from economic activities which harm nature must be the EUs first strategy.

ECOS, the Environmental Coalition on Standards, is an international NGO with a network of members and experts advocating for environmentally friendly technical standards, policies and laws. The old End-of-Life Vehicles Directive has been in force since 2000 with only minor changes and is in urgent need of a fundamental update to meet today's requirements in terms of circular economy and net zero emission targets.

We welcome the opportunity to provide feedback on the different calls for evidence on the Carbon Border Adjustment Mechanism (CBAM). We strongly support a timely, effective and full implementation of the EU CBAM in 2026. In a challenging international context, regulatory stability and predictability are quintessential for a competitive and clean European industrial basis.

In light of the forthcoming revision of Regulation (EU) 1025/2012 and based on its longstanding experience in the standardisation system, and specifically in its role as an Annex III organisation, the Environmental Coalition on Standards (ECOS) would like to contribute its perspective on the key challenges identified by the European Commission.

Streamline environmental and social aspects, not simplify, for better housing delivery ECOS submission to the Call for Evidence for an Impact Assessment on Regulatory Simplification for Housing Brussels, September 2026 Contents General remarks ..............................................................................................................2 EU acquis…

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

ECOS welcomes the proposed implementing act for the Digital Product Passport (DPP) Registry. There is a need for a publicly accessible platform, on the model of the EPREL database, for all to be able to find existing DPPs, as an entry point alternative to the data carriers that can be found on products themselves.

ECOS welcomes the initiative from the Commission to reduce the presence in the environment of unintentionally released microplastics. Microplastics release and accumulation are ramping up at a dramatic scale, and the EU should take significant steps to address and stop this stream of plastic pollution with mandatory regulatory actions.

ECOS welcomes the opportunity to provide feedback to the European Commissions draft implementing decision overhauling the EU rules for calculating, verifying and reporting on recycled plastic content in single-use plastic beverage bottles and repealing the current decision (EU) 2023/2683.

ECOS welcomes the opportunity to provide feedback to the European Commission on the implementing decision laying down common rules for calculating, verifying and reporting on recycled plastic content in single-use plastic beverage bottles.

ECOS supports the Commission’s initiative to review the Alternative Fuel Infrastructure (AFI) Directive 2014/94/EU. Strengthening this policy framework is key for the increase of EVs on European roads, as envisioned by the European Green Deal, to become a reality. Overall, we welcome the objectives and policy options outlined in the Inception Impact Assessment (IIA).

ECOS supports an EAP that accelerates electrification, while streamlining the Energy Efficiency 1st principle. Our recommendations are summarised below and described more thoroughly in the paper attached. To decarbonise heating and cooling, the Action Plan can accelerate the deployment of heat pumps and address consumer costs, energy poverty, indoor air pollution and energy insecurity.

ECOS, welcomes the Commission’s initiative to directly address repair and reuse in the context of sustainable consumption of goods. Considering that e-waste is one of the fastest growing waste streams in the world, and that the amount of household appliances failing within 5 years of purchase is skyrocketing, this is an area that requires urgent and focused policy attention.

ECOS welcomes the possibility to provide feedback on the EU Heating and Cooling Strategy which you can find both in the document attached and summarised in the text below. The EU Heating and Cooling Strategy should grasp and address several challenges that slow down the transition to clean heating and cooling i.e.

Position paper Towards a robust EU Forest Monitoring Law that works for forests and forest managers Brussels, February 2024 Summary of key asks 1. Mandate Member States for the development of national integrated long-term plans and quantified targets to achieve forest protection and restoration goals. This needs to be conducted in a participatory process and following the set of indicators provided in the FML. 2.

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

On behalf of ECOS/EEB/Coolproducts, we welcome the revision of the Ecodesign Regulation for solid fuel local space heaters (EC 2015/1185) The energy crisis which followed the Russian invasion of Ukraine has driven up both the sales of solid fuels and those of solid fuel appliances, as more and more households turned to local space heating when the price of gas went up.

We welcome the opportunity to provide feedback on the different calls for evidence on the Carbon Border Adjustment Mechanism (CBAM). We strongly support a timely, effective and full implementation of the EU CBAM in 2026. In a challenging international context, regulatory stability and predictability are quintessential for a competitive and clean European industrial basis.

ECOS welcomes the European Commission’s proposal on strengthening the role of consumers in the green transition, notably the ban on unsubstantiated generic claims, new information requirements on product durability and repairability, and stronger regulation of labels and information tools.

ECOS welcomes the Commission’s initiative to empower consumers to play an active role in the green transition. Despite the clear preference of European consumers for more sustainable products, the absence of reliable information deprives from them of the opportunity to make informed purchasing decisions and fails to translate that preference into market demand and potentially market transformation.

ECOS welcomes the proposed revision of the Network Code on Requirements for Generators (RfG). It will improve the large-scale integration of electric vehicles (EV) and EV chargers capable of reverse power transfer (a.k.a. vehicle-to-grid, or V2G), as well as other low-power, mass-market products such as storage.

ECOS welcomes the proposal to create a European CRM Centre but considers the Call for Evidence's framing too narrow: it defines resilience almost entirely as securing more supply, while demand reduction, efficiency, substitution and circularity are largely absent, and the environmental impact of expanded extraction is assumed "minor" without evidence.

ECOS has reviewed the European Commissions proposal for a regulation of the European Parliament and of the amending Regulations (EU) No 765/2008, (EU) 2016/424, (EU) 2016/425, (EU) 2016/426, (EU) 2023/1230, (EU) 2023/1542 and (EU) 2024/1781 as regards to digitalisation and common specifications released on 21 May 2025 and this feedback outlines ECOS position with regards to the specific provisions related to the…

ECOS welcomes the draft Delegated Act on a methodology for calculating the carbon footprint of electric vehicle batteries. ECOS considers the methodology an integral part of further reducing vehicle and battery-related emissions and we are pleased to see it has been delivered swiftly.

With the demand for data centres predicted to surge in the coming years, this delegated act, in combination with the upcoming regulation on minimum performance standards, can establish a legal framework to ensure the sustainable development of digital infrastructure.

While Regulation (EU) 2019/1020 on market surveillance and compliance of products has been key in securing the legal framework ruling the market surveillance activities that ensure that non-food products on the EU market meet EU regulatory requirements, it is critical to reinforce checks, adequately resource surveillance authorities and discourage non-compliance also from economic operators such as online…

ECOS welcomes the initiative from the Commission to revise the Textile Labelling Regulation (TLR) to introduce specifications for physical and digital labelling of textiles, including sustainability and circularity parameters. EU mandatory legislation is needed and necessary to ensure harmonised, consistent and clear rules to provide robust information on the textile labelling.

We welcome the opportunity to share feedback on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2024/1781 as regards the details and format for the disclosure of information on discarded unsold consumer products. We look forward to continuing to work with the Commission to ensure effective reporting and a successful Implementing Act.

The adoption of reviewed regulation for this product group is already heavily delayed. With this consultation we are relieved to see the process finally moving forward and we expect the Commission to make sure any further delays in the final steps of the review are strictly avoided.

ECOS, as part of the Coolproducts campaign and the Cool Heating Coalition, strongly welcomes the long-due publication of the European Commissions ecodesign and energy labelling proposals for space and water heaters. The decarbonisation of the energy sector goes hand in hand with reducing gas use in the European Union, especially at residential and heating level.

ECOS, as part of the Coolproducts campaign and the Cool Heating Coalition, strongly welcomes the long-due publication of the European Commissions ecodesign and energy labelling proposals for space and water heaters. The decarbonisation of the energy sector goes hand in hand with reducing gas use in the European Union, especially at residential and heating level.

Water heaters are among the most energy-guzzling technologies in our homes and one with the largest potential for energy savings and climate emissions. While they are technically among the appliances that can best profit from local production of renewable energy (i.e. in combination with solar thermal solutions), as of now water heaters are a major driver for gas and electricity domestic consumption.

Iron and steelmaking are among the most carbon emissive industrial sectors. Product policy under Regulation (EU) 2024/1781 (ESPR) is the key missing cog to decarbonise steelmaking. To do so, the forthcoming delegated act must use all the useful tools embedded into the legal text. The ESPR is designed to bring environmental consideration to the fore of EU product policy, so far dominated by health and safety aspects.

Improving energy efficiency is one of the most effective tools the EU has to cut energy use, reduce dependence on imported fossil fuels, and lower household bills. The EUs energy label has been a success story in guiding consumers towards energy and financial savings and with some key tweaks could continue to do so and deliver even greater benefits.

ECOS, as part of the Coolproducts campaign and the Cool Heating Coalition, strongly welcomes the long-due publication of the European Commissions ecodesign and energy labelling proposals for space and water heaters. The decarbonisation of the energy sector goes hand in hand with reducing gas use in the European Union, especially at residential and heating level.

Space and combination heaters are the main heating products for households, and buildings have the largest energy savings and emission reduction potential, compared to other energy consumption sectors. It is also the main market for EU gas consumption.

ECOS welcomes the opportunity to provide feedback on the draft delegated regulation establishing 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 under Article 8.1 of the Battery Regulation.

ECOS supports improvements on good governance principles in the European Standardisation System (ESS). While progress has been made on stakeholder participation and inclusiveness by some European Standardisation Organisation (ESOs) since the adoption of Regulation (EU) No 1025/2012, under-represented stakeholders still face limitations.

ECOS recognizes the Commission's commitment to reducing regulatory burdens while fostering long-term competitiveness. Nevertheless, delaying the implementation of sector-specific standards will not alleviate the reporting burden, making this proposal counterproductive.

ECOS welcomes the Commission’s initiative to further regulate access to vehicle data. This is key to avoid vendor lock-in while Europe transitions to electrified mobility and to facilitate services such as smart charging needed for the electricity grid to handle the rise of electric vehicles (EVs).

ECOS, as part of the Coolproducts campaign and the Cool Heating Coalition, strongly welcomes the long-due publication of the European Commissions ecodesign and energy labelling proposals for space and water heaters. The decarbonisation of the energy sector goes hand in hand with reducing gas use in the European Union, especially at residential and heating level.

We welcome the long-awaited revision of Energy Labelling Regulation (2015/1186) for local space heaters. Heating products, and their local (room) application, are of crucial interests in the European policy arena, not only for their impact on climate and energy targets, but also to push and increase the independency from fossil fuel and for their human health impact, especially concerning solid fuel-based heaters.

ECOS welcomes the opportunity to provide feedback on the European Commissions proposal to postpone the application date of the battery due diligence obligations under Regulation(EU)2023/1542 from 18 August 2025 to 18 August 2027. While ECOS acknowledges the challenges mentioned in the proposal, a full two-year postponement risks undermining the regulations' objectives.

On behalf of ECOS/EEB/Coolproducts we welcome the revision of the Ecodesign Regulation for solid fuel boilers (EC 2015/1189). We have seen a steady increase in the use of biomass for heating and combined heat and power in recent years, and unless rapid regulatory action is taken to encourage consumers to make more sustainable choices, the forthcoming renewable energy targets, particularly in the buildings sector…

ECOS welcomes the European Commission’s ongoing efforts to develop an EU circular economy. We strongly encourage the EU to ensure that the circular economy respects planetary boundaries and fair share of use and access to resources, and avoids and minimises negative impacts of resource use including biodiversity loss, climate change, pollution, and reduced/impaired human health.

The inception impact assessment document provides a very good introduction to the topic, and we are very supportive of most of the statements made. The best policy option for consumers and the environment is indeed option 3. We would like to insist on three key points: 1/ Ecodesign requirements should be pursued, but thoroughly revised and reinforced to better reflect current technologies and practices.

The inception impact assessment document provides a very good introduction to the topic, and we are very supportive of most of the statements made. The best policy option for consumers and the environment is indeed option 3. We would like to insist on three key points: 1/ Ecodesign requirements should be pursued, but thoroughly revised and reinforced to better reflect current technologies and practices.

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.

Our views on the Commission’s proposal are summarised in the attached paper: https://goo.gl/7XeaF8 We are in favour of Option 4 because Ecodesign & Energy Labelling requirements for household washing machines and washer driers help mitigate climate change, help EU citizens save on their bills, and we strongly support the Commission’s intention to better integrate domestic appliances in a Circular Economy through the…

ECOS, EEB and the Coolproducts and Right to Repair campaigns welcome this initiative. It is necessary to address the environmental impacts of solar energy production while supporting the uptake of this key technology to reach the EU climate objectives. We consider a revised version of Option 6 most appropriate: stringent ecodesign requirements and GPP criteria, combined with an Ecolabel instead of an Energy Label.

Environmental NGOs including the Right to Repair Europe and Coolproducts campaigns welcome the publication of the call for evidence for an impact assessment on imaging equipment including the Commission's understanding of the problem and possible solutions. We call for the implementation of Option 4 a combination of ecodesign requirements and energy labelling.

ECOS believes that at the EU should take action to reduce the environmental impact of batteries, using existing legislation and by introducing new legal instruments addressing all phases of the value chain, from (ethical) sourcing of raw materials to recovery. Regarding the policy options presented, ECOS considers that a combination of options 3, 4 and 5 would be appropriate.

ECOS welcomes the opportunity given by the European Commission to provide input on the EU Emission Trading System (ETS) update of the Activity Level Changes Regulation (ALCR). In principle, we support the rational of the proposed changes as they contribute to the objectives of the ALCR.

In the corrective act, the European Commission states that (3) Annex II to Regulation (EU) 2023/1670 establishes different disassembly requirements for various parts of the product. There is an error regarding the requirements for the replacement of the display assembly, which was erroneously included in two separate sections of the requirements.

ECOS, EEB, iFixit and the members of Coolproducts and Right to Repair campaigns fully agree with the need for unequivocal wording and provisions in order to facilitate timely and uniform implementation of the implementing measures and therefore support the intention of the regulator to correct technical errors and improve the accuracy, consistency and cross-referencing across regulatory texts, including through the…

ECOS, Deutsche Umwelthilfe, IFixIt, and the Coolproducts campaign welcome the publication of the call for evidence for an impact assessment on the review of the eco-design and energy labelling requirements for electronic displays.

ECOS understands the legal context of the Commissions proposal for targeted amendments of the WEEE Directive. But such weakening of EU e-waste rules seems even more a missed opportunity to perform its complete overhaul for PV and all EEEs. It also goes against the EU ambition to recover important materials, including Critical Raw Materials, in line with the EU 2023 CRM Act.

ECOS welcomes the possibility of providing feedback on this Call for Evidence, please find attached the full answer to this initiative. The full document focuses on the following points: (1) measurement and test methods, where ECOS strongly suggest having a common testing method for electric and gas hobs; (2) requirements for energy and material efficiency, current ambition is rather low and ECOS advocate for a more…

ECOS (Environmental Coalition on Standards) and the EEB (European Environmental Bureau) are relieved to see the revision of these regulations moving forward again after lengthy delays, and we welcome the considered options to extend the scope, reintroduce energy labels, and introduce ambitious requirements for material efficiency and lifetime of vacuum cleaners.