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…

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 (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.

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/.

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.

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.

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.

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 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 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 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 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.

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.

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)

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 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.

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.

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.

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, 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, 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.

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 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, 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 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.

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.

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.

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.