European Environmental Bureau

Please find attached the EEB response to the public consultation and the call for evidence on the Circular Economy Act. A prosperous economy that works for people and planet can be achieved through a system embedded in circular principles: living well within planetary boundaries.

INDUSTRIAL ACCELERATOR ACT EEB RECOMMENDATIONS MAY 2026 The European Environmental Bureau (EEB) is the largest network of environmental citizens’ organisations in Europe. It unites 190 civil society organisations from 41 countries, working for a better future where people and nature thrive together.

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

Regarding permitting, new or revised legislation on permitting is not the way forward. Stability is needed, not the legal uncertainty coming from deregulation or re-opening of the EU acquis. Legislation presently into force (e.g.

The European Environmental Bureau welcomes the proposal for the revision of EU rules on packaging and packaging waste. Notably, we support the proposed waste prevention and reuse targets, as well as the strengthened measures for tackling packaging waste.

Please see attached the European Environmental Bureaus (EEB) feedback. The EEB's contribution sets out how the EUs Right to Stay Strategy can align with the renewable energy transition to strengthen rural resilience and territorial cohesion, towards ensuring that rural communities are primary beneficiaries and active participants in the renewable acceleration.

To promote raw materials resilience, secure strategic autonomy, and safeguard a just transition, the CRMA must: include measures to reduce raw material demand; ensure that strategic projects operate transparently and guarantee complete participation of local civil society and of communities and indigenous peoples; prioritise circularity by moving higher up waste hierarchy framework; and mandate compliance with…

Firstly, the CRMA needs to not just focus on reacting to changes in the supply side but also actively influence the demand side. To prioritise demand reduction, sufficiency, and circularity over primary resource extraction. The CRMA can signal politically that the Commission must act on setting this overall materials demand reduction target in its next mandate.

The European Environmental Bureau (EEB) welcomes that reducing greenhouse gas emissions from buildings is part of the performance of buildings in the European Commission’s proposal for the Energy Performance of Buildings Directive (EPBD). The building stock's impact on achieving a climate-neutral Europe by 2050 is crucial, and a clear roadmap should be defined toward its decarbonisation.

EEB welcomes the Energy Performance of Buildings Directive (EPBD) revision to help achieve 2050 EU environmental objectives. EEB considers that an extensive revision of the EPBD should be done ensuring a better cohesion with the national Long Term Renovations Strategies and the Renovation Wave. Failing to do so will be a missed opportunity that could make it challenging to achieve the environmental targets.

The current proposal of the Commission, as announced in July 2025, establishing the European Competitiveness Fund (ECF) raises serious concerns especially linked to the future of the LIFE programme, the current EUs only funding programme exclusively dedicated to the environment and climate.

The EEB welcomes the opportunity to comment on the proposal adopted by the European Commission on 4th March 2020 for a Regulation stablishing the framework for achieving climate neutrality and amending Regulation (EU) 2018/1999 (European Climate Law).

The EEB welcomes the upcoming adoption of the initiative on Climate Law, which will enshrine the commitment to making Europe the first carbon-neutral continent by 2050. The overarching legislative framework will have to put European economy on a path towards a systematic and deeply transformative change to address the existential threats of climate change, biodiversity loss and other negative environmental impacts.

The European Environmental Bureau (EEB) welcomes the Commission's proposal to revise the Waste Framework Directive but regrets the limited scope of the revision. In our attached position paper we detail the following recommendations to policymakers.

The EEB welcomes the planned revision of the Waste Framework Directive. In an attached document we describe few directions that this revision should take into account and address: 1. Increasing waste generation (lack of binding waste prevention targets proves lack of action by member states, regions and cities). There is an urgent.

The European Environmental Bureau (EEB) welcomes the initiative to propose EU-level targets for food waste reduction. Firstly, we would like to remind that all Member States (MS) committed to achieve the SDGs by 2030, and in particular SDG 12.3 on food waste reduction as a minimum. This commitment has been recalled in the Farm to Fork Strategy (F2F Strategy).

A higher carbon price is needed to incentivise faster industrial decarbonisation and reduce reliance on volatile and expensive fossil fuels. While the EU ETS functioning has improved, for certain industrial sectors the decrease of emissions is not in line with reaching climate neutrality by 2050.

EEB is the largest network of environmental citizens organisations in Europe. It consists of 180 member organisations in 38 countries, representing some 30 million individual supporters. OFFSETTING DETERS REAL CLIMATE ACTION The recitals imply that the certificates are aimed at voluntary carbon markets to be used as offsets. Offsetting would greatly deter the EU from reducing its actual emissions.

The EEB welcomes the long-awaited proposal for a Green Claims Directive. Please see our attachd position paper and the summary below: 1) Why this legislation is important - The proliferation of misleading and unsubstantiated claims as well as greenwashing are hampering the green transition.

The EEB welcomes the inception impact assessment for the initiative “Legislative proposal on substantiating green claims”. The EEB actively participates in the Product Environmental Footprint (PEF), its Technical Advisory Board (TAB), as well as the pilot and transition phase projects. The EEB supports the need for standard methodologies to assess the impact on the environment of products on the European market.

For full details, see our attached paper The EEB welcomes the transformation of the current Ecodesign Framework Directive into a new Ecodesign for Sustainable Products Regulation. We think it clearly reflects the ambition of the EU to make sustainable products the norm (we think this should be more explicitely reflected in the article 1 on subject matter and scope, in the proposal of the EU Commission).

The EEB welcomes the initiative, a detailed draft position is included in the attached document. Here we outline the key messages: 'Make sustainable products the norm' represents the core objective of the initiative, implying transformative changes to the European market in order to address the reality that products and consumption drive environmental degradation.

The climate and energy framework regulatory overhaul to step up 2030 climate is a unique opportunity to improve policy coherence and address the existing loopholes. The EU ETS is an important driver of decarbonisation but it needs to be strengthened and cannot work alone. The market mechanism must be reinforced and go in hand with a stronger regulatory approach and by no means replace it.

CBAM call for evidence – EEB position The CBAM review must recognise its role of climate measure intended to help meeting the EU climate neutrality goal and promote decarbonisation globally1, and that relevant and objective data2 is needed to support circumvention claims, which to date is very limited, given that CBAM is still in its transitional phase and many pieces of secondary legislation have not been defined…

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

The EEB welcomes the European Commission's proposal to revise the Construction Products Regulation (CPR). However, the current proposal is not aligned with the Paris Agreement ambition and does not grant an effective contribution to 2050 carbon neutrality objectives. Lack of clear provisions to actually reduce embodied emissions beyond information is a worrying postponement of necessary efforts.

The European Environmental Bureau welcomes the revision of the Construction Products Regulation (CPR). Construction sector consumes nearly half the material resources used in Europe and construction products consequently represent a tremendous potential for circular economy, resources use optimisation and (hazardous) waste prevention.

The European Environmental Bureau (EEB) welcomes the Commission proposal on the revision of the EU regulation on hazard classification, labelling and packaging of substances and mixtures (CLP). The proposal supports the toxic-free environment vision of the European Green Deal and the Chemicals Strategy for Sustainability (CSS) and its intention to shift the focus from the use of toxic chemicals towards the use of…

The CLP Regulation is an essential tool to identify, communicate and trigger the regulation of hazardous chemicals in Europe. However, CLP needs to be improved to support the implementation and the level of ambition of the Chemicals Strategy of Sustainability (CSS).

The EEB welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment for the revision of the Energy Taxation Directive (ETD). We agree with the analysis carried out by the European Commission pointing out the lack of consistency of the current energy taxation regime with the objective set in the European Green Deal of achieving climate-neutrality by 2050 at the latest.

The European Environmental Bureau (EEB) welcomes the opportunity to submit input to the consultation on the Digital Fairness Act. With ever-evolving technologies, deceptive techniques are being used to push consumers to purchase ever-increasing volumes of products.

16 April 2026 European Environmental Bureau Ref. Ares(2026)3961048 - 16/04/2026 The European Environmental Bureau have organised our response to this call for evidence around the following headings from the Call: ● ● ● ● accelerate investments into RES in a cost-effective manner; to strengthen the enabling framework to integrate RES into the electricity sector; to improve energy system integration and facilitate…

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

Please find attached the response from the Rethink Plastic Alliance to the call for evidence for the evaluation of the Single-Use Plastics Directive. The European Environmental Bureau (EEB) draws attention to this joint submission, which reflects the shared position of the alliance.

The European Environmental Bureau strongly supports the proposal for a Regulation on nature restoration. We consider the proposal to be a huge opportunity to bring nature back to Europe, benefiting biodiversity, climate, and people alike.

The European Environmental Bureau (EEB), Europe’s largest network of environmental citizens' organisations, supports the commitment by the European Commission to propose legal instrument setting binding EU nature restoration targets. This action has the political backing from both the Council and the European Parliament.

The European Environmental Bureau welcomes this opportunity to provide feedback on the proposal for a 2040 climate target. The EU must stay the course toward climate neutrality and time is of the essence. The sooner we cut emissions, the greater the benefits and the lesser the damage.

The EEB (real "environmental organisation") = "NGO", together with its active members ClientEarth, Carbon Market Watch and Ecos have provided its preliminary assessment on the proposal for revised IED + the Industrial Emissions Portal at this link https://eeb.org/library/ngo-preliminary-assessment-of-the-european-commissions-proposal-for-revised-ied-and-e-prtr/ Further briefings around the EEB's position and…

Summary: The EEB welcomes the findings of the European Commission that a review of the IED is necessary to improve delivery and effectiveness with respect to its goals. The current goal is to achieve a high general level of environmental protection from industrial activities, with priority to pollution prevention over control.

The European Environmental Bureau (EEB) welcomes the proposal presented by the EC, including the the switch from a directive to a regulation which is necessary for a consistent implementation across all Member States, improving harmonisation and legal certainty.

The IIA sets up good directions for the development of policies on batteries. It indicates the need for an ambitious regulatory framework proposal, capturing the largely improved environmental performance and social impacts such as responsible sourcing, while promoting the EU's competitiveness and ensuring long term sustainability, also in view of the EU post COVID-19 green recovery.

The European Environmental Bureau (EEB) welcomes the opportunity to give feedback regarding the Commission's proposal on "simplification of administrative burden in environmental legislation". Please find attached our detailed contribution, which includes a feedback on the methodology as well as concerns over the announced revision of the Water Framework Directive and the content of the proposal regarding the SCIP…

Nature is a common public good at the basis of social and economic well-being but also has a right to exist in itself and for itself. Nature credits carry significant risks of commodification, privatization, and financialisation of ecosystems and natural elements such as water or land. Biodiversity is complex, long-term, and site-specific, making it inherently unsuitable for fungible credit schemes.

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…

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.

The REACH Regulation is an essential tool for chemicals control in Europe. However, it needs to be improved to support the implementation and the level of ambition of the Chemicals Strategy for Sustainability (CSS).

The EEB welcomes the initiative to provide a framework for local authorities to guide possible restrictions on STRs by clearly outlining which legal principles, rights and obligations are relevant in this context and establishing greater legal certainty. In line with the objective of increasing housing supply, we however strongly urge for the Commission to consider going beyond STRs in this framework.

The housing crisis in Europe demands immediate and effective action. While the European Affordable Housing Plan (EAHP) takes an important step in the right direction, it falls short of advancing the paradigm shift necessary to transform the housing sector.

The European Environmental Bureau (EEB) welcomes the European Commissions initiative to develop an integrated framework on Climate Resilience and Risk Management. The initiative comes at a critical time, as the EU faces escalating climate impacts that threaten ecosystems, societies, and economies alike.

We welcome this urgent initiative to tackle microplastics pollution given that microplastics are pervasive, chronic, persistent, transboundary pollutants with proven harmful impacts on the environment, biodiversity, and pose risks to public health.

The European Environmental Bureau welcomes this opportunity to share feedback on the draft Implementing Decision laying down rules for the application of Directive (EU) 2019/904 of the European Parliament and of the Council as regards the calculation verification and reporting of data on recycled plastic content in single-use plastic beverage bottles.

The EEB welcomes the revised text of the Waste Shipment Regulation. It integrates clear improvements compared to existing law. E.g: a ban by default on shipments for disposal, even within EU; a ban by default to export to non-OECD countries of both hazardous and not hazardous waste; a ban for export untreated, mixed Municipal Solid Waste; a monitoring system for export towards OECD countries; the obligation to audit…

We welcome the inception impact assessment (IIA) of the WSR stressing the intention to stop exporting waste outside the EU and revisit existing rules. The Circular economy set as a priority for the European Union is about designing waste out of the system. The increase of traded waste is certainly in contradiction with that objective.

The European Environmental Bureau (EEB) welcomes the opportunity to contribute to the call for evidence regarding guidance on the application of the 'do no signifcant harm' principle under the 2028-2034 MFF. Please find attached our detailed contribution, which includes a feedback on the Commission's proposal for an EU Budget Performance Regulation, as well as input on the future Commission guidance.

We welcome the opportunity to contribute to the development of the EU Heating & Cooling (H&C) Strategy. The H&C Strategy must prioritise energy efficiency and non-polluting technologies. The phase out of fossil fuels should play a major role in the strategy.

EEB has contributed to the Commissions proposal for a revised UWWTD that should set the path for wastewater treatment for the next two decades. The proposal addresses several of the challenges that were not covered by the existing Directive, including micropollutants, energy use and production and, to some extent, climate change adaptation.

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.

The EEB welcomes the opportunity to provide input to the Call for Evidence on the Water Resilience Research and Innovation (R&I) Strategy. This initiative should serve to support the implementation and achievement of the objectives of EU water legislation to protect and restore coastal and freshwater ecosystems, which are the foundations of Europes water resilience.

The EEB welcomes the opportunity to respond to the Call for Evidence on the digitalization of the water sector, which is one of the flagship actions of the Water Resilience Strategy. The EEB recommends to only promote those digital solutions where the potential benefits for water protection and resilience clearly outweigh the negative impacts stemming from digital infrastructure, such as data centres.

As stated in the Commissions questionnaire on the inclusion of international credits, Expert Section, Question 1, international credits effectively substitute for domestic climate change mitigation. Climate action should not be outsourced.

Forests play a vital role for biodiversity and climate, yet there is a significant deficit in public information about their status, the impact of management practices and their ecological condition. It is concerning that information about the state of forests, and their trends towards destruction or restoration, is often scattered, incomparable, inaccessible, outdated or entirely missing.

The EEB strongly welcomes the legislative initiative to propose a new EU Framework for Forest monitoring and Strategic Plans. Forests are crucial for biodiversity and climate, yet there is a lack of public information about their status, the impact of management practices, their ecological conditions or climate contributions.

The European Environmental Bureau (EEB) provides feedback to the European Commission on the upcoming guidance for Member States on designating Renewables Acceleration Areas (RAAs) under the revised EU Renewable Energy Directive (RED).

The amendments proposed to the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive (CRD) are a step in the right direction to counter the lack of reliable information on products’ durability and reparability, early obsolescence and greenwashing.

The EEB welcomes the initiative “Empowering the consumer for the green transition”. Preventing greenwashing and early obsolescence are necessary priorities in the Green Deal, as well as Europe’s post Covid19 recovery. Consumer legislation should support the forthcoming sustainable products initiative, and its objective “to make sustainable goods, services and business models the norm”.

The European Environmental Bureau, supported by the Zero Mercury Working Group, appreciates the opportunity to provide evidence on the evaluation of the Cosmetics Products Regulation (CPR). The CPR has played a crucial role in ensuring a high level of consumer safety, notably by keeping the most harmful substances out of cosmetics, becoming a reference at global level.

The EUs climate policy framework needs to be designed for at least 90% domestic emissions reductions and aiming for climate neutrality by 2040. It should first and foremost be effective and fair in reaching climate, environmental, and social objectives. Therefore, simple, cost-effective, and competitive cannot be the guiding principles.

Brussels, 14 January 2021 EEB welcomes the publication of the European Commission’s roadmap on the inception impact assessment for the revision of the Ambient Air Quality Directives (AAQDs) and the opportunity to provide feedback to it. The roadmap includes some details on the Commission's understanding of the problem and possible solutions related to the revision of the AAQ Directives.

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

The European Environmental Bureau (EEB) welcomes the Commissions proposals for One Substance, One Assessment (OSOA) to enhance the level of protection of the environment and human health against hazardous chemicals.

The draft delegated regulation proposes to amend article 5, paragraph 5 of Commission Delegated Regulation (EU) 2024/1364 of 14 March 2024. However, the proposed amendment does not address the general presumption of confidentiality made in the article which by default classifies the underlying information related to key performance indicators for individual data centers as commercially sensitive information in the…

The European Environmental Bureau (EEB) welcomes the creation of the Just Transition Mechanism (JTM) but acknowledge that it is not a silver bullet. It will be useful only if used in the right way; this means that all three pillars constituting the JTM must exclude from their scope fossil fuel investments, including natural gas.

The European Environmental Bureau (EEB) welcomes the Commissions proposals for One Substance, One Assessment (OSOA) which aim to enhance the level of protection of the environment and human health against hazardous chemicals.

The European Environmental Bureau welcomes the Commissions proposal for the ECHA Basic Regulation to improve ECHA's governance and financial model as its mandate grows. We provide the following recommendations to further strengthen protection of people and nature from harmful chemicals.

The European Environmental Bureau (EEB) welcomes the Commissions initiative to evaluate the possibility of revising the Textile Labelling Regulation (TLR). The attached document contains considerations we urge policymakers to explore in the evaluation and impact assessment.

The EEB welcomes the fact that the Commission has published its proposal to amend the Aarhus Regulation, with its stated intention to widen the opportunities to review decisions by the EU institutions that harm the environment. The proposal addresses a major obstacle to access to justice, namely the limitation of acts that may be challenged to measures of individual scope.

Access to justice is a widespread problem in the Member States and has been woefully insufficient also at EU level, as was also found by the Aarhus Convention Compliance Committee. Overall, the EEB welcomes the initiative by the Commission to finally address some of the deficiencies around access to justice, but would like to draw attention to certain aspects that are elaborated in the attached document.

The European Environmental Bureau welcomes this 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.

1. Classes of performance and minimum environmental performance thresholds. We support the introduction of classes of performance and minimum environmental performance thresholds. To ensure a strong labelling mechanism and thresholds, robust datasets at installation level should be used.

The EEB has contributed to the development of the proposal to add a range of crucial water pollutants including 24 PFAS, several pesticides and a number of pharmaceuticals to the lists of priority substances. An update that is several years overdue and which will require Member States to monitor these substances in water and make sure that environmental quality standards (EQS) are met.

The EEB welcomes the EU Commissions draft establishing minimum requirements for the issuance of certificates for stationary and mobile refrigeration. Article 3(2) 360º training We hold that all training and certification should be automatically extended to both fluorinated and hydrocarbons.

The European Environmental Bureau (EEB) welcomes the opportunity to provide feedback and call on the European Commission to prioritise people and nature when revising the EU's energy security architecture, based on the following key principles: (1) LNG is just prolonging our fuel dependency neither Russia nor the US should be considered reliable partners.

The Right to Repair campaign Europe represents repair actors and activists including community repair groups, social economy actors, self-repairers and any citizen who would like to advocate for their right to repair.

The Commissions proposal for the MFF Performance Regulation is a welcome step forward. By introducing a single system for monitoring expenditures, the Regulation strengthens transparency while reducing administrative burdens with particular welcomed elements: - Commitment of the EU budget to climate and environment goals; - Application of the Do No Significant Harm principle, ensuring environmentally harmful…

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.

EEB welcomes the opportunity to provide input to the public consultation on the 16th European list of ship recycling facilities and would like to share its recommendations, more specifically on the proposed inclusion of two beaching recycling facilities, YSI Recyclers LLP and Shree Ram Vessel Scrap Pvt, located in Alang, India.

The European Environmental Bureau welcomes the release of European Commissions proposal for revision the EU Mercury Regulation. We comment the Commission for taking responsibility for what it exports to developing countries; yet the ban on linear (LFL) and non-linear fluorescent lamps should take place much faster and as early as 2025, aligning them with domestic bans, and irrespective of global decisions, in line…

Diffuse pollution remains a problem in Europe also because of both historical and current emissions of mercury to the atmosphere and subsequently surface waters. Strong action is needed to curtail remaining mercury use and emissions under the European Green Deal, as per the Chemicals Strategy for Sustainability and as part of the Zero Pollution Action Plan.

As an environmental NGO, the EEB considers that the recent CAP changes appear as failing to properly address farmers concerns while weakening environmental safeguards. The simplification processes lacked transparency and were pushed through without sufficient consultation or evidence, resulting in a more uncertain and less effective framework overall.

The EEB welcomes the opportunity to give feedback to the Commission’s proposal to convert the Farm Accountancy Data Network into a Farm Sustainability Data Network to collect additional environmental and social data at farm level. We would like to comment on three important themes which are touched upon in the proposed legislative amendment: interoperability, data collection and variables.

EEB input to the public consultation on Proposal for a regulation - COM(2022)157 - Industrial Emissions Portal Regulation The EEB is the largest federation of EU citizens organizations & has been involved in following the regulation on industrial emissions (the Sevilla BREF process, the IPPC Directive and Industrial Emissions Directive), including the Regulations for reporting the pollution releases and transfers…

The European Environmental Bureau (EEB) has already concluded in the previous 2015 REFIT that a fundamental overhaul of the E-PRTR and its parent PRTR UNECE protocol are necessary, we welcome the review initiative is finally going forward. We disagree with the statement that ‘in general, the overall structure of the E-PRTR appears to function well’.

Context: The description of the context is broadly accurate, though it fails to mention that the reason that no agreement was reached at the MoP was because the EU opposed the endorsement of the finding of non-compliance (thereby breaking the longstanding practice whereby all findings of non-compliance had previously been endorsed by the MoP with the full support of the EU) but failed to get even a single other…

- ‘Products & services’ are the entry point for material loops: 80% of environmental impacts are determined at design stage and if injecting single use & toxic materials through products we spoil the whole potential for circularity. It is no brainer that products and services need to be better designed for circularity. It’s impossible to make a good recipe with rotten ingredients.

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.

EEB Feedback on the 8th Environment Action Programme (8EAP) The European Environmental Bureau (EEB), representing more than 160 members across all Member States, welcomes the 8EAP proposal. Given the EGD, the 8EAP is of a different nature than preceding EAPs. It remains a very important tool for European environmental policy. EEB welcomes a range of elements, including: 1.

The EEB welcomes the Commission’s proposal as well as the choice to revise the directive rather than to amend it. The EU has an international leadership role to play in the fight against global climate change and biodiversity loss by strengthening of the protection of the environment through criminal law within the EU is a necessary step to support the enforcement of the European Green Deal and the 2030 Climate…

The EEB/Coolproducts 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…

EEB, Europes largest network of environmental citizens organisations with over 190 member organisations in 41 countries, welcomes the opportunity to provide feedback on the draft Implementing Act on modelling applications and spatial representativeness of sampling points.

It is of utmost importance to phase out the use of hazardous substance in products. This is the overarching principle. In the same time a coherence with the Circular Economy STrategy must be achieved. The EEBs report looks into this subject in detail…

Although the European Environmental Bureau (EEB) respects and appreciates the need for legal certainty in accordance with EU law, the decision to revise the Waste Electrical and Electronic Equipment Directive to exempt certain products from proper collection is highly concerning in economic and environmental terms.