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.

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.

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.

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)

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…

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 (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…

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 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.

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 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.

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 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.

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 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 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 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.

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 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…

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/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.

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.