Environmental Defense Fund

The circular economy represents the next critical frontier of greenhouse gas (GHG) mitigation and is equally critical for biodiversity protection. Properly implemented, it can serve as a flagship winwin policy: advancing Europes climate goals, competitiveness, resource sovereignty, and strategic resilience.

Environmental Defense Fund's (EDF) comments include both the strategic need to introduce a methane performance standard and a set of changes to the existing REDII sustainability framework. Considering the EGD’s strategic priorities of decarbonising gas and directing investments to sustainable activities, it is strategically important to ensure alignment of both the RED II and its sustainability framework with the…

Environmental Defense Fund Europe broadly supports the objective of making sustainability reporting under the revised ESRS more focused, proportionate and decision-useful, while stressing that simplification must not undermine the core purpose of the CSRD: improving transparency, enabling efficient capital allocation and supporting the EUs transition to a resilient, climateneutral economy.

Environmental Defense Fund (EDF) welcomes the opportunity to comment on the European Commission’s consultation on a forthcoming “European Climate Law” (ECL) that “will enshrine the EU objective of climate neutrality objective by 2050 in legislation” and “aims to transform the way EU policies are made and to set the long-term direction of travel for meeting the 2050 climate-neutrality objective through all policies…

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

The amount of sustainability certifications and markers on products and packaging is confusing for brands, retailers, and especially consumers. Environmental Defense Fund is excited to see the EU develop regulation around product claims ensuring such claims be backed by scientific evidence.

Environmental Defense Fund (EDF) applauds the European Commission's efforts towards climate neutrality. EDF encourages Europe to leverage its single market to encourage more ambitious global climate ambition and a more pro-climate interpretation of WTO rules.

Environmental Defense Fund (EDF) and Environmental Defense Fund Europe (EDFE) thank the European Commission for the opportunity to comment on the Commission’s update on the EU’s emissions trading system (EU ETS).

Methane emissions from the EU's gas supply chain, CO2 emissions from combustion of fossil fuels in non-ETS sectors and maritime fuels Environmental Defense Fund (EDF) welcomes the opportunity to comment. The fact that the ETDs minimum tax rates have lost their effect and no longer have a converging effect on national tax rates is particularly relevant for the EU’s objective of net zero GHG emissions by 2050 since…

EDF is an international non-governmental organization with expertise in carbon markets, climate finance, and international climate policy, including crediting mechanisms under the Paris Agreement. EDF supports the objective of the IR, with the following observations: 1) The IR unduly constrains the set of third-country carbon pricing measures that are eligible for recognition, potentially exposing the EU to a legal…

To ensure relevance of the revision of EU rules on market access for the EU's climate objectives as well as to enable smooth delivery of objectives 2,3 and 4 of the planned initiative- particularly to level the playing field and ensure robust consumer rights - we recommend a mandatory methane emissions performance standard effective on all gas sold in the EU's market as of 1 January 2025 and inspired by the OGCI…

Environmental Defense Fund (EDF) welcomes the opportunity to comment on the EC’s plans to incentivize sustainable aviation fuels (SAF). The European Commission should only propose a quantitative SAF mandate if it incorporates a robust sustainability and accounting framework that addresses flaws in existing legislation. To achieve this, the EC should require that SAF policies: 1.

Environmental Defense Fund (EDF) fully supports the two specific objectives of the proposal. Regarding the objective of improving the availability and accuracy of information on the specific sources of methane emissions associated with energy consumed in the EU, EDF supports the third option of translating the OGMP framework into EU legislation applicable to the full supply chain, including imports.

Please see the attached files: - A letter with EDF's policy recommendations - Two policy papers: * International credits in the EU: credit quality criteria and implications for the EUs purchasing strategy (EDF and The Nature Conservancy, May 2026) * Buying the 5%: Funding, Governance and Market Design for the EUs International Credit Purchases (EDF, May 2026)

Environmental Defense Fund Europes Response to the Call for Evidence on the EU Energy Security Framework (revision) 13 October 2025 Environmental Defense Fund Europe (EDFE) welcomes the European Commissions initiative to revise the EU energy security framework.

Environmental Defense Fund (EDF) welcomes the opportunity to comment on the European Commission’s proposed plans to incentivise sustainable fuels in maritime transport. The key points the Commission must consider are: • Any policy on maritime fuels must take a full lifecycle approach. In addition to accounting for well-to-wake direct emissions, indirect emissions (such as ILUC) also need to be considered.

Environmental Defense Fund Europe welcomes the opportunity to provide feedback on the proposed directive on the common rules for the internal markets in renewable and natural gases and in hydrogen. We believe that the proposed legislation, together with the related regulation on internal markets for renewable and natural gases and for hydrogen, will be central to ensure that hydrogen is produced and deployed in the…

3892 pre changes Environmental Defense Fund welcomes the opportunity to comment on the Inception Impact Assessment on a revision of the EU ETS for aviation. When evaluating policy options for CORSIA and EU ETS, the Commission should assess their consistency with the Paris Agreement obligation to pursue further climate ambition as well as the Chicago Convention, as the EU noted in the context of ICAO Assembly…

Environmental Defense Fund Europe (EDFE) welcomes the European Commissions initiative to evaluate the performance of the European Union Agency for the Cooperation of Energy Regulators (ACER) and the opportunity to provide feedback to this process. EDFE considers ACER to be structurally well placed to support certain market-facing and cross-border dimensions of the implementation of the EU Methane Regulation (EUMR).