FNADE

FNADE welcomes the European Commissions decision to take up the crucial issue of circular economy through this ambitious initiative. Our members, industrial actors in waste management and resource recovery, see this proposal as a key step towards strengthening the EUs sovereignty, competitiveness and industrial resilience.

FNADE welcomes the European Commission’s proposal for reviewing the 2018 Renewable Energy Directive (REDII) and adjusting its rules to the latest EU climate ambitions for 2030. FNADE also approves the increase of the renewable energy target to 40%. This proposal and the whole “Fit for 55 package” will help to achieve the EU's greenhouse gas reduction and climate neutrality targets.

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

Feedback – Renewable Energy Directive FNADE, the french association for waste management and environmental services welcomes the European initiative for the Revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources.

FNADE, the French association for waste management and environmental services welcomes the proposal of the European Commission for a revision of the packaging and packaging waste directive. Overall, the new regulation on packaging and packaging waste represents a step forward for the waste management sector and FNADE globally supports its objectives.

Feedback on the review of the requirements for packaging and other measures to prevent packaging waste FNADE, the French association for waste management, welcomes the European Commission's initiative to reduce and better recycle packaging waste. First of all, this initiative will have to ensure that the reusability of packaging does not hinder its recyclability at the end of its life.

FNADE, the French association for waste management and environmental services supports the willingness of the European Commission to secure the supply of critical raw materials. European self-sufficiency and autonomy are more than ever needed and dependence on third countries must be drastically reduced.

FNADE, the French association for Depollution and Environmental Activities, welcomes the proposal for a European climate regulation that sets ambitious but necessary targets to achieve the carbon neutrality by 2050 set by the Green Deal. FNADE brings together 223 companies and 48,000 employees.

FNADE, the French association for recycling and waste management fully supports any initiative that aims both to reduce waste production (in particular through prevention) and to promote recycling and circular economy. Nevertheless, we would like to take the opportunity to make some comments on the Waste Framework Directive revisions proposal.

FNADE, the French private companies’ association for waste management and environmental services, welcomes this new initiative from the European Commission in order to reduce waste production, to improve separate waste collection and high-quality recycling avoiding contaminations and to promote oils regeneration. Please find FNADE's feedback attached.

FNADE’s Position FNADE’s feedback on carbon removal certification April 2022 FNADE, the French waste management and environmental services association, welcomes the European initiative on carbon removal certification.

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

FNADE is concerned to hear public statements emanating from some Commission officials that their services will advocate for the inclusion of municipal waste incineration (MWI) and landfill in the EU Emissions Trading System (EU ETS). Such statements are premature and are likely to undermine the legitimacy and credibility of the impact assessment work currently ongoing.

FNADE, the French association of environmental services companies, welcomes the commission's new initiative to improve product performance as well as the information on this performance and thus help consumers make a reliable choice.

FNADE’s Feedback on regulation of the European Parliament and of the Council establishing a framework for setting Ecodesign requirements for Sustainable Products and repealing Directive 2009/125/EC June, 22 2022 FNADE, the French waste management and environmental services association, welcomes the proposal for Sustainable products.

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

Feedback to the Sustainable Products Initiative FNADE, the French association of environmental services companies, welcomes the commission's new initiative on sustainable products, which will lead to implement a coherent policy framework both on product environmental footprint and on consumers information.

FNADE, the French waste management and environmental services association, considers that the Commission’s proposal to set up a carbon border adjustment mechanism falls short of the tremendous opportunities that such a mechanism could have created. FNADE regrets the approach is only sectoral and not linked to the carbon content of products.

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

FNADE the French association for waste management and environmental services companies welcomes the Proposal of the European Commission to Review the Directive 2012/27/EU on energy efficiency aligning the energy efficiency targets with the 2030 EU climate ambitions. Please see document attached for FNADE's comments.

FNADE Feedback – Energy efficiency FNADE, the french association for waste management and environmental services, welcomes the European initiative for the Review of the Directive 2012/27/EU on energy efficiency.

FNADE, the french association for waste management and environmental services, welcomes the next review of the Construction Products Regulation and would like to suggest some improvements in order to facilitate the reuse and the recycling of construction materials. First of all, ecodesign is a necessary requirement to facilitate the deconstruction and dismantling of buildings.

2021.06.01 FNADE’s feedback on revision of CLP regulation FNADE, the French private companies waste management and environmental services association, very welcomes the revision of the CLP regulation to help achieve a toxic-free environment.

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

FNADE, the French association for depollution and environmental activities, welcomes the revision of the Energy taxation Directive (ETD). Indeed, the revision of this directive would better align it with the climate Green Deal’s objectives especially for promotion of renewable energies. It also would harmonize the way it is implemented in the different European countries.

FNADE's attached feedback to the call for evidence highlights that significant challenges remain in relation to traceability and certification requirements in the waste sector. FNADE calls on the European Commission to include much-needed simplification measures in its forthcoming Energy Omnibus proposal instead of waiting for a revision of the post-2030 framework.

FNADE’s Position Industrial emissions – EU rules updated June 2022 FNADE, the French association for waste management and environmental services welcomes the proposal of the European Commission for the Revision of Industrial Emissions Directive (IED) which has really helped to reduce for these last years the emissions of industrial activities in the air, water and soil.

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

Recent assessment of IED has shown both environmental benefits and also the need of some improvements. FNADE, representing the french recycling and waste management sector, would like to give some comments on the different options the commission has explored for modernizing IED: ● First of all, FNADE wants to underline IED is an adequate tool to reduce water and air emissions and to tackle the environment and health…

FNADE, the French association for waste management and environmental services, fully supports the revision of the End-of-Life Vehicles Directive that makes a clear link between design issues and end-of-life treatment aiming to improve recycling efficiency and that requires mandatory recycled content.

The Revision of Directive 2000/53/EC on end-of-life vehicles will lead to update this current legislation to economic reality and to improve coherence with the aims of the Green Deal and the Circular Economy Action Plan.

FNADE, the French association for recycling and waste management fully supports any initiative aiming to reduce the release of any hazardous substance in the environment. The proposal made by the European Commission for a specific regulation in order to reduce the release of microplastics along the value chain of plastics production, recycling, reprocessing and transporting should enable to reduce, as it is already…

FNADE’s Position Measures aiming at reducing the presence in the environment of unintentionally released microplastics from tyres, textiles and plastic pellets 18/01/2021 FNADE, the French association for waste management and environmental services would like to take the opportunity to give feedback and highlight some points.

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

1) We positively welcome the explicit mention that data must come from operational production and not from an industry average. Similarly, maintaining the prohibition of negative credits and the prohibition of credit exchange between sites or companies is positive. 2) Generally, the formulation proposed in the draft implementing decision goes against the principles of proportional traceability.

FNADE’s Feedback Waste shipment regulation review proposal FNADE, the French association for waste management and environmental services welcomes the European Commission’s proposal to review the Waste Shipment Regulation. FNADE used to ask the Commission to introduce technical improvements in order to reduce the too long delays for notification procedure.

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

FNADE welcomes the initiative of the European Commission for revising the WSR and supports, generally speaking, any initiative allowing to move towards more circular economy and recycling, even if in the case of the WSR it will have a limited effect due to the aim of the regulation. The latest evaluation of these procedures’ regulation has pointed out its relevance since its implementation.

The forthcoming technical guidance under Article 5 of the Performance Regulation is an important occasion to clarify the interpretation of the DNSH principle for circular economy as well as some concepts left undefined in the Taxonomy Regulation. Please find attached FNADE's contribution to this work.

FNADEs members support the revision of the UWWT Directive as it aims to better control urban water pollution with simple and clear objectives of results likely to limit distortions between Member States. It should also provide for local authorities an improved legal framework while tackling new societal challenges.

La FNADE fédération française des activités de gestion des déchets et des services à lenvironnement, soutient lobjectif de la Commission visant à établir des critères européens harmonisés de sortie du statut de déchet (SSD) pour les plastiques recyclés, afin de renforcer le marché intérieur des matières plastiques recyclées et la confiance dans les recyclats européens.

Feedback on the consumer policy – Empowering the consumer for the green transition FNADE, the french association for waste management welcomes this essential initiative that will invite each consumer to fulfill a role in the implementation of the Green Deal thanks to reliable and environmental sustainable information.

The attached paper sets out FNADE's position on the post-2030 revision of the Effort Sharing Regulation (ESR) and the broader EU climate framework towards 2040. It calls for the preservation of binding national targets for non-ETS sectors to ensure fair and accountable contributions by Member States.

FNADE, the French federation for waste management and environmental services, is the professional organisation representing the private resource and waste management industry. As a major player in the circular economy, the waste industry produces recycled materials, fertilisers and green energy, substituting natural resources and fossil fuels. It provides solutions to major environmental and climate challenges.

FNADE, the French waste management private companies association, welcomes the willingness of the European Commission to clarify the functioning of the European standards bodies (CEN, Cenelec and ETSI) and establish a certain balance in the representation of the national standards bodies.

FNADE’s feedback POPs regulation (Annexes IV et V) 2021/12/21 FNADE, the French association for waste management and environmental services, welcomes the European Commission’s proposal, in line with the provisions of the Convention of Stockholm, to update the annexes IV and V of Regulation 2019/1021 on Persistent Organic Pollutants (POPs).

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

FNADE, the french association for waste management and environmental services, welcomes amendments to the annexes of Regulation 2019/1021 on Persistent Organic Pollutants (POPs) in order to achieve a zero-pollution ambition and a non-toxic environment.

FNADE’s Position on reporting of environmental data from industrial installations and establishing an Industrial Emissions Portal (E-pRTR) June 2022 FNADE, the French association for waste management and environmental services welcomes the proposal of the European Commission for the Revision of the E-pRTR (European reporting data from industrial installations and establishing an industrial emissions portal).

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

Feedback to the Revision of the Regulation on the European Pollutant Release and Transfer Register (E-PRTR) FNADE, the French waste management and environmental services private companies’ association, welcomes the revision of the E-PRTR.

FNADE: position paper on SUP directive implementing act proposal FNADE, the French Waste Management association would like to take the opportunity to make some comments regarding the European Commission’s proposal on SUP directive guidelines: First, in the draft proposal the word “collection” in article 2, paragraph7 seems misused and seems to correspond more to “recycling”.

FNADE welcomes the European Commissions recent initiatives regarding the reclassification and the ban on nitrous oxide as of 1 February 2027, aimed at addressing the scourge of this substance as a public health, environmental and operational issue, while still allowing its continued use for legitimate purposes.