Comments from the Nordic Swan Ecolabel to the Circular Economy Act - Call for evidence for an impact assessment Nordic Ecolabelling supports the EU Commissions proposed Circular Economy Act. Especially the focus on increasing the use of recycled material and setting mandatory, targeted, impactful and implementable criteria for public procurement of circular goods is highly supported.
NE
Nordic Ecolabelling
Other · Sweden · EU Transparency Register 938600495462-85
11
positions filed
in the 665 files tracked
11
legislative files
of 665 tracked
8
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 171 other organisations on this site, they rank #16 by legislative files engaged, a count of participation, not a measure of influence.
1.6
declared lobbying FTE
self-declared
€10K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2025
in the register since
Declares membership of
- Membership Global Ecolabel Network (GEN) https://globalecolabelling.net/
- Nordic Council of ministers has established nordic Ecolabelling https://www.norden.org/da/nordisk-ministerraad?gad_so…
- Unofficial network with regional or national officially recognised Type 1 Ecolabel Blauer Engel (https://www.blauer-e…
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Other organisations
- Registered as
- Foreningen Nordisk Miljømærkning
- Head office
- Stockholm, Sweden
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Nordic Ecolabelling filed 11 positions between 15 Jun 2022 and 30 Mar 2026, across 11 of the 665 legislative files tracked here, attaching a full position paper 8 times.
2022 · 2 filed2023 · 2 filed2025 · 5 filed2026 · 2 filed
What they argued
The use of ecolabels in public procurement is governed by Article 43.The conditionsin Article 43, paragraph 1 (a), however,mean that inpracticeit isvery difficultfor public authoritiesto require that a product or serviceiscertified with an officiallyrecognizedISO 14024Type I ecolabel such as the Nordic Swan Ecolabel or the EU Ecolabel.
Nordic Ecolabelling (NE) welcomes initiatives aimed at reducing the climate footprint of carbon-intensive raw materials. However, NE stresses the importance of considering the following points: Alignment with existing EU legislation: NE highlights the need for new legislation to be consistent with existing EU frameworks, particularly following: ESPR introduces rating systems and sets minimum requirements for…
The PPD aimed to promote sustainability, stating in the second recital that public procurement should serve as an instrument for achieving smart and sustainable growth while ensuring the most efficient use of public funds. However, its complexity has led to interpretations that hinder public authorities from leveraging its potential.
Stockholm, 14. April 2023 Nordic Ecolabelling feedback on the EU Commissions proposal for a regulation on packaging and packaging waste Thank you for the proposal for a regulation on packaging and packaging waste and the possibility to give feedback.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Nordic Ecolabelling highlights a Report only once approach when demonstrating Taxonomy compliance. This would boost competitiveness as it would make it easier for European companies to operate at the European market. We therefore suggest that alignment with the Taxonomy can be verified by an officially recognized ISO 14024 type I Ecolabel certificate, such as EU Ecolabel and Nordic Swan Ecolabel.
Stockholm, 6. July 2023 Nordic Ecolabelling feedback on the EU Commissions proposal for a directive on Green Claims Thank you for the proposal for a directive on substantiation of explicit environmental claims (Green Claims Directive). Consumers and businesses are powerful forces in the green transition.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Stockholm, 15. June 2022 Nordic Ecolabelling feedback on the EU Commissions proposal to extend the existing Ecodesign framework Thank you for the proposal to extend the existing Ecodesign framework and the possibility to give feedback.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Stockholm, 28. June 2022 Nordic Ecolabelling feedback on the EU Commissions proposal for a Regulation laying down harmonised conditions for the marketing of construction products Thank you for the proposal for a Regulation laying down harmonised conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011 and the possibility to give feedback.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Nordic Ecolabellinghighlightsa Report only once approach whendemonstratingTaxonomy compliance. This wouldboost competitivenessas it would make it easier for European companies tooperateattheEuropean market. We thereforesuggest thatalignment with the Taxonomy can be verified by an officially recognized ISO 14024 type I Ecolabel certificate, such as EU Ecolabel and Nordic Swan Ecolabel.This would also be in line with…
Nordic Ecolabelling believes that there is a need to harmonize calculation methods. Rules for mass balance should be implemented with high caution, and they should be simple to apply and verify and based on controlled blending (proportional allocation at product level), enabling credible sustainability claims.
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Turns up on the same files
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.