German Environment Agency

All the views expressed are those of the Federal Environment Agency (UBA) and may under no circumstances be regarded as an official opinion of the Federal Ministry for the Environment, Climate Protection, Nature Conservation and Nuclear Safety (BMUKN) or the Federal Government of the Federal Republic of Germany.

Filed in German · English published by the European Commission

In the special report on public procurement in the EU, the European Court of Auditors concludes that, in the vast majority of Member States, strategic procurement is only implemented to a very limited extent, including environmental procurement (https://www.eca.europa.eu/ECAPublications/SR-2023-28/SR-2023-28_DE.pdf, p. 35 et seq.).

Filed in German · English published by the European Commission

The German Environment Agency has contributed to the development of the EU Taxonomy since its beginning, and welcomes the opportunity to give feedback. The EU Taxonomy was developed to provide corporates and financial market participants with standardized guidance on the sustainability or transitional nature of an economic activity.

The German Environment Agency welcomes the initiative for a Critical Raw Materials Act. As an environmental agency, we value the importance of a sustainable supply of critical raw materials, in particular, for many products and components of the green transition such as rare earth magnets (e.g. wind turbines, electric vehicles), lithium and cobalt (e.g.

German Environment Agency 12. November 2020 German Environment Agency III 1.3 Wörlitzer Platz 1 D-06844 Dessau-Roßlau Germany Feedback to the Sustainable Products Initiative Disclaimer: Any views expressed are the views of the German Environment Agency and may not in any circumstances be regarded as stating an official position of the German Federal Ministry for the Environment (BMU) or the Federal Republic of…

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

The German Environment Agency has the following comments on the proposed amendments to Regulation EU 2019/6 and the corresponding annex II due to the Biotech Act: i) Art. 136a, regulatory sandbox - The concept of the regulatory sandbox is complex.

The German Environment Agency (UBA) welcomes the opportunity to contribute to the Call for evidence on the Biotech Act II, a proposal for regulation prepared by the EU Commission (DG GROW). From an environmental policy perspective, the identified challenge of insufficient market uptake of bio-based innovations is closely linked to persistent market distortions, regulatory gaps, and widespread uncertainty about…

The Environmental Awareness Study 2024 is part of a biennial series that has been conducted since 1996 to assess environmental awareness and attitudes toward environmental policy among the German population. The core of the study is a representative population survey in Germany.

The German Environment Agency welcomes the initiative of the Commission to investigate measures to tackle unintentional release of microplastics, including to increase the capture of microplastics at all relevant stages of products’ lifecycle. With the three areas tyre abrasion, pellet loss and synthetic textiles very significant sources are considered.

According to the Conversio study Current Status and Forecast of Demand and Availability of Post-Consumer Recyclates in 2030 there will be a gap of recycled plastics with respect to mandatory requirements for packaging but also for future mandatory requirements in other sectors and for voluntary use.

Thank you for providing the opportunity to give feedback on the envisaged Advanced Materials Act and its purpose. In our opinion, advanced materials (AdMa) can play a pivotal role for providing technical solution in strategic areas needed for the societal and industrial transformation, including renewable energies, improved circularity, more sustainable products and procedures, but potentially also to reduce…

The German Environment Agency is the agency responsible for environmental risk assessments of biocidal active substances and products in Germany. We welcome the initiative of the European Commission to evaluate the Biocidal Products Regulation (BPR). While the BPR undoubtedly already reduced emissions of biocidal active substances into the environment, we see room for some improvements.

The German Environment Agency would like to provide feedback on the following topics regarding Regulation 1223/2009 on cosmetic products: - Preservatives in cosmetic products - Definition of nanomaterials - Surfactants in rinse-off cosmetic products - Environmental labelling of cosmetic products The detailed comments can be found in the attached document.

The objectives set out in the CSS, in line with the relevant Council Conclusions, set the path towards a safer and more sustainable management of chemicals. Information on substance properties and conditions of production, processing and use is crucial for the sound assessment and management of chemicals.

Note: Any views expressed are the views of the German Environment Agency and may not in any circumstances be regarded as stating an official position of the German Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection or the Federal Republic of Germany.

The German Environment Agency welcomes the initiative to improve the environmental protection from chemicals used in cosmetics under the Cosmetic Products Regulation (EC) 1223/2009. Preservatives used in cosmetics currently do not fall under any environmental risk assessment comparable to other preservatives used for the preservation of manufactured products.

Thank you for the opportunity to comment on the Commission’s proposal to amend the Water Framework Directive (WFD) and its daughter directives. We welcome many of the proposals to update Directive 2008/105/EC (EQD) and Directive 2006/118/EC (CSD). We do not all consider the proposed amendments to the WFD to further protect against pollution to be useful. Please refer to the attached document for details.

Filed in German · English published by the European Commission

We would like to thank you for the opportunity to participate in the public consultation. We see potential for discussion on the following 3 points. 1) In our opinion, Article 1 lacks a definition of intended use and a classification as application of a specific area of law.

In the past years, several studies (e. g. https://www.aok.de/mk/cms/fileadmin/user_upload/AOK-BW/CSR_Info_Hub/Policy_Paper_Sustainable_supply_of_pharmaceutical_products_AOK.pdf) have shown that fluctuant and peak concentrations of pharmaceuticals in the environment can be attributed to emissions from pharmaceutical production processes, often unintentionally.