Germanwatch welcomes the Circular Economy Act but urges a broader approach beyond recycling to unlock the potential of circularity for resource protection, resilience, more independence from insecure raw material imports and the innovation potential for the European industry. Demand-side measures (reducing material use) must accompany supply-side strategies (strengthening recycling) to improve circularity rates.
GER
Germanwatch
NGO · Germany · EU Transparency Register 99203901869-52
12
positions filed
in the 326 files tracked
12
legislative files
of 326 tracked
9
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 784 non-governmental organisations on this site, they rank #26 by legislative files engaged — a count of participation, not a measure of influence.
0.4
declared lobbying FTE
self-declared
—
declared costs / yr (floor)
1
EP accreditations
as declared to the register
2009
in the register since
Declares membership of
- https://www.germanwatch.org/de/netzwerk
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026).
- Register category
- Non-governmental organisations
- Head office
- Bonn, Germany
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Germanwatch filed 12 positions between 10 Jul 2024 and 30 Jul 2026, across 12 of the 326 legislative files tracked here, attaching a full position paper 9 times.
2024 · 1 filed2025 · 5 filed2026 · 6 filed
What they argued
POLITICS & SOCIETY Ref. Ares(2026)6203364 - 18/06/2026 DISCUSSION PAPER No Competitiveness without Decarbonisation Industrial Accelerator Act : Future-proof investments require a strong demand signal Amid the events of recent weeks, one point has become clear: Europe, and Germany in particular (as its most important industrial nation), must ramp up investment in the resilience of its industrial value chains whilst…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Given the weak demand and the threat of a customs conflict with Trumps USA, the EU and Germany should boost domestic demand for climate-friendly products by smartly linking green lead markets and regional procurement. This reduces dependence on exports and is good for value creation, jobs and climate protection.
Filed in German · English published by the European Commission
As corporate vehicle fleets are important for the uptake of electric vehicles and thus key for both achieving the EU climate goals and a competitive European and German automotive industry, Germanwatch supports the Commissions initiative for decisive legislation.
Germanwatch welcomes the European Commission’s current reform initiative, in particular with regard to downstream scope expansion and the prevention of CBAM circumvention. However, the established timetable for CBAM implementation, together with the parallel phased reduction of the free allocation of emission permits, should be maintained.
Filed in German · English published by the European Commission
The current draft does not effectively meet the goals of the SUPD, especially when it comes to environmental protection and promoting a circular economy. As Recital 13 states, [..] the objective of the targets is to promote the market uptake of recycled plastic, with the aim to ensure the circular use of plastics [..].
Germanwatch welcomes the introduction of an EU aviation strategy. The ongoing cli-mate crisis, geopolitical rifts and tensions as well as shifting global economic roles re-quire strategic answers, to ensure a sustained and truly sustainable European aviation sector: An economically resilient aviation sector which serves European citizens in an equitable manner, while maintaining ecological limits and achieving…
Important questions on project building and integration of international certificates into the EU climate architecture and Germanwatch leitmotiv proposals: International CO2 allowances should be used as a tool for global climate cooperation and ambition-enhancing. Generally: Possible areas of use for Article 6 (current, i.e.
Filed in German · English published by the European Commission
The EU is not on track to meet LULUCF targets The EUs forests, peatlands, wetlands and grasslands are critical for the protection of Europes biodiversity, water, and soils. They are also crucial sinks, and thereby deliver an essential part for achieving the EUs greenhouse gas targets.
As civil society organisations supporting a strong and attractive European rail system to enable citizens and transport to shift from air and road to rail, Europe on Rail welcomes and supports the European Commissions proposal for a Rail Ticketing Regulation.
As civil society organisations supporting a strong and attractive European rail system to enable citizens and transport to shift from air and road to rail, Europe on Rail welcomes and supports the European Commissions proposal for a Rail Ticketing Regulation.
Europe is facing challenges of strategic autonomy, resilience, competitiveness and decarbonisation. In response to these challenges, Europe on Rail recommends an upgraded mandate for the European Union Agency for Railways.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
- Cefic · 7 files in common
- Transport & Environment · 7 files in common
- IDEE ECONOMICHE www.idee-economiche.it · 6 files in common
- Bioenergia ry - the Bioenergy Association of Finland · 6 files in common
- European Environmental Bureau · 5 files in common
Showing 5 of 423.
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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.