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
18
positions filed
in the 665 files tracked
17
legislative files
of 665 tracked
14
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 (57,800 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1107 non-governmental organisations on this site, they rank #51 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 15 Oct 2026).
- Register category
- Non-governmental organisations
- Head office
- Bonn, Germany
Self-declared to the EU Transparency Register (snapshot 15 Oct 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 18 positions between 19 May 2022 and 30 Jul 2026, across 17 of the 665 legislative files tracked here, attaching a full position paper 14 times.
2022 · 2 filed2023 · 1 filed2024 · 1 filed2025 · 7 filed2026 · 7 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
It is of utmost importance that we reach a massive global reduction of greenhouse gases (-45%) by 2030, and a carbon neutral society in the EU until 2050 the latest. We need to create a living and economic model that is socially acceptable and that respects planetary boundaries.
In the impact assessment of the Critical Raw Materials Act (CRMA), at least the following three points must be taken into account: 1. Prioritise sectors of the green transition with low possibilities to decrease resource demand: Before prioritising strategic critical raw materials for regulatory and non-regulatory measures like planned, potentials for reducing resource demand should be scrutinised per sector.
Germanwatch‘s respone to the draft revised European sustainability reporting standards We welcome several improvements in the revised ESRS standards: The reaffirmation of double materiality and the clarification of the materiality-of-information filter are central to ensuring that disclosures are both comprehensive and decisionuseful.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Germanwatch welcomes the proposal on the Corporate Due Diligence Directive (CSDDD). Such a European ‘supply chain law’ can become an effective tool to compensate for injustices in global economic relations, to strengthen the rights of people in producing countries and to contain the environmental and climate crisis.
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 already palpable climate emergency and the war of the oil- and gas-rich dictatorship Russia against Ukraine show: the continued reliance on fossil fuels is unsustainable. Europes coal, oil, and gas consumption is a major contributor to the climate emergency and a key enabler of illiberal tendencies in fossil fuelrich countries. It is thus a central cause of oppression, corruption, and wars.
Import pressures from China, due to growing Chinese overcapacity and reduced domestic demand due to the crisis, are threatening the transformation of European industry. In addition, there are diversion effects due to the US-China customs conflicts and possible dumping strategies.
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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