Green Transition Denmark

In Green Transition Denmark, we clearly support circular economy and the thought that waste is reduced and goods are re-used and recycled as much as possible. However, it is very important to be aware of the limitations – hazardous chemicals. This can in many cases be a big problem, e.g.

31-03-2022 CONSULTATION RESPONSE: THE EUROPEAN COMMISSION'S DRAFT REVISION OF EPBD Green Transition Denmark would like to thank for the Opportunity to comment on the European Commission's proposal for the revision of Energy Performance of Buildings Directive (EPBD). Overall, we believe that stronger regulation of the building sector is needed to ensure that the goal of climate neutrality by 2050 can be achieved.

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

ETS1 and ETS2 must be extended to agriculture to ensure effective carbon pricing in this sector (see "Position paper on future EU climate regulation architecture") ETS1 must be extended to cover the climate impact of wood-energy (see "Position paper on future EU climate regulation architecture") Fossil fuel inputs into the production of plastic and chemicals must be covered by ETS1 (See: "Position paper on future EU…

Green Transition Denmark welcomes the opportunity to provide feedback on the Commissions proposal for CRCF. CARBON FARMING IS ILL-SUITED FOR CERTIFICATION The definition of carbon farming needs to be clarified. Emission reductions from the land sector can be certified as removals under the current definition of carbon farming, which is counterfactual and goes against the findings of the Impact Assessment.

In Green Transition Denmark we welcome the European Commission's proposal to revise the Construction Products Regulation (CPR), underlining the effort to align it with the environmental principles included in the Eco-design Regulation for Sustainable Products (ESPR). The proposal doesn't deliver enough.

Green Transition Denmark (Rådet for Grøn Omstilling) welcomes the draft proposal for a revision of the CLP legislation and greets the intentions behind the proposal in order to modernise the legislation and make it more protective, efficient, and coherent.

Green Transition Denmark (GTD) welcomes the opportunity to provide feedback on the Commission’s discussions of the revision of EU’s CLP Regulation. GTD is a Danish NGO working to promote a green and sustainable transition of society. CLP is an essential tool to regulate hazardous chemicals. However, it needs to be updated to sufficiently support the implementation of the new Chemicals Strategy of Sustainability.

Revision of the Renewable Energy Directive Green Transition Denmark (GTD) appreciates the opportunity to provide evidence regarding the revision of the Renewable Energy Directive (RED). GTF generally is in favor of keeping the Renewable-only Energy Directive as a backbone of the post-2030 Energy Union, with a binding EU renewable-only 2040 target to rapidly reduce dependency on energy imports and meet climate…

Green Transition Denmark welcomes the opportunity to provide comments on the European Commission Roadmap on the revision of EU rules on Food Contact Materials (FCMs). We have four overall points we consider essential: 1) The EU needs to ban all hazardous chemicals in all FCM to honour the commitments of the Green Deal and the new Chemicals Strategy for Sustainability (and not partial regulations, such as BPA).

Green Transition Denmark (GTD) welcomes the opportunity to provide feedback on the Commission’s discussions of the revision of EU’s REACH chemicals regulation. GTD is a Danish NGO working to promote a green and sustainable transition of society. We have many years of experience with the chemicals area and have especially focus on endocrine disrupters and other areas that are not covered by the REACH legislation.

No to an increase of nitrogen on agricultural fields We are in favour of substituting artificial fertiliser with manure or products made from manure. And we are so, no matter whether it is because the artificial fertiliser is based on fossile fuels, or because it is produced in Russia.

We thank you for submitting comments on the proposal for the revision of the LULUCF Regulation. The RGO notes with satisfaction that the revision implies a future target for sinks in the LULUCF sector at EU level, which is burdened to Member States.

Filed in Danish · English published by the European Commission

National targets and flexibilities in the EU climate policy framework after 2030 Green Transition Denmark (GTD) proposes a major reshuffle of the legislative framework securing achievement of the EU 90% climate target for 2040.

EU air quality limit values must (at least) be aligned with WHO Air Quality Guidelines and fulfilled by 2025. Hence, all EU directives and regulations that can improve air quality must be aligned to fulfill the WHO Air Quality Guidelines from 2025.