Health Care Without Harm Europe

Health Care Without Harm (HCWH) Europe welcomes the opportunity to feed into this Inception Impact Assessment proposal. We believe that the EU should commit to more ambitious climate and energy targets to limit temperature increases to 1.5°C and safeguard the environment, safety, and prosperity of people in Europe and worldwide.

The European Commission's proposed revision of the Medical Devices Regulation (MDR) marks an important step forward for European healthcare by requiring manufacturers to justify single-use labelling. This development reflects a long-standing call from healthcare providers and sustainability advocates to ensure that medical devices are reused when safe to do so.

Health Care Without Harm (HCWH) Europe welcomes the European Commission's proposed Packaging and Packaging Waste Regulation (PPWR). We cannot afford more delays and need strong and binding legislation on packaging and packaging waste that prioritises prevention and reuse. The targets must be ambitious and the legislation must be enacted without delay during the current parliamentary term.

Consultation response | Reducing packaging waste Health Care Without Harm (HCWH) Europe welcomes the opportunity to provide feedback on packaging requirements and other measures to prevent packaging waste. In the context of the new Circular Economy Action Plan (CEAP), presented by the Commission on 11 March 2020, this initiative is a promising continuation, recognising key issues and remaining gaps to deliver a more…

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

Health Care Without Harm (HCWH) Europe welcomes the opportunity to feed into this IIA. Our changing climate is already having a significant impact on our health through, for example, extreme weather events, changes in communicable diseases, and respiratory illnesses exacerbated by poor air quality. According to The Lancet, climate change is the “largest public health threat of the 21st Century”.

HCWH Europe supports the Commissions approach towards a greater inclusion of environmental provisions in the revision of the pharmaceutical legislation of the European Union. The proposed package takes into account the harm that the release of pharmaceuticals in the environment has and offers solutions to control and minimise the impact of pharmaceutical compounds, including new rules for Environmental Risk…

Health Care Without Harm (HCWH) Europe welcomes the opportunity to comment on the European Commission’s inception impact assessment on the evaluation and revision of the general pharmaceutical legislation that aims to ensure access to affordable medicines, foster innovation, and enhance security of supply in the framework of a stronger European Health Union.

Health Care Without Harm (HCWH) Europe welcomes proposals to enshrine the EU's ambition for climate neutrality by 2050 in law. Furthermore, we support aims to transform the way in which EU policies are made and to set the long-term vision for meeting the 2050 objective through all policies, in a socially-fair and cost-efficient manner. Pease find our full feedback in the attached file.

Health Care Without Harm (HCWH) Europe welcomes the initiative to review the EU waste framework and to decrease the negative environmental impacts of waste management. HCWH Europe agrees that the priority objective of the initiative should be to decrease waste generation altogether - this can be achieved by respecting the waste hierarchy and looking firstly at upstream solutions.

Health Care Without Harm (HCWH) Europe welcomes and supports the European Commission introducing a standard methodology for assessing products’ environmental impacts and requiring companies to substantiate environmental claims.

Health Care Without Harm (HCWH) Europe welcomes and supports the European Commission’s roadmap to make products on the European market more sustainable. We would like to take this opportunity to recommend embedding the following sustainability considerations into the Sustainable Product Initiative (please, see our detailed contribution in attachment): - Expand the scope of the Ecodesign Directive and sector…

Health Care Without Harm (HCWH) Europe welcomes the opportunity to feed into this Inception Impact Assessment proposal. We believe that the EU should commit to more ambitious climate and energy targets to limit temperature increases to 1.5°C and safeguard the environment, safety, and prosperity of people in Europe and worldwide.

Health Care Without Harm (HCWH) Europe welcomes the revision of the EU rules on food contact materials (FCMs). This roadmap provides an excellent opportunity to promote safe reusable and recyclable solutions, a reduction of the healthcare sector’s environmental impact, and ultimately improve the health of EU citizens. Our detailed contribution can be found in the PDF attached.

Health Care Without Harm (HCWH) Europe welcomes and supports the revision of the Non-Financial Reporting Directive and provides feedback to ensure that the future legislation contributes to the sustainable development agenda. The NFRD can support increased green investment, sustainable public procurement, and responsible consumption. Our detailed contribution can be found in the PDF attached.

The European Commission’s proposed initiative to reduce microplastic pollution is an excellent opportunity to introduce ambitious and binding mandatory regulatory action to address this issue. Urgent action is needed to address the increasing number of microplastics released in the environment and their health and environmental impacts.

Health Care Without Harm (HCWH) Europe welcomes and supports the European Commission’s initiative to promote more sustainable use of goods throughout their useful life through reuse and repair. Crucially, this initiative cannot be achieved without also addressing consumption of healthcare products.

We welcome the inception impact assessment of the WSR stressing the intention to stop exporting waste outside the EU and revisit existing rules. As stated in the EU Circular Economy Action Plan, review of EU rules on waste shipments will aim at restricting exports of waste that have harmful environmental and health impacts in third countries.

In the design of the new vision for aquaculture, the EU must adopt a One Health regulatory framework that prioritises the prevention of antibiotic resistance. The most critical interventions for ensuring the sector's sustainability include the need for accurate species-specific data, and mandating high-welfare environmental standards such as optimised stocking densities and effluent treatment to naturally reduce…

Health Care Without Harm (HCWH) Europe welcomes and supports the CEAP initiative to strengthen the role of consumers in the green transition by improving the availability of products environmental information and increasing protection against misleading claims. Regardless of which proposed policy option the European Commission agrees on, it is essential that healthcare products are considered.

Health Care Without Harm (HCWH) Europe appreciates the opportunity to provide feedback on the Inception Impact Assessment on the Revision of Regulation (EU) 2017/852 on mercury. An extremely toxic and persistent metal, mercury is one of the World Health Organization (WHO)’s top ten chemicals of major public health concern.

With CAP accounting for of the EU budget, its ambition to create a sustainable, high-quality food production across member states is a unique opportunity to strengthen antimicrobial stewardship in farming. Globally, around 70% of all antibiotics sold are used in food-producing animals, and trends suggest continued growth by 2030.

Health Care Without Harm (HCWH) Europe welcomes the opportunity to comment on the European Commission’s inception impact assessment on the European Pollutant Release and Transfer Register (E-PRTR) that aims to help achieve the objectives of the European Green Deal on biodiversity, circular economy, climate neutrality, and zero pollution.