Thank you for the opportunity to provide feedback on the revision of the ESRS. Concerning AR 20 for paragraphs 29 and 30: Under existing EU legislation (RED, EED, EPBD, ..) waste heat is recognised as zero-emissions energy. However, ESRS E1 rely on the GHG Protocol, which does not reflect this approach. This creates inconsistencies in reporting, legal uncertainty, different interpretations by auditors, ...
IND
Indaver
Company · Belgium · EU Transparency Register 214004193485-45
4
positions filed
in the 665 files tracked
4
legislative files
of 665 tracked
0
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 (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1210 companies & groups on this site, they rank #400 by legislative files engaged, a count of participation, not a measure of influence.
1.8
declared lobbying FTE
self-declared
€200K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2024
in the register since
Declares membership of
- CEWEP (Confederation of European Waste-to-Energy Plants):
- www.cewep.eu
- EURITS European Union for Responsible Treatment of Special Waste
- www.eurits.org
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Companies & groups
- Registered as
- Indaver Holding (Indaver)
- Head office
- Mechelen, Belgium
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Indaver filed 4 positions between 10 Jul 2025 and 2 Jun 2026, across 4 of the 665 legislative files tracked here.
2025 · 1 filed2026 · 3 filed
What they argued
We thank you for the opportunity to contribute input to the revision of the Renewable Energy Directive for the post2030 period. We propose that alongside a logical focus on renewable energy, sufficient attention is also given to the use of waste heat. Waste heat is generated as a by-product in different processes (such as waste incineration).
We thank you for the opportunity to contribute input to the revision of the Energy Efficiency Directive for the post2030 period. We like to to highlight the dilemma our sector (waste incineration) is currently facing.
Dear Committee As a member of CEWEP and speaking on behalf of Indaver, a pioneer in advanced materials recovery and sustainable waste management, we applaud the European Commission's initiatives to improve the EU's resilience and circularity by identifying waste streams with the potential to recover critical raw materials (CRM), as specified in Regulation (EU) 2024/1252.
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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.
Showing 5 of 105.
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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.