maki Consulting GmbH

maki Consulting considers a Critical Raw Material (CRM) Regulation (including for Strategic Raw Materials (SRM)) to be a suitable way to address supply risk to societys demand for critical and strategic materials. In fact, it is arguably both more relevant and more meaningful than current indicators on Resource depletion overall that look into extraction speed vs. (global) stock.

maki Consulting welcomes the comprehensive legislation with its expansion to non energy-related products, its many options for measures to be selected and tailored for the specific product group (while considering the individual product’s characteristics).

We welcome the potentially far reaching and inspiring approach of a complete overhaul of the Ecodesign Directive, substantially deepening and broadening it. The Ecodesign Directive has very substantially helped to improve the environmental performance of a range of important energy-using (and to some extend energy-related) products on the EU market.

We welcome the draft Implementing Regulation as a key building block for the DPP system, and particularly its provisions on automatic verification, semantic conformity, versioning, qualified electronic seal, timestamping, and a DPP-version hash. These are essential for a decentralised, modern DPP architecture.

maki Consulting welcomes the publication of the draft Delegated Regulation establishing the methodology for the calculation and verification of the carbon footprint of electric vehicle batteries. We believe the methodology and data basis should be as robust as possible, ensuring valid comparisons. It should moreover incentivise companies to achieve best-in class, improving their products, including at suppliers.

maki Consulting GmbH welcomes the initiative and the substantial technical work undertaken for the future Delegated Act on intermediate iron and steel products. The attached evidence focuses on methodological and policy-design choices that should be tested in the Impact Assessment before the regulatory architecture is fixed.

maki Consulting sees improving the reliability and comparability of ESG ratings as a highly relevant aim at EU level (and beyond), given the complete lack of comparability and the heterogeneity of the reliability of the ratings.

A coordinated, integrated nutrient management plan is a very welcome, overdue framework to align existing and future policies to improve the overall performance of the agricultural sector, while considering non-agriculture N and P sources and losses as well.