NABU

FEEDBACK TO CALL FOR EVIDENCE Circular Economy Act NABU (The Nature and Biodiversity Conservation Union), is the biggest environmental NGO in Germany with around 960,000 members and 70,000 active volunteers. We welcome the European Commission’s plan to propose a Circular Economy Act (CEA) and thank for the opportunity to comment on this call for evidence.

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

Opinion of the NABU (Naturschutzbund Deutschland) e.V. on the electrification of corporate fleets The decarbonisation of the transport sector is a key part of Europe’s climate objectives. Corporate fleets play a key role in this: They account for a significant share of over 66 % of new registrations in Germany, significantly influence the strategic direction of the automotive industry and determine which vehicles…

Filed in German · English published by the European Commission

NABU (Nature and Biodiversity Conservation Union) is the biggest German ENGO with almost one million members and supporters. NABU thanks the EU Commission for the opportunity to give feedback on the Renewable Energy Framework. Please see the NABU feedback attachted.

Filed in German · English published by the European Commission

We welcome the call for evidence and would like to provide feedback on it. The poor environmental status of the seas highlights the need for action to reduce implementation gaps in marine protection and better manage uses.

Filed in German · English published by the European Commission

NABU welcomes the opportunity to submit a statement as part of the consultation on the Implementing Decision for the application of Directive (EU) 2019/904. This Decision specifies the implementation of the product requirements of the SUPD (Article 6) on the minimum content of recycled plastic in beverage bottles.

For NABU as the biggest German eNGO, the EUs CO2-emission standards are a central pillar of the climate and industrial policy for the automotive sector. Its trajectory has created planning-security for the automotive industry and the emobility value chain to make the necessary investments and plan the transition. The regulation includes timely review dates to adapt the instrument if needed.

The NABU is grateful for the opportunity to comment on the European Commission’s planned amendment of Annex III to the Nitrates Directive. The NABU takes the view that the associated increase in the permitted amount of nitrogen fertiliser applied by an additional 100 kg N/ha to a total of 270 kgN/ha per year should be rejected as a matter of urgency.

Filed in German · English published by the European Commission

The German Nature Conservation Association (NABU) e.V., on behalf of its more than 940,000 members and promoters, advocates the ambitious development and implementation of an EU-wide forest monitoring framework providing open access to detailed, accurate, regular and timely information on the state and management of EU forests, as well as on the many forest products and ecosystem services.

Filed in German · English published by the European Commission

Ladies and gentlemen, the NABU Bundesverband expressly welcomes the European Commission’s initiative to develop in a timely manner a guidance document on the designation of the acceleration areas and to incorporate input and experience from the Member States.

Filed in German · English published by the European Commission

In order to ensure climate protection in the EU in a sustainable manner, a robust, nature-friendly and economically viable set of rules with binding national and sectoral emission reduction targets is needed by 2040, guided by an ambitious and science-based greenhouse gas budget.

Filed in German · English published by the European Commission

The LULUCF sector is the key sector not only in the transition towards the EUs net zero emissions targets, but also in terms if biodiversity protection. The potential benefit LULUCF alterations offer in combating both climate and biodiversity crisis are vast.

NABU (Naturschutzbund Deutschland) e.V. is grateful for the opportunity to comment on the draft implementing decision. NABU opposes the inclusion of the Indian ship recycling facilities YSI Recyclers LLP and Shree Ram Vessel Scrap Pvt. in the 16th EU list of ship recycling facilities.

Filed in German · English published by the European Commission

A simplification of the CAP is urgently needed, but it must not come at the expense of existing environmental standards. From a nature conservation perspective, the proposed Omnibus Regulation undermines EU environmental protection.

We welcome the long-awaited review of the Ecodesign regulation of air heating and cooling products covered by EU 2016/2281 and similar products that could also be in the scope of Ecodesign rules. We support the position paper of ECOS/EEB/Coolproducts.