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)

FEEDBACK TO CALL FOR EVIDENCE EU Public Procurement Rules – Revision NABU (The Nature and Biodiversity Conservation Union), is the biggest environmental NGO in Germany with around 960,000 members and 70,000 active volunteers. NABU welcomes the European Commission’s plan to revise the rules on EU public procurement and thanks 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)

Thank you for the opportunity to comment on the PPWR draft. Please find attached NABU's feedback. Information on NABU: Founded in 1899, NABU (Nature And Biodiversity Conservation Union) is the oldest and largest environment association in Germany.

The NABU considers the measures planned by the European Commission to be useful and urgently necessary in order to minimise the negative environmental impacts of packaging and packaging waste (e.g. CO2 emissions from waste incineration, aquatic and terrestrial pollution from littering, biodiversity loss due to extraction of raw materials).

Filed in German · English published by the European Commission

Doubling the renovation rate of buildings is key for Europe to reach its higher climate targets, to kickstart a green recovery from the current economic crisis and to provide modern, healthy and comfortable places to live and work for all Europeans. We therefore strongly endorse the Renovation Wave agenda and welcome the EPBD revision.

The NABU welcomes the Commission’s proposal for the EU climate law, which makes greenhouse gas neutrality legally binding. It is important and correct that, during and after the pandemic, the EU sends strong signals for a climate neutral economy within Europe, but also towards other parties to the Paris Agreement.

Filed in German · English published by the European Commission

NABU welcomes the European Commission’s initiative for a Climate Law that makes the EU climate targets legally binding and underlines the commitment of the EU and its member states to the Paris climate targets. The success of the law will depend on the ability to deliver cuts of greenhouse gas emission in the short term, and on the effort to address the climate and biodiversity crises jointly.

The Nature and Biodiversity Conservation Union (NABU) welcomes the Commission's proposal for a revision of the Waste Framework Directive. However, we regret the lack of ambition regarding the volume reduction of the targeted waste streams and would like to point out that the proposed targets for food waste reduction are too low.

NABU welcomes the revision of the EU Waste Framework Directive and advocates an ambitious revision. While the existing Directive lays down the waste hierarchy as a guiding principle for managing waste in a resource-efficient way, it does not lay down specific requirements for waste prevention or re-use.

Filed in German · English published by the European Commission

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

The planned revision of the Energy Taxation Directive is an excellent carbon pricing tool, which could help putting the transport sector back on track to achieving climate neutrality by 2050. If deployed in the right way, ETD can help influencing sustainable investment choices by sending right pricing signals. ETD should thereby reflect external costs related to C02 impact by applying the Polluter Pays Principle.

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

Dear EC! NABU welcomes the initiative for binding restoration targets and recommends the following: A. Aspects guiding the next steps 1. With this restoration initiative, the Commission should focus on binding nature restoration targets. 2. The also mentioned possibility of an EU wide methodology to map and assess ecosystems and their delivery on soil, pollination etc.

The NABU encourages the Commission to implement its plans set out in the Inception Impact Assessment in a binding, ambitious and timely manner. These include important steps towards safe food packaging, a non-toxic circular economy and the environment. From the perspective of the NABU, it is necessary to create a new regulatory framework (“Option 2”) for FCMs.

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

The nature crisis is accelerating, and public attention drifts elsewhere with serious consequences. According to the latest analysis from the Stockholm Resilience Centre on planetary boundaries, the loss of biodiversity has already pushed ecosystem integrity beyond safe limits. This decline continues, increasingly endangering the ecological processes and services on which human well-being relies.

NABU (Nature and Biodiversity Conservation Union) is the biggest environmental NGO in Germany with more than 800.000 members and supporters. NABU welcomes the European Commission’s (EC) proposal for a revision of the EU CO2 standards for cars and vans. The transport sector is the only sector in which emission were not reduced since 1990.

NABU welcomes the Commission’s initiative to reduce non-initiated microplastics emissions. In accordance with the precautionary principle, any emissions into the environment of plastics which are not demonstrably readily degradable in the surroundings must be prevented.

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.

NABU recognizes the European Commission’s initiative for further action on the decarbonisation of transport through the proposal of the Alternative Fuel Infrastructure Regulation (AFIR) ‘Low-emission vehicles – improving the EU’s refueling/ recharging infrastructure’.

NABU supports the introduction of a mandate for specific sustainable advanced fuels in the aviation sector, but only if certain conditions are met for such a mandate to provide both a clear environmental benefit and investor certainty.

With more than 875 000 members and funders, NABU, founded in 1899, is the oldest and largest environmental association in Germany. NABU welcomes the initiative on “Sustainable consumption of goods and the promotion of repair and reuse”.

Filed in German · English published by the European Commission

NABU welcomes the planned stricter regulation of waste shipments, in particular with regard to plastic waste, the export of which poses significant environmental risks. The revision of the EU Waste Shipment Regulation will make it more difficult in future to export plastic waste to countries with little developed recovery structures.

Filed in German · English published by the European Commission

The NABU welcomes the increased regulation of waste exports from the EU to non-EU countries. Not least through media reporting and NGO work, the devastating environmental and social consequences of waste exports to countries with low recovery infrastructure have become evident. Examples include exports of plastic waste to Asia and exports of waste electrical equipment to Africa.

Filed in German · English published by the European Commission

NABU welcomes the proposal for the revised TEN-E Regulation. The European Commissions` decision to take out the energy infrastructure categories for gas projects and oil transport projects is a necessary step forward. A study by Artelys (2020) found that existing gas infrastructure is able to meet future gas demand scenarios.

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

We welcome the strengthening of the LULUCF regulation with the aim to protect and restore the forests needed to sequester carbon dioxide in the effort to keep climate change below 1.5 degrees. However, this must not lead to a decrease of efforts to reduce emissions in other sectors with the hope of off-setting them through LULUCF removals.

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

NABU recognizes the European Commission’s initiative for further action on the decarbonisation of shipping in the FuelEU Maritime proposal ‘CO2 emissions from shipping – encouraging the use of low-carbon fuels’. Being responsible for over 2 percent of the global greenhouse gas emissions each year, the international shipping sector offers immense potential for emissions reductions.

NABU supports the EC’s initiative to develop a regulation to foster the uptake of sustainable alternative fuels (SAF) for ships. The fast uptake is necessary to achieve the Paris Agreement Climate Goals. The sustainability of e-fuels needs to be safeguarded by criteria. SAF must be entirely based on renewable electricity. We expect the SAF production costs to remain higher than the fossils even in the long term.

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

Feedback on the commission proposal amending Regulation (EU) 2019/1242 as regards strengthening the CO emission performance standards for new heavy-duty vehicles and integrating reporting obligations, and repealing Regulation (EU) 2018/956 by NABU NABU (Nature and Biodiversity Conservation Union) is the biggest environmental NGO in Germany with more than 900.000 members and supporters.

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.

Dear Madame/Sir, As an organisation working on protecting the environment we know about the importance of access to justice for ensuring compliance with EU law and to address the ecological crisis, both at Member State and EU level. We therefore very much welcome the European Commission consultation on the Roadmap. We would like to stress the following points: A.

The EU POPs Regulation should respect the objectives and requirements of the Stockholm Convention. We think that some of the limits for POPs in waste, as set today, are too weak and do not hinder the circulation of POPs in reused materials and recycled products.

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.

Life is the best instrument for environmental and climate action projects among all EU funding programmes. It is particularly important for civil society actors. In the field of nature and biodiversity, it is the only programme that has proven to have contributed to the implementation of Natura 2000 and to the improvement of the conservation status of protected habitats and species.

Filed in German · English published by the European Commission

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.