We support the intention of the proposed Act but recommend two critical modifications to its scoping. The proposed Act conceptualizes raw materials as mining and lightly processed minerals, but the just transition requires materials that are often highly processed into alloyed ingots before any manufacturing or fabrication can be done.
NOM
NomoGaia
Academic / research · United States
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts — staff, costs, accreditations — are not available for it.
2
positions filed
in the 639 files tracked
2
legislative files
of 639 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 639 consultation files tracked so far (53,766 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
NomoGaia filed 2 positions between 23 May 2022 and 18 Nov 2022, across 2 of the 639 legislative files tracked here, attaching a full position paper 2 times.
What they argued
NomoGaia Comments on EU Directive on Corporate Sustainability Due Diligence Nomogaia submits the following comments on the Proposal for a Directive of the European Parliament and the Council on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937, dated 23 February 2022 (the “Draft Directive”). Nomogaia is a non-profit research organization devoted to business and human rights.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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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.
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