SUEZ

As a major player in the circular economy for more than 160 years, SUEZ recognizes that the EU is at a critical turning point. The EU must either maintain its leadership in the environmental transition or risk losing ground to non-EU countries, both in manufacturing and in material sourcing. The competitiveness of the EU industry as a whole is essential.

SUEZ welcomes the Commissions objective to strengthen the EU industry and to stimulate demand for low-carbon products through the creation of lead markets under the Industrial Accelerator Act (IAA). Incentivising circularity and recycling is a key tool to reach these objectives.

SUEZ, European provider of water waste management services, holds public contracts and concessions awarded by public authorities to deliver essential services to European citizens. Since their adoption in 2014, the European directives governing public procurement have established key principles of transparency, competition and equal treatment that benefit economic operators, users of water and sanitation services…

INTRODUCTION As a major player in the waste and water management sector, SUEZ intends to take an active part in the second consultation launched by the European Commission on the EU taxonomy environmental and climate delegated acts to update and simplify both the technical screening criteria (TSC) and do not significantly harm criteria (DNSH).

SUEZ welcomes the opportunity to contribute to the revision of the EU Taxonomy environmental and climate delegated acts. While supporting the Taxonomys ambition to guide sustainable investments, SUEZ highlights challenges that could undermine its effectiveness, including overly complex criteria, heavy administrative workload, and misalignment of criteria and technical thresholds with operational realities.

SUEZ welcomes the ambition of the European Union to accelerate the uptake of zero-emission vehicles in corporate fleets. Indeed, SUEZ manages a fleet of 9,868 light vehicles in France (3,958 company cars and 5,910 operational vehicles), making SUEZ one of the top 10 best equipped French companies. In 2024, more than 1,800 vehicles were renewed, including 25% plug-in hybrid vehicles.

SUEZ welcomes the Commissions consultation on the upcoming revision of the Carbon Border Adjustment Mechanism (CBAM). The CBAM is a necessary instrument to protect the European industry and support its decarbonization efforts. However, its current scope still leaves room for improvement, as it enables loopholes that could undermine its effectiveness.

SUEZ views the EU Biotech Act II as a major opportunity to strengthen Europes industrial biotechnology sector, accelerate the deployment of bio-based solutions, and improve the EUs competitiveness and strategic autonomy.

SUEZ welcomes the opportunity to provide insights and proposals to the consultation concerning the 2030-2040 legal framework for renewable energy. As a key player in waste and water management in Europe, SUEZ supplies reliable, domestic renewable energy through biogas biomethane and biofuels from biowaste, biobased liquid wastes, non-recyclable waste containing biomass fractions, as well as refuse-derived fuel…

As a major player in the waste and water management sector, SUEZ intends to take an active part in the second consultation launched by the European Commission on the EU taxonomy environmental and climate delegated acts to update and simplify both the technical screening criteria (TSC) and do not significantly harm criteria (DNSH).

Executive summary SUEZ welcomes the European Commissions proposal on the implementing decision on the recycled plastic content in single-use plastic beverage bottles. In this position paper SUEZ wants to highlight some remarks on the proposed legislation.

SUEZ welcomes the opportunity to contribute to the call for evidence on the revision of Annex VI of the Renewable Energy Directive. As a major European player in environmental services, SUEZ operates across the entire waste management value chain, including the production of renewable energy through anaerobic digestion and biomethane valorization.

Europe benefits from one of the world's most advanced water research and innovation (R&I) ecosystems and is a global leader in water-related technologies. Yet the challenges facing the European Union today, including climate change, increasing water scarcity, tighter environmental standards, industrial competitiveness, and strategic autonomy, require a shift in priorities.

Digital solutions play a crucial role in strengthening water management, resilience, and sustainability across Europe. They improve water-use efficiency, enable predictive maintenance, enhance service continuity, and support pollution detection and management.

SUEZ, as a company involved in the recycling of aluminum in Europe, welcomes the opportunity to provide feedback on the call for evidence on trade measures aimed at ensuring sufficient availability of aluminium scrap on the EU market. While sharing the objective of strengthening the European aluminium value chain, SUEZ is firmly opposed to the adoption of any restrictive measures on aluminium scrap exports.

SUEZ welcomes the European Commissions initiative to establish a European Critical Raw Materials Centre (CRM-C) and wishes to contribute to it as a key industrial player in metal recycling in Europe. Through its Recycâbles facility in northern France, SUEZ recycles end-of-life electrical cables and produces high-purity secondary copper, a strategic raw material as defined under the Critical Raw Materials Act (CRMA).

As the Commission undertakes this evaluation, we believe it is essential that the Regulation keeps pace with strengthened European ambitions on circularity, bioeconomy and sovereignty. Currently, the Regulation has not yet achieved its objective related to the creation of a market for organic fertilisers.

SUEZ welcomes the opportunity to contribute to the European Commissions public consultation on the definition of low-carbon steel. For 125 years, SUEZ has been creating value from steel across the entire value chain, from stamping operations to recycling, helping to reduce logistics, operational and environmental costs.

SUEZ welcomes the classification of nitrous oxide as a category 1B reproductive toxicant under the CLP Regulation and supports the subsequent restriction under REACH as proposed by the European Commission. SUEZ fully supports the proposed REACH restrictions, in particular on large NO canisters, which have proven to be a significant hazard in waste management.