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, 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…

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 subscribes to the new EU climate ambition of reducing GHG emissions by at least 55% by 2030. Suez’s corporate growth strategy – SUEZ 2030 – is fully aligned with this major milestone of the trajectory of EU’s climate neutrality by 2050. Additionally, Suez is committed to contribute positively and bring value to the objectives of the Green Deal.

SUEZ welcomes the European Commissions proposal on the packaging and packaging waste regulation. In this position paper SUEZ wants to highlight some remarks on the proposed legislation. There should be an obligation to extend a minimum of recycled content in packaging for all kinds of materials (paper, cardboard, and glass) and not only to plastic.

SUEZ is committed to help reducing packaging wherever this is reducing the environmental footprint of the packaged product from cradle to cradle. SUEZ therefore welcomes the actions the EU Commission wishes to take and fully supports the measures listed in the roadmap, notably the following: recycled content targets for packaging and design for reuse and recycling.

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 European Commissions proposal on the Critical Raw Material Act. Indeed, elements in this proposition would contribute to the strategic independency of the European Union while maintaining with regards to the circular economy, a particular reduced environmental footprint through increased recycling.

SUEZ welcomes the European Commissions proposal on the revision of the Waste Framework Directive regarding food waste. In this position paper SUEZ wants to highlight some remarks on the proposed legislation in relation to the proposals regarding food waste.

SUEZ is favorable to this initiative having a well-established Sustainable Corporate Governance team with extra financial reporting in place since 2008. In line with the “Loi Pacte” in France on the modification of the concept of interests of the company (and of its shareholders), SUEZ adopted a “raison d’être” in 2020 that embraces the interests of all stakeholders and commits to a positive impact on people and the…

SUEZ welcomes the European Commissions proposal on the Carbon Removal Certification and the will of the European Commission to create an efficient and voluntary European market on Carbon removal certification. In this position paper SUEZ wants to highlight three major carbon removals methods that should be better promoted considering their positive impact: Bioenergy Carbon Capture and Storage (BECCS), biochar and…

For decades, SUEZ has been playing a key role in converting waste in energy in Europe. SUEZ currently manages a third of Waste-to-Energy (WtE) installations across the French territory and produces each year 950 GWh of electricity and 2100 GWh of heat from waste incineration.

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 Impact Inception Assessment on the Sustainable Products initiative and considers it is necessary to reduce carbon emissions through circular designed products. The promotion of reuse and recycling and incorporation of recycled products is key to the transition to a low carbon and circular economy.

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).

We support the proposal since it supports water carriers an circular economy investments. However, we have had separate points of attention. First of all, in Article 3 (b). 12, Suez advocates for the BAT conclusions to restore as performance level and not to be binding. To avoid cross effects, proposals on emissions and performance should be documented in a technical way.

Filed in French · English published by the European Commission

Mr Suez welcomed the proposal for a regulation on batteries and scrap batteries. We fully support the increased ambition of battery recycling. We have some comments and questions: Waste classification of EV batteries: (list of wastes — Decision 2000/532/EC) o Waste status of electric vehicle batteries is an important element in ensuring the integrity and safety of recycling throughout its stages (collection…

Filed in French · English published by the European Commission

At SUEZ, we fully support the European Commission's initiative to pave the way for a sustainable and competitive batteries value chain in the EU, whilst addressing the social, environmental and health impacts generated.

SUEZ welcomes the European Commissions proposal on the requirement for vehicle design and on management of end-of-life vehicles. The regulation would contribute to a more sustainable management of end-of-life vehicles by improving the circular design, ensuring more materials are recovered and recycled, making producers financially responsible, and better controlling the exports of used vehicles.

SUEZ welcomes the European Commissions regulation proposal on preventing plastic pellet losses and supports the initiative to reduce the release of microplastic substances in the environment which has considerable impacts on human health, biodiversity and the economy.

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 and supports the initiative of the European Commission to boost the supply and demand for sustainable aviation fuels (SAF) which will contribute to achieving EU climate neutrality ambition by 2050. SUEZ as a leader in environmental services in Europe is already engaged in several national initiatives to develop a sustainable value chain for SAF based on different waste feedstocks.

SUEZ would like to express our support of the proposals made by the European Commission to the Urban Wastewater Treatment Directive. These proposals have taken into consideration the full potential of WWTP and sanitation systems and their corresponding positive externalities.

Ensuring Access to Sanitation In 2010, the UN officially acknowledged the Human Right to Water and Sanitation and has also set SDG 6 with the aim to grant access to clean water and sanitation for all by 2030. The current UWWTD Directive does not address the issue related to access to sanitation.

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 proposal on the electricity market design reform. In this position paper SUEZ wants to highlight some remarks on the proposed legislation, in particular: - The importance to maintain a fair access for large companies to the revenues from two-way contracts for difference.

Air Pollution is a critical point to address and SUEZ supports the new revision and its alignment with the WHO recommendations. Reducing air pollution helps to put the EU on a trajectory to achieve zero pollution for air at the latest by 2050, in synergy with climate-neutrality efforts.

SUEZ - GROUPE TOUR CB21 - 16, PLACE DE L’IRIS 92040 PARIS LA DÉFENSE CEDEX, FRANCE TEL [phone removed] WWW.SUEZ.COM DEPARTMENT OF INSTITUTIONAL AFFAIRS – EUROPE SUEZ response to the Ambient Air Quality Directives revision roadmap January 2021 Interest Representative Identification Number: 27799842497-69 Suez welcomes the opportunity to share its views on the upcoming revision of the Ambient Air Quality Directives.

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

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 considers that the European Commission has proposed an ambitious directive on integrated water management surface and groundwater. Protecting water is indeed critical for EU citizens and the environment. The new groundwater directive complements the revision of the Urban wastewater treatment directive. For SUEZ, there is clear alignment between these two topics.

SUEZ is a major player in environmental services. For almost 160 years, SUEZ has supported local communities and industrial companies in the management of essential services such as water, waste, and air quality. As such, SUEZ produces drinking water for 66 million people worldwide, recovers 2 million tons of secondary raw materials per year, and generates 3.1 TWh of renewable energy from waste.

SUEZ welcomes the opportunity to contribute to the roadmap consultation on the conversion of the Farm Accountancy Data Network. In order to feed an ever-expanding world population and face the decline in the availability of natural resources, it is inevitable to make a sustainable agricultural transition.

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.