Swedish Society for Nature Conservation

Call for Evidence for the upcoming Circular Economy Act The Swedish Society for Nature Conservation (SSNC) welcomes the opportunity to provide feedback on the Call for evidence for the upcoming Circular Economy Act. SSNC is a non-profit environmental organisation, working with more than 40 organisations around the world, with almost a quarter of a million members and more than 270 local associations.

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

Your ref no: Ares(2025)9425851 Our ref no: 2026/0004 European Commission DG GROW.C.2 Call for Evidence for the upcoming revision of EU rules on public procurement. The Swedish Society for Nature Conservation (SSNC) welcomes the opportunity to provide feedback on the Call for evidence.

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

The Swedish Society for Nature Conservation (SSNC) welcomes the opportunity to provide input on the EU Public procurement directives. SSNC is a non-profit environmental organisation, working with more than 40 organisations around the world, with almost a quarter of a million members and more than 270 local associations. SSNC also runs the ecolabel Good Environmental Choice.

Please see attached file, which is a translation to English of SSNC's official referral response to the Swedish Government on the CRMA. SSNC also largely supports EEB's and other European NGO:s upcoming position paper on the subject. Kind regards, [name removed] Forest and Mining Specialist Swedish Society for Nature Conservation (SSNC)

The Swedish Society for Nature Conservations (SSNCs) comments on the EU general pharmaceuticals legislation: Regulation COM(2023) 193 (see separate feedback for Directive COM(2023) 192). Please find attached the pdf file containing a detailed response. GENERAL VIEWS: The SSNC supports the Commission's overall intentions regarding greater consideration for the environment in pharmaceuticals legislation.

The Swedish Society for Nature Conservations (SSNCs) comments on the EU general pharmaceuticals legislation: Directive COM(2023) 192 (see separate feedback for Regulation COM(2023) 193). SUMMARY: 1) SSNC proposes that environmental risks should be included in the benefit-risk assessment of a pharmaceutical.

The Swedish Society for Nature Conservation, SSNC (Svenska Naturskyddsföreningen) welcomes the initiative to put in place a Climate Law for Europe. However, SSNC is concerned that the level of ambition is not in line with what science requires to limit global temperature rise to 1.5°C above pre-industrial levels.

The Swedish Society for Nature Conservation, SSNC (Svenska Naturskyddsföreningen) welcome that the European Commission President Ursula Von der Leyen has announced that tackling climate change is a top priority for the European Commission. SSNC very much welcome the initiative to put in place a Climate Law for Europe.

Here are selected inputs from Sweden's largest environmental organization - The Swedish Society for Nature Conservation. For details, please see attached file. The Swedish Society for Nature Conservation's environmental label, Good Environmental Choice (Bra Miljöval), was established in 1990 and has since supported companies, public actors, and individuals in making wise choices that contribute to a sustainable…

The Swedish Society for Nature Conservation has been given the opportunity to comment on the European Commission’s proposal to introduce a carbon border adjustment mechanism (CBAM). Properly designed, such a mechanism could be an important measure to reduce Sweden’s and the Union’s high consumption-based emissions associated with imports from third countries, in accordance with the polluter pays principle.

Filed in Swedish · English published by the European Commission

The Swedish Society for Nature Conservation (SSNC) supports the concept of fully integrating the external environmental cost of products and consumption, including for goods that are imported to the EU. This is not being done in a satisfactory way today and in many EU countries, including Sweden, emissions per capita are higher than perceived if consumption-based emissions are accounted for.

A reform of the EU emissions trading system is indispensable to enable emissions trading to contribute to the achievement of the Union’s new climate objectives and, in particular, to the climate objectives of the Paris Agreement. Summary • The reform needs to take effect by 2023 at the latest. • Ambient level needs to be further increased.

Filed in Swedish · English published by the European Commission

The Swedish Society for Nature Conservation's demands for EU-ETS reform in brief: - The EU needs to reduce its total emissions by at least 75 percent by 2030 compared to 1990 levels and reach near zero emissions by 2035.

The Swedish Society for Nature Conservation is grateful for the European Commission to propose a substantially reformed and updated Energy Taxation Directive. The current Directive dates back to 2003 and has long been outdated and outdated, as the Commission itself found in its Impact Assessment Report.

Filed in Swedish · English published by the European Commission

Minimum tax rates in the Energy Taxation Directive 2003/96 should be raised in order to harmonize energy taxation within the Union and to minimize tax exemptions in the energy sector. The minimum taxation level used for different tax exemptions should initially not be allowed to be lower than at least half of a normative level of full energy tax for fuel, I e the tax on unleaded petrol and on electricity for…

The Swedish Society for Nature Conservation’s (SSNC) response to the nature restoration law. SSNC is a member-based organization and Sweden’s largest environmental organization. SSNC works with issues ranging from climate and energy to chemicals, oceans, agriculture, forests, and biodiversity.

The Swedish Society for Nature Conservation (SSNC) opine the Inception Impact Assessments for revision of the regulation No 1935/2004 on Food Contact Materials (FCM) to be well thought-out. The description of the drawbacks of the current regulation (A 1-8) agrees with our opinion of the situation.

The Swedish Society for Nature Conservation supports the ambition of the EU Ocean Act to improve coherence, coordination and effectiveness of ocean governance. To achieve this, the Act must be firmly grounded in ecosystem-based management and make the achievement of Good Environmental Status (GES) under the Marine Strategy Framework Directive a central and binding objective.

The Swedish Society for Nature Conservation (SSNC) welcomes the Commission's proposal for a revised urban wastewater treatment directive (UWWTD). The current directive, which is over 30 years old, has fulfilled its function well and has contributed to improved water quality in the European water bodies.

Feedback to the Commissions proposal for a Directive revising the rules for application of manure-based fertilisers above the 170 kg limit from The Swedish Society for Nature Conservation 17 May 2024 Summary The Swedish Society for Nature Conservation opposes the proposed increase of the limits of the overall nitrogen load allowed in environmentally vulnerable zones as currently regulated by the Nitrates directive…

Swedish Society for Nature Conservation (SSNC) welcome the commission proposal on a monitoring framework for resilience and biodiversity in the European forest(FML). We regard the proposal as highly necessary for the future health of the European forests, not least in Sweden.

Today´s use of forest ecosystems does not meet the challenges facing society regarding biodiversity and forest ecosystem services, and not at least the need for climate adaptation of the forest and the forestry. Due to human pressures and unsustainable management the majority of the forests in Europe have medium to low ecosystem integrity.

Swedish Society for Nature Conservation (SSNC) support the Commissions Proposal for a Regulation establishing a common data platform on chemicals, with the aim to provide a high level of protection of human health and the environment from the adverse effects of harmful chemicals under the one substance, one assessment approach.

It is currently not possible to perform in-depth environmental and health risk assessments of all chemical substances in use in the EU, because of the great variety of chemicals, their diverse uses, and data gaps. This may put workers, consumers, and the environment at unnecessary risks, so the situation must urgently be addressed.

The Swedish Society for Nature Conservation (SSNC) welcomes the roadmap on Access to Justice and emphasize the importance and urgency of the matter. SSNC supports the intention to amend the Aarhus regulation to improve access to justice concerning acts of the EU institutions.

Feedback on the interception Impact Assessment on “Minimising the risk of deforestation and forest degradation associated with products placed on the EU market” The Swedish Society for Nature Conservation welcomes the commitment of the Commission to step up EU action to protect and restore the world’s forests.

SSNC hereby submits its views on the Commission's proposal in an attached file. In summary: The Swedish Society for Nature Conservation (SSNC) welcomes the Commission's proposal to revise the Water Framework Directive (WFD), the Environmental Quality Standards Directive (EQSD) and the Groundwater directive (GWD).

The Swedish Society for Nature Conservation (SSNC) wants to underscore the necessity of bringing the Aarhus regulation into full compliance with the Aarhus convention. This is of utmost importance to safeguard the integrity of European environmental law and access to justice in environmental matters throughout the Union.

The Swedish Society for Nature Conservation, SSNC, fully supports the inclusion of long-chain perfluorocarboxylic acids, their salts, and related compounds in the POPs Regulation. Regulatory action is essential to safeguard European human health and the environment from this highly persistent and toxic group of chemicals.