Summary - for the full feedback, see attachment WWF Germany welcomes the European Commissions political commitment to developing the Circular Economy Act (CEA). To fully realise its potential, the CEA must go beyond the focus on secondary materials. A genuine Circular Economy requires addressing the full hierarchy of R-strategies, including refuse, reduce, reuse, repair and remanufacturing and recycling.
WG
WWF Germany
NGO · Germany · EU Transparency Register 031571311716-04
10
positions filed
in the 665 files tracked
8
legislative files
of 665 tracked
6
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1106 non-governmental organisations on this site, they rank #148 by legislative files engaged, a count of participation, not a measure of influence.
3.2
declared lobbying FTE
self-declared
–
declared costs / yr (floor)
2
EP accreditations
as declared to the register
2013
in the register since
Declares membership of
- Deutscher Naturschutzring (DNR) →
- Klimaallianz
- Europäische Bewegung Deutschland (EBD): www.netzwerk-ebd.de
- Green G10: www.green10.org
- CAN: www.climnet.org
- IUCN: www.iucn.org
- EBD: www.netzwerk-ebd.de
- Für alle weiteren Mitgliedschaften s. Eintrag im Lobbyregister für Interessenvertretung gegenüber dem Deutschen Bunde…
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Non-governmental organisations
- Registered as
- WWF Deutschland (WWF)
- Head office
- Berlin, Germany
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
WWF Germany filed 10 positions between 22 Aug 2018 and 4 Nov 2025, across 8 of the 665 legislative files tracked here, attaching a full position paper 6 times.
2018 · 2 filed2022 · 1 filed2023 · 5 filed2024 · 1 filed2025 · 1 filed
What they argued
Position WWF Germany on draft proposal of the PPWR Ref. Ares(2023)2829809 - 21/04/2023 20. April 2023 Thank you for the opportunity to comment on the EU COM proposal for a Regulation on packaging and packaging waste. WWF Germany welcomes the basic direction of the proposal of the new EU regulation.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
WWF Germany welcomes the European Commissions proposal for EU-wide legally binding food waste reduction targets.The setting of binding targets is a much-needed step to stimulate action by Member States and food businesses across the value chain.
WWF Germany is very critical about the proposal for a Union certification framework for carbon removals. WWF Germany fears that the proposal gives opportunities for companies to simply clean-balance their continued emissions with allowances from carbon removals. The regulation must not undermine the necessary mitigation efforts in such a way.
Bundesverband Beruflicher Naturschutz e.V. GUT & BÖSEL B E Y O N D F A R M I N G Position statement on soil carbon sequestration and its possible remuneration through CO2 certificates We, the undersigning institutions and individuals, support structural and income-generating efforts to preserve, recover and increase the humus content of agricultural soils.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Hintergrund Durch die ‘Directive of the European Parliament and of the Council on substantiation and communication of explicit environmental claims’ (Green Claims Directive) sollen Unternehmen künftig dazu verpflichtet werden, Angaben zum ökologischen Fußabdruck ihrer Produkte und Dienstleistungen anhand standardisierter Quantifizierungsmethoden zu belegen.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
WWF Germany welcomes the commission's legislative proposal on sustainable finance and the commission's effort to integrate sustainability in financial markets and to channel financial flows towards more sustainable investments. We believe that a sustainable financial market prevents misallocation of capital and supports achieving central targets of the European Union.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
WWF Germany welcomes the commission's legislative proposal on sustainable finance and the commission's effort to integrate sustainability in financial markets and to ensure a better alignment of capital allocation decisions within the financial system with sustainability objectives and policy targets.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
WWF Germany expressed concerns about the draft delegated act amending Annex III to the Nitrates Directive (91/676/EEC). In particular, the increase in nitrogen uptake by a further 100 kg N to 270 kg N ha/a with so-called RENURE fertilisers is neither clearly defined nor sufficiently justified and therefore raises concerns. An actual increase in the permitted amount of nitrogen to 270 kg N ha/a is to be rejected.
Filed in German · English published by the European Commission
The WWF comments below on the Commission’s proposal for a new electricity market design. Align electricity market design with climate objectives The electricity market design reform must be designed to meet the EU’s emissions reduction and climate targets. A system that allows for price spikes creates incentives for efficiency and flexibility and increases the use of renewable energy in electricity generation.
Filed in German · English published by the European Commission
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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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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.