ZERO - Association for the Sustainability of the Earth System

ZERO considers that industrial acceleration should only be supported if it leads to absolute and verifiable emission reductions, avoiding the prolongation of carbon-intensive assets or new fossil dependencies. First, the articles on the subject matter, scope and objectives of the Regulation should be amended to clarify that strengthening European industrial capacity should be conditional on climate neutrality, the…

Filed in Portuguese · English published by the European Commission

Review of EU renewable energy rules – Roadmap consultation Os contributos da ZERO – Associação Sistema Terrestre Sustentável No contexto do Acordo Verde da UE ((European Green Deal), é com satisfação que a ZERO – Associação Sistema Terrestre Sustentável vê o compromisso da Comissão de aumentar a ambição na mitigação das alterações climáticas, bem como os seus planos de revisão da meta de redução dos gases de efeito…

Filed in Portuguese · English published by the European Commission

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

Following the submission of the proposal for a Regulation on Packaging and Packaging Waste, ZERO has submitted its opinion. While the proposal generally reinforces obligations at different levels and presents, for the first time, concrete targets in key areas such as prevention and re-use, its lack of ambition in multiple areas, as well as its current unique justification based on justifications linked to the single…

Filed in Portuguese · English published by the European Commission

Europe’s action on reducing natural resource consumption is long overdue, and the huge amounts of packaging waste being produced every year is a clear sign that we have failed to implement the policies that will deliver on making the waste hierarchy a reality. Focusing on recycling will not do the trick.

EU and global industrial transformation needs to ensure that societies companies, governments and their services, citizens are designed to live in harmony with nature and well within planetary boundaries. This means climate, biodiversity (also through resources and materials), and pollution objectives need to be addressed together, not as separate silos or issues.

To be in line with the goal of the Paris Agreement, the EU should reduce greenhouse gas emissions by 65 % by 2030. This requires higher binding energy targets (at least 45 % for energy efficiency and 50 % for renewables) and at least triple the current annual energy renovation rate, significantly increasing its depth and moving towards a fully renewables-based energy supply.

Filed in Portuguese · English published by the European Commission

ZERO welcomes the opportunity to provide feedback to enhance the potential of the WFD to be a promoter of Circular Economy in the EU. We have the following suggestions, organized in three main themes: 1. Adopt binding waste prevention (reduction and reuse) targets.

ZERO – Association for the sustainability of the Earth System has been following the issue of food waste with great concern. We consider that the Farm to Fork strategy envisions a high level of ambition to this process and therefore we should make the 50% food loss and waste reduction target by 2030 (SDG 12.3) that was voted by all UN member states in 2015, binding at the EU level and matching the bloc’s ambition on…

What science says is clear: we need to remove carbon from the atmosphere in this century to keep global warming below 1.5 °C. The role of carbon removals in pursuing the goals of the Paris Agreement is undeniable, but the burden of climate action remains in a deep and comprehensive emission reduction for all sectors, not least because removals should be complementary and not substitute for emission reductions at…

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Both technological and nature based solutions for CO2 removals are crucial to keep within 1,5 degree warming, and need to be scaled up. While technological CO2 removals are permanent and need strong financial instruments, nature based solutions have uncertainties in permanence, but potentially significant co benefits.

Corporate fleets represent a significant opportunity to accelerate the decarbonisation of road transport. In the first half of 2025, they accounted for 60% of new car registrations across the EU, yet were responsible for approximately 75% of car-related emissions, largely due to their higher mileage. Therefore, this regulamentation is a great opportunity to accelerate transition for road transport. How?

We strongly recommend the inclusion of municipal waste (MSW) incineration in the EU ETS scheme in the upcoming review. Evidence shows that municipal waste incineration has a growing negative impact on climate, yet because they are not part of the EU ETS or any similar scheme to progressively reduce CO2 emissions, these incinerators are not compensating for the resulting climate damage.

To meet the Paris 1.5 °C objective, the EU needs to reduce its emissions by at least 65 % by 2030. Reductions should be socially and economically fair, requiring a comprehensive approach to the whole policy architecture. ETS is only one element of a package and needs to be complemented by a significantly robust set of climate and energy policies. To this end, the ETS and ESRs need to be strengthened.

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Parecer da ZERO em relação à proposta de revisão do Regulamento dos Produtos de Construção (CPR) 12 Julho de 2022 Sumário A ZERO congratula a Comissão Europeia pela proposta de revisão do Regulamento de Produtos de Construção (CPR na sigla inglesa), em particular o esforço de alinhar o Regulamento com os princípios ambientais já apresentados no Regulamento Eco-design Para Produtos Sustentáveis (ESPR na sigla…

Filed in Portuguese · English published by the European Commission

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

The construction sector has a significant global impact on the environment, including here in Europe. Business-as -usual is no longer an option, but the current regulatory framework is not sustainability-ready. The planned revision of the Construction Product Regulation (CPR) can play an important role in reducing the impact of the sector, but incremental change will not be enough.

The Single-Use Plastics Directive has already delivered important progress and should remain a cornerstone of EU action against plastic pollution. It has helped establish legal certainty, stimulated innovation, supported national action and raised awareness across institutions, businesses and the public. These achievements must now be consolidated rather than diluted.

Comments on “Protecting biodiversity: nature restoration targets under EU biodiversity strategy – Roadmap” No âmbito da Estratégia de Biodiversidade e considerando que é de enorme relevância uma intervenção abrangente ao nível dos habitats, parece-nos importante focar as florestas.

Filed in Portuguese · English published by the European Commission

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

ZERO welcomes the European Commissions initiative to include a 2040 climate target within the European Climate Law, as an essential milestone between 2030 and 2050. However, as currently framed, the proposed target of a 90% net reduction in greenhouse gas emissions by 2040 does not fully reflect either the urgency of the climate crisis nor the EUs fair contribution to the 1.5°C limit of the Paris Agreement.

ZERO congratulates the EU for finally moving forward in reducing the problems for health and the environment resulting from FCM. It is clear for us that hazardous chemicals must never be allowed in whatever FCM. That is fundamental to honor the commitments of the Green Deal and the new Chemicals Strategy for Sustainability.

ZERO - Associação Sistema Terrestre Sustentável is an Environmental NGO working on a broad range of issues where Climate Change and Energy are major action priorities. As a member of several European NGO networks - such as ECOS (European Environmental Citizens Organisation for Standardisation), EEB (European Environmental Bureau), CAN-Europe (Climate Action Network), etc.

The environmental foundation ZERO is an independent, not-for-profit organisation that promotes practical climate solutions, based and working out of Norway. ZERO is politically independent, has an analytical and knowledge-based approach, and gains knowledge through continuous cooperation with private businesses, research, policy and organisational networks. Find our respons in attached file.

ZERO welcomes the European Commissions intention to develop a comprehensive framework for climate resilience and risk management. Europe is already suffering profound impacts from climate change. Portugal, one of the most climate-vulnerable countries in the EU, is experiencing these with increasing severity, making it urgent that adaptation and resilience are addressed with ambition, equity, and binding commitments.

ZERO welcomes this initiative as an opportunity for the EU to significantly reduce this pollution using mandatory regulatory actions. As an environmental NGO, prevention and upstream/reduction at source are seen as the fundamental strategies to address this problem. Downstream mitigation should be a last resort and allowed only for a short period.

ZERO supports the introduction of a mandatory incorporation of advanced fuels into the aviation sector, however this should only be advanced if it brings a clear environmental benefit. It´s important the exclusion of food & feed crops and waste-based fossil fuels, key safeguards to ensure that the promised emission reductions are achievable and that the level of obligation following a serious assessment of the…

One of our major concerns relates to the policy options presented, since they will most likely encourage manufacturers to “close” the repair market to independent actors and user repair. In order for product life extension to remain effective, timely and affordable, the repair market should be open and competitive.

ZERO welcomes the inception impact assessment (IIA) of the WSR stressing the intention to stop exporting waste outside the EU and revisit existing rules. According to the IIA, “International trade in waste has increased considerably. In 2016, four times more waste were traded across international borders than in 1992 and this waste had a value of around 100 billion euro.

ZERO argues that EU climate neutrality should be achieved through deep domestic emission reductions. To align with 1.5 °C and equity criteria, the EU should reach carbon neutrality by 2040 (net zero emissions), underpinned by gross reductions of at least 92 % compared to 1990. 1.

Filed in Portuguese · English published by the European Commission

It is undisputed that in order to achieve climate neutrality and meet the common climate and biodiversity objectives, the Member States (MS) of the European Union (EU) should phase out the use of fossil fuels, strongly reduce energy consumption – through maximum energy efficiency ambition, prioritising electrification and limiting the use of Green Hydrogen to sectors for which there are no viable alternatives – and…

Filed in Portuguese · English published by the European Commission

The revision of the Governance Regulation should strengthen the EU framework to plan, monitor and support the energy transition after 2030, without changing the current architecture for 2030 and preserving elements that have already proven effective.

Filed in Portuguese · English published by the European Commission

ZERO advocates for a substantial increase in the EU’s domestic ambition and a governance framework that ensures environmental integrity, accountability, and consistency between targets and public spending. To align with 1.5 °C and equity principles, the EU should aim for domestic neutrality by 2040, based on deep gross reductions: at least ~ 65 % by 2030 (76 % net), ~ 82 % by 2035 (94 % net) and a net reduction of…

Filed in Portuguese · English published by the European Commission

Effective market surveillance should be strengthened through a set of targeted actions. Member States market surveillance authorities need sufficient staff and technical resources to apply rules more consistently across the EU, supported by the creation of an EU-wide Market Surveillance Authority.

The EU's LULUCF sector is essential for protecting Europe's biodiversity, water, and soils. Yet, since the year 2010, the net LULUCF has been sinking and the projections indicate that the EU will most likely miss its -310Mt LULUCF 2030 target by 50-125Mt.

ZERO - Associação Sistema Terrestre Sustentável, welcomes the review of the Commission Regulation (EU) 206/2012 and (EU) 626/2011, recognizing that ecodesign and energy labelling is paramount to accelerate the establishment of circular economies and to stimulate the production of higher efficiency products.

The EU POPs Regulation should respect the objectives and requirements of the Stockholm Convention and should therefore not lead to or promote the recycling of POPs waste. This may be the case if the defined limits for the content of POPs in waste are too benevolent and if their setting is based more on the economic interests of industrial groups than on the protection of public health and the environment.

ZERO – Associação Sistema Terrestrial Sustainable, is a Portuguese environmental NGO working on a number of topics, with priority being given to the areas of climate change and energy. He is an active member of several networks of European NGOs, such as: ECOS (European Environmental Citizens Organisation for Standardisation), EEB (European Environmental Bureau), CAN-Europe (Climate Action Network) and RGI (Renewable…

Filed in Portuguese · English published by the European Commission

ZERO is a Portuguese Environmental NGO that has followed the issue of mercury for several years and has been advocating for a fast phase out of dental amalgam containing mercury. We are totally in favour of the Commission's proposal to phase-out dental amalgam by 2025. We support this approach because we will be able to avoid 10 t of Mercury that would otherwise be released into the environment by 2030!

From our experience as an environmental NGO following mercury issues, we are confident to say that phasing out dental amalgam by 2025 is technically and economically feasible, and therefore should be implemented without delay. Furthermore, the EU should follow this path if it is truly committed to promote the toxic-free environment goal of the European Green Deal.

From ZERO's point of view it will be very important that strict requirements for the quality of the material are set, even in the cases where plastic botles are collected together with other recyclables, so that closed-loop bottle-to-bottle recycling is still possible.

Amendment of the Aarhus Regulation is the only means available to the EU legislature to bring the EU into compliance with its international law obligations. On 17 March 2017, the Aarhus Convention Compliance Committee (ACCC) found the EU to be in violation of the Aarhus Convention by failing to provide members of the public with access to the EU courts (CJEU).

ZERO - Associação Sistema Terrestre Sustentável is a Portuguese Environmental NGO working on various issues where Climate Change and Energy are major action priorities and is an active member of several European NGO networks - ECOS (European Environmental Citizens Organisation for Standardisation), EEB (European Environmental Bureau) and CAN-Europe (Climate Action Network).

- ‘Products & services’ are the entry point for material loops: 80% of environmental impacts are determined at design stage and if injecting single use & toxic materials through products we spoil the whole potential for circularity. It is no brainer that products and services need to be better designed for circularity. It’s impossible to make a good recipe with rotten ingredients.

ZERO welcomes the immediate efforts to reduce Europe’s dependence on Russian fossil fuels in the context of the severe Russian aggression against Ukraine. However, the European Commission’s proposal falls short of mobilising sufficient additional funding at EU level and puts at risk the achievement of core environmental objectives.

Filed in Portuguese · English published by the European Commission

We would like to support the draft Ecodesign and Energy Labelling Regulations, and in particular the new energy efficiency formulas, less linear and more able, thus avoiding the current incentive for ever increasing capacities. We also welcome the provisions to avoid very lengthy programmes, with a preference for the duration indicated in Ecodesign on duration on the energy label.

Filed in Portuguese · English published by the European Commission