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Brussels For Human Rights Development

BHRD

Human Rights and Development Organization in Brussels BHRD AISBL.

Lobbying Activity

Response to Integrated child protection systems

5 Oct 2023

At "Brussels for Human Rights and Development," we are heartened by your initiative to prioritize the development and strengthening of integrated child protection systems within the EU. Safeguarding the rights and well-being of our children is a fundamental commitment, and your focus on a holistic approach is truly commendable. Here is our heartfelt feedback on this significant initiative. Children at the Core: We deeply appreciate your emphasis on children's needs and the urgency of integrating child protection systems. Putting the prevention of abuse and violence against children at the forefront mirrors a compassionate perspective, echoing the principles of international conventions and standards. Advocating for Collaboration: Encouraging relevant authorities and services to collaborate holistically is a vital step forward. Integration is the linchpin of an effective child protection system, and collaborative efforts ensure that all aspects of children's safety and well-being are thoughtfully considered. Optimizing EU Resources: The intention to maximize the use of existing EU tools, laws, policies, and funding to fortify child protection systems is a wise move. By breaking down silos and promoting collaboration, the EU can channel its resources efficiently and ensure a comprehensive approach to child protection. Upholding Global Standards: It's paramount to ensure that this initiative aligns with international standards and best practices, especially the United Nations Convention on the Rights of the Child (UNCRC). The EU should strive to integrate the principles outlined in these vital instruments, setting a global benchmark for child protection. Including Voices of Communities and Civil Society: We strongly advocate for the active involvement of civil society organizations and communities in shaping these integrated child protection systems. Their experiences and insights are invaluable in crafting policies that resonate with the unique needs of children across the EU. Accessible Justice for Children: Prioritizing easy access to justice for children is pivotal. Ensuring that legal frameworks and mechanisms are child-friendly and readily accessible is vital to empower children to seek protection and justice in a manner that suits their individual circumstances. Regular Progress Checks: Instituting a robust monitoring and evaluation framework is key to tracking progress and effectiveness. Regular assessments will enable data-driven decisions, identify gaps, and ensure a continuous and responsive approach to these vital child protection systems.
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Response to Review of energy labelling requirements for solid fuel boilers

5 Oct 2023

As "Brussels for Human Rights and Development," we extend our appreciation for your dedicated efforts in driving energy efficiency and advancing climate neutrality through ecodesign requirements. Your proactive approach to review and improve these requirements for solid-fuel boilers is a vital step towards achieving sustainability and addressing the pressing climate crisis. We offer the following feedback on this critical initiative. Commendation and Support: We commend the European Commission for making energy efficiency and sustainable design a priority for solid-fuel boilers. Ecodesign requirements are fundamental to the journey towards a greener future, aligning well with the European Union's ambition of becoming climate-neutral. Emphasizing Energy Efficiency: Enhancing the energy efficiency of appliances, including solid-fuel boilers, is of utmost importance. Energy-efficient products contribute significantly to reducing energy consumption, cutting down greenhouse gas emissions, and saving costs for consumers. We strongly encourage setting ambitious targets to substantially enhance the energy efficiency of these boilers. Incorporating Repairability and Durability: Integrating repairability and durability into ecodesign requirements is a wise move. Prolonging the lifespan of appliances through repairability and durability is a crucial step towards waste reduction and supports the concept of a circular economy. Establishing clear guidelines is essential to ensure that manufacturers prioritize designs that facilitate easy repairs and result in longer-lasting products. Adherence to Circular Economy Principles: It is vital that the revised ecodesign requirements align with the principles of the circular economy. Prioritizing material efficiency, recycling, and minimizing the use of hazardous substances will promote sustainable production and consumption patterns, ultimately reducing the environmental impact of solid-fuel boilers. Considering Affordability and Accessibility: As we strive for enhanced energy efficiency, it's important to consider the affordability and accessibility of energy-efficient appliances. Striking the right balance between promoting energy efficiency and ensuring accessibility for all socio-economic groups is crucial to prevent energy poverty and promote social equity. Comprehensive Environmental Assessment: We recommend conducting a comprehensive life cycle assessment of solid-fuel boilers, encompassing not only energy efficiency but also environmental impacts throughout their entire life cycle. This approach will provide a holistic understanding of the environmental consequences associated with these appliances. Encouraging Stakeholder Involvement: We advocate for robust stakeholder engagement, involving active participation from environmental NGOs, industry experts, consumer organizations, and affected communities. Collaborative efforts will result in well-informed and balanced ecodesign requirements that are widely accepted and successfully implemented.
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Response to Rules for the reporting of aggregated emissions data at shipping company level

28 Aug 2023

As "Brussels for Human Rights and Development," we appreciate the European Commission's efforts to tackle greenhouse gas emissions from the shipping sector. The draft initiative concerning the reporting of aggregated emissions data at the company level and the determination of emissions data by relevant administering authorities is a promising step toward transparency, accountability, and emissions reduction in this crucial industry. In our role as advocates for human rights, environmental sustainability, and climate action, we'd like to offer detailed feedback to strengthen and improve this initiative: 1. Clarity and Specificity: We believe that the draft initiative could benefit from greater clarity and specificity regarding the data elements that shipping companies should report. Well-defined guidelines are essential to ensure that reporting is consistent across the industry, leading to more accurate emissions assessments and supporting the transition to a greener maritime sector. 2. Alignment with International Standards: Considering the global reach of the shipping industry, it's essential that the proposed rules align with international standards and agreements. We recommend close collaboration with international bodies, such as the International Maritime Organization (IMO), to ensure that EU regulations complement and reinforce global efforts to combat emissions from shipping. This alignment will prevent duplication of efforts and promote a unified approach to emissions reporting. 3. Data Accuracy and Verification: We believe that the initiative should place a strong emphasis on data accuracy and verification mechanisms. It's crucial to establish robust procedures for verifying emissions data to ensure that the reported information is credible and reliable. The inclusion of provisions for third-party verification could significantly enhance the trustworthiness of the data. 4. Flexibility and Adaptability: Recognizing the diverse nature of the shipping industry and the different operational profiles of shipping companies, we suggest allowing flexibility in reporting requirements. Tailoring reporting criteria to accommodate various vessel types, sizes, and operations is essential to ensure that compliance remains feasible and effective across the sector. 5. Correction of Emissions Data: While it's important for administering authorities to have the capacity to correct emissions data in specific situations, we urge the establishment of clear and transparent guidelines. It's paramount to have mechanisms for oversight and accountability in place to prevent any misuse of this authority. Additionally, a robust mechanism for appeals and dispute resolution should be introduced to ensure fairness and protect stakeholders' rights. 6. Data Privacy and Confidentiality: Emissions data may contain sensitive business information, trade secrets, and commercially confidential data. To address these concerns, the initiative must find a balance between transparency and the protection of sensitive information. We recommend implementing safeguards and encryption measures to secure commercially sensitive data. 7. Public Access to Data: While preserving data privacy and confidentiality, we believe the initiative should ensure public access to aggregated emissions data. Providing relevant emissions data to the public can play a crucial role in raising awareness and accountability within the shipping industry. However, safeguards should be in place to prevent the misuse of data for competitive or harmful purposes. 8. Capacity Building and Support: To ensure effective implementation, we recommend including provisions for capacity building and support for both shipping companies and administering authorities. Technical assistance, guidance, and training should be made available to enhance understanding and compliance with the regulations.
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Response to EU rules for the calculation and reporting of recycled content in single-use plastic bottles

26 May 2023

Brussels for Human Rights and Developments (BHRD) welcomes the European Commission's draft act on Single-use plastic beverage bottles EU rules for calculating, verifying and reporting on recycled plastic content. We believe that the act is a significant step forward in the EU's efforts to reduce plastic waste and promote the circular economy. We support the following key provisions of the draft act: The requirement that all producers of single-use plastic beverage bottles in the EU must calculate the recycled plastic content of their products. The requirement that producers verify the accuracy of their recycled plastic content calculations. The requirement that producers report their recycled plastic content calculations to the European Commission. We believe that these provisions will help to increase the transparency of the recycled plastic market and make it easier for producers to find and use recycled materials. We also believe that these provisions will help to reduce plastic waste incineration and landfill. We have a few suggestions for improving the draft act: We suggest that the act be extended to include other single-use plastic products, such as straws, stirrers, and cutlery. We suggest that the act include a requirement for producers to use recycled plastic in their products. We suggest that the act include a financial incentive for producers to use recycled plastic in their products. We believe that these suggestions would further strengthen the act and help to achieve its objectives. We thank the European Commission for its work on this important issue. We look forward to working with the Commission to ensure that the act is adopted and implemented effectively. In addition to the above, we would like to highlight the following specific concerns: The draft act does not include any provisions to address the human rights impacts of plastic production and disposal. We believe that it is important to ensure that the transition to a circular economy does not lead to new human rights abuses, such as forced labor or environmental degradation. The draft act does not include any provisions to address the issue of plastic pollution in developing countries. We believe that it is important to ensure that the EU's efforts to reduce plastic waste do not lead to a disproportionate burden being placed on developing countries. We urge the European Commission to address these concerns in the final version of the act.
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Response to Persistent organic pollutants - perfluorohexane sulfonic acid (PFHxS)

17 Feb 2023

Brussels for Human Rights and Development welcomes the initiative taken by the European Commission to include perfluorohexane sulfonic acid (PFHxS), its salts, and related compounds under the restrictions of the Stockholm Convention on persistent organic pollutants. The regulation (EU) 2019/1021 is an important step towards safeguarding the environment and protecting human health from the harmful effects of these toxic substances. PFHxS is a persistent organic pollutant that is widely used in various industrial and consumer products, such as non-stick cookware, water-repellent clothing, and fire-fighting foams. The substance has been found to bioaccumulate in the environment and pose a significant threat to wildlife and human health, including endocrine disruption and reproductive toxicity. The inclusion of PFHxS under the Stockholm Convention will bring about much-needed restrictions on the production, use, and release of this substance into the environment. This will help to reduce its overall presence in the environment and prevent future harm to wildlife and human health. However, we would like to raise a concern regarding the implementation of this regulation. The success of this initiative will largely depend on the effectiveness of its implementation and enforcement at the national level. It is essential that the member states provide adequate resources and capacities to monitor and enforce the restrictions imposed on PFHxS and its related compounds. Moreover, we would like to emphasize the importance of considering alternative, safer, and more sustainable options to PFHxS in the production of industrial and consumer goods. The phasing out of PFHxS should be accompanied by the promotion and development of alternative technologies and materials that are safe for both the environment and human health. Brussels for Human Rights and Development supports the regulation concerning the inclusion of PFHxS under the restrictions of the Stockholm Convention. We hope that the initiative will be effectively implemented and enforced, and that alternative, safer, and more sustainable options will be developed to replace PFHxS in the future.
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Response to Measures addressing the environmental impact of imaging equipment including consumables

31 Jan 2023

As an organization dedicated to promoting human rights and sustainable development, we are pleased to provide feedback on this initiative. Firstly, we would like to commend the Commission's effort to address the environmental impact of these products, as it is a critical issue that has far-reaching consequences for our planet and future generations. The Commission's recognition that imaging equipment, including consumables, play a significant role in waste generation and the depletion of natural resources is an important first step. However, we would like to emphasize the importance of ensuring that the initiative takes into account the social and economic impacts of its proposed solutions. For instance, while promoting energy and resource efficiency is important, we must also consider the affordability of these products and the potential impact on communities that may be unable to afford sustainable options. It is crucial to find a balance between environmental protection and ensuring that the rights and needs of all people are respected and protected. Additionally, we would like to suggest that the Commission consider the potential impact of its proposed solutions on the global south, particularly in developing countries. The manufacture and disposal of imaging equipment and consumables has a significant impact on the environment and communities in these regions. Therefore, it is imperative that any proposed solutions take into account the needs and realities of communities in the global south and ensure that they are not unfairly burdened by the consequences of this industry. We also recommend that the Commission consider the role of the informal sector in the disposal and recycling of waste from imaging equipment and consumables. This sector, which employs a significant number of people in many countries, provides valuable services in the management of waste and should be acknowledged and supported in the Commission's initiative. In conclusion, we support the Commission's efforts to address the environmental impact of imaging equipment and consumables. We believe that a comprehensive and well-informed approach that takes into account the social and economic impacts of proposed solutions, as well as the needs and realities of communities in the global south, is critical for ensuring the success of this initiative. We look forward to engaging with the Commission as it moves forward with its work and to the positive outcomes that this initiative can bring for our planet and future generations.
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Response to Evaluation of the Council Recommendation on Upskilling Pathways

21 Jan 2021

- We endorse and support the roadmap of Upskilling Pathways for Adults, particularly adults especially those with low levels of skills, knowledge and competencies and helping adults to acquire minimum literacy, numeracy, digital skills and/or a wider range of skills. - The education and upskilling of adults is an urgent need in order to contribute to create and sustain development, and to achieve the contribution of individuals and groups to economic and social growth. - BHRD believes that adult education requires a continuous effort in order to allow them to acquire knowledge and skills as well as work on talent development, including targeting literacy and engaging in activities of interest to certain groups. In addition to teaching various skills according to technological and digital information progress. - BHRD emphasize that the European Union, with its members, has achieved tangible high success in caring for and educating adults, improving their skills and raising efficiency. However, efforts must continue to reach a higher level of achievement in this matter. - What's required to achieve more and more: - In order to achieve greater success in that framework; - A real and clear desire among adults to learn and take advantage of the opportunities available must be created, - The appropriate method must be chosen for them to receive different sciences and skills, which will be new to them. - Adults have some features and advantages, so we must pay attention to these features when developing programmes and legislation to improve their skills and education, because adult education is different from that of children in many respects: 1. Adults are self-reliant in education and do not need to rely on others as young learners. 2. Adults have a certain amount of life experience, as some of them may have received a little education that would give them the ability to absorb quickly and easily learn. 3. Adults often need to learn and improve skills to help them develop their own lives. - We encourage adults who have drop out school or university to complete their education. , returning to educational institutes in order to improve their careers, but without leaving their jobs and devote themselves to education again.
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Response to Digitalisation of cross-border judicial cooperation

19 Jan 2021

Updating Judicial Cooperation Between EU Countries - the use of digital technology. -BHRD supports the initiative to update the judicial cooperation between EU countries - the use of digital technology. -The Corona pandemic is a threat that must be transformed into an opportunity for development and modernization in all areas, including the field of justice and fundamental rights. -It will make it necessary for the participating authorities in each country to use digital technology, rather than paper, to communicate, although it is a development and modernization imposed by reality, but the difficulties and challenges facing these systems must be avoided, especially as this development threatens piracy that may lead to the loss or withholding of information. -Information must be protected and we have to make sure that its transmission and exchange are safe. -We emphasize that we encourage modernization and development but in the same time taking into account not completely dispensing with
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