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Club EMAS - Associació d'organitzacions registrades EMAS a Catalunya

Club EMAS

Our aim is to promote and oversee the continuous improvement of the environmental behaviour of organisations and of society in general, and the protection of the common interests of the association’s organisations concerning their participation in the EMAS system.

Lobbying Activity

Response to Review of Directive 2012/27/EU on energy efficiency

18 Sept 2020

The Club EMAS supports the initiative for the revision of the EED as a way to achieve better energy efficiency performance in Europe, but calls for EMAS, the EU's eco-management and audit scheme, to be clearly and forcefully taken into account. In fact, the regulation itself already indicates to the commission that it shall consider how registration under EMAS can be taken into account in the development of new legislation and revision of existing legislation, in particular in the form of regulatory relief and better regulation and used as a tool in the context of application and enforcement of legislation (see Article 44 - Integration of EMAS into other policies and instruments in the Community). This is even more necessary when some member states are in turn trying to take EMAS into account in the transposition of this directive, and they encounter many barriers as they are not supported at European level because the directive does not mention it, furthermore, in section 24 of the preamble the directive (version of 2012) makes reference to the ISO 14000 standard, while there is no reference to EMAS. For this reason, we demand that regulatory reliefs for EMAS companies be explicitly included in the Directive, as well as taking advantage of the great synergies between EMAS and the objectives pursued by the directive. Moreover, in relation to the “exemplary role of the administration”, it should be considered that those buildings in which it is not technically or economically possible to carry out certain interventions (for example, officially protected buildings, buildings of the armed forces, etc.) Member States could be highly encouraged to promote the adoption of EMAS in such buildings as a way to increase energy efficiency and generally speaking, a better environmental performance. It's understandable that certain buildings cannot be easily modified, but it does not mean that good energy and environmental practices cannot be adopted. There are already examples of adoption of EMAS in protected buildings, buildings owned by the army and religious places. In relation to the adoption of energy efficiency plans, the directive should also consider that EMAS registered public bodies and social housing bodies governed by public law, should use the framework of EMAS (for example, the environmental objectives and programmes, the operational controls among others) to provide evidence of their energy management plans, not being necessary to create other documents. The directive should encourage public bodies and social housing bodies governed by public law shall to consider the implementation of EMAS as a way to address a more comprehensive management approach of environmental performance (energy, water, waste, etc.).
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

7 Sept 2020

Club EMAS welcomes the Commissions initiatives towards a more sustainable Europe but is concerned about this initiative and its link to the EU Eco-management and audit scheme (EMAS). The current version of the NFRD has included only one reference to EMAS in the recital n. 9 “In providing this information, undertakings which are subject to this Directive may rely on national frameworks, Union-based frameworks such as the Eco-Management and Audit Scheme (EMAS), or international frameworks such as the United Nations (UN) Global Compact, the Guiding Principles on Business and Human Rights implementing the UN ‘Protect, Respect and Remedy’ Framework, the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, the International Organisation for Standardisation's ISO 26000, the International Labour Organisation's Tripartite Declaration of principles concerning multinational enterprises and social policy, the Global Reporting Initiative, or other recognised international frameworks.” This overly discreet reference to EMAS has not made it easier for Member States to continue their efforts to effectively integrate EMAS into the transposition of the directive in their state regulations. Generally speaking, it’s important that within the development of EU initiatives, all EU tool are efficiently mainstreamed. EMAS ensures transparent reporting both, on environmental performance and green activities and projects, and thus EMAS registered organisations should be able to provide their validated environmental statement as evidence of their environmental information without incurring additional costs or bureaucratic procedures, since this information has been validated by an independent third party competent in environmental matters. From our perspective, this should be reflected in the rules that are intended to be developed within the framework of the NFRD.
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Response to Environmental claims based on environmental footprint methods

25 Aug 2020

We share the opinion that consumers and organisations need reliable and verifiable information to make sustainable decisions, and this is essential in the context of the circular economy, although it’s not clear how this initiative will be aligned with the existing EU Eco-management and Audit scheme (EMAS), particularly in the case of environmental performance of businesses. Establish further labels for the environmental performance of an organization could increase the confusion in the markets and consumers. EMAS is a reliable instrument for the presentation, communication and validation of environmental performance and a robust scheme is already in place at EU and MS level in order to implement it. In reality, what is needed is an adequate integration of EMAS in the various European policies and, above all, a greater promotion of a tool (EMAS) that has not been fully exploited due to lack of knowledge on the part of the market. We also agree with the UGA, that when determining an organisation environmental footprint (OEF), EMAS offers validated data (validated by an environmental verifier) and, in addition to it, the examination and confirmation of an organization’s legal compliance, an aspect that should be considered due to the fact that OEF are oriented to the market and final consumers.
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Response to Climate Law

3 Feb 2020

In order to achieve the objectives considered in the roadmap, it is necessary to take a systematic approach by administrations and all stakeholders, thus ensuring that issues related to climate emergency and Carbon neutrality are considered in all aspects and processes of organizations. For this reason, we consider that the EMAS as a management and auditing system and as transparent environmental reporting should be the priority tool, since it guarantees this systematic approach and aims at continuous improvement. Moreover, this is the EU eco-management system and a reference should always be included in order to ensure consistency within the EU environmental framework.
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