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Environmental association Za Zemiata

ZZ

Za Zemiata (ZZ) is an independent non-profit non-governmental organization established in 1995 to work for environmental justice and sustainable and equitable life on our planet, without exploitation of people or nature.

Lobbying Activity

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

19 Jun 2025 · Implementation of the clean transition agenda in Bulgaria

Response to Ecodesign requirements for solid fuel local space heaters (review)

13 Dec 2023

Bulgaria is one of the countries in EU, where air quality is unhealthy and domestic heating with wood and to lesser extend coal are a dominant source. Despite the programmes for heating appliances exchange targeting the oldest and dirtiest stoves (space heaters) the progress is slow. Additional research in Denmark and Germany shows that the eco-design stoves still emit unacceptably large amounts of pollutants compared to the dirty diesel. Indoor pollution is yet another area where very little is done when it comes to stoves for heating. Finally the conclusions of JRC 2021 report on biomass usage shows that its use for heating continues to cause damage to climate and biodiversity. We believe that newer stoves need to guarantee higher emission standards both outdoor and indoor. We are attaching a small study from Bulgaria pointing to the high Ultra fine particle number and PM values pollution by common stoves even with dry wood (11-15%) and to lesser extend with pellets. User behavior is important, however much difficult to change, hence the appliances need to meet much higher standards that depend less on user behavior. In general we think that local spaces heaters using coal and biomass should be progressively phased out if EU is serious about climate, health, biodiversity and energy poverty. Additional suggestions: - emission limits need to be based at least on current BATs, however German Blue Angel could be used as a guide - introduce requirements for indoor pollution levels - the testing procedures for local space heaters need to be as close as possible to real-usage conditions - strengthened air combustion control and exhaust cleaning We call on the European Commission to propose a strong revised text of the Eco-design regulations in line with evidence on health, biodiversity and climate damage caused by coal and biomass space heaters.
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Response to A new Circular Economy Action Plan

20 Jan 2020

The currently enormous circularity gap (91%) <https://www.legacy.circularity-gap.world/2019> can only be effectively tackled by aboslute reduction of natural resource use, with the ultimate goal of respecting the planetary limits to produce resources and process or store wastes. Therefore we ask for a EU headline target on absolute reduction (in quantity and footprint) of resources use, instead of decoupling from GDP. That target should use the Total Material Consumption indicator, aiming for at least a 50% reduction by 2030 (baseline 2017 levels), applying a dashboard of sub-indicators on land use, water use and carbon footprint. In order to move towards circular economy, the action plan needs to address “systems”, not just “products” and “materials”. Prioritizing prevention and reuse over recycling is vital for slowing, narrowing and closing material cycles for a circular economy. Therefore we ask for the following to be included in the CEAP: Set an EU-level binding waste prevention target, including a set of stream/sector-specific targets (food waste, construction and demolition, packaging, industrial waste, etc.) Set binding reduction and reuse targets for packaging as soon as possible. Encourage the introduction of reuse Deposit Return Systems with standardised containers for consumer packaging across EU. EPR schemes should be improved: including modulated fees (bonus/malus) for reused and recycled packaging in order to incentivize circular design for reducing, reusing and recycling materials. EPR schemes should begin to cover a fair share of the costs of the packaging lifecycle. In Bulgaria packaging recovery organisations sort and sell just the most profitable fractions of the separately collected packaging waste (e.g. PET bottles, aluminum cans, etc.), while the remaining waste packaging is sent to inferiour waste treatment options such as incineration or landfill. For many years this was done at the expense of local taxpayers. IN addition, the costs for cleaning up the growing amounts of littered packaging items are currently typically covered by local authorities or individual volunteers, while recent brand audits (including from Bulgaria) show that the most frequently littered items are indeed various types of single-use plastic packaging. Producers need to fully cover the costs related to the lifecycle of their products and packaging. Waste trade The CEAP should address the issue of waste trade and pave the way for a strong revision of the EU Waste Shipment regulation, that includes a ban on plastic waste exports. Recently disclosed mismanagement and crimes related to illegal waste imports from Italy into Bulgaria have caused serious publc outcry. In order to prevent the 'dumping' effect, the EU should set a binding target for a cap on residual (mixed) waste in kilograms per capita, combined with harmonized taxes on landfilling, incineration and plastic. In addition, perverse subsidies for using waste as fuel in energy-intensive and energy-generation processes, should be eliminated across EU.
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Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and ClientEarth AISBL and

7 May 2019 · discussion on Struma Motorway, Bulgaria and Kresna Gorge case

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and Greenpeace European Unit and

18 Oct 2018 · discussion on Plastics Strategy