Foreningen Nordisk Miljømærkning
The Nordic Ecolabel was set up as an official label for the countries in the Region.
ID: 938600495462-85
Lobbying Activity
Response to EU taxonomy - Review of the environmental delegated act
3 Dec 2025
Nordic Ecolabelling highlights a Report only once approach when demonstrating Taxonomy compliance. This would boost competitiveness as it would make it easier for European companies to operate at the European market. We therefore suggest that alignment with the Taxonomy can be verified by an officially recognized ISO 14024 type I Ecolabel certificate, such as EU Ecolabel and Nordic Swan Ecolabel. This would also be in line with other EU legislation such as EU 2024/825 (Empowering Consumers directive) where officially recognized type 1 ecolabels are granted a special role since, they demonstrate excellent environmental performance. It would also be in line with the simplification agenda as it would ease the administrative burden for many companies and ensure third part verified documentation on alignment of the Taxonomy, which could ease the control-effort of Taxonomy compliance in the financial sector. The reference to officially recognized ISO 14024 type I ecolabels could be introduced directly in the legal text or across the Taxonomy chapters and annexes. The wording could be the following: Taxonomy alignment can, where available for the specific product category, be verified by the manufacturer/service provider with an officially recognised ISO 14024 type I ecolabel. Main practical challenges: The main challenges in the current EU Taxonomy are a general lack of triviality limits, unclear test method and unclear definitions of what materials/products/processes are covered by the specific requirements. This is especially an issue for the DNSH criteria. The result of unclear definitions and lack of triviality limits is that companies and national organizations spend large amounts of administrative work to interpret the requirements to investigate if it is possible to achieve alignment for the activity across the industry. This uncertainty can result in unfair competition at the European market. The challenges can be exemplified by the following related to the climate delegated act, activities 7.1 and 7.2, but Nordic Ecolabelling experiences that same issues occur throughout the Taxonomy: Annex C: A triviality limit should be implemented. All certification schemes in the construction sector have triviality limits. Nordic Ecolabelling suggests to exclude nails, screws, strips, hole plated, hinged, nuts, bolts etc. Clearly define what components and materials should be documented. The current reference to CPR (Annex VII) is not sufficient. Do not set requirements for materials with low risk of harmful substances, e.g. steel rebars, bricks or concrete elements. Nordic Ecolabelling strongly urges to include CMR substances (minimum category 1A and 1B) in Appendix C. Emission testing: Specify which materials should be tested. Suggestion for new text in footnote 289: Applying to the following visible indoor materials: Paints, varnishes, sealants, adhesives, ceiling tiles and floor coverings. Mineral based materials such as e.g. cement should not be accounted for. Test methods for formaldehyde are not clear. Test conditions for formaldehyde in Annex XVII in REACH are aligned with EN 717 (according to several European test institutes). This standard is not used by most producers of building materials but adapted to wood-based products. It must be specified if EN 16516 is accepted and if so, a threshold limit must be defined. Insisting on EN 717 tests imposes a high and unnecessary cost for producers. Protection and restoration of biodiversity and ecosystems: Remove part a) of the requirement, as LUCAS Surveys are not available in all EU and arable land/crop land has nothing to do with biodiversity. Please find attached our findings regarding implementation constraints of the Taxonomy.
Read full responseResponse to Circular Economy Act
6 Nov 2025
Comments from the Nordic Swan Ecolabel to the Circular Economy Act - Call for evidence for an impact assessment Nordic Ecolabelling supports the EU Commissions proposed Circular Economy Act. Especially the focus on increasing the use of recycled material and setting mandatory, targeted, impactful and implementable criteria for public procurement of circular goods is highly supported. Officially recognized ISO 14024 Type 1 - Ecolabels can play a great role in circular economy due to our life cycle perspective and role as competition parameter for companies. The role awarded to these labels in Empowering Consumers Directive should be reflected in the Circular Economy Act to ensure coherency and consistency in EU legislation. Green public procurement can and should play a role in achieving a more circular economy. Also here, officially recognized ISO 14024 Type 1 - Ecolabels should be awarded a special role. Nordic Ecolabelling has long experience working with substances harmful to environment and health and at the same time set requirements striving to increase use of recycled material in the Nordic Swan Ecolabelled products and their packaging. Our experience tells us that availability and quality of recycled material is a limiting factor, mainly due to evolving market. There is also a lack of methods to guarantee safety of recycled material. Recycled material may contain harmful substances, impurities and residues that risk being kept in the loop of future products and/or pose a risk for migration of harmful substances for instance from packaging to product. The demands for the safety of the recycled material differ depending on where it is used. For instance. demands for recycled plastic in packaging of toys or food contact materials are quite different from those used to e.g. packaging of furniture. As a starting point for the increased use of recycled materials, Nordic Ecolabelling believes that the Commission should establish quality requirements to recycled materials to ensure its safe use, especially developing guidance, measures and routines regarding e.g. origin and traceability as well as accepted test methods for impurities and potential migration of harmful substances. Nordic Ecolabelling sets strict requirements for chemicals used in products to ensure that products do not contain substances harmful to health and the environment. This is also to ensure that products are recyclable and made from materials and substances that are suitable for inclusion in a closed resource loop once the product is at the end of its life. Public procurement can accelerate the circular transition if purchasers set requirements that promote the circular economy, so that projects that use circular solutions are rewarded to a significantly greater extent than today. Type 1 - Ecolabels ensures deliveries that: Are produced with less consumption of resources and energy Meet strict chemical requirements Are produced to a greater extent from renewable, recycled and sustainable raw materials Are designed for disassembly, reuse and repair Have good quality and a long lifespan Using the official Type 1 - Ecolabels as minimum requirements simplifies and streamlines the work of buyers. It also provides increased predictability for the industry. When they know what will pay off in upcoming tenders, they can dare to adjust production to be more circular and less environmentally damaging. This way, the green transition can accelerate.
Read full responseResponse to Derogations to the prohibition of the destruction of unsold Apparel and Footwear
16 Jul 2025
Nordic Ecolabelling thank the commission for giving the opportunity to send feedback on the draft act. We understand the need to have some derogations from the prohibition of destruction of unsold textile and footwear, but we are concerned about risk for interpretation that can lead to loopholes in the suggested derogations: Concerning article 2 (e): It is unclear how commonly recognised social norms and values are defined. Due to the lack of definition, we see a potential for divergent interpretation and implementation as well as a risk of abuse/circumvention of this derogation. This should be clearer defined before implemented in the delegated act. Concerning article 2 (i): It should be added the economic operator should offer to cover the cost of transportation and showing flexibility on the timing for the donation when offering their unsold goods to the social economy entity. Concerning article 3 (e): It should be added that the economic operator should include an argumentation for why they have evaluated that the textile label/logo/characteristics are considered inappropriate by reference to commonly recognised social norms and sensitivities. (Also see our comment on article 2(e), concerning lack of definitions)
Read full responseResponse to Industrial Decarbonisation Accelerator Act
3 Jul 2025
Nordic Ecolabelling (NE) welcomes initiatives aimed at reducing the climate footprint of carbon-intensive raw materials. However, NE stresses the importance of considering the following points: Alignment with existing EU legislation: NE highlights the need for new legislation to be consistent with existing EU frameworks, particularly following: ESPR introduces rating systems and sets minimum requirements for reducing environmental and climate impact. This applies to several products, including steel, iron, and aluminium. EU Taxonomy sets requirements for calculating climate data in the construction sector, which are not based on CBAM/ETS data, as is proposed for the climate label under the IDAA. These calculations are carried out according to national legislation or Level(s) indicator 1.2. In both cases, a combination of generic and product-specific EPD data is typically used. This results in different data foundations, which is particularly problematic in countries that have implemented mandatory GWP limit values in their building codes. Furthermore, it may lead to increased administrative burdens and reduce the applicability and value of a voluntary EU climate label. New labelling schemes should have strict criteria, high transparency, and include multiple environmental parameters: New labelling schemes should impose strict criteria, guarantee transparency in requirement development, and mandate third-party verification of companies/products to maintain credibility. Only through independent control and clear accountability can the necessary trust and transparency be achieved. Additionally, a labelling scheme should include several environmental parameters and support EUs objective to address the Triple Planetary Crisis. A narrow focus on climate risks promoting solutions that reduce emissions but worsen other environmental impacts, such as the use of hazardous substances or contributions to biodiversity loss. Analysis of existing tools: NE urges a thorough analysis of the potential for success and impact of a new voluntary label. For a labelling scheme to have a positive effect, high credibility and awareness are essential, which requires significant resources and time to achieve. In addition, regular maintenance and control are required. It should therefore be considered whether existing schemes, including the EU Ecolabel, could be expanded. The data basis must be comparable and fair: NE finds it essential, that labels are based on harmonized data and calculation models used across EU legislation, to ensure fair product comparisons. It is also important that calculations, including within CBAM, are based on actual production emissions. This is crucial for obtaining reliable data that reflect real emissions, gaining insight into the sectors actual emissions, and thus improving benchmarking for industry. This contrasts with the use of generic data (as allowed in CBAM), which is problematic, as polluting producers can opt for average data. In relation to the electricity system, it is particularly problematic that emission factors for national electricity mixes can be used within an interconnected grid. This is misleading and problematic as some MS sell green certificates without correcting the national electricity mix data accordingly. This raises concern that the proposed calculation methods and data basis could lead to unfair competition between producers in different countries. Use of labels in public procurement: NE recommends that the revision of rules on the use of labels in public procurement to be handled within the Procurement Directive and not through sectoral legislation such as the IDAA. Public procurers need one clear and operational framework and should retain the ability to use officially recognised Type 1 ecolabels as the Nordic Swan and EU Ecolabel. It should be noted that public procurers typically do not purchase industrial products such as steel, aluminium or paper pulp, but rather buildin
Read full responseResponse to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies
6 Mar 2025
We support that companies should only report and document sustainability data once. To further strengthen this principle, we propose ensuring that companies holding an officially recognized Type 1 ecolabel, such as the Nordic Swan Ecolabel/EU Ecolabel can use the documentation conducted during the certification process as compliance documentation within the Taxonomy. Other EU legislation, such as the Empowering Consumers Directive (2024/825) already acknowledges that officially recognized Type 1 Ecolabels demonstrate excellent environmental performance (Article 1(1) and Recital 10). This recognition should be extended to allow ecolabelled companies to use their verified ecolabel licenses directly as documentation using following formulation: "The alignment to the Taxonomy can, where the official ISO 14024 Type 1 Ecolabelling criteria is applicable for the specific product category, be verified by the manufacturer or service provider with an official ISO 14024 Type 1 Ecolabel certificate." This would create synergies between existing EU legislation and ecolabel schemes, reducing the administrative burden for businesses while encouraging the uptake of ecolabels as practical tools for companies, their supply chain partners, and financial sector stakeholders. It would also ensure that companies do not face double documentation requirements, allowing them to fully leverage the data already provided in the ecolabel certification process. The consequence of EC proposal is that many companies will no longer be covered by the Taxonomy. Large investors (e.g. pension funds) can avoid reporting on taxonomy compliance for specific economic activities (e.g. new buildings) as it is less than 10% of their financial activity. These can be significant activities. Due to this we question the Taxonomys relevance and whether it will be frequently updated. Changes to last part of bullet f in Annex C Changes to the last part of bullet f are needed. The last part of bullet f is important to ensure limited use of harmful chemicals. In the first suggestion given by the EU commission it is suggested to remove the last part of bullet f entirely. This cannot be supported as it would limit Annex C to only setting requirements for the candidate list (apart from mandatory legislation listed in annex C). The last part of f) ensures that e.g. CMR substances are restricted in the Taxonomy even if they are not on the candidate list, this is important. Only setting requirements for substances with harmonized classification is problematic. There is a risk that producers will steer towards substances with similar problematic properties that currently do not have a harmonized classification. However, we think that limiting the requirement to substances with a harmonized classification is a better alternative. A third option should be considered. Our experience with the construction industry shows that the primary problem is that the last part of bullet f is very unclear. The following suggestion is focused on making bullet f clearer rather than less strict: f) substances, whether () that are: - categorized SVHC and included on the EU Candidate List. - classified CMR Cat. 1A or 1B. - classified ED for human health, cat. 1 and 2 - classified ED for the environment, cat. 1 and 2 - classified PBT, vPvB, PMT and vPvM Pollution and prevention Apart from the suggested change in Annex C f Nordic Ecolabelling have the following suggestions: Introduce triviality limit for Annex C in construction related activities: Exclude Nails, screws, strips, hole plates, hinges, nuts, bolts etc. Test conditions for formaldehyde in Annex XVII in REACH are aligned with EN 717. This standard is NOT used by most producers of building materials but adapted to wood-based products. It must be specified if EN 16516 is accepted and if yes: a threshold limit must be defined. Insisting on EN 717 tests impose a high unnecessary cost for producers.
Read full responseResponse to Evaluation of the Public Procurement Directives
5 Mar 2025
The PPD aimed to promote sustainability, stating in the second recital that public procurement should serve as an instrument for achieving smart and sustainable growth while ensuring the most efficient use of public funds. However, its complexity has led to interpretations that hinder public authorities from leveraging its potential. This includes the use of officially recognised ISO 14024 Type I ecolabels such as the Nordic Swan Ecolabel or the EU Ecolabel. The wording and the subsequent interpretation of the directive has made it very difficult for public authorities to refer to the label as a whole, creating unnecessary administrative burdens without extra gain, despite Recital 75 stating that contracting authorities should be able to refer to European and (multi)national ecolabels. The wording of Article 43 in the directive has, in practice, made it nearly impossible to require an officially recognized ecolabel as comprehensive documentation of compliance. This is very unfortunate, as officially recognized Type I ecolabels are powerful tools for setting and documenting excellent environmental performance (as of the Empowering consumers directive) We propose A strengthened focus on green public procurement within the directive to ensure it becomes a key driver in the EU's green transition. Ensuring efficient use of officially recognized ISO 14024 Type I ecolabels, enabling public procurers to reference these ecolabels as a whole, thereby reducing unnecessary administrative burdens. This can be done by revising, simplifying and clarifying article 43 in the directive. To simplify the work of public sector we propose aligning with the list of pre-approved ecolabels, according to the Green Claims Directive. Ensuring legal clarity to use the official recognized Type I ecolabels in public procurement and harmonization across member states to avoid different interpretations and implementations of the rules. Challenges with the current wording of Article 43 of the directive It is explicitly stated in Article 43 of the Public Procurement Directive that public contracting authorities may require a specific ecolabel in public tenders. According to Article 43(1)(a)-(e), five conditions must be met. Particularly significant is the first condition outlined in Article 43(1)(a). For an ecolabel to be required, all the underlying label requirements, which collectively constitute the label, must: · Be linked to the subject matter of the contract, and · Be appropriate to define characteristics of the works, supplies or services that are the subject-matter of the contract These conditions align with the requirements for setting technical specifications, as outlined in Article 42, and thus are restrictive in relation to the criteria for determining contract terms and award criteria. As these conditions are interpreted, it is in practice nearly impossible,to require that a product or service is certified with an officially recognised Type I ecolabel. This, because one or more of the labels requirements almost always extend beyond the specific production of the item being procured. . The wording of article 43 restricts the use of official recognised Type I ecolabels compared with the wording of recital 75. The wording in recital 97 which states that contracting authorities may set criteria linked to a products life cycle, including production methods, energy efficiency and fair trade. This is not in line with the interpretation of article 43. The Nordic Ecolabelling recommends an amendment to ensure that contracting authorities may require a specific officially recognized Type I ecolabel as proof of compliance with environmental, social, or other relevant criteria, without the requirement that all label criteria be directly linked to the subject matter of the contract in a strict sense and be appropriate to define characteristics of the subject-matter of the contract, and thereby not be governed by the criteria in Article 42.
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