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Friends of the Earth Europe

FoEE

Friends of the Earth Europe is a leading environmental network campaigning for sustainable and just societies.

Lobbying Activity

Meeting with Rudi Kennes (Member of the European Parliament)

8 Dec 2025 · International cooperation

Meeting with Dorota Denning (Cabinet of Commissioner Valdis Dombrovskis), Michael Hager (Cabinet of Commissioner Valdis Dombrovskis) and

2 Dec 2025 · Roundtable on Food and Feed Safety Omnibus

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and Transport and Environment (European Federation for Transport and Environment) and

19 Nov 2025 · Exchange of views on raw materials, on the side of the EU Raw Materials Week 2025

Friends of the Earth Europe demands material footprint cap

6 Nov 2025
Topic — Circular Economy Act to enhance EU competitiveness while promoting sustainable production models.
Message — The organization demands the EU establish a binding material footprint target of 5 tonnes per capita by 2050, with interim targets of 20% reduction by 2030 and 50% by 2040. They call for the Act to be built on dual legal basis including environmental objectives (Article 192), not just single market provisions. They advocate for sufficiency strategies including bans on fast fashion advertising, phasing out single-use products, and tax shifts from labour to primary raw material use.1234
Why — This would legitimate their broader environmental agenda while potentially reducing industrial extraction activities.56
Impact — Resource-intensive industries lose as deregulation is rejected and polluting sectors face transition requirements.78
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Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

3 Nov 2025 · Sustainability omnibus - update for civil society

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and WWF European Policy Programme and

28 Oct 2025 · Sustainability omnibus and climate transition plans

Meeting with Martin Günther (Member of the European Parliament)

15 Oct 2025 · Nature credits

Environmental group opposes EU plans to weaken pesticide rules

14 Oct 2025
Topic — EU proposal to simplify food safety regulations including pesticide approval processes.
Message — Friends of the Earth Europe demands the EU reject plans to reopen pesticide legislation, maintain current protection standards for biocontrol products, and focus instead on robust implementation of existing rules to reduce pesticide dependency. They call for automatic default MRLs for banned pesticides in imports and proper risk assessment and labelling of GMM-produced foods.1234
Why — This preserves stringent environmental protections and maintains barriers against imported products with banned pesticide residues.56
Impact — Agrochemical industry and food importers lose opportunities to streamline approval processes and ease market access.78
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Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

2 Oct 2025 · Sustainability omnibus - update for civil society

Response to Roadmap towards Nature Credits

30 Sept 2025

Friends of the Earth Europe sees the European Commissions plan for nature credits as a dangerous distraction from the urgent tasks of phasing out harmful subsidies and establishing strong regulation. Instead of addressing the root causes of biodiversity loss, this proposal risks prioritising private profit over the public interest and deepening ecological and social injustices. The experience of carbon credits demonstrates that such market-based approaches fail to deliver real environmental benefits, are highly vulnerable to fraud and abuse, often serve as a licence for continued destruction, and can lead to severe human rights impacts. We join the concerns of more than 330 organisations and academics who have called for a halt to the promotion and use of biodiversity offsetting and crediting schemes (https://www.biodmarketwatch.info/civil-society-statement). Why nature credits are fundamentally flawed: 1. Undermining regulation and democratic governance: By shifting responsibility from governments and public institutions to private actors with profit motives, nature credits risk making conservation conditional on market performance. Investors are likely to focus on projects that are easiest or most profitable, not those that are ecologically most urgent. This undermines long-term protections, while proven public funding mechanisms such as the LIFE programme are currently being dismantled. 2. Inherent flaws of measurement and permanence: Ecosystems are too complex to be reduced to tradable units. Attempts to quantify biodiversity gains rely on flawed methodologies, cherry-picked indicators, and unverifiable baseline scenarios that can be easily manipulated. This creates the risk of false, worthless, or even harmful credits. 3. Offsetting in disguise: Despite the Commissions claims, the roadmap contains no safeguards against offsetting. In fact, the roadmap explicitly refers to the mitigation hierarchy - placing credits after avoidance and minimisation - which is the standard framework for offsets. With little demand beyond offsetting purposes, companies are likely to use credits to justify continued destruction or to greenwash harmful practices.4. Dubious pilot projects: The Commissions designated pilot projects raise serious questions regarding their selection, purpose, and transparency. One of the two flagship pilots - a forestry project in Estonia - has been flagged as harmful to biodiversity. 5. Perpetuating market failures and colonial injustice: The inclusion of a pilot project in Peru signals an intent to expand nature credit markets beyond EU borders. This creates the risk that corporations in the Global North will buy cheap credits from the Global South while continuing to degrade ecosystems at home. Such practices replicate colonial patterns of resource extraction and dispossession, often accompanied by land grabbing and violations of the rights of Indigenous peoples and local communities who depend directly on these ecosystems for their livelihoods. 6. A dangerous distraction from real solutions: Designing speculative markets for nature credits diverts time, political attention, and resources from the urgent measures actually needed: ending destructive practices, redirecting harmful subsidies, and scaling up public investment in restoration. A 2024 WWF report shows that the EUs 37 billion biodiversity funding gap could be closed simply by reallocating existing public funds. Turning nature into a financial asset will only allow destructive activities to continue business as usual. The EU should instead prioritise transformational change in tackling the underlying causes of biodiversity loss. This includes stopping and redirecting financial flows and investments that are damaging to biodiversity; enforcing effective environmental laws; and supporting community-led conservation efforts.
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Meeting with Terry Reintke (Member of the European Parliament) and European Environmental Bureau and

30 Sept 2025 · Climate and Environmental Policies

Meeting with Antonella Rossetti (Cabinet of Commissioner Christophe Hansen) and International Federation of Organic Agriculture Movements EU Regional Group and

29 Sept 2025 · presentation of and discussion about their roadmap to reduce pesticide use in Europe

Response to Legislative initiative on CO2 transportation infrastructure and markets

11 Sept 2025

Friends of the Earth Europe is deeply concerned that the European Commissions plans for CO2 transport and dumping and risk a further lock-in of fossil fuels in Europe, further support for the fossil fuel industry who are at the heart of the climate crisis, another distraction from the clean solutions which we need to pursue and yet another dangerous delay to the day when we exit all fossil fuels. CCS already has a long history of failure and wasted taxpayer investment. These plans will waste further taxpayers money on dangerous and unproven schemes which are likely to fail and subtract investment from proven solutions which can and should be made today. We are concerned that the continued discussion and prioritisation of schemes to continue fossil fuel use will delay the decisions and investments required to finally phase out fossil fuels in the EU so that the EU can make it's necessary contribution to reducing greenhouse gas emissions and climate justice. We are also highly concerned by the potential non-climate direct risk to people and the environment from failed CCS projects. While the fossil fuel industry will continue to lobby for 'solutions' which delay the end of their business model, the public interest demands that decision makers focus on real solutions that will truly contribute to combating climate change and provide for a just transition for Europe's citizens. We urge the Commission to discontinue these plans and focus instead on solutions which do not prolong the life and profits of the fossil fuel corporations which have already brought us to a world of increasing climate catastrophes.
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Friends of the Earth Europe calls for community energy targets

11 Sept 2025
Topic — A consultation on protecting and empowering citizens during the European energy transition.
Message — Friends of the Earth Europe calls for clear EU-level targets to expand energy communities. They want to prioritize vulnerable households and prevent corporate capture of local energy initiatives. They also demand redirecting fossil fuel subsidies toward tackling energy poverty.123
Why — This empowers local citizen-led initiatives over large corporations while securing dedicated funding.45
Impact — Large energy corporations would lose market dominance and face stricter oversight against profit-seeking.67
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Friends of the Earth urges robust EU strategy for activists

5 Sept 2025
Topic — EU consultation on a strategy to strengthen engagement and protect civil society.
Message — They demand a systematic civic space impact assessment for all new EU legislation. They call for a comprehensive protection system for environmental defenders under attack. The group seeks a binding agreement to ensure regular engagement across policy stages.123
Why — This would shield the organization from harassment and secure funding for environmental advocacy.45
Impact — Corporations and repressive governments would lose the ability to silence activists using lawsuits.67
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Friends of the Earth urges ban on EU export of banned pesticides

31 Jul 2025
Topic — EU regulation on export and import of hazardous chemicals under the Rotterdam Convention.
Message — The organization demands the European Commission automatically prohibit export of all pesticides banned in the EU for health or environmental reasons by adding them to Annex V of Regulation 649/2012. They call for ending the practice of manufacturing hazardous chemicals like carbendazim and metribuzin for export to countries with weaker protections.123
Why — This would prevent EU-based corporations from profiting by manufacturing banned toxic substances for export.45
Impact — Chemical companies lose profits from manufacturing and exporting banned pesticides to vulnerable countries.67
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Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis) and ClientEarth AISBL and

18 Jun 2025 · Omnibus

Meeting with Ana Miranda Paz (Member of the European Parliament) and European Environmental Bureau and ClientEarth AISBL

11 Jun 2025 · Meeting

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur for opinion) and Transport and Environment (European Federation for Transport and Environment) and

29 Apr 2025 · Omnibus I

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

29 Apr 2025 · Sustainability omnibus

Meeting with Valérie Hayer (Member of the European Parliament)

4 Apr 2025 · Mercosur agreement

Meeting with Irene Sacristan Sanchez (Head of Unit Health and Food Safety)

1 Apr 2025 · Application for authorisation for soy leghemoglobin produced from genetically modified Komagataella phaffii as food ingredient under Regulation (EC) No 1829/200

Meeting with Barry Andrews (Member of the European Parliament, Committee chair)

20 Mar 2025 · Development

Meeting with Lynn Boylan (Member of the European Parliament, Delegation chair)

18 Mar 2025 · Environmental Destruction in Palestine

Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

12 Mar 2025 · Implementation of CRM Act, Strategic Projects that FoEE consider pose seriouse environmental and human rights problems.

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

21 Feb 2025 · • Impact of a possible deregulation of measures to combat climate change • Strategic lines of the next Clean Industrial Deal • The Omnibus Package

Meeting with Estelle Ceulemans (Member of the European Parliament)

20 Feb 2025 · Dossier ENVI à venir

Meeting with William Sleath (Director Secretariat-General) and European Coalition for Corporate Justice and

20 Feb 2025 · The Omnibus proposal regarding the CSRD, the CSDDD, and taxonomy

Meeting with Daniel Freund (Member of the European Parliament) and European Environmental Bureau and

18 Feb 2025 · NGO funding & transparency

Meeting with Pierpaolo Settembri (Cabinet of Commissioner Apostolos Tzitzikostas) and Anti-Slavery International and Clean Clothes Campaign / Stichting Schone Kleren Kampagne

4 Feb 2025 · exchange of views

Meeting with Marie Toussaint (Member of the European Parliament)

28 Jan 2025 · gas project in mozambic

Meeting with Terhi Lehtonen (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and Human Rights Watch and

14 Jan 2025 · Discussion on the CSRD and CSDDD frameworks

Meeting with Fiona Knab-Lunny (Cabinet of Commissioner Michael McGrath) and Human Rights Watch and

9 Jan 2025 · Meeting with a delegation of civil society organisations (CSOs) to discuss their concerns regarding the ‘omnibus’ initiative recently announced by President Von der Leyen.

Meeting with Lynn Boylan (Member of the European Parliament) and SOLIDAR Foundation for Humanitarian, Development and European Cooperation

10 Dec 2024 · Deforestation, just transition and workers' rights in Indonesia

Meeting with Vicent Marzà Ibáñez (Member of the European Parliament)

10 Dec 2024 · CRM in Mercosur FTA

Meeting with Kathleen Van Brempt (Member of the European Parliament)

9 Dec 2024 · Meeting with Indonesian and Mercosur CSOs

Meeting with Marit Maij (Member of the European Parliament)

5 Dec 2024 · Meeting with representative of Friends of the Earth Europe

Meeting with Per Clausen (Member of the European Parliament)

4 Dec 2024 · Forholdene for mennesker og miljø i landområder med storindustrielle animalske landbrug

Meeting with Carola Rackete (Member of the European Parliament)

4 Dec 2024 · Intensive livestock farming

Meeting with Lena Schilling (Member of the European Parliament)

3 Dec 2024 · Gas phase-out

Meeting with Lynn Boylan (Member of the European Parliament)

26 Nov 2024 · Human Rights in Mozambique; UN Binding Treaty on Business and Human Rights

Meeting with Lara Wolters (Member of the European Parliament)

18 Nov 2024 · Due Diligence

Meeting with Lynn Boylan (Member of the European Parliament) and Climate Action Network Europe and Cooperatives Europe

15 Oct 2024 · Facilitating an exchange between Bohemians Climate Coop and NGOs

Meeting with Bernd Lange (Member of the European Parliament, Committee chair) and Greenpeace European Unit and Eurogroup for Animals

14 Oct 2024 · General exchange of views

Meeting with Majdouline Sbai (Member of the European Parliament)

2 Oct 2024 · Pesticides

Meeting with Eric Sargiacomo (Member of the European Parliament) and European Environmental Bureau

2 Oct 2024 · Agriculture

Meeting with Martin Schirdewan (Member of the European Parliament) and Climate Action Network Europe and

26 Sept 2024 · Fairer Handel

Meeting with Chloé Ridel (Member of the European Parliament)

24 Sept 2024 · Environmental policies and EU priorities

Meeting with César Luena (Member of the European Parliament)

20 Sept 2024 · Fossil fuels

Meeting with Ville Niinistö (Member of the European Parliament)

11 Sept 2024 · Upcoming 2040 climate legislation

Meeting with Barry Andrews (Member of the European Parliament)

9 Sept 2024 · climate and environment

Meeting with Anna Cavazzini (Member of the European Parliament) and Germanwatch and Bischöfliches Hilfswerk Misereor e.V.

1 Jul 2024 · Lieferkettengesetz

Meeting with Helena Braun (Cabinet of Vice-President Maroš Šefčovič) and European Environmental Bureau and

9 Apr 2024 · European Green Deal and sustainable resource management

Meeting with Miriam Garcia Ferrer (Cabinet of Executive Vice-President Valdis Dombrovskis)

27 Feb 2024 · FTA negotiations

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and Climate Action Network Europe and

21 Feb 2024 · gas package

Meeting with Maroš Šefčovič (Executive Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

30 Jan 2024 · Green Deal, 2040 climate target, strategic dialogue on the future of agriculture in the EU

Meeting with Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius)

24 Jan 2024 · Northern forests

Meeting with Jutta Paulus (Member of the European Parliament, Rapporteur) and Climate Action Network Europe and

10 Nov 2023 · Methane

Friends of the Earth Europe urges rejection of new GMO deregulation

27 Oct 2023
Topic — EU proposal to deregulate new genomic techniques in plant breeding and food production.
Message — The organization demands rejection of the Commission's proposal to deregulate new GMOs. They want all new genomic techniques to remain regulated under existing GMO rules, including pre-marketing authorization, safety checks, labeling, transparency and monitoring. They oppose exemptions for Category 1 NGTs that would allow release without safety assessments.123
Why — This would preserve environmental protections and prevent corporate control over seed markets through patents.45
Impact — Biotech and seed companies lose faster market access and reduced compliance costs for new GMO products.6
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Meeting with Christophe Clergeau (Member of the European Parliament, Shadow rapporteur) and Greenpeace European Unit and

26 Oct 2023 · Table ronde avec les représentants de la société civile sur la proposition de règlement sur les nouveaux OGM

Meeting with Jan Huitema (Member of the European Parliament, Shadow rapporteur) and Bayer AG and CropLife Europe

24 Oct 2023 · New Genomic Techniques

Meeting with Christophe Clergeau (Member of the European Parliament) and Brot für die Welt and Bischöfliches Hilfswerk Misereor e.V.

23 Oct 2023 · Impact local d'un projet pétrolier au Mozambique

Meeting with Jutta Paulus (Member of the European Parliament, Rapporteur) and Climate Action Network Europe and

5 Oct 2023 · Methane

Meeting with Jutta Paulus (Member of the European Parliament, Rapporteur) and Climate Action Network Europe and

21 Sept 2023 · Methane

Meeting with Marie Toussaint (Member of the European Parliament) and Climate Action Network Europe and Global Witness

4 Jul 2023 · gas phase out in 2040

Friends of the Earth urges 2030 target to cut raw materials demand

30 Jun 2023
Topic — EU regulation on securing sustainable supply of critical raw materials for green transition.
Message — The organization requests a 2030 target to reduce critical raw materials demand, raising recycling targets from 15% to 30%, and stronger protections including mining exclusion zones in protected areas. They oppose fast-track permitting and want mandatory community consultation with full veto rights.1234
Why — This would reduce pressure to expand mining operations in Europe and resource-rich countries.5
Impact — Mining companies lose fast-track permitting advantages and access to protected areas for extraction.67
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Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and Greenpeace European Unit and

27 Jun 2023 · New Genomic Techiniques.

Meeting with Frans Timmermans (Executive Vice-President) and Greenpeace European Unit and

27 Jun 2023 · New genomic techniques

Meeting with Marie Toussaint (Member of the European Parliament)

20 Apr 2023 · BarMar / H2Med pipeline project on the PCI list

Meeting with Lara Wolters (Member of the European Parliament, Rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and

21 Mar 2023 · Meeting to discuss the burden of proof in the civil liability regime of CSDDD

Meeting with Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson) and European Federation of Public Service Unions and

28 Feb 2023 · Cost of living crisis

Meeting with Martin Häusling (Member of the European Parliament) and European Coordination Via Campesina and

7 Feb 2023 · Übergabe der Petition “Keep New GMOs regulated and labelled!”

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and Climate Action Network Europe and Global Witness

26 Jan 2023 · gas regulation

Meeting with Damien Carême (Member of the European Parliament) and Amnesty International Limited and

13 Jan 2023 · Le devoir de vigilance des entreprises

Meeting with Jutta Paulus (Member of the European Parliament)

6 Dec 2022 · Public Webinar organized by Jutta Paulus on Chemicals in Children's Toys

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and Climate Action Network Europe and

30 Nov 2022 · gas market

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

25 Nov 2022 · Energy Charter Treaty

Friends of Earth urges EU to cut raw materials demand

17 Nov 2022
Topic — New EU regulation on securing critical raw materials for green and digital transitions.
Message — The organization requests the EU prioritize demand reduction, sufficiency and circularity over primary extraction. They want an EU-wide material footprint reduction target, binding recycling targets, and strict environmental and human rights standards for all mining projects.123
Why — This would reduce environmental harm from mining and shift policy toward their circular economy priorities.45
Impact — Mining and extraction industries lose easier access to new projects and streamlined permitting procedures.6
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

16 Nov 2022 · On the side of the EU Raw Materials week High Level Conference, the parties met to discuss current issues related to raw materials supply.

Meeting with Heidi Hautala (Member of the European Parliament, Shadow rapporteur) and Amnesty International Limited and

15 Nov 2022 · NGO roundtable on Due Diligence

Meeting with Eszter Batta (Cabinet of Commissioner Thierry Breton), Joan Canton (Cabinet of Commissioner Thierry Breton) and European Environmental Bureau

15 Nov 2022 · Preparation of the critical raw materials act

Meeting with Caroline Roose (Member of the European Parliament) and Greenpeace European Unit and Green Finance Observatory

10 Nov 2022 · COP 15 : derniers développements en matière de financement de la biodiversité, y compris la compensation (Assistant·e·s)

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and Climate Action Network Europe and

9 Nov 2022 · gas market

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides)

8 Nov 2022 · Discussion on Antimicrobial Resistance (AMR)

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and Climate Action Network Europe and

6 Oct 2022 · gas market

Friends of the Earth Europe demands 80% pesticide cut by 2030

16 Sept 2022
Topic — EU regulation on sustainable use of plant protection products and pesticide reduction targets.
Message — The organization demands an 80% reduction of synthetic pesticides by 2030, a full ban of the most hazardous pesticides by 2030, and a complete phase-out of all synthetic pesticides by 2035. They argue the Commission's proposal is too weak and leaves excessive room for Member States to avoid compliance.1234
Why — This would advance their goal of transitioning towards agroecology and protecting the environment from pesticide impacts.56
Impact — The pesticide industry loses revenue from reduced chemical sales and prohibited advisory services to farmers.78
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Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur) and Pesticide Action Network Europe and

27 Jul 2022 · staff only: Discussion on the Harmonised Risk Indicator 1 (SUR proposal)

Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur) and Pesticide Action Network Europe and GLOBAL 2000, Friends of the Earth Austria

20 Jul 2022 · staff only: Discussion on the Harmonised Risk Indicator 1 (SUR proposal)

Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

13 Jul 2022 · staff only: Discussion on the Harmonised Risk Indicator 1 (SUR proposal)

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and Climate Action Network Europe and

23 Jun 2022 · gas regulation

Friends of the Earth Europe demands binding resource reduction targets

3 Jun 2022
Topic — The European Commission is revising indicators to monitor progress towards a circular economy.
Message — They demand all Member States use a harmonized methodology for reporting material footprints. The framework must drive binding reduction targets and concrete policy changes to be effective.123
Why — Standardized data and binding targets would strengthen their advocacy for stricter environmental regulations.4
Impact — Member States currently using custom reporting methods would lose the ability to choose methodologies.5
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Friends of the Earth Europe demands stronger corporate accountability law

10 May 2022
Topic — EU directive requiring companies to prevent human rights and environmental harm in operations.
Message — The organization requests comprehensive due diligence obligations to prevent harm, effective civil liability for parent companies, and mainstreamed climate obligations with concrete reduction targets. They argue the proposal has too many loopholes that will deny justice to affected people.1234
Why — This would strengthen their ability to take legal cases against corporations for environmental and human rights violations.567
Impact — Large corporations lose ability to escape liability through contractual workarounds and procedural compliance.8910
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Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and Greenpeace European Unit and

3 May 2022 · New Genomic Techinques

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and Greenpeace European Unit and

3 May 2022 · New genomic techniques

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

20 Apr 2022 · Energy Charter Treaty

Meeting with Marie Toussaint (Member of the European Parliament)

7 Apr 2022 · Due diligence

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

It’s clear: Now is the time to deliver subsidized renovation & renewable programmes across Europe. This is a no-regret solution to cut our energy bills, end our fossil fuel addiction & reduce our energy consumption to stay below 1.5 degrees. Moreover, inefficient housing is a systemic root cause of energy poverty; with over 50 million Europeans unable to adequately light, heat or cool their homes even before the gas crisis. Friends of the Earth Europe is the largest grassroot environmental network in Europe, with over 30 national organisations & thousands of local groups. We are happy to send more detailed recommendations & analysis directly. With our members we call for: 1.A robust supportive framework to ensure a just introduction of Minimum Energy Performance Standards (MEPS) in the residential sector. MEPS in the residential sector are an integral step to tackle the indecent housing scandal across Europe but the current EPC E ambition is far too low. We call for a requirement for all buildings to meet a EU harmonised, minimum standard of C rather than E by 2030 to ensure decent housing for all. MEPS should be complemented by an increased deep renovation definition with the aim to prioritise a one-step deep renovation approach whenever feasible. It should also be an obligation for MEPS to be introduced in all building segments by 2027. ‘Best practice’ social safeguards & renovation programmes must be showcased to member states including guidance on implementing MEPS alongside rent caps, a ban on renovictions, monitoring rental increases & social rental agencies. 2.Streamlined & increased funding at EU & national level to deliver subsidised renovation & renewable programmes We recommend including a criteria in the EPBD to ensure the lowest income quartile have access to a 100% free of charge deep renovation programmes. This should be complemented by further finance & support to assist all other households particularly for low-income tenants. 3. Further technical assistance from the EU to Member States to deliver socially-just renovation programmes effectively We recommend the European Commission develop further technical assistance alongside the Energy Poverty advisory Hub to support member states on how to deliver socially just, subsidized deep renovation programmes. This should include streamlining relevant funding sources & should be synergised with the development of the national Social Climate Plans. 4. A commitment to Fossil Free homes by 2030 with a ban on fossil fuel infrastructure in new buildings by 2023 & a phase out in existing buildings by 2030. We recommend a ban on fossil fuel infrastructure in new buildings by 2023 (instead of 2027) & a phase out of fossil fuel infrastructure in existing buildings, prioritising residential homes, by 2030. Finally an immediate phase-out of all fossil boiler subsidies is needed with revenue redirected to renovation & heat pump subsidies for the lowest-income households. 5. A requirement for tailored One Stop Shops with outreach programmes. These should be run on a not-for-profit basis by trusted local actors. Member states should be required to deliver tailored one-stop-shop services on a not-for profit basis. These mus have outreach schemes with the ethos of decent, affordable housing for all. These OSSs should combine renewable & renovations support as well as energy & bill advice. Municipalities should also provide further resources & training to social sectors to raise awareness of the co-benefits of renovations. 6. Further incentives & penalties must be put in place for Member States to deliver on their new Building Renovation Plans as governments have typically underdeliver on the Long-term Renovation Strategies in the past. 7. There must be sufficient investment in reskilling workers to deliver on good quality jobs. 8. Finally The EC should deliver on their promise to deliver a strategy for a sustainable built environment which was due in 2021.
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Meeting with Giorgos Rossides (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and

9 Mar 2022 · VTC meeting: Revision of the SUD Proposal

Meeting with Pascal Canfin (Member of the European Parliament) and European Environmental Bureau and Climate Action Network Europe

2 Mar 2022 · Green Deal

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager) and OXFAM INTERNATIONAL EU ADVOCACY OFFICE and

14 Feb 2022 · Sustainable Corporate Governance

Meeting with Frans Timmermans (Executive Vice-President) and European Environmental Bureau and

10 Dec 2021 · European Green Deal and racial justice issues in climate, energy, transport and environment policies

Meeting with Kadri Simson (Commissioner) and

3 Dec 2021 · Discussion on upcoming Hydrogen and Decarbonised Gas Markets Package (adoption foreseen for 14.12.2021)

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson) and Bureau Européen des Unions de Consommateurs and

2 Dec 2021 · EPBD - Energy poverty

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

18 Nov 2021

The revision of this Directive comes at a crucial time. Over 50 million Europeans currently live in unhealthy, leaky homes; forced to choose between heating their homes and having food on the table. Moreover the social cost of inefficient housing is severely understated, with indecent housing linked to over 100,000 premature deaths and a public health burden of over €194 billion a year across the EU. Fortunately energy efficiency is increasingly recognised as the most effective solution to tackle one of the root causes of energy poverty. In the context of the gas crisis, it is imperative we deliver on the Renovation Wave commitment to reduce our energy consumption, alleviate energy poverty and decarbonise heating and cooling in this directive. While we welcome the increase in the energy efficiency target and the proposal to make the EU target binding, this is not enough to stay below 1.5 degrees or to protect those in energy poverty sufficiently. Our allies in CAN Europe recommend an increase to the current energy efficiency targets of at least 45% to ensure we stay in line with the Paris Agreement. This target must also be binding, and not indicative, at national level to reduce Europe's fairshare of carbon emissions. Additionally, further action is needed to fully decarbonise our heating and cooling systems in line with climate targets, whilst ensuring that no European is left behind. We highly recommend a requirement to phase out all fossil fuel subsidies and infrastructure from new buildings by 2025 and existing buildings by 2030. This is also crucial for social justice to ensure energy poor households have access to renewable energy and are not locked into fossil fuels for decades to come. We welcome the revision of article 8 to ring-fence a proportion of Energy Efficiency Obligations (EEOs) savings for energy poverty measures. This, in combination with an increase in the annual energy savings requirement to at least 1.5% from 2024 onwards, will see a substantial step towards developing low-income energy efficiency programmes across Europe and must be kept and strengthened if we hope to meet climate targets and alleviate energy poverty. Secondly Article 22 on vulnerable consumers is an essential step to ensure member states are required to deliver energy efficiency measures to vulnerable groups as well as the important requirement that efficiency measures must have no adverse effects on vulnerable consumers. It is also significant that member states are required to set up national boards of stakeholders on energy poverty mitigation. However those with lived experience of energy precarity should be included in these advisory boards to the government. Impacted groups should be directly involved in the design and implementation of energy poverty definitions, indicators & mitigation strategies. There is ample room to provide further technical assistance to member states to deliver subsidised energy efficiency programmes effectively. This should be in collaboration with the Energy Poverty Advisory Hub and their work with the Committee of the Regions and the covenant of Mayors to catalyse municipality level action. Regarding definitions, the EED should refer to ‘low-income, energy poor and vulnerable households’ throughout. This would allow a much wider target group of those living in need to access support, regardless of the member states current data on energy poverty. Finally we should incentivize & hold member states accountable for revising and delivering on their upcoming NECPs and potential Long-Term Renovation Strategies. At EU level, there is a need for stronger synergies with the proposed Social Climate Fund as well as the EPBD & RED. We look forward to a strengthened EED to tackle energy poverty, cut carbon emissions and provide green good quality jobs across the EU. Friends of the Earth Europe is the largest grassroot climate network in Europe uniting over 30 national groups & over 5000 local groups.
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

17 Nov 2021 · Director General Kerstin Jorna meeting NGOs/CSOs in connection with Raw Materials Week - Civil society organisations (CSOs) involved in the EIP Raw Materials brought forward their views on current developments on raw materials

Meeting with Thierry Breton (Commissioner) and

9 Nov 2021 · Governance, hydrogen

Meeting with Thierry Breton (Commissioner) and

8 Nov 2021 · Sustainable Corporate Governance

Meeting with Ciarán Cuffe (Member of the European Parliament)

4 Nov 2021 · Friends of the Earth

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and International Federation of Organic Agriculture Movements EU Regional Group and

18 Oct 2021 · Presentation of their assessment of the working paper on new genomic techniques +next steps

Meeting with Agnieszka Skonieczna (Cabinet of Commissioner Thierry Breton), Filomena Chirico (Cabinet of Commissioner Thierry Breton)

22 Sept 2021 · Sustainable Corporate Governance

Meeting with Sarah Nelen (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

9 Jul 2021 · Meeting on Fit for 55 package

Meeting with Anne Funch Jensen (Cabinet of Executive Vice-President Margrethe Vestager), Mette Dyrskjot (Cabinet of Executive Vice-President Margrethe Vestager)

22 Jun 2021 · Meeting with NOAH, the Danish member of Friends of the Earth. Topic: Green Deal and Fit for 55

Meeting with Lara Wolters (Member of the European Parliament)

3 Jun 2021 · Event on civil litigation against EU companies for human rights abuses abroad

Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and Greenpeace European Unit and

11 May 2021 · VTC Meeting - New Genomic Techniques and Gene drives

Response to Evaluation and revision of the general pharmaceutical legislation

26 Apr 2021

BUND / FoE Germany welcomes the intention of the Commission to strengthen the pharmaceutical legislation. We regret that the roadmap is apparently limited to human medicines (HMP) and does not include plans to further improve legislative measures for veterinary medicinal products. Focusing on environmental aspects please find attached a more detailed comment on your strategy and additionally a separate file with our position paper on pharmaceuticals in the environment outlining the urgent need to protect the environment with respect to pharmaceuticals. From our perspective the following key points should be considered when amending the legislation: - Antibiotic resistance (AMR) is an outstanding problem for human health and environment. Effective measures to reduce the consumption of antibiotics are necessary. - Since several pharmaceutical substances are detected in the environment measures to limit and reduce consumption of drugs should be implemented. These should include inter alia a safe collection and disposal of medication residues, a mandatory prescription of human medicines with identified environmental hazards and a ban on the advertising of non-prescription medicines. - Environmental risk assessment (ERA) of HMP in the approval process should have more weight. The risk-benefit assessment should be applied like for veterinary medicines. The methods of ERA should be oriented on the principles set forth in the Commission’s “Chemicals Strategy for Sustainability” from October 2020. The requirements for pharmaceuticals containing endocrine disruptors, nanomedicines or GMO should be harmonized with the respective legislation and rules for chemicals and organisms. This is in accordance with the “one substance – one assessment approach” of the above mentioned Chemicals Strategy. - BAT pursuant to Directive 2010/75/EU should be obligatory for pharmaceutical production. - Incentives for the development of non-persistent active substances are needed (“Green Pharmacy”). - The system of pharmacovigilance should be expanded to include environmental effects.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

30 Mar 2021 · EU-Africa cooperation on energy access and green transition

Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen), Renaud Savignat (Cabinet of Commissioner Jutta Urpilainen) and

22 Mar 2021 · corporate due diligence

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

19 Mar 2021

Friends of the Earth Europe fully supports the revision of this directive, as outlined in option 3, to deliver on the Renovation Wave and drastically reduce Europe’s carbon emissions. Renovations can provide extensive co-benefits for tackling climate change, alleviating energy poverty and creating green, local jobs if enabled by a strong financial and legislative framework. This revision comes at a pivotal time. As over 50 million Europeans live in unhealthy, leaky homes: inadequate housing is linked to 100,000 premature deaths a year (WHO, 2019) and a public health burden of over €140 billion across the EU (Eurofound, 2019). It is time to provide renovations for those that need them most. To this end, we welcome the proposed introduction of mandatory minimum energy performance standards (MEPS) as a key measure to meet climate targets and prioritise worst performing buildings, particularly in the residential sector. If properly implemented, these have great potential for increased health, welfare and safe, decent housing. MEPS can drive deep renovation & should be complemented with financing schemes, updated provisions for Energy Performance Certification and a deep renovation standard to maximise impact. We should also consider circularity principles to reduce lifecycle emissions & resource extraction. However our support of MEPS relies on the provision that adequate safeguard measures are introduced to address unjust distributional impacts. If not properly considered, this legislation risks negatively affecting low-income households through increased costs, e.g. rent increases and gentrification. These risks are heightened by the potential extension of ETS to buildings. We call for comprehensive social measures and funding to be put in place to ensure socially sustainable policy; including an EU fund, rent caps and action to address split incentives. To deliver on the Renovation Wave strategy, this revision would also benefit from a more explicit commitment to prioritise low-income households. Although renovations have great potential for the energy poor; it is not a given that these groups will benefit. Hence legislation is required from the Commission to guide member states to target renovations for: 1) social housing residents 2) low-income tenants and 3) low-income homeowners. As noted, renovations require significant upfront investment which is a particular barrier for low-income households. Sufficient funding & financial support is crucial to ensure we see these benefits materialise. We call for an EU fund specifically for low-income energy efficiency measures; this would kickstart further investment in member states. This is also an opportunity to forge clearer synergies with the RED to streamline renovations & renewable installations through a citizen-led, neighborhood approach. Tailored One Stop Shops could combine renewable installations & renovations to provide holistic technical assistance. This service should be inclusive & actively reach out to vulnerable groups facing exclusion; enabling renovations & renewables to be accessible for the energy poor. To conclude, we encourage the Commission to: Prioritise energy poor tenants, low-income homeowners & social housing as primary target recipients for renovations Include binding MEPS with comprehensive safeguards for the residential sector Provide an EU fund for low-income renovations Encourage tailored, accessible one stop shops and a ‘citizen-led’ renovation approach Strengthen synergies between renewables and renovation programmes for energy poor households Leaky roofs, unhealthy homes and wasted energy can and must be a thing of the past. Renovations have the potential to change the lives of millions of Europeans but this is not a given; hence energy poor households must be adequately prioritised in the EBPD. We welcome a revised directive that sets ambitious measures & a strong financial framework for a healthier, more equitable, renovated Europe.
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Meeting with Janusz Wojciechowski (Commissioner) and

17 Mar 2021 · New genomic techniques.

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

22 Jan 2021 · Energy Charter Treaty

Meeting with Stella Kyriakides (Commissioner) and Greenpeace European Unit and

15 Jan 2021 · VC Meeting - Farm to Fork Strategy and GMOs

Meeting with Kitti Nyitrai (Cabinet of Commissioner Kadri Simson) and Climate Action Network Europe and

14 Jan 2021 · TEN-E

Meeting with Virginijus Sinkevičius (Commissioner) and

12 Jan 2021 · To discuss the implementation of the Biodiversity strategy, the actions under the zero-pollution ambition as well as green funding under the new MFF and the recovery funds.

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

This feedback outlines Friends of the Earth Europe’s response to the European Commission’s draft Delegated Act on the EU Sustainable Taxonomy. The EU Taxonomy has significant potential to guide ambitious investments towards a climate neutral Europe. Hence this act requires regular revision to align with increased climate ambition, higher EU emission reduction targets and new regulations. It should also specifically exclude any activities that harm the environment or put climate targets in jeopardy. This will enable the EU to reduce its fareshare of carbon emissions and continually improve alongside updated climate targets. We will specifically respond to the consultation on building renovation which needs attention. In regards to the renovation of existing buildings, the criteria for the “substantial contribution to climate change mitigation” currently outlines a reduction of primary energy demand (PED) of at least 30% for major renovations. This requirement is not in alignment with the ambition of the European Commission’s Renovation Wave strategy which requires energy savings of at least 60% for deep renovations, thus the current percentage in this draft act is a literal half-measure. If this is not revised to encourage deep renovations across Europe, it could hinder investments and risk the Renovation Wave falling short on job creation, air quality improvements, alleviation of energy poverty and carbon emission cuts. When this delegated act is up to date, it will play an important role to incentivise the substantial increase in the rate and depth of energy renovations needed. Therefore for the EU to adequately commit to deep renovations of at least 60% energy savings in line with the climate neutrality objective and the Renovation Wave strategy; this requires a revision to double the current reduction of PED in this proposal. Additionally, the Energy Performance of Buildings Directive (EPBD) will be reviewed in late 2021 and will include the phased introduction of mandatory minimum energy performance standards to prioritise worst performing buildings which was the main recommendation in the Renovation Wave. The current reference to applicable requirements for major renovations in this draft does not take into account this upcoming change (ref.534 of Annex 1). These requirements should be in line with the future revisions stated by the Commission or at least formulated in a way that prepares for an upward revision in 2021 related to minimum energy requirements. Also when two alternative criteria are available, the one that results in the highest energy savings should be applied. EU investment is essential to adequately fulfil the Renovation Wave strategy and make sure it is socially and environmentally sustainable. As 1 in 4 European households live in energy poverty in leaky and inefficient buildings; we need a wave of investment and strong criteria to ensure essential renovations for Europe’s energy poor so no one is left behind. We only have one chance per generation to renovate our building stock, hence substantial funding and investment to grow this sector is necessary so we do not miss this opportunity through limited shallow or bad quality renovations. Finally in light of the Energy Efficiency Directive revision in February 2021, the Energy Efficiency First principle should be properly referenced in this act. As buildings account for 36% of carbon emissions, we would like to reiterate the importance of prioritising deep renovations which is imperative to align with DG ENER’s strategies and the EU’s climate targets.
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Meeting with Didier Reynders (Commissioner) and

4 Dec 2020 · Substainable corporate governance

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and Amnesty International Limited and

30 Nov 2020 · Corporate Sustainability Due Diligence

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

8 Oct 2020 · Energy charter treaty revision

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

6 Oct 2020 · The future of gas

Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen)

24 Sept 2020 · European Green deal

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and OXFAM INTERNATIONAL EU ADVOCACY OFFICE and

22 Sept 2020 · Corporate Sustainability Due Diligence

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

FRIENDS OF THE EARTH EUROPE FEEDBACK TO THE INCEPTION IMPACT ASSESMENT Friends of the Earth Europe is the largest grassroots environmental network in Europe, uniting more than 30 national organisations with thousands of local groups. Since 2013 we have been campaigning to speed up the development of people’s ownership of renewable energy. Renewable Energy Target. We welcome the initiative to increase the target from the current level of at least a 32% share in 2030. To avoid the catastrophic climate impacts we need to urgently switch to a 100% renewable energy system. To achieve a higher renewables target it is essential that the full, accurate and timely transposition of Articles 21 and 22 takes place. These provisions do not need to be revisited; they need to be retained, transposed and implemented as soon as possible. Europe and other rich industrialised countries must do their fair share to act first to combat climate change and create a fossil free energy system. The growth of renewables in Europe must be in line with this fair share and citizen and community ownership of renewable energy should be at the heart of this. To ensure that the switch to a fully renewable system can take place at the pace required communities and local governments must be involved. Community renewable energy projects or RECs increase the popularity and support for the energy transition and prevent local opposition. When energy transitions are unfair, or perceived as unfair, they lose public support and slow down or stagnate. Preserving the REC provisions. We note that this consultation does not propose changes to articles 21 and 22 and we welcome this. We are monitoring transposition of these articles across member states and do not wish to see them opened at this stage. It is imperative that national governments proceed with putting in place both nationally-appropriate definitions of Renewable Energy Communities and establishing an enabling framework to support them. Articles related to community involvement in the energy transition do not need to be revisited; they need to be implemented. We note with concern the lack of preparation for transposition that is taking place in key member states such as Germany and Denmark. We note that some member states are placing only the definition, rather than the full enabling framework into primary legislation, what we call a “copy and translate” approach. Member states will then attempt to create the enabling framework with secondary regulation or ministerial decisions, e,g Flanders and Portugal. This is not sufficient. We need primary legislation that creates an enabling framework for RECs. Enabling framework An enabling legal framework should be nationally appropriate and include financial support, a clear pathway for grid access and a one-stop-shop for advice and permitting. Barriers and potential In understanding what a nationally-appropriate enabling framework is, it is vital that member states carry out an assessment of the barriers and potential of RECs in their countries. In relation to this we draw attention to paragraph 3 of Article 22 and the lack of member states progress on this. The Commission must urge member states to carry out and publish this assessment as soon as possible and give them the support or capacity building required. Hydrogen We anticipate that the revision of RED II will include measures on hydrogen. The European Commission’s European Hydrogen Strategy, clearly defines clean hydrogen as hydrogen from renewable electricity. We would like this definition to be strengthened to include only surplus renewable electricity, which would in turn require increased investments in renewable electricity installations. Any related certification scheme must guarantee that all hydrogen used to contribute to the EU’s renewable energy targets comes from surplus renewable electricity. Any support to hydrogen or hydrogen infrastructure must be exclusively for 100% renewable hydrogen.
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Meeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

10 Sept 2020 · HRDD legislation and sustainable corporate governance

Response to Long term vision for rural areas

9 Sept 2020

Friends of the Earth Europe welcomes the will by the EC to develop a long term vision for rural areas including a holistic approach to find real solutions for Europe’s rural areas that can effectively tackle the current trends of rural exodus, contaminated environments and less and less farmers. We agree that the strategy should be coherent with relevant aspects related to the European Green Deal. Especially important would be an assessment of the impacts of the CAP to some of the challenges in rural areas and evaluating if the suggested actions in the Farm to Fork and Biodiversity strategies are sufficient to solve those (especially those related to the future of the food and farming sector). Rural areas make up half of EU’s area and are the home of around 10 million farmers and their families, as well as generally 20% of EU’s population. Therefore preserving the natural resources in those areas is essential not only for the future of EU’s food production, but also for the heath and well-being of every European citizen. However industrial agriculture has contributed to a number of problems impacting rural areas - biodiversity loss, soil degradation, water pollution, some of which impact directly rural population. The link between the impacts of industrial farming like e.g. use of artificial fertilisers and pesticides, nitrates pollution and ammonia emissions coming from animal farming etc. and those problems need to be further assessed. One example, in 2015, 61% of the EU’s agricultural area was designated “Nitrate vulnerable zones”, areas at risk from agricultural nitrate pollution under the Nitrates Directive. These problems need to be explored by the vision and solutions proposed. Public policies to ensure rural infrastructures and public services are key to stop rural exodus and diversified and relocalised food chains can support this needed shift to more thriving rural livelihoods. The vision should aim to lead to a transformative change towards a sustained and sustainable balance between nature, in a good status, and its use by humans. It needs to call for a new economic model that brings society within planetary boundaries whilst ensuring a good life for all, whilst at the same time ensuring social and environmental justice. In order to improve living conditions in rural areas, policies should be assessed which restore nature and to move away from the further imposition of large-scale, destructive projects, in for example the sectors of farming, resource extraction, hydropower or biofuels. Community-led policy design should be especially looked at to ensure they answer the needs of the rural populations and not be determined by short-term profit opportunities. Transforming the current CAP should be one of the main priorities of the vision. It should make sure that farmers who produce sustainably are rewarded and therefore contribute to the long term survival of rural areas and food production. The CAP budget for the second pillar must be consistent with a vision of vibrant, prosperous and sustainable rural areas. In order to tackle climate change and improve on sustainable development, the vision should look at effective mechanisms to ensure resource sufficiency. The long-term vision for rural areas is an opportunity in this sense as it could make sure to relocalise and diversify resource production, management and use. With a degrowth approach, the EU can play a leading role in an economic paradigm shift that is good for its citizens and environment. There is also need of policy coherence at the different EU and global levels. The EU’s (over)contribution to the loss of biodiversity globally, climate change, resource extraction needs to be urgently reversed through concrete measures to stop its unjust consumption and exploitative trade policy. Rural areas in Europe can be a central factor in the solutions to these challenges and the vision should propose a number of options to achieve those.
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Response to Modernising the EU’s batteries legislation

9 Jul 2020

Batteries put on the EU’s single market must have robust sustainability requirements – we call for an ambitious set of rules regarding the sourcing of raw materials, design and manufacturing stages of batteries, and end of life, as well as the necessary information to be conveyed to end users and the supply chain actors, ensuring as follows: 1. Ethical and responsible sourcing of raw materials at all stages of battery manufacturing. The legislation should encompass full transparency and due diligence requirements covering the entire supply chain. The EU’s current focus on ‘securing social license to operate’ will not ameliorate the growing community resistance to mining projects – it pays lip service to communities’ right to be consulted, but does not recognise their right to give or withhold their consent - a critical and necessary right that must be recognised to balance power relations and avert conflict between mining companies, political authorities and citizens. Thus, any EU sourcing of battery raw materials must recognise and include communities’ rights to Free Prior and Informed Consent, including the right to say no to new projects. 2. Reduced carbon footprint over the whole product value chain and the full production cycle, with particular attention to the manufacturing processes. The regulation should require a disclosure of carbon footprinting of batteries placed on the EU market according to a harmonised methodology and future requirements, as well as mandate the move towards renewable energy sources during production. 3. Circular design, incorporating recycled content and facilitating the reuse, repurposing, remanufacturing, second life, and ultimately recycling. The regulation should remove the identified barriers to those activities. Recycling targets should also be set for specific materials, especially for cobalt, nickel and lithium. A recent OECD report shows that taxes on virgin metals and minerals production and subsidies for secondary metals and minerals as a way to reduce demand for virgin metals and minerals https://www.oecd-ilibrary.org/environment/the-consequences-of-a-more-resource-efficient-and-circular-economy-for-international-trade-patterns_fa01b672-en 4. Mandatory removability and replaceability of batteries, using no tools or common tools and their interoperability by default. The burden of proof to justify the non-interoperability of a battery should be put on the producer. 5. Transparent communication and tracking of performance across these criteria and on material/chemical contents to end users and supply chain actors. 6. Advanced measures to better collect batteries at EoL stage or for second life/reuse. This is of paramount importance to reduce the costs of pollution and treatment in municipal waste streams. Deposit-return or reward systems, provided they prioritise the re-use of batteries and of products in which they are contained, should be encouraged at EU level. Also, the collection targets must be upgraded significantly. 7. Rechargeable batteries should become the norm, notably consumers application should not be equipped with disposable batteries. Only strictly necessary applications might be exempted. Burden of proof to justify the need to use a primary battery must be duly presented by producers in all cases. 8. Upgraded minimum requirements for EPR schemes for batteries towards coverage of all types of batteries, reuse, collection and treatment. EPR scheme should be applied and enforced to online sales too. The “Sustainable Batteries” initiative should take more into account the civil society perspective - CSOs voices echoing principles of the EGD/CEAP are not always sufficiently considered to balance industry representatives in the various processes. Finally, enforcement has to be revisited, as most countries are not actively enforcing even the existing targets in the current legislation. These obligations have to be made clearer and more stringent.
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Response to Chemicals strategy for sustainability

19 Jun 2020

Similar to climate change and loss of biological diversity, the ever-increasing production and use of chemicals is threatening the Earth´s ecological balance, planetary boundaries are in danger to be irreversibly exceeded. The current Covid-19 pandemic shows where loss and degradation of natural habitats can take us. A sustainable chemicals policy must aim at reducing material flows, interlinking chemicals, resource, product and waste policies and be closely geared to the principle of precaution. In this context, the Chemicals Strategy for Sustainability could settle a transformative agenda committed to zero-pollution and non-toxic environment goals as defined in the European Green Deal. It is time for an ambitious commitment to drastic reduction of chemical pollution in line with the global sustainable development goals which gives citizens confidence that clean air and water, safe food and products, good living and working conditions for everyone in functioning democracies are truly achievable. The BUND/Friends of the Earth Germany position „Challenges for a Sustainable Chemicals and Materials Policy – The Need for Transformation in the Global Context“ (attached), contains our view of the main priorities. Basics are: • Taking serious and implementing the United Nations Sustainable Development Goals through adequate and binding measures. • Chemicals policy must focus on the principles of precaution and sustainability enshrined in EU treaties. • Slow down and reduce material flows through resource efficiency, recycling and sufficiency in handling and use of substances and materials. • Consider waste hierarchy as key to reducing material flows by integrating and complementing substance, product and waste legislations. • Sustainability needs everybody: governments with regulations and incentives, companies taking up their global responsibility, citizens changing consumer behaviour. REACH/EU chemicals legislations • Strict requirements for import AND export products, intermediates, polymers and nanomaterials • Strick requirements for implementation and updating of registration dossiers (no data, no market) (https://eeb.org/a-third-of-chemicals-break-eu-safety-laws) • Speed up evaluation, risk management and restriction, no authorisations for SVHC when safe alternatives available • Joint assessment of substance groups where appropriate • Set up additional SVHC criteria for persistent, mobile and toxic (PMT), very persistent and very mobile (vPvM) substances, classy endocrine disruptors as SVHC • Make sure that identified SVHC are restricted across legislations • Full disclosure of substances in materials, articles, products and waste • Support ECHA´s SCIP database and interlink to other data bases e.g. Ask REACH data base • Improve REACH Art. 33 to make sure that consumers are provided with reliable information on harmful substances in products (see www.bund.net/toxfox and www.askreach.eu) • Consistent strategy for managing material flows aiming at non-toxic material cycles, considering that also non-toxic substances might hinder effective recycling (https://enveurope.springeropen.com/track/pdf/10.1186/s12302-019-0236-7) • Address mixtures of chemicals • Promote substitution of hazardous chemicals by integrating Green Chemistry principles, phase-out non-essential uses, support of SMEs, financial incentives for substitution International Policy • EU takes a leading role in the current process for a strong new „SAICM beyond 2020“ treaty for the sound management of chemicals and waste • Develop an international framework convention on chemicals and materials safety including resource policy • EU legislation for decent working and social standards along supply chains from globally operating EU companies • Extend REACH provisions to substances, mixtures and articles for export to non-EU countries in order to avoid double standards • Withdraw existing EU exemptions in the POPs regulation allowing use of hazardous substances banned
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Response to A EU hydrogen strategy

8 Jun 2020

No room for fossil hydrogen Friends of the Earth Europe is very concerned about the level of attention given to hydrogen in the debate on the decarbonisation of Europe’s energy system. Despite optimistic projections in industry-funded studies, we have serious reservations about the ability of hydrogen to deliver at the scale and speed necessary to play a large role. In the absence of evidence that hydrogen will be able to play that part, the European Commission should not focus its efforts on hydrogen but rather existing solutions with scale up potential such as renewable energy. Therefore it should not propose a Hydrogen Strategy, but rather continue to explore the potential of fossil free hydrogen to play a role in the energy transition. In order to help avoid the worst impacts of the climate crisis, Europe must phase out all fossil fuels, including fossil gas, by 2030. Research carried out by the University of Manchester [1] shows that “there is categorically no role for bringing additional fossil fuel reserves, including gas, into production”. This means the EU must plan for the phase out of fossil gas and all associated infrastructure in the next decade. This also means that there is no future for technologies that use fossil gas, including hydrogen produced from fossil gas - with or without the supposed application of (CCS) at scale. Europe’s energy transition must rely on proven technologies that are already delivering emission reductions. This means prioritising energy efficiency and demand side solutions as the guiding principle for all energy system planning. These measures have extraordinary co-benefits such as improving building comfort, tackling energy poverty, improving air quality and associated health benefits. On the supply side, direct electrification via 100% renewables must be the priority. These technologies are proven, mature and generating significant cost reductions. They are fit well with the democratisation of the energy system. Citizens and communities can participate directly in and benefit from the energy transition through renewable energy projects. There is no room for fossil gas, or hydrogen produced from fossil gas in Europe’s energy transition (terms such as ‘grey’ or ‘blue’ hydrogen should not be used and instead a clear set of definitions should be established). The only form of hydrogen that should receive EU regulatory and financial support is hydrogen from additional renewable electricity. Despite optimistic industry projects, independent assessments suggest that this technology will be very limited in volume for some time. This is largely due to the much higher costs of this form of hydrogen as well as its reliance on the build out of renewable electricity sources. Currently, more than 95% of European hydrogen production is based on fossil fuels. Given this significant constraint, hydrogen from renewable electricity should only be used only in sectors that are difficult to decarbonise otherwise. That means it should not be used e.g. in passenger cars or residential space heating. Overestimating hydrogen potential risks failing to decommission obsolete gas pipelines , creating stranded assets and high carbon lock-in. A failure in delivering the anticipated volumes of hydrogen from renewable electricity will result in falling back on fossil gas and hydrogen produced from fossil gas. These options are unacceptable from a climate science perspective. The Commission has proposed the creation of a ‘European Clean Hydrogen Alliance’. There is also mention of a ‘European Partnership for Clean Hydrogen’. The function and composition of these entities is not clear but the Commission must not create governance systems that put undue influence over policy decisions into the hands of the industry it is regulating. [1] Anderson, K & Broderick, J 2017, Natural gas and climate change. University of Manchester.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

6 Jun 2020

An environmental, economic and social emergency Economic and social shockwaves as a result of the COVID-19 pandemic have already begun to impact Europe. With a high likelihood of an economic recession we are now at a junction of two emergencies: socio-economic and environmental. While the impacts of climate breakdown are becoming more visible every year as people across the world suffer the consequences of droughts, floods and other climate disasters the socio-economic crisis threatens further harm. Energy poverty, a major issue before the economic crisis, is now set to explode. 80 million Europeans already live in homes that make them sick. Buildings in Europe are highly inefficient: a 2017 BPIE study has shown more than 97% of buildings must be renovated to achieve decarbonisation. Inadequate buildings can be tied to half of excess winter deaths. The Renovation Wave must tackle this pressing issue: indecent housing must be eradicated. An ambitious renovation wave can also lower energy bills for the 50-90 million Europeans who cannot afford their energy bills in winter and summer respectively. To weather the crisis, Europeans urgently need a green bailout: providing healthy, zero-carbon homes for all, creating millions of jobs, and slashing energy bills. New legislation is needed. To address current low rates of renovation across Europe, strategic communication will not be enough. new legislation is crucial to start phasing out inefficient buildings at speed. Policies putting in place minimum requirements for buildings energy performance is the best legislative tool to phase out inefficient homes. Some European countries have, for example, banned the letting of homes in lower efficiency bands (UK), or require all buildings to be in minimum categories by a certain year (Netherlands). At the EU level, Energy Performance Certificates (EPCs) must also be strengthened, as their quality vary across the EU. Efforts should not be wasted on shallow renovations. The focus on doubling renovations is welcome but is not sufficient and without adequate measures, it risks incentivising shallow renovations rather than the deep renovations ultimately required. The Renovation Wave should include provisions for new review mechanisms to ensure that the national Long-Term Renovation Strategies are of high quality, and put in place credible measures to meet their long-term objective of decarbonising the building stock. The 2050 decarbonisation objective in the EPBD is too far away to ensure political accountability. Specific, enforceable milestones and review mechanisms are needed. Regarding energy poverty, the European Parliament has asked in its resolution on the European Green Deal that renovation costs should not be passed on to low-income households -- policy tools must ensure this is not the case, and that legislation improves peoples’ standards of living and lowers energy poverty. The EU must also enforce the Clean Energy package which calls for national action plans against energy poverty. To accelerate investments in housing renovation, the low 2030 energy efficiency target of 32,5% must be steeply increased. The target must also be made binding, with five-year plans to meet it. Rather than bail-out polluting industries, EU relief funds, must be redirected towards renovation efforts, through the EU budget and the Just Transition mechanism. Efforts must also be made to decarbonise heating sources by rolling out 100% renewable energy-based heating and cooling systems in buildings. Governments must urgently shift away from fossil fuels and phase out all public support for fossil gas infrastructure from oil and gas boilers to building new gas pipelines. Community energy projects also support energy savings: they must be supported both financially and in full implementation of the relevant EU legislation. Finally, coherence with other building-related legislation such as the Circular Economy Action Plan should be ensured.
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Meeting with Didier Reynders (Commissioner) and

5 Jun 2020 · Sustainable corporate governance

Response to Climate change mitigation and adaptation taxonomy

26 Apr 2020

FEEDBACK on Sustainable finance – EU classification system for green investments TEG experts keep nuclear out of the Green Taxonomy The TEG report was conducted in a concisive manner with a clear result - also concerning nuclear. The experts who prepared the TEG report concluded that they cannot see a sustainable way of managing nuclear waste. Since some member states and some industry representatives continue their efforts to have nuclear included at least as transition technology, we need to shine some light on some arguments in particular nuclear waste management, where we share the TEG expert’s view that high level waste is incompatible with fulfilling the sustainability goals. Nuclear waste remains unsolved – and it might stay that way After 60 years of commercial operation of nuclear power plants not a single final repository for and spent fuel and other high level waste is working anywhere around the world. Here again, facts weigh more than arguing that experts agree that in theory a Deep Geological Repository might be best and R&D is almost there. Another popular argument used by industry: The EU has strict rules on waste. However, it is an illusion to believe that the Nuclear Waste Directive 2011/70/Euratom solves all open questions. In its 2nd Report on the progress of implementation of the Nuclear Waste Directive The European Commission summarized that: „[...] more needs to be done.” Impacts of nuclear accidents affect the world forever While some would like to forget them as quickly, they are actually everyday business of the nuclear generation. The debris and molten core are still there, another enormously expensive shelter was recently installed, but the 1986 Chernobyl accident consequences continue being a threat for people and environment. The situation is far from safe, current forest fires threaten large parts of Europe with radioactive contamination. Also the 2011 Fukushima accident is still out of control, not even robots can work in this environment to start clean-up. The pollution of the environment is still everyday reality, currently the tanks on site will be emptied, because no other solutation seems to be viable. This water does not only contain the radioactive isotope Tritium, but also numerous other harmful radioactive isotopes, including long-lived isotopes such as Cesium-137, Strontium-90 and others. More details can be found on the website of the plant operator TEPCO . The Japanese government’s plan (!) suggest to release: Nuclear energy is not CO2-free Nuclear energy is definitely not CO2-free. Its CO2 emissions are only slightly higher than those of renewable energies like solar and wind – but only as long as the uranium ore grade is high. As uranium has to be produced from ore with a low grad, which will be the case within this century, CO2 emissions are going to rise significantly. The range seems to be differing widely, however one those few companies who ever mentioned this was e.g. EDF by stating that their fleet produces around 57 CO2eq/kWh currently. Recommendations We agree with the assessment the TEG report arrived at and see no further need for another group of experts, a close look at the much-quoted 2018 IPCC 1.5 degrees report also refrained from recommending nuclear energy as a means to combat climate change. We would recommend the European Commission respects this assessment and does give in to nuclear industry‘scallfor the establishment of yet another expert group. Clearly the usual closed circle of pro-nuclear institutions such as IAEA, NEA etc. is meant who will copy-paste their reports into another format. The Platform which is supposed to start work in autumn 2020 will be responsible for updating and extending the technical criteria. We demand that - in case nuclear energy is still on the agenda – also academics and other experts are included to avoid the “nuclear“ experts from hijacking this exercise. Instead we hope that this EU policy initiative of defining a Gree
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Meeting with Valdis Dombrovskis (Executive Vice-President) and

24 Apr 2020 · Economic recovery, sustainable finance taxonomy, EIB energy lending policy, Just Transition Mechanism, Industrial Strategy, Integrating SDGs in the European Semester

Meeting with Thierry Breton (Commissioner) and Transport and Environment (European Federation for Transport and Environment) and

15 Apr 2020 · Priorities for the Coronavirus recovery

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Greenpeace European Unit and Slow Food

4 Mar 2020 · Transition Towards Sustainable Food Systems and European Green Deal

Response to Farm to Fork Strategy

2 Mar 2020

A/ The strategy must develop a coherent vision and bold actions for a transition towards sustainable food systems. It should challenge the practices, interests and values of a wide range of actors and administrative bodies. A transition strategy should also acknowledge the existence of barriers to change and system “lock-ins” that constrain the current pathway towards a sustainable food system. It must pave the way for reforming policies where needed, integrating existing policies, or creating new policies where gaps exist. The CAP must be fully aligned with its objectives and targets. The problem definition is too narrow. The sustainability of food systems needs to be seen in much broader contexts: Concentration in the food chain and corporate control over decision making; The role of the EU in the global food system and its contribution to climate change, biodiversity loss, water and air pollution, and soil degradation. In terms of the economic survival of the agricultural sector, special attention needs to be paid to the disappearance of small-scale farming. The unsustainability of Europe’s animal farming and the overconsumption of meat, dairy and eggs is missing. B/ The strategy needs to address 7 key policy areas: 1) Develop an inclusive and transparent governance framework for policy coherence and transformation; 2) Support a transition to food production that safeguards the environment, climate and health; 3) Drive a transition to sustainable, healthy diets; 4) Establish a socially and economically just food system; 5) Ensure the welfare and health of farmed animals; 6) Promote participatory research and knowledge exchange; 7) Drive global action for sustainable food systems. The following are especially important for FoEE: Creating a new food and farming system: The EU’s strategy needs to follow scientists call for transformative change and develop a new economic model and food system that brings society to within planetary boundaries whilst ensuring a good life for all and ensuring social and environmental justice. A socially just food economy: Measures and targets to halt the loss of farms under 10 hectares, recognising the role small, peasant and family farming structures. Fairer payments for farmers the recognise the UN Declaration on the Rights of Peasants and Other People Working in Rural Areas; Support alternative business models such as short supply chains and consumer cooperatives. The strategy needs to ensure that everyone can access safe, healthy and sustainably-produced food; Define indicators for more nature and environmental-friendly farming as condition for any public support for digital farming under EU research and the CAP. Stopping the ecological collapse: An urgent transition towards agroecological farming, funded by CAP; Phase out synthetic pesticides use by 80% by 2030; Remove subsidies for industrial livestock production, and place legally binding restrictions on feed imports linked to deforestation and rights violations. Citizens first: a healthy and safe food system: Policies across the food chain to support less and better meat and dairy consumption; Ensure that research and innovation in the food sector follows the precautionary principle, and focuses on delivering the societal transition needed to empower food systems change;Increase food and environmental standards and ensure that newer generations of GMOs (eg gene editing) are fully assessed and labelled under the current GMO legislation. Cutting our footprint: a globally just food system: Introduce regulatory measures that cut the EU’s use of agrocommodities such as palm oil and soy products; Introduce legislative measures that oblige companies to carry out supply-chain risk analysis and measures to ensure that no products that contribute to deforestation or conversion of natural ecosystems enter Europe; Establish assessment methodologies on the impact of EU policies and trade deals on food systems in third countries.
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Response to Minimising the risk of deforestation and forest degradation associated with products placed on the EU market

28 Feb 2020

A/ We welcome the acknowledgement that the expansion of agriculture is one of the most important drivers of deforestation and the role of the EU's trade in this is clearly recognised. We are however disappointed that despite this recognition, clear acknowledgement of the need to cut the EU’s demand for agrocommodities is missing from the problem definition. This is a significant failure that will open up the EU initiatives to justified criticism. A wider problem definition is required, looking at the sectors and policies that drive the EU consumption of products related to deforestation and rights violations. This should include demand created by industrial agriculture and biomass for animal feeds and bioenergy/biofuels, and the policies that underpin these sectors. The EU’s inequitable and overconsumption of resources, in particular related to vegetable oils and products of animal origin, needs to be the central issue addressed by deforestation initiatives, especially if the EU wants to adequately capture indirect land-use change effects. Transformative change from industrial agriculture to agroecology and the advancement of community-based forest and land governance has to be the core aim of any EU action. The role of good forest governance, and the role of forest communities, is missing from the analysis. From community forest management (CFM) to agroecology and short supply-chains, initiatives around the world demonstrate how forests can be preserved in a way that protects the climate, promotes biodiversity and ecosystem services, and allows communities to strengthen their tenure rights and take control of their livelihoods and local food systems. The EU’s role in promoting and securing CFM should be a complimentary part of its role in halting and reversing deforestation and forest degradation. B/ We agree with the main aim expressed to “minimise the EU’s contribution to deforestation and forest degradation worldwide” but we disagree that the promotion of consumption of products from deforestation-free supply chains in the EU should be a complementary aim. The EU should prioritise solving the root causes of deforestation and therefore should be focused on reducing the EU’s overall contribution to global agriculture expansion as part of a wider EU strategy to reduce its global resource footprints to equitable and sustainable levels. Putting an emphasis on improving the sustainability of supply chains and consumer information, whilst welcome, will not address the environmental and social impacts caused by the EU’s high demand for resources. We would be very concerned if initiatives focused on consumer labelling (mandatory or not) are presented as an option to halt deforestation. The burden should not be put on consumers but on the businesses profiting from expanding agriculture. Important rule-makers such as the EU need to bring in legislation and policies that cut demand and define clear rules for businesses. Whilst we see violation of human rights mentioned in the problem description, we see no mention of human rights in the aim. Human rights should be added to the aim to direct the scope of regulation and policies and ensure the human rights violations in supply chains are addressed. We would also like to see the promotion of good forest governance in the aim in order to open up to collaboration with deforestation countries to improve the livelihoods of those dependent on forests. There is ample evidence that voluntary measures are not effective to halt deforestation. The impact assessment should go into detail on the different forms of Due Diligence regulations, including Duty of Vigilance, mandatory due diligence and be very explicit about the different impacts. D/ We would like to stress that consultation of actors, especially civil society, in deforestation countries should be well resourced and organised by the EC. Full and accessible information and processes should be offered.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

28 Feb 2020 · Green Deal and circular economy

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Giorgos Rossides (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and

19 Feb 2020 · Farm to Fork

Response to EU 2030 Biodiversity Strategy

20 Jan 2020

Friends of the Earth Europe (FoEE) supports the EU’s commitment to lead the world in the negotiations on a post-2020 global biodiversity framework. An inherent part is leading by example and to adopt a comprehensive, ambitious and effective EU Biodiversity strategy by 2030. FoEE refers to the joint European Habitats Forum input and FoEE’s own input to a new biodiversity strategy from May and October respectively (annexed). FoEE agrees on the five specific points listed in the Roadmap, section B. In order to achieve this, the EU and its member states should: - finalize the Natura 2000 network and ensure its active implementation, i.a. by establishing a participative and effective management for every site, and implement the EU’s green infrastructure (TEN-G) as priority Identify the area of degraded habitats and accordingly set concrete restoration targets - Ensure a substantial reform of the CAP to shift agriculture towards agroecological approaches, eliminate perverse incentives, and introduce ambitious targets to phase out pesticide use by 80% by 2030 and ensure 30% of agricultural area in under organic farming by 2025. Further support outcome-based agri-environment measures. Set out a transition away from factory farming with mandatory cuts to overall livestock numbers. - Biodiversity proof international trade policies with an obligatory assessment of their impacts, further mainstream development funds (ODA) and adopt regulations that ensures that corporations respect international social and biodiversity standards. Set circular economy targets to reduce the EU’s absolute resource consumption levels, especially to reduce agrocommodities such as palm, beef and soy. - Ensure sufficient funding and human resources for the implementation of the strategy, as well as earmarking at least 0.5% of its budget for the support of biodiversity. As stated in our position for OEWG-1 (see annex), the most important part of the EU’s position for the CBD COP 15 should be to strengthen implementation, notably by: - Basing the new global biodiversity framework on a whole government approach to implement the GBF/EU Biodiversity strategy, with implementation overseen at the highest level and done by every ministry according to their competence - Ensuring a participative, inclusive and rights-based approach by giving the public access to information, ensuring public participation in decision-making and giving access to justice in environmental issues, as enshrined in the Arhus convention - Streamlining NBSAPs and National Reports by agreeing on a consistent standard format, and establishing a mandatory peer review process for every country, based on an institutionalised procedure - Agree indicators that assess the indirect drivers of biodiversity loss and spell out what transformative change means - A compliance mechanism (like in the Århus or the Bern Convention) and ensure sufficient finance for biodiversity We do not support mechanisms that financialise nature, such as by offsetting or institutionalizing voluntary commitments, and we recommend not to oversimplify the targets, i.a. by setting an apex goal that does not cover all three objectives of the Convention. Messaging and Content should be separate. Finally, we urge NOT to set any targets for increasing consumption, as included under the “meeting people’s needs” section of the zero draft, and put management plans for protected areas and an obligation to update NBSAPs into the targets. Following widespread scientific opinion, the EU and global strategy should lead to a transformative change towards a sustained and sustainable balance between nature, in a good status, and its use by humans. It needs to call for a new economic model that brings society to within planetary boundaries whilst ensuring a good life for all, whilst at the same time ensuring social and environmental justice.
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Response to A new Circular Economy Action Plan

17 Jan 2020

Friends of the Earth Europe call on the European Commission to act with more ambition. What we see of the new Circular Economy Action Plan so far falls short of the urgency required to match the scale of the global ecological crises we are facing. We urge that priority is put on “making the circle smaller” ie reducing the absolute quantity of natural resources that go into our economy to within ecological limits, and reducing the quantity of waste coming out, with a focus on reuse. We need to set legally binding targets on these. The Roadmap states that “Global material use has tripled in the past decades and without intervention, it is expected to double in the next 40 years”. Indeed, current global consumption is beyond planetary boundaries and is driving further destruction to wildlife, and driving up greenhouse gas emissions. The EU consumes more than its fair share of resources, and thus has a greater responsibility to act. FoEE urges the Commission to move beyond the focus on decoupling of resource use from GDP and go further than “increasing the circularity” of products. Efforts to decouple GDP from resource use have been made for decades and have not succeeded - relative decoupling has occurred in some instances, yet evidence shows absolute decoupling is unlikely to succeed. Thus, the pathway of “decoupling” cannot reduce resource use on anywhere near the scale required to deal with global environmental breakdown. The focus needs to be solely on absolute reduction of resource use. Furthermore, we need to address “systems” not just “products” and “materials”. It is positive to see a “sustainable products policy” promised in the Roadmap that will give options to “prioritise reuse and repair before recycling”. However, in particular regarding attempts to increase reusable packaging at scale, FoEE emphasise the need for cross-sectoral policy approaches. Both the packaging material and the product in the packaging itself need to be addressed together to make reuse viable. For example, efforts to increase reuse for food and beverage packaging go hand in hand with efforts to relocalise food systems and move to shorter more sustainable food supply chains. Therefore, FoEE asks you to include in the new Circular Economy Action Plan: ● Limits to absolute natural resource consumption by establishing a clear headline target for virgin resource reduction: such a target would enable the measurement of progress of a circular economy and provide a legal driver to support ambitious resource reduction legislation and drive true solutions. It could play a similar role to climate or energy efficiency targets. The headline target should be based on the Total Material Consumption indicator, aiming for at least a 50% reduction by 2030 (baseline 2017 levels) and with a dashboard of sub-indicators on land, water and carbon, such as in the 2011 EU Roadmap to a Resource Efficient Europe ● Set an EU level binding waste prevention target: the Roadmap states “The action plan will help reduce waste generation and support the modernisation of certain waste laws so that they further contribute to the circular economy” - it is vital that a binding EU target is set up the cap the level of municipal solid waste in kg per capita per year that Member States can generate. Specific sectoral targets could also be set in key areas such as for food waste, construction waste, industrial waste, and packaging waste ● More systemic measures to increase reuse: in particular for packaging. It is vital binding packaging reduction targets and packaging reuse targets are set (the commitment to look into this by 2024 in the PPWD must be sooner). As well as cross-sectoral cooperation to make reusable packaging more viable (with DG TRADE, SANTE, AGRI), prioritise reusable packaging/products in GPP and look into the obligation for Member States to facilitate the introduction of reuse Deposit Return Systems with standardised containers for consumer packaging
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Response to Evaluation of the effectiveness and policy coherence of the guidelines for trans-European Energy infrastructure

9 Jul 2019

The TEN-E Regulation should be a cornerstone of the EU regulatory framework that organises the energy transition we need to meet EU’s climate and energy objectives. Six years after its enactment, the Regulation and its guidelines however require a thorough examination and update based on the many new climate objectives agreed by the EU since 2013, and based on the many weaknesses the implementation of the guidelines has revealed. You can find in the document attached the details of our views on what should be improved in the TEN-E guidelines and on what should be looked at as part of the future public consultation and as part of the assessment the European Commission is about to make: - Since 2013, many new climate objectives have been set at the European level that should be enshrined at the core of the TEN-E guidelines: The Clean Energy Package, the updated 2030 objectives, the European Commission’s 2050 long-term climate strategy, but also the Paris Agreement, the IPCC 1.5°C report and the ongoing discussions to reach carbon neutrality by 2050. They should all have impacts of the TEN-E governance: If the EU genuinely aims at keeping temperature rise below 1.5°C (or well below 2°C), it should phase-out as quickly as possible fossil fuels from its energy mix and therefore start this challenging process by stopping the support given to the construction of new fossil gas infrastructure which will prolongs the fossil fuel era. - The sustainability criterion, one of the alleged four criteria pillars for PCI gas projects, is today an undefined empty shell which should become an overarching criterion that no PCI project should be able to bypass as it does today: For gas projects to become PCIs, they should be able to demonstrate that their full life-cycle (including upstream and downstream CO2 AND methane emissions) is Paris compatible. - The role of ENTSOG should be seriously reconsidered: their conflicts of interest and the lack of transparency of their work (TYNDP, CBA methodology and gas demand projections in particular) create artificially inflated need for unnecessary new gas projects. - The efficiency first principle is not implemented as part of the needs assessment methodology. - The evaluation of the TEN-E guidelines should not limit its scope to what happened between 2013 and 2019, but should also be forward-looking, first because new gas projects are built for the next 30 to 50 years, and secondly because the TEN-E guidelines should anticipate the consequence of the completion of the gas market planned for 2022 according to the European Commission. - The methodology to count projects also lacks transparency. The large amount of gas projects in the PCI largely overshoots the initial objective set in the Regulation and is too often hidden by clustering projects together. While the European Commission supposed to give electricity projects “the major part of the financial assistance available to those projects”, facts show that gas projects have received proportionally way more support than they should have. This is not how carbon neutrality will be achieved. - The ongoing lively debates on the potential of new forms of gas should be used to justify new transmission gas infrastructure: their potential is limited, their viability needs to be proven and their sustainability criteria need to be defined. - The ACER has been repeatedly questioning the legitimacy of large number of PCI gas projects which do not show progress and which don’t demonstrate that their alleged benefits outweigh their costs. - The public consultations organised for the PCI list don’t have any impact on the selection process and question the transparency, governance and social licence of the entire process. - The lack of transparency of the overall process partly comes from the very short life of each PCI list (2 years). Extending it to three years would probably help organising a more participatory and transparency process.
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Meeting with Miguel Arias Cañete (Commissioner) and WWF European Policy Programme and

4 Jun 2019 · Debate on the strategic agenda and its relevance for climate and energy, NECP recommendations

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)

22 Feb 2019 · discussion on legally binding instruments for corporate accountability

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

18 Oct 2018 · discussion on Plastics Strategy

Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella)

18 Oct 2018 · Single Use Plastics

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and Zero Waste Europe and Seas At Risk vzw

5 Oct 2018 · discussion on the implementation of the Plastic Strategy

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and Zero Waste Europe and

13 Apr 2018 · discussion on single-use plastics legislation

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and European Environmental Bureau and

13 Apr 2018 · Single use plastic

Response to EU Pollinators Initiative

22 Dec 2017

EU Pollinators Roadmap - see below and attached Response by Friends of the Earth Europe Friends of the Earth welcomes the opportunity to comment on the roadmap for an EU Pollinators Roadmap, which we support and are keen to see develop. Urgency As well as welcoming the EU Pollinators Roadmap we recommend that the initiative is treated with a strong degree of urgency, rather than as just another activity to be undertaken. The EU needs to inject a sense of urgency and find ways to add impetus to existing programmes and activities and be prepared to focus on particular areas where progress can be made especially to boost knowledge and its practical application. Wild bees We welcome the prime focus on wild bees and pollinators as opposed to managed / domesticated honey bees. Knowledge transfer Bee and pollinator decline requires rapid assimilation of evidence and knowledge of the best actions to take to help reverse the situation. Therefore a useful role for the EC would be to improve and speed up knowledge transfer between Member States so that each nations does not have to go through the same long learning curve. For example the EU could support: - a series of EU-wide Bee and Pollinator Summits to help fast-track learning about the issues and the practical actions; - rapid learning of the scientific evidence on pesticides and on practical measures for land owners, users, farmers and growers also to avoid slow learning curves; - by putting funds into boosting community-based activity in response to bee and pollinator decline. B. What does the initiative aim to achieve and how This section should be clearer that the consequences (whether intended or unintended) of the EU Common Agriculture Policy need to be reviewed in the light of bee and pollinator decline. This is also timely because of the renegotiation of CAP. For example, the EU needs to be specific about the role, either positive or negative, of the role of the CAP under BII, “Tackle the causes of the decline of pollinators, including by: a. Supporting the maintenance and restoration of diverse pollinator habitats in rural and urban areas through improved use of existing EU tools and policies”. Implementing nature directives Also under II.a the EU should highlight the importance of proper implementation and enforcement of the Birds and Habitats Directives as was committed to as an outcome of the REFIT process. The importance of protected sites was also pointed out by the European Red List of Bees report by IUCN which noted that many rare and scarce species are only found within Natura 2000 sites saying that “protected areas provide an essential tool in conservation even if these sites were never designated based on the presence of particular bee species”. In terms of Member State action, there is also a basic need for national planning policies to ensure protection of bee habitat and require bee friendly landscaping in new developments. Pesticides Also under point II.b on pesticides the roadmap refers to enhancing the risk assessment of pesticides but there is no specific reference to adopting the Bee Guidance document. What can the EC do to make sure this happens, as this still seems to be in stalemate? And also on pesticides, it will be important that Member States are held to account for the lack of progress on IMP and pesticide reduction. The European Commission has said that it is disappointed with the National Action Plans but this does not provide clarity on what it will do to ensure the Sustainable Use Directive is actually implemented? Research Under BI the EU may wish to conduct more specific research than the general research outlined in the roadmap. For example, to expedite action and inject the necessary sense of urgency, the EU could conduct research to identify regions and Member States where particular urgent attention is required either to restore conditions o
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Meeting with Frans Timmermans (First Vice-President) and European Environmental Bureau and

6 Nov 2017 · Discussion on EU Plastics Strategy

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Green 10 and

26 Oct 2017 · Plastic strategy

Meeting with Ann Mettler (Director-General Inspire, Debate, Engage and Accelerate Action) and CEE Bankwatch Network

18 Sept 2017 · Sustainable Development Goals

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and European Environmental Bureau and

4 May 2017 · Green Ten contribution to the White Paper reflection on the future of Europe

Response to Monitoring Framework for the Circular Economy

3 May 2017

pls see full text in attach: 1. Full coherence across EU policies and initiatives, in particular the 2030 Agenda for Sustainable Development: Measuring the externalities of our domestic policies, in this case the Circular Economy – this means fully aligning with all the SDGs and not just a few chosen ones, like SDG 12 on SCP and SDG 8 on sustained growth. For example, if we are to achieve SDGs 1 (no poverty) and 2 (zero hunger), our high reliance on resources from outside our borders will likely hinder these goals – Europeans’ high levels of consumption of imported raw materials is associated with local food supply issues, social conflicts due to land grabbing, water scarcity, deforestation, water and soil pollution, biodiversity loss, and more. If we continue to overconsume from outside our borders and not measure or monitor this properly via consumption-based indicators in this framework, we will not succeed in achieving the SDGs. Our overconsumption, as well as unsustainable consumption, is hindering many attemps to solve poverty, hunger, restauration of the environment and cleaning the oceans from the plastic soup. For human rights and justice reasons we should integrate more and better the “externalities” of our current economic system (circular or not). 2. A strong focus on committing to move towards consumption-based indicators – the global outlook: Based on our analysis above, Friends of the Earth Europe believes it is of vital importance that the framework commits to, and puts resources towards, further developing consumption-based indicators and measuring the externalities of our domestic policies. The global outlook of our resource use has been severely missing in the EU Circular Economy debate (especially in the choice of legislative processes followed up on). There was good progress to further develop a set of consumption-based indicators (the “dashboard” indicators) and indeed FoEE for many years have been advocating for the EU to officially measure and monitor its land, water, material and carbon footprints. We have carried out several studies in this area (see website www.foeeurope.org ). FoEE support the further development of a robust Raw Material Consumption indicator, and with a view to adopting the Total Material Consumption indicator in the future (concrete timeline to be outlined). The International Resources Panel openly support the transition from DMC to TMC. 3. Addressing incompatibilities in the scope of the framework and ensuring progress is continued beyond existing indicators: The key criteria in choosing the final indicators are incompatible with the stated aims of the Roadmap. We acknowledge that existing data and resources (time, expertise etc.) are limited, and that in order to publish a set of indicators in the coming months, the ideal choice of indicators is also limited. However, given the significant gaps which exist in official measurement of the EU’s true use of resources (especially consumption-based indicators), we believe the framework must include something to address this so that progress is continued in developing more ambitious indicators. We suggest that the framework includes several indicators “to-be-further-developed” and outlines how they will ensure this. As data improves, these indicators should be merged into the existing set and/or replace less ambitious ones (e.g. land footprint/embodied land to replace artificial land or built-up area). also see: http://www.foeeurope.org/land
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Meeting with Jyrki Katainen (Vice-President) and WWF European Policy Programme and

3 Apr 2017 · Sustainability finance in the mid-term review of the Capital Markets Union

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Pedro Velasco Martins (Cabinet of Vice-President Cecilia Malmström) and Campact

15 Mar 2017 · Multilateral investment court

Meeting with Antoine Colombani (Cabinet of First Vice-President Frans Timmermans), Michelle Sutton (Cabinet of First Vice-President Frans Timmermans) and

1 Mar 2017 · Transparency Register

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and Transport and Environment (European Federation for Transport and Environment) and

1 Feb 2017 · A Union of Democratic Change; Energy Union; Jobs, Growth and Investment; A stronger Global Actor

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

27 Jan 2017 · Energy Efficiency/Performance of buildings

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

27 Jan 2017 · Efficiency negotiations

Response to Draft Commission Directive updating the environmental risk assessment of GMOs

8 Dec 2016

Friends of Earth Europe’s comments on gaps and key requirements for improvements of the ERA of GMO under directive 2001/18: The EC proposal aims to frame a scientifically sound legal base for the ERA of all of GMO for the upcoming years. Politically incomplete: Already in 2008 all environment ministers demanded to strengthen the ERA on specific geographical areas, long-term effects as well the coherence between risk assessments of pesticides and GM crops. This is only partly integrated in the proposal. Scope of the ERA not up to date: The EFSA ERA guidance is already from 2010. Scientific findings and more recent EFSA guidance documents are not integrated in the draft. The draft should also include ERA for other organisms than plants such as GM animals (insects, fishes and others as well as for perennial plants and trees, single celled organisms). This should be explicitly added in a separate recital. The draft that cumulative effects at all steps in an ERA have to be assessed in much more detail (add to recital 5). The draft lacks specific protection goal definitions for pesticide producing GM crops and their interaction with receiving environments. The proposal fails to implement the request of the 2008 Environmental Council conclusions on improved interplay between ERA for pesticides and GMO. ( Recital 8) and Annex II) The current risk assessment of herbicide tolerant GM crops has major gaps. Increased use of pesticides as a result of GMO releases is currently neither assessed under 1107/2009 nor under GMO laws. Data from major GM growing countries underline that HR crops results in strong increase of pesticide use. This should be included in the assessment of changes in agriculture practices and needs to assess the often higher residues of pesticides in HR crops than in non-resistant crops, that herbicides can be applied at different times impacting non-target organisms and biodiversity differently, and metabolites may be different in GM crops. The draft GMO ERA also lacks assessment of cumulative effects due to resistance to different pesticides. Therefore what is needed is to define the interplay between those regulations to make sure that no relevant risks can escape EU regulations. The proposal fails to incorporate high scientific standards for data used in the ERA The review of the GMO ERA should strengthen scientific literature in the ERA but it limits the role of peer reviewed research to a voluntary reflection option by applicants and authorities. Data delivered by applicants as well as the ERA by the authority shall give scientific literature the same weight as industry OECD data. This would bring the ERA of GMO to the same level as for defined in 1107/2009 and would implement the requirements of 2001/18 itself. The proposals undermines a sound risk assessment of stacked events Data from stacked events do have to fulfill at least same requirements as those of the parental single events. Annex II C.2. Steps in ERA 1. Problem formulation should be add clear criteria that an GMO cannot be assessed as safe: - Define cut off criteria such as lack of control of the genetically engineered organisms and its newly introduced genetic information in spatio-temporal dimension. - knowledge gaps and uncertainties that do not allow to draw final conclusions.
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Meeting with Miguel Arias Cañete (Commissioner) and WWF European Policy Programme and

18 Nov 2016 · COP22

Meeting with Miguel Arias Cañete (Commissioner) and WWF European Policy Programme and

17 Nov 2016 · COP 22

Meeting with Miguel Arias Cañete (Commissioner) and WWF European Policy Programme and

15 Nov 2016 · COP 22

Meeting with Miguel Arias Cañete (Commissioner) and WWF European Policy Programme and

14 Nov 2016 · COP 22

Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan) and Greenpeace European Unit

9 Nov 2016 · presentation of their new study on the potential of energy citizens in the EU

Meeting with Dominique Ristori (Director-General Energy) and Greenpeace European Unit and European Renewable Energies Federation asbl

8 Nov 2016 · Energy Union, renewable energy, energy efficiency

Meeting with Valdis Dombrovskis (Vice-President) and

27 Oct 2016 · Sustainable Finance; CMU

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

27 Oct 2016 · Energy Package

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

28 Sept 2016 · Climate Change, Methan Emissions Gas

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

27 Sept 2016 · Role of gas

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu) and Climate Action Network Europe and

12 Apr 2016 · Upcoming legislative proposals related to energy efficiency and renewable energy.

Meeting with Miguel Arias Cañete (Commissioner) and Transport and Environment (European Federation for Transport and Environment) and

11 Mar 2016 · Implications of the Paris Agreement in the EU climate and energy policies

Meeting with Kilian Gross (Digital Economy)

28 Jan 2016 · energy efficiency

Meeting with Kilian Gross (Digital Economy)

28 Jan 2016 · energy efficiency, gas package

Meeting with Miguel Arias Cañete (Commissioner) and Transport and Environment (European Federation for Transport and Environment) and

21 Jan 2016 · COP21 and oncoming legislative package

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

21 Jan 2016 · Discuss energy efficiency in the context of the revision of the 2030 target and the forthcoming gas package

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete) and Stichting European Climate Foundation

19 Jan 2016 · 2030 efficiency targeet

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu)

11 Jan 2016 · Revision of the 2030 energy efficiency target (together with European Climate Foundation)

Meeting with Dominique Ristori (Director-General Energy)

3 Dec 2015 · Energy efficiency

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

26 Oct 2015 · governance of the Energy Union

Meeting with Gonzalo De Mendoza Asensi (Cabinet of Vice-President Miguel Arias Cañete) and Food & Water Action Europe

23 Oct 2015 · Shale gas & fracking

Meeting with Daniel Calleja Crespo (Director-General Environment)

5 Oct 2015 · Fitness check of Nature Directives & Biodiverisy Objectives

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and Food & Water Action Europe

1 Oct 2015 · Shale Gas

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

7 Sept 2015 · Community Energy

Meeting with Miguel Arias Cañete (Commissioner) and

4 Sept 2015 · International Climate negotiations and Commission Working Programme

Meeting with Miguel Arias Cañete (Commissioner) and

23 Jun 2015 · ETS review, Energy Union implementation and International Climate negotiations

Meeting with Miguel Arias Cañete (Commissioner) and

30 Apr 2015 · International climate talks and EU climate diplomacy. State of play of legislative files

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu)

29 Apr 2015 · EU ENERGY AND CLIMATE POLICY

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

10 Mar 2015 · Circular Economy

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

10 Mar 2015 · Circular Economy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and European Environmental Bureau and Zero Waste Europe

10 Mar 2015 · Circular Economy

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

10 Mar 2015 · Circular Economy

Meeting with Frans Timmermans (First Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

13 Feb 2015 · Meeting with Representatives of Green 10 on CWP 2015

Meeting with Vytenis Andriukaitis (Commissioner) and

30 Jan 2015 · The Food Chain, Innovation and Challenges, Food Information to Consumers, Nutrition, and Food Waste, Animal Health, Animal Welfare and Plant Health

Meeting with Miguel Arias Cañete (Commissioner) and

15 Jan 2015 · Follow-up to Lima and climate action diplomacy up to Paris / Energy Union (state of play)

Meeting with Pierre Schellekens (Cabinet of Vice-President Miguel Arias Cañete)

11 Dec 2014 · Climate Action

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and Climate Action Network Europe and OXFAM INTERNATIONAL EU ADVOCACY OFFICE

3 Dec 2014 · Meeting with Wendel Trio, Molly Walsh and Jean-Cyril Dagorn on energy and climate policy

Meeting with Soren Schonberg (Cabinet of Commissioner Margrethe Vestager) and Climate Action Network Europe and OXFAM INTERNATIONAL EU ADVOCACY OFFICE

2 Dec 2014 · EU climate and energy policy