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SUEZ Group

SUEZ

SUEZ is a global water and waste management company providing drinking water, sanitation, and waste-to-energy services while supporting the ecological transition.

Lobbying Activity

SUEZ Group demands more flexible and inclusive EU Taxonomy

5 Dec 2025
Topic — The European Commission is reviewing rules for the EU environmental taxonomy.
Message — SUEZ wants the EU to include waste-to-energy and sewage sludge recycling in its sustainable investment rules. They also propose a scoring system that rewards gradual environmental progress rather than binary compliance.12
Why — Broadening the criteria would allow SUEZ to classify more activities as sustainable.3
Impact — Environmental groups may fear that including incineration undermines waste reduction targets.4
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Meeting with Stéphane Séjourné (Executive Vice-President) and ELECTRICITE DE FRANCE and

17 Nov 2025 · Compétitivité et politique industrielle

Response to Circular Economy Act

6 Nov 2025

As a major player in the circular economy for more than 160 years, SUEZ recognizes that the EU is at a critical turning point. The EU must either maintain its leadership in the environmental transition or risk losing ground to non-EU countries, both in manufacturing and in material sourcing. The competitiveness of the EU industry as a whole is essential. There is no recycling industry separate from the manufacturing industry; we are all part of a single value chain, competing globally with players from the US and Asia who do not always adhere to the same rules. SUEZ sincerely thanks the European Commission, and in particular DG Environment, for its initiatives through the Circular Economy Act (CEA), a much-needed regulatory framework for the EU. SUEZ also welcomes the announced winter-package by the end of 2025 and the acceleration of the 2026 timeline regarding the publication of the CEA (Q3 2026), which underlines the urgency of the situation. The main challenge for the recycling industry is not material availability but unfair competition and weak demand. Immediate action is required to help EU recyclers that face unfair competition: US trade barriers and low-cost Asian imports, combined with regulatory loopholes, undermine the European recycling industry. SUEZ believes that clear and urgent measures are essential, and the success of the CEA will depend on a few key levers. First, waste management must be recognized as a strategic industrial sector. This requires strengthening controls and taxation on imports of virgin materials to secure circular value chains, ensure a level playing field, and protect the competitiveness of EU recyclers in global trade. Secondly, the CEA should strongly boost demand for local (EU) recycled materials through binding incorporation targets. A European preference requirement on the incorporation of recycled materials will stimulate the demand and production of recycled products made in the EUand therefore decrease the dependency on virgin materials, hereby reducing the consumption of natural resources and GHG emissions and improving the EU trade balance. SUEZ also calls on the European Commission to broaden the scope of mandatory recycled plastic content obligations to include additional sectors, notably construction and transport, and to apply those targets to other materials (paper, cardboard, metals, critical raw materials). Demand for recycled materials should also be strengthened through economic incentives and harmonised rules to build a truly integrated internal market for secondary materials. Indeed, the harmonization of End-of-Waste criteria (plastics, paper, critical materials) and EPR rules is essential to facilitate waste transfers and develop a true single market for recycling in Europe. This convergence on EPR schemes must, however, preserve national implementation adapted to operational realities, while ensuring enhanced vigilance regarding environmental and health risks. SUEZ stands ready to cooperate with EU institutions and stakeholders, contributing its expertise and operational experience in circular economy, waste, water, and energy management. For more detailed information, please refer to the attached position paper and the accompanying table (pp. 1124), which summarize SUEZs arguments and responses to all questions and sub-questions.
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Meeting with Aurel Ciobanu-Dordea (Director Environment) and

16 Oct 2025 · Circular Economy

Meeting with Pascal Canfin (Member of the European Parliament)

14 Oct 2025 · Recycling industry

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné)

14 Oct 2025 · Competitiveness in the recycling sector and challenges around plastics, batteries and steel

Meeting with Veronica Manfredi (Director Environment)

30 Sept 2025 · Suez stated their support for the Water Resilience Strategy with their areas of interest including water efficiency, water reuse, water investments, PFAS remediation, digitalisation, and resilience planning.

SUEZ calls for pragmatic biochar rules and BECCS clarity

22 Sept 2025
Topic — EU certification methodologies for permanent carbon removal via DACCS, BioCCS and biochar.
Message — SUEZ requests that biochar's economic value be recognized beyond carbon credits, that permanence be measured at production rather than requiring one-year soil monitoring, and that only waste or residual biomass be eligible. They seek clearer rules on mixed biogenic CO2 streams in BECCS and correction of regulatory references.1234
Why — This would enable SUEZ to commercialize biochar for climate adaptation and monetize its multiple soil benefits.56
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SUEZ Group calls for CBAM extension to plastics and paper

26 Aug 2025
Topic — Expanding the Carbon Border Adjustment Mechanism to downstream products and tackling circumvention.
Message — SUEZ recommends extending the CBAM scope to downstream products and energy-intensive sectors like virgin plastic and paper. They also advocate for distinct customs codes to differentiate recycled materials from high-carbon virgin imports.12
Why — Including these sectors would protect the European recycling industry from cheaper, high-emission foreign imports.3
Impact — Non-EU manufacturers using virgin materials lose their price advantage over European recycled products.4
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SUEZ Group Urges EU Support for European Electric Fleet Transition

6 Aug 2025
Topic — This consultation focuses on increasing the uptake of zero-emission vehicles within corporate fleets.
Message — SUEZ requests dedicated financial support for fleet electrification and charging infrastructure. They advocate for policies favoring European-made vehicles and seek clearer rules for installing charging points on public sites.123
Why — Financial aid and revised accounting treatments would protect SUEZ's investment capacity and financial ratios.45
Impact — Asian vehicle manufacturers would face a competitive disadvantage under the proposed preference for European vehicles.6
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Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall) and TotalEnergies SE and

22 Jul 2025 · EU environmental policies

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and TotalEnergies SE and

10 Jul 2025 · Clean industrial deal Financement Simplification

SUEZ Group opposes including waste-to-energy in EU emissions trading

4 Jul 2025
Topic — The European Commission is evaluating whether to include municipal waste incineration in the EU ETS.
Message — SUEZ recommends an opt-out mechanism for waste-to-energy plants in countries with equivalent national taxation. They suggest taxing producers of non-recyclable plastics directly to ensure more effective decarbonization.12
Why — A national taxation system would provide the group with better financial visibility and stability.3
Impact — Municipalities and households would face higher costs and significant financial uncertainty under ETS rules.4
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Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and CMA CGM

25 Jun 2025 · Decarbonisation of fuels for maritime industry

Meeting with Annika Kroon (Head of Unit Mobility and Transport) and CMA CGM

25 Jun 2025 · Production and certification of biomethane

SUEZ Group urges EU to unlock biowaste and biomethane potential

20 Jun 2025
Topic — Initiative aiming to foster a circular and climate-neutral European bioeconomy strategy.
Message — The group wants legally binding biomethane targets and better biowaste collection. They also request updated regulations to support recycling nutrients from sewage sludge.12
Why — Supportive policies and subsidies would boost demand for SUEZ's waste recovery technologies.34
Impact — Global fossil fuel and mineral fertilizer exporters face reduced European market demand.56
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Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné) and

12 Jun 2025 · Challenges and opportunities in Europe’s Water Sector

Meeting with Hoa-Binh Adjemian (Head of Unit Enlargement and Eastern Neighbourhood)

6 Jun 2025 · Prep meeting for Implementation Dialogue with the Commissioner

Meeting with Anne-Maud Orlinski (Cabinet of Commissioner Dan Jørgensen) and Veolia Environnement and

28 May 2025 · Water Resilience Strategy Water Energy Efficiency Solutions

Meeting with Ruth Reichstein (Cabinet of President Ursula von der Leyen) and Veolia Environnement and

27 May 2025 · to follow

Meeting with Ruth Reichstein (Cabinet of President Ursula von der Leyen) and Veolia Environnement and

27 May 2025 · The EU Water Resilience Strategy

Meeting with Hoa-Binh Adjemian (Head of Unit Enlargement and Eastern Neighbourhood)

24 Apr 2025 · Introductory meeting between SUEZ Group and DG ENEST, in the framework of the initiative ‘Accelerating Investment in Montenegro’ (AIM)

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

1 Apr 2025 · In the context of the EU-LAC Global Gateway Investment Agenda, the European Commission’s Directorate-General for International Partnerships (DG INTPA) launches an initiative with a view to develop circular economy value chains in Latin America

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

1 Apr 2025 · Plenary Feedback round on previously held GGIA Working Group sessions of 9 different thematical groups regarding Latin America and the Caribbean (LAC).

Meeting with Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall) and Veolia Environnement and

27 Mar 2025 · Meeting with Digital Water Coalition on Water Resilience Strategy

Response to 2025 Strategic Foresight Report

19 Mar 2025

Water resilience is one of todays biggest challenges. Climate change, causing water stress, associated with increasing industrial demand for water, are forcing us to rethink how we treat water, both from a quantity and quality point of view. To meet these current and future challenges, it is crucial to deliver on a strong and ambitious European Water Resilience Strategy. This urgency affects everyone, at all levels and across all sectors. It is therefore essential that the cross-cutting nature of water is considered through strengthened governance and the development of stronger synergies between EU policies. As governance at the basin level can present challenges for regions and Member States, it is crucial to reinforce transboundary cooperation at the operational, tactical, and strategic levels, with mutual and harmonised processes and obligations. The European Commission must as well ensure that obligations related to water availability and quality are fully enforced in the EU, by better controlling the implementation of existing water policies. Furthermore, the EU must prioritise circular solutions, such as the reuse of treated wastewater, encourage aquifer recharge to maintain groundwater levels, combat leaks in water networks, and encourage the digitalization of water management processes. Finally, the EU should push Member States to rethink the price value of water to promote a more rationale use of the resource. The selling price of water is currently too low to enable water management operators to effectively fulfil their mission: ensuring a sufficient supply of quality water both today and in the future. The undervaluation of water hinders the investment opportunities needed for the deployment of necessary infrastructures and the development of innovative water-smart solutions.
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SUEZ calls for dedicated European Water Fund and governance

4 Mar 2025
Topic — A holistic EU plan to manage water scarcity and achieve water resilience.
Message — SUEZ recommends establishing a dedicated European Water Fund and strengthening governance via an inter-service group. They urge the Commission to prioritize wastewater reuse and enforce polluter-pays principles for PFAS. They advocate for an economic model where water pricing reflects its social value.123
Why — New funding and pricing models would subsidize SUEZ's infrastructure projects and digital services.45
Impact — Industrial polluters and consumers face higher costs through polluter-pays fees and price hikes.67
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Meeting with Gaelle Marion (Head of Unit Agriculture and Rural Development) and Veolia Environnement and

19 Feb 2025 · Water Resilience Strategy and Agriculture

Meeting with Pascal Canfin (Member of the European Parliament)

3 Feb 2025 · End-of-waste criteria

Meeting with Florika Fink-Hooijer (Director-General Environment)

28 Jan 2025 · Circular economy and water

Meeting with Alejandro Ulzurrun De Asanza Y Munoz (Acting Director Energy)

28 Jan 2025 · Circular Economy Act, Water Resilience Strategy

Meeting with Axel Hellman (Cabinet of Commissioner Jessika Roswall), Paulina Dejmek Hack (Cabinet of Commissioner Jessika Roswall)

28 Jan 2025 · Exchange of views on EU water policy and circularity.

Meeting with Stéphane Séjourné (Executive Vice-President) and

28 Jan 2025 · Meeting with Vice-présidents exécutifs et PDG par intérim - Clean Industrial Deal - Simplification - Accès aux matières premières et circularité - Valorisation des déchets et eau

Meeting with Alexandr Vondra (Member of the European Parliament)

28 Jan 2025 · Working lunch - Water Resilience Strategy

Meeting with Wopke Hoekstra (Commissioner) and

28 Jan 2025 · Discussion on the potential and challenges of achieving a full circular economy in Europe

Meeting with Tiemo Wölken (Member of the European Parliament) and Danfoss A/S and Xylem Inc.

21 Jan 2025 · Digitisation of the water sector (staff level)

Meeting with Stefano Soro (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

9 Jan 2025 · Exchange of views on the upcoming Circular Economy Act and the necessary support measures for European recyclers.

Meeting with Laurent Castillo (Member of the European Parliament)

26 Nov 2024 · Energie

Meeting with Pietro Fiocchi (Member of the European Parliament)

21 Nov 2024 · Economia circolare

Meeting with András Tivadar Kulja (Member of the European Parliament)

19 Nov 2024 · Water cycle management and recycling

Meeting with Hildegard Bentele (Member of the European Parliament)

18 Nov 2024 · Water and Energy Policy

Meeting with Dario Nardella (Member of the European Parliament)

4 Nov 2024 · Priorities in the field of industries, research and innovation

Meeting with Sander Smit (Member of the European Parliament) and Novartis International AG

18 Oct 2024 · ENVI

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

9 Oct 2024 · Meeting with Suez Group

Meeting with Nora Mebarek (Member of the European Parliament) and Réseau Action Climat France

1 Oct 2024 · Prise de contact

Meeting with Barry Andrews (Member of the European Parliament)

30 Sept 2024 · Waste Water and Circular Economy

Meeting with Grégory Allione (Member of the European Parliament)

23 Sept 2024 · Réunion Suez

Response to Environmental Implementation Review 2025

4 Jul 2024

SUEZ welcomes the upcoming Environmental Implementation Review of the European Commission. Additionally of reviewing the implementation of EU environmental laws, SUEZ would like to express our perception where further or additional legislations are needed: - Continuing the work on plastics and pursue efforts on making plastic recycling more attractive. - Encouraging wastewater reuse after a treatment process and SUEZ is calling to publish a proposal on water resilience. - Encouraging nutrient recycling from sludge in order to enable its use for organic fertilizers. - Publishing the legislative proposal on industrial carbon management. - Ensuring regulatory visibility for the emergence of the new carbon capture industry. You can find more about SUEZ's position attached to this consultation.
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SUEZ Group urges spreading flexibility and stricter nitrate rule enforcement

8 Mar 2024
Topic — Evaluation of EU rules preventing water pollution caused by agricultural nitrates.
Message — SUEZ requests more flexibility for spreading seasons to adapt to climate change. They argue current regulations should be fully applied before adding new requirements. Financing should support techniques like dose modulation and soil incorporation.123
Why — Flexible spreading seasons allow the group to manage sludge disposal more efficiently.4
Impact — Farmers currently avoiding strict nitrate limits would face tougher enforcement and oversight.5
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Response to Measures to reduce microplastic pollution

15 Jan 2024

SUEZ welcomes the European Commissions regulation proposal on preventing plastic pellet losses and supports the initiative to reduce the release of microplastic substances in the environment which has considerable impacts on human health, biodiversity and the economy. Our key messages for improving the European Commissions proposal are the following: Clarification on the size of plastic pellets (diameter around 5 mm) and a definition of economic operators. Inclusion of flakes and grinded plastics in the definition of plastic pellets. Harmonization with already existing national certification criteria for example with the French law-decree n° 2021-461 of the 16 April 2021. Clarity on which competent authorities oversee reporting obligations. Additional flexibility to allow scientific updates on methodology criteria and standards to evolve. A more defined set of scope for penalties in case of non-implementation. You can find more about SUEZ's position attached to this consultation.
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SUEZ backs ambitious circularity targets for vehicle recycling

4 Dec 2023
Topic — The European Commission is revising rules for vehicle design and end-of-life management.
Message — SUEZ supports ambitious circularity targets but insists that the recycling closed loop must not give priority access to producers. They request that producer responsibility schemes remain financial rather than operational to avoid disrupting waste management. Additionally, waste operators should retain ownership of all spare parts and components.123
Why — This approach secures SUEZ's role in the recycling market and its control over valuable materials.4
Impact — Vehicle manufacturers would lose direct control over recycled material supplies and waste management logistics.5
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

21 Nov 2023

SUEZ welcomes the European Commissions proposal on the revision of the Waste Framework Directive regarding food waste. In this position paper SUEZ wants to highlight some remarks on the proposed legislation in relation to the proposals regarding food waste. - Clarification of the definition of food waste - Coherent targets for food waste prevention with the already existing ones in Member States - Adding a definition of the term food production For further information, please see our position paper attached to this consultation.
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SUEZ urges binding targets for EU soil monitoring law

26 Oct 2023
Topic — A proposal defining healthy soil conditions and rules for sustainable use and restoration.
Message — SUEZ requests binding intermediary targets to ensure all EU soils are healthy by 2050. They advocate for the inclusion of recovered carbon sources in soil management. They also suggest stronger links between soil monitoring and water resilience.123
Why — This would promote SUEZ’s bio-waste products as sustainable alternatives to chemical fertilizers.4
Impact — Chemical fertilizer manufacturers may lose market share as natural alternatives are prioritized.5
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Response to European Critical Raw Materials Act

30 Jun 2023

SUEZ welcomes the European Commissions proposal on the Critical Raw Material Act. Indeed, elements in this proposition would contribute to the strategic independency of the European Union while maintaining with regards to the circular economy, a particular reduced environmental footprint through increased recycling. Our key messages for improving the European Commissions proposal are the following involves clearly defining strategic technologies, limiting the possibility of removing critical materials from the critical raw material list, introducing recycled content obligations for magnets, ensuring permitting granting does not exceed 12 months and ensuring adequate representation and circular economy focus within the proposed Critical Raw Materials Board. Our position paper is attached to our feedback.
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SUEZ urges broader recycled plastic rules for beverage bottles

30 May 2023
Topic — The European Commission is defining rules for reporting recycled content in plastic bottles.
Message — SUEZ requests including PET depolymerization and expanding the recycled plastic definition to include pre-consumer waste. They recommend integrating a precise chain of custody for depolymerization.12
Why — Providing a clear timeline and including new technologies ensures predictability for industry investors.34
Impact — Innovative recycling firms lose out if the legislation focuses exclusively on mechanical processes.56
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SUEZ pushes for waste-to-energy inclusion in electricity market reform

22 May 2023
Topic — The consultation addresses reforming EU electricity markets to stabilize prices and boost renewables.
Message — SUEZ requests that energy from waste be eligible for two-way contracts. They also want large companies included in energy sharing systems.12
Why — Inclusion would provide the group with financial predictability and security for its green investments.3
Impact — Public water customers face higher costs if large firms are excluded from revenue sharing.4
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SUEZ Urges Taxonomy Alignment with EU Water Directives

3 May 2023
Topic — This consultation defines sustainable economic activities for water, circular economy, pollution, and biodiversity objectives.
Message — SUEZ calls for the taxonomy to align with the Urban Wastewater Treatment Directive and recognize digital smart metering solutions. They also request that phosphorus recovery through sludge spreading and waste-derived fuel production be considered sustainable.123
Why — Inclusion would allow SUEZ to classify its core waste-to-energy and digital services as sustainable investments.45
Impact — Environmental groups may oppose lowering emission standards for desalination or promoting the spreading of sewage sludge.67
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Meeting with Kadri Simson (Commissioner) and

3 May 2023 · Biomethane production from wastewater.

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

3 May 2023 · EU circular economy and water policies

SUEZ Urges Recycled Content Targets for All Packaging Materials

24 Apr 2023
Topic — The European Commission is reviewing rules to reduce packaging waste and increase recycling.
Message — SUEZ calls for mandatory recycled content targets for all materials, including paper and glass. They argue deposit return systems should be flexible and that compostable packaging use should be strictly limited.123
Why — Mandating recycled content across all materials would boost demand for SUEZ's industrial recycling services.4
Impact — Producers of compostable packaging face restricted market access if their products are strictly limited.5
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Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson), Stefano Grassi (Cabinet of Commissioner Kadri Simson)

21 Apr 2023 · Energy from waste and water management - biomethane production from wastewater

SUEZ Group calls for recognition of hybrid carbon removal methods

23 Mar 2023
Topic — The European Commission is proposing a voluntary regulatory framework for certifying high-quality carbon removals.
Message — SUEZ recommends that the framework better promote Bioenergy Carbon Capture and Storage, biochar, and compost. They suggest creating a new 'hybrid-based solution' category for methods combining nature and technology. The group also urges aligning certification baselines with existing voluntary market standards.123
Why — This would allow SUEZ to monetize its waste management activities through carbon certificates.4
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SUEZ Group urges inclusion of air treatment in EU law

14 Mar 2023
Topic — The European Commission is revising air quality standards to align with WHO recommendations.
Message — SUEZ proposes integrating air treatment technologies and greenhouse gas capture into the directive. They also advocate for guidelines on innovative screening and public-private partnerships.12
Why — These policy changes would create new commercial opportunities for SUEZ’s proprietary environmental technologies.34
Impact — Industrial firms would face increased compliance costs from new greenhouse gas capture requirements.5
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SUEZ calls for EU Water Fund to boost wastewater treatment

14 Mar 2023
Topic — Revision of the Urban Wastewater Treatment Directive to protect human health and environment.
Message — SUEZ supports the Commission's ambitious wastewater proposal and the introduction of producer responsibility for pollutants. They call for a dedicated EU Water Fund to finance transitions to more advanced treatment and recovery. They also suggest setting more realistic, binding targets for reducing stormwater discharges.123
Why — New funding and producer responsibility schemes would help SUEZ deploy its advanced water treatment solutions.4
Impact — Pharmaceutical and cosmetic manufacturers must pay to clean up pollutants they currently discharge for free.5
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SUEZ Group warns against rigid standards for aquifer recharge

14 Mar 2023
Topic — The EU is revising rules to control chemical pollutants in surface and groundwaters.
Message — SUEZ recommends that new pollution standards do not block the essential practice of recharging aquifers. They suggest using drinking water limits because proposed targets are currently impossible to measure.12
Why — The company avoids unachievable measurement requirements and maintains its existing water recharge operations.34
Impact — Environmental protections are weakened by allowing higher pollutant levels during artificial groundwater replenishment.567
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Meeting with Margrete Auken (Member of the European Parliament, Shadow rapporteur) and ECOLAB and

7 Feb 2023 · Recast of the UWWTD

Meeting with Daphne Von Buxhoeveden (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

20 Sept 2022 · VTC meeting: Waste water surveillance

Meeting with Pierre Delsaux (Director-General Health Emergency Preparedness and Response Authority)

18 Jul 2022 · Mr Hugues d’Antin, Institutional Relations at Suez Group To discuss use of wastewater analysis in the preparedness and crisis management

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and Veolia Environnement and

5 Jul 2022 · Urban wastewater treatment (Zero Pollution)

Meeting with Arunas Ribokas (Cabinet of Commissioner Virginijus Sinkevičius) and Veolia Environnement and

5 Jul 2022 · To discuss the review of the Urban Waste Water Treatment Directive

SUEZ Group urges non-binding industrial emission performance standards

21 Jun 2022
Topic — The EU is revising industrial emissions rules to support zero pollution goals.
Message — SUEZ advocates for emission performance levels to remain non-binding rather than mandatory. They also seek clarification on performance parameters and oppose public disclosure of management systems.12
Why — The company avoids mandatory compliance levels and protects sensitive internal management data.34
Impact — Transparency advocates lose access to detailed data on industrial environmental management.5
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SUEZ urges clearer greenhouse gas rules for recycled fuels

17 Jun 2022
Topic — The Commission is establishing a methodology for greenhouse gas savings from recycled carbon fuels.
Message — SUEZ recommends that incineration for electricity should be the default reference for non-recyclable waste. They also propose extending the 'existing use' concept to advanced biofuels for mixed feedstocks.12
Why — This methodology allows their waste-to-fuel projects to meet the mandatory 70% emission reduction target.3
Impact — Long-term waste-to-fuel projects lose viability due to the planned 2035 limit on non-sustainable carbon.4
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Response to Amendment to the Regulation (EU) No 1025/2012 European standardisation

7 Apr 2022

SUEZ is a major player in environmental services. For almost 160 years, SUEZ has supported local communities and industrial companies in the management of essential services such as water, waste, and air quality. As such, SUEZ produces drinking water for 66 million people worldwide, recovers 2 million tons of secondary raw materials per year, and generates 3.1 TWh of renewable energy from waste. SUEZ supports the proposed revision of European Regulation 1025/2012. On the national level, the European Commission appears to confirm the value of the principle of national delegation through its revision proposal. With regards to ETSI, this revision could give more weight to national representation, through national standardization bodies. On a European level, this revision will strengthen the coordination and coherence of the actions and programs of the three European standardization organizations CEN, CENELEC and ETSI. Finally on the international level, the proposed amendment should strengthen the weight of European companies in the decision-making processes that define European standards.
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Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

16 Mar 2022

SUEZ is a major player in environmental services. For almost 160 years, SUEZ has supported local communities and industrial companies in the management of essential services such as water, waste, and air quality. As such, SUEZ produces drinking water for 66 million people worldwide, recovers 2 million tons of secondary raw materials per year, and generates 3.1 TWh of renewable energy from waste. In our ongoing management of the ecological transition and climate change challenges, SUEZ will rely on the expertise and commitment of its 35,000 employees (particularly in France, Italy, Central Europe, Africa, Asia, and Australia) to offer high value-added and customized environmental solutions to all its customers. A decrease in the organic matter content of soils has been observed in recent years leading to an increased vulnerability in erosion and a decrease in soil fertility. Therefore, regular supplies of organic matter, such as organic amendments, contribute to maintain the levels of organic matter of the soils in order to preserve their functions and their fertility. Moreover, the contribution of stabilized materials rich in stable organic matter contributes to the storage of carbon and mineral elements via the increase of the Cation Exchange Capacity of agricultural soils. The contribution of organic fertilizers must be encouraged and facilitated in a perspective of preservation and improvement of soil fertility. Concerning the materials returned to the soil and especially the materials resulting from recycling such as sludge, these also contribute to the maintenance of the stock of organic matter in the soil and provide usable fertilizing elements. The quality of these materials is constantly improving, however it seems important to prevent pollution at the source in order to ensure the quality of the spread products.
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Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

SUEZ conducted a study internally in 2018 on the compostability of bio-sourced plastics. It became evident to us, given the rapid interest from industries on bio-sourced and compostable plastics, that it was important to communicate our findings regarding the impact on the following waste treatment processes: composting (aerobic digestion), anaerobic digestion and recycling. • Standard 14995: 2006 specifies the requirements and methods for determining the compostability or ability for anaerobic digestion of plastics, excluding packaging applications. • EN 13432: 2002 specifies the requirements and methods for determining the feasibility of composting and anaerobically treating plastic packaging and compostable plastic packaging material. • Compostable plastics, used in particular for the collection of bio-waste, mainly meet EN 13432 but can simultaneously meet EN 14995. o The verification of the absence of toxicological or endocrine disrupting effect (FD U44-167 or NF EN ISO 11269-2, ISO 19040-1-2-3, draft decree common to Fertilizing Materials and Crop Supports) could be added to EN 13432 if it is considered that the components of biobased plastics or biodegradable plastics may exhibit this kind of effect that would lead to non-compliant composts / digestates. The major problem with these standards is that they are not in line (duration and temperature) with the operating conditions of organic recovery sites (anaerobic digestion and composting). For example, EN 13432 recommends disintegration at 60 ° C for 3 months and biodegradation at 60 ° C for 6 months, while the industrial composting process meets a regulatory duration of 2-3 weeks of fermentation with at least 55 ° C for 3 days, followed by a maturation of 2-3 months. Regarding heavy metal contents, the requirements of these standards are much more restrictive than NF U44-051. In the end, the rate of disintegration and biodegradation of so-called compostable plastic materials is not favored by conventional operating conditions. Industrial plants based on mesophilic anaerobic digestion process are the most exposed. Industrial composting seems to be more favorable to the disintegration of starch-based composite materials, provided that the other constituents of the industrial recipe comply with the appropriate thresholds. However, this disintegration will always generate microplastics, the dosage of which remains problematic. SUEZ is not in favor of developing the use of plastic bags for biowaste collection as it is NOT demonstrated that this material will be effectively biodegraded through composting or anaerobic digestions processes. In addition, we have concerns over the additives and other elements that are released into the soil. Thus, paper bags are preferred material for biowaste collection as their composition is close to what is treated by organics treatment processes. In conclusion, and to date, the end-of-life management of these plastic materials by anaerobic digestion and composting sites remains problematic, generates additional impurities, and causes mechanical malfunctions. These materials must be taken care of by dedicated channels capable of adapting to the specific nature of these materials. Finally, we insist that these materials have no organic value and thus bring no value to the soil.
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Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

8 Oct 2021 · World Materials Forum and EU action on circular economy

Response to Restoring sustainable carbon cycles

7 Oct 2021

SUEZ welcomes the initiative to develop a long-term vision for sustainable carbon cycles (including capture, storage, and use of CO2) in a climate-neutral EU economy and to support in the development of technological and nature-based solutions. We look forward to an upcoming proposal for a regulatory framework for the certification of carbon removals. Our recommendations are detailed in the paper attached to this consultation.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

1 Oct 2021 · Circular economy, waste management and recycled content

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans)

22 Jul 2021 · World Materials Forum

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

7 Jul 2021 · Meeting on Fit for 55

Response to Conversion to a Farm Sustainability Data Network (FSDN)

2 Jul 2021

SUEZ welcomes the opportunity to contribute to the roadmap consultation on the conversion of the Farm Accountancy Data Network. In order to feed an ever-expanding world population and face the decline in the availability of natural resources, it is inevitable to make a sustainable agricultural transition. The stakeholders can and must rely on digital technology to achieve this: in some places, the agricultural sector is already one of the most digitally advanced, and data plays a chief role. Collecting data indeed now makes it possible to measure a wealth of information directly related to sustainability, such as carbon emissions avoided or volumes of water and energy saved. It should be an integral part of the success of the European Green Deal, the CAP or the Farm to Fork Strategy. It is therefore time to further the Farm Accountancy Data Network into a Farm Sustainability Data Network, which should help foster the digital transition of farms and allow to reflect their environmental performance. Digital technologies allow to measure the positive externalities of agriculture practices (carbon sequestration, flood control, promotion of biodiversity…). Virtuous agriculture can help alleviate the environmental emergency and become more attractive to farmers. Data collection and processing within the FSDN could ensure that CAP payments directed towards sustainable agriculture are truly payments for environmental services (PES) and that farmers are remunerated appropriately. The FSDN should encourage the use of those digital tools that lead to new processing, analysis and data collection while reinventing farm management. They include, for instance, tools to make it possible to treat crops and irrigate only when necessary (precision agriculture) and decision support tools and weather forecasting to better control production. The future FSDN could also spark virtuous cycles: providing data to consumers about the quality and environmental friendliness of agricultural products, thereby helping them to make better choices at the time of purchase would subsequently encourage better production. Data also facilitates the connection between stakeholders, which favours short food supply chains. Finally, the FSDN should aim at embarking local authorities by fostering the creation of smart cities in which smart agriculture would play a triggering role and where local digital centres could bring together stakeholders and serve as decision tools for public services based on data related to carbon, water, land, air, or short food supply systems for instance.
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Meeting with Virginijus Sinkevičius (Commissioner) and

30 Apr 2021 · To discuss the European Green Deal in in terms of clean technologies, innovation and sustainable investments, as well as the zero pollution ambition and the role of innovative environmental services.

Meeting with Elina Melngaile (Cabinet of Executive Vice-President Valdis Dombrovskis)

13 Apr 2021 · EU Taxonomy and its impact on energy sector

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

12 Apr 2021 · Taxonomy regulation and delegated acts

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

29 Mar 2021 · Digital economy, smart cities, data management (virtual meeting)

Meeting with Kitti Nyitrai (Cabinet of Commissioner Kadri Simson), Laure Chapuis (Cabinet of Commissioner Kadri Simson) and Brunswick Group Limited srl

26 Mar 2021 · Implementation of the Green Deal; Implementation of the EU recovery plan.

Meeting with Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius) and Brunswick Group Limited srl

22 Mar 2021 · ‘’Implementation of the European Green Deal and circular economy’’

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans), Sarah Nelen (Cabinet of Executive Vice-President Frans Timmermans) and Brunswick Group Limited srl

22 Mar 2021 · Implementation of the European Green Deal and circular economy

Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager) and Brunswick Group Limited srl

22 Mar 2021 · Implementation of the European Green Deal and circular economy

Response to Technical amendments to the annexes to the Fertilising Products Regulation

2 Mar 2021

SUEZ welcomes the opportunity to provide input to the technical provisions of the Fertilisers Regulation. Our comments concern the input for compost and digestates (CMC 3 and 4), being slight but significant modifications that have been added to composts and digestates CMCs (both more and less flexible), as well as containing several new requirements concerning declarations of product composition: • The authorized list of input materials for composts and digestates (CMC 3 and 5) have been modified to include "animal by-products that cannot be considered living or dead organisms", explicitly to make it more flexible to unprocessed animal manure (even accepted in organic agriculture). • The authorized list of input materials for composts and digestates (CMC 3 and 5) have been modified to be more restrictive towards mixed waste. The expression "organic fraction of mixed municipal household waste" was replaced by "materials originating from mixed municipal waste". We fully support these modifications. SUEZ’s proposition concerns a modification of PFC 1(C). As struvite and other recovered phosphate salts (new CMC) are intended to match PFC 1(C), it seems pertinent to include a mention (f) for “crystals” to the possible forms of the physical units. Adding to that, it can be noted that the proposal repeats “a combination of two or more” in both the introduction and the listed forms. Our Proposition: Annex 3, page 6: “(1) point 3 is replaced by the following: 3. The form of the physical unit of the product shall be indicated with one, or a combination of two or more, of the following mentions: (a) granules, (b) pellets, (c) powder, where at least 90 % by mass of the product can pass through a sieve with a mesh of 1 mm, (d) prills, or (e) a combination of two or more of the above-mentioned forms.’; [already mentioned above in the proposal of modified introduction] (f) crystals” We remain at your disposal, should you require further information.
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

Suez accueille favorablement la proposition de règlement sur les batteries et les déchets de batteries. Nous soutenons pleinement l'ambition accrue du recyclage des batteries. Nous avons quelques commentaires et des questions : Classification des déchets des EV batteries : (liste de déchets – décision 2000/532/CE) o Le statut déchet des batteries de véhicules électriques est un élément important pour garantir l’intégrité et la sécurité du recyclage, tout au long de ses étapes (collecte, transport, démantèlement, séparation et purification des matériaux). Le fait que les batteries de véhicules électriques soient considérées comme déchets à défaut de remplir les critères (définis en Annexe VII) leur permettant une seconde vie est donc satisfaisant. o Dans un souci d’harmonisation au niveau européen, la réglementation peut-elle préciser l’évolution du statut des déchets de batteries (dangereux, non dangereux, non déchet) aux différents étapes du recyclage mentionnées ci-dessus ? o Qu’est-il prévu pour encadrer les différentes étapes et préciser le statut des déchets, compte tenu de la nature des matériaux intermédiaires obtenus ? o En particulier, quel sera le statut de la black mass obtenue par broyage des cellules de batteries de véhicules électriques ? Cette black mass fera-t-elle l’objet d’un code spécifique dans la liste des déchets ? Paramètres de santé et durée de vie des batteries collectées (Annexe VII) o Quand et comment seront quantifiés les critères de santé et durée de seconde vie des batteries de véhicules électriques collectées (Annexe VII) destinés à sortir les batteries du statut déchet ? Transfert pour traitement et recyclage hors d’Europe : (Article 58) o Les conditions et critères permettant le transfert hors Europe des batteries des véhicules électriques en fin de vie et/ou des leurs composants sont des éléments clés pour le développement d’une filière européenne pérenne de recyclage des batteries des véhicules électriques. o Les dispositions concernant le transfert hors d’Europe seront-t-elles les même pour les batteries des véhicules électriques et pour les composants de ces batteries, en cas de démantèlement préalable à leur transfert (ex. modules, cellules ou black mass) ? o Quand et comment seront définis les critères d’évaluation des conditions équivalentes (Article 58.3)
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Response to Precipitated phosphate salts and derivates in EU fertilising products

1 Feb 2021

SUEZ Group is pleased to have the opportunity to respond in detail to the delegated act on Fertilising products - precipitated phosphate salts and derivates. Our response has been attached. We welcome any opportunity to further explain our position should the need arise.
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Response to Revision of EU Ambient Air Quality legislation

14 Jan 2021

Suez welcomes the opportunity to provide feedback on the AAQ Directives revision roadmap. Please find our contribution attached.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Suez supports the European Commission’s work on setting a set of technical criteria to help private and public investors to guide their investments towards sustainable projects, assets, technologies and services. Our corporate strategy Shaping SUEZ 2030 follows the same path with an ambition to propose 100% sustainable solutions to our clients by 2030. Recently, the Group has reinforced its commitments to align its own activities with the 1.5°C trajectory of the Paris Agreement, as well as enabling its municipal and industrial clients to scale up their own ambitions in terms of mitigating or adapting to climate change. When setting these technical criteria, we call on the European Commission and its experts to consider the principles of subsidiarity and proportionality, for the sake of clarity and global policy coherence, and to avoid being decorrelated from operational reality. The assessment of the draft delegated acts on climate change mitigation was eye-opening on the following aspects: • At a moment in time when significant investments are needed in water and wastewater infrastructures (OECD study, May 2020, Financing Water Supply, Sanitation and Flood Protection) to ensure full compliance with EU water legislation, but also to grasp the benefits of the Green Deal and support the recovery, we are concerned that the proposed technical criteria could jeopardise these investment needs by making the alignment of water systems very complex. We consider that a real risk of downgrading of the financial attractivity of water and wastewater infrastructures exist, because draft technical criteria proposed are not correlated to an operational reality and would thus have a major impact on alignment. We reassert that the Taxonomy objective “Sustainable use and management of water” remains the most relevant as far as water services are concerned. • EU policymaking is often driven by a fundamental principle: technology neutrality. We understand that when setting technology prescriptive criteria, this principle is difficult to apply. However, the European Commission and its experts needs to ensure a level playing field in this Taxonomy process, e.g chemical recycling, a broad term which encompasses technologies such as gasification or pyrolysis, is considered as a sustainable technology while energy recovery of non-recyclable sorted waste is not. This is one of many inconsistencies. • For the sake of policy coherence, it is absolutely critical that the whole Taxonomy process takes on board the EU environmental policy acquis. Existing sectorial legislation must be carefully considered when setting technical criteria to ensure consistency and avoid double regulation, e.g technical criteria on leakage of water systems not aligned on the criteria defined in the EU Drinking Water Directive. Our assessment of the draft delegated acts on climate change mitigation leads us to recommend to the European Commission and its experts to take a step back to ensure an overall coherence on the 6 objectives of the Taxonomy. This additional time should be dedicated to further consultation of regulated sectors and stakeholders, capitalize on lesson learned from the first 2 objectives while progressing with the Sustainable Finance Platform on the remaining 4 objectives (circular economy, sustainable management of water, pollution, and healthy ecosystems). Taxonomy will be a strategic instrument in driving public and private investment towards a more sustainable and more resilient Europe, so we should ensure that the technical criteria set are sound, based on operational reality and enforceable. SUEZ remains committed to contribute in a constructive way to the development of these technical criteria and reassert its offer to the European Commission and its experts to share our long-standing and internationally recognized expertise and experience in environmental services.
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Response to New EU Soil Strategy - healthy soil for a healthy life

10 Dec 2020

Suez welcomes the update of the soil Thematic Strategy which was announced in the EU Biodiversity Strategy for 2030. Suez agrees on the objectives included in this Roadmap (particularly items proposed in section B), mainly regarding the need for significant progress on identifying contaminated sites, restoring degraded soils, defining the conditions for their good ecological status and improving the monitoring of soil quality. We stress the importance in developing a coherent policy framework on soils, in close coordination with all the different strategies and action plans, already initiated in the Green deal context, in which soils (pollution and remediation) are listed : EU biodiversity Strategy for 2030, Zero Pollution Action Plan, Chemical strategy for sustainability, Strategy for a Sustainable Built Environment,… Within the Roadmap, various sources and pollution are mentioned. However, mentioning in a single sentence all sources and pollution without distinction and without prioritizing (e.g. excess fertilizer and sludge without the notion of excess) leads to a stigmatization of materials which nonetheless contribute by their return to the soil to: • A reduction of GHGs. • An increase in the carbon stock in the soil (cross-reference the “4 per 1000 initiative”). • An agricultural economy. In this regard, it is important to: - Update the figures and/or study the contribution of each polluting source to soil pollution. - Promote the return to the soil of MAFOR (fertilizers of residual origin) including sewage sludge and compost from the fermentable fraction of Household Waste; via an inclusive regulation. o Three stakes exist: return to the soil of organic matter (and all its benefits, see challenges of the “4 per 1000 initiative”), return to the soil of nutrients (from recycling) in substitution of mineral fertilizers and reconstitution of the carbon of the soil in a logic of 'sequestration' (via a potential mix with biochar). - Promote "carbon credit" projects (e.g. low carbon label). o Carbon pricing systems must be able to help farmers move towards more virtuous practices (use of bio-sourced fertilizers in general: organic matter, nutrients from recycling, bio stimulants, etc.). There is no real market for ‘bio-fertilizers’ today due to the lack of a financing system; however, Carbon credits can be one of them. - Find solutions against soil acidification and manage the pH to reduce GHG emissions. We have additional comments on Soil Remediation and Sewage Sludge but we have not been able to technically upload our Position Paper. There was an error message. We would still like to provide you with our position.
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Response to Sustainable Products Initiative

2 Nov 2020

SUEZ welcomes the Impact Inception Assessment on the Sustainable Products initiative and considers it is necessary to reduce carbon emissions through circular designed products. The promotion of reuse and recycling and incorporation of recycled products is key to the transition to a low carbon and circular economy. Our key messages to take into consideration for the Impact Inception Assessment are the following: • Design of products should keep in mind the end of the value chain and it’s sub sequential process: reuse, repair and/or recycling. The Ecodesign Directive should be extended to other applications. The energy-centric focus of the current Ecodesign Directive prevents EU legislation to use an existing legislative tool to address the full life cycle of thousands of products on the Internal Market. Widening the scope would enable the EU to properly address resource use, recyclability and durability of products. • With respect to recycling o Standard testing protocols and scoring method needs to be implemented for assessing the recyclability of products. For packaging, we support the guidelines established by Recyclass. We also have very good experience with the development of technical standards for the application of recyclates specifically for construction and demolition waste. o Marketeers and product designers have a clear responsibility to increase the attractiveness for end consumers of high-quality recycled products that are often more expensive than virgin material-based products. • Use of recycled content o Recycled Content must be an obligation for certain products in order to promote recycling and sustainability. A minimum obligation of 25% recycled plastics is already feasible today in specific applications. o It is important to note that in order to count towards the recycled plastic targets, only the plastics recycled from waste should be counted and not the by-products not legally defined as waste. These by-products are: a) the off-grades virgin plastics from the petrochemical industry, b) the virgin plastics blended in so-called circular compounds, and c) the onsite reprocessed off-cuts from the conversion of plastics into products. We insist on defining “recycled plastics” as the plastics originating from waste, namely materials recycled from products which have reached the waste status (by-products cannot be included). • Recycled Paper and Cardboard o The market today suffers from an oversupply with demand for low prices. o Sustainable products should have an obligation to use recycled paper and cardboard of at least 25% within certain products such as tissue and graphic paper. For other paper and cardboard products such as paper and packaging, there is already good use of recycled materials. o Another means to stimulate the demand for these products is to decentralize the packaging of products to the EU. Products are shipped to the EU in bulk adequately protected to prevent breakage. The products are then packaged according to the Producer’s requirements using recycled materials. This creates jobs within the EU. • SUEZ supports in addition the Carbon Border Adjustment Mechanism proposal as it will stimulate the growth of the circular economy, particularly within the EU if levies are placed on imported products that are not sustainable or sustainably sourced. • We support traceability of substances in products in order to promote recycling; requirements within REACH must be adhered to. • We support the use of Product Environmental Footprint and Ecolabel to rate sustainability of products which must be standardized and harmonized; direct and indirect emissions need also to be considered. • Harmonized labelling should be put in place for consumers. • Our position on bioplastics and degradability is that the impact on the environment should be closely studied. Our position is attached to this consultation.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

As a provider and leader in environmental essential services to the society and economy, Suez is convinced that the Zero Pollution ambition will boost the needed transition towards a sustainable society and has the potential to rapidly deliver local jobs for all, growth and improve the quality of life of European citizens. Our Policy recommendations include the following:  To reach good ecological status of freshwater bodies, tackle water pollutions more effectively, by combining source control actions minimizing diffuse emissions (microplastics, pharma residues, EDCs, industry chemicals), with advanced water treatment solutions for remediation, for water reuse and preventing release of pollution through water discharge (both urban and industrial).  To drastically reduce the water footprint of agriculture, support advanced irrigation and treated wastewater reuse, crop-growing technologies and biofertilizers (organic waste, sludge recovery) that are cost-effective, resource efficient and reduce impact on soils.  To lower the water needs in industry and its emissions to water bodies, promote a sustainable and efficient use of water, favor water industry and process industry collaboration, deploy point of use recycling solutions and advanced reuse technologies while preserving the industry product quality and competitiveness.  To restore resources to an environmental objective (rewilding, parks, wetlands), deploy innovative remediation solutions for polluted soils and groundwater.  To accompany reshoring of key industries in Europe and transition of urban areas, support financially cost-effective solutions for remediation of brownfields and polluted soils.  To fully grasp the potential of wastewater, stimulate investments in cost-effective solutions and in biofactories to recover energy (biomethane and hydrogen, from sludge and wastewater), to manufacture biofertilizers, bio-CO2, N/P/inorganic and metal substances, to produce optimized quantities of hygienized biosolids; while accelerating the deployment of advanced water recycling and reuse solutions for several usages (agriculture, urban, industrial, aquifer recharge).  To control point and diffuse emissions of contaminants to the air by developing and implementing capture and treatment solutions for wastewater treatment plants.  To drive sustainable urbanization, support and encourage the deployment of integrated solutions and technologies to create tomorrow’s European cities (connected command center, Artificial Intelligence Tools, data platforms…) with the objective of reducing overall air pollution.  To maintain attractiveness of European cities (talents, growth, quality of life) while reducing pollution and positively impact public health, strengthen ambient air quality policies (national plans, WHO limits, monitoring, treatment) with dedicated EU funds; and allow carbon capture at the same time.  To invest in intelligent and remote systems and automations infrastructure (smart metering) to reduce CO2 footprint through water and energy reduction (end-user water and water heating consumption, network leakage reduction). We call on the European Commission to make projects implementing these solutions and technologies eligible for EU grants coming from the Recovery and Resilience Facility. To conclude, we seek a more resilient, more circular and resource-efficient economy and society, where the key indicator would be the quality of life of citizens. We therefore fully support the European Commission’s proposal on the Zero Pollution ambition as well as the accompanying initiatives such as the Chemicals Strategy for sustainability, the Strategy to reduce methane emissions, the Sustainable Products Initiative. We also support the E-PRTR and IED revisions which shall improve both data collection and tackle more stringently emission to soil and water. A high level of ambition with the accompanying policy and financing is essential to make this much needed change.
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Response to Sustainable corporate governance

8 Oct 2020

SUEZ is favorable to this initiative having a well-established Sustainable Corporate Governance team with extra financial reporting in place since 2008. In line with the “Loi Pacte” in France on the modification of the concept of interests of the company (and of its shareholders), SUEZ adopted a “raison d’être” in 2020 that embraces the interests of all stakeholders and commits to a positive impact on people and the planet. Moreover, SUEZ published in 2017 a due diligence plan to comply with the French law on corporate due diligence that would certainly inspire the future European regulation. In that sense, SUEZ welcomes the initiative of the Commission that will create a level playing field for corporate due diligence in Europe. The details of the legislation as envisaged by DG Justice should then be clarified in line with the existing regulations in European countries and the provisions that will be taken on other texts like the existing and to be revised, Non-Financial Reporting Directive, but also the taxonomy. If this regulation takes the form of a directive, its transposition should be closely monitored because translation of concepts could lead to legal uncertainties within the EU. The future regulation should apply to all companies active on the European market and articulated with commercial treaties. The scope of corporate responsibility should be clear and manageable in terms of reference texts, when for instance defining ‘human rights”, place in the value chain (tier 1 seems reasonable) or disclosure obligations (that should not create market distortion). Support should be provided to companies for implementation, in a continuous progress approach.
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Meeting with Frans Timmermans (Executive Vice-President)

29 Sept 2020 · Circular economy and green recovery

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

21 Sept 2020

Suez subscribes to the new EU climate ambition of reducing GHG emissions by at least 55% by 2030. Suez’s corporate growth strategy – SUEZ 2030 – is fully aligned with this major milestone of the trajectory of EU’s climate neutrality by 2050. Additionally, Suez is committed to contribute positively and bring value to the objectives of the Green Deal. In 2018, Suez produced 7.7 TWh of renewable energy and avoided 10 million tCO2 equivalent. As part of the review of the Renewable energy Directive, we call for full coherence between this piece of legislation other energy legislation (EED, Energy Taxation Directive), and sectoral legislation (DW Directive, Urban WW Treatment Directive, Sewage Sludge Directive, Waste Directives, CEAP, Methane Strategy). Within this context, the environmental services sector’s potential for renewable energy production represents a powerful asset which needs to be further exploited for increasing the share of renewable energy sources in the energy mix of EU Member States and industries. Another significant benefit of promoting more renewables produced from waste and water in Europe, is that the energy outlets produced are based on local assets, meet local community and business needs, and are all based on local biomasses (solid waste, wastewater). Last but not least, environmental services’ production of renewable energy is generating domestic jobs which cannot be relocated. Suez would like to stress the following elements (more detailed in the document attached), as part of the evaluation and possible revision of the Renewable Energy Directive (known as RED II): • The treatment of water and wastewater represents a local source of renewable energy through the recovery of their energy potential (liquid sludge, heat of wastewater, dried sludge, etc). Indeed, wastewater treatment represents a great source of renewable gas (biogas, biomethane), electricity and heat with different solutions to meet the needs of cities as well as industries; • Because of its dual function, energy recovery of non-recyclable waste is the link between renewable energy and circular economy. Residual waste (not suitable for recycling after sorting) should be regarded as a sustainable source of energy; • Solid Recovered Fuels (SRF) or Refuse Derived Fuels (RDF) (produced from residues of non-recyclable, non-hazardous municipal or industrial and commercial waste, such as paper, cardboard, wood, textiles, etc.) are composed from more than 60% of biomass (according to a recent French study). This could be a significant part of the production of low carbon energy in substitution to fossil fuels; • In order to be able to invest in the production of sustainable aviation fuels (SAF), the waste sector needs a stable policy framework which guarantees the eligibility of waste for SAF production over time (RED II revision is capital in that sense), without ambiguity of competition with the primary generation sectors and in particular with dedicated energy cultures; • Suez is convinced by the potential of green hydrogen for driving Europe’s sustainable mobility and energy grid transition. The environmental services’ sector can contribute to this transition by providing the renewable energy needed (notably electricity) for making green hydrogen mainstream.
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Meeting with Pascal Canfin (Member of the European Parliament)

14 Sept 2020 · Green Deal

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

8 Sept 2020

SUEZ is one of the two main global players in the environmental services sector and offers solutions tailored to its customers’ needs and local specificities. The Group focuses on a circular economy model throughout the water management and waste recovery value chain, from the construction and the operation of water networks and infrastructure, to collection, sorting and recycling. It also generates renewable energy, produce secondary raw materials and delivers digital services. SUEZ supports the environmental transition of cities and industrials that fully engage with the question of resource scarcity and the need to combat climate change, while simultaneously adapting to the consequences this change has already brought about. The Group provides a substantial positive contribution to the challenges experienced by his clients. For instance, services delivered by SUEZ are key to the decarbonization of business activities and territories, contribute to the optimization of energy performance and the improvement of climate resilience, and can even upgrade the safety of industrial processes impacted by the proven effects of climate change. As a listed company, SUEZ discloses in its Universal Registration Document (URD) information compliant with Directive 2014/95/EU. In accordance with French Code of Commerce, SUEZ publishes a Declaration de Performance Extra-financière (DPEF) detailing its exposure to the most material and significant extra-financial risks it has identified and the associated mitigation policies, plans and performance indicators. With total revenues of EUR 18 billion and 89,352 employees as of December 31, 2019, SUEZ is directly impacted by the modifications brought to the NFRD and future delegated acts related to the implementation of the EU Taxonomy. As such: 1. The Group welcomes any guideline and clarification related to the disclosure of EU taxonomy related turnover, CAPEX and OPEX; considering the specificities of its business and the numerous challenges related to data collection processes, the adaptation of its IT infrastructure and the costs related to the adaptation of its operational and environmental management systems, it is crucial to provide issuers details about the scope and methodology expected to publish the KPIs. 2. The Group would benefit from clear instructions on applicable methodologies and the possibility to attach a methodological note publicly accessible. This would help guide investors and relevant stakeholders to understand its performance. 3. The Group calls for an alignment of the KPIs requested by the ESG-market stakeholders (administration, investors, rating agencies,..); corporates are under increasing pressure to answer a wide and increasing variety of ESG questionnaires from different stakeholders (data providers, rating agencies, investors, clients' rating agencies etc.). Each requests come under a specific format and target either very specific topics (supply chain, human rights, carbon, environment etc) or general ESG overview; most of the time, these questionnaires ask corporate to provide specific KPIs. This creates confusion about which KPIs are the most relevant for stakeholders and this process has become particularly time-consuming for corporates. It also hampers their ability to focus on the most relevant KPIs to best reflect their contribution to the Paris Agreement and the EU Agenda on environmental transition and carbon neutrality.
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Response to Revision of the Urban Wastewater Treatment Directive

8 Sept 2020

Ensuring Access to Sanitation In 2010, the UN officially acknowledged the Human Right to Water and Sanitation and has also set SDG 6 with the aim to grant access to clean water and sanitation for all by 2030. The current UWWTD Directive does not address the issue related to access to sanitation. Yet, an increasing number of people, including homeless people in urban areas, lack access to decent sanitation facilities. The new UWWTD should include legal provisions to enshrine this international right into European law. Managing Combined Sewer Overflows (CSOs) Combined Sewer Overflows create an increasing pressure on the aquatic environment and can represent a source of pollution. This includes usual parameters like Total Suspended Solids (TSS) and Chemical Oxygen Demand (COD), but also emerging pollutants like microplastics and even more macroscopic waste. Moreover, climate change has already visible impacts including lower summer flows, less dilution of pollution, and more unpredictable rain patterns. There is hence a need to gain more visibility on the fate of untreated urban wastewater, beyond the footnote of the Annex I of the current UWWTD. For example, in France, the UWWTD has been complemented by a Government Decree (adopted on 21 July 2015) which limits to 5% the untreated volume and flow of Combined Sewers. For these reasons, Suez thinks that the Directive should cap CSOs discharges in terms of Total Suspended Solids (TSS), Chemical Oxygen Demand (COD), Biological Oxygen Demand (BOD), and possibly microplastics at agglomeration level. Addressing Emerging Pollutants New types of pollution such as Endocrine Disrupting Compounds (EDCs), pharmaceuticals, Antimicrobial Resistance (AMR), and microplastics, are increasingly attracting citizens, experts and media’s attention, as they continue to make their way into European water resources. The revision of the UWWTD should set obligations for Member States to investigate how to reduce pollution at source, particularly in hospitals and industrial sites identified upstream of waste water treatment plants. The level of pollution treatment should be adjusted accordingly. Treating pollution at source is more cost-effective than treating it once already diluted and causing consequently diffuse pollution in the environment. Moreover, the UWWTD should consider including additional specific limit values on the release of new pollutants into the environment. Suez is convinced that a combined approach is required to address emerging pollution: both upstream (control at source) and downstream (end-of-pipe treatment) in order to prevent as much as possible any risks of polluting water resources. A short-list of selected molecules used as indicators of groups of substances should be monitored in treated waste water, with action thresholds triggering more targeted source control, and/or extra-treatment. The application of bioanalytical tools to assess the toxic effects of complex chemical mixtures and their elimination by treatment processes should also be considered. Switching to a Circular & Efficient Model This revision represents an opportunity to bring more circular principles into the UWWTD. Therefore, the UWWTD revision could introduce obligations to evaluate, at least for large WWTPs, the potential for sludge to land (one option amongst more), nutrient and phosphorus recovery, methane generation, and treated wastewater reuse, in full respect of health and environment standards. We also recommend, at least for large WWTPs, to run emission (carbon at least) and energy audits, to pave the way to increasing energy efficiency of plants while reducing their climate impact. Studies show that the carbon content of municipal wastewater could cover the WWTPs energy consumption. The UWWTD revision could impose minimum standards when it comes to energy performance. This could be implemented, for example, through the application of energy management systems such as ISO 50001.
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Response to Evaluation of the Sewage Sludge Directive 86/278/EEC

25 Aug 2020

Sludge potential is diverse: soil stimulator and fertilizer, energetic, strategic material recovery (phosphorus), pollution removal, compost. Spreading of sewage sludge on farm land is currently regulated by the Sewage Sludge Directive. With the on-going transition towards a circular, low-carbon economy, SUEZ considers that a revision of the SSD is relevant to make it fit for the challenges and priorities of the 21st century, and hence provide legal certainty for future investments. • On the health aspect, and according to the French health monitoring committee created in 1997 to support the land spreading sector, no direct link has been established, since the start of its work, between sewage sludge spreading on land farm and pathological accidents. In addition, according to the French environmental transition agency ADEME, all LCA that have been run demonstrate that sewage sludge spreading is the most interesting elimination and recovery solution. • Additionally, this solution enables to ensure organic material input (and lime for limed sludge) to soils and fertilizing components to cultivation; while being a cost-efficient and economically attractive solution for wastewater public services. • Lastly, spreading of sewage sludge from wastewater treatment plants only represents 1 to 2% of spreading on farm land; the rest is spreading of manure, cultivated liquid manure and chicken droppings. ● The French authorities have completed the Sewage Sludge Directive with several national requirements: ○ Compliance of the producer of sewage sludge with waste management legislation, as sewage sludge are for the moment considered as waste; ○ Sewage sludge have to be tracked from production until their spreading, excluding standardized compost; ○ Ban unless exceptions of mixing sludge from different wastewater treatment plants. Hygienisation is becoming more and more the rule, and compulsory in the context of the sanitary crisis; ○ The operator is also required to (except for standardized compost): ■ Provide a preliminary study demonstrating the innocuity; ■ Set up a spreading plan and manage a log book; ■ Perform a close surveillance of sludge and soils; ■ Sign a convention with farmers • Thus, the requirements, thresholds and usages of environmental protection have noticeably advanced since the adoption of the SSD. The assessment of the SSD in view of a revision is therefore justified in order to include practices now made usual, and to consider the new findings and knowledge about new pollutants (micropollutants, microplastics, EDCs, etc.), as well as new requirements of farming practices (momentum for organic farming and products). • This revision must consider the on-going parallel work in view of a “Zero Pollution Europe”. We call for policy coordination driven by the Green Deal, as the SSD has obvious ties with the new Circular Economy Action Plan; greening the CAP; the Farm-to-Fork and Biodiversity Strategies. ● We recommend that the SSD is put in perspective with the on-going assessment in view of the revision of the UWWTD, notably as regards micropollutants. Indeed, the production of sludge is intrinsically linked, both in terms of quantity and quality, to the requirements and levels set for the treatment of wastewater (e.g source control of inputs, level of treatment of micropollutants in wastewater treatment plants, …). ● The revision of the SSD must also be driven by innovation as significant progress has been made in spreading practices since its entry into force. Digital tools (e.g AI) can guarantee both health and environmental concerns and security. ● The end-of-waste status, under certain conditions, should be a European ambition to contribute to a circular economy in all European regions, and hence guide sludge spreading on farm land. Finally, new European requirements can lead to constraints and additional costs. Therefore, any policy options in view of a revision must consider the needs and adaptation period required.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

27 Jul 2020

SUEZ is committed to help reducing packaging wherever this is reducing the environmental footprint of the packaged product from cradle to cradle. SUEZ therefore welcomes the actions the EU Commission wishes to take and fully supports the measures listed in the roadmap, notably the following: recycled content targets for packaging and design for reuse and recycling. SUEZ is actively involved in the Circular Plastic Alliance and the European Plastics Pact. We also do support for instance the ban of secondary packaging that have exclusively a marketing role without contributing to the protection of the packaged good. We support the light-weighting of packaging, as long as this operation is not degrading the recyclability of the initial packaging. Finally, we recommend delocalised packaging in order to take advantage of the oversupply of recycled paper/cardboard on the market in Europe thereby creating jobs within the EU. The idea is to ship products in brut form with adequate protection (such as plastic films that are recycled), to then have the product packaged within Europe to sell on the market using recycled packaging materials while still maintaining the principal of not overpackaging a product.
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Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

16 Jul 2020 · Green Deal

Response to Modernising the EU’s batteries legislation

9 Jul 2020

At SUEZ, we fully support the European Commission's initiative to pave the way for a sustainable and competitive batteries value chain in the EU, whilst addressing the social, environmental and health impacts generated. We have identified recommendations to further this initiative and to strengthen the safe recycling of batteries within the EU, thereby facilitating the transition to the Circular Economy that is just and successful. • Promote the eco-design of batteries to facilitate recycling with a focus on parts that are easy to lift, do not have non-separable plastics and that includes use of recycled plastics. Avoid use of multilayer metals / plastics. • Set up recycling rates by type of metal. Plastics should also be recycled. • Encourage recycling in the EU and avoid the export out of the EU of batteries (such as "blackmass"). Ensure harmonization of existing rules and promote a level playing field. • Facilitate collection whilst ensuring an optimized collection. • Take into account externalities. For example: sourcing of primary materials, savings in recycling those materials and savings linked to transportation of batteries (example: biomethane instead of fuel). • Attention is needed on the status of waste in used batteries in order to safely facilitate recycling. • Collection of data using digital tools will help further traceability of materials and exchange of information.
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Meeting with Thierry Breton (Commissioner)

29 Jun 2020 · La double transition; Le plan de relance européen, Les Alliances industrielles

Meeting with Carole Mancel-Blanchard (Cabinet of Commissioner Elisa Ferreira)

26 Jun 2020 · Video conference on the Green Recovery

Response to Minimum standards for benchmarks labelled as EU Climate Transition and EU Paris-aligned Benchmarks

6 May 2020

SUEZ considers that the European Commission has well understood the problems faced related to greenhouse gas emissions and welcomes the recent actions to reduce them. The proposed delegated regulation on minimum standards for climate benchmarks allows for a common methodological basis. Climate regulations are usually based on an analysis of territorial, direct GHG emissions, scientific methodology used by the IPCC (example the Global Carbon Project). However, territorial GHG emissions do not capture the GHG impact of importations and exportations (indirect emissions, captured by GHG footprint methodologies). Focusing only on reducing territorial GHG emissions might lead to delocalizing production to replace it by importation, or delocalizing treatment of waste. To lower indirect emissions it is key to reduce the GHG impact of producing material goods (accounting for 45% of total current GHG emissions, according to a Ellen MacArthur Foundation recent report). To do so, circular economy is an important enabler: • The positive impact of the circular economy solutions on GHG emissions should be well quantified & identified by the European regulators in the carbon budgets. Countries & EU should quantify consumption based emissions (including imports /exports, instead of focusing only on territorial emissions – IPCC accounting) in their carbon budget; thereby giving value to the positive impact of solutions that reduce the need to import primary raw materials (saved emissions). • The EU should promote standardized accounting with science-based consensus on the net GHG impact of waste & circular economy solutions including on how to compute saved emissions. Saved emissions are part of the solutions package to reach both carbon neutrality and the -1.5°C objective (and not only through reduced emissions and nature-based offsets). • Ownership of saved emissions should be attributed along the value chain, with a large attribution to the circular economy & recycling industry that is producing them through secondary materials and green energy. • The Green Deal should finance a carbon price mechanism monetizing saved emissions at a level enabling a real transition to finance source segregated collection & sorting and stable markets for recycled materials throughout the EU. In addition, a carbon border tax will serve as a climate shield to foster the emergency of strategic value chains (recycling, batteries, water reuse), downstream European markets for recycling and recovery; and pave the way to the reindustrialization of Europe.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

21 Apr 2020

SUEZ welcomes and supports the initiative of the European Commission to boost the supply and demand for sustainable aviation fuels (SAF) which will contribute to achieving EU climate neutrality ambition by 2050. SUEZ as a leader in environmental services in Europe is already engaged in several national initiatives to develop a sustainable value chain for SAF based on different waste feedstocks. SUEZ would like to make the following recommendations: 1. Waste can clearly take part in the European ambition to produce SAF. Thanks to its low carbon footprint, waste is a sustainable way to help the aviation sector reduce its greenhouse gas emissions in the long term. 2. In order to be able to invest in this SAF production sector, the waste sector needs a stable policy framework which guarantees the eligibility of waste for SAF production over time (RED II), without ambiguity of competition with the primary generation sectors and in particular with dedicated energy cultures. 3. We foster putting in place support schemes for waste streams under tension in Europe and for which the emergence of an alternative SAF production sector would constitute a new recovery opportunity (biogenic fraction of municipal waste, SRF/RDF, Paper and cardboard, waste wood). We hope that the production of SAF will appear as a virtuous way of recovering waste if only for its benefits for the climatic challenges of air transport and that it be supported in the same way as material recovery. 4. We are convinced that the development of the SAF sector would require regulators to put in place feed-in tariffs, in exchange for strong commitments from aviation sector on incorporation levels over the medium to long term. 5. Finally, we welcome the initiative to create a coordination platform and very much hope that the waste sector will be represented somehow as managers of the feedstock.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

25 Mar 2020 · EU Green Deal, crisis recovery and circular economy

Meeting with Frans Timmermans (Executive Vice-President)

6 Feb 2020 · Green Deal an circular economy

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Fédération Nationale des Activités de Dépollution et de l'Environnement

21 Jun 2019 · SUEZ Manifesto on Sustainable Europe and compostable recycling

Meeting with Jean-Eric Paquet (Director-General Research and Innovation)

26 Mar 2019 · Innovation policy

Response to Towards an EU Product Policy Framework contributing to the Circular Economy

4 Jun 2018

Please find attached SUEZ's answer to the Roadmap "Towards an EU Product Policy Framework contributing to the Circular Economy"
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Meeting with Frans Timmermans (First Vice-President)

11 Apr 2018 · discussion on the implementation of the Plastic Strategy

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

7 Feb 2018 · Discussion on the Plastic Strategy

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

30 Jan 2018 · Circular Economy

Meeting with Miguel Arias Cañete (Commissioner)

30 Jan 2018 · Clean Energy Package

Meeting with Karmenu Vella (Commissioner) and

30 Jan 2018 · Circular Economy Action Plan

Meeting with Daniel Calleja Crespo (Director-General Environment)

20 Dec 2017 · Waste shipments to China

Response to Strategic approach to pharmaceuticals in the environment

26 May 2017

Dear Madam, Sir, Please find attached the contribution of SUEZ to the consultation on the Roadmap "Strategic approach to pharmaceuticals in the environment". We hope our input will contribute in a constructive way to the work of the European Commission. Should you have any questions, do not hesitate to contact us. Best regards, Denis Bonvillain EU Permanent Delegate SUEZ Group
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Meeting with Phil Hogan (Commissioner)

25 Apr 2017 · Information regarding the work of SUEZ

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

25 Apr 2017 · digitalisation, circular economy

Meeting with Carlos Moedas (Commissioner) and

25 Apr 2017 · Circular Economy

Meeting with Pierre Moscovici (Commissioner)

18 Jan 2017 · Economic outlook in France and Europe

Meeting with Jyrki Katainen (Vice-President) and

2 Jun 2016 · CE8 side-event at EBS - Circular Economy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

19 May 2016 · Circular Economy - Energy

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

19 Apr 2016 · circular economy

Meeting with Daniel Calleja Crespo (Director-General Environment)

13 Oct 2015 · Circular Economy

Meeting with Frans Timmermans (First Vice-President)

1 Oct 2015 · Circular Economy

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

2 Jul 2015 · Circular Economy

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

2 Jul 2015 · Circular economy

Meeting with Bernardus Smulders (Cabinet of First Vice-President Frans Timmermans), Heidi Jern (Cabinet of Vice-President Jyrki Katainen), Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

2 Jul 2015 · Circular Economy

Meeting with Karmenu Vella (Commissioner)

5 May 2015 · Circular Economy

Meeting with Pierre Moscovici (Commissioner)

20 Mar 2015 · Economie Circulaire

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu)

4 Feb 2015 · Public Private Partnerships within Cohesion policy

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

4 Feb 2015 · Circular Economy

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

27 Jan 2015 · Circular Economy

Meeting with Patrick Costello (Cabinet of Vice-President Karmenu Vella)

4 Dec 2014 · Circular economy and water issues