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Teema: EEB vision on how the EU can deliver the European Green Deal and address the multiple crises we face
Kuupäev: 2022-10-14 12:10
To: Ministers of Environment, Climate, Energy, Economics, and Industry of
EU Member States
Dear Minister,
On behalf of Patrick ten Brink, European Environmental Bureau’s Secretary
General, please find attached the EEB vision on how the EU can deliver the
European Green Deal and address the multiple crises we face.
Kind regards,
Alina Lukianova
Secretary
European Environmental Bureau
Rue des Deux Eglises 14-16, B-1000 Brussels
Tel: +32 2 289 10 90
Email:
[email protected]
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To: Ministers of Environment, Climate, Energy, Economics, and Industry of EU Member States
14 October 2022
Dear Ministers,
EEB vision on how the EU can deliver the European Green Deal and address the multiple crises we face
Europe is at a turning point in history and the EU’s response to the current geopolitical and fuel price crises,
and to the linked climate, biodiversity, and pollution crises, will define what the EU is and what future we are
choosing for current and future generations.
The European Green Deal (EGD) was launched as a “man on the moon” moment in 2019 and promised to
deliver a set of deeply transformative policies that would “reconcile the way we produce, the way we consume,
with our planet and to make it work for our people”. EEB’s mid-term assessment of the EGD highlighted
several achievements but also missed opportunities that need to be addressed by the European Commission
in 2023 in support of the EGD ambitious agenda, as well as by Council and Parliament in trilogues.
We are highly concerned that the Commission’s Letter of Intent outlining priority initiatives for 2023 did not
mention a number of the promised legislative files. We are writing to you to ask you to:
A. Encourage and support the European Commission to adopt an ambitious Work Programme 2023
and resist pressures to delay important files; and
B. Drive initiatives to help Europe overcome the current energy crisis.
Together this can be the person on the moon moment for Europe, while making a major contribution to
addressing the current energy price, climate, environment and social crises.
A. Encourage and support an ambitious CWP2023 and resist pressures to delay important files
It has become increasingly evident that many arguments are being tabled to delay key files that had been
promised for 2023 and essential for the EGD.
Critics of the EGD are defending business-as-usual and demanding that there be no new regulatory
obligations. This would mean missing the opportunity to make these sectors into climate resilient and
environmentally responsible. Listening to these unjustified arguments risks locking-in wrong and overly short-
term solutions and should be resisted.
Good short-term solutions should and can enable long term viability and sustainability. In fact, faster
implementation of the EGD will help support fuel independence from Russia, reduce fuel prices faced by
industry and consumers, as well as boosting green innovation.
If the proposals that had been promised for 2023 by the Commission are delayed, then there is a strong risk
of missed opportunity as a new Parliament and Commission may not continue the inter-institutional
negotiations in late 2024, undermining the legacy of the EGD. Legislative initiatives that need to be prominent
in CWP2023 include:
European Environmental Bureau
● Rue des Deux Églises 14-16, 1000 Brussels, Belgium ● ☏ +32 228 91090 ●
[email protected] ● www.eeb.org
International non-profit association ● Association internationale sans but lucratif (AISBL) ● EC register for interest representatives:
ID number: 06798511314-27 ● BCE ID number: 0415.814.848 ● RPM Tribunal de l’entreprise francophone de Bruxelles
- The REACH regulation, originally foreseen for 2022. The REACH reform proposal should not happen
beyond March 2023. Note that REACH will not create obligations on companies in the short term. The
objective of a toxic-free future ahead of us will trigger new solutions and investments. If the Commission
sticks to its EGD promises on REACH, then the EU will be in a good place to avoid future chemicals
pollution, health impacts, and the climate and biodiversity crises.
- The Review of the EU Mercury regulation, initially planned for Q4 2022, and now promised for Spring
2023, should not be delayed further. A few months delay in the CWP can lead to years of actual delay.
- The New Sustainable Food Systems (SFS) law. This is a fundamentally important piece of legislation and
essential in our bid to ensure food system sustainability, long term resilience and food security.
- The Soil Health Law and Forest Monitoring Law were all also earlier promised for 2023. This promise
needs to be kept. These are essential to invest in the regenerative economy promised in the 8EAP.
- The Raw Materials Act is particularly needed to contain the demand for critical materials, secure recycling
investments through systematic and ambitious recycling targets, and only allow mining on condition of
strict environmental and social criteria.
- While progress has been made on carbon emissions from new cars, trucks, if left untouched, will eat up all
the car CO2 savings by 2030. The Commission should propose truck CO2 standards no later than January
2023, including a 100% CO2 reduction from new freight trucks not later than 2035.
B. Drive initiatives to help Europe overcome the current energy crisis.
The way forward needs to be a positive agenda that gives companies and citizens hope and leaves no one
behind. The following priorities should be embraced to demonstrate EU action and concern and drive a
positive way out from the fuel crisis. We ask Ministers to:
1. Push for the fastest possible roll out of energy efficiency, energy savings and building renovation
measures. This will decrease the burden on the private and public sectors. Particular attention should be
paid to the most vulnerable and most affected by energy poverty;
2. Speed up renewables deployment without undermining EU law or consultation processes that underpin
our democratic model and reputation for the rule of law. We are very concerned about the weakening of
assessment processes and consultations and the implications not only for nature but also for citizen
support;
3. Promote taxes on windfall profits to raise needed funds and to give a signal of fairness to the
population. Make direct use of the taxes to fund renovation, energy savings, renewable technologies to
support households in need;
4. Ensure that the Social Climate Fund is well-resourced and revenues from it are a reliable source. This
can be a real game changer if it helps countries provide social assistance and an alternative to the fossil
fuel subsidies that many countries cannot afford;
European Environmental Bureau
● Rue des Deux Églises 14-16, 1000 Brussels, Belgium ● ☏ +32 228 91090 ●
[email protected] ● www.eeb.org
International non-profit association ● Association internationale sans but lucratif (AISBL) ● EC register for interest representatives:
ID number: 06798511314-27 ● BCE ID number: 0415.814.848 ● RPM Tribunal de l’entreprise francophone de Bruxelles
5. Encourage national action and policy reform. Make use of the Semester, the National Recovery and
Resilience Plans (NRRPs), as well as the National Energy and Climate Plans (NECPs) to push for policies to
drive renewable and energy savings;
6. Promote hydrogen in a targeted way to enable fuel switching from gas and support some hard-to-abate
industrial activities, but don’t promote hydrogen for domestic heating as this is it not a cost-effective use of
green hydrogen. Hydrogen production should only be based on additional renewable electricity;
7. Push forward a substantial reform of the Stability and Growth Pact. This can provide the fiscal space
to fill the green funding gap and make Europe energy independent from fossil fuels;
8. Promote actions to reduce national material and consumption footprint to scale up of resource
savings;
9. Invest in safe and sustainable by design chemicals to support EU chemicals industry transition towards
decarbonisation and detoxification as well as to reduce energy dependence;
10. Implement and enforce the EU laws: the EU already has important laws in place, however their
implementation is often challenging. Implementing and enforcing EU laws will help protect nature, achieve
sustainable water management, support energy savings, improve energy performance of buildings,
products and processes, support resource efficiency, and help reduce sensitivity towards fuel and material
prices among others.
Many Member States and the Commission have already moved on a number of these areas. Of course, had
we moved faster on energy efficiency, renewables, less fossil-dependent chemicals, and circular economy
before, we wouldn’t be in as difficult a situation as we are in now. A further positive push in these areas will
create an agenda of hope, increase our resilience and be a clear demonstration of solidarity.
We are at a turning point.
We can either accelerate the move towards energy and materials independence or we can take a step back
into the past by subsidising fossil fuels and deregulating. The former creates a solution for the future and is a
peace project. The latter is a major missed opportunity and reneges on decision-makers’ responsibilities for
your youth and future generations.
The EGD has the potential to be the transformative agenda we need, that citizens demand, that science
argues for, and make industry future proof. It can be the person on the moon moment that has been
promised. Europe is impacted by Russia’s war in Ukraine and facing a difficult winter. Positive commitments
will help us get through this together and give hope.
We look to you, Ministers, to push European Commission to continue with the EGD and create the future we
need.
Thank you for your engagement and we wish you and your citizens well.
Patrick ten Brink
Secretary General, European Environmental Bureau (EEB)
European Environmental Bureau
● Rue des Deux Églises 14-16, 1000 Brussels, Belgium ● ☏ +32 228 91090 ●
[email protected] ● www.eeb.org
International non-profit association ● Association internationale sans but lucratif (AISBL) ● EC register for interest representatives:
ID number: 06798511314-27 ● BCE ID number: 0415.814.848 ● RPM Tribunal de l’entreprise francophone de Bruxelles