Environment/Logistics
EuroCommerce position paper on the proposal for a Regulation of the European Parliament and of the Council concerning the placing on the market and use of biocidal products (COM/2009/0267 final) of 12th June 2009
Published: 25/11/2009 - last updated: 25/11/2009
1. General evaluation
The Commission proposal for a Regulation concerning the placing on the market and use of biocidal products is very unclear on several points raising a number of questions and making an assessment of its impact on the commerce sector very difficult
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EuroCommerce contribution to the recast Directive on the energy performance of buildings
Published: 22/09/2009 - last updated: 22/09/2009
Key messages
1. EuroCommerce agrees with the overall objectives of the recast of the energy performance of buildings directive. In particular, we support the approach of assessing all measures from a perspective of cost-effectiveness.
2. The directive was adopted in 2006 and many member states are still lagging behind in its implementation. In the absence of a complete overview, or any substantial data on the impact of the directive, EuroCommerce would suggest caution.
3. Some amendments of the EP, if confirmed by the Council, would generate further costs and bureaucracy without any real added value, either for retailers or consumers.
4. If the EP proposal to issue and display an energy certificate in buildings frequently visited by the public is confirmed by the Council and shop premises fall under this category this could cost German retailers alone at least some €25 million.
5. Displaying the energy certificate in shop premises is of little value: it details the energy consumption of the building itself and has no bearing on the energy requirements of the retail activities carried on inside the building.
6. EuroCommerce suggests delaying the deletion of the 1000m² threshold.
7. EuroCommerce supports the Commission threshold of 25% of the value of the building when defining “major renovation”
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EuroCommerce Response to European Commission Consultation “A sustainable future for transport: Towards an integrated, technology-led and user friendly system”
Published: 30/09/2009 - last updated: 30/09/2009
EuroCommerce had the opportunity to contribute to the EU Commission consultation paper on “A sustainable future for transport: Towards an integrated, technology-led and user friendly system”, prior its publication on 17 June 2009, by participating to the Future of Transport 3rd focus group on Infrastructure and Logistics (including urban and land planning).
EuroCommerce welcomes this Communication on the Future of Transport. With this paper we would like to provide the Commission with additional input on issues which are of particular relevance for the commerce sector and which should be included in the forthcoming 2010 White Paper as well as in other future initiatives of the Commission.
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Recast of the WEEE Directive
Published: 27/08/2009 - last updated: 27/08/2009
Key messages
The commerce sector regards the Commission’s proposal to recast the WEEE (Waste Electrical and Electronic Equipment) directive as an opportunity to rectify some of its shortcomings. In particular, we would like to focus on the following elements:
(i) the scope of the Directive;
(ii) the definitions of some key terms; (art. 3)
(iii) the reporting requirements; (art. 16)
(iv) individual responsibility of producers; (art. 5 p.2c)
(v)take-back systems for distributors; (art. 5, p.2b)
(vi) the visible fee (art. 12, 14)
(vii) the collection rates (art. 7)
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EuroCommerce response to the consultation on the guidance on requirements for substances in articles
Published: 07/08/2009 - last updated: 07/08/2009
Introduction
Of all the guidance documents, the one on requirements for substances in articles is the most important for the commerce sector. EuroCommerce would therefore like to contribute to its revision with the following remarks.
Our comments will focus in particular on chapter 5 of the guidance – obtaining information on substances in articles – and appendix 1 – borderline cases. This will be preceded by some short general remarks regarding information flow as foreseen by article 33.
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EuroCommerce contribution to the recast of Directive on the energy performance of buildings
Published: 18/02/2009 - last updated: 18/02/2009
In March 2007, the Heads of States committed to the following targets by 2020: cut greenhouse gas emissions by 20%; increase the share of renewables in energy use to 20%; improve energy efficiency by 20%
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SCP Package
Published: 10/12/2008 - last updated: 15/01/2009
EuroCommerce welcomes the publication of the SCP Package and agrees with the overall objectives. In particular, we welcome the proposed mix of voluntary and regulatory measures to promote change.
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European Commission Proposal: Amending Directive 1999/62/EC on the Charging of Heavy Good Vehicles for the Use of Certain Infrastructures
Published: 12/11/2008 - last updated: 12/11/2008
EuroCommerce is critical of the European Commission’s proposal on the revision of the Eurovignette Directive 1999/62/EC. The proposal risks making road transport getting more expensive but it will not necessarily yield any significant environmental results.
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Revision of the energy label: new proposal for layout
Published: 01/09/2008 - last updated: 07/10/2008
EuroCommerce appreciates the efforts of DG Transport and Energy to find a compromise between two approaches regarding a new label ahead of the revision of the directive on the energy labelling scheme for household appliances. While this proposal might prove satisfactory from a political point of view, EuroCommerce warns against a political compromise which could prove sub-optimal in practice.
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EuroCommerce voting recommendations on the waste framework directive
Published: 09/06/2008 - last updated: 09/06/2008
Ahead of the Plenary vote on the Waste Framework Directive in June, EuroCommerce would like to highlight and comment on the key amendments for the commerce sector. The amendments relate to article 7 (producer responsibility), article 11 (waste hierarchy) and article 8 (recovery).
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Stakeholder consultation on the review of the Directive on Waste Electrical and Electronic equipment (WEEE)
Published: 06/06/2008 - last updated: 06/06/2008
EuroCommerce welcomes this consultation on the review of the WEEE Directive (2002/96/EC).
The implementation of the WEEE Directive has been slow and some Member States have only recently started complying with all its provisions. Despite this, a number of inconsistencies have arisen, which regrettably the consultation does not address.
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Eurocommerce position for 2nd reading on the revision of the Waste Framework Directive
Published: 28/02/2008 - last updated: 28/02/2008
EuroCommerce welcomes the improvements that were introduced in first reading. Ahead of second reading, EuroCommerce would like to draw the attention of policy-makers to a few points which can still be improved to make the revision of the waste framework directive a workable instrument for European businesses.
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EuroCommerce response to the Commission consultation on the revision of the Energy Labelling Directive 92/75/EEC
Published: 22/02/2008 - last updated: 22/02/2008
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Position paper on the green paper on urban transport “towards a new culture for urban mobility”
Published: 22/02/2008 - last updated: 03/03/2008
Key messages and solutions for a better functioning urban mobility
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Position paper “consultation internalisation of external costs”
Published: 21/12/2007 - last updated: 10/01/2008
EuroCommerce welcomes the public consultation the Commission is carrying out on the preparation of an impact assessment on the internalisation of external costs, launched on 30 October 2007.
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Upcoming Sustainable Consumption and Production Action plan
Published: 10/10/2007 - last updated: 11/10/2007
Considering the current challenges environmental, energy etc. the upcoming action plans on sustainable consumption and production and sustainable industrial policy are of the utmost importance. These action plans will shape the future EU policies and will have major implications for society at large.
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EuroCommerce response to the green paper on market based instruments for environment and energy related policy purposes
Published: 07/08/2007 - last updated: 07/08/2007
Scarcity of natural resources and climate change are a reality which must imperatively be addressed. This is why EuroCommerce adheres to the efforts of the EU and the more recent commitment made by the Heads of State at the Spring Council to tackle energy and climate change issues.
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EuroCommerce views on the Commission proposals regarding supply chain security
Published: 11/07/2007 - last updated: 20/07/2007
EuroCommerce participated in the information meeting on supply chain security organised by DG Tren on 8 June. The purpose of this meeting was to discuss – besides the state of play, the new developments and the future steps to take. Two concrete proposals were put forward, namely: closer co-operation with the police and the development of a CEN standard on supply chain security.
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Preparation of the green paper on urban transport
Published: 30/04/2007 - last updated: 02/05/2007
Cities need commerce
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Eurocommerce position on amendments on waste framework directive tabled in the environment committee
- last updated: 18/11/2006
EuroCommerce supports an overall EU waste framework for developing national waste management measures, but we believe it is up to local, regional and national stakeholders to manage their waste. Ahead of the vote on the Waste Framework Directive in the Environment Committee, EuroCommerce would like to highlight the key amendments for the commerce sector. The amendments relate to Article 1 (the establishment of a waste hierarchy), Article 3 (definitions) and Articles 26 and 29-31 (national waste management plans and waste prevention programmes and measures)
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EuroCommerce position on amendments on REACH tabled by the environment committee in 2. reading
- last updated: 09/11/2006
Ahead of REACH vote in the Environment Committee on 10 October, EuroCommerce would like to highlight and comment on the key amendments for the commerce sector. The amendments relate to articles 6 (substances in preparations) article 7 (substances in articles), article 8 (quality mark) and article 32 (information flow).
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REACH: EuroCommerce position for 2nd reading
- last updated: 09/11/2006
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EuroCommerce comments on the proposal for a regulation on enhancing the supply chain security
Published: 13/10/2006 - last updated: 09/11/2006
Introduction
Recent events confirm that the risk of a terrorist attack remains high. The security of transport of goods and passengers must therefore stay a priority and efforts to improve security should be welcome.
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EuroCommerce comments on the communication of the commission on freight logistics in Europe – key to sustainable mobility
Published: 13/10/2006 - last updated: 09/11/2006
Introduction
Commerce is very dependant on transport and has already long integrated the logistics aspect in its daily activities as a means to optimise flows of goods. EuroCommerce therefore welcomes the Commission’s communication on freight logistics in Europe which aims at introducing a logistics perspective into transport policy.
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Eurocommerce response to the consultation on the revision of the community legislation on the access to the road transport market and on the admission to the occupation of road transport operator
Published: 08/08/2006 - last updated: 09/11/2006
Introduction
Deliveries play a vital role for the commerce sector, whose primary function is to bring goods and services to customers. Increasingly customers expect a full range of high quality, reasonably priced products to be available at all times. Efficient transport is therefore necessary to ensure that the goods are delivered in an optimal manner and at a least possible cost for consumers.
EuroCommerce welcomes the consultation launched by the European Commission. As transport buyers the only issue of direct relevance for commerce is cabotage, which can contribute towards reducing transport costs and limiting the number of empty vehicles on the roads. Our response will therefore limit itself to this aspect of the consultation.
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Proposal for a directive of the European Parliament and of the Council on waste- Com(2005) 667 final
Published: 07/08/2006 - last updated: 09/11/2006
EuroCommerce welcomes the proposal for a review of the Waste framework Directive as a measure to modernise waste legislation in the EU. The review should lead to a simpler set of rules offering the necessary legal certainty for all actors in the supply chain, while delivering increased environmental benefits across the EU.
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Comments on the options for the revision of the eco-label scheme
Published: 30/06/2006 - last updated: 09/11/2006
EuroCommerce is the business representation of the retail, international trade and wholesale sectors to the European Union. Overall, the Commerce sector represents the interface between the manufacturing sector and the 450 million consumers across Europe. Commerce is a large and dynamic sector in the European Union, representing 13% of the EU GDP, 5.5 million enterprises and providing jobs to over 27 million people from all parts of Society.
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Proposal for a Directive on ambient air and cleaner air for Europe
Published: 06/04/2006 - last updated: 09/11/2006
EuroCommerce welcomes the initiative of the Commission to simplify existing legislation on air quality and to further improve the air quality in Europe. Air quality has already improved significantly over the last decade, and if more can be done more should be done. Further action should however be based on solid scientific evidence and should be proportionate to its economic costs.
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EuroCommerce response to the Green Paper on Energy Efficiency
Published: 05/04/2006 - last updated: 09/11/2006
EuroCommerce welcomes the fact that the European Commission is launching the consultation process through the publication of the green paper on energy efficiency which we see as an opportunity to develop energy efficient policies while maintaining a competitive Europe. We see the consultation process as an important step for involving business in advancing the better regulation agenda in evolving policy areas. Not all the issues taken up in the green paper are relevant to wholesalers or retailers. We have therefore limited our response to the most important aspects for the commerce sector.
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Proposal for a Directive of the European Parliament and of the Council amending Directive 1999/62/EC on the charging of heavy goods vehicles for the use of certain infrastrucures (COM 2003, 448 FINAL) – Second reading
Published: 05/09/2005 - last updated: 09/11/2006
EuroCommerce is the business representation of the retail, international trade and wholesale sectors to the European Union. Overall, the Commerce sector represents the interface between the manufacturing sector and the 450 million consumers across Europe. Commerce is a large and dynamic sector in the European Union, representing 13% of the EU GDP, 5.5 million enterprises and providing jobs to over 27 million people from all parts of Society.
EuroCommerce welcomes the common position of the Council and wishes to give the following general key recommendations:
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Updating the energy labelling of the framework 92/75/EEC – discussion paper
Published: 20/12/2004 - last updated: 09/11/2006
EuroCommerce is the business representation of the retail, international trade and wholesale sectors to the European Union. Overall, the Commerce sector represents the interface between the manufacturing sector and the 450 million consumers across Europe. Commerce is a large and dynamic sector in the European Union, representing 13% of the EU GDP, 5.3 million enterprises and providing jobs to over 26 million people from all parts of Society.
EuroCommerce welcomes the consultation of the Commission on the revision of the Energy labelling scheme. We would like to answer the following specific questions.
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Environmental labels and EU Flower
Published: 14/04/2004 - last updated: 09/11/2006
EuroCommerce strongly encourages the national label organisations and the EU Eco-label to harmonise as much as possible their criteria to make the different schemes transparent to the consumers with the aim to have one single European label as we have one single market and one single currency.
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Eurocommerce comments on the mid-term review of the White Paper on Transport
Published: 01/11/2006 - last updated: 08/05/2007
Introduction
Transport is a major component of the EU economy. It generates 7% of the EU GDP and employs 5% of the population, which makes it an important contributor to the Lisbon strategy. Furthermore, transport is also a priority of the sustainable development strategy.
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