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Carbon removals, carbon farming and carbon storage - certification methodologies for permanent carbon removals

Climate action

The delegated regulation establishes methodologies to certify carbon removal activities storing permanently CO2 out of the atmosphere. It covers processes related to direct air carbon capture and storage (DACCS), biogenic carbon capture and storage (BioCCS) and biochar production. The methodologies set requirements to ensure that activity complies with the quality criteria set out in Articles 4 to 7 of Regulation 2024/3012 and provides the elements set out in Annex I of Regulation 2024/3012.

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Public consultation

ID: 14573

Lobbying Activity

63 responses

WWF Warns EU Carbon Removal Rules Enable Climate Greenwashing

WWF European Policy Programme, 22 Sept 2025

WWF demands the Commission redesign BECCS and biochar methodologies to require full lifecycle assessments or restrict eligibility to fast-decaying wastes with no other uses. They want stricter reporting requirements on biomass feedstocks consistent with existing EU regulations.
This would prevent certification of activities that WWF believes actually increase emissions.
Bioenergy operators lose access to carbon removal credits for forest biomass feedstocks.

Climate Action Network Europe urges rejection of carbon removal certification rules

Climate Action Network Europe, 22 Sept 2025

The organization urges the Commission to reject the Delegated Act, arguing it fails legal requirements and lacks scientific integrity. They demand stronger sustainability provisions, bans on harmful biomass sources, and strict additionality criteria to prevent bogus credits.
This would preserve their credibility on climate policy and prevent regulatory legitimization of practices they oppose.
The biomass and carbon capture industries lose access to certification and credits for their projects.

BirdLife urges Commission to reject biomass carbon removal methodologies

Stichting BirdLife Europe, 22 Sept 2025

BirdLife urges the Commission not to adopt the BioCCS and biochar methodologies in their current form. They argue the methodologies rely on faulty sustainability criteria, fail to account for land sector impacts, and dismiss legal requirements in the CRCF regulation.
This would prevent methodologies that could increase emissions and harm ecosystems BirdLife works to protect.
Forests and ecosystems lose protection as increased biomass harvesting drives further degradation of carbon sinks.

Consultation response

Fern, 22 Sept 2025

We thank the European Commissions DG CLIMA for this additional opportunity to express our concerns about the draft Delegated Act for certifying permanent carbon removals, in particular the methodologies for BioCCS and Biochar. As stated many times within the Expert Group and in subsequent meetings…

Austrian Industry Urges EU To Certify Cement Recarbonation

Wirtschaftskammer Österreich, 10 Sept 2025

The Chamber urges the EU to recognize cement recarbonation as a permanent carbon removal pathway. They also demand that these removals be tradable as allowances within the EU carbon market. Additionally, they seek simplified verification rules to reduce administrative burdens.
This would lower decarbonization costs for energy-intensive sectors and reduce administrative expenses.

ENGIE urges swift adoption of EU carbon removal certification framework

ENGIE, 22 Sept 2025

ENGIE calls for swift adoption of the delegated act and remaining secondary legislation to enable first certifications. They request recognition of CO₂ midstreamers' role, extension of storage eligibility to UK sites, and alignment with RED certification to reduce administrative burden.
This would provide legal certainty for their €10 billion annual energy transition investments and enable their midstreamer business model.

Ørsted urges flexibility in EU carbon removal certification rules

Ørsted A/S, 22 Sept 2025

The organization requests flexible monitoring requirements that allow design optimization until operation starts, quarterly or monthly credit issuance with annual audits instead of audits at each certification, and alignment of biomass sustainability rules with existing RED requirements. They argue current narrow technical requirements risk locking projects into suboptimal designs years before operation.
This would reduce compliance costs and enable faster cash flow for their capital-intensive BioCCS projects.

French Industry Demands Carbon Credit Flexibility for ETS Compliance

Association Française des Entreprises Privées / French Association of Large Companies, 22 Sept 2025

The organization requests that certified carbon removal credits be usable for EU ETS compliance without restriction to residual emissions. They demand consistency across EU climate regulations and alignment with international standards before detailed regulations proceed.
This would give their members immediate flexibility to meet emissions targets using removal credits.

Cepi urges simplified rules and longer timelines for BioCCS

Confederation of European Paper Industries, 22 Sept 2025

Cepi requests aligning biomass sustainability criteria with existing rules to avoid redundant reporting obligations. They propose extending activity periods to match a facility's technical lifespan for better investment certainty. Additionally, they call for simplified emissions calculations by excluding complex parameters like construction costs.
Longer certification periods would reduce administrative burdens and provide long-term investment security.
Carbon farming projects would lose financial support if the voluntary compensation requirements are deleted.

German Energy Industry Urges Extended Project Periods for Carbon Removal

BDEW Bundesverband der Energie- und Wasserwirtschaft e. V., 22 Sept 2025

The organization requests extending the activity period from 10 to 20 years and eliminating capital stock emissions from calculations. They seek differentiated approaches for electricity emission factors and simplified requirements for biomass-based carbon removal technologies.
This would reduce compliance costs and align certification cycles with financing structures.

Oil and Gas Producers Seek Lighter Monitoring for Carbon Storage

International Association of Oil Gas Producers Europe, 22 Sept 2025

The organisation requests less strict monitoring requirements for storage sites, grandfathering of electricity rules for early projects, and clearer definitions of biogenic CO2. They argue current monitoring obligations are unnecessary and create barriers to investment.
This would reduce their compliance costs and provide investment certainty for early carbon capture projects.
Environmental groups lose stronger safeguards against carbon leakage from storage sites and weaker permanence guarantees.

RWE urges flexible BioCCS rules to accelerate carbon removal

RWE AG, 22 Sept 2025

RWE requests extending activity periods from 10 to 15 years to align with financing structures. They want simplified electricity verification rules and transitional incentives for capturing fossil CO2 from mixed waste sources. They seek to replace 'nameplate biomass consumption' with 'nameplate power production' to avoid locking facilities into current fuel sources.
This would improve bankability of their BECCUS projects capturing 11-14 Mt CO₂ annually at Dutch plants.

Equinor Urges EU to Align Carbon Removal Framework with Market Realities

Equinor ASA, 22 Sept 2025

Equinor requests extending activity periods to match installation lifetimes, revising the economic viability test to focus on feedstock sustainability rather than profitability, and clarifying eligibility for cross-border storage providers. They argue current timelines and restrictions risk excluding viable projects and fragmenting the market.
This would reduce regulatory uncertainty for Equinor's CCS investments across Europe and enable use of their Norwegian storage infrastructure.

Gas industry seeks 20-year certification period for carbon removal projects

EUROGAS, 19 Sept 2025

Eurogas requests extending carbon removal certification from 10 to 20 years, expanding biochar definitions to include biomethane pyrolysis, and integrating certified removals into EU emissions trading. They argue current timelines create financing mismatches and discourage investment.
This would align certification periods with their 15-year subsidy schemes and financing structures.

Cement industry seeks clarity on biogenic CO2 capture under carbon removal rules

CEMBUREAU - The European Cement Association, 22 Sept 2025

The association requests clearer definitions for capture facilities to include industrial installations under the EU ETS. They want clarification on biomass supplier emissions accountability and recognition that biogenic CO2 from industrial processes should count toward carbon removal credits.
This would allow cement plants capturing biogenic CO2 to qualify for carbon removal certification and credits.

Swedish Forest Industries urges longer timelines for bio-CCS certification

Swedish Forest Industries Federation, 22 Sept 2025

The organization requests extending activity periods to at least 20 years and eliminating compensation requirements. They argue short timelines prevent large industrial investments and that LCA methodology creates problematic double counting with ETS.
Longer timelines would enable major industrial investments with decades-long technical and economic lifespans.

European Ceramic Industry Seeks Biochar Eligibility for Ceramic Products

European Ceramic Industry Association, 18 Sept 2025

The association requests that carbon removal certification be extended to include biochar incorporated into ceramic products like filled clay blocks, not just construction materials.
This would allow ceramic manufacturers to certify carbon removal activities and benefit from the certification scheme.

SUEZ calls for pragmatic biochar rules and BECCS clarity

SUEZ Group, 22 Sept 2025

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.
This would enable SUEZ to commercialize biochar for climate adaptation and monetize its multiple soil benefits.

European Biogas Association urges simpler carbon removal certification for biogenic CO₂

European Biogas Association, 19 Sept 2025

The association requests explicit recognition of biogas and biomethane in the definition of biogenic CO₂. They oppose the introduction of Do No Significant Harm principles, warning these would create over-complication with little environmental benefit. They demand full alignment with existing renewable energy rules without introducing new requirements or accounting methodologies.
This would reduce regulatory complexity and compliance costs while enabling growth of their sector.

Consultation response

Carbon Market Watch, 22 Sept 2025

Carbon Market Watch urges the Commission to not adopt the Delegated Act (DA) in its current form. While the text has improved since earlier versions (e.g. toxicity safeguards for biochar), more work is still needed. Several key political questions must be answered scientifically. Don't rush the…

Zero Waste Europe urges strict limits on waste incineration BioCCS

Zero Waste Europe, 23 Jul 2025

The group demands the exclusion of waste incinerators from certification unless they implement full separate collection systems for recyclables. They claim that certifying carbon from unsorted waste undermines the circular economy and ignores the waste hierarchy.
Restricting these certifications prevents incineration from becoming more cost-competitive than recycling and reuse.
Incineration facilities would lose potential public funding and certification for their existing waste processing.

Snam calls for simplified CO2 transport certification rules

Snam S.p.A., 22 Sept 2025

The company requests that CO2 network operators define transport segments and calculate emissions values centrally, rather than requiring individual projects to coordinate. They seek clear objective criteria instead of vague cost-based rules, and standardized emission factors for transport components.
This would reduce administrative burden and coordination requirements for their Ravenna CCS hub and CO2Vault infrastructure projects.
Environmental integrity suffers if standardized factors replace site-specific measurement of actual emissions.

Bioenergy Europe seeks flexibility in carbon removal certification rules

Bioenergy Europe, 22 Sept 2025

The organization requests alignment with existing renewable energy rules, flexibility in biomass feedstock choices for biochar projects, and removal of economic viability tests for new facilities. They argue current requirements create unnecessary barriers and inconsistencies with established sustainability frameworks.
This would reduce regulatory barriers and enable larger-scale deployment of bioenergy carbon removal projects.

Clean Air Task Force urges stricter carbon removal certification

Clean Air Task Force, Inc., 22 Sept 2025

CATF calls for regular baseline updates and a review clause to prevent over-crediting. They urge stricter liability for biochar and annual electricity matching for early air capture projects.
Stricter integrity rules protect the group's reputation and ensure real climate progress.
Biochar producers lose out due to proposed credit discounts and stricter liability.

Wiener Stadtwerke challenges EU limits on mixed CO2 stream accounting

WIENER STADTWERKE GmbH, 16 Sept 2025

The organization requests that biogenic CO2 from mixed streams be treated separately through mass balance accounting, similar to renewable gas networks. They argue the current requirement to maintain biogenic/fossil ratios prevents full decarbonization and blocks viable business models.
This would enable flexible business models and higher revenues from carbon removal compared to ETS prices.
Chemical industry loses access to 40 million tons of biogenic CO2 needed for decarbonization.

IAG Urges EU to Expand Carbon Removal Certification Scope

International Consolidated Airlines Group, 22 Sept 2025

IAG recommends broadening the scope of eligible applications to support investment in durable removals. They suggest using statistical sampling for continuous production monitoring instead of batch processing. The group also wants policy rewards for carbon capture integrated into fuel production.
Recognizing these removals helps the airline group meet its net-zero goals.

Uniper Urges Longer Certification for Carbon Removal Projects

Uniper, 19 Sept 2025

Uniper recommends that the activity period "should be extended" to "at 20 years" to "reflect operational and financing realities". They also argue "fuel switching at existing facilities" should "not face additional burdens" or complexities.
Longer certification periods and simplified biomass transition rules would "encourage investment" and "improve the bankability of projects".
Environmental groups lose safeguards against "unsustainable demand for biomass" if retrofitting rules for existing facilities are relaxed.

Norsk Hydro urges fast-tracked carbon removal credits for EU ETS compliance

Norsk Hydro, 22 Sept 2025

Hydro requests that certified permanent carbon removals be eligible for EU ETS compliance from 2028, not 2031. They want eligibility broadened to all ETS installations without volume restrictions, and call for public funding to cover both capital and operating costs for high-cost removal technologies.
This would provide compliance flexibility for residual aluminium emissions and help prevent further industrial closures.
Environmental groups lose stricter emissions reduction requirements as industry gains flexibility through carbon removal offsets.

Consultation response

Carbon Gap ASBL, 22 Sept 2025

Carbon Gap welcomes DG CLIMA continued engagement in building the policy mix CDR requires to grow, and the opportunity to provide feedback on the delegated acts of the Carbon Removal and Carbon Farming (CRCF) regulation. Carbon Gap supports the design of a robust CRCF as a trusted basis for a…

VTT urges including mineralisation in carbon removal rules

VTT Technical Research Centre of Finland Ltd, 22 Sept 2025

VTT calls for including permanent CO2 mineralisation in the certification scope. They also advocate for simplified energy emission definitions and removing biochar feedstock criteria.
Broadening the scope and simplifying rules would reduce monitoring costs and encourage investment.
Innovative biochar producers using slow pyrolysis face unequal treatment under current feedstock restrictions.

Waste industry urges broader carbon removal certification scope

FEAD, 22 Sept 2025

The organization requests expanded certification methodologies beyond geological storage to include biogenic emissions captured and stored in long-lasting products. They demand clearer sustainability requirements, arguing the current linkage to Taxonomy Regulation creates unworkable interpretation challenges for waste-to-energy operators.
This would allow waste-to-energy facilities to participate in carbon removal certification markets.

CCSA urges longer certification cycles to ensure project bankability

Carbon Capture & Storage Association, 22 Sept 2025

The association recommends extending the activity period from 10 to 15 years to align with investment cycles. They also seek to ensure emitters can benefit from certification and ask for more flexible electricity sourcing rules.
Longer cycles and flexible rules improve project bankability and lower costs for early-stage technologies.
Wood-based industries lose protection if the cascading principle for sustainable biomass usage is removed.

Green Transition Denmark slams 'overstated' carbon removal certification rules

Rådet for Grøn Omstilling, 22 Sept 2025

The organization demands that methodologies reflect the time-lag between storage and actual carbon removal. They reject current drafts that credit avoided emissions from biowaste decay as immediate removals.
Stricter rules protect the credibility of the climate policies the organization supports.
Technology developers would receive significantly fewer credits for immediate sale to finance operations.

Negative Emissions Platform urges longer certification for carbon removals

Negative Emissions Platform, 22 Sept 2025

NEP recommends extending the activity period to 15 years to align with financing. They also call for allowing storage providers to trigger credit issuance.
These changes would improve project bankability and provide greater regulatory certainty for developers.
Traditional biomass users could face supply distortions if strict economic viability tests are removed.

Drax Group urges flexible rules for bioenergy carbon removal projects

Drax Group plc, 22 Sept 2025

Drax requests extending the activity period to 15 years for better commercial certainty. They also urge the removal of economic viability tests for new carbon capture facilities. The group recommends excluding rules that prioritize wood use for materials over energy production.
These adjustments would provide the long-term certainty needed to unlock investments in large-scale projects.
Forest ecosystems may face increased pressure if cascading wood use rules are not applied.

CEWEP urges inclusion of Waste-to-Energy in carbon removal certification

Confederation of European Waste-to-Energy Plants, 22 Sept 2025

The organization wants Waste-to-Energy recognized as a provider of permanent carbon removals. They argue biogenic CO2 capture can result in net negative emissions and credits.
This would enable waste plants to generate valuable credits and reach net-negative emissions.

Vantaan Energia urges carbon credits for waste-to-energy plants

Vantaan Energia, 9 Sept 2025

Vantaan Energia supports robust certification standards to guarantee carbon credit integrity. They advocate for including municipal waste incineration in the emissions trading system. Captured biogenic carbon should generate credits to reduce compliance obligations.
The company would benefit from new revenue streams to finance its carbon capture technology.
Environmental groups lose if credits allow other polluters to avoid direct emission cuts.

Consultation response

voestalpine AG, 22 Sept 2025

Thank you very much for the opportunity to comment. Please find attached our comments and suggestions on the present draft.

Consultation response

GE Vernova, 19 Sept 2025

GE Vernova's position on the Carbon removals and carbon farming methodologies for certifying permanent carbon removals We support the Commissions initiative to create a Union certification framework for carbon removals. To ensure credibility, transparency, and investment confidence, we recommend…

Consultation response

Ragn Sells AS, 25 Jul 2025

Incentivise innovations that store carbon in materials Ragn-Sells welcomes the Commissions strong commitment to phasing out fossil fuel activities in the EU. Along with this, we also see the commitment from the Commission to create necessary carbon sinks by hiding away as much carbon dioxide as…

US wood pellet industry urges alignment with existing energy rules

US Industrial Pellet Association, 22 Sept 2025

USIPA recommends removing cascading principle and industrial-grade roundwood restrictions to ensure consistency across EU legislation. They also propose replacing the narrow economic viability test for new projects with strategic decarbonization assessments.
These amendments would lower administrative costs and protect market access for US biomass producers.
Traditional timber industries lose priority access to wood feedstock if cascading principles are removed.

Wood panel industry urges EU to protect timber from combustion

European Panel Federation, 21 Sept 2025

EPF strongly recommends that paragraph 4.3.3 be deleted to prevent incentivising the burning of high-value woody biomass. They request that certification methodologies prioritise material-first applications of biomass into long-lived harvested wood products.
This would protect their raw material supply from being diverted to energy generation.
BioCCS and biochar projects would lose the option to use high-quality saw logs.

CCU Industry Urges Swift Recognition of Mineralisation Carbon Removals

CO2 Value Europe AISBL, 22 Sept 2025

The organization requests swift adoption of rules recognizing mineralisation technologies using biogenic or DAC CO2 as carbon removals. They want harmonised definitions for DAC CO2 and biogenic CO2 across EU legislations, enabling CCU and CCS technologies to be deployed together. They urge avoiding replication of unworkable legal precedents from RFNBO rules.
This would enable their members to access carbon removal certification for mineralisation projects storing atmospheric CO2.
Joint CCU/CCS projects face additional hurdles from rules treating storage and utilisation separately.

PFPI slams weak EU certification rules for carbon removals

Partnership for Policy Integrity, 22 Sept 2025

They want a clear distinction between removing carbon and just storing it. The group also calls for stricter environmental safeguards and more accurate baseline measurements that include forest loss.
Stricter rules would prevent the incentivization of activities that cause environmental harm.
Bioenergy firms lose the ability to certify projects that may harm biodiversity.

Consultation response

European Biochar Industry Consortium, 22 Sept 2025

We appreciate the efforts and thank the commission for this thorough work over the last years. Please find our feedback attacked

EREF urges longer certification periods for permanent carbon removals

European Renewable Energies Federation asbl, 22 Sept 2025

EREF requests extending the certification period to thirty years to ensure investment bankability. They seek priority for BioCCS and alignment with existing renewable energy sustainability criteria.
This would reduce administrative burdens and provide the predictability required for long-term project financing.
Fossil fuel operators would be denied incentives to prevent extending the life of polluting plants.

Woodworking industry urges removal of saw logs from carbon rules

European Confederation of Woodworking Industries, 22 Sept 2025

CEI-Bois demands removing rules that allow saw logs to be burned for carbon credits. They argue this diverts quality feedstock away from better solutions like physical wood products. The industry also calls for tighter implementation to prevent carbon leakage from biochar.
This would ensure wood processing companies maintain access to affordable timber supplies.
Bioenergy firms lose the ability to use high-quality timber for carbon credits.

Lime industry urges EU to credit carbon-absorbing materials

European Lime Association, 22 Sept 2025

EuLA requests that the EU recognize enhanced carbonation of lime products as a carbon removal pathway. They also want biogenic carbon capture integrated into compliance regimes rather than voluntary markets.
This would prevent the overestimation of the industry's net emissions and unlock new investments.
Alternative material producers may lose their competitive advantage if lime receives these carbon credits.

Consultation response

International Emissions Trading Association, 22 Sept 2025

Representing over 320 companies operating across carbon market ecosystems globally, IETA welcomes the opportunity to respond to the European Commissions consultation on the draft delegated regulation establishing methodologies for certifying permanent carbon removals under the EU Carbon Removals…

Finnish Bioenergy Association Opposes Biochar Feedstock Restrictions in EU Carbon Removal Rules

Bioenergia ry - Bioenergy Association of Finland, 22 Sept 2025

The association requests removal of restrictions limiting biochar projects to waste feedstocks when biochar is the primary product. They argue such restrictions lack scientific justification and would marginalize biochar production. They also call for alignment with the Renewable Energy Directive and clarification that cascading principles apply only when subsidies are granted for energy production.
This would expand eligible biomass sources for their biochar members and reduce regulatory burdens.
Environmental groups lose stricter safeguards against diverting wood from material uses to carbon removal.

Consultation response

Carbon Engineering ULC, 22 Sept 2025

On behalf of a group of global Direct Air Capture (DAC) leaders who share the EU Commissions goals of advancing robust, transparent, and efficient certification processes that facilitate investment in our innovative carbon removal technologies, we are pleased to provide feedback on the draft…

Consultation response

ISCC System GmbH, 22 Sept 2025

ISCC (International Sustainability and Carbon Certification) welcomes the opportunity to provide feedback on the European Commissions draft Delegating Regulation on Methodologies for Certifying Permanent Carbon Removals under the new EU Carbon Removals and Carbon Farming Regulation (CRCF). ISCC is…

Consultation response

MVV Energie AG, 10 Sept 2025

Wir reichen eine ausführliche Stellungnahme der MVV Energie AG zur Initiative über die Methoden zur Zertifizierung von CO2-Entnahmetätigkeiten, bei denen CO2 aus der Atmosphäre abgeschieden und dauerhaft gespeichert wird, über das angefügte PDF-Dokument ein.

Consultation response

Puro.earth, 22 Sept 2025

We welcome the publication of draft methodologies, which can support the scaling up of removal activities in the EU and eventually integrate them into the EU ETS. We applaud the Expert group in selecting the first methodologies to cover biochar, BioCCS and DACCS activities. Puro.earth has published…

Consultation response

Bundesverband Bioenergie e.V., 22 Sept 2025

The CO2 removal methods biochar and BioCCS (also known as BECCS) make an important contribution to European climate neutrality. They remove CO2 from the atmosphere and enable the long-term storage of CO2 and its use in value chains. When implementing these methods, it is important to consider the…

Consultation response

Climeworks, 22 Sept 2025

Please find attached Climeworks response to the public consultation on "Carbon removals and carbon farming - methodologies for certifying permanent carbon removals". We would like to thank the Commission for all of your efforts in developing this important piece of regulation for the Carbon Dioxide…

Consultation response

Stockholm Exergi, 19 Sept 2025

Stockholm Exergi strongly welcomes the CRCF and its implementation in the Commission Delegated Regulation, with its detailed implementation in the acts Annex. We limit our comments to BioCCS, where we deem the Annex to provide a robust and promising basis for a standardized approach to permanent…

Consultation response

St1 Nordic Oy, 22 Sept 2025

On Biogenic Emissions Carbon Capture and Storage Bio-CCS: 1) To support development of new DACCS and Bio-CCS initiatives, we propose widening the coverage of the methodology from geological storage to permanent non-geological storage, including injection and mineralization to concrete and cement.…

Consultation response

Hauptverband der Deutschen Holzindustrie und Kunststoffe verarbeitenden Industrie und verwandter Industrie- und Wirtschaftszweige, 22 Sept 2025

Der Hauptverband der Deutschen Holzindustrie und Kunststoffe verarbeitenden Industrie und verwandter Industrie- und Wirtschaftszweige e.V. (HDH) begrüßt die Schaffung eines verlässlichen Rahmens für Carbon-Removal-Maßnahmen durch den CRCF, warnt jedoch vor Regelungen, die die Kaskadennutzung von…

Consultation response

Carbo Culture Oy, 22 Sept 2025

Please find Carbo Culture Oy's feedback to the public consultation attached. Kind regards, Hanna Ojanen

Consultation response

European Renewable Gas Registry, 22 Sept 2025

ERGaR welcomes the opportunity to comment on the draft Delegated Act (DA) and highlights several improvements needed to ensure clarity, consistency, and feasibility for operators of biogenic CO capture and permanent carbon removal projects. First, ERGaR stresses the importance of enabling biogenic…

Consultation response

Fertő tó Barátai Egyesület, 22 Sept 2025

The Friends of Fertő Lake Association is glad to provide its input into this public consultation. First of all, the European Commission and the Council should recognise that the intertwined biodiversity and climate crises require a coordinated response. The current proposal of the Delegated Act…

Consultation response

, 22 Sept 2025

Vielen Dank für die Möglichkeit einer Rückmeldung, anbei übermitteln wir unsere Stellungnahme.