Lobbying on Roadmap towards Nature Credits

Roadmap towards Nature Credits

Environment

Links

Public consultation

ID: 14723

Lobbying Activity

102 responses

Environmental groups warn nature credits risk commodifying ecosystems

European Environmental Bureau, 30 Sept 2025

The organization demands nature credits never replace public funding, legal enforcement, or subsidy phase-outs. They require credits to be non-tradable, locally-scoped, and subject to strict environmental and social safeguards. The next EU budget must earmark at least 10% for biodiversity with 50% total climate spending.

This would ensure biodiversity protection relies on public resources rather than market mechanisms.

Private investors and large landowners lose opportunities for speculative trading and disproportionate financial gains.

WWF: Nature Credits Must Complement Not Replace Public Funding

WWF European Policy Programme, 26 Sept 2025

WWF insists nature credits must complement public funding and not be used for offsetting. They call for mandatory EU regulation to ensure integrity and scale up funding.

A formal framework would steer more private investment toward the conservation goals WWF supports.

Sectors receiving harmful subsidies, like bioenergy, would face significant loss of EU funding.

German Industry Demands Voluntary Nature Credits to Protect Competitiveness

Bundesverband der Deutschen Industrie e.V., 30 Sept 2025

The organisation insists nature credits must remain voluntary for businesses, not mandatory. They want recognition in regulatory frameworks and life cycle assessments. The system must align with existing German compensation regulations and avoid restricting land availability.

This would protect their international competitiveness and preserve land access for industrial activities.

Environmental advocates lose stronger mandatory biodiversity protections and dedicated conservation land.

Chemical Industry Council Urges Voluntary Approach to Nature Credits

European Chemical Industry Council, 30 Sept 2025

The organization requests that nature credits remain voluntary rather than mandatory, with clear guidelines that support existing company biodiversity work. They emphasize developing the approach in a pragmatic, practical, science-based way without creating additional requirements. The industry wants recognition of existing initiatives and better integration with current reporting frameworks.

This would avoid new compliance burdens while allowing them flexibility in biodiversity efforts.

Environmental groups lose stronger mandatory biodiversity protections and standardized accountability measures.

European Farmers Warn Nature Credits Risk Undermining Food Production

European farmers, 30 Sept 2025

The organization demands the Commission slow down and clarify fundamental questions before legislating. They want nature credits designed as complementary income, not replacement for productive land use. A dedicated Nature Restoration Fund outside CAP is essential to meet €11-12 billion annual costs.

This would protect their productive land use while accessing new income streams.

Environmental groups lose stricter requirements if productive farming remains compatible with credits.

ClientEarth urges strict safeguards for EU nature credits market

ClientEarth AISBL, 29 Sept 2025

ClientEarth requests that the EU prioritize scaling up public biodiversity funding, redirect harmful subsidies, and exclude offsetting from any nature credits market. They argue credits must be outcome-based and issued only after concrete biodiversity results are delivered, not for business-as-usual practices.

This would ensure credits genuinely close the biodiversity financing gap rather than rewarding existing practices.

Businesses seeking credits for compliance activities or existing management practices would lose eligibility.

Animal welfare group warns against rewarding industrial farms with nature credits

Eurogroup for Animals, 29 Sept 2025

The organization requests strict criteria preventing industrial farms from receiving credits and limiting beneficiaries to those solely dedicated to conservation. They demand independent audits and public data to ensure beneficiaries don't undertake harmful activities. Only net positive actions beyond legal obligations should qualify, not mere maintenance of biodiversity.

This would prevent nature credits from subsidizing the industrial agriculture sector they oppose.

Industrial farms lose potential revenue from nature credits despite their environmental impact.

Finnish Forest Industries urge strict rules for Nature Credits

Finnish Forest Industries Federation (Metsäteollisuus ry), 29 Sept 2025

The federation demands that nature credit trading only occur after companies have minimized their own biodiversity harm. They want clear additionality criteria targeting valuable protected sites with proper monitoring.

This would protect their forest operations from competing biodiversity offset demands.

Companies seeking cheaper biodiversity offsets lose flexible market access to credits.

Finnish Farmers Urge Voluntary Nature Credit Market Without EU Legislation

Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners, 30 Sept 2025

MTK requests that nature credit markets remain voluntary without mandatory EU legislation or harmonization. They emphasize agricultural producers and forest owners must participate in all development stages and pilot testing. The system must allow nature credits alongside profitable food and timber production.

This would preserve their flexibility to pursue diverse income streams and management approaches.

Biodiversity advocates lose stronger standardization and mandatory requirements for nature protection.

Bayer urges EU to align nature credits with carbon farming framework

Bayer AG, 26 Sept 2025

Bayer requests integration of nature credits into existing frameworks like the Carbon Removal Certification Framework and the planned agricultural sustainability compass. They advocate for outcome-based certification covering multiple nature outcomes including endangered species, habitats, and ecosystem services, with flexibility through different credit types and quality tiers.

This would create business opportunities for their carbon and regenerative agricultural services division.

Environmental groups lose if nature credits allow offsetting rather than requiring direct biodiversity improvements.

EDF urges EU to prioritize ecosystem functionality over historical conservation

ELECTRICITE DE FRANCE, 26 Sept 2025

EDF requests that nature credits focus on preserving ecosystem functions rather than just species conservation. They want credit dimensioning based on restoration measures implemented, not on achieved nature states. The company seeks ex-ante credit recognition and clarification on integrating credits into corporate sustainability strategies.

This would reduce their exposure to risks and strengthen resilience against ecosystem dependencies.

French Banking Federation calls for nature credit market framework

Fédération bancaire française, 30 Sept 2025

The Federation requests clear measurement standards, a secondary market with traceability, and supply visibility for banking risk assessment. They emphasize the need for harmonized accounting rules and governance involving all stakeholders.

This would allow banks to integrate nature credits into portfolios while managing financial risks.

German Auto Industry Urges Voluntary Nature Credits Without New Obligations

Verband der Automobilindustrie, 30 Sept 2025

The industry requests that nature credits remain strictly voluntary without additional obligations. They seek recognition of credits in existing regulations like the EU Taxonomy and life cycle assessments. They want small plots to be certifiable and clear guidelines on measurement and monitoring.

This would allow offsetting biodiversity impacts without mandatory compliance costs or competitive disadvantages.

Environmental groups lose mandatory protections as voluntary credits could replace stronger regulatory requirements.

BirdLife Europe calls for high-integrity nature credits to complement public funding

Stichting BirdLife Europe, 30 Sept 2025

The organization requests nature credits be closely linked to the Nature Restoration Law, ruled out from offsetting schemes, and started slowly with strong regulatory frameworks. They emphasize credits should complement rather than replace public investment.

This would ensure nature credits fund genuine restoration while protecting their core advocacy positions on nature law implementation.

Companies seeking to use credits for greenwashing or offsetting biodiversity impacts lose flexibility.

Consultation response

Friends of the Earth Europe, 30 Sept 2025

Friends of the Earth Europe sees the European Commissions plan for nature credits as a dangerous distraction from the urgent tasks of phasing out harmful subsidies and establishing strong regulation. Instead of addressing the root causes of biodiversity loss, this proposal risks prioritising…

Food Industry Urges Science-Based EU Nature Credit Framework

FoodDrinkEurope, 26 Sept 2025

The organization requests a comprehensive framework that incentivizes nature-positive impact while ensuring competitiveness. They want nature credits combined with carbon credits, recognition of corporate contributions, and initial focus on EU markets before international alignment.

This would secure resilient agricultural supply chains and long-term productivity for their sector.

Speculative buyers without supply chain ties could distort markets and divert land from food production.

Austrian Business Chamber Rejects EU Nature Credits as Economically Unviable

Wirtschaftskammer Österreich, 29 Sept 2025

The organization demands that Nature Credits should only advance once legal clarity, binding certification, simple digital tools, and tangible economic benefits are established. They reject forest set-asides that would jeopardize wood-based value chains.

This would protect 500,000 Austrian businesses from costly compliance burdens without economic returns.

Environmental advocates lose potential private funding streams for biodiversity conservation and restoration projects.

French business group backs EU nature credit framework with conditions

Association Française des Entreprises Privées / French Association of Large Companies, 30 Sept 2025

The association requests clear separation between project developers, certifiers and registries. They emphasize nature credits must remain voluntary and complementary to national compensation schemes, with harmonized baselines across Member States.

This would reduce regulatory uncertainty and compliance costs for member companies investing in nature projects.

Paper Industry Warns Nature Credits Could Threaten Wood Supply

Confederation of European Paper Industries, 26 Sept 2025

The industry requests that nature credits remain voluntary, focus on results rather than prescriptive methods, and avoid taking land out of production. They emphasize the need to prevent wood supply shortages and ensure all sustainable forest management practices qualify for credits.

This would protect their access to European wood supply and prevent production restrictions.

Environmental groups lose stronger biodiversity protections as credits enable continued harmful practices elsewhere.

Organic farming groups urge recognition in EU nature credits scheme

International Federation of Organic Agriculture Movements EU Regional Group, 30 Sept 2025

The organization requests that organic certification be recognized as evidence of biodiversity delivery in nature credit schemes. They emphasize that organic farming already provides proven biodiversity benefits and should not require additional verification beyond existing EU certification.

This would allow organic farmers to access nature credit payments without duplicating existing certification requirements.

Conventional farmers who haven't adopted biodiversity practices lose competitive advantage if first-movers aren't rewarded.

Spirits industry backs EU nature credits to reward farm biodiversity

spiritsEUROPE, 29 Sept 2025

The organization requests nature credits reward demonstrable positive actions that protect and restore nature, not offset damage elsewhere. They want a single EU market with clear boundaries, flexibility for local contexts, and standards applied to imports with robust safeguards.

This would provide farmers additional income while offering companies verifiable sustainability investments across supply chains.

Equinor recommends integrating nature credits with carbon markets

Equinor ASA, 30 Sept 2025

Equinor recommends building on the existing Carbon Removals and Carbon Farming Regulation framework. They suggest a single registry for both credits to maximize project development efficiency. They also request including offshore industry representatives within the relevant expert group.

A unified system would reduce administrative complexity and streamline certification for energy developers.

CEMBUREAU warns nature credits roadmap lacks market clarity and timelines

CEMBUREAU - The European Cement Association, 30 Sept 2025

The cement industry requests clearer market guarantees and a more realistic timeline. They oppose mandatory credit requirements for projects already meeting environmental standards, arguing this would undermine the voluntary nature of the system.

This would prevent additional compliance costs for cement projects already meeting environmental requirements.

Swedish Forest Industries urges nature credits to support wood supply

Swedish Forest Industries Federation, 30 Sept 2025

The federation requests balanced stakeholder representation including forest actors, flexibility in implementation methods focused on outcomes rather than prescriptive practices, and voluntary participation without legislative mandates. They emphasize nature credits must maintain sustainable wood supply for the bioeconomy.

This would protect their wood supply and competitiveness while accessing new revenue from nature credits.

Climate mitigation loses as biodiversity-focused forestry reduces carbon sequestration and fossil replacement materials.

Bruegel Warns Markets Cannot Replace Public Funding For Nature

Bruegel, 11 Jul 2025

The Commission must establish consistent standards and outcome-based metrics while ensuring private finance only complements public funding. They urge the reallocation of nature-harming subsidies to close the biodiversity financing gap.

Clear EU standards would facilitate the adoption of Bruegel's proposed nature shares investment model.

Restoration efforts are harmed if governments use the prospect of private finance to cut budgets.

Swedish Farmers Urge Clear Market Incentives for Nature Credits

Lantbrukarnas Riksförbund, 29 Sept 2025

The organization requests that the EU establish a common framework ensuring transparency and traceability, while leaving methodology, pricing, and transaction terms to market actors. They emphasize that administrative requirements must be kept to a minimum and that nature credits must remain voluntary and compatible with active land management.

This would create new income opportunities while avoiding heavy administrative burdens on farmers.

Food producers and landowners lose if offsetting mechanisms drive up land prices or reduce agricultural land.

German Chemical Industry Urges Simplification of EU Nature Credit Plans

Verband der Chemischen Industrie e.V., 30 Sept 2025

The association requests that existing biodiversity regulations be improved and integrated before introducing new instruments. They call for feasibility and market analyses of the nature credit system, including certification systems and trading platforms. They emphasize the need for clear rules and definitions.

This would reduce bureaucratic burden and compliance costs for their member companies.

Carbon Market Watch Opposes EU Nature Credits Scheme

Carbon Market Watch, 30 Sept 2025

The organization urges the EU to reject voluntary nature credits in favor of binding regulation, phasing out harmful subsidies, and ensuring public funding guarantees nature-positive action. They demand categorical exclusion of offsetting from any scheme.

This would prevent greenwashing and ensure companies pay for environmental damage through enforceable rules.

Small farmers lose as only large landowners can afford implementation costs and benefit from certification.

Consultation response

Volvo Car Corporation AB, 12 Sept 2025

Volvo Cars welcomes the European Commissions initiative to develop a roadmap for nature credits and particularly values the recognition of the need for public seed funding and the linkage with the Nature Restoration Regulation, which together provide a strong foundation for fostering collaboration…

German conservation group backs EU nature credits with strict safeguards

Naturschutzbund Deutschland e.V., 26 Sept 2025

NABU supports EU nature credits as one financing tool among many, not a replacement for public investment. They urge strong regulation, mandatory standards, independent monitoring, and tight alignment with the Nature Restoration Law. Credits must deliver additional biodiversity benefits beyond legal requirements and never serve as offsets for ecological damage.

This positions them as constructive partners in EU policy development while ensuring environmental integrity.

Polluting industries lose flexibility to buy credits instead of reducing environmental harm directly.

Finnish Chemical Industry Seeks Clarity on Nature Credits Framework

Chemical Industry Federation of Finland (Kemianteollisuus ry), 30 Sept 2025

The organization requests clear objectives and science-based verification for the Nature Credits framework. They emphasize the need to clarify how Nature Credits relate to existing ISO standards, certification schemes, and sustainability platforms, questioning what added value credits would provide beyond current commitments.

This would reduce administrative burden and prevent duplicative reporting requirements across frameworks.

ECOS urges EU to ban nature offsetting and greenwashing

Environmental Coalition on Standards, 30 Sept 2025

ECOS demands a ban on nature offsetting and harmful subsidies. They argue credits should only implement the polluter-pays principle.

Strong regulation prevents market-driven deregulation and safeguards long-term public funding.

Companies lose the ability to use cheap offsets to justify destructive practices.

Consultation response

Veolia Environnement, 30 Sept 2025

Please find attached Veolia's contribution to the European Commission's consultation on the Roadmap towards Nature Credits. Our key recommendations are: 1° Establish a high-integrity, science-based EU system compatible with existing legislation, with clear eligibility criteria, ecosystem-specific…

Bankwatch urges EU to scrap nature credits plan as unproven distraction

CEE Bankwatch Network, 26 Sept 2025

The organization requests the Commission abandon nature credits and instead prioritize cutting harmful subsidies, improving public funds, enforcing environmental law, and raising revenue through taxes and user charges. They argue nature credits lack evidence of effectiveness and distract from proven solutions.

This would redirect Commission resources toward policies with proven track records for biodiversity.

Biodiversity loses as limited EU staff capacity gets diverted to experimental schemes instead of urgent protection needs.

Stora Enso Urges Flexible Voluntary EU Nature Credits

Stora Enso Oyj, 9 Jul 2025

The framework must support both biodiversity and bioeconomy goals without imposing restrictive management methods. Stora Enso requests a flexible, outcome-focused methodology that accommodates local specificities. They strongly argue that credits should reward positive actions rather than being used for offsetting damage.

This framework provides new funding while protecting the supply of renewable wood materials.

Polluting industries would be prevented from using nature credits to compensate for environmental degradation.

Finance Denmark urges swift action on nature credits regulatory framework

Finance Denmark, 30 Sept 2025

The organization requests speedy implementation of the proposed timeline and early development of regulatory clarity. They emphasize maintaining profitability in the framework and exploring blended finance mechanisms while avoiding excessive disclosure requirements.

This would provide their members clear market rules and profitable investment opportunities.

European Landowners urge market-based nature credits to reward conservation

European Landowners' Organization asbl, 30 Sept 2025

The organization requests recognition of landowners as primary partners with secure property rights in nature credit systems. They call for flexible, cost-effective verification methods and progressive credit issuance that rewards both new restoration and existing conservation. They warn against merging carbon and biodiversity frameworks.

This would enable landowners to monetize previously unvalued ecosystem services and access early financing for conservation efforts.

Silent biodiversity in non-iconic habitats risks being overlooked by market-driven credit systems.

Vienna utility backs EU nature credits with call for practical framework

WIENER STADTWERKE GmbH, 30 Sept 2025

The organization requests uniform EU-wide standards, clear certification, and simplified procedures that allow municipal utilities to participate. They want existing projects like ecological enhancements around solar installations to be eligible for credits, and urban biodiversity measures to be recognized alongside agricultural approaches.

This would enable them to monetize biodiversity work already underway at infrastructure sites.

Consultation response

SURFRIDER FOUNDATION EUROPE, 30 Sept 2025

Although blue carbon credits are not explicitly mentioned in the roadmap accompanying this public consultation, the text does explicitly reference the Ocean Pact released in June, which reflects the European Commissions intention to develop European blue carbon reserves and new business models for…

FNSEA seeks practice-based nature credits and earlier market launch

Fédération Nationale des Syndicats d'Exploitants Agricoles, 30 Sept 2025

The FNSEA requests nature credits based on implementing specific practices rather than results to ensure income security. They demand that nature and carbon credits remain distinct and stackable, with a market launch earlier than 2027.

This approach ensures stable income for farmers by decoupling payments from unpredictable climate-driven environmental outcomes.

Environmental goals may suffer if financial rewards are provided without guaranteeing measurable biodiversity improvements.

IUCN urges nature credits to complement public conservation funding

International Union for Conservation of Nature EU Representative Office, 8 Sept 2025

IUCN argues nature credits must supplement public funding rather than replace it. They demand a science-led framework based on the mitigation hierarchy to prevent greenwashing.

This strategy protects the primacy of public funding and IUCN's advisory role.

Ecosystems lose if credits become a loophole for avoiding strict environmental standards.

Caisse des Dépôts calls for distinct voluntary nature credit rules

CAISSE DES DEPOTS, 30 Sept 2025

The group demands a clear distinction between mandatory regulatory frameworks and voluntary financial instruments. They argue that the framework must combine simplicity for users with high integrity and robust calculation methodologies.

Standardized credits and clear asset classification would help the group attract more private investment for environmental projects.

Local ecosystems may suffer if the EU applies rigid carbon-style permanence standards to dynamic biodiversity environments.

Austrian farmers demand fair nature credits compensation and voluntary participation

Landwirtschaftskammer Österreich, 30 Sept 2025

The organization demands that nature credits must genuinely promote biodiversity while fairly compensating farmers' contributions. They require minimal bureaucracy, voluntary participation without indirect obligations through supply chains, and recognition of existing environmental efforts. Public funding must continue alongside any private market mechanisms.

This would ensure farmers receive compensation while avoiding new bureaucratic burdens and mandatory requirements.

Companies seeking nature credits face unclear incentives and potential difficulties establishing a viable market.

Finnish food industry urges voluntary and harmonized nature credits

Finnish Food and Drink Industries' Federation (Elintarviketeollisuusliitto ry), 27 Sept 2025

The federation demands a voluntary model based on harmonized definitions and indicators. They request public seed funding and pilot programs to test practical solutions. They also suggest merging carbon and nature markets to simplify the system.

Merging credit markets would reduce administrative costs and increase market attractiveness.

Non-expert stakeholders lose influence if policy-making remains restricted to select expert groups.

ICLEI Demands Urban Inclusion in EU Nature Credit Roadmap

ICLEI - Local Governments for Sustainability European Secretariat, 30 Sept 2025

The organization requests including urban nature projects in European certification systems. They argue that nature credits should only complement direct pollution cuts rather than replace them.

Cities would secure private funding to cool streets and improve local air quality.

Financial institutions lose the power to dictate projects based purely on potential profit.

IFAW urges strict safeguards for EU nature credit markets

International Fund for Animal Welfare, 29 Sept 2025

IFAW insists that nature credits must never be used for offsetting environmental damage caused by firms. They advocate for including wild animal contributions and animal welfare within project integrity standards.

These rules would protect the organization's mission by preventing the commodification of nature.

Corporations would lose the ability to use nature credits as a substitute for regulation.

The Nature Conservancy urges EU-wide rules for nature credits

THE NATURE CONSERVANCY IN EUROPE gemeinnützige GmbH, 29 Sept 2025

TNC requests a mandatory EU regulatory framework where nature credits supplement public funding rather than replace it. They insist credits should not be used for offsetting irreversible biodiversity loss.

A regulated market would direct private investment toward large-scale conservation and restoration.

Small landowners and municipalities might face high administrative and financial burdens.

Consultation response

EuroNatur - Stiftung Europäisches Naturerbe, 30 Sept 2025

EuroNatur welcomes the European Commissions consultation on the recently published Roadmap for Nature Credits. Facing natures rapid decline, it is of utmost importance that the EU fulfills its environmental obligations under the EU Biodiversity Strategy, particularly through the implementation of…

TIC Council Demands Independent Certification for New Nature Credits

TIC Council, 29 Sept 2025

TIC Council wants a system based on independent certification and harmonized methodologies. They urge maintaining on-site audits and alignment with current EU environmental laws.

TIC firms would gain a central role as verifiers, expanding their environmental services market.

Unregulated operators and greenwashers would be excluded from the nature credit market.

Austrian Labor Chamber rejects EU nature credits as neoliberal market solution

Bundesarbeitskammer Österreich, 23 Sept 2025

The organization opposes nature credits and calls for an EU Transformation Fund where polluting companies must contribute. They demand abolition of biodiversity-damaging subsidies and stronger legal protections for nature instead of market mechanisms.

This would avoid market-driven land price increases that raise their members' food costs.

Large landowners and financial firms lose opportunities for windfall profits from unused land.

Conservation International urges high-integrity standards for nature credits

Conservation International Europe, 30 Sept 2025

The organization calls for science-based nature credits that complement public funding. They demand that the framework safeguards Indigenous Peoples' rights and eliminates discrimination against nature-based carbon removals.

Formalized markets would increase investment confidence and distribute restoration costs through unitized credits.

Fossil fuel companies lose access to these specific markets due to strict eligibility exclusions.

EUSTAFOR seeks credit for existing sustainable state forest management

European State Forest Association, 26 Sept 2025

EUSTAFOR requests that the credit system rewards existing sustainable forest management instead of only new projects. They seek full inclusion for public forest owners and the integration of current certification standards.

Public forest managers would secure new revenue streams and avoid expensive, duplicative administrative requirements.

Global biodiversity risks harm if reduced logging in credited areas causes increased extraction elsewhere.

WCS EU urges nature credits to fund conservation, not trading

Wildlife Conservation Society European Union office, 30 Sept 2025

The group opposes credit trading, suggesting funds instead support Natura 2000 sites and international conservation. They demand credits only supplement public funding and utilize metrics based on ecological integrity.

Standardized nature credits would boost funding for the organization's global biodiversity and restoration initiatives.

Commercial traders lose the ability to exchange credits as the group rejects their fungibility.

Consultation response

Irish Creamery Milk Suppliers Association, 30 Sept 2025

The Irish Creamery Milk Suppliers Association (ICMSA) represents all Irish farmersparticularly dairy and livestock farmers and we place a special emphasis on preserving the family farm structure and defending the rights and incomes of farm families. We were formed in 195) and have spent the last 75…

Finnish Association for Nature Conservation demands safeguards for credits

Suomen luonnonsuojeluliitto - The Finnish Association for Nature Conservation, 30 Sept 2025

They insist that nature credits must not delay local or global biodiversity action. They demand implementation of the mitigation hierarchy and the removal of harmful subsidies.

This ensures that public funding remains a priority and environmental standards are maintained.

Industries benefiting from harmful subsidies would lose significant financial support and regulatory leeway.

German Technical Inspection Body Calls for Independent Certification of Nature Credits

TÜV-Verband e. V., 30 Sept 2025

The association urges the Commission to make independent third-party certification mandatory for nature credits, build on existing international methodologies like Verra's SD VISta framework, and ensure nature credits are recognized as standalone contributions rather than mere co-benefits of carbon projects.

This would position TÜV inspection bodies as key verifiers in the emerging nature credits market.

Project developers face higher costs from mandatory independent certification requirements.

IPIFF Urges Inclusion of Insect Sector in Nature Credits

International Platform of Insects for Food and Feed (IPIFF), 30 Sept 2025

IPIFF requests that sustainable insect farming be explicitly included as a qualifying activity. They suggest developing sector-specific methodologies to quantify benefits like waste reduction. Finally, they urge the Commission to ensure the system is accessible for smaller companies.

This inclusion would provide financial incentives and private capital to scale up production.

Traditional producers of fishmeal and soybean meal could lose market share to insects.

Consultation response

Acea S.p.A., 30 Sept 2025

The path outlined in the roadmap to Nature Credits recognizes the central role of nature for economic and environmental resilience, with a focus on water ecosystems. Addressing the challenges that the protection of biodiversity and natural ecosystems pose today requires a collective effort and an…

Novamont seeks Nature Credits for bio-based and biodegradable products

Novamont SpA, 30 Sept 2025

Novamont requests that Nature Credits reward industrial bioeconomy activities that use bio-based feedstocks and provide ecosystem solutions. They advocate for credits for compostable plastics and biodegradable agricultural films that protect soil health.

This framework would create new income streams for Novamont's bio-based products and bioplastics.

Manufacturers of traditional plastics face a competitive disadvantage against credited biodegradable alternatives.

PFPI warns nature credits risk greenwashing without strict rules

Partnership for Policy Integrity, 29 Sept 2025

PFPI demands that nature credits never be used to offset environmental damage. They insist that ecologists design the criteria instead of industry lobbyists. Harmful bioenergy subsidies should be redirected towards ecosystem restoration activities.

Strict rules would help PFPI achieve its goal of protecting forest ecosystems.

The bioenergy industry loses lucrative subsidies currently used for burning woody biomass.

European aquaculture producers demand recognition in nature credit system

Federation of European Aquaculture Producers, 16 Sept 2025

FEAP requests including traditional freshwater pond and marine lagoon aquaculture in the nature credit scheme. They urge the Commission to develop certification methods tailored to aquaculture-related biodiversity services.

This would provide new income streams to support the economic viability of traditional fish farming.

European wood industries demand safeguards for raw material supply

European Confederation of Woodworking Industries, 30 Sept 2025

CEI-Bois calls for nature credits to act as a complementary tool reinforcing sustainable forest management. They demand safeguards to prevent unintended reductions in wood supply that would weaken the bioeconomy.

This ensures a stable feedstock supply and protects the wood industry's competitiveness.

Strict conservation measures would reduce the volume of wood available for industry.

Consultation response

Aggregates Europe - UEPG, 30 Sept 2025

"Aggregates Europe represents the largest non-energy extractive industry with a production of 3 billion tonnes of sand, gravel, crushed rock, marine, recycled and manufactured aggregates, produced by 15,000 companies, operating 26,000 sites exclusively in Europe. We are essential to Europes economy…

Consultation response

DIE PAPIERINDUSTRIE e.V., 30 Sept 2025

The German association DIE PAPIERINDUSTRIE e. V. represents the interests of the German pulp and paper industry. In terms of turnover, it covers more than 94% of the sector, speaking on behalf of the largest national pulp and paper industry in Europe and the fifth largest worldwide. In 2023,…

Consultation response

European Organisation of the Sawmill industry, 30 Sept 2025

The European sawmill industries are concerned about the absence of a clear framework on how nature credits will be developed in practice. Without proper safeguards, such schemes risk undermining the availability of raw materials for the wood-processing industries, which are the backbone of Europes…

Consultation response

PETITA I MITJANA EMPRESA DE CATALUNYA, 24 Jul 2025

We welcome the EC's initiative to develop a Nature Credits system within the EU. Subject to further elaboration, we believe that Nature Credits should be linked to the EU Emissions Trading System (ETS) and its related market, so that credit owners can monetise their contributions to biodiversity…

Born Free urges exclusion of offsetting from nature credit scheme

The Born Free Foundation, 30 Sept 2025

The foundation requests that credits only fund positive actions and explicitly exclude offsetting. They also demand a mandatory regulatory framework that integrates animal welfare into biodiversity assessments.

This would provide animal welfare NGOs with new funding and policy influence.

Businesses that rely on offsetting to justify environmental damage would be effectively excluded.

Consultation response

Södra Skogsägarna ekonomisk förening, 30 Sept 2025

Södra appreciates the opportunity to comment on the European Commissions Roadmap towards Nature Credits. As a member owned forest owners cooperative with over 50,000 members and a long tradition of sustainable forestry, we welcome the ambition to develop a voluntary, transparent and science based…

FSC demands EU ban nature credit offsetting

FSC International Center GmbH (IC), 30 Sept 2025

The organization insists that nature credits should only fund actions beyond legal requirements rather than offsetting pollution. They advocate for simplified methodologies for small landholders and the use of existing certification systems.

Adopting existing standards would solidify FSC’s market position and influence in Europe.

Major polluters lose the ability to use nature credits for regulatory compliance.

Austrian forest owners demand voluntary and simple nature credits

LandForst Betriebe Österreich / Association of Austrian Land and Forest Owners, 29 Sept 2025

The association demands a voluntary system that is compatible with existing land management. It seeks to avoid excessive paperwork by aligning the new system with current EU regulations.

Landowners would generate additional income while avoiding the introduction of mandatory new standards.

Conservation groups lose if the system supports commercial management rather than pure habitat protection.

Consultation response

Blue Marine Belgium, 17 Sept 2025

Blue Marine welcomes the opportunity to provide feedback on the Commission's Roadmap towards Nature Credits. In our reply (attached), we underline that EU nature credits could potentially be further developed only if: (1) Biodiversity harmful subsidies are first eliminated and/or re-directed to…

EBIC Urges Commission to Include Biostimulants in Nature Credits

European Biostimulants Industry Council, 30 Sept 2025

EBIC requests that plant biostimulants be recognized as eligible interventions within the nature credits framework. They propose using existing EU fertilising product regulations as the baseline for certification and monitoring.

Official recognition would allow the industry to access new green finance streams and increase sales.

Synthetic fertilizer producers face lower demand as biostimulants improve nutrient use efficiency and reduce requirements.

Consultation response

European Association of Remote Sensing Companies, 29 Sept 2025

Please find attached feedback from the European Association of Remote Sensing Companies (EARSC).

Consultation response

Unión de Uniones de Agricultores y Ganaderos, 30 Sept 2025

Desde Unión de Uniones valoramos positivamente la iniciativa de la Comisión Europea de abrir un proceso participativo para diseñar un sistema europeo de créditos de naturaleza que reconozca y remunere los beneficios ambientales derivados de prácticas sostenibles. Entendemos que, para que este…

Consultation response

Föderation der Natur- und Nationalparke Europas (Föderation EUROPARC) e.V., 25 Sept 2025

EUROPARC Federation acknowledges the work of the European Commission towards achieving the international and EU biodiversity targets agreed in the Kunming-Montral Global Biodiversity Framework and the EU Biodiversity Strategy for 2030. The Roadmap towards Nature Credits contributes towards that…

Consultation response

European Molluscan Producers' Association, 15 Sept 2025

The European Molluscs Producers Association (EMPA) welcomes the publication of the European Commissions new Roadmap toward Nature credits (COM (2025)374) and fully shares its ambitious and cutting-edge objectives. As a sector delivering essential ecosystem services, including nitrogen absorption,…

Minerals Industry Seeks Recognition as Nature Credit Contributors

Industrial Minerals Association - Europe, 29 Sept 2025

The association requests recognition of the minerals sector as a key contributor to nature preservation. They emphasize their expertise in land restoration across extraction stages and want the sector included in nature credit schemes. They highlight existing biodiversity work including habitat creation, five million trees planted, and collaborative projects with conservation authorities.

This would reward their existing biodiversity investments and recognize their contribution toward closing the €48-65 billion annual EU nature funding gap.

Consultation response

Biom Association, 30 Sept 2025

The Association Biom BirdLife Croatia welcomes the opportunity to provide comments on the European Roadmap towards Nature Credits. The latest report by the European Environment Agency on the state of Europes environment presents alarming findings, showing that many ecosystems and species are at…

European Marine Board calls for ocean focus in nature credits

European Marine Board, 22 Sept 2025

Include marine perspective and expertise throughout the process. Standardize marine valuation methods and create open databases. Support sustained ocean monitoring and professional training.

This secures funding for marine observation systems and research initiatives.

Land-based interest groups lose their central influence over nature credit development.

Consultation response

Związek Stowarzyszeń Polska Zielona Sieć, 30 Sept 2025

Mając na uwadze założenia przedstawionego przez Komisję Planu, cele Rozporządzenia, jego wagę określoną w Europejskim Zielonym Ładzie oraz skutki społeczne jakie przyniesie wdrażanie krajowych planów odbudowy zasobów przyrodniczych w poszczególnych państwach członkowskich, stwierdzamy, co…

Consultation response

The Green Tank, 30 Sept 2025

The ARTEMIS Interreg Euro-MED project (https://artemis.interreg-euro-med.eu/) - developing Payment for Ecosystem Services (PES) schemes based on seagrass biodiversity and blue carbon - partnership welcomes the initiative. We recognize its timeliness and potential to mobilize private investment to…

VÖWG urges fair financing and strict nature credit standards

VÖWG, 30 Sept 2025

VÖWG calls for financing based on the polluter pays principle to protect citizens. They demand strict standards to prevent greenwashing and simple procedures for smaller entities.

This prevents additional financial burdens on citizens and municipal public services.

Private actors using natural resources would bear the costs of restoration.

Consultation response

Buglife - The Invertebrate Conservation Trust, 30 Sept 2025

Buglife- The Invertebrate Conservation Trust welcomes the chance to submit a response to the call for feedback on the "Roadmap towards Nature Credits. While there is clearly a need for higher and sustained levels of funding to meet nature restoration ambitions across Europe, Nature Credits are not…

Consultation response

Deutscher Forstwirtschaftsrat e. V., 30 Sept 2025

Wir begrüßen die Idee, naturpositive Maßnahmen sichtbar zu machen und zusätzliche private Investitionen für Biodiversität und Klimaschutz zu mobilisieren. Für eine erfolgreiche Umsetzung aus Sicht der Forstwirtschaft sind folgende Punkte entscheidend: Klare, wissenschaftlich fundierte Standards für…

Consultation response

European Organic Certifiers Council, 30 Sept 2025

The European Organic Certifiers Council gathers 74 Control Bodies and Control Authorities active in 165 countries worldwide. EOCC members control and certify according to EU organic standards: - In European Union: at least 180 000 operators and 6 million hectares; - In Third countries: at least 180…

Consultation response

Austropapier - Vereinigung der Österreichischen Papierindustrie, 30 Sept 2025

The position of the Austrian paper and pulp industry is attached as pdf-file.

Consultation response

Conseil national de l'expertise foncière agricole et forestière, 29 Sept 2025

The National Council of Land, Agricultural and Forestry Expertise (CNEFAF) a French organization representing Land and Agricultural Experts and Forestry Experts welcomes the European Commissions initiative to develop a roadmap for nature credits. CNEFAF underlines the considerable potential of this…

Consultation response

tgo AG, 14 Jul 2025

Feedback on the EU Initiative for Nature Credits Submitted by a nature-based solution provider working at the intersection of biodiversity, regenerative land use, and environmental accounting. We strongly support the European Commissions vision to create a Nature Credit framework that recognizes,…

Consultation response

Zero Waste Alliance Ireland, 30 Sept 2025

Zero Waste Alliance Ireland (ZWAI) welcomes the European Commissions initiative to explore innovative finance mechanisms for biodiversity through the Roadmap towards Nature Credits. The ambition to mobilise private investment for nature restoration and conservation is timely, reflecting the urgent…

Consultation response

Union of European Foresters, 30 Sept 2025

DearMadams, dear Sirs, I just submitted our statement yesterday but without transparency number, so now once again. Best regards

Consultation response

Pravni center za varstvo človekovih pravic in okolja, 30 Sept 2025

PIC is not inclined towards the financial valuation of nature and its services. Humans are part of nature, which cannot be fully quantified or comprehended. It is a condition of life and life itself. It is our common good, which we must take better care of (like stewardship) for the benefit of all,…

Consultation response

Preferred by Nature, 30 Sept 2025

Preferred by Nature feedback to the Roadmap towards Nature Credits 30th Sept 2025 Preferred by Nature would like to thank the European Commission for the opportunity to provide feedback to the Communication from the Commission to the European Parliament, Council, The European Economic And Social…

Consultation response

Umanotera, The Slovenian Foundation for Sustainable Development, 30 Sept 2025

V mreži nevladnih organizacij za trajnostni razvoj Plan B za Slovenijo, ki jo koordinira Umanotera, Slovenska fundacija za trajnostni razvoj podpiramo prizadevanja, da se na ravni EU iščejo možnosti za financiranje obnove narave, saj to predstavlja veliko oviro pri učinkoviti implementaciji Uredbe…

Consultation response

Deutsche Gesellschaft für Nachhaltiges Bauen – DGNB e.V., 30 Sept 2025

Please find attached DGNB's comments and recommendations

Consultation response

Instituut Natuur- en Bosonderzoek/Research Institute for Nature and Forest, 30 Sept 2025

A roadmap towards nature credits provides a useful basis to assess their credibility, scientific rigour, and potential contribution to nature restoration. However, nature credits are only one of several tools available to mobilise finance for nature protection and restoration. Other policy…

Consultation response

ISEAL Alliance, 29 Sept 2025

ISEAL welcomes the objectives of the EU Nature Credits Roadmap: namely to restore nature, halt and reverse biodiversity loss, ensure the long-term provision of ecosystem services, and strengthen Europes natural capital. We recognise the importance of this initiative in mobilising private finance to…

Consultation response

Allianz der öffentlichen Wasserwirtschaft e.V., 29 Sept 2025

Die Mitteilung der Kommission ist zwar ein wichtiger erster Schritt, bleibt in vielen Punkten jedoch noch zu unkonkret. Die vorliegende kritische Bewertung soll die weitere Entwicklung daher konstruktiv begleiten. Insbesondere der Wasserhaushalt und die damit verbundenen Ökosystemleistungen…

Consultation response

Qarlbo Biodiversity, 25 Sept 2025

The Roadmap towards Nature Credits presented by the EU commission on the 7th of July represents a promising first step towards a standardized and credible European nature market. Nature credit markets are inherently complex structures with inbuilt risks and opportunities. Building a new market…

Consultation response

DigitalTrade4.EU, 24 Sept 2025

Our feedback outlines a strategic proposal to integrate Nature Credits into the European Trade Indexes Registry (EUTIR), establishing a unified digital trust infrastructure for environmental, trade, and sustainability data. By anchoring Nature Credits within EUTIRs accredited certification…

Consultation response

European Outdoor Conservation Association, 18 Sept 2025

The European Outdoor Conservation Association (EOCA) welcomes the opportunity to submit feedback on the "Roadmap towards Nature Credits" on behalf of it's membership. The full response is attached as a pdf but please see the summary below: In EOCAs view any proposed Nature Credit system must: - Be…

Consultation response

Aquatic Life Institute, 15 Jul 2025

Aquatic Life Institute (ALI) welcomes the European Commissions initiative to explore nature credits as part of a broader strategy to address biodiversity loss. We appreciate the recognition that marine and freshwater ecosystems are crucial to Europe's ecological and economic resilience. However, we…

Consultation response

, 14 Jul 2025

This document proposes an innovative approach to integrate biodiversity conservation into agricultural and forestry practices, while transforming investment in nature restoration into a lever for economic value creation and long-term sustainability. We welcome this pragmatic vision that balances…