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Both ENDS

BE

Both ENDS is een onafhankelijke, niet-gouvernementele organisatie (NGO) die werkt aan een duurzame toekomst voor onze planeet.

Lobbying Activity

Meeting with Fabien Gehl (Head of Unit Trade) and Counter Balance

16 Oct 2025 · • Presentation of the report by Both Ends “The role of EU Export Credit Agencies (ECAs) in financing the Energy Transition” • Discussion about ECAs’ role in decarbonisation and about the enhanced coordination between export and development finance

Meeting with Kathleen Van Brempt (Member of the European Parliament) and Counter Balance

16 Oct 2025 · The role of European Export Credit Agencies (ECAs) in financing the Energy Transition

Meeting with Catarina Vieira (Member of the European Parliament) and Federatie Nederlandse Vakbeweging and Stichting Onderzoek Multinationale Ondernemingen

22 May 2025 · Trade Vision

Meeting with Catarina Vieira (Member of the European Parliament)

19 Mar 2025 · Sustainable trade

Meeting with Kathleen Van Brempt (Member of the European Parliament) and Counter Balance

28 Jan 2025 · Critical Raw Materials + Export Credit Agencies

Meeting with Martin Schirdewan (Member of the European Parliament) and Climate Action Network Europe and

26 Sept 2024 · Fairer Handel

Meeting with Bernd Lange (Member of the European Parliament)

19 Mar 2024 · Export Credit Agencies

Meeting with Kathleen Van Brempt (Member of the European Parliament) and Counter Balance

14 Sept 2023 · Export Credit Agencies impact analysis Com and state of play - APA

Meeting with Olivia Gippner (Cabinet of Executive Vice-President Frans Timmermans) and Counter Balance

26 Jul 2023 · EU Export Credit Agencies and the Green Deal

Meeting with Heidi Hautala (Member of the European Parliament) and Counter Balance

20 Jun 2023 · European Export Credit Agencies (staff level)

Meeting with Kathleen Van Brempt (Member of the European Parliament) and Counter Balance

4 May 2023 · State of play in depth analysis and feasibility study on export credit agencies - APA

Meeting with Bernd Lange (Member of the European Parliament, Committee chair) and Ford Motor Company

9 Nov 2022 · General exchange of views

Meeting with Kathleen Van Brempt (Member of the European Parliament)

11 Oct 2022 · EU export credits round table discussion

Meeting with Kathleen Van Brempt (Member of the European Parliament)

15 Sept 2022 · Export Credit Agencies - APA

Meeting with Kathleen Van Brempt (Member of the European Parliament)

2 Aug 2022 · Export Credit Agencies - APA

Response to High and low Indirect Land-Use Change (ILUC) - risks biofuels, bioliquids and biomass fuels

8 Mar 2019

Expanding palm oil production causes deforestation and ecosystem destruction on a massive scale. Since the introduction of the RED's renewable energy targets, especially for the transport sector, the EU's consumption of palm oil for the biofuels market has doubled the EU's palm oil imports; half of all palm oil imported into the EU is now burned as biofuels. Given the EU is the second largest importer of palm oil in the world, the reliance on palm oil as a form of "renewable energy" has created perverse market incentives for palm oil production and increased impacts on forests, local communities, indigenous peoples, ecosystems and wildlife in production regions. However, palm oil is not the only vegetable oil crop that causes land-use change impacts for communities, the environment and the climate. All vegetable oil crops must be addressed consistently based on clear and robust ILUC criteria that prioritise the EU's climate commitments and human rights obligations over market considerations. The draft Delegated Regulation ("Act"), while an improvement on the original RED, fails to phase out food-based biofuels as a means of achieving the EU’s renewable energy targets, thus sanctioning the climate impacts associated with expanding palm oil, soy, sunflower and other vegetable oil crop plantations. LOOPHOLES AND WEAK HIGH ILUC CRITERIA The criteria for defining food crops that are unfit for EU biofuels (High ILUC-Risk) in Article 3 are too weak, basically mean that only palm oil is considered a High ILUC-Risk feedstock, and will, in practice, result in the exclusion of soy products, despite soy production being the second largest cause of deforestation and associated human rights violations in South America. Soy must be in the High Risk category or this law will be ineffective. As the 2015 GLOBIOM study indicated, biofuels from vegetable oils in the high ILUC category, as a group, cause more GHG emissions than their fossil alternatives. Both palm oil and soy stand out in the GLOBIOM study as causing high ILUC and neither should not be regarded as "low ILUC". Vegetable oils are highly interchangeable and the high ILUC classification should apply to ALL vegetable oils. Improved governance of so-called sustainable palm oil and soy production should be key preconditions before legislating the use of designated sustainable palm oil and soy for biofuels use. The Low Risk exceptions in Articles 4 & 5 allow certain production of vegetable crops to be used for biofuels. These exceptions are arbitrary, counter-productive and must go, or this law will be ineffective. UNUSED LAND The definition of "unused land" excludes consideration of the uses and functions of land besides active food or fodder production, completely ignoring the ecological importance of forests, grasslands and wetlands to communities, biodiversity and the climate. Land may be 'used' by society in countless other ways. "Unused land", as defined in the Act, could be occupied by local communities or indigenous peoples, could provide rich cultural and spiritual value, provide a habitat for rare biodiversity, and other invaluable ecosystem services (like clean water and fresh air). The concept of "unused land" must therefore be altered or removed entirely. STRENGTHEN MONITORING & VERIFICATION REQUIREMENTS Article 6 provides that “voluntary schemes may be used" to demonstrate compliance with the Low Risk exception. The Low Risk exception should be removed, and other exceptions should be based on strict international criteria that are robust, verifiable, transparent, and consistent with the EU's human rights obligations (especially towards indigenous peoples) and climate commitments. Likewise, measures may satisfy the 'additionality measure' conditions if they "are applied by smallholders", rendering the Act unlikely to prevent ILUC impacts caused by smallholders and without any robust mechanism to guarantee that smallholders will actually benefit from this exception.
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Response to Stepping up EU Action against Deforestation and Forest Degradation

15 Jan 2019

The feedback in the ATTACHED DOCUMENT is jointly submitted by eight civil society and forest peoples’ organisations from Europe and tropical forest countries. A summary of key points is provided below. 1. NECESSITY AND MANDATE FOR LEGISLATIVE MEASURES While we support “a more coherent and comprehensive approach to the problem”, we are concerned by the unreasonably limited scope of the Roadmap’s so-called ‘comprehensive approach’. Modifying existing EU policies and supporting existing commitments is woefully inadequate to reverse the rising trend of EU contribution to global deforestation. This approach ignores the fact that existing policies and tools, as well as voluntary market mechanisms and certification schemes, have failed to slow global deforestation or prevent systemic landgrabbing and human rights abuse linked to trade in forest-risk commodities. The preference for relatively easy options of tinkering with existing initiatives and avoiding legislative intervention also suggests an alarming underestimation of the scale of the problem and disconnect with Commission’s policy-making mandate. The Feasibility Study concluded that “a more coherent and comprehensive EU approach” acting on multiple levels to address the problem from several angles is needed that new legislative measures combined with non-legislative measures (‘Option C’) “should have the greatest impact”. The present Roadmap disregards options for legislative initiatives, adopting an approach consistent with ‘Option A’ described in the Feasibility Study as being least effective, with the lowest likely contribution to the objective. This low-impact approach is misguided, as many existing measures have proven inadequate. While the European Parliament’s repeated calls for an Action Plan on Deforestation and Forest Degradation that includes legislative measures to reduce EU consumption of embodied deforestation and forest-risk commodities are acknowledged, the Roadmap rejects the policy-making mandate conferred by the Parliament. Instead of the least-effective ‘Option A’, the Roadmap should propose a substantive response to the Parliament’s repeated calls for regulatory measures and pursue Action Plan that combines improving existing initiatives and developing necessary legislative interventions. 2. THE HUMAN RIGHTS DIMENSION OF DEFORESTATION MUST BE ADDRESSED Global agricultural production is intricately linked with patterns of social injustice, environmental damage, displacement, violence and murder of local and indigenous people, their leaders and human rights defenders. It is not clear what measures are proposed to eliminate these negative impacts of EU trade and consumption, nor is it clear how EU trade, investment and development cooperation will be aligned with EU human rights commitments and treaty obligations. While we support improving land governance, livelihoods and sustainable agriculture and forestry practices in producing countries, such initiatives must prioritise protection of the rights of local communities and ensure that EU companies do not contribute to human rights violations abroad. A rights-based approach would support efforts towards halting deforestation and requirements on EU enterprises to obtain and verify evidence of respect for the rights of local communities would enhance efforts to address local drivers of deforestation. The Roadmap should therefore adopt a rights-based approach aligned with existing EU commitments on good governance of land tenure. To ensure measures are effective, human rights and environmental due diligence obligations should be mandatory. Given formally recognised and secure tenure rights are proven to mitigate deforestation-risks, the importance of secure tenure rights of local communities should also be recognised by including specific measures for “Supporting Secure Tenure Rights of Forest Peoples”, such as targeted assistance for land and livelihood rights for communities in producer countries.
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