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Buglife - The Invertebrate Conservation Trust

Buglife

Buglife’s aim is to stop the extinction of invertebrate species and to achieve sustainable populations of invertebrates.

Lobbying Activity

Response to Roadmap towards Nature Credits

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 the route to achieving the necessary levels of investment. The necessary funding will only be possible with a long-term commitment of public funds. There remains a risk that Nature Credits are used to justify cuts in public funds. While private funding is clearly necessary, it is essential that any investment is complementary to public funding commitments. The scope of Nature Credits must be clearly defined and restricted to clear conservation and restoration activities. Importantly, offsetting or other forms of ecological compensation for destructive activities, should be excluded from Nature Credit proposals. Biodiversity Net Gain (BNG) has been described as mandatory in England since February 2024, with a requirement for 10% BNG. However, it has so far failed to meet anticipated targets. Crucially, there have been concerns from species groups that the biodiversity metric fails to address the true value of sites to species, risking BNG facilitating continued species losses. There is evidence that BNG has been applied inconsistently, has embedded biases and perverse habitat outcomes that often align with convenience or costs rather than nature conservation priorities. While BNG is mandatory in planning law, loopholes have been repeatedly exploited to avoid delivering BNG while meeting planning requirements. Offsetting has also led to zoning between areas for nature and areas for development, potentially leading to localised losses of wildlife-rich habitat and species as BNG is implemented over time and reducing peoples access to nature. Frequently, the inadequacy of baseline habitat assessment and over-exaggeration of compensation endpoints, including overconfidence that habitats can be created or restored off-site has raised concerns that BNG is simply not being achieved. This demonstrates the challenges in trying to quantify nature, while there are also concerns at how well created and restored habitat will develop. Such uncertainties demonstrate how Nature Credits should remain complementary/additional to the vital works of protecting existing nature sites and how public funds must continue to drive biodiversity recovery work. With poor implementation, offsetting risks helping to facilitate development on nature-rich sites, while leading to poor outcomes and long-term losses. Any governance or monitoring of Nature Credits must be heavily regulated and appropriately funded. The quality and appropriateness of outcomes must also be carefully considered, and linked to legislation such as Nature Restoration Regulation (and the associated National Restoration Plans), Birds and Habitats Directives and the Water Framework Directive.
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Response to Nature Restoration Law - Method for monitoring pollinator diversity and pollinator populations (delegated act)

10 Jul 2025

Buglife- The Invertebrate Conservation Trust, is the only organisation in Europe devoted to the conservation of all invertebrates. Buglife welcomes the Commissions pollinator monitoring proposals that will implement the crucial target in Article 10 of the Nature Restoration Regulation (NRR). Europes pollinators are vital to supporting a healthy society and for its food security and to support effort to restore these populations, it is essential that a scientifically robust monitoring programme is put in place in all Member States. Buglife asks the Commission and Member States to implement the proposals in full as an urgent priority, to keep pace with the implementation timetable of the NRR. Buglife has been raising awareness of the decline of pollinator populations across Europe for 20 years and the actions that are required to secure their future. The introduction of a science-based method for monitoring pollinator diversity and pollinator populations is welcomed. This must include a commitment from all Member States to use approved and comparable methodologies and with a sufficient number of sites for meaningful scientific assessment. Buglifes aims include preventing invertebrate extinctions, so it would strongly support the use of European Red Lists to help identify the rare and threatened pollinators that will be monitored through the programme.
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Response to Updating the list of invasive species threatening biodiversity and ecosystem services across the EU

21 Mar 2025

Buglife support the updates proposed to the invasive alien species of Union concern list. However, we remain concerned by the lack of biosecurity measures in place to prevent the spread of Invasive Alien Species between Member States and beyond the EU. This is especially relevant to soil dwelling species that are currently present in some Member States but not in others. Buglife recommend plants be moved within Europe bare rooted and soil consignments are restricted from areas with known populations of species included on the invasive alien species of Union concern list.
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Response to Ensuring that hazardous chemicals banned in the European Union are not produced for export

25 May 2023

The January 2017 Report of the Special Rapporteur on the right to food report to the UN Human Rights Council concluded that pesticides are responsible for an estimated 200,000 acute poisoning deaths each year, 99 per cent of which occur in developing countries but that Approximately 25 per cent of developing countries lack effective laws on distribution and use, while about 80 per cent lack sufficient resources to enforce existing pesticide-related laws. In addition to human health concerns there are global concerns about the release of persistent pesticides harmful to biodiversity into the environment. With regard to chemicals banned in the EU due to the harm they cause to pollinators there is a high risk that their use in countries near the EU will damage EU pollination services and food security as populations of pollinating hoverflies and moths in particular are often migratory in nature, hence would be vulnerable to harm while in countries outside the EU https://www.sciencedirect.com/science/article/pii/S0960982219306050 Regulating to prevent the export of chemicals where we know the intended use is likely to damage human health and the environment would be a sensible and proportionate measure that would apply the fundamental EU environmental principle of preventing harm.
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Response to Protecting biodiversity: nature restoration targets

10 Nov 2020

We strongly welcome the proposal to set binding nature restoration targets. It is essential that they are focused on achieving positive outcomes for species and habitats across the EU. We would direct the EC to the work of the European Habitats Forum for general guidance on the approaches that should be taken. But given the tragic and rapid declines in insect populations, many species of which are not listed on the Habitats Directive and do not occur on Natura 2000 Sites, we would draw attention to the following three areas for which targets must be established to reverse this loss of biodiversity: 1) A bees and pollinator abundance target - to protect ecosystem health and >18 billion euros of pollinator services. 2) A open habitats connectivity target - habitat fragmentation combined with climate change will probably cause the decline and extinction of more species than any other factor in the next 50 years - restoring wildflower rich grassland is the only feasible way to introduce enough stepping stones to ensure that biodiversity can thrive - this requires a target, and indeed a mapped network map, to drive cost effective habitat restoration that will enable species to respond to climate change pressures. 3) A light pollution target - this is a factor that impacts on many species, and has yet to be addressed by EU measures - a light reduction target would set the right direction of travel. Matt Shardlow CEO Buglife - the Invertebrate Conservation Trust
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and Stichting BirdLife Europe and

13 Mar 2020 · Green Deal

Response to EU 2030 Biodiversity Strategy

8 Jan 2020

We at Buglife – The Invertebrate Conservation Trust very much welcome the development of the 2030 EU Biodiversity Strategy. In particular we draw your attention to the recent scientific papers showing profoundly substantial declines in insect numbers in Germany, the Netherlands, Denmark, the UK and elsewhere on the continent. The loss of wild bees, hoverflies, moths and other small animals threatens the basis of a healthy ecosystem and puts at jeopardy our future ability to feed ourselves. Not only have recent EU Red Data List assessments revealed that about 9% of insect species in the EU are threatened with extinction, most recently the EU Grassland Butterflies index has shown that there has been a shocking 39% decline in butterfly numbers in the last 30 years. https://butterfly-monitoring.net/sites/default/files/Publications/Technical%20report%20EU%20Grassland%20indicator%201990-2017%20June%202019%20v4%20(3).pdf The huge losses to biodiversity as a result of invertebrate population decline have not previously been factored into the EU Biodiversity Strategy. They must be and the actions must be followed through to avoid repeating the disastrous failure to achieve the 2010 and 2020 biodiversity targets. These are our suggestions for planning the roadmap: 1) Incorporate the EU Pollinators Initiative fully into the biodiversity strategy, this document should be listed in the evidence base of publications. In addition the NGO review of action needed to resolve pollinator decline should be included in scoping the actions required - https://cdn.buglife.org.uk/2019/07/Full-Pollinator-Initiative-response-Final.pdf 2) The Roadmap is strong on creating space for wildlife to recover, but is less resolute on the key activity that spaces must also be made safe – this includes improving the protection from agricultural chemicals, electromagnetic radiation, invasive non-native species, medicines, light pollution and other pollutants. Targets should be set to reduce the levels of harmful pollutants and measures introduced to prevent new pollutants emerging. 3) Actions must be firmly embedded across the operations of all EU and Government departments – for instance fixing the CAP, preventing pollution and stopping the transport system from fragmenting nature are all dependent on the departments other than DG-11 taking resolute action. 4) The strategy and targets must have more underpinning than has previously been the case, having failed to halt biodiversity loss twice, new international mechanisms are needed that will hold countries to account for setting and achieving ‘halt and restore’ targets for biodiversity. Yours Matt Shardlow CEO
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Response to EU Pollinators Initiative

28 Dec 2017

Buglife, the European charity dedicated to halting and reversing declines in all pollinators warmly welcomes the Pollinators Roadmap. A significant proportion of EU species are pollinating insects and their role is critical; plants and vertebrates depend on them. This initiative must make a profound difference as wild pollinators declines are already impacting on our ability to feed ourselves. The lack of any bees on the Nature Directives and their failure to bring about interconnected networks of wildlife habitats point to the urgent need for a pollinators initiative. We welcome both the broad scope of the initiative and its focus on wild pollinators. If we resolve the problems facing Europe’s pollinators we will resolve most of the challenges facing wildlife. The two towering issues the initiative must tackle head on are: 1) Reversing the fragmentation of flower rich habitats – requiring the following alignments: a) Ensuring existing wild flower rich habitats are protected (e.g. EIA rules being applied) and are positively managed to secure their continued biodiversity contribution – use existing EC tools, and ensuring compliance and achievement of objectives. b) A CAP much more closely aligned to paying for public goods, with assistance in maintaining pollination services a key priority – requires real progress to be made in the next review, across EC directorates. c) The production of a coordinated network of wildflower rich grassland across the EU, in terms of improving pollinator dispersal this will be five times more cost effective than a scattergun approach – there is an important leadership role here for the EC. We commend our B-Lines scheme, winner of the ELO 2016 Bee Prize, as an example of how this can work. 2) Once the three most persistent neonicotinoids are banned action is needed to avert a similar future environmental impact from pesticides: a. Improved approval process - science strengthened – with replication and statistical tests as the norm, the EFSA Bee Guidance formally adopted, and a similar approach introduced for Lepidoptera. b. The introduction of a Europe wide series of pollinator monitoring schemes (following methodologies like those proposed by the FAO and applied in 2017 in the UK) to better understand the relationships between pesticides, wild pollinators and crop yields. c. Clear global leadership on pesticide regulation, recognising that the current sale of pesticides deemed too harmful to use in the EU to countries with no pesticide regulation, to the profit of EU operating companies, is indeed a case of human rights abuse. Support a global convention on pesticide regulation, advocate reform to the market to promote a longer term product horizons, better custodianship and improved environmental standards – thereby benefitting the worlds pollinators. In the attached document, prepared with Butterfly Conservation Europe, we set out a detailed list of activities to be addressed, with suggested stakeholders to be engaged to achieve progress. The scale of the task is considerable and will require resources, urgency and careful planning of timescales to complete to the necessary standard. We were surprised that the roadmap did not set-out clear timelines or establish when deliverables would be produced. We trust that a detailed plan of the initiative with clear end points will be the next activity and will be made available for public comment. Conclusion Buglife is keen that this becomes the turning point for our disappearing pollinators. The initiative’s aim should be clarified so that “tackle the decline in pollinators” is clearly understood to mean ‘halting and reversing the decline in wild pollinators’. The scope of the roadmap is sufficiently broad, the urgency and scale of change necessary does not shine through. We hope that resources and support are marshaled so that it can be sufficiently impactful. Matt Shardlow, CEO, December 2017
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Response to Commission Delegated Regulation on the methodology for risk assessments of invasive alien species

15 Dec 2017

Overall Buglife is very supportive of the Delegated Act as it is currently drafted. Indeed, we do not believe any substantive amendments are needed to the draft. Buglife consider that this draft Delegated Act meets, and in no way exceeds, the scope of the Delegated Act as determined by Article 5(3) the EU IAS Regulation 1143/2014. We consider that the distinction between Risk Assessment and Risk Management is crucial and praise the Commission for clearly highlighting this distinction within the Explanatory Memorandum. As clearly detailed in Article 5(3) of Regulation 1143/2014, this Delegated Act exists to further specify the evidence requirements for the Risk Assessments required under Article 5(1) of Regulation 1143/2014. It is clear from Article 5(3) that the Delegated Act does not exist to specify the evidence requirements for any Risk Management analyses. Consequently, Buglife praises the Commission for ensuring the scope of this Delegated Act has been limited to that of specifying the evidence required for Risk Assessment, and not deviated to considering the evidence required for Risk Management. Article 5(1)(h) of Regulation 1143/2014 requires Risk Assessments to include ‘a description of the known uses for the species and social and economic benefits deriving from those uses’. Article 5(1)(h) is therefore asking for a description of the Risk Management considerations, so as to provide initial context to the Risk Assessment. However Article 5(1)(h) is clearly not requiring a detailed analysis of the Risk Management considerations, as this can be provided if necessary directly to the EU IAS Committee when it considers whether to include the species on the EU IAS List or not. We consider the wording of the section relating to Article 5(1)(h) of the Annex of Common Elements to be appropriate and entirely within the aim and the spirit of Regulation 1143/2014. However, for the avoidance of doubt, we wonder whether there is in adding a note to this section which clearly states that the Regulation merely requires a brief description of social and economic considerations to provide context to the Risk Assessment, and not a full analysis of the Risk Management considerations. Furthermore, we consider it unnecessary to specify that only economic experts can compile evidence relating to Article 5(1)(h) as this would be an unnecessary burden for what is merely a descriptive section. The primary aim of Regulation 1143/2014 is to prevent future damaging invasions by alien species. Due to the nature of invasive alien species, an invasive alien species may become established and cause harm within the EU before it is possible to complete rigorous scientific studies into the impact of that species in Europe. Consequently, as per international best practice, it is not appropriate to rely solely on peer reviewed literature when assessing the risk that an invasive alien species poses. However, it is entirely appropriate, as per international best practice, to consider expert opinion and grey literature when assessing the risk that species poses. But only if peer-reviewed evidence is not available and the uncertainty surrounding such material is appropriately articulated. As this Delegated Act allows for the use of non-peer reviewed evidence, with appropriate and proportional caveats, Buglife praises the mature and considered approach to evidence that this Delegated Act presents. With regards to the section of the Annex of Common Elements relating to Article 5(1)(f), within Paragraph (3) We suggest that ‘endangered habitats’ is changed to simply ‘habitats’. A habitat may become endangered by the presence of an IAS, so merely focusing on endangered, as opposed to all, habitats may miss significant elements of the risk assessment. Buglife would be very happy to discuss these comments further if this would be helpful and is very welcome to being contacted by the Commission at any point to discuss this consultation response further.
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