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Butterfly Conservation Europe

BCE

Butterfly Conservation Europe aims to prevent the extinction of any species of butterfly and moth, especially in Europe, and promote all activities and initiatives to conserve and restore butterflies, moths and their habitats in Europe and to contribute to reversing the decline in insect pollinators.

Lobbying Activity

Response to Nature Restoration Law - Method for monitoring pollinator diversity and pollinator populations (delegated act)

17 Jul 2025

My name is Eva Monteiro. I am the President of Tagis Portuguese Butterfly Conservation Centre, a nature conservation NGO and member of Butterfly Conservation Europe. I am also the national coordinator of the Portuguese Butterfly Monitoring Scheme (Pt-BMS) since 2019. I am writing on behalf my organization to express full support of the Commission proposal for a delegated act under the EU Nature Restoration Regulation (NRR) to establish a standardised pollinator monitoring methodology for bees, hoverflies, butterflies and moths. A document we consider essential to implement the important target in Article 10 of the NRR to reverse the decline of wild pollinators. Therefore, we ask the Commission to implement this proposal in full and without delay, so that pollinator monitoring can start in 2027. Tagis and the Pt-BMS, were involved in several projects crucial for the preparation of this delegate act testing its methodologies as part of the SPRING project, contributing with to the European Grassland Butterfly Index (GBI), and participating as trainers and trainees on the European Projects EPIC bee, EPIC Fly and EPIC Butterfly that will help Member States with the implementation of the Delegated Act by training people to identify pollinators to the species level.
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Meeting with Martin Hojsík (Member of the European Parliament)

21 Nov 2022 · Pollinators: Nature Restoration Law, SPRING implementation and pesticides

Response to Protecting biodiversity: nature restoration targets

22 Aug 2022

Butterfly Conservation Europe (BCE) welcomes the proposed Nature Restoration Law and the introduction of legally binding targets for the restoration of ecosystems. The proposed regulation rightly recognises that biodiversity loss has not been halted by previous EU legislation such as the Habitats Directive, as demonstrated by the most recent Article 17 reports submitted by Member States which show that most of the protected butterfly species in Europe are in Unfavourable Conservation Status, as are the grassland habitats that many of them depend on. Legally binding targets are needed because initiatives such as the EU Biodiversity Strategies 2010 and 2020 which relied on setting voluntary targets, have also failed to prevent further loss of biodiversity. BCE supports all the proposals relating to butterflies and other pollinators, including: -Increasing the number and size of Protected and Specially Protected areas, including grasslands, peatlands and old-growth forests and ensuring that they are managed effectively. -Article 8 for the restoration of pollinator populations and allowing the Commission to use implementing acts to establish a method for monitoring the populations of pollinators. -Setting targets to reverse the decline in pollinators, the obligation to monitor pollinators and the use of the Grassland Butterfly Index as an indicator for Agricultural Ecosystems. BCE welcomes the proposal for Member States to produce National Restoration Plans and supports the proposed timescales for producing draft plans, their assessment by the Commission and their finalisation and publication. BCE believes that a financial system is needed to support the implementation of the Nature Restoration Law and suggests that the EU should establish a dedicated EU ecosystem and species recovery fund.
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Response to New EU Forest Monitoring and Strategic Planning Framework

27 Apr 2022

BCE welcome the proposal to develop an EU Forest Monitoring Framework, within the context of the EU Forest Strategy, the EU Green Deal, the EU Biodiversity Strategy 2030 and the climate situation. Butterfly Conservation Europe has expertise on the importance of forests and woodlands for biodiversity, including wild pollinating insect species dependant on forest ecosystems, including several butterflies and moths, some of EU Importance or on Red Lists. Accordingly, BCE recommend that you add a specific item to the REASONS for a Forestry Monitoring Strategy, as follows: - To help track delivery of biodiversity recovery, including reversing the declines in wild insect pollinators dependant on woodland and forest ecosystems In the framework for monitoring to be developed, BCE recommend you include the following particular elements 1. Activity tracking measures - including the inclusion of sufficient open areas and biodiverse rich pathways and edges in forests that are important for pollinating insects 2. Biodiversity outcome data and indicators, including the conservation status and trends in abundance and diversity of: 2a Butterflies and moths, characteristic of forests and woodlands 2b Other insect pollinators dependant on forest ecosystems 2c Natura 2000 forest species of European Importance (HD Art 17 Reporting) and Natura 2000 forest habitat extent and quality. BCE support European Butterfly Monitoring Schemes (eBMS) which regularly and frequently collect and report, (on the basis of implementation of validated, standardised methodology), data on butterfly abundance and diversity across the EU, including in woodland and forest habitats. BCE also publish a woodland butterfly Indicator. BCE recommend these butterfly monitoring results and the Woodland Butterfly Indicator should be included in the new EU Forest Monitoring Framework and that resources should be provided to help support coordination and data management of these monitoring schemes. See https://butterfly-monitoring.net/able-results for Indicator results and technical reports about eBMS Methodology, Indicators, Tools and Networking.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Butterfly Conservation Europe welcome the planned EU Regulations to classify Green Investments. Take up of this initiative by sectors and companies will speed up the necessary transformation of economic sectors onto a more sustanable path. This momentum is much needed. And will help to realise the aspirations of the EU Green Deal. Biodiversity is a key test of sustainability. The IPBES Reports on Biodiversity and Ecosystem Services, on Land Degradation and on Pollinators underline the scale and the urgency of substantive moves to halt harm to the environemt and our ecosystems and to build back better thorough prudent and sound investments. Private sector actions and investments that reduce greenhouse gas emissions, reduce polution, adapt land use and management practices effectively in the face of climate change, reverse the decline in wild pollinators and help to restore habitat area, enhance habitat quatlity, restore species populations and support the functionality and resilience of ecosystems, are much needed. We believe this new Taxonomy approach, founded on sound science with claims validated by evidence, will be an important step forward in achieving these goals. Commitment and determination by all EU Member States and from industry and sectors leaders will be needed to achieve these results in practice. Implementation of these new Regulations will be an acid test of the impact of the EU Green Deal, the Climate Pact, the EU Biodiversity Strategy 2030 and the EU Farm to Fork Strategy. They could also be influential in the global debates and Action Plans, and underpin the EU's credibility in important forthcoming international negotiations. BCE welcome implementation pf the principle of "Do no Harm" and the emphasis on positive action to support biodiversity, environmental health and climate action. We particularly welcome the inclusion of the Agriculture, Forestry and Water sectors in these Regulations, given the negative impacts they can have and the enormous potential they have, if they adapt practices. They can be a force for good delivering a greener future for the planet and a healthier future for people. The current pandemic has underlined the imperative for moving away from business as usual and for individuals and enterprises to act in ways which sustain and enhance, rather than destroy nature. The health and well being of this and future generations is at stake and these developments need urgent implementation and action at scale.
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Response to EU Forest Strategy

3 Dec 2020

Forests and woodlands are important for biodiversity, including butterflies, moths and other pollinators. It is important that the EU Forest Strategy sets out the contribution of EU forests and woods to sustaining populations of butterflies, moths and other pollinators and sets out targets, measures and finance for their enhancement, in line with the EU Biodiversity Strategy and the EU Green Deal. The design and management of forests and woods has a significant impact on their biodiversity. Butterflies of forests and woodlands require larval food plants for reproduction, nectar for feeding and structural diversity for roosting. Including open flowery, herb rich glades in forests, letting some light into the understorey and sustainably creating and managing wide flowery rides and edges will enhance butterfly and other pollinator populations, enhancing the benefits of forestry. Sustaining these features should form part of the management guidelines for sustainable forestry. The Strategy should make provision for frequent, systematic field monitoring of biodiversity, including of butterflies, moths and other pollinators which depend on forests and woodlands. It should also mainstream the use of butterfly indicators to support design, implementation and evaluation of forestry policies. The ABLE project (Assessing Butterflies in Europe - see Report attached) has extended citizen science butterfly monitoring schemes to an additional 10 EU Member States, and eBMS now brings together data on butterfly abundance trends from a total of 22 EU countries. BCE and partners have developed a woodland butterfly indicator which tracks the abundance of widespread butterfly species of woodlands and forests. These Citizen Science butterfly monitoring schemes offer excellent value for money and need some on going support for coordination and training of volunteers. It would be good to involve foresters in this monitoring effort. More investment is also needed in monitoring rare and vulnerable woodland butterflies and other pollinators. Forests and tree planting have a significant part to play in climate regulation - both mitigation and adaptation. However, safeguards are required to prevent loss of biodiversity. The way in which planting is done, forests are designed and the location of planting schemes influences their biodiversity. It is imperative that there is no afforestation, reforestation or natural regeneration of trees on existing or abandoned semi natiural grasslands. The latter habitats are important resources for grassland butterflies and other pollinators. Monitoring shows that grassland specialist butterflies, listed on the EU Habitats Directive, are mostly in unfavourable conservation status and are being lost partly due to abandonment of agricultural management of grasslands with the cessation of sustainable grazing and mowing. This leads to invasion by scrub and eventually reforestation. It may seem superficially attractive to plant trees on abandoned grasslands but it is devastating to already threatened butterfly species; such areas need restoration to biodiverse grassland. It is therefore vital that rules on afforestation and reforestation prevent planting of trees on existing or abandoned semi natural grassland to avoid damaging effects on grassland butterflies and other insect pollinators, which provide important ecosystem services, support other biodiversity, especially birds and are enjoyed by the public. Wood pastures are also an important biodiversity habitat, particularly in Eastern and Central Europe and Boreal and Mediterranea regions. They and their characteristic pollinators are acutely vulnerable to land use change. Better protection of Wood Pasture habitats as part of EU forestry Strategy would represent good EU added value and would contribute to biodiversity recovery and maintenance of rural development.
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Response to Farm to Fork Strategy

16 Mar 2020

Butterfly Conservation Europe welcomes the EU Commission plan to agree a Farm to Fork Strategy for the European Union. The Strategy must be ambitious, complement, be coherent with and help to implement the parallel EU Biodiversity Strategy for beyond 2020. The credibility of the EU in global negotiations on a new Biodiversity Strategy and Climate agreement will depend on the quality of the EU F2F Strategy and the extent to which it leads to the scale of transformational change needed in the agriculture sector. This is set out in the recent IPBES Report on Biodiversity and Ecosystem Services. Business as usual will not work to sustain remaining biodiversity across the EU farmed landscape and to support recovery of biodiversity, ecosystem health and ecosystem services, including pollination services. The Strategy needs to drive the degree of change required to deliver environmental and economically sustainable farming and food systems across the EU, including through setting the framework for a truly environmental reform of the CAP and its rules, spending priorities and incentives. BCE welcomes the Political Guidelines of President von der Leyen. They are insufficiently reflected in the draft Road Map. Much more transformational action is required in the agriculture sector, than that envisaged in the current draft, if the EU F2F Strategy is to deliver effective new standards and measures to protect and restore biodiversity and ecosystem services across Europe’s farmland. The Guidelines envisage closing the gap between words and deeds. This is strongly needed in revising this strategy. Past commitments eg in the EU Biodiversity Strategy 2020, target 3, have not been achieved. Research, EU Auditors Reports and field monitoring of biodiversity outcomes have documented these failures clearly. The Road Map's identification of the problem is too narrow. More ambition needs to be demonstrated. There is urgency to learn from the above Reports and develop a more robust and effective approach which delivers public goods (ie those goods not delivered by the market) for public money. European citizens expect this and now is the time for transformational change. We no longer have the luxury of time in which we can fail the environment, the planet and our children again. This time the adverse consequences will be irreversibly damaging. The F2F stated Strategy Aims are too narrow. A specific Aim to "Sustain and Restore Biodiversity across the Farmed Landscape" must be added and accorded high priority, in accordance with the EU Green Deal. EU Member States' monitoring of habitats and species of European Importance (Art 17 Reports) show most habitats and species, dependent on Agro ecosystems, are in unfavourable inadequate or bad conservation status and some are declining further. The EU Grassland Butterfly Abundance Indicator shows some 40% decline since 1990. This evidence is the “writing on the wall” for wild pollinators and soil biodiversity on which ecosystem heath and productive agriculture depends. We agree food waste needs to be hugely reduced. Agriculture systems need to reduce carbon emissions, pollution, pesticide use and antibiotic use. Food policy needs to encourage lower meat consumption, while supporting sustainable grazing of semi natural meadows of high biodiversity value. Biodiversity needs to be accepted as a test of sustainable farming. Support must be given to field monitoring of butterflies, moths, wild bees and hoverflies and other pollinators and resources must be devoted to their recovery. The F2F Strategy must set the framework for a future CAP which uses public money and rules to drive transformational change across the farming and food sectors, rewarding farmers for sustaining and restoring wild pollinators, other biodiversity, cutural landscapes and ecosystem functionality and resilience and driving down climate change emissions and supporting a healthy rural economy and responsible food consumption.
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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

20 Jan 2020

Butterfly Conservation Europe (BCE) welcomes the draft EU Road Map towards an EU Biodiversity Strategy to 2030. The EU Biodiversity Vision for 2050, in the existing Strategy, is still relevant and should be in the new EU Strategy. We welcome the Political Guidelines from the new EU President which confirm the importance of setting new standards that cut across trade, industry, agriculture and economic policy. Commitments to such new standards need to be explicitly included in the Road Map (and the parallel EU Farm to Fork Strategy). The drivers of biodiversity declines and ecosystem degradation are well documented in the references cited in the draft (including recent IPBES Reports on Pollination, Ecosystems and on Land Degradation) and in other studies in academic and grey literature. Please add a reference to EU Auditors' reports on CAP and biodiversity. "Problem Definition" in the Road Map is good, as far as it goes. But the scale, depth and urgency of the problems and pressures facing the EU, if it is to sustain remaining areas of high biodiversity value and restore degraded areas, are underplayed. As the Road Map recognises, targets in past EU Biodiversity Strategies have largely been missed (some, eg current Target 3, by a wide margin). For the EU to have credibility in leading globally it must take effective action at home. The Road Map needs to be more ambitious and strengthened in committing additional resources for biodiversity recovery and positive actions by sectors. This is essential to meet the EU President’s commitment to "strengthen the link between words and deeds". We do not now have the luxury of time. If Europe makes only minor policy adjustments and business across sectors continues much as in the past decade, we will stay on a path to an existential crisis for civilization and a healthy planet, within the lifetimes of our children. The Strategy must recognize this more radically and act for the health and wellbeing of this and future generations. Some of the powerful forces that have prevented substantive changes to policy or have hindered full implementation of good EU legislation, like the EU Habitats and Birds Directives, have been vested interests. The Road Map needs to acknowledge this. The new Strategy needs to introduce new measures to face up to the influential lobbying by companies and organisations that seek to promote private interests over the duty of governments and the EU to deliver public goods for public money. Biodiversity and ecosystem degradation is a classic example of market failure. Perverse subsidies need to be removed. Pollution, including from damaging pesticides needs to be outlawed. Sustaining and restoring biodiversity needs to be recognisd, valued and rewarded. What has been missing, so far, is the political will and leadership needed "to lead the transition to a healthy planet". As the Road Map recognises there are many examples at a small scale of what can work to sustain biodiversity and ecosystem health and to support restoration and recovery. There have been many Conferences and studies which have provided examples of effective interventions. Now we need investment and coordinated action at a much larger scale. This issue of scale needs more emphasis in the Road Map. Data provided by EU Member States in accordance with Article 17 of the EU Habitats Direcive, every 6 years, indicates the scale of the degradation, even in the 18% of the EU land area which is designated as of European Importance for its wildlife. Most designated grasslands, peatlands and butterflies are in unfavorable conservation status and many are still declining. The EU Grassland Butterfly Indicator shows almost 40% decline in butterfly abundance since 1990. Full implementation of the EU wild Pollinators Strategy must be reinforced and the Road map needs to commit to stronger partnerships with volunteers and NGOs to deliver cost effective biodiversity monitoring.
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Response to Commission Delegated Regulation on the methodology for risk assessments of invasive alien species

22 Dec 2017

Overall Butterfly Conservation Europe (BCE) is very supportive of the Delegated Act as it is currently drafted. No substantive amendments are needed to the draft. We 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. BCE considers Alien Invasive species ar a significant threat to biodiversity, including insects and can cause significant harm, including to endemic insect pollinators. The 2016 IPBES Report on Pollinators and Pollination Services reviews these issues. BCE considers that the distinction between Risk Assessment and Risk Management is crucial . We welcome the Commission's highlighting of 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, BCE 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 evaluates the Risk Management of whether to include the species on the EU IAS List or not. BCE considers the wording of the section relating to Article 5(1)(h) of the Annex of Common Elements to be appropriate and well within the aim and the spirit of Regulation 1143/2014. However, for the avoidance of doubt, there could be value 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. It is unnecessary to specify that only economic experts can compile evidence relating to Article 5(1)(h); 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 international best practice, to consider expert opinion and grey literature when assessing the risk that a species may pose. But only when peer-reviewed evidence is not available and only when 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, BCE welcomes the 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, BCE suggests that ‘endangered habitats’ is changed to simply ‘habitats’. A habitat may become endangered by the presence of an IAS, so merely focusing on endangered habitats may miss significant elements for the risk assessment.
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Response to EU Pollinators Initiative

22 Dec 2017

EU Pollinators Initiative Road Map Comments by Butterfly Conservation Europe on the Commission’s understanding of the problem and possible solutions plus relevant information and refs Context Yes - animal pollination is vital. Wild pollinators are especially important Yes - pollinators essential for food production. Pollinators also essential for pollination of wild flowers on which future pollination services depend ie essential components of a healthy ecosystem Yes – insect pollinators including wild bees, moths and butterflies are important Some EU policies are helpful – yes. Some EU Policies, like CAP and Pesticides Regulation and implementation are in urgent need of reform in order to make a significant improvement in the state of pollinators across the EU. And significant increases in EU and EU Member State funding and commitment to action are needed to support better implementation of the Nature Legislation and strategic investment in green infrastructure Problems the initiative aims to tackle The problem to be tackled is essentially the declines in pollinator abundance and diversity – yes. But the scope of the problem needs wider definition. It is not just vital that declines are halted; it is essential that EU beneficial insect abundance declines are reversed; and that the semi natural grassland and other ecosystems on which they depend are restored, so that pollinator populations become more sustainable and resilient. The widespread scale of this problem and the deep resistance to recognizing it fully and implementing the political, economic, social and governance changes to really reverse the situation need to be acknowledged and tackled. Business as usual is entrenched in the agriculture and agri chemical sectors and they are highly resistant to the changes needed There may not be one single cause of insect declines but much evidence points to the significance of the negative impacts of intensive agricultural practices; the use of highly toxic pesticides, especially neonicotinoids; the adverse effects of agricultural abandonment on the quality and quantity of semi natural and HNV grassland; and the negative effects of fragmentation and losses of connectivity across landscapes. Pollinator services are highly valuable (estimated at €15 billion pa?) to EU Agricultural food production – yes. This is important and probably underestimates the total value of pollinators because of the difficulty of assigning a monetary value to the essential role they play in ecosystem health and resilience. Basis for EU Intervention These problems need to be tackled at EU level and need coherent, coordinated, and effective interventions. We agree that EU action can be instrumental. Action at EU level needs to be undertaken with greater political understanding of the scale and urgency. What does the EU Initiative aim to achieve and How? The Initiative aims to establish an integrated EU approach to tackle the decline of pollinators by raising its political profile and increasing the effectiveness of EU policies for pollinators – Yes this is important but an insufficient response. The EU needs to be more ambitious, given the scale, gravity and resistance of the problem and to reverse pollinator declines and increase essential ecosystem health and resilience. Mechanisms Increase knowledge – yes. But we know a lot already – sufficient to implement some actions that are highly likely to make a difference, and some that are likely to stop things getting worse. The EU could act more decisively and quickly on key drivers of loss eg degradation and loss of semi natural grassland and banning of pesticides that are highly toxic to insects. Tackle Causes – yes. Continue to support what is already good in EU policy and MS practices which are working well for sustaining beneficial insect populations. But the EU need to do more, especially reducing risks and the pervasive impact
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