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EuroNatur - Stiftung Europäisches Naturerbe

EuroNatur

EuroNatur is an international foundation dedicated to protecting European species, habitats, and wild rivers across national borders.

Lobbying Activity

Meeting with César Luena (Member of the European Parliament) and WWF European Policy Programme and Stichting BirdLife Europe

19 Nov 2025 · LIFE programme

Meeting with Thomas Waitz (Member of the European Parliament, Delegation chair)

19 Nov 2025 · Chapter 27 Montenegro

Meeting with Andrea Vettori (Head of Unit Environment)

21 Oct 2025 · Financing under the next MFF for nature conservation and the Nature Restoration Regulation, & complaint case to the Bern Convention of the Vjosa river and the airport project on that site

Response to Roadmap towards Nature Credits

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 the Nature Restoration Regulation. However, the Commission has also recently published its proposal for the next MFF, which foresees the disappearance of its only programme dedicated to the environment, LIFE, and scraps a specific biodiversity spending target. While we believe that it is necessary to generate substantial contributions from the private sector, and particularly sectors which rely on ecosystem services, for nature conservation and restoration work the implementation of environmental legislation should not depend on private financing solely. Therefore, the priority should remain to maintain enough direct public funding for nature restoration and nature conservation. Nature credits, if well-regulated and additional to public sources, could come in complement to close the biodiversity funding gap. Having said that, the financialisation of nature harbours risks such as speculation through secondary markets, trading or offsetting, which would lead to the perpetuation of harmful practices. It is therefore crucial that nature markets are developed on the basis of a regulated, science-based approach that strictly respects the mitigation hierarchy and sets principles of integrity for the market. Furthermore, strict definitions, methodologies and verification systems should be developed and enforced under the supervision of supervisory authorities. We therefore advocate for the creation of a robust mandatory regulatory framework to prevent excesses as well as a variety of unregulated and unsupervised certification mechanisms. In its Roadmap, the European Commission suggests looking into voluntary schemes. Voluntary only markets should be regulated to avoid greenwashing and the compensation of projects that harm nature. If strictly regulated, voluntary schemes could come in complement to well-regulated compliance markets, which should also be strictly monitored to avoid offsets. However, according to existing research, there is for the moment no example globally of a voluntary scheme generating significant volume. Another key aspect is equity and fair access for all participants, by setting transparent rules for all stakeholders and creating a level playing field where all actors involved in the market have fair and accessible opportunities to participate. In terms of governance, this can partly be achieved by providing guidance and financial support to adjust capacity at national, regional and local levels. Effective governance also protects the interests of buyers, suppliers, intermediaries and third parties. In the attached document, EuroNatur lays out key principles to price the priceless and ensure that nature markets benefit from a binding regulatory framework that lays out the basis for high integrity, well-regulated, science-based credits.
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Meeting with Sebastian Everding (Member of the European Parliament)

4 Mar 2025 · Situation of Balkan Lynx

EuroNatur demands detailed science-based national nature restoration plans

6 Feb 2025
Topic — This consultation defines the mandatory template for Member States' nature restoration plans.
Message — EuroNatur calls for the format to include mandatory legal requirements and high levels of detail. They recommend adding concrete maps and specific sections for habitat connectivity.123
Why — Standardized, detailed reporting allows the organization to monitor implementation and hold governments accountable.4
Impact — Member States lose the flexibility to submit vague reports and must meet stricter data standards.5
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Meeting with Martin Häusling (Member of the European Parliament) and Naturschutzbund Deutschland e.V.

3 Feb 2025 · Abendessen mit Vertretern von Verbänden

Meeting with Martin Häusling (Member of the European Parliament) and Deutsche Umwelthilfe e.V. and

11 Dec 2024 · Treffen mit DNR Mitgliedern

Meeting with Marie Toussaint (Member of the European Parliament)

22 Oct 2024 · Nature credits

Meeting with Thomas Waitz (Member of the European Parliament, Delegation chair)

3 Oct 2024 · Klima- und Umweltpolitik

Meeting with Jens Geier (Member of the European Parliament) and Naturschutzbund Deutschland e.V.

11 Sept 2024 · MFF Post-2027

Response to Application of the ‘do no significant harm’ principle to the Social Climate Fund and its possible future extension

28 May 2024

EuroNatur with its network, in close collaboration with CEE Bankwatch Network welcomes the opportunity to provide feedback and input for the application of DNSH to the Social Climate Fund. As an organisation a colaition of NGOs, we have been closely monitoring the application of the DNSH to both RRF and Cohesion Policy Funds at both EU and national level, and believe our findings can help strengthen its use when expanding to new funding instruments. In principle, the tool has recognised the need to take a holistic approach and avoid an investment in one sector leading to a negative impact in another, which is very much welcomed. However, overall our experience is that it ultimately depends on how DNSH is applied in practice on the ground by the national authorities. Greater training and support is needed at national level to ensure those applying the DNSH assessment to programmes/projects have the necessary level of knowledge and expertise to do so in a meaningful way. Without this, the tool is largely ineffective at preventing environmental harm. More detail can be found in the attached file.
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Meeting with Virginijus Sinkevičius (Commissioner) and

5 Mar 2024 · To take over the petition signatures and discuss the Oder River situation

Meeting with Jutta Paulus (Member of the European Parliament)

8 Jan 2024 · Best Belt Europe

Meeting with Thomas Waitz (Member of the European Parliament)

20 Sept 2023 · Vjosa River National Park

Meeting with Marc Botenga (Member of the European Parliament) and CEE Bankwatch Network

8 Nov 2022 · Renewable energies and protection of biodiversity in the RED III and RED IV revisions

Meeting with Martin Hojsík (Member of the European Parliament)

14 Sept 2022 · Renewable energy directive

Meeting with Delara Burkhardt (Member of the European Parliament)

13 Sept 2022 · RED

Meeting with Petros Kokkalis (Member of the European Parliament) and CEE Bankwatch Network

2 Sept 2022 · energy from renewable sources

EuroNatur Urges Nature Protection While Accelerating Renewable Energy

27 Jul 2022
Topic — Guidance on accelerating permitting processes for renewable energy and facilitating power agreements.
Message — EuroNatur demands maintaining environmental assessments. They oppose using "overriding public interest" to bypass laws. They advocate for prioritizing degraded lands.123
Why — This ensures nature restoration goals are met alongside renewable energy deployment.4
Impact — Local citizens lose their democratic right to challenge energy projects.5
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Meeting with Catherine Chabaud (Member of the European Parliament)

11 May 2022 · Protection de la vie sauvage dans le cadre de la révision de la directive RED

EuroNatur Urges Nature Protections in Green Energy Permitting

11 Apr 2022
Topic — EU guidance on accelerating permitting processes for renewable energy projects and power agreements.
Message — EuroNatur calls for renewable energy projects to use strategic, ecosystem-based planning approaches. They demand comprehensive environmental impact assessments and independent scientific oversight for all installations. The group insists that energy activities remain excluded from all protected areas.123
Why — The NGO secures stronger legal safeguards for habitats and participation in early-stage consultations.4
Impact — Energy developers lose fast-track permitting and face costs for independent environmental studies.56
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Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur) and Stora Enso Oyj

31 Mar 2022 · RED III

Meeting with Catherine Chabaud (Member of the European Parliament)

1 Dec 2021 · Energies renouvelables

Meeting with Asger Christensen (Member of the European Parliament)

1 Dec 2021 · RED

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson) and Naturschutzbund Deutschland e.V. and Riverwatch

30 Nov 2021 · To discuss the revision of the Renewable Energy Directive.

Response to Setting out common indicators and detailed elements of the recovery and resilience scoreboard

24 Aug 2021

EuroNatur welcomes the possibility to provide feedback on the draft delegated regulation that will define common indicators to report on progress and to monitor and evaluate the EU’s recovery and resilience facility and the national plans. Given the short period of time that has taken to release 672.5 bn EUR, an unprecedented large amount, monitoring the spending of the recovery and resilience facility will require accurate and meaningful indicators to assess progress against its intended objectives, as well as strong mechanisms to guarantee compliance with all relevant rules and improve the levels of control. We therefore welcome the Commission’s proposal to establish a scoreboard mechanism for assessing the progress of national recovery plans against shared objectives. However, under its current form, the indicators are insufficient and lack in substance to accurate reflect how Member States have financed the progress on green transition, one of the six pillars of the RRF, in particular on biodiversity. There are no meaningful indicators to measure and assess progress with regard to tackling biodiversity loss, in particular for what concerns objectives of EU environmental legislations including the Birds Directive, the Habitats Directive, the Water Framework Directive and the Marine Strategy Framework Directive. Furthermore, the indicators do not align with the targets and objectives set out in the Biodiversity Strategy to 2030, in particular the need to greatly increase efforts to restore nature in the EU. This contrasts with the RRF regulation where the green transition should include biodiversity given that it is a key part of the recovery. Furthermore, given that 37% of the RRF should be towards the green transition, we expect a much higher number of indicators to reflect the importance and wide range of challenges that need to be overcome. If the recovery is to be positive for nature, the efforts and progress should be justified and transparent. The scoreboard should serve to reflect the priorities of the fund and communicate these clearly and accurately to the public. Therefore, to better reflect the contribution of recovery funds on biodiversity, more specific and targeted indicators are needed. This should include: - Hectares of Natura 2000 sites with improved conservation status, - Number of species with improved conservation statues - Hectares of restored habitats/areas (outside and inside Natura 2000). - Hectares of areas with green infrastructure that delivers benefits to biodiversity and ecosystems services - Percentage of population with better understanding and appreciation of biodiversity and ecosystem services - Number of green jobs created that are directly related to management of Natura 2000 sites and restored areas As for indicator 4, this does not indicate any useful information for biodiversity nor does it give any indicator whether these measures have helped achieve a green transition in line with EU environmental legislation or the Biodiversity Strategy to 2030. Furthermore, the involvement of civil society was a precondition for the preparation of the recovery plans and should therefore be reaffirmed in the implementation phase. Indicators related to civic participation in the implementation of the national plans should be added, including the number of meetings with environmental NGOs. Several green investments included in the plans depend on the correct implementation of the Do No Significant Harm principle. A dedicated indicator related to the systems in place to ensure full respect of the DNSH principle should be made part of the Scoreboard, including number of complaints/concerns raised regarding a specific investment.
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Response to Delegated act supplementing the Instrument for Pre-accession Assistance (IPA III)

23 Aug 2021

EuroNatur welcomes this consultation on the priorities of the IPA III. We believe that although the 15 areas set out are important, there should be added emphasis on specific priorities. In particular, the IPA should emphasise the top crises that Europe and the world are currently facing, specifically the ecological crises brought upon by climate change and biodiversity loss. These ecological crises aggravate other problems including natural disasters as well as social problems. For example, the current Covid-19 pandemic is caused by nature degradation and removing wild species from natural habitats. Furthermore, the Multiannual Financial Framework 2021-2027 is committed to spend at least 10% of the budget to tackle biodiversity loss and 30% to tackle climate change. This should therefore be reflected in IPA III. It is also important that environmental objectives be mainstreamed under other thematic priorities of the IPA III, ensuring that environmental-related opportunities are available relating to, for example, gender, human rights, migration etc. In regard to the priorities themselves, we believe that this should reflect the EU’s political commitments. Priority 15 should be further aligned to the EU political commitments of the Biodiversity Strategy to 2030, specifically, it should refer to strictly protecting areas as well as to nature restoration. These are fundamental points that can ensure financial support is provided to protect the last wild river of Europe, the Vjosa River in Albania, or restore one of the most important wetlands in the Balkans, Ulcinj Salina in Montenegro. Also, the delegated act should refer to zero-carbon instead of low carbon. The EU is committed to climate neutrality and achieve zero-carbon emissions. IPA III funds should not be allocated to supporting fossil fuels and the delegated act must ensure that the IPA III funds are used to support energy efficiency and the deployment of sustainable low-impact renewables. It should be highlighted that when referring to “renewable energy sources” these should be “low-impact renewable energy sources” as not all renewable energy sources are compatible with nature, in particular hydropower and wood-biomass. The delegated act should also ensure the inclusion of conditionality and safeguards of IPA III financing to EU standards, including with EU Directives and international commitments (e.g. Birds Directives, Habitats Directives, and the Bern convention). Furthermore, we ask that the Commission set up a platform to engage with civil society, as well as a public system with regular updates, explanation of the process and clear indicators of the spending, which enables civil society to engage, monitor, and contribute to the process in a more efficient and timelier format. We also would like the Commission to ensure that national level public consultation will take place on setting the priorities and planning. As a final note, in the future, it would be better to avoid consultations during summer holidays as this limits the amount of input from stakeholders.
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EuroNatur urges stricter bans on forest biomass in protected areas

28 Apr 2021
Topic — New EU guidelines for demonstrating compliance with sustainability criteria for forest biomass energy.
Message — EuroNatur calls for banning forest biomass from protected areas, old-growth forests, and peatlands to prevent ecosystem degradation. They demand that criteria apply to land managers and smaller installations while restricting materials to waste-based sources.123
Why — Stricter criteria would help EuroNatur achieve its goal of halting the overexploitation of European forests.4
Impact — Forestry operators and energy companies would lose automatic compliance status and face increased inspections.5
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Riverwatch

19 Apr 2021 · European Green Deal, biodiversity and the contribution of Vjosa river

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Mirzha De Manuel (Cabinet of Executive Vice-President Valdis Dombrovskis) and

8 Apr 2021 · Recovery and resilience plans

Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius), Ruben Alexander Schuster (Cabinet of Commissioner Virginijus Sinkevičius)

25 Mar 2021 · To discuss the Vjosa river – how can the EU support designation of a national park.

Meeting with Virginijus Sinkevičius (Commissioner) and

22 Mar 2021 · Meeting on the NGOs campaign for Vjosa river in Albania, seeking to make it a National Park.

Response to EU implementation of the Aarhus Convention in the area of access to justice in environmental matters

5 Jun 2018

Amendment of the Aarhus Regulation is the only means available to the EU legislature to bring the EU into compliance with its international law obligations. On 17 March 2017 the Aarhus Convention Compliance Committee (ACCC) found the EU to be in violation of the Aarhus Convention by failing to provide members of the public with access to the EU courts (CJEU). The findings of the ACCC are unequivocal: The EU fails to comply with the Convention and is recommended to amend the Aarhus Regulation (or adopt new legislation) in the absence of a change in jurisprudence of the CJEU. The lack of agreement on the findings at the last Meeting of the Parties was due to the unprecedented clash provoked by the EU’s attempt to block endorsement of the ACCC’s decision. However some of the other State parties were strongly opposed to the EU’s argumentation. The decision was therefore postponed. During the meeting a number of States voiced concern that the EU was seeking to obtain a special status under the Treaty, a status that is justified neither legally nor politically. By now the EU Member States have also realized the disastrous precedent set and that the EU cannot exempt itself from international law obligations, as demonstrated by the intent of the Council to make an official request based on Article 241 TFEU to the Commission asking them to adopt a legislative proposal. The European Parliament and the EESC have also called upon the Commission to comply with the findings of the ACCC and to revise the Aarhus Regulation. The Commission seems to be the only one hesitating as to the way to bring about compliance. Rather than being “already complete” as stated in the Roadmap, the EU system of remedies suffers from considerable shortcomings. As recognized already in the first ACCC’s findings in 2011, the preliminary reference system under Article 267 TFEU does not meet the requirements of Article 9(3) of the Convention. Over the last years the CJEU has further consolidated its case law in claims brought by NGOs, thereby clarifying that members of the public have no standing under Article 263 TFEU to challenge acts and omissions of EU institutions that are not addressed directly to them. The Aarhus Regulation is the only remaining avenue for the public but it remains unduly restrictive in its current form. Since the adoption of the Aarhus Regulation in 2006 members of the public have attempted to request the internal review of a range of acts of the EU institutions. However to this day only 7 out of 35 requests were declared admissible. Almost all of these requests were denied on the basis of the requirement that an ‘administrative act’ must be of “individual scope”, “adopted under environmental law” and “have legally binding and external effects”. The Compliance Committee found that all of these requirements, as well as other aspects of the Regulation, fail to comply with the Convention. The situation is therefore clear: 1) The EU is a party to the Aarhus Convention in its own right; it therefore constitutes an integral part of the EU legal order. 2) The EU is in non-compliance with the Convention and therefore violates international law and primary EU law. 3) Based on one of the fundamental principles of the international legal order (article 27 of the Vienna Convention of the Law of Treaties), the EU cannot avoid performing its obligations by invoking its internal law. 4) The only option open to the Commission to remedy this violation of international law is to propose an amendment of the Aarhus Regulation. There is no need to conduct a further assessment of “how access to justice works”. For over 10 years the Commission has been presented with legal analyses, an abundance of specific case examples and statistics on access to justice. Nonetheless, the Commission has delayed remedying this issue, even contrary to calls by international bodies and its fellow institutions. The time for studies is over, it is time to amend the Regulation.
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