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European Landowners' Organization asbl

ELO asbl

The European Landowners' Organization represents landowners, land managers, and rural entrepreneurs across Europe, promoting sustainable development and conservation through responsible natural resource management.

Lobbying Activity

European Landowners urge practical changes to EU forest taxonomy

5 Dec 2025
Topic — The European Commission is reviewing environmental criteria for sustainable financial investments in forestry.
Message — The organization calls for practical criteria reflecting the diversity of European forests. They propose extending the monitoring period and increasing the compliance threshold.12
Why — This would lower compliance costs for smaller landowners by reducing reporting obligations.3
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Meeting with Barry Cowen (Member of the European Parliament, Committee chair)

20 Nov 2025 · Speaking at the Forum for the Future of Agriculture

Meeting with Andrea Vettori (Head of Unit Environment) and European farmers and

19 Nov 2025 · Guidance document on the species protection requirements of the Birds Directive

European Landowners urge faster approval of biocontrol farming products

14 Oct 2025
Topic — EU regulation simplifying food safety rules and plant protection product approvals.
Message — The organization requests faster approval of biocontrol products, mutual recognition between Member States, and reactivation of provisional authorizations. They want extended authorization periods and simplified renewals for biological products. They also seek harmonized drone use rules for precision agriculture.1234
Why — This would give farmers faster access to innovative products and reduce compliance costs.56
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European Landowners urge market-based nature credits to reward conservation

30 Sept 2025
Topic — EU roadmap on voluntary nature credits to incentivize biodiversity conservation.
Message — 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.1234
Why — This would enable landowners to monetize previously unvalued ecosystem services and access early financing for conservation efforts.567
Impact — Silent biodiversity in non-iconic habitats risks being overlooked by market-driven credit systems.8
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Meeting with Valérie Hayer (Member of the European Parliament)

15 Sept 2025 · Forest Monitoring

Meeting with Eric Mamer (Director-General Environment) and

3 Sept 2025 · Exchange on ELO’s role and its initiatives regarding biodiversity conservation and land stewardship

European Landowners Organization demands economic viability in welfare rules

16 Jul 2025
Topic — Revision of EU rules to improve animal welfare and phase out cages.
Message — The organization calls for species-specific rules and long transition periods to protect farmers. They seek financial support for new investments and equivalent standards for food imports.123
Why — This would protect farm profitability and prevent competition from lower-standard imports.45
Impact — Animal advocacy groups lose the swift implementation of universal cage-free standards.6
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European Landowners' Organization urges flexible pollinator monitoring rules

15 Jul 2025
Topic — The Commission is establishing a standardized method for monitoring pollinator diversity across Europe.
Message — The ELO requests an adaptive monitoring framework that respects property rights. They advocate for using technology like eDNA to minimize human resource burdens. They demand explicit landowner consent for any monitoring on private lands.12
Why — Landowners would maintain control over property access while minimizing disruptions to farming.3
Impact — Conservationists lose access to precise data if monitoring locations are not public.4
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European Landowners urge focus on farm succession and profitability

14 Jul 2025
Topic — The EU initiative seeks a strategy to attract young farmers to agriculture.
Message — The ELO demands the strategy prioritizes profitability and entrepreneurship over simply increasing farmer numbers. They propose supporting family succession as the primary method for providing land access.12
Why — This approach secures the continuity of existing family businesses and protects private property rights.34
Impact — New entrants without family ties face higher hurdles and less policy support for entry.56
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Meeting with Benoit Cassart (Member of the European Parliament)

8 Jul 2025 · Nutrition animale

Meeting with Barry Cowen (Member of the European Parliament)

25 Jun 2025 · Meeting with the European Landowners Organisation

Meeting with Axel Hellman (Cabinet of Commissioner Jessika Roswall), Paulina Dejmek Hack (Cabinet of Commissioner Jessika Roswall)

24 Jun 2025 · To exchange views on the emerging topic of nature credits, with a view to contributing to the ongoing reflection at the EU level.

Meeting with Elsi Katainen (Member of the European Parliament) and John Deere GmbHCo.Kg

5 Jun 2025 · Biofuels: Growing Sustainable Energy

Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur)

21 May 2025 · Soil Monitoring Law

Meeting with Christophe Hansen (Commissioner) and

11 Apr 2025 · Discussion on exploring innovative solutions on the future of agriculture in response to the Vision on Agriculture and Food

Meeting with Jessika Roswall (Commissioner) and

25 Mar 2025 · Roundtable “Water, Agriculture, and the Food Supply Chain”

Meeting with Herbert Dorfmann (Member of the European Parliament)

12 Feb 2025 · EU Carbon Removals and Carbon Farming Certification (CRCF)

European Landowners demand private manager inclusion in restoration plans

5 Feb 2025
Topic — Defining the mandatory format for EU countries to report nature restoration plans.
Message — ELO calls for a dedicated section on private landowner involvement in restoration. They want more space for climate exemptions and strict protection of property rights.12
Why — Landowners would secure financial compensation and shield property from unauthorized restoration designations.34
Impact — Restoration targets may be weakened if broad climate-related exemptions are allowed.5
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Meeting with Florika Fink-Hooijer (Director-General Environment)

20 Jan 2025 · The discussion focused on the challenges of soil degradation, private conservation of nature and nature credits.

Meeting with Juan Ignacio Zoido Álvarez (Member of the European Parliament)

12 Dec 2024 · Intergroup Biodiversity, Hunting, Countryside

Meeting with Stefan Köhler (Member of the European Parliament) and Nestlé S.A.

12 Nov 2024 · Politischer Austausch

Meeting with Riho Terras (Member of the European Parliament)

7 Nov 2024 · wildlife, countryside

Meeting with Barbara Bonte (Member of the European Parliament, Shadow rapporteur)

6 Nov 2024 · Soil Monitoring Law

Meeting with Herbert Dorfmann (Member of the European Parliament)

17 Oct 2024 · Exchange of views following the Strategic Dialogue on the future of Agriculture

Meeting with Elsi Katainen (Member of the European Parliament)

30 Sept 2024 · Ajankohtaiset metsäasiat

Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur)

13 Sept 2024 · soil & forest monitoring

Meeting with Céline Imart (Member of the European Parliament)

16 Jul 2024 · Déjeuner avec plusieurs députés

Meeting with Norbert Lins (Member of the European Parliament)

16 Jul 2024 · Forum for the Future of Agriculture

European Landowners urge technology-neutral rules for Renure fertilisers

17 May 2024
Topic — This consultation concerns updating the Nitrates Directive to permit recovered nitrogen fertilisers.
Message — The group requests the inclusion of digestates and emerging technologies to ensure technology neutrality. They also oppose the 100kg/ha application limit and redundant pathogen restrictions.123
Why — This would reduce farmers' costs and decrease reliance on external fertiliser imports.4
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European Landowners' Organization urges flexibility in animal transport rules

12 Apr 2024
Topic — The EU is revising rules on animal welfare during transport journeys.
Message — The ELO requests extending journey limits to 12 hours and removing mandatory veterinarian oversight during loading. They advocate for a flexible, risk-based approach to temperature limits instead of prescriptive rules.12
Why — These changes would reduce regulatory burdens and protect profit margins for rural businesses.34
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Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur)

4 Apr 2024 · Soil Law

Response to GreenData4All - Revision of EU legislation on geospatial environmental data and access to environmental information

22 Mar 2024

The European Landowners' Organization (ELO) recognizes the importance of environmental data sharing for informed decision-making and sustainable development. As stewards of the land, we understand the significance of initiatives like GreenData4All in facilitating access to environmental information. However, we also have concerns regarding the potential implications of this initiative on landowners and farmers, particularly regarding data and property rights. Our feedback aligns with the key points detailed in the attached document.
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Meeting with Maroš Šefčovič (Executive Vice-President) and European farmers and

14 Mar 2024 · High level dialogue on forest-based bioeconomy

Meeting with Janusz Wojciechowski (Commissioner) and

14 Feb 2024 · ECR Spanish Delegation & Leaders of the Spanish Agri Association

European Landowners urge more clarity on forest monitoring proposal

7 Feb 2024
Topic — Establishment of an EU-wide observation framework to monitor forest health and management.
Message — The ELO demands clearer rules on data collection and stronger roles for existing national forest authorities. They argue that leaving details to secondary legislation undermines the legitimacy of the current proposal.12
Why — Greater clarity would help landowners avoid administrative burdens and protect sensitive proprietary information about their lands.34
Impact — Environmental groups may see delayed action as forest planning is paused for further legal clarifications.5
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Response to Standing Forest and Forestry Expert Group

23 Jan 2024

The ELO welcomes the intention to reinforce cooperation and the multidisciplinary exchange between the Commision and the Member States related to the forest sector. However, we question the necessity to change the name and nature of the current Standing Forest Committee, which can already incorporate the aims the Commission is planning to reinforce. The changing of the name to forest and forestry is likely to bolster an unhelpful segregation view of the sector, and the change of the nature of the group risks limiting its role and importance, which goes against the professed goals of cooperation and improved exchange between commission and Member States. We would instead focus on making better use of the existing Standing Forest Committee, consulting regularly to cover all the expectations and tasks mentioned under the proposed new article two, which are covered under the current wording of the Council Decision 89/367/EEC due to its broad nature. Maintaining the nature of the Standing Forest Committee is particularly important due to the subsidiarity nature of the forest sector within the EU.
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Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur)

11 Jan 2024 · Soil Health Law

Response to Revision of the plant and forest reproductive material legislation

7 Dec 2023

The European Landowners Organization (ELO) acknowledges and welcomes the ongoing efforts by the European Commission to enhance the legislation on Plant Reproductive Material (PRM) and Forest Reproductive Material (FRM). These initiatives are particularly timely and essential, given the imperative need to adapt to the challenges posed by climate change. The attached document aims to provide an overview of ELO's stance on key aspects of the proposal.
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European Landowners Organization urges quick adoption of gene-editing rules

26 Oct 2023
Topic — EU consultation on a new legal framework for plants produced using genomic techniques.
Message — ELO supports a simplified notification procedure to reduce administrative burdens for breeders. They also advocate for proportionate costs to help smaller businesses compete.123
Why — Landowners gain competitiveness through reduced administrative costs and faster access to sustainable farming tools.4
Impact — Opponents of gene editing lose ground as the EU shifts toward science-led, streamlined approvals.5
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

26 Oct 2023

The European Landowners Organization (ELO) welcomes the opportunity to provide feedback on the recently published Proposal for a Directive of the European Parliament and of the Council amending Directive 2008/98/EC on waste. As an organisation representing landowners, farmers, and rural entrepreneurs, ELO aims to provide through this feedback paper its stance and recommendations on key elements of the proposal, nonetheless concentrating solely on aspects related to food.
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Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

28 Sept 2023 · Soil Health Law

Response to Mid-term evaluation of the LIFE programme 2021-2027

14 Sept 2023

As a coordinator of several (preparatory) LIFE projects, the European Landowners Organization is thankful for the LIFE fund which makes change in the field possible and has proven to be of immense value for nature progress and our environment. Requirement to translate project outcomes into policy language The LIFE fund has the unique position to bridge the gap between the field and the policy level. Not only do the outcomes of LIFE projects contribute to reaching our environmental and climate objectives, they also play a crucial role in informing and evaluating EU policy. Legislative proposals and discussions must be substantiated by scientific proof, fieldwork tests, and project outcomes. However, we regret that there is still often a lack of translation of project outcomes and recommendations into policy instruments. We plead for a better uptake of LIFE projects' best practices and results. We offer some suggestions to help to facilitate this: - The project outcomes should be the source of information, scientific background, and serve as try-outs and pilot projects to support and inform legislative proposals. Therefore a solid two-way exchange should be ensured between each project consortium and the European Commission on the matters of how the policy reflects practice and vice versa. Project coordinators should be in direct and regular contact with representatives from the European Commission (EC). European Commission policy officers should automatically consider the LIFE project outcomes as an integral and direct contribution to their policy work and inform the consortium during the project to which policies or guidelines they (can) contribute. At the end of a project, it should be the responsibility of primarily the EC to guide the translation of the outcomes from project to policy discussions and communicate on how these outcomes can be reflected in legislation. - To make this practical and considering the above suggestions, project calls should be aligned with the Commission Work Programme and calendar as closely as possible. - In addition, it is important for the EC to have the capacity and processes in place to communicate and discuss relevant project outcomes across its DGs. Indeed, outcomes of projects supported by DG ENV can also be relevant and inspiring for other Directorates. Scalability and capacity building Small operators, e.g. landowner associations, mostly lack the capacity or resources to successfully undergo the required application procedure. At the same time, these associations might be the ones most in need of funding to create local and regional impact for nature conservation. If these associations are left behind, the LIFE program fails to involve an important stakeholder group. Support or funding should also be provided to engage smaller operators. Similarly, the outcomes of projects should be effectively shared and distributed among stakeholders in order to scale up the effect of the outcomes. Many LIFE projects that end as being a pilot or a one of a kind would create more benefit if mechanisms of scaling up the use of good practice were put in place. Follow-up of project outcomes Projects involving natural processes, mainly concerning forestry projects, are time demanding. Projects of 3 years can offer the support to build capacity and implement the first actions, but a longer term follow-up is prerequisite to ensure the investment is effectively used and contributes to public well-being. To make this happen a consortium needs expert guidance with consultation from the EC when developing their after-life plan. If a follow-up project seems relevant, a set of funding options for such projects should be offered to the consortium and the application process should be streamlined if the potential success of a project has already been shown. Proper follow-up will require more funding, but it is fully in line with principles of serious and responsible investment of public money.
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Meeting with Florika Fink-Hooijer (Director-General Environment)

13 Sept 2023 · ELO presents its point of view on relevant EU legislation

European Landowners' Organization urges EU to allow chemical exports

26 Jul 2023
Topic — The EU considers banning exports of hazardous chemicals prohibited for domestic use.
Message — ELO requests that the EU continues producing these chemicals under strict safety rules. They suggest sharing information with other countries instead of a total ban.12
Why — This allows European manufacturers to keep market share while avoiding relocation to less regulated regions.3
Impact — Global environmental safety is harmed if production shifts to regions with fewer regulatory controls.4
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Meeting with Jérémy Decerle (Member of the European Parliament)

5 Jul 2023 · Restauration de la nature et grands carnivores

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and European farmers and

15 Jun 2023 · EU forest related policies, including the upcoming forest monitoring proposal

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European farmers and

15 Jun 2023 · EU forest related policies, including the upcoming forest monitoring proposal

Meeting with Tom Vandenkendelaere (Member of the European Parliament) and WWF European Policy Programme and Familienbetriebe Land und Forst Bayern e.V.

23 May 2023 · Nature restoration law

Meeting with Christine Schneider (Member of the European Parliament, Shadow rapporteur)

23 May 2023 · nature restoration

Meeting with Frans Timmermans (Executive Vice-President) and European farmers and

29 Mar 2023 · Forest owners’ perspectives regarding the state of forests in the EU and discussion about EU policies impacting forest-based bioeconomy activities

Landowners urge EU to build common digital farming records platform

2 Nov 2022
Topic — Consultation on common rules for the electronic recording of plant protection product use.
Message — The ELO requests a common EU-wide platform to host integrated data for various farming records. They urge better definitions for electronic records and oppose requirements to track specific application hours. This would simplify procedures and prevent excessive bureaucracy.12
Why — A unified platform would reduce the bureaucratic burden and simplify administrative procedures for farmers.3
Impact — Private software providers may lose market share if a free EU platform is developed.4
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Meeting with Pascal Arimont (Member of the European Parliament)

18 Oct 2022 · Jury EU Bee Award

European Landowners warn pesticide reduction targets threaten food security

19 Sept 2022
Topic — The Commission is reviewing rules to reduce risks from chemical pesticide use.
Message — The ELO argues that proposed pesticide reduction targets are unreasonable and threaten agricultural livelihoods. They request removing bans in sensitive areas and advocate for flexible pest management based on regional conditions.123
Why — This approach would maintain the economic viability of rural businesses and prevent production losses.45
Impact — Environmental groups lose if pesticide bans are lifted for protected habitats and sensitive areas.6
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European Landowners demand flexible, funded nature restoration targets

22 Aug 2022
Topic — The EU is consulting on legally binding targets to restore degraded ecosystems.
Message — They advocate for a bottom-up approach prioritizing qualitative improvements over strict quantitative targets. They call for simplified governance and meaningful involvement of landowners in restoration planning. Financial incentives and compensation are essential to secure long-term engagement from land managers.123
Why — Targeted funding and simplified administration would reduce the financial burden on private landowners.45
Impact — Member States with poor environmental data face penalties regardless of their actual progress.6
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Response to Revision of the EU Pollinators Initiative

8 Jun 2022

The EU pollinator initiative touches upon several policy areas where common EU action already exists. It is vital that farmers, industry and all concerned parties work together to promote solutions that offer favourable outcomes for both insects and agricultural productivity. The ELO welcomes an enforcement of pollinator friendly actions particularly with regard to the loss of habitats in farming landscapes and the impacts of pesticides. However, a reduction of chemical pesticides should go together with the development of environmentally friendly alternatives enabling farmers to ensure plant and human health and food security through an economically viable business. The implementation of some best management practices can incur additional financial cost, but can also lead to positive results in yield. Local stakeholders – citizens, organised civil society, private sector and municipal governments – ought to have greater access to data and should therefore be closely engaged in setting up monitoring schemes and evaluation of rural policies. The ELO welcomes following recommendations: Reward and acknowledge best practices and upgrade the profile of identified high biodiversity farmland in Europe through communication instruments Raise awareness of the positive contribution land managers can make to the enhancement of biodiversity Map existing initiatives at national/regional level Develop and implement a label rewarding active farms for biodiversity
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Meeting with Frans Timmermans (Executive Vice-President) and European farmers and

7 Apr 2022 · European Green Deal and forest related policies, including the new European Forest Strategy for 2030

Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

16 Mar 2022

The European Landowners’ Organization (ELO - https://www.europeanlandowners.org/ ) welcomes the increasing focus on soil and carbon farming in policy debates. Improving organic matter in soils and recognising such efforts are crucial and we look forward to the development of the actions announced in the communication on sustainable carbon cycles (COM (2021)800 final), namely the expected EU regulatory framework for the accounting and certification of carbon removals. The role of markets and private finance in carbon farming should not be underestimated and therefore a broad definition of carbon farming is needed. CAP is the main policy tool that covers agricultural soil in Europe and the ELO welcomes more initiatives and tools to ensure a sustainable management. While implementing such tools, the Commission needs to take into account non anthropogenic reasons of influence on soils such as climate change effect on erosion, and impact on soil quality in general. Although the soil strategy describes what soil health should look like, it lacks a concrete definition of soil health and its indicators. Likewise, we need more analyses on monitoring and reporting of soil and soil biodiversity. As recognized practitioners landowners and managers should actively be part of the expert group dealing with this issue and be a major actor in the development of voluntary Sustainable Soil Management (SSM) and its supporting tools, namely financing. SSM needs to recognize the different realities in land use and land conditions across regions of Europe. Policies should give the right market signals to value soil ecosystem services by society, and thus not putting the burden only on the landowners. The ELO recommends taking into account the different realities in land use across regions of Europe. The ELO welcomes the proposed revision of the directive on the sustainable use of pesticides and continues to support constructive efforts to phase out substances of high risk to health and the environment wherever possible by investing in alternatives and by reinforcing Integrated Pest Management (IPM). The ELO has always been in favour of a sound approach to plant protection, taking into account a broader choice of options based on science and innovation. The EU should therefore dedicate a significant part of Horizon Europe to research and innovation to increase the farmer toolbox. With climate change drastically affecting our weather systems, floods will only increase, and the damage and costs, both financial and environmental, will also increase. The ELO welcomes the fact that COM promotes the exchange of practices between Member States on the relationship between soil, water and sediments and publishes guidelines for sustainable sediment management. While measures such as urban planning and infrastructure are stressing massive importance to deal with flood risks, landowners and managers are in a great position to contribute, as long as they are part of the discussion and their efforts are recognized. While soil management should consider certain water management measures such as extra ground requirement preventing flooding impacts, the ELO recommends to look in priority for other types of solution. If such measures to prevent soil impact are a necessity, the ELO stresses the need for compensation to landowners. Coherence between the different policies affecting soil is a requirement, in addition to their analysis on their cumulative impact on land use. The ELO supports and enhances awareness of the topic and rewards efforts made towards the environment and soil management, namely with the “EU Soil and Land management Award”. https://www.europeanlandowners.org/awards/soil-land-award#:~:text=The%20prize%20rewards%20land%20use,%2C%20sealing%2C%20flooding%20and%20landslides.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European farmers and Conféderation Européenne des Propriétaires Forestiers

16 Mar 2022 · Preparation for EVP Timmermans’ meeting with the representatives of CEPF, COPA-COGECA and ELO on forest related policies

Response to Application of EU health and environmental standards to imported agricultural and agri-food products

14 Mar 2022

The potential direct repercussions of Green Deal criteria for agricultural output and trade in the EU are among the first things to consider when assessing trade impacts. Several studies have attempted to quantify the effects of implementing several of the quantitative targets included in the F2F Strategy on productivity and farm revenue. All forecast a considerable decrease in production generally. Imports from third countries are expected to rise as a result of lower production, according to these analyses. The studies have been criticized for a number of reasons, including the fact that they disregard potential demand adjustments resulting from the F2F Strategy's food policy measures (shift to more plant-based diets particularly through the greater availability of alternative proteins, introduction of sustainability labelling, reduction in food waste). Some dietary changes have the potential to lower EU consumption, but there is skepticism about the efficiency of the proposed techniques for achieving large dietary changes in a short period of time. More thought is needed before implementing the actions announced in the different strategies, including the cumulative effects of them. The European Green Deal's first-round effects have the potential to raise demand for developing-country exports, notably fruits and vegetables. Mirror clauses, on the other hand, are in high demand because of this possibility. They will limit possible import supply to the EU market and also the extent to which EU consumption in exporting nations contributes to rising negative health and environmental pressures. Finally, they act as a direct incentive for exporters to increase their standards in order to keep their lucrative EU market access. CBAM implementation could also contribute to creating a more level playing field for European producers. The European Landowners'’ Organization believes that: • Overall, the EU green Deal is an opportunity to push for development of sustainable agriculture both in Europe and around the world. However, this push must be balanced through the different spectrum of the food chain and also at both internal and global markets. Its success will rely on close cooperation with third countries and support for trade partners by enabling their access to European technology. • The high diversity of environmental conditions and farming practices across the world make it difficult to set up the same measures at an international level. It should also be taken into consideration that new standards should be sustainable in the context of growing population and therefore demand. While it is necessary for the EU to export knowledge, we should also put ourselves in the position to learn. • But the Farm to Fork Strategy is rather incomplete, as it does not consider the implications on trade flows i.e., on the EU's position as a major trade block for agri-food products. While the CBAM would be an appropriate market instrument for off-setting some of the negative overall impacts, but not sufficient in the case of Farm to Fork. • If the EU’s major competitors would not have to comply with the same standards, the consequential leakages would affect the domestic markets as well. A bigger discrepancy between domestic and export chains would be a likely outcome. All food chain will be affected due to increasing costs, traceability requirements and general bureaucracy. Both the external and internal market losses would have negative impacts in rural areas, with the potential increase of abandonment in these areas. • There are a few ways to ensure sustainability is taken into account at trade level: mandatory sustainability standards (that also recognize local issues and might require different approaches), multilateral environmental agreements, sustainability clauses in trade agreements, and labelling requirements.
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Response to Carbon Border Adjustment Mechanism

18 Nov 2021

The European Landowners’ Organization (ELO) supports EU’s objective of climate neutrality by 2050, and encourages the EU to adopt measures addressing carbon emissions globally. Additional market mechanisms are necessary to decarbonise industries globally, while avoiding carbon leakage. We particularly encourage the EU to invest in greener industry, at home and abroad, as a part of the CBAM. We believe the EU could also propose incentives from non-EU countries to export low-carbon products to the EU. This principle is already implemented for sustainable forest products (FLEGT Action Plan). That way, EU competitiveness will not be harmed, and exports from third countries to the EU will continue. The EU should keep in mind that some products targeted by the CBAM are widely used in building construction. An interesting alternative to explore would be to encourage the use of timber to replace the high carbon production materials targeted in the CBAM.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and European farmers and

8 Nov 2021 · Forest based industries

Response to Land use, land use change and forestry – review of EU rules

5 Nov 2021

The European Landowners’ Organization (ELO) strongly supports the goals set by the EU and the Paris Agreement to combat climate change. We believe forestry and land use play a crucial role in this regard. Therefore, the ELO is alarmed by the LULUCF Regulation amendment proposal. In the proposal, the use of forest materials is limited: forests should grow as carbon sinks. Limiting the use of forest resources is not an optimal practice to address climate change. While forests are natural sinks, conserving forests has little impact on forest growth, has a negative impact on forest resilience, drive forests to age, in turn decreasing their carbon sink potential. If adopted, the proposal will put forest sustainability at risk and will turn to long-term suboptimal path to climate change mitigation. In addition, it will shift forest use to other parts of the world, in which forest management abides by lower standards and regulations. By relying on forest sinks, the proposal disregards forest use and jeopardises EU Bioeconomy Strategy. The latter aims at developing sustainable and renewable alternatives to fossil-based materials. The proposal will impede substituting fossil-based materials for other (forest) materials (e.g. construction wood, biomass for energy), slowing down fossil-based material phaseout. Overall, the proposal aims at offsetting other sectors’ emissions (such as agriculture) rather than finding a solution to emissions. The responsibility of implementing the LULUCF Regulation will be devolved to forest owners and the forest industry. Forest growth results from sustainable forest management practices and investments of forest owners and forest industry. Abiding by the proposed regulation, they will not be able to engage in sustainable forest management, endangering forests sustainability. The proposed LULUCF Regulation will take down states’ economy which rely on productive forests and have a dramatic impact on forest-dependent people. It also alters the power balance between the EU and its member states as the LULUCF will have direct implications on landowners possibility to use their lands and forests. The proposal threatens property rights. It must also be noted that the amendment proposal is not consistent with the Renewable Energy Directive amendment proposal. The RED introduces sustainability criteria for forest biomass. It commands to use forest biomass and replace the used biomass (e.g.: reforest a piece of land). Using the biomass contradicts the LULUCF proposal, that advocates to keep forests standing. Using biomass is consistent with our understanding of effective and sustainable forest use for climate change. Developing forest use and circular economy is the way to go to tackle climate change by mitigating carbon emission while increasing the size of carbon sinks. Forest materials are long-term carbon storage. Encouraging their use will add to the decreasing as aging forest sink capacity and boost their resilience. Enhancing the use of forest material in wood-processing industries (e.g. construction wood, furniture, bioenergy) will foster forest growth. In turn, a dynamic and effective use of forest resources will participate to develop local, national and European bioeconomy. It will also have a positive impact on circular economy, in which all parts of wood (from timber to biomass) are used. Forest-dependent people will not be at risk. Using forest material as substitute for fossil-based materials will allow the EU to phase out from fossil-based materials, which is a pre-condition for carbon neutrality. Therefore, we insist the EU should encourage forest use and growth in the LULUCF Regulation by explicitly mentioning and promoting it within the Regulation. We also encourage the EU to develop targets for substitutions, and optimisation of harvest together with increasing the size of carbon sinks in growing timber. Forest inventories would be extended to properties where it is not in use.
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Response to Sustainable food system – setting up an EU framework

21 Oct 2021

The European Landowners’ Organization welcomes the publication of the roadmap on sustainable food system framework initiative. It is important for European landowners to have EU-wide Marketing Standards that ensure harmonization and a level-playing field for producers’ access to the market, while being important means in tackling food fraud. However, harmonized standards do not always mean harmonized interpretation. We call for the European Commission to pay special attention to the definition of eventual minimum standards based on sustainability principles for a fair and just implementation. The use of sustainability labels has increased recently, driven by consumers demand, but so have the number of lawsuits in the US from different NGOs which accuse misuse of sustainability claims and labels by food beverages companies, arguing they are deceptive and lack clarity in the definition of sustainability. The existence of voluntary standards can be an indicator for consumers’ interest in certain product characteristics (e.g., organic, PDO, TSG etc.). The most popular voluntary standards producers use to increase their market competitiveness should thus be taken into consideration before drafting a proposal. While considering a minimum requirement of sustainability for a product to reach the market, we need to also keep in mind that consumers, although asking for more sustainably produced products, are not always willing to pay more for them. Also, consumers’ preferences shift over time. The Commission has therefore to make sure to introduce only those sustainability standards that consumers will pay for. For this to happen, detailed studies should be conducted to assess not only their stated preferences, but also their acquisition behaviour. Finally, the potential effect on third countries shouldn’t be neglected. Depending on how ambitious the new sustainability standards will be, we might encounter food shortages or import prices increase, should third countries not produce as sustainably as Europe.
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Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and European farmers and

2 Jul 2021 · European Green Deal and the next EU Forest Strategy

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European farmers and

2 Jul 2021 · European Green Deal and the next EU Forest Strategy

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives and

28 Apr 2021 · to discuss the preparation of the EU Forest Strategy.

Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and European farmers and

28 Apr 2021 · to discuss the Preparation of the EU Forest Strategy

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

19 Mar 2021

More than 40% of the historical building heritage in Europe is privately-owned. The European Historic Houses (EHH) and the European Landowner’s Organisation (ELO), which speak for millions of family-owned heritage houses all over Europe represent some of the potentially most endangered and fragile houses which could be impacted by the recently launched Commission’s Renovation Wave initiative. EHH and ELO are keen to actively contribute to the common climate and environmental objectives and are in favour of making the existing building stock more energy efficient. We are convinced that better-performing buildings can ensure healthier and safer living environments for all citizens and for future generations. Investing in energy efficiency can significantly reduce utility costs by contributing at the same time to the overall fight against climate change. By the same token, we see significant potential for job creation, especially at the local level, via the thousands of construction SMEs and craftsmen in the sector. By means of massive state investments, a new market in the field of digitalisation, circular economy, and energy retrofitting can be created and developed. However, it is of the utmost importance to understand that many energy efficiency measures cannot be applied without seriously damaging and altering what is for many the very essence of the European continent: its cultural heritage. The inclusion of historical buildings within the scope of the new Directives risks more than just the buildings, but the wider impact of cultural heritage on the economy. EHH and ELO, therefore, suggest taking measures to acknowledge the uniqueness of cultural heritage within the built real estate sector. Full statement enclosed here:
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Meeting with Janusz Wojciechowski (Commissioner) and

3 Feb 2021 · New EU Forest Strategy.

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

The ELO – European landowners’ Org. welcomes the recognition given to the agriculture and forestry activities that have been included in the scope of the proposed regulation. However, the text contains several vague and undefined concepts, lacking scientific support as well as basic requirements for legal certainty. Relaying on delegated acts to regulate issues of this importance and without sufficient involvement of experts and expertise with sector-specific knowledge and sufficient understanding of forestry, farming and their value chains, can lead to outcomes far from the initial objectives of the sustainable finance regulation. Potential restrictions in investments in land-based sectors can lead to less sustainable land uses, that can also put into jeopardy the expansion of Bioeconomy. Due to its vagueness, the proposed taxonomy must be in line with existing EU legislation and existing control and monitoring mechanisms, namely in the CAP and the recently decided RED II. This would also minimise the risk of excess complexity for unwanted outcomes. For example, there is no clarity on the definition and even on a potential advantage regarding improved forest management and regeneration and “Close-to-nature forestry”. It increases the complexity of the system by relying on concepts that are not clear and thus not with implementation issues. The proposed sustainable finance regulation must rely more on the definition of sustainable forest management (SFM) agreed upon at the Ministerial Conference on the Protection of Forests in Europe and that was referred to in the 2013 EU Forest Strategy. The criteria should apply at country-level and fit with the long-term cycles of forests, thus relying on Member States’ legislation and bodies for assessing the sustainability of investments is a better option than developing an additional new system of screening criteria. The requirement of forest management plans for forest holdings should strictly follow the respective legislation of Member States, especially regarding provisions for their content, disclosure of information, auditing and reporting intervals. Besides, the provisions on forest management plans should be consistent and in line with the Rural Development Policy 2014-2020 that acknowledges the small-scaled nature of private forest ownership in the EU. Market-based solutions, such as forest certification and the forestry criteria of the Climate Bonds Initiative could be carefully used considering their voluntary nature and that they are only one of many means of proof. Sustainable finance cannot restrict itself to conservation practices. If we are serious about being carbon neutral by 2050 the land-based sector must be allowed to contribute. For instance, the substitution effect of using biomass instead of fossil-based material need to be recognized. Residues and by-products from the forest and agriculture sectors are utilised with increased resource efficiency co-producing heat, power, biofuels and bio-products by advanced technologies, which is a prerequisite to reach fossil-free energy systems. Access to finance is crucial to modernise the land-based sectors, improving its sustainability and the contribution to a carbon-neutral and circular bioeconomy. The taxonomy legislation needs to go in this direction and therefore we expected it to be based on science, sectorial knowledge and proven experience.
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Response to EU Forest Strategy

4 Dec 2020

We welcome the publication of the roadmap, as the current EU Forest Strategy runs until the end of 2020. The EU Forest Strategy must remain the main policy tool to integrate European forests and forestry into all other policy areas. It should provide a holistic and inclusive framework, with sustainable forest management (SFM) principles at its core. Therefore, we welcomed the Council conclusions (10/11/2020) that underlined the need for coherent forest-related policies after 2020 & call for a new "balanced & strengthened" post-2020 Forest Strategy as well as the report from the European Parliament. The repercussions of climate change on our rural areas are obvious, recent years show, without any doubt, the hugely detrimental effects of heatwaves, with extended drought periods, pest and diseases outbreaks and a new trend of mega-fires. These have massive immediate economic impacts but also environmental consequences. Climate change is influencing our complex ecosystems in many ways, namely by shifting the boundaries of today’s biogeographical regions. For forest ecosystems, the long lifespan of trees does not give much flexibility for rapid adaptation to climate change. A passive response is not an option. There is a pressing need for knowledge-based policy tools to face these challenges. Therefore, more attention needs to be paid to research and innovation in forests and forestry, and training and skills. Becoming climate neutral by 2050 requires the modernization of all the land-based sectors to become more sustainably efficient and resilient. If we are serious about systemic change, more attention needs to be given to a circular bioeconomy and more value needs to be given to the provision of ecosystem services. The discussions so far have been light on the multiple benefits forests provide to society and the benefits which forest-based bio-industry could contribute to a more sustainable and climate-neutral society. Maximizing synergies and minimizing potential trade-offs between the diverse needs for forests from society requires a thorough analysis, forest sector know-how. While we agree with the aims detailed in the roadmap, the economic and social considerations cannot be an afterthought. There must be a collective effort to remunerate the ecosystems services provided by well-managed forests. For instance, the development of “carbon farming” and certification of carbon removals should be the most effective way of boosting removals by directly supporting those who are in the best position to do so. These approaches to value ecosystems are a must more effective and inclusive way to protect nature than just strict protection. Finally, the involvement of experts and stakeholders leads to more shared ownership of the strategy, and therefore also more effective policy implementation.
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Response to Protecting biodiversity: nature restoration targets

2 Dec 2020

1/ Properly access the implementation of a new binding nature restoration target: Evaluating ecosystem services is a delicate exercise. ELO has itself launched a survey and research on the evaluation of cultural ecosystem services (currently undervalued) and we are fully implicated in the MAES working group with the European Commission. This leads ELO to think that a binding target would be premature. Instead, we would favour a robust and efficient action plan to reverse the current trend of degradation of ecosystem services. It needs to be assessed against an impact assessment. This requires the full involvement of the land managers and the necessary financial resources to support their actions as a sign of the EU commitment. The ELO is still advocating payments for ecosystems services. Unfortunately, the EU fails to adopt what would constitute a decisive set of measures for land managers. ELO regrets that this measure is not even mentioned as an essential instrument in the Strategy. ELO requests and insists on the importance of having a continuous and serious dialogue in the scientific field. We do not yet know everything about the evolution of species and habitats, their ecosystems and the impact of climate change. Let us remain modest and remember that nature and animals are constantly evolving and participate in complex dynamics that must be regularly studied. To achieve Favorable Conservation Status, ELO considers it is essential to create a “partnership in the countryside” so that we are able to combine this scientific knowledge with the practices of managers and experience in the field. ELO will support a binding approach if and only if, all these prerequisites are taken on board and fully evaluated. 2/ Work with land managers to improve biodiversity: Farmers and foresters are ready to engage for biodiversity but they need to understand how the suggested target of 10% agricultural area under high-diversity landscapes will be designated and articulated with the new CAP. Will it be included in the eco-scheme architecture and how will it be paid for? Overall, much will be asked to the Member States, starting with the adoption of the CAP Strategic Plans themselves. We fear that we will end up with a very diverse set of rules and funding systems that would create even more uncertainties for farmers and foresters. In parallel, pollinator decline must be reversed and land managers through multifunctional field margins can play an important role. The EU pollinators initiative was particularly timely and we would favour more ambitious programmes with a clear link with the new CAP and the Farm to Fork Strategy. In the same spirit, the proposed reduction of chemical pesticides should go hand-in-hand with the development of more environmentally friendly alternatives enabling farmers to ensure Europe’s and the world’s food security. This requires actions to enable faster deployment of biological control methods and products by revising the regulatory approval process for such products and to review the regulatory provisions affecting efforts to internalising plant protection in crop genotypes by utilising the best modern biotechnology can offer. 3/Ensure objectives are accompanied by the necessary financial incentives: ELO welcomes the proposed investment priorities and the European Commission’s exercise suggesting 20 billion euro/year be spent on nature. Synergies with other EU funding flows are particularly important. There is a need to come up with new sources of biodiversity funding to complement whatever can be made available through public funds. For example, market-based solutions such as biodiversity offsets to development, tax credits, incentives as well as mechanisms for compensation to organize the engagement of partners. Payments for ecosystem services, tax benefits, and labels for nature conservation management or durable natural products are being explored by an ELO Life program “Land Is Forever"
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European farmers and

25 Nov 2020 · Exchange of views on the upcoming EU Forest Strategy

Meeting with Agne Razmislaviciute-Palioniene (Cabinet of Commissioner Virginijus Sinkevičius) and European farmers and

25 Nov 2020 · Exchange of views on the upcoming EU Forest Strategy

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and European farmers and

25 Nov 2020 · Meeting with forest stakeholders on the review of the Forest Strategy

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and WWF European Policy Programme

10 Nov 2020 · European Green Deal, agriculture and the 3 billion trees initiative

Response to Action plan for the development of EU organic production

23 Oct 2020

The European Landowners’ Organization (ELO) welcomes the Commission’s ambition to enhance the sustainability of the EU’s food system. The farmers and rural business owners represented by ELO are more than willing to contribute to this endeavour and are committed to adapting their practices to meet the sustainability goals set by the EU. The ELO recognizes that there is a growing interest from consumers for organic food products and producers are already responding to market signals and increasing the production of these products. However, the mandatory push to achieve 25% of European farmland under organic production by 2030 seems to be set arbitrarily. What data has been used to develop this target, and on what grounds should this farming approach be supported in comparison to other sustainable practices? In light of these interrogations, the ELO would like to raise three points of discussion: 1. Such a significant shift towards organic farming should be accompanied by a feasibility study, taking into account the cumulative effects of the other objectives set by the European Green Deal, particulalry on the economic and environmental impacts at farm level. The shift will undoubtedly affect land use in the EU and will affect food prices. The premium price thar farmers get for organic products will be affected bystipulating a mandatory area for organic farming. It is important that the commission considers the impacts of their proposals. More information on this point here: https://www.europeanlandowners.org/images/Green_Deal/200511_Land_management_at_a_time_of_great_challenges_Final.pdf 2. The ELO regrets that Commission is solely relying on organic farming to achieve the goals set by the F2F and Biodiversity strategies. While we understand that organic farming is an approach more familiar to consumers, the claims about its nutritional and environmental benefits are based mostly on public perception rather than being fact-based. Therefore, they should be properly assessed, particularly when comparing this approach to other well established sustainable farming approaches. We are not aware of such an assessment being made public by the Commission so far. If the claims are not properly substantiated, support for organic products should continue to be left to the market and the commission should rather support farmers towards more sustainable farming practices, whose benefits are well established. Read more here: https://portals.iucn.org/library/sites/library/files/documents/2020-017-En.pdf 3. The ELO strongly supports the Commission’s ambition regarding innovation and technology for improving the sustainability of farming. The EU has long been at the forefront of agrotechnology, which has greatly contributed to the economic welfare of the Union. New developments in seed breeding could be used essential tools for making our agriculture more sustainable. However, the organic label and its requirements restrict considerably the use of such innovative tools for farmers. It is important that if organic farming is to be chosen as the practice of predilection by Commission, the requirements for obtaining the organic label are made flexible enough to evolve along with the innovative methods and varieties developed by the EU.
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Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

9 Oct 2020 · Exchange on CAP reform and Green Deal Strategies

Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius)

10 Sept 2020 · To discuss EU BIODIVERSITY and PRIVATE LAND CONSERVATION

Response to Sustainable use of pesticides – revision of the EU rules

4 Aug 2020

The European Landowners’ Organization welcomes the Commission’s initiative to assess and evaluate the implementation of the SUD. Our members are looking forward to contributing to the consultation and to bring their expertise on this topic. There are a few key points that we would like to see addressed regarding the evaluation of the SUD (A) as well as the impact assessment of a reinforcement of the Directive (B). A. • As mentioned by the Commission, the SUD has been unevenly implemented in Member States. However, some Member States did carry out concrete measures for farmers in order to reduce their use of pesticides and to ensure some degree of IPM’s uptake, like Sweden or Portugal. More needs to be done to support its implementation, namely by sharing what has been working and not working, among Member States. • The ELO is pleased to read that the Commission emphasizes the need for alternative methods and new technologies for farmers to reduce pesticides’ use. There is however no exhaustive comprehension of what alternatives are considered for support by the Commission. We would recommend to list and assess alternatives which already exist as well as those currently in the pipeline (such as New genomic Techniques and or biocontrol). Assessments of new techniques and technologies could result in better regulation when it is failing or lacking or promotion schemes to ensure better uptake among farmers. It is crucial that primary producers have access to efficient and affordable tools for controlling pests and diseases in due time. The viability of their business and the food security of the Union depend on it. B. • Policy objectives brought forward after evaluation and impact assessment of the SUD have to be supported by verifiable and measurable evidence. Targets such as on organic farming and pesticides have to be justified by strong facts and figures in order to properly inform co-legislators and impacted stakeholders on the rationale and goals behind these objectives. The ELO worries that such evidence has not been made available to the public so far. • As outlined in its roadmap, the Commission is hoping that a reduction in the use of pesticides will result in an increasing shift towards organic farming. Because the targets on pesticides and organic farming are interlinked, it is crucial that the impact assessment on the SUD is conducted in parallel with the one on organic farming. We believe that before promoting such a shift, one has to assess if the market for organics products is ready to absorb a rapid growth in production and it's price effects. Also, the economics of land use change and input restrictions need to be considered together in any impact assessment.
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Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski)

7 Jul 2020 · Opening address at the FFA 2020 dinner - lessons to be learnt from COVID-19 in revitalising the fight for creating a more resilient and sustainable food system, with special mention to the Green Deal & the Farm to Fork Strategy.

Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

24 Jun 2020 · Exchange of views on the EU Green Deal and its forthcoming strategies

Response to Minimum standards for benchmarks labelled as EU Climate Transition and EU Paris-aligned Benchmarks

6 May 2020

Generally speaking, the ELO supports the idea of this regulation, but we recommend a small change to clarify the following: In the “supplementing Regulation (EU) 2016/1011 of the European Parliament and of the Council as regards minimum standards for EU Climate Transition Benchmarks and EU Paris-aligned Benchmarks” where is stated that: ”The sectors listed in Sections A to H and Section L of Annex I to Regulation (EC) No 1893/2006 of the European Parliament and of the Council, including oil, gas, mining and transportation, are sectors that highly contribute to climate change”. We would be more precise, changing the word “including” to “especially” or similar, to be more targeted and emphasize the responsibility of these particular sectors. The ELO represents the collective voice of landowners, managers and farmers across Europe. Their businesses and private properties are the core for a sustainable and prosperous countryside. The ELO addresses issues that affect European rural areas, which represent over 82% of the EU's territory (48% farmland and 36% forest) and is home to around half its population (consisting of farming communities and other residents).
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Response to Farm to Fork Strategy

16 Mar 2020

The European Landowners’ Organization (ELO) welcomes the Commission’s initiative to implement a set of policies leading the EU into the transition towards a sustainable food system. The ELO believes the agricultural sector is crucial in this endeavor and supports the idea that landowners and managers can contribute substantially to sustainably producing food as well as environmental benefits, as long as these are adequately compensated for, and they are supported in this work by the appropriate authorities. In this submission we would like to stress three points; the setting of reduction targets on Plant Protection Products (PPPs) and a general Risk Assessment of the revision of the Sustainable Use Directive (SUD) and the policy cohesion between the new demands of the Farm to Fork (F2F) Strategy and the CAP reform. The ELO supports a reduction of the use of harmful PPPs on crops grown in the EU. In doing so, ELO asks the Commission to use a risk-based model for their assessment and by conducting a risk and an impact assessment before setting a reduction target on PPPs. The establishment of the risk has to be science-based in order for it to be measurable and comparable. In light of findings of measurable risk, European authorities must cooperate with all stakeholders but prioritise those whose livelihoods may be impacted. Furthermore, the ELO strongly recommends conducting an impact assessment before restricting PPP use under the F2F Strategy, as well as deliver clear guidance to farmers regarding credible alternatives should substances fall under increased regulation. Reduction in their use could have a negative impact on revenues for primary producers as well as on the prices of food. Additionally, the EU will need to import agricultural products from producers who will still have access to a non-reduced level of PPPs. This raises the question of compliance controls on imports as well as of unfair competition for farmers from the EU. Reduction targets should therefore be set after considering their economic and social impact. These assessments should also be applied to the rest of the targets set by the F2F Strategy. The Commission will have to ensure the policy cohesion between the F2F Strategy, in particular the revision of the SUD, and the CAP. Requirements for farmers have to be consistent for the two set of policies in order to avoid any confusion and compliance burden. Finally, the ELO represents the collective voice of landowners, managers and farmers across Europe. Their business and private properties are the core for a sustainable and prosperous countryside. The ELO addresses issues that affect European rural areas, which represent over 82% of the EU's territory (48% farmland and 36% forest) and is home to around half its population (consisting of farming communities and other residents). Therefore, it is crucial that the ELO remains a member of the Advisory Group on the Food Chain, Animal and Plant Health.
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Response to Illegal logging – evaluation of EU rules (fitness check)

28 Feb 2020

The ELO represents the collective voice of landowners, managers and farmers across Europe. Their business and private properties are the core for a sustainable and prosperous countryside. The ELO addresses issues that affect European rural areas, which represent over 82% of the EU's territory (48% farmland and 36% forest) and is home to around half its population (consisting of farming communities and other residents). ELO stands for sustainable and fair business. We consider that the EUTR is “fit for purpose” and continues to be the main tool to minimize the risks of unfair competition in market. The principle of due diligence must remain central and the implementation of the EUTR should be improved, particularly in areas deemed riskier. We are also supportive of extending EUTR to cover all forest-based products.
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Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

20 Jan 2020 · Present their organization and its objectives, including the labelling system for rural land management (wildlife estate initiative) that ELO runs, address the issue of private land conservation, and raise some concerns in relation with large carnivores and the Green Deal, in particular as regards forests.

Meeting with Karmenu Vella (Commissioner) and

24 May 2019 · Wolf study

Meeting with Daniel Calleja Crespo (Director-General Environment)

17 May 2019 · Study on large carnivores

Meeting with Daniel Calleja Crespo (Director-General Environment)

19 Nov 2018 · Wolves

Meeting with Karmenu Vella (Commissioner) and

13 Jul 2018 · EU Large Carnivore Platform , Wolfs, Nature Directives

Meeting with Phil Hogan (Commissioner)

12 Jul 2017 · Agri Matters

Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan)

12 Jul 2017 · CAP modernisation and simplification

Meeting with Phil Hogan (Commissioner)

28 Mar 2017 · Address conference

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan) and Certisys

18 Nov 2016 · Reform of organic regulation

Response to Criteria to identify endocrine disruptors for plant protection products

28 Jul 2016

The European Landowners' Organization (ELO), created in 1972, is a unique federation of national associations from the 28 EU Member States and beyond, which represents the interests of landowners, land managers and rural entrepreneurs at the European political level. Independent and non-profit making, the ELO is the only organization able to stand for all rural entrepreneurs. The ELO promotes a prosperous countryside through private property dynamism. First, we believe that scientific evidence should be at the heart of any decision being made regarding crop protection products, including those on ED. We believe that such a basis should be required for any further discussion, and urge all parties to refrain from appeals to emotion or distortion of scientific evidence. Second, we have long stated that the use of hazard-based criteria regarding crop protection does not represent a useful method of evaluation, as it does not take into account exposure, proper information for farmers and other users, potency or other relevant factors. We therefore believe that hazard characterisation elements such as lead toxicity, severity and reversibility must be part of the criteria for endocrine disruption. Third, we submit that the choice of roadmap option number 2 and 3 will negatively impact small and medium size enterprises, representing most farmers. This is indeed borne out by the executive summary of the impact assessment: “it was assumed in the IA that a decrease of availability of PPP or BP would negatively affect SMEs”. With most European farmers already in financial distress, and with current harvests already looking negative for the year, we express our deep concern that the European Commission has chosen to include 2 and 3, while fully aware of its negative impact on the farming sector. Fourth, we urge that farmers in all EU Member States should have multiple options for crop protection in order to maintain an effective set of tools that can manage the development of resistance. Such management is already at risk from the limits placed on European farmers, and a further removal of more active ingredients due to severe application of endocrine disrupting criteria would only worsen an already bad situation. Fifth, we believe that regulating necessary active ingredients and crop protection products through derogation represents a fundamental undermining of scientific principle as well as the basic regulation 1107/2009 and should not form the basis of long-term, reliable decision making. Regulation by derogation will inevitably create uncertainty for our members. However, should all reasonable options be exhausted, we support the maintenance of these derogations, but we believe them to be a measure of last resort, rather than a first choice. Sixth, we strongly urge that categorisation of ED has no place in the current proposal. Categories are both not required under the current regulation and will not assist in decision making processes or delivering clarity for farmers and consumers. Furthermore, the development of categories does not fit with any scientific evidence. We believe that the establishment of categories will inevitably lead to misinformation of consumers, as well as highly time-consuming debates over the categorisation of each individual chemical that may have endocrine disrupting properties. This would not only create uncertainty in the current marketplace, but would also be prohibitive in the development of new active ingredients. Finally, we would like to stress the negative consequences the application of severe ED criteria will have for EU farmers to compete on the global market place in terms of both reduced production and the creation of further uncertainty. Should a severe application of ED criteria lead to a zeroing out of import tolerances, the consequences for EU agricultural imports, which are vital to livestock and other sectors, would be dire.
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Meeting with Phil Hogan (Commissioner)

22 Mar 2016 · Keynote address on 9th Forum for the Future of Agriculture

Meeting with Daniel Calleja Crespo (Director-General Environment)

3 Dec 2015 · ELO's activity-Biodiversity