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Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners

MTK

MTK represents Finnish farmers, forest owners and rural entrepreneurs, working to improve their economic wellbeing and promote sustainable use of rural resources.

Lobbying Activity

Meeting with Katri Kulmuni (Member of the European Parliament)

29 Jan 2026 · maitostrategia, MFF ja CAP

Meeting with Pekka Toveri (Member of the European Parliament) and Neova Oy

11 Dec 2025 · Current Topics in EU

Meeting with Eero Heinäluoma (Member of the European Parliament)

10 Dec 2025 · Biotalous

Finnish forest owners urge practical, simplified EU taxonomy criteria

4 Dec 2025
Topic — The consultation reviews technical screening criteria for the EU taxonomy environmental delegated act.
Message — MTK requests practical climate analysis criteria and higher thresholds for small-scale forest owners. They advocate for including Nordic peatland management and excluding mandatory management plans from EU law.12
Why — These changes would lower administrative burdens and technical costs for private family forest owners.34
Impact — Environmental groups lose if fertilization and peatland management are deemed sustainable under taxonomy rules.5
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Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)

4 Dec 2025 · Last official visit to Brussels while holding the Presidency position.

Meeting with Eero Heinäluoma (Member of the European Parliament)

3 Dec 2025 · Ajankohtaiset asiat

Meeting with Peter Wehrheim (Head of Unit Research and Innovation)

20 Nov 2025 · Introduction of MTK’s work in developing nature value markets, along with a discussion on the EU Bioeconomy Strategy and the sustainable use of forests.

Meeting with Ion Codescu (Acting Director Environment)

20 Nov 2025 · 1. Bioeconomy strategy 2. Forest Strategy 3. Nature Credits

Finnish farmers urge simpler organic rules for Nordic conditions

18 Nov 2025
Topic — Revision of EU organic rules to simplify production standards and trade requirements.
Message — MTK requests removing the mandatory 48-hour medicine withdrawal period and extending exemptions for conventional protein feed. They also call for flexible greenhouse rules to protect Finnish potted herb production.123
Why — Simplification would lower operational costs and help Nordic farmers compete in the organic market.45
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Finnish Farmers Urge Economic Incentives and Clearer Rules for Circular Economy

6 Nov 2025
Topic — EU Circular Economy Act aims to boost sustainable production and recycled materials supply.
Message — The organization requests economic incentives or legislation to make circular materials competitive with virgin materials. They call for EU-wide clarification of end-of-waste rules to enable free movement across member states. They emphasize that obligatory legislation must recognize size differences and not impose one-size-fits-all solutions on smaller operators.123
Why — This would make circular materials economically viable for their members to use or produce.45
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Meeting with Elsi Katainen (Member of the European Parliament)

6 Nov 2025 · Trade policy

Meeting with Elsi Katainen (Member of the European Parliament)

5 Nov 2025 · Topical issues in EU agriculture policy, MFF

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)

5 Nov 2025 · Certification Forestry issues in Finland

Meeting with Katri Kulmuni (Member of the European Parliament)

23 Oct 2025 · AdBlue

Meeting with Katri Kulmuni (Member of the European Parliament)

15 Oct 2025 · Metsien monitorointi, metsäkomitea, LULUCF

Finnish Farmers Urge Relaxed EU Pesticide Approval Rules

14 Oct 2025
Topic — Proposed amendments to EU food and feed safety regulations affecting pesticide authorizations.
Message — The organization requests more flexible pesticide approval criteria and faster authorization processes. They argue current rules are too strict and slow, causing farmers to lose essential crop protection tools without adequate replacements.123
Why — This would expand farmers' access to crop protection products and reduce compliance costs for pesticide companies.45
Impact — Environmental and public health protections lose ground as higher-risk pesticides gain approval.6
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Meeting with Brigitte Misonne (Acting Director Agriculture and Rural Development)

14 Oct 2025 · Nordic Seminar on Sustainable Livestock Production - Climate, Biodiversity & Animal Welfare

Meeting with Elsi Katainen (Member of the European Parliament)

14 Oct 2025 · Mercosur

Meeting with Katri Kulmuni (Member of the European Parliament)

14 Oct 2025 · Ajankohtaiset maatalousasiat

Meeting with Katri Kulmuni (Member of the European Parliament)

14 Oct 2025 · Ajankohtainen maatalouspolitiikka

Meeting with Aura Salla (Member of the European Parliament)

13 Oct 2025 · MMF and the EU's Competitiveness Fund

Meeting with Pierre Bascou (Deputy Director-General Agriculture and Rural Development)

13 Oct 2025 · Farmers’ position in the food chain, especially UTPs

Finnish Farmers Warn Against Stricter EU Pesticide Approval Requirements

8 Oct 2025
Topic — EU regulation on evaluation and authorization of plant protection products.
Message — The organization opposes making approval requirements stricter and more complex. They argue the current system is already extremely demanding and slow, causing useful active substances to disappear from the market without replacements. They want delayed study submissions to be accepted in evaluations to prevent unnecessary withdrawals.123
Why — This would maintain access to effective pest control tools and prevent crop losses.45
Impact — Environmental and health protections could weaken if higher-risk substances receive approval.6
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Meeting with Katri Kulmuni (Member of the European Parliament) and KEMIJOKI OY

2 Oct 2025 · Ajankohtaiset EU-asiat

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)

2 Oct 2025 · Sustainable Livestock Work Stream, Future CAP for Livestock sector.

Meeting with Katri Kulmuni (Member of the European Parliament)

1 Oct 2025 · Ajankohtaiset EU-asiat

Finnish Farmers Urge Voluntary Nature Credit Market Without EU Legislation

30 Sept 2025
Topic — EU roadmap for developing nature credits to fund biodiversity protection and restoration.
Message — MTK requests that nature credit markets remain voluntary without mandatory EU legislation or harmonization. They emphasize agricultural producers and forest owners must participate in all development stages and pilot testing. The system must allow nature credits alongside profitable food and timber production.123
Why — This would preserve their flexibility to pursue diverse income streams and management approaches.45
Impact — Biodiversity advocates lose stronger standardization and mandatory requirements for nature protection.67
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Meeting with Katri Kulmuni (Member of the European Parliament)

30 Sept 2025 · Ajankohtaiset EU-asiat

Meeting with Elsi Katainen (Member of the European Parliament)

26 Sept 2025 · Kauppa- ja maatalouspolitiikka

Meeting with Pekka Toveri (Member of the European Parliament) and Kemira Oyj

24 Sept 2025 · Current EU Agricultural topics

Meeting with Eero Heinäluoma (Member of the European Parliament)

17 Sept 2025 · Ajankohtaisasiat

Finnish Farmers Urge EU Support for Eastern Border Economy and Agriculture

16 Sept 2025
Topic — EU initiative to support eastern regions affected by Russia's war on Ukraine.
Message — MTK requests targeted regional policy measures including tax solutions, pilot projects like student loan refunds, support for renewable energy development, and stronger agricultural financing. They emphasize that economic vitality and agriculture are essential for border security and crisis resilience.1234
Why — This would improve business conditions, attract investment, and ease financing constraints for their members' farms and rural enterprises.567
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Finnish forest owners urge EU to drop mandatory sink targets

16 Sept 2025
Topic — This consultation proposes amending European Climate Law to include 2040 carbon targets.
Message — The organization requests that forest carbon sink targets be indicative rather than mandatory. They argue for a focus on replacing fossil-based materials with renewable bio-based products.12
Why — This allows members to maintain active forest management and increase timber production.3
Impact — Environmental groups lose the legal guarantee of protected and increasing carbon sinks.4
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Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra) and Lantbrukarnas Riksförbund and Bureau of Nordic Family Forestry

16 Sept 2025 · LULUCF and carbon removals and carbon farming certification framework (CRCF)

Meeting with Elsi Katainen (Member of the European Parliament)

10 Sept 2025 · Maatalouspolitiikka ja tuleva CAP

Meeting with Eero Heinäluoma (Member of the European Parliament)

9 Sept 2025 · Maa- ja metsätalouden ajankohtaisasiat

Meeting with Pekka Toveri (Member of the European Parliament)

9 Sept 2025 · Current EU Agricultural topics

Meeting with Elsi Katainen (Member of the European Parliament)

9 Sept 2025 · Maatalouspolitiikka ja tuleva CAP

Meeting with Katri Kulmuni (Member of the European Parliament)

9 Sept 2025 · Maa- ja metsätalouden ajankohtaiset kysymykset

Meeting with Pekka Toveri (Member of the European Parliament)

3 Sept 2025 · Current EU Agricultural topics

Finnish farmers urge flexibility and property rights in pollinator monitoring

16 Jul 2025
Topic — New EU rules establishing a science-based method for monitoring pollinator diversity and populations.
Message — MTK requests flexibility for Member States to use existing monitoring sites and methods to ensure data continuity. They emphasize the need for landowner consent before accessing private property and protecting the privacy of monitoring locations.123
Why — Allowing national methods avoids the high costs of replacing functional monitoring systems and safeguards private property.45
Impact — The scientific goal of achieving uniform monitoring across all Member States would be compromised by increased national flexibility.6
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Finnish farmers demand long transitions for animal welfare reforms

10 Jul 2025
Topic — This consultation explores updating EU legislation for on-farm animal welfare and cage-free production.
Message — The organization requests a 10 to 15-year transition period for phasing out calf boxes. They demand that imported products meet the same animal welfare requirements as EU producers. Additionally, they oppose an immediate EU-wide ban on culling male day-old chicks.123
Why — This would protect Finnish producers from unfair competition and reduce their administrative oversight.45
Impact — Non-EU exporters would lose market access if they cannot meet European production standards.6
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Meeting with Katri Kulmuni (Member of the European Parliament)

2 Jul 2025 · Omnibuss

Meeting with Elsi Katainen (Member of the European Parliament)

1 Jul 2025 · Agricultural policy

Meeting with Pierre Bascou (Deputy Director-General Agriculture and Rural Development)

25 Jun 2025 · Courtesy visit

Finnish forest owners demand less regulation in bioeconomy strategy

19 Jun 2025
Topic — The European Commission's plan to create a circular and climate-neutral economy using sustainable biomass.
Message — MTK calls for a simplified strategy that reduces regulatory burdens and avoids new sustainability criteria. They advocate for local solutions and reject a legislated cascading principle to protect market flexibility.123
Why — This would lower operational costs and maintain national control over forest management.45
Impact — Environmental advocates lose when harvesting levels are not restricted for conservation purposes.6
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Response to Land use, land use change and forestry - flexibility mechanism related to impacts from natural disturbances

11 Jun 2025

The boreal zone forests will face major impacts due to climate change.1 The impacts are mostly beyond MSs ability to mitigate or adapt them. One of the aspects a MS cant influence is the share of peatlands that happen to be in the MSs area. The flexibility mechanism introduced is welcome effort to adjust the LULUCF burden for the reasons that are beyond MSs influence. The COM should implement the flexibility mechanism in the way that MSs where peatlands are common, can actually utilize the accepted flexibility mechanism. In Finland the government has introduced several policy actions to mitigate and adapt climate change in the LULUCF sector. The implementation of policies will take time and the results will be shown after relevant time scales. The implementing act article 2 proposes that Member States shall identify, in a geographically explicit manner, areas affected by the long-term impact of climate change. The meaning of geographically explicit manner needs to be clarified. In Finland the relevant affected area consists the whole country, since the global warming is stronger the closer to polar zones. Also in the article 3 Member States with an exceptionally high proportion of organic soils determined pursuant to paragraph 1 shall identify, in a geographically explicit manner, areas affected by the legacy effects of past management practices that occurred before 2013. The COM should take into account that the share of peatlands comes as given to MS without MSs ability to influence it. It seems that flexibility mechanism may include unnecessary burdensome reporting without a certainty of possibility to utilize the much needed mechanism. 1Even modest climate change may lead to major transitions in boreal forests | Nature
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Meeting with Elsi Katainen (Member of the European Parliament)

20 May 2025 · Suomen elintarvikeviennin haasteet ja mahdollisuudet

Meeting with Maria Blassar (Head of Representation Communication)

19 May 2025 · The Central Union of Agricultural Producers and Forest Owners in Finland wanted to brief on their views of MFF and related CAP budget.

Meeting with Pekka Toveri (Member of the European Parliament)

13 May 2025 · Current Topics in EU politics

Meeting with Anna-Maja Henriksson (Member of the European Parliament)

13 May 2025 · ¨Bio-chemistry

Meeting with Elsi Katainen (Member of the European Parliament)

29 Apr 2025 · Suomalainen ruuantuotanto ja CAP

Meeting with Pekka Toveri (Member of the European Parliament)

29 Apr 2025 · Current agri topics

Meeting with Andrea Gavinelli (Head of Unit Health and Food Safety)

28 Apr 2025 · Meeting on pig and poultry indicators

Meeting with Anna-Maja Henriksson (Member of the European Parliament)

24 Apr 2025 · Forestry

Meeting with Pekka Toveri (Member of the European Parliament) and Gevo

24 Apr 2025 · Current Topics in EU politics

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

24 Apr 2025 · Forests, bioeconomy and climate objectives

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

23 Apr 2025 · Agriculture and forestry

Meeting with Pekka Toveri (Member of the European Parliament) and Paulig Group

11 Apr 2025 · Current Topics in EU politics

Meeting with Christophe Hansen (Commissioner) and

4 Apr 2025 · Common Agricultural Policy (CAP), forestry, Vision for Agriculture and Food

Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur)

28 Mar 2025 · Forest monitoring and other topical forest issues

Meeting with Elsi Katainen (Member of the European Parliament)

26 Mar 2025 · Agricultural policy

Meeting with Eero Heinäluoma (Member of the European Parliament)

25 Mar 2025 · Seminar on sustainable agriculture and forestry

Meeting with Henna Virkkunen (Executive Vice-President) and

24 Mar 2025 · Common Agriculture Policy, Discussion on the future Multiannual Financial Framework, and food .

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and Lantbrukarnas Riksförbund and

19 Mar 2025 · Upcoming EU policy developments around the forest-based bioeconomy, in light of the upcoming strategic initiatives of the Clean Industrial Deal and the new EU Bioeconomy Strategy

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)

18 Mar 2025 · Meeting with MTK & MEP Elsi Katainen on the Vision on Agriculture and Food

Meeting with Elsi Katainen (Member of the European Parliament)

18 Mar 2025 · Russian fertilizers

Finnish farmers urge water strategy to prioritize local implementation

28 Feb 2025
Topic — The consultation seeks views on a multi-annual plan for European water resilience.
Message — The group requests investments in field drainage, irrigation reservoirs, and water-saving technologies. They advocate for implementing existing directives instead of creating new legislative burdens. Additionally, they demand that water business and infrastructure remain under national ownership.123
Why — Avoiding new regulations reduces administrative burdens while infrastructure funding supports farming continuity.4
Impact — Environmental groups lose stricter oversight if the strategy avoids creating new binding regulations.5
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Meeting with Andrea Gavinelli (Head of Unit Health and Food Safety)

27 Feb 2025 · Animal welfare law in the future, Pig welfare directive implementation (Finnish point of view), Animal welfare labelling, Transport proposal

Meeting with Herbert Dorfmann (Member of the European Parliament)

20 Feb 2025 · MFF and CAP

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)

19 Feb 2025 · (1) LULUCF, (2) Vision for Agriculture and Food; (3) Omnibus package; (4) Fertilizers

Meeting with Anna-Maja Henriksson (Member of the European Parliament)

18 Feb 2025 · Agricultural policy

Meeting with Katri Kulmuni (Member of the European Parliament)

18 Feb 2025 · Ajankohtaiset EU-lakihankkeet maa- ja metsätalous

Meeting with Elsi Katainen (Member of the European Parliament)

18 Feb 2025 · Yleiset maa- ja metsätalouden kysymykset

Meeting with Eero Heinäluoma (Member of the European Parliament)

18 Feb 2025 · MTK:n biotalouskannat

Meeting with Elsi Katainen (Member of the European Parliament)

12 Feb 2025 · Komission pitkän aikavälin maaseutuvisio

Finnish forest owners urge simple format for restoration plans

6 Feb 2025
Topic — Standardizing the layout for Member States to submit their national restoration plans.
Message — MTK demands a simplified format that respects national flexibility and minimizes administrative burdens. They request removing optional fields to ensure the format matches the regulation.12
Why — This would reduce administrative costs and prevent unauthorized mapping of private land.34
Impact — EU monitors lose the ability to track granular restoration progress across Member States.5
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Meeting with Elsi Katainen (Member of the European Parliament)

31 Jan 2025 · Cohesion policy

Meeting with Alexandra Nikolakopoulou (Head of Unit Health and Food Safety)

30 Jan 2025 · To discuss about food system policies and SANTE priorities.

Meeting with Cristina Rueda Catry (Head of Unit Agriculture and Rural Development) and Ruokatieto Yhdistys ry

29 Jan 2025 · EC AGRI promotion policy

Meeting with Brigitte Misonne (Head of Unit Agriculture and Rural Development)

27 Jan 2025 · Sustainable livestock production in Finland and upcoming policy developments

Meeting with Anna-Maja Henriksson (Member of the European Parliament)

24 Jan 2025 · EU policy

Meeting with Gijs Schilthuis (Director Agriculture and Rural Development)

15 Jan 2025 · Sustainability agenda for Finnish agriculture

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

15 Jan 2025 · Presentation and exchange on the low-carbon roadmap for Finnish agriculture

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)

14 Jan 2025 · Forestry and bioeconomy

Meeting with Gijs Schilthuis (Director Agriculture and Rural Development)

13 Jan 2025 · Presentation of two papers on Bioeconomy and Nature Value Markets by MTK

Meeting with Pekka Toveri (Member of the European Parliament)

11 Dec 2024 · Common agricultural policy

Meeting with Taru Haapaniemi (Cabinet of Commissioner Janusz Wojciechowski)

28 Nov 2024 · Courtesy Meeting

Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur)

14 Nov 2024 · Forest monitoring

Meeting with Pekka Toveri (Member of the European Parliament) and Foundation for a Living Baltic Sea - Baltic Sea Action Group

6 Nov 2024 · Current Topics in EU politics

Meeting with Benoit Cassart (Member of the European Parliament, Shadow rapporteur)

5 Nov 2024 · Animal transport

Meeting with Elsi Katainen (Member of the European Parliament)

17 Oct 2024 · Regional policies in the new term

Meeting with Pekka Toveri (Member of the European Parliament)

15 Oct 2024 · Current Topics in Agriculture and Forestry

Finnish Farmers Warn Against Double Standards in Ukraine Trade

1 Oct 2024
Topic — The consultation concerns accelerating the mutual elimination of customs duties between the EU and Ukraine.
Message — The organization argues that all imports must comply with EU health and welfare standards to avoid double standards. They warn that increasing import quotas for poultry and sugar will significantly disrupt the internal market.12
Why — Restricting liberalization would protect domestic farmers from falling prices and the burden of higher production costs.34
Impact — EU consumers face confusion regarding food standards, while domestic producers lose their competitive level playing field.56
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Meeting with Pekka Toveri (Member of the European Parliament)

26 Sept 2024 · Current Topics in EU politics

Meeting with Mika Aaltola (Member of the European Parliament) and Suomen Yrittäjät ry and FinMobility ry

25 Sept 2024 · EU Competitiveness

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

25 Sept 2024 · Maa- ja metsätalousalan ajankohtaisaiheet

Meeting with Sebastian Tynkkynen (Member of the European Parliament) and Suomen Yrittäjät ry and FinMobility ry

25 Sept 2024 · Pk-yritysten sekä liikenne-, maatalous- ja metsäsektorien ajankohtaisaiheet

Meeting with Merja Kyllönen (Member of the European Parliament)

18 Sept 2024 · Maa- ja metsätaloustuottajain Keskusliitto MTK r.y., suomalaisten europarlamentaarikoiden avustajien aamiainen, keskusteluan ajankohtaisista maa- ja metsätalouteen liittyvistä kysymyksistä

Meeting with Eero Heinäluoma (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry)

18 Sept 2024 · Ajankohtaisaiheet

Meeting with Sebastian Tynkkynen (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry)

18 Sept 2024 · Metsäalan ajankohtaisasiat

Meeting with Krzysztof Hetman (Member of the European Parliament)

18 Sept 2024 · animals transport

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

17 Sept 2024 · Ajankohtaisasiat

Meeting with Pekka Toveri (Member of the European Parliament)

17 Sept 2024 · Current Topics in Forestry and Agriculture

Meeting with Elsi Katainen (Member of the European Parliament)

17 Sept 2024 · Illallistapaaminen, ajankohtaiset EU-asiat

Meeting with Janusz Wojciechowski (Commissioner) and

17 Sept 2024 · Analysis of the current CAP and its future. Forestry and Bio-economy sectors role in the coming years.

Meeting with Anna-Maja Henriksson (Member of the European Parliament) and Finnish trade union representation to the EU

17 Sept 2024 · Agriculture and forestry, labor market issues

Meeting with Pekka Toveri (Member of the European Parliament)

5 Sept 2024 · Current Topics in EU Politics

Meeting with Eero Heinäluoma (Member of the European Parliament) and Suomen itsenäisyyden juhlarahasto

5 Sept 2024 · Ajankohtaisaiheet

Finnish forest owners urge EU to set realistic carbon targets

4 Jul 2024
Topic — Evaluation of EU rules for land use, forestry, and carbon sinks.
Message — MTK argues that climate policy should prioritize cutting fossil emissions rather than relying on fluctuating forest carbon sinks. They request that targets be lowered to reasonable levels that permit active, sustainable forest management.12
Why — This would protect timber harvesting revenues and reduce regulatory burdens for private landowners.3
Impact — Other Member States lose the ability to offset their national emissions using Finnish sinks.4
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Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen), Taneli Lahti (Cabinet of Commissioner Jutta Urpilainen)

27 Jun 2024 · Green Deal and EU’s transition/election year

Finnish farmers back RENURE to improve nutrient recycling

6 May 2024
Topic — The consultation concerns amending the Nitrates Directive regarding nitrogen recovered from manure.
Message — The organization supports the proposal because it encourages processing manure nitrogen and promotes recycling. They emphasize that the rules should reduce dependence on imported nutrient sources.123
Why — This would provide legal certainty for scaling up farm-based biogas and technologies.45
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Meeting with Nils Torvalds (Member of the European Parliament)

17 Apr 2024 · CAP

Meeting with Taru Haapaniemi (Cabinet of Commissioner Janusz Wojciechowski)

17 Apr 2024 · Meeting with MTK delegation on Deforestation

Meeting with Pirkko Ruohonen-Lerner (Member of the European Parliament)

10 Apr 2024 · Yhteinen maatalouspolitiikka

Meeting with Nils Torvalds (Member of the European Parliament) and Svenska lantbruksproducenternas centralförbund r.f.

9 Apr 2024 · CAP

Response to Evaluation of the European Food Safety Authority (EFSA) 2017-2024

8 Apr 2024

The Central Union of Finnish farmers and forest owners appreciates and thanks Commission evaluation of EFSAs operation. Food safety is extremely important issue and EFSAs has done responsible work for it. Local circumstances should be better taken in to account. Specially we recognized this in poultry studies where Finnish production method was not taken into account. EFSA should take into account social economy impacts better in coming research. Our broiler sector works with all in all out principle and this was not mentioned in EFSAs work. Overall we see that EFSAs work is important and we want to highlight also practical methods in EFSAs evaluations. Meaning that evaluation can not been done only in literature work. Great that EFSA has asked also during this year (turkey and cattle) these practical, country information in their work.
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Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur)

4 Apr 2024 · Animal transport regulation

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

3 Apr 2024 · Relevant animal welfare policies

Meeting with Petri Sarvamaa (Member of the European Parliament)

5 Mar 2024 · Current Topics in Agriculture

Meeting with Henna Virkkunen (Member of the European Parliament)

21 Feb 2024 · Current EU affairs

Meeting with Ville Niinistö (Member of the European Parliament)

21 Feb 2024 · EU affairs, agriculture, forestry

Meeting with Petri Sarvamaa (Member of the European Parliament)

20 Feb 2024 · Current Topics in Agriculture

Finnish forest owners urge national control over monitoring

7 Feb 2024
Topic — A proposal establishing an EU-wide framework for monitoring forest health.
Message — MTK wants national inventories to remain the primary data source and opposes reporting at the individual holding level. They call for a more flexible approach using guidelines instead of a mandatory regulation.123
Why — Maintaining national data systems would prevent increased administrative costs and protect private property information.45
Impact — EU regulators would lose access to granular data needed for unified conservation strategies.67
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Response to Standing Forest and Forestry Expert Group

19 Jan 2024

The Central Union of Agricultural Producers and Forest Owners MTK welcomes to express views on the proposal on EU forest governance structure that has been presented part of the Forest Monitoring Regulation. MTK supports the aim to reinforce the coordination of different forest-related policies. This should be ensured with the involvement of experts especially from countries with a high forest cover. Given the increasing interest of EUs forests, the future group should strengthen the coordination of various forest-related policies. From the Commissions side, MTK supports DG Agri to take the lead in the coordination of the future group. MTK also supports that the Standing Forestry Committee would extend its tasks. This would support the holistic view of forests that covers the multifunctionality and prevents the EU legislation preparation in silos. It is highly important that the extended committee considers all the possibilities that active and sustainable forest management provides. When acknowledging economic, ecological, and social sustainability, forest-related legislations will lead into a more balanced outcomes. To achieve this, exchange of views on the role of forests also from the practice-oriented viewpoint is key as this has been lacking in the current work of the Commission. Nevertheless, MTK has some concerns about renaming the Standing Forestry Committee as the Standing Forest and Forestry Expert Group as it is somewhat unclear, what the role of the expert group would be. Changing the name could make it harder to follow as there are already various expert groups in place, and thus hamper the efficient Member State involvement. It is crucial that the future Standing Committee has a goal to meet regularly and to be influential by making majority-based decisions. Renaming should not prevent the group making decisions efficiently e.g. by voting, if needed. It is key to ensure that the appointment and representation of experts will be decided by the Member States. It is highly important that all Member States are well-heard then preparing forest-related regulation. Nevertheless, especially Member States that have a high forest cover, including their experts, should be sufficiently represented in the meetings.
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Finnish farmers' union urges modernizing Nitrates Directive for food security

17 Jan 2024
Topic — EU evaluation of rules preventing water pollution caused by agricultural nitrates.
Message — MTK calls for updating the 1991 rules to reflect modern farming and support recycled nutrients. They want to reduce administrative burdens and maintain national control over implementation details.123
Why — Finnish farmers would face lower compliance costs and gain flexibility to increase yields.45
Impact — Environmental protection efforts could suffer if nitrogen use is not strictly minimized.6
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Meeting with Janusz Wojciechowski (Commissioner) and

11 Jan 2024 · Current CAP and its implementation

Meeting with Eero Heinäluoma (Member of the European Parliament) and Kangaroo Group

5 Dec 2023 · Topical issues

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

30 Nov 2023 · Tour d'horizon in Agriculture

Meeting with Helena Braun (Cabinet of Vice-President Maroš Šefčovič) and Lantbrukarnas Riksförbund and

30 Nov 2023 · EU forest monitoring and other forest related proposals

Meeting with Silvia Modig (Member of the European Parliament)

16 Nov 2023 · Topical Issues (staff level)

Meeting with Petri Sarvamaa (Member of the European Parliament)

16 Nov 2023 · Topical issues in EU AGRI politics

Meeting with Elsi Katainen (Member of the European Parliament)

10 Nov 2023 · Union certification framework for carbon removals

Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur for opinion)

20 Oct 2023 · Soil monitoring legislation

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen), Taneli Lahti (Cabinet of Commissioner Jutta Urpilainen)

5 Oct 2023 · animal welfare

Meeting with Eero Heinäluoma (Member of the European Parliament)

3 Oct 2023 · Topical issues

Finnish farmers demand regional flexibility in soil health law

29 Sept 2023
Topic — The EU is proposing new rules to monitor and restore soil health.
Message — MTK requests a result-based approach that allows for regional differences in soil types. They reject the 'one out-all out' principle and suggest monitoring every ten years.123
Why — Finnish landowners would avoid high costs for unnecessary measurements and restrictive management rules.45
Impact — EU authorities would lose the ability to compare soil health data consistently across member states.6
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Meeting with Petri Sarvamaa (Member of the European Parliament)

12 Jul 2023 · Topical issues in EU AGRI politics

Finnish farmers urge focus on fossil emissions over sinks

21 Jun 2023
Topic — The EU is establishing a 2040 climate target to achieve neutrality by 2050.
Message — MTK demands that climate policy focus clearly be on reducing fossil emissions rather than terrestrial carbon pools. They support creating an integrated pillar for all agricultural and forestry gases. Landowners must retain ownership of carbon pools with no exceptions.12
Why — This ensures farmers maintain control over their land assets and access carbon markets.3
Impact — Environmental groups lose if prioritizing carbon sinks allows for the continued use of fossil materials.4
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Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen)

19 Jun 2023 · sharing key messages regarding soil health law

Meeting with Petri Sarvamaa (Member of the European Parliament)

1 Jun 2023 · Topical issues in EU AGRI politics

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Lantbrukarnas Riksförbund and

31 May 2023 · To discuss about the relevant forest-policy priorities, especially the upcoming forest monitoring law.

Finnish forestry group MTK demands lower wood reuse targets

3 May 2023
Topic — The consultation defines technical criteria for investments contributing to European environmental objectives.
Message — The organization calls for lower bio-based material reuse targets and voluntary landowner approval for restoration. They argue current criteria for construction on forest land are unrealistic for Finland.12
Why — Flexible criteria would reduce administrative costs and protect rural development opportunities.3
Impact — Biodiversity protection efforts lose out if construction is permitted on forest land.4
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Meeting with Mauri Pekkarinen (Member of the European Parliament)

26 Apr 2023 · Meeting on MFF, EU:'s actions for border areas, deforestation

Meeting with Nils Torvalds (Member of the European Parliament)

21 Mar 2023 · forestry questions

Meeting with Petri Sarvamaa (Member of the European Parliament)

28 Feb 2023 · Topical issues in EU politics

Meeting with Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis)

28 Feb 2023 · Trade agenda, WTO discussion, unilateral measures

Meeting with Ville Itala (Director-General European Anti-Fraud Office)

17 Feb 2023 · Food fraud

Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur)

8 Feb 2023 · Urban wastewater treatment

Finnish farmers demand simpler rules for carbon removal certification

2 Feb 2023
Topic — The Commission proposes a regulatory framework for certifying high-quality carbon removals in the EU.
Message — MTK calls for simple certification criteria and verification costs that align with market prices. They insist that funding must come from private sources rather than agricultural subsidies. The rules should also avoid binding future landowners with long-term contractual obligations.123
Why — This would allow forest owners to profit from climate benefits without depleting existing agricultural budgets.4
Impact — Strict EU regulations could drive private investment toward carbon projects located outside of Europe.5
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Meeting with Anne Sander (Member of the European Parliament, Rapporteur for opinion)

10 Jan 2023 · Nature Restoration Law

Meeting with Petri Sarvamaa (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry)

10 Jan 2023 · Nature restoration law

Meeting with Jutta Urpilainen (Commissioner) and

19 Oct 2022 · Food security, gender equality.

Meeting with Janusz Wojciechowski (Commissioner) and

23 Sept 2022 · CAP-implementation in Finland, nature restoration and carbon certification

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis)

22 Sept 2022 · Forests; EU taxonomy of environmentally sustainable economic activities; carbon certification

Meeting with Nils Torvalds (Member of the European Parliament)

13 Sept 2022 · Agriculture and forestry

Meeting with Petri Sarvamaa (Member of the European Parliament)

13 Sept 2022 · Agriculture & Forestry

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

31 Aug 2022 · Implementation of the EU Forest Strategy for 2030, and proposal for EU Nature Restoration Law

Finnish farmers reject EU nature restoration law as threat to agriculture

19 Aug 2022
Topic — EU regulation setting legally binding targets for restoring ecosystems and biodiversity.
Message — MTK demands the proposal be rejected or significantly amended. They argue restoration must remain voluntary, based on national decision-making rather than EU regulation. They want agricultural and forest land excluded from restoration obligations and flexible approaches respecting landowner rights.123
Why — This would protect their members' farmland and forestry operations from mandatory restoration requirements.45
Impact — Biodiversity loses as voluntary approaches may fall short of halting species decline.6
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Meeting with Frans Timmermans (Executive Vice-President) and Greenpeace European Unit and

9 Jun 2022 · forest visit

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

1 Jun 2022 · Taxonomy of environmentally sustainable economic activities

Meeting with Nils Torvalds (Member of the European Parliament)

19 May 2022 · Forestry

Finnish farmers demand clear definitions for reserved antimicrobials

13 May 2022
Topic — EU initiative to designate specific antimicrobials for exclusive human medical use.
Message — MTK supports the reservation list but calls for clear definitions of included substances. They request that macrolides remain available for treating specific infections in pigs.12
Why — This prevents the loss of essential treatment options for pig production.3
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Finnish forest owners demand property rights in monitoring plan

3 May 2022
Topic — This initiative develops an EU-wide framework for forest observation, data collection, and reporting.
Message — MTK insists the proposal must respect private property rights and avoid creating administrative burdens. They demand that forest owners be included in the legislative process to prevent strong resistance. Monitoring should remain large-scale to protect sensitive information.123
Why — This protects forest owners from new administrative costs and privacy intrusions.45
Impact — EU regulators lose access to granular data required for tracking biodiversity.67
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Finnish farmers urge EU to adopt private carbon standards

29 Apr 2022
Topic — The European Commission is creating a framework to certify sustainable carbon removals.
Message — MTK rejects new EU standards, preferring existing private carbon market platforms. They want rules allowing farmers to sell credits globally. The system should provide immediate pre-financing for climate actions.123
Why — Private standards help landowners reach global markets with fewer regulatory hurdles.45
Impact — Regulators lose control as private firms would handle all project verification tasks.6
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Meeting with Petri Sarvamaa (Member of the European Parliament)

28 Apr 2022 · Agriculture & Forestry

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen), Taneli Lahti (Cabinet of Commissioner Jutta Urpilainen)

28 Apr 2022 · Food Security and Global Development

Response to Carbon Border Adjustment Mechanism

18 Nov 2021

Hiilirajamekanismi (CBAM) on tärkeä osa kokonaisuutta, jolla pyritään huolehtimaan EU:n omien toimijoiden tasavertaisista kilpailuedellytyksistä osana EU:n Green Dealin toteuttamista. Maa- ja Metsätaloustuottajian Keskusliiton (MTK) näkökulmasta prosessissa korostuu seuraavat asiat: 1. EU:n työvälineen on toteutettava tavoitetta mahdollisimman kevyin hallinnollisin kustannuksin. 2. Valmistelussa on huomioitava järjestelmän WTO-yhteensopivuuden lisäksi jo käytössä samaa tavoitetta tukevien toimien yhteisvaikutukset, kuten polkumyyntitullit tai esitykset metsäkatomerkinnät, due diligence ym. 3. CBAMin vaikutusten rajaaminen vain yhteen arvoketjun tuotteeseen ei huomioi koko arvoketjun haastetta. Elintarvikesektorin näkökulmasta lannoitteiden hiilitullit heijastuvat korkeampina tuotantokustannuksina vilja-, rehu-, kotieläntuotteiden markkinoilla. Hiilitullin kohdistaminen lannoitteisiin aiheuttaa arvoketjun seuraaville tuotteille kilpailuhaittaa, kun kuitenkin toimitaan samoilla globaaleilla markkinoilla. 4. CBAM-määrittely tarvitsee merkittävästi lisää paikallista tutkimustietoa. Omasta kokemuksesta tiedämme, että oman paikallisen tuotannon hiililaskenta on haasteellista, vaikka maataloustutkimus on tehnyt asian kanssa jo pitkään työtä. Yhdessä tutkimuksen kanssa olemme valmistelleet mm. MTK's Climate Programme https://www.mtk.fi/documents/20143/623429/MTK_ilmasto-ohjelma_ENG_net.pdf/dbdcf1ac-c402-e81f-99bc-daef32c8d619 5. Asetettaessa hiilitullit pitää markkinoilla toimijoiden voida todentaa oman toimintansa ja omien tuotteiden hiilivaikutukset suhteessa esitettyihin keskiarvojen perusteella laskettuihin hiilitulleihin. Toimijat voivat omien todennettujen lukujen perusteella hakea oikaisua hiiliotulleihin. 6. Viitaten edellä olevaan mekanismiin, EU:n pitää varmmistaa, että kauppakumppaniemme ottaessa käyttöön vastaavia mekanismeja, myös EU:n toimijoilla on mahdollisuus vaatia oikaisuja käytössä oleviin hiilitulleihin.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

16 Nov 2021

MTK is in favour of a separate minimum share for advanced biofuels and biogas produced from raw materials in Part A of Annex IX. MTK is also in favour of abolishing double counting. Finland has already abandoned double counting in the past, and the blending obligation rates applied in Finland are significantly higher than those imposed by the EU. Instead MTK is not in favour of lowering the target percentage of the aforementioned fuels by half a percentage point in EU legislation in 2025 and 1.3% in 2030. It is important that the share of renewable energy is increased throughout Europe. MTK is disappointed that COM has decided to open the sustainability criteria of the RED, even though the implementation of the sustainability criteria under the previous directive has not been implemented in the MS – nor the implementing act has been finalized by the COM. MTK does not consider the progress as desired in terms of predictability of legislation or operator motivation to act more sustainably. The MTK considers that the new definitions of forests set out in the proposal are unclear and the legal effects of the new definitions are impossible to assess at this stage. The definitions have been substantially amended from the previous, rather precise, directive. Quality roundwood can be used as an example of these new definitions. In the wood markets all buyers have their own individual size and quality requirements to meet the needs of the markets. An unambiguous definition of high-quality roundwood cannot be formed at national level – let alone at EU level. Even the try to define the high-quality roundwood in EU legislation would harm the timber market dynamics and lead to welfare losses. There is a real threat of unheard administrative burden for wood supply operators on this and real possibility for landowners to loose the value of their woodlands if the existing market dynamics are disturbed. The proposal for a directive would bring the cascade principle to EU law. Both the reference to the waste hierarchy and the cascade principle do not fit into timber markets. In MTK's view, the cascade principle should not be brought into EU law at all. This is not a matter with minority meaning for the functioning of the timber markets, but has a direct impact on competition in the timber market. The COM should not get a licence to propose implementing act on the cascading use. COM proposes a number of changes to the sustainability criteria for forest biomass. The content of the proposed changes are so unclear that it is not possible to assess their legal effects at this stage. Moreover, COM has not assessed the impacts in this respect. The MTK proposes that the co-decision procedure should return to the formulations of RED2. MTK is most critical on the proposal on expanding no-go areas.COM has not assessed at all the loss of value of these forests or peatlands which would be considered as no-go-areas. Nor has COM assessed the compensation need for the landowers whose forests or peatlands would loose the value on timber and also real-estate markets. It is unclear whether the proposal respects the risk-based approach at all, or whether the changes will lead to gradual rejection of the risk-based approach. MTK supports to maintain of risk-based approach in the sustainability articles of the RED. MTK notes that it will be impossible for the EU to meet the renewable energy growth targets it has set if biofuels, biogas and forest biomass are not available in a wide range of means. MTK points out that all EU countries where the share of renewable energy plays an important role in final energy consumption have managed to utilise bioenergy when developing their energy supply. With its proposal, COM will not continue on the path of long-term and predictable legislation in this respect. It is unclear whether COM proposal for RED will lead to the main objective of the directive at all, to increase the final use of renewable energy in EU.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

7 Nov 2021

EU climate policy can only be brought into line with the Paris Climate Agreement if each Member State fulfills its responsibilities. This means that no Member State will have its emissions credited to the other Member States, in another words Each Member state needs to fulfill no-debit-rule on its own. This must be the basic principle in the further negotiations in the Fit for 55% package, in which the Finnish state has one of the strictest targets set by the EU in both LULUCF and ESR policies. Finnish agricultural producers and forest owners will play their fair share of the EU's common climate policy at the proposed target levels by contributing to Finland’s targets, and no further tightening should be imposed on Finland.    Commissar Timmermans said 14.7.2021: “The package needs to be fair, fairness within EU and between member states.” MTK emphasizes that to be fair to landowners, the Member States and nature, the implementation of the Fit for 55% package must be based on 1) scientific criteria and 2) national calculations of emissions and removals (carbon sequestration). 3) Effort sharing should not be based on GDP / capita but on the cost-effectiveness of emission reductions. Now, commission proposes vice versa which puts Finland on the top of the emission reduction targets among the EU member states. Same time the flexibility options for ESR and agriculture (carbon credits from one-off ETS / LULUCF) are set to the lowest for Finland. Thus, the ERS proposal for Finland does not fit for promise set by commissar Timmermans. For Finnish agriculture and national food security the proposal puts enormous pressures, if emissions are calculated in the manner which ignore the carbon removals by agriculture, the carbon sequestration by photosynthesis of growing crops. In ESR and agriculture, the importance of soil productivity and cultivation methods must be seen as solution. Currently, the use, i.e., amounts of nitrogen fertilizers or liming products will cause agricultural emissions in ESR, without paying attention how much these essential inputs cause crop growth and removals. This is not logic because nitrogen supply and appropriate pH add crop growth and thus removals of CO2. Finnish soils are naturally acidic and need continuous liming to set pH above 6 to make most use of cropland for food production and nutrient use efficiency. Based on our understanding under Finnish conditions, there are less soil emissions when soil has a good crop growth. Currently the agricultural removals are not accounted with agricultural emissions, which would help to reach ESR-targets. Therefore, the MTK is open to considering the inclusion of agricultural greenhouse gases (methane and nitrous oxide), currently calculated in the effort sharing, in the same pillar as other land-use gases (CO2), if done nationally and on a gross-net basis. This would create an AFOLU (Agriculture, Forestry and Other Land Use) pillar covering all gases in the entire land use sector. Before 2030, the soil type and management -specific emission factors from soils (non-CO2 and CO2) need to be set and the data gap filled.   MTK stresses that agriculture is under unreasonable pressure to reduce agricultural greenhouse gases (methane and nitrous oxide emissions) in the declining effort sharing sector. The target for Finland is unrealistic high: 50 % by 2030. The current accounting does not recognize biogenic carbon flows (methane) and does not see the dependence of emissions on weather conditions and soil microbiological activity related to frosty winters (nitrous oxide). There is a great deal of uncertainty in the assessment of nitrous oxide emissions from agriculture, which research is currently seeking to clarify.  Additionally, the effects of methane emissions from ruminants on climate are under scientific discussion. Thus, the scientific base is not ready to set the given emission reduction target in ESR with current criteria for agriculture.
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Response to Land use, land use change and forestry – review of EU rules

5 Nov 2021

MTK welcomes COM proposal to review LULUCF EU rules. MTK's feed-back includes aspects of proposed calculation methodology, ambition level, compatibility with Paris Agreement, compatibility with coming initiative on restoring sustainable carbon cycles, voluntary carbon market mechanisms, general flexibility, establishing AFOLU, flexibilities of the framwork and environmental integrity. Please find attached the detailed comments on these aspects.
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Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

26 Oct 2021 · Exchange of views on CAP

Response to Restoring sustainable carbon cycles

7 Oct 2021

The scope of the initiative should include the minimum criteria by which EU originated nature-based solutions/land sector supply can feed the demand of Corsia. We solely believe that supply of diversified and robust nature-based solutions will rise also in the EU, if the regulatory framework is established in a transparent way and right incentives are in place on the customer side. One example of these right incentives in the customer side would be to give full recognition of this supply in the Corsia implementation. The cross-compliance with LULUCF/AFOLU-bookkeeping should be robust in order to avoid double-accounting. In Paris era all the projects will be part of the originating country’s national GHG-inventory if party/country reports AFOLU to UN. That is a fundament that can’t be avoided if national GHG-inventories are robust. Important is that voluntary carbon market measures are registered and their contribution to climate efforts are noted. Without this recognition it is hard to believe that market demand for voluntary carbon credits/certification could accelerate. On this issue EU could show an example how to establish a single market for voluntary carbon market measures, how to bookkeep the registries in the way that double accounting is avoided end-to-end and how landowners’ & customers’ efforts/contribution is recognized in a robust and transparent way in the Paris era climate framework? Of particular interest is how cross-compliance is secured with LULUCF article 9 carbon removal products? Will this article already have bookkeeping rules for EU based nature-based solutions as well - even the projects would be privately funded and voluntarily established? EU level answers are much needed if the goal is to have an EU wide single market or an example for international level to fulfill the Paris agreement article 6 with an EU example. Public authorities in the EU level or national level don’t need to establish any market platforms, new certificates or GHG-calculation standards. There are already in place many alternatives for such market services, for example ISO-standards, Gold Standard and Verra VCS program. The quality of these services is getting better all the time with the pressure of market competition. Yet these services need a bit of adaptation to local conditions and to be better in line with subsidiarity principle to gain local social acceptance among landowners. What is needed, is that the role of these new market-based models and their additional contribution in the form of credits are recognized in the climate framework, the volume is registered, and mutual end-to-end rules are established for single market. One should keep in mind that farmers and forest owners also in EU are micro enterprises and their economical capacity to tackle expensive market access costs are very limited. The goal should be to form a new single market for carbon removals from forests, agricultural practices or engineered solutions. This means that the role of the public funding should stay only in the capacity building measures and even there the funding should not distort the competition between for example different market platforms/certificates/project concepts/supply sources. For agriculture and forestry, the market needs to be a clear possibility to earn extra income and not an obligatory target based initiative. Clever design acknowledges multiple role of forests on fighting climate change; sequestrate, store & substitute. The initiative should not hinder the sustainable forestry’s other valuable contributions to sustainable development such as for example wood supply to the markets or agriculture’s fundamental role to provide healthy and nutritious food to people.
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Response to Update of the questionnaire on the implementation of the Sewage Sludge Directive

27 Sept 2021

Puhdistamolietteen käyttöön liittyvän tiedon keräämisessä on tärkeää, että tieto kerätään olemassa olevia rekistereitä hyödyntäen. Tukihakurekisteri (IACS) sopii tähän tarkoitukseen hyvin, eikä lisää viljelijöihin kohdistuvaa byrokratiaa. Tiedon keräämisessä on tärkeää, että EU:n tasolla määritetään selkeästi, mitä tietoa kerätään, jotta kerättävä tieto on vertailukelpoista EU:n eri jäsenmaiden välillä. Erilaisia lannoitevalmisteita, joissa puhdistamolietettä käytetään raaka-aineena, on paljon. Tuotteiden sisältämät puhdistamolietteen osuudet vaihtelevat suuresti.
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Response to Review of the EU school fruit, vegetables and milk scheme - EU aid

8 Jul 2021

Children and food producers should be in the core when reviewing the EU school scheme. Large variety of products enable good food education and eating habits for the children as well as offers opportunities for more food producers and SMEs.   Balanced and healthy diet should be in the focus of the scheme. The scheme should not be specifically targeted because targeting in the school environment easily leads to discrimination.    The overall nutritional value of the products should be taken into account. Nutritional content of low fat milk products is excellent. There are large variety of low fat milk based snacks suitable for children. The products offered under the school scheme has to obey the national nutritional recommendations. If more emphasis is put on sustainable products, regional, local and seasonal products should be recognised as well as organic products. It is meaningful to promote organic production but organic must not be the only criteria of sustainability. This is important especially when climate impact is considered.   The objective to develop educational measures is good. The proposed priority topics are important. However, the healthy eating habits should be the clear priority in which the most educational measures should be targeted.   It would be valuable to tell more about European agriculture to the children considering children’s age. It is essential to make sure that the information is correct and scientifically proven. Educational measures should also take into consideration characteristics of the MS's agriculture.   The eligible products should include large variety of dairy products, fruits, vegetables, berries and frozen berries. Large offering of products is a part of good food education and it would also enable more SME's to offer their products under this scheme.   Cooperation among public authorities and stakeholders increases awareness and understanding. However, in the context of the school scheme, it is essential that the decisions are made responsibly and based on scientific information. 
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Meeting with Jutta Urpilainen (Commissioner)

5 Jul 2021 · 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 Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and European farmers and

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

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

Central Union of Agricultural Producers and Forest Owners (MTK) welcomes the opportunity to respond to this consultation. MTK supports responsible and sustainable business and is committed the objectives of Paris Agreement. However, the way how the Commission has introduced the ‘Taxonomy’ and the recent proposals of Delegated Acts aiming to promote sustainable investment is problematic in many ways. The first delegated act on the taxonomy approved by the EU Commission covers forest management. The set of criteria put forward by the Commission will be increasing the administrative burden of forest holdings. The proposal that every forest holding of at least 13 hectares should look climate impact of forest on holding level is not acceptable. This is far too bureaucratic. Such an impact must be done much more aggregated level. It is obvious that the bigger companies will extend the reporting obligation to all forest holdings in the form of contractual practices. At worst the system could lead to smaller forest holdings being prevented from entering to markets. MTK points out that the Commission proposals include concepts, for instance “do no significant harm (DNSH)” and methodology of environmentally sustainable economic activities which do not have clear definition. This is not the right way to regulate and this will cause problems later. All concepts must be clear and clearly defined. MTK highlights that it is important to exclude agriculture from the technical specifications at this stage. Sustainability requirements for agriculture are part of the Common Agricultural Policy (CAP). The details related to agriculture should be decided as part of the CAP reform process.
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Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

Feedback: EU Draft Operational Guidance on the evidence for demonstrating compliance with the sustainability criteria for forest biomass laid down in Article 29 of Directive (EU) 2018/2001 of the European Parliament and of the Council Agricultural Producers and Forest Owners (MTK) of Finland regrets that the operational guidance fails to deliver much needed legality security for the producers of most significant source of European renewable energy - bioenergy. In generally we find the draft guidance excessive and stretching beyond the mandate given by REDII. As agricultural and forest producers who locally produce raw materials for many end-use purposes, also bioenergy, we were expecting guidance that provides examples for verification and workable tools. By and large, the draft guidance is missing these elements. At the same time the guidance is trying to broaden the scope of the co-legislated REDII directive and is not entirely in coherence of existing EU regulations. In this regard the energy legislation seemingly tries to broaden the scope to other sectors legislation, which for example forestry is not in the competence of the EU. In principle the draft guidance should not be political. In this regard the draft tries to determine sector legislation, which goes beyond the narrative of the RED2 and out of competence of EU. Coherence in the interpretation of the measures and timeliness in transposition and implementation are paramount in preventing barriers to the internal market. We find it very unfortunate that the Commission is significantly delayed with this implementation act. That is particularly problematic as the REDII directive set the deadline for guidance by the end of January 2021. In parallel the commission has insisted that the Member States must implement REDII in time. This legal non-synchronization may create unnecessary biomass market turbulence in the coming months. Agricultural Producers and Forest Owners (MTK) of Finland proposes to revise the document to improve the applicability and preciseness of the document and ease operationalisation of sustainability criteria as follows in the attached document.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Farmers and forest owners are key players in carbon mitigation and adaptation to new climate conditions. They need a strong support to continue to invest in more sustainable production methods and adaptation measures and smarter technologies. Access to finance is key for economically viable activities, including access to finance earmarked for the recovery fund. While creating new tools for financing it is important to take stock of the existing legislation and recognise the work done by farmers and forest owners to improve sustainability in agriculture and forestry. Agriculture and forestry are not the main objectives or beneficiaries of the financial products that Regulation 2020/852 focuses on, but the delegated act (DA) supplementing takes a strong stance on and a disproportionate approach to these NACE-code activities although some of them are not independently profit generating economic activity. It seems to us that the Commission is using a DA to regulate issues which are extremely important for agriculture and forestry as sustainable (economical, environmental and social) business activity. Therefore there should be a transparent, accurate, consistent, complete and comparable process described in the DA how to set criteria to SC or DNSH together with stakeholders. In terms of sustainability, the main shortcoming is the lack of the sectorial impact assessments. This leads to the situation where the Commission jeopardised the EU principals to have viable agriculture in all parts of the Union. The DA also represents an unprecedented attempt to propose conflicting legislation and to enforce criteria that set a new policy in parallel with the Common Agricultural Policy (CAP), other sectoral regulations and national legislation. In fact, Regulation 2020/852 states that when establishing and updating the technical screening criteria, the Commission should consider “relevant Union law”. The technical screening criteria must be in line and compatible with existing measures (and already adopted into national legislations) of CAP, REDII and Sustainable Forest Management (SFM) of Forest Europe which EU as signatory has agreed on. Forest certifications are voluntary and market-based instruments, not legislation. The DA questioned the bioeconomy sectors’ important role in fighting climate change and replacing fossil-based materials. The delegated act creates additional and stricter requirements on the DNSH-level compared to those already in place (CAP, REDII, Forest Europe). Many of the criteria are unfeasible (request use of unavailable data, proposed targets, farm sustainability plans and frequent reporting). This should be based on the existing reporting and auditing system for the CAP or the SFM rules. The share of the raw material is significant in the climate impact of bioenergy, the technical criteria are impractical, unworkable and, above all, require a disproportionate amount of effort. Actually large parts of the EU bioeconomy risk being determined unsustainable for taxonomy purposes, even if their primary purpose is to produce added value while using renewable resources as feedstock to make innovative, value-added products and materials. The delegated act refers to the use of agricultural raw materials for industrial and energy applications, such as plastics, biofuels, biowaste and organic chemicals. It is not acceptable that a key criterion is that “Food or feed crops are not used as bio-based feedstock for the manufacture” of these bio-based products and ingredients. To prevent carbon leakage is one of main objectives in the Green Deal. We emphasize that as an indirect effect there is an obvious risk of leakage if investments are hindered by the defined criteria. Every day, farmers and forest owners produce food, wood, fibres and energy as sustainably as possible so that they can leave the farms and forests for future generations in a more vibrant countryside. We can only achieve this with innovative investments
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Response to EU Forest Strategy

4 Dec 2020

Central Union of Agricultural Producers and Forest Owners MTK welcomes the roadmap as a starting point for the EU Forest Strategy. MTK is happy to notice that sustainable forest management can be found in the roadmap, however, MTK reminds that it should be a starting point to all actions suggested in the roadmap. Health of the European forests is important for the stability of the multifunctional role of forests: it is important to note that sustainable management is the best way to ensure the forest health. Elements MTK supports: Without sustainable forest management forests cannot act in their multifunctional role and provide efficient sinks for climate changes purposes, prevent forest fires and diseases or promote services at rural areas. In order to contribute to climate neutral, resource-efficient and competitive economy sustainable forest management is a must – not an option. The new EU Forest Strategy should have as main guiding principles the same principles of the current strategy: sustainable forest management (SFM) and the multifunctional role of forests. Critical aspects: The roadmap is ambitious and it has many objectives. However, the legal basis for so many miscellaneous objectives is unclear. Since there is no common forest policy and forests are a matter of Member States and, yet, there are many policies including forests and forest-based sector in the Union, the legal basis for the EU Forest Strategy should be clear. At the moment, all objectives of the roadmap do not have legal basis found in the Treaties. Forest are mainly privately owned in the EU. Property rights of individuals must be respected and they should also be mentioned in the future strategy. In the roadmap there is no single mention of the matter. To recognize this is important since property right is one of the key elements of fundamental human rights: articles stating this can be found in the Universal Declaration of Human Rights the and the Charter of Fundamental Rights of the European Union. It is necessary and bounding for the Commission to keep these property rights in mind when planning the EU Forest Strategy. The EUFS must recognize and reward commitments of forest owners to ensure sustainable forest management in a form of ownership. In order to manage forests sustainably there should be found criteria, indicators and principles in order to avoid unsustainable practices. These C&I are also agreed by the Commission on behalf of the EU in the Forest Europe processes. However, there is no indication to these measures in the Road Map. There should be clear reference to these Forest Europe C&I and principles in the Forest Strategy. These definitions and principles are already an integral part of national legislations and voluntary certification systems in the Member States. Multifunctionality of forests means a balance between economic, environmental and social dimensions of sustainability. At the Road Map the economic and social dimensions have stepped away from the balance and more room has been given to environmental dimensions. Both social and economic dimensions must be pointed out stronger: without them the forest- based value chain cannot exist and the transformation towards bio-based circular economy is impossible. Support to the EP and the Council: Finally, MTK supports the views of European Parliament (8 Oct 2020) and the Council presenting the Member States of the Union (11 Nov 2020). Both institutions are calling for a holistic approach to forests highlighting multifunctionality of forests and sustainable forest management.
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Finnish Forest Owners Urge Voluntary Measures Over Legally Binding Targets

1 Dec 2020
Topic — The EU's initiative to propose legally binding nature restoration targets under the 2030 Biodiversity Strategy.
Message — MTK calls for a shift toward voluntary, incentive-based measures rather than legally binding obligations. They stress that restoration planning must remain at the national level to ensure the rights of landowners are respected.12
Why — This approach allows their members to avoid mandatory restrictions and maintain control over their land assets.34
Impact — EU environmental authorities would face difficulties achieving uniform biodiversity targets without standardized, legally binding regulations.56
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

The key elements for forests to combat the climate change are Substitution, Sequestration and Storage. Forests are unique in doing all this at the same time. All sectors must carry responsibility in the path towards climate neutrality by 2050. There is potential to increase forests capacity to sequestrate and store carbon for example by afforestation, by improving the growth of the existing forests and by increasing the forest areas under sustainable management. Active and sustainable forest management increases the resilience and adaptation capability of forests as well as produces better quality timber for harvested wood products. We want to remind that in the last decades growing stock in EU forests has increased significantly! We didn’t find a suitable option of those proposed in the roadmap. The Commission’s roadmap aiming at “strengthening the current LULUCF Regulation and to increase its ambition in line with the 2020 Climate Target plan”, MTK is of the views that this should be completed with measures and actions that acknowledge and increase the substitution effect. In the roadmap this effect is not sufficiently considered although it has a potential to play a very important role. MTK supports the increased use of harvested wood products to both store carbon and substitute the fossil fuels and materials, including building materials in construction. The LULUCF regulation should be further developed in a direction where the full potential of forests and wood products for climate protection can be exploited. Support for measures to manage forests and increase growth as well as the substitution effect using wood are to be given a much higher priority. The overall effect on society must be optimized in order to ensure ecological, economic and social sustainability. The roadmap refers to combining the forest sector greenhouse gas balances with agriculture and other Effort Sharing Regulation sectors. We see that such flexibility of the burden sharing regulation could lead to a one-sided shift of efforts from CO2-emitting sectors to CO2-absorbing sectors. Forests’ role should not be to offset the emissions of the other sectors. It is necessary to differentiate between emitters of fossil CO2 (industry, transport, etc.) and CO2 from natural, biogenic cycles. Forests are part of the natural, biogenic carbon cycle. If forestry would not be its separate accounting sector, the higher storage and sink potential on the part of forestry could lead to relocation effects. This means that more wood raw material could possibly be sourced outside EU. One of the major concerns of MTK is how to keep the bioeconomy viable in the EU given the multiple demands on forests. Complex regulation could lead to a lockdown of raw material supply from EU forests. EU industry would have to meet new demands linked to the development of the bioeconomy by increased imports of raw material or relocating the industry outside EU. Sustainability would then be out of our reach. Without a clear sales path for increased wood production, forest owners will not increase productivity to meet the demand. One of the solutions is the promotion of sustainable forest management (SFM) on privately owned EU forests. The principle of SFM already takes into account the multifunctionality of forests. Support to forest owners and managers by voluntary measures, including voluntary carbon markets which contribute as nature based solution to NDC’s, could be considered to strengthen the LULUCF regulation. As the Commission will look at the ways of monitoring, reporting and verification for LULUCF sector, it is good to keep in mind the broad spectrum of forest data as shown by the previous LULUCF process. Member States, forest owners and other organisations have diversity of forest data that can be approached in very different ways. MTK wants to emphasize that the data used as a basis for decision making must be accepted and validated by all parties involved.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

MTK supports the overall ambition to act on climate change and find it essential that the agricultural and forestry sector contributes to the debate on climate action. Finnish farmers and forest owners have been successful in reducing green-house gas emissions significantly in past three decades and in contributing substantially to circular bioeconomy by replacing fossil-based products and materials. The constant improvement shall be continued by applying solutions from a more practice-oriented research, embracing innovative technologies, and creating a policy environment which enables cross-sectorial, fair cooperation. Agriculture and forestry play their crucial role in the EU’s joint effort to achieve with the goal of the Paris Agreement to limit temperature rise to 1.5°C. However, increasing the flexibility for burden-sharing between sectors would rather lead to burden shift from carbon emitting sectors to natural adsorbing sectors. MTK would like to stress that compliance with the 2030-target is feasible by pursuing cost-effective reductions within the ETS-sectors and we support the focus on carbon removals as a tool for achieving carbon neutrality. Carbon removals contain a great potential for complying with the targets for 2030 and 2050 and besides the vital funds allocated under the CAP, the mobilization of private funding is essential for that. A market-based carbon farming scheme is a promising approach to enhance the carbon sequestration potential of the farming sector Improving farming and forestry’s carbon absorption -potential through active and smart management is in the focus of farmers’ and forest owners‘ efforts but this needs to be supported by the right tools and rewarded. To combine the agricultural sector with the LULUCF sector into a climate policy pillar could be further examined, since a climate policy pillar could strengthen the work on carbon farming as well as climate action in the agricultural sector. Nevertheless, such merger carries the significant risk to fade the distinction between natural emitting and natural adsorbing sectors. Under ‘option 3’, the pressure derived from the greenhouse-gas reduction trajectory would mount unproportionally on agriculture and the forestry sector. Additionally, the Commission must examine thoroughly how to establish a climate policy pillar that takes into account the competitiveness and growth options within the agricultural and forestry sectors in the member states. The solution should not lead to carbon-leakage and should threat member states in a fair manner, that takes into account member states ability to adapt to coming climate architecture. One MS should not bear the burden of others inability to achieve emission reductions. Cost efficiency should play clearer role in coming climate architecture and GDB/capita should not be used anymore as burden sharing criteria, since it is very unfair criteria for MS with low amount of people, but high economical dependency on bioeconomies. This should be acknowledged especially in the situation where EU is suffering COVID-19 recession and EU's ability to gain new growth from bioeconomy is evermore important.
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Meeting with Jutta Urpilainen (Commissioner)

19 Oct 2020 · Green deal related policies and international partnerships

Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen)

15 Oct 2020 · Green deal related policies and international partnerships

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides)

14 Jul 2020 · VC Meeting on Farm to Fork Strategy

Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski)

23 Apr 2020 · CAP and Farm to fork

Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

The Central Union of Agricultural Producers and Forest Owners (MTK) is an interest organisation representing farmers, forest owners and rural entrepreneurs in Finland. MTK has over 316 000 members in local agricultural producers’ organisations and regional forest management associations. All of the occupations and businesses of our members are based on renewable natural resources and their utilisation in a sustainable and economical way. Regional activities and lobbying are carried out by 14 regional MTK unions and 62 forest management associations. It is important that the taxonomy report of the TEG Sustainable Finance recognises the principles of the EU Forestry Strategy, both the benefits of sustainable forest management and the multifunctional role of forests. We highlight once again that taxonomy criteria should respect this shared competency between the Union and the Member States on forestry issues, respect sustainable forest management practices covered and defined in Forest Europe process and must not undermine the role of forests in bioeconomy replacing fossils in the climate battle. In this respect, the scope of the taxonomy has to be enlarged as soon as possible to include “enabling” activities involving long-lived and harvested wood products and not just to protect and enhance forest carbon stocks and sinks. In our Finnish economy forestry is essential part of the whole society and for our forest owners a diverse use of forests, including social and economic sustainability circural-bioeconomy, is outmost important. The sustainable investment framework should recognize and enabled it. For agriculture the proposed farm sustainability management tool could be useful only if it is directly integrated with CAP measures. The reporting should be connected to the controls of the CAP. It is the only way how to reduce the monitoring, reporting and verification workload at farm level. In addition, the sustainable criteria and the DNSH-level should be integrated to the CAP criteria. At least the new eco-schemes and agro-environmental programs should fulfil the sustainable criteria as such, not only the DNSH-level. MTK emphasises that the incentive for the investments to low-carbon economy should mainly come from the market, but in respect to investments the financing sector plays an essential role to encourage sustainable investment and not discourage it by cost overload. It seems that by increasing sustainable criteria are well beyond the CAP a substantial part of the agricultural sector or food value chain will not be able to benefit from sustainable finance tools. There are 600000 private forest owners in Finland. The rotation period is long (60 – 80) years. These numerous forest owners are suppliers of wood raw material for the few forest-based globally active companies or biorefineries. The normal sourcing area of our forest-companies is the whole of Finland. Sustainable forest management (SFM) is the basis of the Finnish national legislation. The carbon sequestration is screened with the accurate national forest inventory. This data is national and can well be used to calculate the carbon stock in forests. The taxonomy report refers several times that management practices have to be audited and reported in a three year or ten years interval. Especially on forestry it is not well rationalised why this kind of reporting is needed nearly ten times in one rotation period. From MTK’s point of view it is the only rationale way to go on is that on forestry the reporting level is the same as in REDII and LULUCF. And the same is with the CAP controls and reports of the food value chain. In this respect existing reporting should be used and, if needed, adapted to ensure a reasonable cost-benefit-ratio. We acknowledge that reporting and verification is necessary, but the Commission must propose a solution in the delegated act that has a reasonable cost-benefit-ratio.
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Response to Access to Justice in Environmental matters

3 Apr 2020

The Central Union of Agricultural Producers and Forest Owners (MTK) recognizes the importance of the general principles of the Aarhus Convention in relation to access to justice in environmental matters. However, the Commission’s initiative described in the roadmap includes actions that are not justifiable from the point of view of the Aarhus Convention. Unreasonable interpretation of the principles and obligations of the Aarhus Convention based on the opinions of the Aarhus Convention Compliance Committee (ACCC) endanger the balance, functionality and efficiency of the existing judicial system. The ACCC supports a very broad interpretation of the Aarhus Convention which is too comprehensive in relation to e.g. different actors (individual scope vs. general scope), different kinds of administrative and judicial processes, and the linkage to the environmental aspect. Following the view of the ACCC would lead to unbalanced implementation of the Aarhus Convention at the level of both the EU and its Member States. In addition, enabling unnecessary procedures is not desirable since it would cause many negative consequences as pointed out by the external study (Ref. Ares(2019)6088660 - 02/10/2019). According to the roadmap, the existing Aarhus Regulation would be revised by extending the scope and time limits. This is not necessary. At the EU level, access to justice in environmental matters is already sufficiently granted and the system allows for appropriate participation. This is based not only on the Aarhus Regulation but also on the primary legislation of the EU. The harmony and coherency between the primary legislation and the secondary legislation needs to be ensured also when implementing and complying with the Aarhus Convention. In addition to the targeted revision of the Aarhus Regulation, the Commission would put forward a new Commission Communication on access to justice in environmental matters. This would aim at improving the current situation at the level of the Member States. MTK reminds that the background of this current discussion is the claimed noncompliance situation at the EU level as pointed out by the ACCC. Therefore, any actions related to the level of Member States should be reconsidered. MTK does not share the Commission’s opinion related to the statement that access to justice in environmental matters in the Member State’s national courts should be such that it would be possible to challenge the national implementing measures of EU non-legislative acts of general scope. Instead of amending the Aarhus Regulation or continuing any other actions at the level of the EU or the Member States, the Commission should consider non-legislative options. Too far-reaching interpretations of the Aarhus Convention or setting aside the balance between different interests could endanger the positive aspects of the Aarhus Convention. MTK believes that it would be more reasonable to pay attention to the involvement of relevant parties and to the quality of interaction during different processes instead of allowing access to justice based on a system which would not be controllable, predictable or cost-effective.
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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

I'm representing the Central Union of Agricultural Producers and Forest Owners (MTK). MTK is an interest organisation representing farmers, forest owners and rural entrepreneurs in Finland. MTK has over 316 000 members in local agricultural producers’ organisations and regional forest management associations. In principle the CBAM could be an excellent measure to avoid carbon leakage in all sectors. It is of the utmost relevance in emission-intensive sectors, in which the ETS system is already in place. Carbon is not the only thing what should be followed. Water use, biodiversity, deforestation and animal welfare, resource efficiency, use of fossil fuels etc. also need attention a compensating adjustment mechanism. Our goal is to limit global warming to 1.5°C. Any weakening of the EU’s current border protection for agricultural or forestry products could dramatically undermine efforts to this goal. Due to the urgent nature of climate action, a chapter on the application of climate measures with the possibility to sanctions must be included in all free trade agreements. The future does not lie in decreasing productivity and shifting production as well as climate impacts (carbon leakage and water scarcity) to third countries with lower standards. We have to make sure that the consumption complies with all the Sustainable Development Goals including trade policy. Before having a new carbon pricing system, the EU should, if necessary, suspend tariff preferences when non-compliance with the provisions of the agreement on sustainable development upsets the balance of competitive conditions for European producers. Secondly there is a possibility in the antidumping legislation to have tariffs also because of environmental requirements. Carbon pricing mechanisms in agriculture and forestry should be based on the carbon farming framework envisaged by the Commission and be compliant with the CAP. Within this scope, the carbon dioxide that farmers remove (negative emissions) would also be recognised in traded goods according to their production method. This carbon farming framework must neither contradict the Emission Trading Scheme nor the Effort Sharing Regulation. The special role of agriculture in climate action, as laid out in the Paris Agreement, must be recognised. Carbon border adjustments on agricultural goods must be based on the Life-Cycle Assessment (LCA) principles, including carbon sequestration. If agricultural and forestry products fall within the scope of the CBAM, principles should be elaborated with farmers and forest owners. While no WTO member has established a similar mechanism, there is a number of technical, legal and political questions. - The CBAM must be compatible with the WTO and other international trade commitments. - It must minimise administrative burdens where possible and not have any adverse effects on the environment or climate - A carbon marketplace or crediting schemes should be part of the incentivising toolbox to deliver on climate objectives. - The CBAM should be thoroughly assessed and carefully thought through along the entire food chain. The Commission to undertake a thorough impact assessment along the entire value chain prior to initiating any CBAM. - The flat-rate calculation methods do not work. - The tax on agricultural imports from unsustainable land use (i.e. deforested land) should be prohibitively high. - A huge amount of information will be required in order to establish a fair and uniform calculation system. - The trading partner countries should have properly implemented schemes for the CBAM. From MTK’s point of view there are too many open questions to build up a successful CBAM system, which could be used EU-wide and does not lead to costly red tape at the EU borders. If we are willing to use the CBAM in EU level, good starting point to test the system could be sectors like steel, aluminium, cement or electricity.
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Response to Farm to Fork Strategy

19 Mar 2020

MTK warmly welcomes the idea of European Green Deal and Farm to Fork and better agricultural standards. F2F approach has already for a long time been the cornerstone of promoting sustainability in the food chain in Finland. MTK feels this is a valuable opportunity to continue that work throughout the whole EU. We are very happy to continue this discussion and share our experiences. The main principle should be to raise the general awareness and improve the baseline and create a level playing field for sustainable food production. This includes also improving the profitability of agriculture and improve the standard of living for farmers. Farmers need to be part of the process and their work has to be recognized. Only this way, can farming attracts young farmers, new investments and innovations. The F2F strategy for sustainable food must take into account all three pillars of sustainability (economic, social and environmental) in this broader discussion. This is the only way to recognize the contribution of agriculture and of rural areas to food production. It is of utmost importance that work already done in MS to fulfill the goals of the F2F are fully recognized and MS are treated equally. It would be unfair and completely unacceptable to demand e.g. the same kind of reduction -% of antimicrobial substances, fertilizers or pesticides in a country as Finland, that has among the lowest usage in the world, as in the EU in general. European production standards must be respected when it comes to trade and imports from third countries. Imported food that does not comply with relevant EU environmental standards should not be allowed on EU markets in order to maintain a level playing field. Farmers may have recourse to pesticides to grow healthy crops on competitive terms, provide safe food, feed and non food agricultural products, safeguard the environment and ensure that consumer demands are met at the same time. Research and innovation must aim to find new tools and practice to find alternative and sustainable pest management solutions. We cannot have food security without food safety. Concerning fertilizer the aim should be to fertilise crops as accurately as possible. Instead of looking at the amount of fertilizers, focus should be on the efficiency of fertilizing. The nitrate directive should be implemented similarly in the whole EU, before introducing new restrictions. It is clear that a “One Health" approach is important for all health stakeholders in the EU and everyone must play their role in controlling and reducing antimicrobial resistance in Europe. In Finland we have shown, that the use of medicines can be dramatically reduced by better management. This means simply that the health of production animals has to be taken care of in a more ambitious way in EU member states. Biosecurity on farms – both internal and external – should be better to take care of health of the animals. The same principle applies for animal welfare. Animal welfare is part of good animal health and promotes food safety issues as well. Fully implementation of existing EU directives should be the basis of promoting better welfare. Concerning labeling MTK welcomes the Commission’s intention to explore new ways to give consumers better information on food. In Finland, origin labelling of meat and dairy has been developed in recent years. In our opinion, the regulative frame should be extended to include the origin of all main ingredients in retails, restaurants and public food service, in order to be as transparent as possible to the customers. The harmonization of animal welfare labels, at leaston a minimum level, is important for better consumer information. At present, consumers might get disinformation if national legislation is stricter than the requirements of an animal welfare label. We think that the consumers always have the right to know where and how the food is produced regardless where the food is bought or consumed.
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Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

11 Mar 2020

The Green Deal proposed by the EU Commission contains a wide range of climate actions. Quite a many of those presents new demands on the agriculture and forestry climate policy, while at the same time both the overall level of the EU financial framework for several years and the financial share of agriculture are threatened with cuts. The Central Union of Agricultural Producers and Forest Owners of Finland (MTK) stresses the importance of the EU securing a strong agricultural budget. JTF is a new fund and MTK demands that no new funds are made if the EU’s old responsibilities are not taken care of at the same time. The EU Green Deal is a step in the right direction in an effort to clarify the currently muddled and ineffectual environmental and climate policy. However, it fails to take account of the fact that the agriculture of Finland and the entire EU is currently driven up a blind alley in the grip of increasingly tight demands and funding cuts. Despite this, agricultural entrepreneurs are committed to the European agriculture model, with the goal of most sustainable production in the world. MTK stresses that if the Commission fails to pay serious attention to sufficient rural finance and the social and economic fairness to rural regions of the new climate and environmental measures, there is an increasing risk that the reforms will end in failure. The just transition fund is not directly aimed to agriculture and forestry, but it may have big influences for those sectors and rural areas. MTK has proposed that the EU should be drafting a new Rural Deal as part of the Green Deal. The new deal should provide solutions and additional funding for agriculture and forestry, climate and environmental actions to further bioeconomy and circular economy based on the sector, and deployment of new innovations. MTK supports JTF, but demands careful preparation when country specific JTF areas and criterium are finalized. For example, Finland’s share from JTF comes partly from peat production. The aim in JTF is to decrease energy peat production. However, in coming months the EU must secure that also in the future the member states are allowed to produce peat for other purposes such as animal health (bedding), growthsurface in horticulture and new innovations such as activated carbon. In commission country report Finland 2020 were given investment guidance on JTF for Finland. Guidance tells that East and North Finland appears to be the most affected region by transition from peat. These regions are also the main cohesion policy areas in Finland. However, JTF should also be in use in other peat producing areas in western Finland. With the aid of new financial instruments, JTF as a part of Rural Deal would help to create a pathway covering the different sectors for developing and regenerating rural areas that are ecologically, economically and socially sustainable, as well as offering young people opportunities for a good life in a variety of occupations.
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Meeting with Arto Virtanen (Cabinet of Commissioner Jutta Urpilainen)

13 Feb 2020 · farm to fork ; forest climate development seminar 17.03.

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

6 Feb 2020 · Sustainable food chains

Response to EU 2030 Biodiversity Strategy

20 Jan 2020

The Central Union of Agricultural Producers and Forest Owners (MTK) welcomes the possibility to provide feedback on the roadmap. The involvement and engagement of landowners is of utmost importance when formulating the EU Biodiversity Strategy to 2030 and the related implementation measures. Thus, MTK expresses its concern about the fact that according to the roadmap involvement and consultation of stakeholders is very limited. Treating farmers and forest owners as active partners and taking account of their opinions is a prerequisite for an acceptable and balanced outcome. Safeguarding and enhancing biodiversity is an inseparable part of sustainable agriculture and forest management in Finland. MTK highlights that balancing ecological sustainability with social and economic aspects is an essential requirement to holistically address environmental challenges in an equitable way. The need for high ambition should not overrule policy coherence, or the aim to keep the EU Biodiversity Strategy 2030 framework within realistic limits. Furthermore, the burden needs to be shared in a just way. The roadmap states that the EU has an extensive legal and policy framework related to biodiversity and sustainable use of natural resources. MTK welcomes this remark and stresses the role of good implementation of the existing legislation before considering the need for some additional restrictions based on some new legislation. To further integrate biodiversity across EU policies and instruments MTK highlights the need for policy coherence when simultaneously solving cross-cutting environmental challenges like biodiversity loss and climate change. MTK supports the roadmap’s reference to the fact that climate change poses a significant threat to biodiversity, and reminds that sustainable agriculture and forest management are necessary to combat climate change, as well as to address many of the sustainable development goals. Although biodiversity-related challenges and many of the drivers of negative development are of global nature, effective solutions vary from country to country and even from region to region. Therefore, MTK calls for a strategic approach for the EU Biodiversity Strategy 2030. Indicating the need to continue efforts for safeguarding biodiversity in the EU is one of the main functions of the EU-level strategy together with ensuring the adequate financial resources, strong knowledge base and stakeholder involvement. The actual actions, however, should be defined at the national level to ensure effective and targeted measures considering the needs and priorities as well as the specificities of each country. A bottom-up approach supports the engagement of farmers and forest owners when the focus is on expanding and strengthening the existing actions that already maintain and promote biodiversity in practice. MTK kindly asks the Commission to take the abovementioned viewpoints into consideration when preparing the EU Biodiversity Strategy 2030. Finally, MTK emphasizes that a framework focusing on strategic elements would allow for versatile biodiversity actions at each member state according to the local needs. Since neither the results of the final evaluation of the current EU Biodiversity Strategy nor the global post-2020 biodiversity framework are in hand, ensuring flexibility at the EU level at this point would be important and reasonable.
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Meeting with Arto Virtanen (Cabinet of Commissioner Jutta Urpilainen) and Svenska lantbruksproducenternas centralförbund r.f.

14 Jan 2020 · Green Deal

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

29 Oct 2019 · CAP reform

Meeting with Antti Timonen (Cabinet of Vice-President Jyrki Katainen)

22 Oct 2019 · Forestry, sustainable finance and Climate change

Meeting with Antti Timonen (Cabinet of Vice-President Jyrki Katainen)

22 Oct 2019 · Forestry, sustainable finance and climate change

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

13 Sept 2019 · CAP reform

Meeting with Jyrki Katainen (Vice-President)

10 Sept 2019 · Current and future Commission

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

13 Mar 2019 · Sustainable finance

Response to Review of Agricultural Block Exemption Regulation

27 Feb 2019

Helsinki, the 27th of February 2019 Feedback on the European Commission inception impact assessment: Review of Agricultural State aid Guidelines and Review of the Agricultural Block Exemption Regulation The Central Union of Agricultural Producers and Forest Owners (MTK) welcomes the European Commission initiative to review the Agricultural State aid Guidelines and the Agricultural Block Exemption Regulation (ABER). Consistency and continuity between the CAP Strategic Plans regulation and future State aids Guidelines and ABER are essential. It is also important to ensure appropriate national flexibility and to simplify and streamline processes were possible. The current State aids Guidelines follow closely the Rural Development regulation 2014-2020. As the delivery model and the structure of the Commission proposal for a CAP Strategic Plans regulation differs significantly from it, with the removal of EU level eligibility criteria for support and increased Member States flexibility to define national eligibility conditions and measures, the reviewed State aids Guidelines should be adapted to the new legal framework. Given this new approach, State aid Guidelines framework should allow enough flexibility for Member States to define appropriate forestry and agricultural support schemes and eligible agricultural and forestry measures according to their national context. Moreover, State aid Guidelines should not set stricter limit to eligible support schemes and measures than the CAP Strategic Plans regulation. This is important for a level playing field in all member states. If State aid Guidelines would set a stricter limit than the CAP Strategic Plans regulation it would also be against a coherent policy between EU funded support schemes and national funded schemes. Hence, MTK thinks that Option 2 is the minimum change needed i.e. the adaptation of the State aid rules to the new legal framework of the CAP, but we also think that if possible within this timeline the system should be streamlined and simplified.
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Meeting with Nathalie De Basaldua Lemarchand (Cabinet of Vice-President Jyrki Katainen)

27 Feb 2019 · Sustainable Finance

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

19 Feb 2019 · Role of cooperatives in the EU

Meeting with Jyrki Katainen (Vice-President)

18 Dec 2018 · Cooperatives and Future of Europe

Meeting with Marika Lautso-Mousnier (Cabinet of Vice-President Jyrki Katainen)

26 Oct 2018 · Bio-economy strategy and regulation on pesticides

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

17 Oct 2018 · Functioning of food market

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

13 Sept 2018 · Drought in Northern Europe

Meeting with Jyrki Katainen (Vice-President)

11 Sept 2018 · MFF/CAP; Drought support payments; Transparency of food chain pricing; Fertilisers/circular economy; Erasmus for farmers

Response to Initiative to improve the Food Supply Chain

14 Jun 2018

The Central Union of Agricultural Producers and Forest Owners (MTK) welcome the Commission’s proposal for a Directive to curb UTPs in the food supply chain. MTK did join the voluntary Supply Chain Initiative (SCI) platform in Finland. MTK did also leave the voluntary system because it did not work. Purely voluntary systems do not work. We need an European solution and a directive is perfect, as Member States can then make it work with their own legislative system and special problems. Still having a directive in place will make sure that there is a level playing field for economic operators across the EU and it will ensure a proper functioning of the internal market and prevent its fragmentation. We do however feel that the directive can still be improved. There should be a definition of UTPs. A list of forbidden UTPs is not enough, as new UTPs surely will be invented. A list can never be exhaustive. The definition should capture the principles and essence of an UTP. An UTP is unfair, unethical and abusive and usually transfers risks or costs from the stronger one to the weaker one. The scope of the directive should be larger. It should be applicable to all businesses and not only to SMEs suppliers and non-SMEs buyers. Finland has a small and an extremely concentrated market and the fear factor is always present. When a microsized company is dealing with an SME is can be subjected to UTPs. Therefore the scope needs to be larger and include selling to and SME. Regarding monitoring, control and enforcement, we think these are essential. These should fall under the responsibility of an independent authority. Especially when it comes to the enforcement of the legislative provisions the authority should be acting in a proactive and robust manner. Sanctions should aim to eliminate any financial gain or benefit from noncompliance and deter future noncompliance. The authority must be able to receive anonymous complaints and initiate and conduct “ex-officio” investigations. Farmers being the weakest link in the chain are suffering their impacts and they cannot endure this situation any longer. When unfair and unethical behaviour leads to financial gains, only legislation backed by proper enforcement can deliver the necessary results. We need a cultural change in the business ethics. The European Commission and Member State authorities must implement a coordinated approach to prevent aggressive, unfair and abusive commercial practices that do not serve consumer interests.
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Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

14 Jun 2018 · Business discussion

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska)

14 Jun 2018 · bioeconomy

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

13 Jun 2018 · CAP reform

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

4 May 2018 · Preparation of CAP proposals

Meeting with Phil Hogan (Commissioner)

9 Apr 2018 · Forestry Issues

Meeting with Jyrki Katainen (Vice-President)

9 Apr 2018 · Agricultural Policy, Circular-Bioeconomy, Trade

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

9 Apr 2018 · Future of CAP

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

4 Apr 2018 · Business discussion

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

27 Mar 2018 · Sustainable agriculture

Response to Update of the 2012 Bioeconomy Strategy

19 Mar 2018

- The update of EU´s bioeconomy strategy is needed to include all the recent global policy developments, such as UN Sustainable Development Goals and Paris Agreement - Current strategy highlights food security and this should in the focus also in the upcoming strategy. Sustainable growth of the sector can be achieved by stronger inclusion of sectors that use non-food products as raw material, such as forestry. Also, better inclusion of blue bioeconomy should strongly supported. - In the EU forests don´t generally compete with food production so they provide the most socio-economically sustainable biomass source for the increasing need to substitute fossil-based raw materials. - Revision of strategy offers opportunity to increase policy coherency with relevant EU policies. Especially connections to CAP, Rural Development policies and EU´s Forest Strategy should be strengthened to ensure strengthening support for the education and training. - Bioeconomy isn´t just using biomass to substitute fossil-based raw materials and research and development how these goals could be achieved. Most importantly it is about changing the society to evolve from fossil-based economy, where markets are in the hands of few operators towards socially and environmentally sustainable circular bioeconomy, where benefits of the markets are distributed more evenly. For example, in the EU forest covering around 40% of the land area of which one-third is owned by 16 million private forest owners. - Forest owners’ and important role as the provider of sustainable raw materials and multiple ecosystem services should be acknowledged. Functioning markets and incentives should be created to support multipurpose sustainable forest management, innovation, capacity-building and value-adding networks. The EU Bioeconomy Strategy should acknowledge and support forest owners when they are promoting multipurpose forest management with sufficient incentives and subsidies. For example, water management, recreation, climate change mitigation etc. should be financially supported when there are no such markets available. - Supporting the creation of new markets should be one of the main focus of the strategy. Use of market-based tools to should be used and SMART indicators that would measure also socio-economic factors.
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Meeting with Vytenis Andriukaitis (Commissioner) and

6 Mar 2018 · African Swine Fever, Animal welfare

Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development)

7 Dec 2017 · Exchange of view on the future of the CAP

Meeting with Jyrki Katainen (Vice-President)

30 Nov 2017 · CAP and MFF

Meeting with Jon Nyman (Cabinet of Vice-President Cecilia Malmström)

30 Nov 2017 · Oveview of Trade Policy Agenda

Meeting with Marika Lautso-Mousnier (Cabinet of Vice-President Jyrki Katainen)

21 Sept 2017 · Topical issues in the field of agriculture & health policies, including LULUCF, Sustainable criteria, animal health

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

6 Sept 2017 · Progress of CAP reform

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

10 May 2017 · Organic greenhouse production in the northern parts of the EU

Meeting with Jyrki Katainen (Vice-President)

20 Mar 2017 · Future of the CAP and MFF

Meeting with Isabelle Magne (Cabinet of Vice-President Cecilia Malmström)

9 Mar 2017 · Anti-microbial resistance

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

7 Mar 2017 · The milk market situation in Finland and future CAP with focus on milk production

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

9 Feb 2017 · CAP and trade, energy, animal welfare

Meeting with Antti Timonen (Cabinet of Vice-President Jyrki Katainen)

7 Dec 2016 · Energy package

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

14 Nov 2016 · Forestry

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis)

31 Oct 2016 · Food waste

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

18 Oct 2016 · EU nature policy

Meeting with Jon Nyman (Cabinet of Vice-President Cecilia Malmström)

22 Sept 2016 · Overview of Trade Agenda

Meeting with Jyrki Katainen (Vice-President)

15 Jun 2016 · Agriculture climate

Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan)

15 Jun 2016 · Climate change, LULUCF

Meeting with Arunas Ribokas (Cabinet of Commissioner Vytenis Andriukaitis)

21 Apr 2016 · Exports to Russia of lactose free dairy products

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

4 Mar 2016 · Bioeconomy

Meeting with Jon Nyman (Cabinet of Vice-President Cecilia Malmström)

18 Feb 2016 · General Trade Policy + Possible visit of Commissioner to Finland

Meeting with Carl-Christian Buhr (Cabinet of Commissioner Phil Hogan)

27 Jan 2016 · Policy developments on the food supply chain; Finnish situation

Meeting with Elisabetta Siracusa (Cabinet of Commissioner Phil Hogan)

24 Sept 2015 · Crises package for Milk production; State of play of advance of CAP payments, • Direct payment and simplification

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

13 May 2015 · Forest and Agricultural policy

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

14 Apr 2015 · Permanent grassland

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

23 Mar 2015 · Bioeconomy and air quality

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

13 Mar 2015 · Forestry policy

Meeting with Aura Salla (Cabinet of Vice-President Jyrki Katainen)

9 Mar 2015 · Investment Package

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

5 Feb 2015 · Simplification, Retail chain, Dairy industry consolidation, Commissioner's visit to Finland

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

28 Jan 2015 · Bio economy

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen) and Landbrug Fødevarer - Danish Agriculture and Food Council

21 Jan 2015 · Competitiveness of agriculture sector

Meeting with Jyrki Katainen (Vice-President) and

4 Dec 2014 · Investment initiative