OpenLobby.EU
Explore

Natuur Milieu

Dutch environmental non-governmental non-profit organisation.

Lobbying Activity

Response to Clean corporate vehicles

8 Sept 2025

Response from Natuur & Milieu to the European Commissions Call for Evidence on Clean Corporate Cars and Trucks Natuur & Milieu strongly supports the Commissions initiative to accelerate the transition to zero-emission (ZE) corporate fleets, both cars and trucks. Corporate vehicles play a decisive role in transport-related CO emissions, and EU-level action is essential to ensure a fair, effective, and timely transition. This legislation will be a key measure to support the planned phase-out of internal combustion engine (ICE) vehicles. Corporate Cars In the Netherlands, 60% of new car registrations are corporate cars, and they are responsible for around 75% of road transport emissions. Accelerated electrification of this segment will significantly reduce CO emissions and strengthen public support for climate policy, including ETS 2. As corporate cars enter the second-hand market more quickly, households will gain access to affordable EVs and be better protected against rising fuel costs. Although the total cost of ownership (TCO) of EVs is already favourable for employers, 3 in 10 new corporate cars are still ICE vehicles in the Netherlands. While subsidies and fiscal incentives were effective in the past, this type of measures are no longer sufficient to drive the systemic change required as they are costly. At this stage, regulatory measures are more effective, but they need an EU-level framework. Natuur & Milieu therefore recommends binding EU targets for large employers (100+ or 250+ employees), aiming for at least 90% EV share in new corporate car sales by 2030. Member States should be allowed to go further, with more ambitious national targets or sub-targets for specific company categories. Corporate Freight Large enterprises (250+ employees and turnover above 50 million) are responsible for the majority of freight movements in the EU. Yet the actual transport is often carried out by very small operators: in the Netherlands, 74% of companies run five or fewer vehicles. These small firms lack the financial strength to make the upfront investments in ZE trucks, vans, and charging infrastructure, resulting in an uneven playing field. To accelerate the transition, shippers themselves must be made responsible for ZE deliveries. Shared responsibility between shippers and transport companies will ensure investments in both vehicles and infrastructure are distributed more fairly. Natuur & Milieu therefore calls for binding EU-level targets for the share of zero-emission ton-kilometres in corporate freight. This is the most appropriate metric, as it captures responsibility across the value chain while allowing flexibility in compliance. Conclusion EU legislation should establish clear minimum targets that accelerate the transition, while leaving room for Member States to go further. Binding requirements for corporate cars and trucks will deliver large-scale emission reductions, create a fairer competitive environment, and provide households and small businesses with better opportunities to participate in the zero-emission transition.
Read full response

Response to European Climate Law amendment

8 Sept 2025

Natuur & Milieu strongly supports setting the EU on a 1.5°C-consistent pathway. The climate crisis and current geopolitical reality require a high, binding, and inflexible 2040 reduction target, supported by a separate, transparent carbon removal target. This separation is essential to ensure that uncertainties around carbon removal do not delay the urgent emission reductions we need. We therefore call on the European Commission to: Enshrine a binding 2040 reduction target of at least 9095% greenhouse gas emissions compared to 1990, in line with the advice of the ESABCC. Introduce a distinct, binding target for carbon removal of 5-10% of the emissions compared to 1990, so that reduction and removal efforts complement each other but do not substitute one for the other. This is in line with the EC impact assessment that works towards 400 Mton CDR in 2050. The rest of our argument can be found in the attached file.
Read full response

Meeting with Petr Lapka (Head of Unit Agriculture and Rural Development) and Stichting BirdLife Europe and

4 Sept 2025 · Exchange of views on the next CAP proposal

Meeting with Tom Berendsen (Member of the European Parliament) and Natuurmonumenten

3 Sept 2025 · Industry and climate

Meeting with Jessika Roswall (Commissioner) and

20 May 2025 · Water legislations and Natura 2000

Response to Amendment of the EU ETS Monitoring and Reporting Regulation (MRR) in response to the ETS revision/Fit For 55 (Batch 2)

26 Jul 2024

Truly effective climate policy for aviation requires addressing worldwide non-CO2 climate effects. Aviation contributes to the warming of our planet. This is because greenhouse gases are released during flying. But that's not all. There is increasing understanding that the so-called non-CO2-related climate effects of aviation have an even greater impact. It's time for action. Why are non-CO2 effects important? The climate impact of non-CO2 effects is greater than the CO2 effects of aviation. Non-CO2 effects are estimated to be responsible for two-third of aviation's climate impact. Non-CO2 effects are of much shorter duration and are strongly influenced by atmospheric conditions and the timing that the emissions occur. Addressing non-CO2 effects has a direct and significant impact and is a highly effective way to reduce the total climate impact of aviation. Mitigating non-CO2 climate effects can quickly reduce warming pressures on the climate system, thereby reducing the likelihood of crossing tipping points that lead to irreversible and significant changes in the earths climate and ecosystems. While reducing CO2 should remain the primary focus, reducing non-CO2 climate effects provides the easiest and risk-free opportunity to significantly reduce the impact of aviation. It is the best opportunity for the aviation sector to significantly lower its climate impact in the short-term without having to reduce its total energy usage, as the transition to alternative fuels and more efficient technologies will probably take decades. What do we think of the EU Commission proposal? We are therefore pleased that the EU Commission proposes to implement the first step to mitigating non-CO2 climate effects, by including Monitoring, Reporting and Verification (MRV) obligations. This will aid in better understanding the issue, and guide the development of policies to implement mitigation solutions. It will help to achieve the overarching goals of the Paris Agreement of limiting global climate change. However, we are disappointed that in this revision, the scope has been weakened to exclude flights departing from- or arriving into the EEA at least until 2027. Exactly these long haul flights have a disproportionate non-CO2 climate effect, as formation of contrails mainly occurs at the high altitudes of long-distance flights. Excluding them from the non-CO2 monitoring scheme would therefore keep the by far largest part of the non-CO2 climate effects unmonitored. Which will make it harder to formulate effective policies to implement mitigation solutions. The revision will therefore prevent the Commission to reach its goal to be able to understand factors and conditions influencing non-CO2 effects in order to develop effective measures. Our key recommendations 1. Include all routes in the monitoring obligation for aircraft operators. Also those arriving in or departing from outside the European Economic Area (EEA) 2. Formulate and implement regulation to reduce non-CO2 effects as soon as possible as an easy-to-abate effect and as fair contribution of the aviation sector that has so far hardly contributed to the reduction of CO2 emissions. In the attached file, we elaborte on our key recommendations.
Read full response

Response to Commission Directive amending Annex III of the Nitrates Directive

16 May 2024

We support the use of valuable raw materials like manure (animal or human) rather than chemical fertilizers in favor of a circular economy. We have, however, major concerns about the proposal of the European Commission to allow the application of RENURE above the threshold of 170 N/ha/year for animal manure. You can find our view in the supporting PDF document. In short, our recommendations: We urge the European Commission to withdraw this draft-decision and take it back into the process of the Nitrates Directive evaluation. Should the proposal make a comeback in this process, we have the following recommendations: 1) Drastically reduce the maximum allowable amount of N in RENURE exceeding the 170 kg N/ha/year 2) Take over the responsibility from Member States to decide on the maximum allowable total amounts of N applied and restrict these fertilization rates according to what is needed to achieve the objectives of the Water Framework Directive. Thereby, consider changing climate conditions due to which nitrogen leaching is enhanced. This should ensure that livestock density is being limited. 3) Be more specific when it comes to stating that Member States take measures to prevent adverse effects in and around Natura 2000 areas, and in the vicinity of drinking water abstraction points. (Annex, c (vii)). We recommend to prohibit RENURE in these areas. 4) Substantiate the need for applying RENURE in excess of the 170 kg N/ha/year restriction and come up with scientific sound evidence that this application will not lead to more leakage of nitrogen compared to the present situation.
Read full response

Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra)

20 Feb 2024 · Meeting with North Holland residents concerning Schiphol

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean), Rachel Smit (Cabinet of Commissioner Adina Vălean)

20 Feb 2024 · Balanced Approach for the temporary reduction of the Amsterdam Airport Schiphol

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

26 May 2023 · EU Airport slot regulation

Meeting with Jan Huitema (Member of the European Parliament, Shadow rapporteur) and European Potato Trade Association

14 Nov 2022 · Sustainable use of plant protection products

Meeting with Mohammed Chahim (Member of the European Parliament, Rapporteur)

19 Apr 2022 · FF55

Meeting with Esther De Lange (Member of the European Parliament, Rapporteur)

1 Mar 2022 · Social Climate Fund

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

2 Dec 2021 · Coalition for sustainable travel by rail

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

15 May 2020 · Railways and a green recovery

Meeting with Frans Timmermans (First Vice-President) and Greenpeace European Unit and

15 Oct 2019 · Discussion on climate and biodiversity

Response to Evaluation of the Alternative Fuels Infrastructure Directive

19 Mar 2019

The 2014 Alternative Fuels Infrastructure Directive is not fit for purpose Emobility is at the core of decarbonising Europe’s transport, since all new cars and vans and most new trucks sold in early-2030s will have to be zero emission if Europe is to comply with the Paris Agreement. This requires a speedy and comprehensive roll-out of charging infrastructure across Europe, but the current Directive 2014/94/EU is not aligned with EU’s climate goals or in line with the expected roll-out of electric vehicles (EV). It has failed to achieve core objectives of sustainability and comprehensiveness: 1. The inclusion of fossil fuels such as CNG, LNG and LPG in the definition of alternative fuels contradicts the EU’s full decarbonisation goal, which requires the entire vehicle fleet to be zero-emission by 2050. Continuing to include these fuels would lead to stranded assets and public funds being invested in soon-to-be obsolete fossil infrastructure. The binding nature of these infrastructure targets should therefore be removed. Crucially, the revised directive should focus on the deployment of infrastructure for zero emission and zero emission capable vehicle technologies. 2. Currently, the uneven infrastructure coverage across Member States jeopardises cross border e-mobility, as highlighted by the Commission evaluation of the National Policy Frameworks. To remedy this, the NPF should be replaced by country specific binding and enforceable targets. The directive’s current focus on the TEN-T Core network is not sufficient, as these locations only partly cater for EV drivers’ needs, especially in remote areas. The revised directive should mandate full coverage of the TEN-T Core Network in early 2020s and the TEN-T Comprehensive Network by 2025. Post-2020 infrastructure requirements for road vehicles It is important that the EU policy framework for infrastructure is consistent with its policy milestones, notably the recently agreed 2nd and 3rd mobility packages, to ensure e-charging is rolled out in line with the expected market developments. The definition of recharging power in the AFID should be regularly updated in line with technological progress, notably for ultra-fast charging. The current ratio of 10 EVs to one public charger is not adequate, in particular in urban areas. The Commission should base the new directive on an improved methodology to assess these public charging infrastructure needs. A new metric for supply of public charging in urban areas should be set depending on, for example, city density and size and expected fleet of EVs. The new directive should ensure price transparency for drivers, including free roaming across Europe. Also, interoperability and adequate maintenance should ensure seamless access to EV charging networks across Europe. In addition, more transparent pricing, e.g. €/100km will also help raise consumer awareness of benefits of using EVs. The revision of AFID should create the right framework for the roll-out of zero emission (capable) heavy duty vehicles, in particular: ● Long haul along the TEN-T Core network. The EC should investigate how the different zero-emission recharging (“dynamic” and road-side) and refuelling (hydrogen) technologies can coexist, be encouraged and mandated. ● Urban and regional delivery: adequate fast and ultra-fast charging infrastructure should be interoperable between all truck types and other vehicles such as buses, coaches, cars and vans. On-shore power supply (OPS) So far, no Member State has set any target for the provision of shore side electricity. In order to incentivise the use of OPS, the Directive needs to: ● Make OPS infrastructure mandatory in all ferry and cruise passenger terminals across Europe by 2023 and be adequate for propulsion of ships. ● Require OPS in all cargo ship terminals on a mandatory basis by 2025 at the latest.
Read full response

Response to High and low Indirect Land-Use Change (ILUC) - risks biofuels, bioliquids and biomass fuels

20 Feb 2019

We would like to point out some faulty or unclear phrases in the draft legislation: - It is stated that ILUC leads to additional GHG emissions and intensification of production does not. However, also intensification of production leads to additional release of GHG emissions, especially when carbon stocks of the soil are not well maintained -A historical analysis of growth is a very poor way to determine if a crop can lead to ILUC effects or has a high ILUC risk. If you use this methodology only palm oil is high ILUC. Even soybean might qualify as low ILUC while it has very low performance as a biofuel feedstock (see for example Searchinger et al. "Assessing the efficiency of changes in land use for mitigating climate change") - The formula for calculating the share of expansion in land with high carbon stock benefits permanent oil crops, and reduces the chances of rotational crops that might benefit the soil. Also the treshold of 10% should be <1%. -There is no reason to make an exemption for small holders. This loophole might lead to much unwanted biofuel. -If you calculate additionality of production you should take into account a growing demand for food due to growth of world population and change of diet. This probably leads to a additional demand for food of 50 to 70% in 2050. Only additional sustainable production on top of this necessary growing production (baseline) can count as additional production that you can use in other ways. -Article 5.1 b) is unclear. Does it mean that if additional production is achieved by implementing measures maximum 10 years ago that this additional production might be eligible as low ILUC? This would not make sense. If it means that additional production might only count as low ILUC for a limited amount of time it makes more sense, but then the period is too long considering the high speed of increasing demand for food. -Article 6.1 a) and b) are very vague. What is 'reliable'? What is 'adequate'? -It is unclear how Article 6.2 can be implemented. How can you reliably verify that certain measures lead to certain additional production? How to connect the additional production reliably to specific biofuel production? How to correct for weather influences?
Read full response

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

15 Feb 2017 · Decarbonization of Transport and Electric Vehicles

Meeting with Miguel Arias Cañete (Commissioner) and ENGIE and

7 Feb 2017 · Decarbonization of Transport electric-vehicules

Response to Real-Driving Emissions in the EURO 6 regulation on emissions from light passenger and commercial vehicles (RDE3)

5 Dec 2016

The Netherlands Society for Nature and Environment (Natuur & Milieu, N&M) welcomes the Commission’s proposal on the 3rd RDE package as a timely step in the right direction to tackle particulate emissions from Gasoline Direct Injection cars and strengthen the RDE test procedure. It helps to reduce pollutant emissions from cars, which is very necessary to ensure EU citizens' health as well as recude pollution in general. Air quality is not improving fast enough in Europe, and traffic emissions are growing more important as the main cause. EU regulation is the only fair way, in accordance with internal market rules, to tackle these emissions across the continent. Following the Dieselgate scandal, N&M believes that transparency in any vehicle regulation is key. Which is why we are particularly concerned by two issues: - Firstly, the extension of RDE to measure PN emissions must be implemented without delay under the proposed timetable, i.e. 2017 for new types and 2018 for all new vehicles. Any slippage of either of these dates is unacceptable and would lead to delaying urgent investment needed to ensure the growing fleet of direct gasoline injection petrol cars meets the Euro 6 limit on the road. - Secondly, both the actual RDE test results and the maximum declared values for manufacturers must be made available in the public database in line with the Commission proposal. Any weakening of these important access to data provisions will seriously undermine RDE 3 and public information. There are orders of magnitude difference in emissions for vehicles fitted with gasoline particle filters and not, and drivers should be provided with this information. N&M considers the current draft text of the proposed 3rd RDE package to be the minimum acceptable to be effective. If there is any further weakening of the text during discussions in TCMV on the 20th December, N&M and many other stakeholders, including possibly the European Parliament; will have legitimate concerns as to the suitability of the new regulation and whether we should seek to have it rejected. There are several areas of potential improvements that should be made to the text, ideally now, or certainly before the 2nd step of RDE is introduced in 2020. These are: - Addressing ultra-fine particles (sub-23-nm) something the Commission recognises in recital 14. Further work is needed to extend measurement to these most dangerous to health emissions in order to include them by 2020 at the latest. - The approach used to account for higher cold-start emissions (point 27 in annex 2) should be replaced with a more accurate weighting process of their fair share in an average urban trip. Furthermore the possibility to use an up to 30s idling period between the engine start and the first movement of the vehicle (point 25 in annex 2) is a loophole to severely underestimate cold-start emissions of gasoline engines, and should be closed. - As regards regeneration events, N&M asks the TCMV to remove the possibility to use Engine Control Unit (ECU) data for detection of such evens to ensure RDE results cannot be manipulated by carmakers (point 19 of annex 2). The exhaust temperature should be used instead. We welcome recital 17 that allows updates of Ki factors to be closer to real-world situations, but the Commission should establish a public database with more realistic values from independent tests. - The conformity factors should be reviewed annually. N&M believes that the above changes will ensure that the on-road emissions tests are robust and accurately represent vehicles’ performance on the road. Which is a crucial and urgent mission that the EU should take very seriously.
Read full response

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

5 Oct 2015 · Dutch Presidency