Preferred by Nature
Preferred by Nature is a non-profit organisation that supports better land management and business practices that benefit people, nature and the climate.
ID: 550015650750-94
Lobbying Activity
Response to Roadmap towards Nature Credits
30 Sept 2025
Preferred by Nature feedback to the Roadmap towards Nature Credits 30th Sept 2025 Preferred by Nature would like to thank the European Commission for the opportunity to provide feedback to the Communication from the Commission to the European Parliament, Council, The European Economic And Social Committee and the Committee Of The Regions Roadmap towards Nature Credits. We would like to take this opportunity to express our reflections that nature credits can serve as a valuable additional tool to: reward voluntary good practice beyond legal requirements, leverage private funding, help meet ambitious restoration and biodiversity goals, Used properly, with integrity, transparency, strong standards - and in coordination with legal frameworks and public funding - nature credits could help accelerate the transition to a nature-positive economy without undermining essential obligations or risking biodiversity loss through loose offset logic. However, Preferred by Nature believes that they should not be treated as a substitute for obligations to avoid or reduce harm, or as a justification to rely on credits in lieu of necessary environmental regulation, and never as offsets. This would undermine the mitigation hierarchy, would have important challenges in terms of equivalence, permanence, and monitoring, and represent a big risk for greenwashing/perverse incentives. Please contact David Hadley, Regulatory Impact Programme Director with any questions or comments in relation to this submission at dhadley@preferredbynature.org.
Read full responseResponse to Verification of carbon removals, carbon farming and carbon storage in products
30 Jun 2025
Introduction (7): As per ISO 14065, the level of assurance is only required for verifications (re-certification), but not for validation (certification of compliance). (9): We do not understand the requirement for certification bodies to be accredited under relevant European standards if it is already required in Art. 13 of this Delegated Act that they shall be accredited in accordance with international standards several ISO). It will be a problem for existing certification bodies accredited by international accreditation bodies using those international standards. Art. 6. If both major and minor non-conformities (NC) shall be closed in the certification process, we suggest using the approach of some existing schemes of the Voluntary Carbon Market (VCM): Type 1: linked to the non-fulfilment of a requirement Type 2: linked to lack of information Art 6. 4. Major NC: Why should be a NC be repeated to be major? A one-time, single and isolated NC could also be major. Why systematic? There are non-systematic failures that can also be rated as major. (a): we suggest significant problems with GHG data reported, instead of repeated. (b): this as an example of a non-repeated violation. If it is an omission of declaration, should it be critical instead of major (reversible)? If this omission is voluntary, it could be classified as per point 3 (b) of this article: deliberate misstatement of activity description (c): example of non-repeated violation Art 7. The process and requirements for remediation measures to close non-conformities are not specified. In the case of critical, we understand there are no options, but in the case of major and minor, process and requirements are not clear. In the case of minor it is not clear if the certificate can be issued before remediation. 7.3. The condition to re-apply for certification in case of critical and major NC are described exactly in the same way. We are not sure if this description is correct in both cases. Suspension is not explained and included in the definitions Article. Art10. 10.2. The technical review is mentioned here for the first time. We suggest including it in definitions and/or a specific point in this Article 10. 10.3. Should audits be conducted in accordance with all three norms mentioned, or with any of them? 10.4.(f) Is this requirement linked with the non-conformities' remediation process? Art 11. 11.1. What is the difference, in terms of operator reporting and auditing, between re-certification and surveillance? Is it the same process but in different points in time? Is certification similar to validation and re-certification and surveillance to verification of ISO 14065? 11.3. The remediation measures mentioned in this point relate to the NC identified in the certification and re-certification or to the reversals. Art 12. 12. 6. .. which also represent at least 25% of the total area covered by the activities of the group... This 25% of the total area refers to total group area or total sample area? 12.7. We do not understand the justification of the need to audit group managers on-site, since they may not be representative and thus incur in bias. In this paragraph is the first and unique mention to on-site audits in the document. Are the on-site audits mandatory or voluntary for Certification audits in Article 11? Art 13.The appointment of CBs shall be done by the certification scheme or by the operator? 13.1 Verification as mentioned here is aligned with the definition of ISO 17029? Is validation also considered under CRCF? 13.2. Why the need to be accredited as CB taking into consideration the scope of the CRCF. E.g. would it be necessary to be accredited as CB in the case of carbon farming activities, or would it be enough to be a VVB? This is usually the case in exisiting carbon schemes in the VCM. 13.4. c.1. Sector-specific, not needed for CR and soil emissions More in the document attached.
Read full responseResponse to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)
13 May 2025
Preferred by Nature feedback on European Draft Delegated Act Ref Ares (2025) 3099313 - 15/04/2025 13th May 2025 #1: A formal definition is required of the terms second-hand products and used products. Preferred by Nature supports the intentions of Recital 4 and subsequent revisions to relevant wood and rubber products, to highlight where used products and second-hand products are excluded from the regulation. This measure leans to supporting a circular economy and resource-efficient practices , which may otherwise have been discouraged due to existing ambiguities. However, the words "used products" and "second-hand" are employed for the first time within the context of the EUDR and the EC has not provided a formal definition of these. Preferred by Natures own analysis has not found a formal definition of "used" in any previous EU legislation, although there is perhaps some customs usage of the terms. A working definition inferred from the definition of reuse in the End-of-Life Vehicles Directive (2000/53/EC) could consider used products as those which have been operated or consumed at least once. Second-hand goods are defined in the EU VAT Directive (2006/112/EC) as movable tangible property that is suitable for further use as it is or after repair References within the text: Recital (4) Certain entries in Annex I to Regulation (EU) 2023/1115 could give rise to ambiguity whether waste, second-hand and used products fall within the scope of Regulation (EU) 2023/1115, thus discouraging circular and resource efficient practices. Therefore, it should be made clear that waste as defined in Article 3, point (1) of Directive 2008/98/EC of the European Parliament and of the Council2, as well as second-hand and used products do not fall within the scope of that Regulation. Revisions to the Annex: revisions to relevant wood and rubber products referencing "used products" and "second-hand products". #2: A definition or interpretation is needed of what can be considered as scrap as used in Annex I. In the case of Pulp and paper of Chapters 47 and 48, recovered (waste and scrap) products are excluded from the scope of relevant products. While, in the case of 4017 (Hard rubber), and 4401 (Fuel wood), scrap is included within the scope of what would be relevant products for the EUDR. References within the text: References in the Annex to scrap in the definitions of relevant wood, paper and rubber products. #3: A definition or interpretations are needed, that illustrate the final stages in different processes for each relevant commodity or relevant products, where they can be considered at the end of their lifecycles. In the case of Pulp and paper of Chapters 47 and 48, recovered (waste and scrap) products are excluded from the scope of relevant products. While, in the case of 4017 (Hard rubber), and 4401 (Fuel wood), scrap is included within the scope of what would be relevant products for the EUDR. References within the text: Reference in the Annex to lifecycle in the definitions of relevant wood, paper and rubber products.
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