Stichting Feedback EU
Feedback EU
The preservation, protection and improvement of the environment for the benefit of the public interest, in particular in the areas of biodiversity, sustainable land use, the promotion of sustainable development and the prudent use of resources.
ID: 863953146634-48
Lobbying Activity
Response to Towards a Circular, Regenerative and Competitive Bioeconomy
23 Jun 2025
In our view as a food justice organisation committed to climate, nature, and people, the bioeconomy can have potential to contribute to Europes renewable energy needs and the protection of our oceans, but only if guided by robust sustainability principles, clear policy safeguards, as well as the consistent involvement of local communities. When it comes to the future production of biomethane in the EU, unfortunately, current approaches raise serious concerns. For instance, despite the REPowerEU plan being launched over 3 years ago, the Commission has yet to publish an impact assessment for its ambitious 35 bcm biomethane target, leaving critical environmental and socio-economic questions unanswered. We acknowledge that biomethane can play a role in Europes energy mix when it uses unavoidable waste streams - such as sewage sludge, industrial wastewater, or landfill gas - and when it is embedded within comprehensive waste prevention strategies. It is therefore crucial to prioritise the prevention and reduction of organic waste such as food waste and manure from animal production at source rather than creating incentives for its continuous generation. For manure production, this means that current unsustainable numbers of animals held in the EU do need to be reduced significantly rather than becoming dependent on the same levels as today to produce biogas and biomethane through anaerobic digestion. As highlighted by Foodrise, this also means that manure from industrial livestock production must no longer be treated as simple waste but as an integral by-product of an unsustainable farming system, with all the environmental damage - from methane emissions to nitrogen pollution - properly accounted for. It is misleading and harmful to frame manure-based biomethane as a clean solution: doing so perpetuates business-as-usual factory farming to maintain a steady supply of feedstock, which in turn drives land use change, biodiversity loss, and escalating climate impacts - here in Europe and in the Global South. Lastly, not every obstacle to biomethane expansion should be seen as a barrier to remove; some limits serve vital ecological and social functions and help maintain public acceptance. We therefore urge policy-makers to take into consideration evidence brought forward in our report "Biomethane from manure: a curse, not a cure"'. Europe must adopt a precautionary, prevention-first approach to organic waste and ensure biomethane development aligns with genuine sustainability in our food systems and local communities. When it comes to the role of fisheries in the European bioeconomy, the EU's Strategic guidelines for a more sustainable and competitive EU aquaculture underline that the environmental performance of the EU aquaculture sector can be improved, highlighting the need to limit feed producers reliance on fishmeal and fish oil taken from wild stocks. This must also be reflected in the updated Bioeconomy Strategy, shedding light on what a truly sustainable Blue Bioeconomy must deliver. However, marginal improvements are not enough; it is critical that the EU stops supporting and transitions away from extractive, high-impact forms of aquaculture such as seabass and salmon farming, which pose a large number of problems including mass fish die offs, increase in harmful algal blooms, plastic pollution and antimicrobial resistance. Foodrise's research into Mediterranean seabass and seabream farming (Ocean Takeover - Foodrise EU) as well as Scottish and Norwegian salmon farming (Blue food imperialism: how farming fish in Europe undermines food security and livelihoods in West Africa - Foodrise EU) has demonstrated that the use of wild fish is fuelling an ecological and social disaster. Instead, the EU should actively support aquaculture systems that do not harm marine ecosystems nor communities that depend on those healthy marine ecosystems for their livelihoods.
Read full responseResponse to European Democracy Shield
26 May 2025
As Foodrise, a small independent non-governmental organization based in the Netherlands, Brussels, and the UK, we are active in the field of food systems change. From launching legal action and producing hard-hitting research to working directly with local communities, we drive systemic change across food and farming powered by grassroots energy and backed by the facts. In our work, at European and national level, we experience an increasingly hostile and populistic debate driven by hatred against minorities and fake news. Fueled by foreign interference, this is leading to radicalization, online aggressions, and even physical attacks against policymakers and those running for office, as experienced before the last European elections. The rapidly declining trust in public institutions is also shown by many contributions to this public consultation, blaming the EU for restricting their right to express themselves, and condemning this initiative without solid underlying arguments. Importantly, only the trust in democratic institutions and processes, and the feeling that the EU is able to defend itself and its citizens will give us the possibility to solve the existential challenges we face as Europeans. We therefore welcome efforts to defend our democracy through the envisioned Democracy Shield. Such initiative must also protect the space for advocacy, protest, and participation - especially for groups operating outside traditional party structures. The European Democracy Action Plan should reinforce fundamental rights and ensure support for independent media, oversight bodies, and civic actors essential to democratic resilience. Furthermore, in light of an increasingly hostile environment for civil society organisations active at EU and national level, we call on EU policymakers to avoid policies that restrict civil society or reduce access to funding; as well as develop a robust EU-wide framework to support and protect CSOs, including legal safeguards and operational funding.
Read full responseResponse to The European Oceans Pact
16 Feb 2025
(All references can be found in the annex) Major international bodies such as the FAO, World Bank and also the EU have been calling for the development of aquaculture and the blue economy in the name of food security and to protect our oceans. While low-impact types of aquaculture can be beneficial to both the environment and people, an established body of evidence has shown that some forms of fish farming such as salmon and sea bass production have devastating effects on the environment (1) and people (2), have poor animal welfare (3) and high mortality rates (4), show low nutrient retention (5) and are highly dependent on feed raw materials (6) taken from the sea, such as fish meal and fish oil made from whole pelagic fish. Resistance to industrial fish farming is gathering pace around the world, resulting in restrictions (7) and bans (8) and making companies revise their expansion plans (9). Europe is not spared by the damaging nature of fish farming at industrial scale: in Greece, industrial sea bass farming is harming the environment and has led to citizen protests in places like Poros (10) and other localities in Greece (11). Organic deposits such as uneaten feed, dead fish or faeces accumulate under the farms, creating veritable dead zones. One farm can keep large amounts of fish, often numbering in the tens of thousands. To keep diseases and parasites in check, farm owners use harmful chemicals like formaldehyde and antibiotics which contaminate the surrounding ecosystem. Every year, the EU produces between 370000 and 520'000 tonnes of fish meal and 120'000 to 190'000 tonnes of fish oil, accounting for 10% to 15% of global production (12). This production is primarily based on catches of small pelagic species like sprat, sand-eels, blue whiting, and herring as well as trimmings from the fish processing industry. All these fish are human-edible and could be consumed directly instead of being extracted for production of FMFO. Furthermore, in its 2024 assessment of the EU's aquaculture policy, the European Court of Auditors has found that the European Union has been pouring funds (over 1 billion over 7 years) into the development of aquaculture without proof that this has contributed to the sectors environmental and social sustainability or its competitiveness. In light of the huge environmental and socioeconomic damage industrial aquaculture inflicts on communities in the European Union and in regions supplying feed, including West Africa, we call on you to ensure that the EU Oceans Pact prevents further harm from irresponsible fish farming, and incorporates the recommendations laid out in the Blue Manifesto (13).
Read full responseMeeting with Luis Carazo Jimenez (Head of Unit Agriculture and Rural Development) and Slow Food and
22 Jan 2025 · Exchange of views on the report “Trading away the future? How the EU’s agri-trade policy is at odds with sustainability goals"