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Suomen luonnonsuojeluliitto - The Finnish Association for Nature Conservation

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The Finnish Association for Nature Conservation is Finland's oldest and largest NGO dedicated to environmental protection and cultural heritage.

Lobbying Activity

Finnish Association for Nature Conservation demands safeguards for credits

30 Sept 2025
Topic — The European Commission is developing a roadmap for biodiversity-related nature credits.
Message — They insist that nature credits must not delay local or global biodiversity action. They demand implementation of the mitigation hierarchy and the removal of harmful subsidies.123
Why — This ensures that public funding remains a priority and environmental standards are maintained.45
Impact — Industries benefiting from harmful subsidies would lose significant financial support and regulatory leeway.6
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Meeting with Jessika Roswall (Commissioner) and

26 Aug 2025 · Working dinner with stakeholders hosted by Nordea Bank

Meeting with Eva Maria Carballeira Fernandez (Head of Unit Maritime Affairs and Fisheries) and ClientEarth AISBL and

15 Jul 2025 · Recommendations on how to address shortcomings in the ICES advice and requests

Finnish Nature Association supports EU-wide pollinator monitoring network

14 Jul 2025
Topic — EU consultation on standardizing monitoring methods for pollinator diversity and populations.
Message — The association warmly supports the establishment of an EU-wide pollinator monitoring network. It ensures the acquisition of minimum information from all member states.12
Why — Robust data will assist the association in monitoring the state of European nature.34
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Finnish conservationists demand strict ecological limits for bioeconomy

23 Jun 2025
Topic — The EU initiative focuses on creating a circular and climate-neutral bioeconomy.
Message — The association urges reducing biomass demand and prioritizing high-value products over energy. They advocate for binding cascading principles and including civil society in policy implementation.123
Why — Preventing overexploitation safeguards the ecological foundations necessary for long-term environmental health.45
Impact — The bioenergy and paper industries would lose access to cheap, primary biomass.6
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Response to European Democracy Shield

25 May 2025

Suomen luonnonsuojeluliitto on maamme vanhin ja suurin ympäristöjärjestö. Toimimme valtakunnallisen tason lisäksi maakunnissa (15 piiriä) ja kunnissa (149 paikallisyhdistystä). On hyvä, että EU ottaa vakavasti demokraattisen tilan supistumisen vaarat. Kyse ei ole vain Euroopan ulkopuolisten vaikutusyritysten lisääntymisestä. Näitä ongelmia on myös EU:ssa ja sen jäsenmaissa. Huomattakoon, että vastaavia huolia on käsitelty EU:n lisäksi myös yleiseurooppalaisessa Euroopan neuvostossa. EU:n toimet ovat kuitenkin tärkeitä, koska sillä on mahdollisuus tehdä sitovaa lainsäädäntöä ja ohjata toimia tukevaa rahoitusta. Eurooppalaiseen demokraattiseen kilpeen soveltuvat hyvin seuraavat Pohjoismaisten ympäristöjärjestöjen Helsingissä 7.5.2025 pitämän kokouksen suositukset päättäjille: 1. Suojelkaa ympäristöjärjestöjen demokraattista roolia. Turvatkaa, että ympäristöjärjestöt ja niiden jäsenet voivat osallistua julkiseen keskusteluun, päätöksentekoon ja oikeusprosesseihin ympäristöasioissa täysin Århusin yleissopimuksen mukaisesti. 2. Vastustakaa poliittisia pyrkimyksiä hiljentää ympäristövaikuttamista. Torjukaa kertomukset ja politiikka, jotka pyrkivät vähättelemään ympäristöjärjestöjen työtä tai kansalaisten oikeutta puhtaaseen ilmaan, veteen ja terveelliseen ympäristöön. Turvatkaa pääsy ympäristötietoon, läpinäkyvä päätöksenteko, oikeussuojakeinot ja merkityksellinen kansalaisosallistuminen. 3. Puolustakaa kansalaisyhteiskunnan tilaa ja oikeusvaltioperiaatetta ympäristöasioissa Ottakaa selkeä kanta kansalaisyhteiskunnan ja ympäristöaktivismin kutistumista vastaan maailmanlaajuisesti. Vahvistakaa demokraattisia periaatteita ja pitäkää oikeusvaltioperiaate keskiössä ympäristöhallinnossa Pohjoismaissa. 4. Turvatkaa ympäristöjärjestöjen kestävä rahoitus. Tunnustakaa julkisesti tuettujen, kansalaisten perustamien ympäristöjärjestöjen elintärkeä rooli ja varmistakaa, etteivät ne joudu taloudellisesti ahtaalle tai estetyksi puolustamasta luontoa, ilmastoa ja ympäristöoikeudenmukaisuutta. SUOMEN LUONNONSUOJELULIITTO RY Toimeksi saaneena Tapani Veistola toiminnanjohtaja
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Response to Updating the list of invasive species threatening biodiversity and ecosystem services across the EU

24 Mar 2025

Suomen luonnonsuojeluliitto on Suomen vanhin ja suurin ympäristöjärjestö. Olemme toimineet vieraslajiasioissa vuosikymmeniä. Teimme esimerkiksi aloitteen Suomen kansallisesta strategiasta MTK:n kanssa vuonna 2002. Olemme toimineet ja toimimme nytkin monissa asiaan liittyvissä työryhmissä ja LIFE- ym. hankkeissa. Tässä lausunnossa kommentoimme kahta lajia: amerikanmajavaa ja minkkiä. 1 Amerikanmajava (Castor canadensis) Amerikanmajavaa eli kanadanmajavaa esiintyy EU:ssa vain Suomessa. Suomesta sitä on levinnyt myös Venäjän puolelle. Suomella on kansainvälistä erityisvastuuta siitä, ettei niitä levisi enää enempää eikä laajemmalle. Suomessa amerikanmajavasta on myös hyötyjä monille lajeille ennen muuta tekemiensä kosteikkojen kautta. Toisaalta euroopanmajavasta saadaan aivan samat hyödyt. Siksi amerikanmajavan metsästys pois euroopanmajavan tieltä on kannatettavaa. Sitä tehdään jo nyt vähän esiintymisalueen reunoilla, mutta EU:n vieraslajiasetus vauhdittaisi myönteistä kehitystä. 2 Minkki (Neogale vison) Minkki luokiteltiin jo vuoden 2012 Suomen kansallisessa vieraslajistrategiassa erityisen haitalliseksi vieraslajiksi. Se oli sen luettelon ainoa selkärankainen eläin. Sitä koskevat myös kotimainen vieraslajilaki ja -asetus. Minkin poistaminen erityisesti lintuvesiltä ja -kosteikoilta on Suomessa vakiintunut toimenpide. Se on monissa merikansallispuistojen ja lintuvesien hoitosuunnitelmissa sekä SOTKA-lintuvesihankkeessa. Minkin lisääminen myös EU:n vieraslajiluetteloon on tieteellisesti hyvin perusteltu. EU-luettelon lisäarvo on se, että se koskee myös maita, joissa ei ole riittävän tehokkaita omia kansallisia vieraslajisäännöksiä. Lisäksi kokemusten mukaan kansainvälinen yhteistyö on välttämätöntä haitallisten vieraslajien torjunnassa. Huomattakoon, että kysymys turkistarhauksesta ratkeaa eri prosessissa kuin tässä poikkeusluvan mahdollisuuden takia. 3 Yhteenveto Suomen luonnonsuojeluliitto kannattaa esitystä. SUOMEN LUONNONSUOJELULIITTO RY Toimeksi saaneena Tapani Veistola toiminnanjohtaja
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Finnish nature group urges mandatory legal standards for restoration plans

7 Feb 2025
Topic — Creation of a uniform format for member states' National Restoration Plans under EU law.
Message — The final reporting template must ensure all legal requirements are mandatory to guarantee compliance and transparency. Member States should base decision-making on best available scientific knowledge and ensure inclusive public participation. The format must include detailed sections on financial needs and long-term planning for 2050 targets.123
Why — This would ensure full legal compliance and prevent governments from weakening nature restoration commitments.4
Impact — Member States lose reporting flexibility and face higher administrative burdens by making all requirements mandatory.5
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Meeting with Maria Ohisalo (Member of the European Parliament) and WWF European Policy Programme and Greenpeace European Unit

22 Jan 2025 · Forest Monitoring

Meeting with Katri Kulmuni (Member of the European Parliament)

11 Nov 2024 · Parlamenttikauden ympäristökysymykset

Meeting with Eero Heinäluoma (Member of the European Parliament) and Finnish trade union representation to the EU

16 Oct 2024 · Ajankohtaisaiheet

Meeting with Ville Niinistö (Member of the European Parliament)

16 Oct 2024 · Biodiversity, climate

Meeting with Li Andersson (Member of the European Parliament)

15 Oct 2024 · Environmental politics

Meeting with Maria Ohisalo (Member of the European Parliament) and Fern

15 Oct 2024 · Conservation

Meeting with Li Andersson (Member of the European Parliament)

15 Oct 2024 · Environmental policy

Meeting with Mika Aaltola (Member of the European Parliament)

4 Oct 2024 · EU Climate Policy

Finnish Nature Association Urges Stronger Natural Carbon Sink Targets

2 Jul 2024
Topic — Evaluation of EU rules for managing greenhouse gas emissions and removals from land.
Message — The organization calls for absolute national targets and longer reference periods to ensure policy stability. They demand that technological carbon capture remain separate from land use targets and not replace natural ecosystems. They argue that limiting forest harvests is the most effective way to store carbon.123
Why — Stricter EU requirements would force the Finnish government to implement long-delayed land protection measures.4
Impact — The forestry sector faces economic losses from restricted harvest levels and potential new carbon taxes.56
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Finnish conservation group opposes changes to EU nitrates directive

8 Mar 2024
Topic — EU rules protecting water quality by reducing nitrate pollution from agriculture.
Message — The organization urges the Commission to keep the directive unchanged, strengthen enforcement, develop an integrated nutrient management plan to halve emissions by 2030, and grant no further exemptions. They call for a shift to agroecological farming methods and plant-based diets.1234
Why — This would protect water ecosystems and biodiversity from agricultural pollution.56
Impact — Intensive livestock operations lose exemptions allowing higher manure application rates.78
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Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

29 Jan 2024 · Carbon removals

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

15 Jan 2024 · Relevant environment and animal welfare policies

Finnish conservation group urges stronger circular economy focus in EU minerals law

30 Jun 2023
Topic — EU regulation on securing supply of critical raw materials for green transition.
Message — The organization supports circular economy goals but warns the proposal threatens environmental protections and Natura 2000 sites. They request removing automatic permit approval provisions and strengthening recycling measures instead of prioritizing new mining projects.123
Why — This would prevent weakening of environmental protections and constitutional safeguards in Finland.45
Impact — Citizens lose environmental protections and participation rights in mining decisions affecting their communities.6
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Finnish conservationists urge EU to reach net zero by 2040

22 Jun 2023
Topic — The EU is consulting on establishing a climate target for 2040.
Message — The association demands that the EU reach net zero emissions by 2040 and implements a 90% cut in gross emissions. They also call for separate carbon removal targets and a budget based on global fairness.12
Why — Stronger targets would force the adoption of nature-based solutions that promote the group's core biodiversity goals.3
Impact — Fossil fuel and intensive agriculture industries would face significantly higher costs and a shorter transition period.4
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Finnish NGO urges deeper ecosystem approach in EU fisheries reform

23 Sept 2022
Topic — EU review of Common Fisheries Policy implementation and alignment with Green Deal objectives.
Message — The organization requests moving beyond maximum sustainable yield to ecosystem-based management that considers water quality and impacts on non-quota species. They want recreational fishing included under CFP rules and quotas, policy extended to inland waters, and replacement of relative stability principle with spawning state principle for migratory fish.1234
Why — This would strengthen marine ecosystem protections beyond their core conservation mission.56
Impact — Commercial fishing fleets lose flexibility as recreational fishers face new quota restrictions.78
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Finnish conservation group backs EU pesticide reduction regulation

19 Sept 2022
Topic — EU regulation on sustainable use of plant protection products and pesticide reduction.
Message — The organization supports the Commission's proposal and urges strict EU-level rules with limited national flexibility. They emphasize that directives give member states too much freedom to undermine environmental objectives, and call for stronger enforcement through economic instruments, monitoring, and sanctions.1234
Why — This would reduce chemical pollution and protect biodiversity and water quality across Europe.5
Impact — Conventional farmers lose flexibility to continue current pesticide-intensive agricultural practices.67
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Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

9 Sept 2022 · Deforestation Regulation

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

9 Jun 2022 · forest visit

Meeting with Ville Niinistö (Member of the European Parliament)

27 May 2022 · EU environmental law and mines (staff level)

Meeting with Silvia Modig (Member of the European Parliament)

20 May 2022 · Topical Issues (staff level)

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

16 Mar 2022

Luonnonsuojeluliitto katsoo tarpeelliseksi, että EU asettaa kynnysarvoja saastumiselle tieteellisin perustein sekä minimivaatimuksia maankäytön suhteen. Raja-arvot kytkeytyvät myös vesipuitedirektiivin ja vaarallisten aineiden lainsäädännän raja-arvoihin, normeissa voidaan huomioida paikallinen tausta. Samoin maa-alan käytön kestävyydelle tulee antaa sitovia tavoitteita. Ilmastonmuutos, kauppasotien riskit ja Euroopan turvallisuustilanteen muutos aiheuttavat myös riskejä maaperälle ja siitä riippuvalle elintarviketurvallisuudelle. Ravinteiden luonnollisen kierron turvaaminen on tärkeää viljelymailla. Biologisten jätteiden käsittelyä ja kompostointia ja palauttamista kiertoon turvallisesti kehitettävä. Toisaalta kiertotalouteen perustuvien maanparannus/rakennus ja lannoiteinnovaatioiden turvallisuus tulee selvittää hyvin kattavasti myös vähemmän tutkittujen haitallisten aineiden kuten teknologiametallien (esim. harvinaiset maametallit, koboltti) ja suola-aineiden (esim litium, strontium, sulfaatti) suhteen. Kehotamme EU:n toimielimiä sitoutumaan täysin Green Deal -strategioiden maaperään liittyviin tavoitteisiin: vähentämään ravinteiden ja kemikaalien käyttöä maataloudessa ja karjanhoidossa, lisäämään luomuviljelyn peittoa maata ja luonnonmaisemia maaseutualueilla, edistämään agroekologista maaseutualueiden luonnollisten elinympäristöjen ennallistamista, huonontuneiden, suljettujen tai saastuneiden alueiden maaperän ennallistamista ja uudistamista. EUssa tarvitaan vähimmäissäännöksiä maaperän suojeluun, koska monessa jäsenmaassa ei muuten tapahdu kotimaisesti riittävää kehitystä. Jäsenmailla tulee olla vähimmäistavoitteet rakennetun maan määrän kasvun hillitsemiseksi. Tavoitteeksi tulkoon maan käyttöönoton nettonollataso vuoteen 2050 mennessä ja tätä varten tarvitaan kunnianhimoiset välitavoitteet Maaperän suojelu Maaperän Terveyslain erityinen luku tulee omistaa koskemattoman maaperän, kuten metsien, laitumien, soiden, kosteikkojen ja niittyjen peittämä maaperä, suojeluun. Ne sisältävät suurimman mannermaisen orgaanisen hiilen varaston ja isännöivät merkittävintä maaperän biologisen monimuotoisuuden varastoa. koko Euroopan mantereelle. Pakollisten ehtojen maaperän suojelua koskevien tavoitteiden asettaminen on priorisoitava riittävästi, samoin kuin viljelymaan ekologisen tilan parantamista koskevat tavoitteet. Kannatamme säätelyä koskien kosteikkoja ja turvemaita sekä niiden ennallistamista johtuen merkityksestä hiilensidonnassa . Kosteikkojen suojelu on tärkeää paitsi maaperän hiilivarastojen myös vesiensuojelun, tulva- ja kuivuusriskien ja parantaa luonnon monimuotoisuutta. EU on sitoutunut suojelemaan kosteikkoja ja turvemaita YMP:n strategiasuunnitelma-asetuksella. Ns. pilaantumattoman maaperän tutkiminen ja riskien arvioiminen on hyvin tärkeää esimerkiksi malmikriittisillä ja muilla haitallisia mineraaleja luonnollisesti käsittävillä alueilla. Haitallisia ja vaarallisia sulfidi- ja asbestimineraaleja esiintyy sekä moreenissa, että mahdollisissa hyödynnettävissä kiviaineksissa. Louhinta ja kaivostoiminta:Tarvekiviaineksen ottoa tehdään kallioperän pintaosassa, joka johtaa laajojen pinta-maa-alueiden kuorimiseen ja varastoimiseen sekaisena läjityksenä. Kun tällaista tehdään, pitäisi maan elävimmät pintakerrokset säilyttää erillään, huolehtia niiden elinvoimasta ja palauttaa ne ehjinä uuteen kohteeseen. Toisaalta louhinta ja kaivostoimintaa voidaan tehdä tunneleissa ja kallioperän sisällä, jolloin maaperä pääosin säilyy. Kaivostoiminnan sivuvirtojen käyttöä rakentamisessa tulee edistää samalla kun otetaan metallit ja muut mineraalit tarkemmin talteen myös vanhoista jätteistä. Kaivostoiminnan jätteet ovat noin ¾ Suomen kaikista jätteistä ja yli 90% vaarallisista eli ongelmajätteistä ja oikeasti käsittäen vaarallisempiakin jätteitä jopa miljardeja tonneja, kuten Terrafamessa. Jätteitä kapseloidaan maanpinnalle tietäen, että ne tulevat vuotamaan. Kaivannaisjätedirektiivi saatettava voimaan maaperänkin suojaamiseksi.
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Meeting with Nils Torvalds (Member of the European Parliament)

10 Mar 2022 · Mining

Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

Mining wastes should be considered as a major waste problem. In Finland the limit for EIA for hazard waste handling is 5000 tons, when it would be disposed on a regular waste dump. However mining wastes are disposed on "mining waste areas" and no EIA is needed even for the environmental permit of Terrafame mine in Sotkamo and Kajaani in Finland. Terrafame has plans to dispose by capsulation 1 500 million tons mining wastes in a 30 years plan and possiblu 3000 tons in 60 years plan. Capsulations are known to leak sooner or later. Other hazard or regular wastes are totally irrelevant compared to mining wastes in Finland.
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Response to Evaluation of the Environmental Liability Directive and of its implementation

27 Dec 2021

Suomen luonnonsuojeluliitto (Finnish Association for Nature Conservation) is the oldest and biggest environmental non-governmental organisation in Finland. We strongly support the evaluation and strengthening of the Environmental Liability Directive (ELD). Our experience is that the idea of the ELD was very good. However, the ELD has been used only in a few cases in Finland. That is why the Polluter Pays Principle is not working and taxpayers have to pay remediation costs. In fact, usually nature is the last payer – because of lack of remediation. We think that the biggest gaps are in the very narrow definitions (“significant”, scope of “environmental damage”) and slow processes (there should be maximum time for starting remediation works in the ELD). There are brand new studies, for example Sándor Fülöp (ed.): “Improving implementation and the evidence base for the ELD” (COWI, Prospect, Justice and Environment, 2021), stating: “The problems analysed in the study include the availability of ELD-specific information in the Member States, the scarce use of the ELD laws in the specific sense, and also the time and costs of these procedures. The almost totally lacking ability and willingness of the operators to pay the costs shows even more how important is to develop the ELD systems towards ensuring more effective prevention of seemingly dangerous activities, not seldom reckless operations.” We encourage the Commission to strengthen both the ELD and implementation. On behalf of SUOMEN LUONNONSUOJELULIITTO Tapani Veistola Head of Environmental Policy Unit Acting Executive Director
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Response to Environmental Implementation Review 2022

18 Oct 2021

The need for coherence in environmental regulation is also further emphasized in the attempt to change the rule of law so that the problems of climate change and natural impoverishment can be effectively addressed. In the transformation of environmental regulation, the green transition is one of the developments shaping the economy of the EU region, which will affect the Member States in different ways. For example, the electrification of transport required more and more renewable and non-renewable natural resources. However, natural resources are unevenly distributed among Member States, which poses its own challenge to a fair transition. The transformation of green economic growth must succeed without increasing the consumption of natural resources, ie by decoupling economic growth from the use of natural resources so that the impoverishment of nature as a result of the pressure caused by human activities can come to a halt. The passage of the do not significant harm principle from various financial subsidies and all active human activities, such as the planning and construction of areas, must be the red thread of environmental regulation. Individual point-to-point regulatory changes do not reach different regulatory overlaps or gaps. Ex-ante and ex-post development of legislative impact assessments would be a first step towards a coherent and sustainable legal system at EU level and in the Member States.
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Response to European Bioeconomy Policy: Stocktaking and future developments

31 Aug 2021

The Finnish Association for Nature Conservation (FANC) thanks for the opportunity to give feedback about the European Bioeconomy Policy. FANC emphasizes the importance of stopping the biodiversity loss and increasing the natural carbons sinks and maintaining carbon storages and the central role the bioeconomy sector holds. In the current situation facing the climate and biodiversity crisis it is crucial that the planetary boundaries are recognised and respected. We need healthy well functioning ecosystems and natural carbon sinks and storages in order to survive. Bioeconomy has a key role in the issue. Root causes driving the collapse of biodiversity and other environmental issues must be addressed. The Bioeconomy Policy could give valuable information and solutions about how the European bioeconomy sector is contributing to the biodiversity loss and climate change and what could be done. Biomasses are often considered a great way to replace the fossils. However it is vital to make sure that the use of biomasses is sustainable. Biomasses are a limited resource we need to use wisely. The sustainable use and distribution of the limited resource needs to be considered closely. Everything cannot be replaced by biomasses. This means that the consumption patterns also need to be on a sustainable level. We need information and right kind of drivers to make sure that the biomasses used are produced, harvested and used sustainably and wisely within the planetary boundaries.
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Meeting with Jutta Urpilainen (Commissioner)

5 Jul 2021 · EU Forest Strategy.

Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental NGO in Finland. 1) EU legislation on packaging 
 The limits for dangerous wastes in the EU REACH packaging regulations are extremely high. They are often directly in huge conflict with the EU Water Framework Directive, Groundwater Directive, all dangerous and prioritized substance regulations and Mining Waste Directive, the goals of European Commission's Green Deal and the high ambition for zero pollution leading to a toxic-free environment.

 It is beyond common sense and definitely any scientific reasoning to state that everything present as portion under 0.1% is not dangerous. The worst substances are toxic as concentrations of million fold lower or less. Substance can be soluted from certain compositions to water even as much higher concentrations than the 0.1 %. Defining everything not being dangerous waste as non-dangerous waste is even much worse from the point of view of the high goals set for the regulations. The goal of zero pollution is really effectively undermined by the packaging regulation and its applications to wastes. The massive legislation is going to have a totally opposite effect than the suggested zero pollution. Therefore the system needs to be fixed based on the best science, and not the waste dumping preferences of the worst of the industries, which appears to be the status quo now. 

 2) Chemicals hazard classification
 The quality of chemicals safety information in REACH documentation – especially with regard to environmental safety but even to health effects – is varying and in many cases very poor. This reflects two problems: 
i) Industries and their consultants do not have competence or will to provide correct information. In some cases there is obvious abuse in using different chemical names to avoid finding the correct information from already available chemical databases.
 ii) The officials of the REACH organizations are not skilled or motivated enough to locate relevant scientific information about the chemical and especially ecologic effects of the substances.

 Solution is to create a scientific evaluation and comparison process of the information about toxicity and ecological impacts. It is the not best use of resources when EU industries would hire commercial consultants to even mislead the authorities and regulations. The REACH documentation for registration should not be produced by clearly industry dependent consultants, but by an independent scientific community and EU officials with the highest level research scientific skills. The data should be compared with the best international environmental and chemical authorities. This could actually reduce the bureaucracy and the costs for the companies two ways. Academic competence is cheaper than the commercial consultants, and the process can be streamlined as an expert process without the delays of the process caused by cheating or lack of competence by the company or by the regulator. The industry way of streamlining the process will likely involve weakening of the system.

 The EU REACH hazard and packaging documentation is often used as certificates for environmental safety in environmental permit processes or as evidence to avoid such processes. This is very harmful due to obviously and absolutely wrong ideas in packaging classification and presence of really substandard environmental information in substantial part of the documentation. 

The incomplete regulations are dangerous to people and the environment. The Commission is requested for urgent corrections.

 For the additional information: Special advisor, PhD Jari Natunen, 
jari.natunen@sll.fi 

 On behalf of SUOMEN LUONNONSUOJELULIITTO Tapani Veistola Acting Executive Director
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental NGO. 

 We think that the quality of chemicals safety information in REACH documentation especially with regard to environmental safety, but even to health effects, is varying and in many cases very poor. This reflects two problems: 
 i) Industries and their consultants do not have competence or will to provide correct information. In some cases there is obvious abuse in using different chemical names to avoid finding the correct information from already available chemical databases.
 ii) The officials of the REACH organizations are not skilled or motivated enough to locate relevant scientific information about the chemical and especially ecologic effects of the substances.

 Solution is to create a scientific evaluation and comparison process of the information about toxicity and ecological impacts. It is not the best use of resources when EU industries would hire commercial consultants to even mislead the authorities and regulations. The REACH documentation for registration should not be produced by clearly industry dependent consultants, but by an independent scientific community and EU officials with the highest level research scientific skills. The data should be compared with the best international environmental and chemical authorities. This would actually reduce the bureaucracy and the costs for the companies in two ways: Academic competence is cheaper than the commercial consultants, and the process can be streamlined as an expert process without the delays of the process caused by cheating or lack of competence by the company or by the regulator. (
These problems could be easily verified by taking random 1000 REACH chemical dossiers and giving them to the top academic research groups for evaluation for correctness against the state of the art scientific information.) 

The industry way of streamlining the process will likely involve weakening of the system. 

The EU REACH documentation is often used as certificates for environmental safety in environmental permit processes or as evidence to avoid such processes. This is very harmful due to the presence of really substandard environmental information in substantial part of the documentation. 

The limits of dangerous wastes set based on the REACH packaging regulations are extremely dangerous and often directly in huge conflict with standards EU Water Framework Directive, Groundwater Directive, all dangerous and prioritized substance regulations and Mining Waste Directive. It is beyond any scientific reasoning to state that everything present as a portion under 0.1% is not dangerous. The worst substances are toxic as concentrations of million fold lower or less. Substance can be soluted from certain compositions to water even as much higher concentrations than the 0.1 %. Defining everything not being dangerous waste as non-dangerous waste is even much worse from the point of view of the high goals set for the regulations. Therefore the system needs to be fixed based on the best science, and not the waste dumping preferences of the worst of the industries. This statement was prepared by our senior advisor Dr. Jari Natunen. On behalf of SUOMEN LUONNONSUOJELULIITTO Tapani Veistola Acting Executive Director
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Finnish conservationists urge EU to ban bottom trawling, protect endangered species

12 May 2021
Topic — EU action plan to conserve fisheries and protect marine ecosystems through technical measures.
Message — The organization wants improved fishing selectivity to reduce bycatch of mammals, birds and endangered species. They call for banning bottom trawling across the EU and better technical measures in the Baltic Sea for Cod and Salmon. They emphasize urgent protection for critically endangered Eel throughout the EU.1234
Why — This would protect Finland's endemic Saimaa Seal population from fishing nets and preserve Baltic marine habitats.56
Impact — Bottom trawling fisheries in other Member States would lose access to current fishing methods and areas.7
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Finnish Nature Group Calls for EU Diamond Mining Ban

10 May 2021
Topic — EU regulation updating the Kimberley Process certification scheme for rough diamond trade.
Message — The organization urges the EU to ban mined diamonds entirely and transition to synthetic alternatives. They argue diamond mining causes severe environmental harm and contradicts the Green Deal's 'do no significant harm' principle. They propose a vanity tax on environmentally costly jewels and carbon footprint controls.1234
Why — This would advance their core mission of protecting nature and reducing environmental destruction from mining.56
Impact — Diamond-dependent developing economies and EU diamond businesses lose income, though transition support is proposed.78
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Response to Protecting the environment in the EU’s seas and oceans

6 May 2021

Suomen luonnonsuojeluliitto (The Finnish Association of Nature Conservation) is the oldest and biggest environmental NGO in Finland. We have seen how the MSFD has given real added value and new ideas to our old national marine and environmental politics. The biggest gap has been in the implementation in the Member States: too little progress, too late, too little staff and resources. The main reason behind these problems is often in national administration. For example, in Finland CAP and CFP have been dominated by the Ministry of Agriculture and Forestry, and they don’t take environmental EU and national targets seriously enough in their semi independent silo. The solution is not in opening the MSFD, because the main problems are not in the Directive. That is why we agree with Option 3. Opening the Directive may take long time and cause more delays in the implementation and achieving GES. We think that the best answer is better integration in the EU and Member States (e.g. CAP, CFP, Blue economy, Biodiversity Strategy, EU funds etc.). In addition, some pieces of new binding complementary legislation can help MSFD and Member States to achieve the GES as soon as possible (restoration, ZPAP etc.). On behalf of SUOMEN LUONNONSUOJELULIITTO RY Tapani Veistola acting executive director
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Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

The Finnish Association for Nature Conservation thinks this guidance is not enough to ensure the sustainability of forest biomass used in energy production. We need a revision of the REDII in order to create a system that favors renewable energy solutions that are actually climate neutral and not based on burning. Burning of wood is not climate neutral and should not be treated as such. We need a criteria that makes a clear difference between the use of secondary forest biomasses and primary forest biomasses in energy production. We are calling for stricter sustainability criteria for forest biomasses. We need to stop burning tree trunks (over 10 cm diameter), stumps, deadwood, and biomass from protected areas. The sustainability criteria should be applied to all installations, not just those over 20 MW and 2MW. The guidance relies on national laws but the existing national laws are not enough to ensure the sustainability of forest biomasses from climate or biodiversity perspectives.  We hope that this guidance is a start for developing and putting to practice actually functioning sustainability criteria for forest biomasses. It is good that the guidelines mention (article 3, 1 b ii and article 4,1 b iv) that there should be no biodiversity degradation or degradation of primary, natural or semi-natural forests. Soil quality protection (in article 3, 1 b iv and article 4, 1 b iv) should be concerned especially in the peatland forestry as it causes CO₂ emissions each year from the long term carbon storage of forest soil. It is good that the article 4, 1 b iv mentions that clearcuts should be minimized and that there should be no collection of roots and stumps. These are all valid points but not enough and it is still doubtful that the guidance system presented will ensure that all the points mentioned above actually happen. In order to make sure that the guidance criteria is followed through there should be checks on the ground by auditioners or MS.
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Response to Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies

5 Apr 2021

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental NGO in FInland. We strongly support the development of the GBER and EEAG to implement new Green Deal targets, including Do Not Harm principle. This gives real added value to current EU environmental law obligations. The Green Deal goes beyond current directives. This should be taken into account in all public investments, too. That is why it is time to stop public investments in fossil fuels (including peat and infrastructure) and even small hydropower. Now it is time to restore freshwater habitats with e.g. fishways, so this kind of activity should be supported – no new dams anymore even to rivers with many old dams (when building is not always against the Water Framework Directive). The development in the energy sector is fast. Now we are worried about sustainablity of hydrogen and batteries. The impacts of hydrogen depend largely on the energy source, so only renewable hydrogen and R&D should be supported. There are similar problems with batteries: now they need minerals that may come from mines with problems in mining waste and waters or human rights. Only R&D of more modern batteries with lower environmental impacts should be funded. This is important also for the revision of the EU Battery Regulation. In addition, we are worried about sustainability of forest biomass. It can have severe problems with biodiversity, carbon sinks and storages etc. We need stricter criteria for forest biomass than the current RED legislation. On behalf of SUOMEN LUONNONSUOJELULIITTO RY Mr. Tapani Veistola Head of Nature Conservation Unit
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

( See document attached for full response)The Finnish Association for Nature Conservation (FANC) is the largest non-governmental organization for environmental protection and nature conservation in Finland. It has been a frontrunner in Finland’s environmental affairs since 1938. The purpose of FANC is to protect the Finnish natural environment, promote nature conservation, preserve cultural heritage and spark up active citizenship and strong environmental awareness. FANC welcomes the objectives seeked by the Commission’ s proposal for a regulation concerning batteries and waste batteries to reach circularity and protection of health and the environment.
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Response to 8th Environment Action Programme

31 Dec 2020

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental NGO in Finland. We warmly welcome and support the 8 EAP with good principles like Do Not Harm, planetary boundaries, wellbeing, monitoring and enforcement. Do Not Harm Principle is a good start. It should be implemented in all legislation and financing (including so-called Taxonomy). However, the Commission could develop it in the future even to more active and positive direction (e.g. Do Always the Best Thing for Nature). Implementation has been the biggest gap in earlier EAPs. Reporting in the European Semester and EUCOs is important. It is essential to get EU funds work for environmental targets. This time the biggest problems are in the CAP, which should be put into very strict control. It is wise to give more resources for EEA and ECHA. Monitoring is essential, and also Member States should keep long-term data series alive. If we have too few monitoring indicators, we don’t find all important changes early enough. Mid-term evaluation of the 8 EAP is important. In addition, minimising the EU footprint also in other countries is important. The role of trade agreements and sustainable financing is growing in achieving environmental targets. On behalf of SUOMEN LUONNONSUOJELULIITTO RY Tapani Veistola Head of nature conservation unit
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Response to Improving environmental protection through criminal law

30 Dec 2020

Suomen luonnonsuojeluliitto ry katsoo, että komission ehdotus ympäristönsuojelua koskevien EU:n sääntöjen parantaminen rikosoikeudellisin keinoin tarpeellinen ja kannatettava. Jäsenvaltioiden ympäristörikosten harmonisoinnilla voidaan Nykyisellä ympäristorikosdirektiivillä ei ole voitu riittävästi varmistaa ympäristönsuojelulainsäädännön täysimääräistä noudattamista jäsenvaltioissa. Lainsäädännön noudattamista voidaan ja sitä pitäisi parantaa sillä, että käytettävissä on rikosoikeudelliset yhtenäiset vähimmäisrangaistukset, jotka ovat luonteeltaan aivan erilainen osoitus yhteiskunnan paheksunnasta kuin hallinnolliset seuraamukset tai yksityisoikeudellinen korvausjärjestelmä. Harmonisoinnilla turvattaisiin myös sisämarkkinoiden parempi toimivuus, kun ympäristölle vahingollisella toiminnalla ei voida saavuttaa epäoikeudenmukaista kilpailuetua ja varmistettaisiin paremmin rajatylittävien ympäristövaikutusten kattava rikosoikeudellinen huomiointi. Suomen luonnonsuojeluliitto ry:n puolesta Ympäristöjuristi Matti Kattainen +358447785013 matti.kattainen@sll.fi
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Response to Revision of the Communication on important projects of common European interest

21 Dec 2020

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the biggest environmental non-governmental NGO in Finland. We warmly welcome the update of “Important Projects in the Common European Interest” (IPCEI) Communication to fulfil also all new environmental targets, as the Green Deal, Climate change and “Do Not Harm” principle. The IPCEIs have been rare, and the criteria should be very strict also in the future. Just now we are worried about possible hydrogen IPCEIs and their relation to EU environmental targets. It is wiser, better and safer to develop renewable energy (except hydropower and biomass, because of their other sustainability problems). Ex ante evaluations and mid term monitoring are essential in IPCEIs. Transparency and public participation are needed, too. SMEs are important and sometimes very flexible actors in innovations. However, we doubt how active they can be in IPCEIs. Perhaps more resources and know how is needed, at least at the beginning of these projects. We are looking forward to following this revision process. On behalf of SUOMEN LUONNONSUOJELULIITTO RY Tapani Veistola head of nature conservation
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Response to Revision of Regulation on Union guidelines for the development of the trans-European transport network (TEN-T)

18 Dec 2020

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental Non-governmental Organisation in Finland. We warmly welcome the modernisation of the TEN-T to implement European Green Deal, including Climate targets and do-not-harm principle for biodiversity. Traffic causes a quarter of GHG emissions in the EU and lots of other pollution. Some old-fashioned infrastructure projects have cut ecological corridors, split large wilderness areas and destroyed large amounts of forest and other habitats. They have caused problems for waters, too. The most interesting option is the third one: boosting digitalisation and innovation in the TEN-E policy. We should see traffic as a service – which can be achieved also digitally, not only physically by cars, trains or planes. The Covid-19 has led to a rapid digital revolution. Now everyone is used to video conferences, so it is not necessary to fly to international meetings anymore. For example, I had this morning a meeting with our Lapland region people, then a Christmas party with all our sister organisations in the Baltic Sea countries, and then a meeting with the Ministry in Helsinki. The speed in these travels was nearly as fast as a thought! It could not have been possible to have all these meetings at the same day physically in the range of some thousands of kilometers. This is decarbonisation but also very cost-effective working in post-industrial society. This is also something else than old-fashioned plans for “one hour trains” from Helsinki to Turku or Tampere: They need lots of space and raw materials, they cost 1-2 billion euros each, and they are not even economically suitable. In modern digital society light traffic, like cycling and walking, should get more attention in traffic policy. On behalf of SUOMEN LUONNONSUOJELULIITTO RY Tapani Veistola Head of nature conservation unit
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest non-governmental organisation in Finland. We welcome the Taxonomy Regulation. It is an essential basis for the Green Deal and implementation of the Do Not Significant Harm principle into practice. Of course, it doesn’t solve all the problems and the methodology has still some restrictions. However, it is a good start towards more sustainable funding. In our national discussion there discussion about some special items: Peatlands: In Finland farmers are still draining new carbon-rich peatlands for cultivation. This is often connected to livestock production and the need for more space to spread manure from a farm. Peat burning is still going on in Finland. Some companies take peat also for gardens and farms. They are trying to find new uses for peat and moss, because higher price of CO2 emissions has made peat burning less profitable than some years ago. Peat taking is extremely harmful for climate and biodiversity. It is essential to exclude all peat and moss products from sustainable financing also in the future. It is now better to invest in peat-free products, restoration of peatlands and paludiculture. Afforestation: It can be harmful for traditional rural habitats, cultural landscape areas and High Nature Value Farmland. We have more effective and less controversial ways to combat Climate change. Forestry: It is the biggest problem for biodiversity in Finland, a big problem for waters and in most years also a climate problem (massive clear-cutting causes loss of carbon from trees and soil). National legislation, national and regional forest strategies, most used certification (PEFC) and current forest planning system have not been enough to halt the loss of forest biodiversity. We really need Improved Forest Management with preservation of landscape and consultation of stakeholders. (Finnish forest legislation is now not in the line of Aarhus Convention: no participation and access to justice.) Hydropower: Nearly all of our rivers are blocked by dams, which is extremely bad for migratory fish and water habitats. In addition, hydropower dams are usually connected to artificial lakes. Companies are taking water from these lakes when the price of electricity is the best, so there can be rapid big changes of water level in lakes and rivers. This leads to many other environmental problems. That is why we don’t need any new dams – in the Western Europe we are removing them and restoring ways for migratory fish (e.g. Finnish National Fishway Strategy). Bioenergy. Forest biomass can be used only as a transition time solution temporarily – in the long run, burning even this kind of carbon is not a wise and sustainable solution. Peat, which is worse for Climate than Coal, should not be used in the same power plants. It is important to understand that an EIA or IED licence for a bioenergy power plant doesn’t include the impacts from taking the raw material. Waste incineration: we have lost recycling targets because of incineration, so this kind of projects should be excluded from any sustainable financing also in the future. Nuclear energy: It causes the biggest risks in energy production. The nuclear waste question is still largely open even in Finland, which has the most developed plans. In addition, Uranium mining can cause large environmental problems: it is not only because of radioactivity, but also chemistry (harmful substance to waters). We have some lessons learnt from Talvivaara/Terrafame mine, which has already now become extremely expensive for Finnish taxpayers. Nuclear projects should be excluded also in the future. On behalf of SUOMEN LUONNONSUOJELULIITTO Tapani Veistola Head of nature conservation unit
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Response to New EU Soil Strategy - healthy soil for a healthy life

10 Dec 2020

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental NGO in Finland. We welcome the new Soil Strategy. Soil is one of the main elements, and it needs own EU legislation now. The new Soil Strategy should be the first step towards new Framework Directive with measurable and binding targets with timetables. Last time there were five Member States blocking the Directive, but now one of them (UK) has left the EU. Some Member States have best practices for inspiration to the whole EU. For example, we have a special section in the Finnish Environmental Protection Act (527/2014, 16 §): "Prohibition against soil contamination. Waste or other substances, organisms or micro-organisms shall not be dumped or discharged into or on the ground so as to result in such deterioration of soil quality as may cause hazard or harm to health or the environment, substantial decline in amenities or comparable infringement of the public or private interest (prohibition against soil contamination)." This kind of prohibitions should be included in the Strategy and future Framework Directive. Chemical pollution is one basic problem for soils. There is urgent need to reduce pollution in agriculture and other activities. Remediation of polluted sites is important, too. We need urgent measures to national CAP strategies and programmes, because they are just now under preparation in all Member States. CAP should contribute to Biodiversity and Farm to Fork strategies, as with Climate Change targets. That is why protection of peatlands and other carbon-rich soils should be mandatory. The "no net land take" principle should be operationalised quickly against sealing of greenfield areas, with practical reduction targets and timetables. Also compensatory and restoration measures are needed. It is especially important to stop sealing with EU funds, like TEN and Structural Funds. One special problem is deforestation, which is going on also in Finland and many other EU Member States. On the other side, afforestation should be done only with native tree species and suitable places (not in traditional rural habitats or High Nature Value farmland). In addition, taking of moss should be restricted (this is a brand new environmental problem in Finland, which is not regulated now). It is important to estimate, reduce and compensate the soil footprint from consumption in the EU Member States in other continents, too. On behalf of Suomen luonnonsuojeluliitto Tapani Veistola Head of nature conservation
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Finnish conservationists urge binding EU rules for forest protection

3 Dec 2020
Topic — The new EU Forest Strategy aims to enhance biodiversity and climate resilience.
Message — The association calls for the strategy to include clear targets to protect old-growth forests and promote nature-friendly practices. They argue national laws and voluntary tools have failed to solve environmental problems.12
Why — This would stop the forestry industry from avoiding environmental restrictions through national-level lobbying.3
Impact — The forestry industry would face stricter limits on practices like ditching and peatland harvesting.4
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Response to Protecting biodiversity: nature restoration targets

2 Dec 2020

Suomen luonnonsuojeluliitto (The Finnish Association) is the oldest and biggest environmental non-governmental organisation in Finland. We have done restoration work in practice in our projects especially with traditional rural habitats and peatlands. We welcome the legal tool, because current commitments have not been enough. For example, Finland has made many projects to develop restoration (e.g. ELITE, HELMI), but results are far away from older CBD, EU or national targets. There are some voluntary systems collecting money for restoration. In Finland the biggest of them is Hiilipörssi. It was developed in our organisation for peatland restoration, and now it independent. However, these voluntary systems can't replace legal instruments. Legal instrument is the best option, because it gives binding targets. Old EU and national biodiversity strategies and restoration targets failed, because Member States didn't invest in them enough money. There was lack of legal basis and sanctions. Legal instument can give large scale (e.g. 15 % of the EU’s land and sea areas and rivers into free flowing by 2030). It can lead also to proper scientific planning (e.g. connectivity planning with Zonation program or other tools). Also other EU policies and funding instruments should support restoration. It is essential to put especially Common Agricultural Policy and Farm to Fork Strategy support restoration. In our country farmers are still taking new peatlands into cultivation. That is a vast problem: peatlands are only a small part of our agriculture land, but they are causing the majority of carbon emissios from our agriculture. On other side, thare there is big potential in peatland restoration, paludiculture, agroecology and carbon farming. CAP should be reformed and ecosystem services should become basis of payments in the future. Restoration is important also in forests. The best option in Boreal region is to allow natural forests to grow older and larger, so they can become connected to other high nature value forests in the long run. Afforestation is not always the best option for e.g. peatlands, and it should be made only by native species in suitable places (not in e.g. traditional rural habitats and High Nature Value farmland). Some afforestation payments can become perverse incentives, especially if it is legal to have forestry in these areas in the future. Restoration is usually good for other environmental targets, like climate change mitigation and adaptation. However, it is important to understand and accept, that in some special cases restoration is essential for biodiversity despite some temporary emissions to climate or waters (e.g. some peatland habitats). It is important to protect all restored lands and waters, so their nature values can live long. In some special areas management is needed also in the future, for example in open sandy habitats against Invasive Alien Species flora as Rosa rugosa etc. and meadows against of too many bushes. Monitoring and feedback is essential. All the data should be public and NGOs should have legal tools to act as watchdogs for nature. On behalf of Suomen luonnonsuojeluliitto Tapani Veistola Head of nature conservation unit
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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

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental non-governmental organization in Finland. We would like to make the following points about EU Effort Sharing Regulation (ESR) review Emissions in the EU must be cut at least 65 % by the year 2030 in order to keep the global temperature rise to 1.5 °C. The ESR target should be increased accordingly. Focus should be on reducing emissions in all sectors, also in the ESR. Nationally binding targets need to remain in all sectors and for this keeping the ESR is important. The emissions from road transport and buildings should also remain under the ESR. There should be no offsets or flexibilities between sectors. Banking, borrowing and transferring emissions should be limited to minimum.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental non-governmental organization in Finland. We would like to make the following points concerning the updating of the EU emissions trading system (ETS) Emissions in the EU must be cut at least 65 % by the year 2030 in order to keep the global temperature rise to 1.5 °C. Targets of the EU ETS should be increased as well in order to reach the climate targets. In order to make the EU ETS more efficient in reducing emissions there should be no free allowances, the cap should be re-evaluated to reflect real emission levels and carbon floor price should be set. We would like to see emissions from international transport (aviation and maritime) included in the EU ETS. All use of biomass should have a sustainability criteria and correct carbon accounting.
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental non-governmental organization in Finland. We would like to make the following points concerning the LULUCF regulation. Emissions in the EU must be cut at least 65 % by the year 2030 in order to keep the global temperature rise to 1.5 °C. The focus should be on reducing emissions in all sectors instead of creating or increasing flexibility between sectors. Separate targets are also needed for different land-use categories within the LULUCF sector. There are still many data gaps in monitoring, reporting and verification in the LULUCF sector and the accounting needs to be improved. For example in Finland the FRL does not set an ambitious goal for increasing the carbon sink and storage of forests. Stronger incentives or regulation are needed in order for the use of forests to be in line with the climate targets. All actions in the LULUCF sector should support biodiversity and reaching the targets of the biodiversity strategy.
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Response to Industrial pollution - revision of the European Pollutant Release and Transfer Register

26 Oct 2020

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental non-governmental organization in Finland. We warmly welcome the E-PRTR and this work to develop it. This reporting system can help us to achieve EU environmental targets, SDGs etc. This type of reporting and monitoring is essential in this work. We think that the Aspect 1 (Baseline Scenario) is not enough. Inclusion of additonal sectors (Aspect 2) and pollutants (Aspect 3) are needed to reach EU environmental targets. These things are connected also to new issues in the Aspect 6 (circular economy, decarbonisation of industry and zero pollution). In addition, Aspects 4 (Access to information and public participation) and 5 (reporting modalities) are very important. We need more real time data and more integrated reporting and monitoring of many EU directives at the same time. We need more information more quickly and easier than today. Digitalization is helping everybody in this big and important work. More integrated electric reporting system is useful also for companies, because ut can even reduce their current administory burden. On belhalf of Suomen luonnonsuojeluliitto Mr. Tapani Veistola Head of nature conservation unit
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Finnish conservationists urge separate carbon removal targets

14 Sept 2020
Topic — This consultation sets forest reference levels for carbon storage between 2021 and 2025.
Message — FANC argues for a separate carbon removals target to increase action in the land sector. They propose taking older forests out of the line of fire to protect biodiversity.12
Why — This would advance the group’s core objective of promoting environmental protection and nature conservation.3
Impact — Logging-intensive member states would lose the flexibility to significantly increase their wood harvesting.45
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Response to Climate Law

29 Apr 2020

The Climate Law is a step forward and could be a great opportunity and tool for climate governance. The Climate Law, in addition to enshrining a long-term climate target into law, should govern ambitious policymaking to deliver on the European Green Deal and should avoid specific pitfalls related watering down the speed or ambition of climate action. Separate emission reductions from emissions removals: Targets and accounting for negative emissions should be explicitly set and managed separately from existing and future targets for emissions reduction. Failure to make such a separation has already hampered climate policy (see LULUCF flexibilities), and could further delay ambition if emitting sectors exaggerate the expected future contribution of negative emissions technologies. With current 2030 reduction pledges, we are set on a pathway towards 3-3.2°C increase in temperature. Countries however agreed in Paris to limit the increase in temperature to 1.5°C. If the Commission wants to fulfill its promise it should reach climate neutrality already by 2040 and increase its 2030 climate target to at least 65%. The NDC increase by 2030 target should not include offsetting, but be an emission reduction target only. Avoid putting false hope in large-scale geo-engineering: We have no substitute for keeping fossil fuels in the ground, and we are not decarbonizing rapidly enough. Geo-engineering projects in Europe have failed to materialize despite trials, offer huge trade-offs at scale, and have been found to be a “mitigation deterrence” in climate planning; particularly BECCS, which validates delays in reducing emissions. Prioritize natural sinks: Our vegetation and oceans are the largest absorbers of CO2 in Europe and across the globe. Since 2000, the net reported annual LULUCF sink has been around 300 Mt CO2e on average, with an unfavourable declining trend over the past 8 years owing to growing demand for wood for material uses and energy production, according to the EEA. With proper protection and restoration of forests we could triple the amount of carbon they store each year. Mainstreaming action on climate and biodiversity: All pathways and national measures to achieve climate targets should respect and enhance biodiversity as well as take into account the conclusions of Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES). Independent scientific body: The law currently lacks a scientific approach. FANC therefore calls for effective, independent and accountable climate governance which requires the creation of independent scientific advice concerning the sufficiency of EU action in relation to the set targets. The inclusion of an independent scientific body in the climate law is primordial to ensure legitimacy and accountability of the Commission and guarantee that climate science is duly taken into account in climate policy and climate targets. This would be a non-stakeholder body in order to guarantee the independence of its scientific advice. The memebrs should be chosen based on proposals of academic scientific bodies based on the academic achievements in fields relevant on addressing climate change. Access to justice and public participation: In line with the Aarhus Convention FANC calls for a reinterpretation of the Court's jurisprudence, that has interpreted the Treaty too strictly up until now, clarifying that citizens and their representatives are directly and individually concerned by the compliance of the EU’s bodies with the Paris agreement goals. The Commission must publish all assessments containing environmental information in an adequate, timely and effective manner allowing for, where relevant, public input. Review clause: A review clause should be included to ensure that the 2050 and 2030 targets are not set in stone, but reviewed every 5 years in line with the Paris Agreement’s five-year cycle and based on best available science. No backliding can be allowed.
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Response to EU rules on industrial emissions - revision

21 Apr 2020

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental NGO in Finland. We have been quite happy with the IPPC/IED, but we largely agree with the analysis by the European Commission. Now it is high time to take the next step forward and make a review of the IED. There are our three main messages for further work. The key word in the history of the IPPC/IED has been "integration". Combatting classic pollution is not anymore enough, when we must solve multiple environmental problems of the 21th century. Now the IED should become integrated also to climate and circular economy targets. More integrated IED could serve as even more comprehensive legislative tool for many environmental policies. This kind of integration helps also companies by making more simple and stable EU legislation for them. Integration could be improved also by taking more activities into the scope of the IED (e.g. aquaculture, mining etc.). On the other hand, there should be possibility to stop the use of the worst old technologies (e.g. peat mining and burning). The ambition level of the IED and BATs etc. should be raised to achieve all EU environmental targets. This means also that derogation possibilities should be reduced. The best way to improve implementation is develop the IED to a new Regulation.
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Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental NGO in Finland. We warmly welcome the EU work for more sustainable financing. In addition to Climate Change mitigation and adaptation, also other EU environmental targets should be highlighted. For example, good ecological status of waters (e.g. problems of hydropower dams and aquaculture), halting the loss of biodiversity (e.g. problems is forestry and agriculture) and ecoefficiency (e.g. vast amounts of materials and energy are wasted to get small amout of gold or diamonds etc.). The EU criteria should give added value compared to current status quo. If the current level of legislation and standards were enough, there could not be any climate or biodiversity crisis. Business as usual is not enough anymore, so we ne need better practicies and more sustainable financing. It is essential that EU work goes beyond national targets. For example, it is hard for Finland to confess any problems in forestry (e.g. current loss of carbon storage and biodiversity), peat (e.g. peat burning and agriculture) and nuclear energy (e.g. problems in Uranium mining, technical problems in building of new nuclear power plants and still open questions in nuclear fuel encapsulation and and final disposal facility). These things can't be solved in the Member State level. We need more wide EU view and unpartial scientific criteria work, which goes over national or local political and economic interests.
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Response to Access to Justice in Environmental matters

2 Apr 2020

The Finnish Association for Nature Conservation is the oldest and biggest environmental NGO in FInland. We have always been a strong advocate for the Aarhus Convention and so-called third pillar rights both in Finland and in the EU. Within the Finnish legal system, access to justice has long traditions even in our earlier and current Constitution. For the protection of the environment in an European context, access to justice is one of the key elements of democratic decision making. According to our Finnish experience, access to justice gives more power also to public participation. It can help in preventing environmental problems beforehand, too. Continuously improving access to justice is a vital element in ensuring de facto implementation of the right to access to justice. Therefore we highly welcome the initiative of the Commission to make amendments to the Aarhus Regulation. As an environmental organization, we see that for example longer deadlines are needed in environmental cases: there is usually big amount of documents and need to consult many specialists etc. In addition, access to justice varies greatly within the Member States resulting currently in unequal access to justice in the EU. While taking into account the sovereignty of national judicial systems, the Aarhus Convention and amendments to it are a vital tool in balancing this gap in access to justice. In addition, we need also new Access to Justice Directive to make effectively binding minimum criteria for the whole EU. Expertise in environmental matters within judicial systems of the Member States is vital in ensuring access to justice. Justice in environmental matters requires the knowledge of legal questions relating to values of nature. Special courts in environmental issues, such as the Vaasa Administrative Court in Finland, can be seen as best practices for the whole EU. Acts of general scope, instead of only acts of individual scope, should be included in the Regulation. In order to ensure broad access to justice, it is vital to safeguard that costs relating to judicial proceedings do not act as a de facto barrier to access to justice for environmental organisations. The Finnish Association for Nature Conservation firmly believes amending the Aarhus Regulation to broaden its scope is one important way of ensuring compliance with the Aarhus Convention. The new Access of Justice Directive is needed, too. It is important to arrange public hearings about these proposals. Our statement was prepared by environmental lawyer Maria Westerman working in our Uusimaa (capitol) region office and senior advisor Tapani Veistola working both for the Headquarters and Uusimaa region office.
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Finnish conservationists urge radical food policy and CAP delay

20 Mar 2020
Topic — The EU initiative to create a sustainable, healthy food system for people and planet.
Message — The group calls for a two-year delay to the new CAP to integrate environmental goals. They demand binding numeric targets for pesticide reduction and a shift from volume-based subsidies. The Commission must reject national plans that fail to implement Green Deal and biodiversity targets.123
Why — This ensures European agricultural policy aligns with environmental protection and biodiversity conservation goals.4
Impact — Producers of environmentally harmful bulk food lose access to current massive subsidy payments.5
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

Suomen luonnonsuojeluliitto (Finnish Association for Nature Consevation) is looking forward to preparation of EU Biodiversity Strategy 2030. This new strategy is very important and urgent, because biodiversity loss is still going on in the EU and Member States. The main reason are gaps and delays in Member States and so-called other sectors, like agriculture, forestry, fisheries etc. This is why next Strategy must have stronger connections to EU and national funding and programs, like CAP, EMFF, structural funds etc. The new strategy must push also Member States to use terrestial and maritime spatial planning more in biodiverity conservation. There is enough knowledge about biodiversity loss – it is now time for action. That is why preparation process can be very quick. However, it is important to have a public hearing for stakeholders about the draft ot the strategy. It can help in awareness and commitment raising. Suomen luonnonsuojeluliitto supports strongly this strategy and wants to help the Commission in this important work. On behalf of Suomen luonnonsuojeluliitto Tapani Veistola senior advisor
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Response to Update of the list of Invasive Alien Species of Union concern

6 Apr 2019

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) supports proposed new Invasive Alien Species (IAS) to the EU regulation. IAS is one good example about EU added value in international co-operation. The best way to stop IAS is to stop it before it comes to your country. Finland is the northernmost EU Member State, and we are largely dependent on how IAS prevention goes in other MSs. However, we can't understand and accept why American Mink is not included in the list. This exclusion is against scientific assessment. For example, in our Finnish IAS national strategy American Mink is included in the top 7 especially harmful IAS (Kansallinen vieraslajistrategia, 2012). Our national parliament adopted in 19.3.2019 changes to the national Hunting Act and IAS Act, which allows extraordinary hard measures against this species in Finland (the implementation decrees of these changes of laws are coming later this year). We know, that the exclusion of American Mink is based on the interests of fur farming industry in e.g. Finland. However, fur farms could have similar derogations as Finland is using with Raccoon Dog, if needed. That is why this exclusion is not even necessary for the industry. There has been discussion whether Member States could use lighter measures than EU regulation with American Mink, like regional co-operation. Of course Member States can make bilateral and multinational co-operation without EU. However, this can't replace legal basis of the EU IAS regulation. To sum up, we support the new species to the Regulation but want also American Mink to it as soon as possible.
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Response to High and low Indirect Land-Use Change (ILUC) - risks biofuels, bioliquids and biomass fuels

4 Mar 2019

The recast of the RED aims at limiting the support to food-based biofuels after 2020 and ending the support to the highest emitting biofuels on the EU market by 2030 at the latest. The proposed draft delegated act is not fit for purpose and too weak. On the contrary, it could lead to the same level or even more palm oil biofuels to be used on the EU market compared to today’s consumption. The Globiom study for the European Commission revealed that biodiesel from palm oil is three times worse for the climate than regular diesel while soy oil diesel is two times worse. Despite a drop in the use of palm oil in consumer products (food, cosmetics etc.) in EU palm oil consumption keeps increasing because of biodiesel. The EU is the second largest importer of crude palm oil in the world. The majority of palm oil imported into the EU (51%) is currently subsidised to make biofuel. Europe uses around 4 million tonnes of crude palm oil to produce diesel, making drivers the top consumers of palm oil in EU. Based on the most recent available published by Transport & Environment in January they concluded that soy and palm as well as their co-products should be included in the category of high ILUC risk biofuels to be phased out of the renewable targets. Regarding the low ILUC risk category, the available evidence did not provide for a workable and sufficiently robust system for certification and recommended the Commission to close the door to this option for high ILUC risk biofuels. The draft delegated act released by the European Commission includes palm oil in the category of high ILUC risk biofuels, due to its massive expansion on high carbon stocks since 2008 (average 45%). This is an important element and constitutes a landmark decision. But the choice of a 10% threshold keeps soy out of this category despite the fact that 8% of its expansion took place on high carbon stocks since 2008. We recommend the Commission to choose a lower threshold - at maximum 3% - to decide what is significantly expanding on high carbon stocks or not. Palm and soy have been identified as forest risk commodities in various initiatives (e.g. Amsterdam Declaration) and classifying soy as ‘high ILUC risk’ would be in line with these. The draft delegated act unfortunately keeps this option open for high ILUC risk biofuels to enter as low risk ILUC biofuels. It includes a requirement for an additionality test, to ensure that a project wouldn’t have happened in the absence of the ‘low ILUC risk’ certification. But it also includes broad derogations regarding ‘unused’ land and smallholders. For example, the ICCT concluded that up to 5 million tonnes of palm oil will be produced in 2030 only in Indonesia and Malaysia on land which would be considered ‘low ILUC risk’ according to the draft act. This land will be needed to meet the increased demand for food, feed and oleochemicals so its use for biofuels will still indirectly cause further palm expansion, in other words, ILUC. Also, the definition of ‘unused’ land doesn’t capture cases of uses by local communities or important ecosystem services provided by this land. The availability of large areas of "unused land" is disputable. The size of a plantation or the type of land tenure have no relation to the risk of indirect deforestation or ILUC. Recommendations: - The Commission should adopt a lower threshold for categorizing crops in the ‘high ILUC risk’ category and thus include soy in this category, together with palm and their respective co-products. - The low ILUC risk criteria should be fixed through a package of amendments, in order to avoid bringing on the EU market significant quantities of palm oil for biofuels. A proper additionality test is needed for all projects, without derogations, and the governance system for certification needs to be heavily strengthened. Unless this is done all ILUC risk crops (including palm oil and soy) should be completely ruled out.
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Finnish nature group demands overhaul of failing eel protection plans

9 May 2018
Topic — Evaluation of EU regulations and management plans for the recovery of European eels.
Message — The evaluation must ensure plans are fit for purpose based on actual conservation status. It should critically analyze the movement of eels between countries and prioritize dam removals.12
Why — Stronger regulations would help the group achieve its core mission of protecting endangered species.3
Impact — Hydropower operators would face new costs to install fishways and prevent eel deaths.4
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Finnish Nature Association demands pesticide-free ecological focus areas

12 Jan 2017
Topic — The consultation reviews greening rules and direct payment regulations for EU agriculture.
Message — The association demands that no pesticides be used in Ecological Focus Areas. They argue that chemicals pose a significant threat to conservation goals.12
Why — Achieving a pesticide ban would help the organization reach its core conservation goals.3
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