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Umweltdachverband

UWD

Der Umweltdachverband (UWD) mit Sitz in Wien ist für 35 Umwelt- und Naturschutzorganisationen bzw.

Lobbying Activity

Response to Food and Feed Safety Simplification Omnibus

14 Oct 2025

Please find attached the Umweltdachverbands statement in response to the European Commissions Call for Evidence on Food and Feed Safety Omnibus Simplification Package.
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Meeting with Patrick Lobis (Head of Representation Communication)

25 Sept 2025 · State of play European Green Deal / MFF & SOTEU

Meeting with Günther Sidl (Member of the European Parliament)

21 May 2025 · General Exchange on Views

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

28 Feb 2025 · Exchange of views on the Common Agriculture Policy and the cooperation between environmental and agricultural stakeholders

Meeting with Thomas Waitz (Member of the European Parliament)

4 Feb 2025 · Environmental Protection

Meeting with Alexander Bernhuber (Member of the European Parliament) and Eurelectric aisbl and Landwirtschaftskammer Österreich

10 Feb 2023 · Nature Restoration Law - Stakeholder Dialog

Response to Commission Delegated Regulation on the methodology for risk assessments of invasive alien species

20 Dec 2017

Umweltdachverband would like to express its overall support to the Delegated Act as it is currently drafted. Indeed, the Umweltdachverband does not believe any substantive amendments are needed to the draft. The Umweltdachverband considers that this draft Delegated Act meets, and in no way exceeds, the scope of the Delegated Act as determined by Article 5(3) the EU IAS Regulation 1143/2014. As we also consider that the distinction between Risk Assessment and Risk Management is very important we welcome the Commission’s approach which clearly highlights this distinction within the Explanatory Memorandum. As clearly detailed in Article 5(3) of Regulation 1143/2014, this Delegated Act exists to further specify the evidence requirements for the Risk Assessments required under Article 5(1) of Regulation 1143/2014. It is clear from Article 5(3) that the Delegated Act does not exist to specify the evidence requirements for any Risk Management analyses. Consequently, the Umweltdachverband is supportive of the Commission’s ensuring the scope of this Delegated Act is limited to that of specifying the evidence required for Risk Assessment, and not deviated to considering the evidence required for Risk Management. Article 5(1)(h) of Regulation 1143/2014 requires Risk Assessments to include ‘a description of the known uses for the species and social and economic benefits deriving from those uses’. Article 5(1)(h) is therefore asking for a description of the Risk Management considerations, so as to provide initial context to the Risk Assessment. However Article 5(1)(h) is clearly not requiring a detailed analysis of the Risk Management considerations; as this can be provided, if necessary, directly to the EU IAS Committee when it evaluates the Risk Management of whether to include the species on the EU IAS List or not. Umweltdachverband considers the wording of the section relating to Article 5(1)(h) of the Annex of Common Elements to be appropriate and entirely within the aim and the spirit of Regulation 1143/2014. However, for the avoidance of doubt, we wonder whether there would be value in adding a note to this section which clearly states that the Regulation merely requires a brief description of social and economic considerations to provide context to the Risk Assessment, and not a full analysis of the Risk Management considerations. Furthermore, the Umweltdachverband considers it unnecessary to specify that only economic experts can compile evidence relating to Article 5(1)(h) as this would be an unnecessary burden for what is merely a descriptive section. The primary aim of Regulation 1143/2014 is to prevent future damaging invasions by alien species. Due to the nature of invasive alien species, an IAS may become established and cause harm within the EU before it is possible to complete rigorous scientific studies into the impact of that species in Europe. Consequently, as per international best practice, it is not appropriate to rely solely on peer reviewed literature when assessing the risk that an invasive alien species poses. However, it is entirely appropriate, as per international best practice, to consider expert opinion and grey literature when assessing the risk that a species may pose. But only when peer-reviewed evidence is not available and only when the uncertainty surrounding such material is appropriately articulated. As this Delegated Act allows for the use of non-peer reviewed evidence, with appropriate and proportional caveats, Umweltdachverband praises the mature and considered approach to evidence that this Delegated Act presents. With regards to the section of the Annex of Common Elements relating to Article 5(1)(f); within Paragraph 3, the Umweltdachverband suggest that ‘endangered habitats’ is changed to ‘habitats’. A habitat may become endangered by the presence of an IAS, so merely focusing on endangered habitats, as opposed to all habitats, may miss significant elements for the risk assessment.
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