OpenLobby.EU
Explore

Vereniging Milieudefensie

Milieudefensie

Milieudefensie has been working toward a sustainable and fair Netherlands since 1971.

Lobbying Activity

Meeting with Ingeborg Ter Laak (Member of the European Parliament) and Greenpeace European Unit and OXFAM INTERNATIONAL EU ADVOCACY OFFICE

3 Nov 2025 · 2040 targe

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and WWF European Policy Programme and

28 Oct 2025 · Sustainability omnibus and climate transition plans

Meeting with Myriam Jans (Cabinet of Commissioner Wopke Hoekstra) and Greenpeace European Unit and

3 Sept 2025 · Climate Policy

Meeting with Lara Wolters (Member of the European Parliament)

4 Dec 2024 · Climate and Due Diligence

Meeting with Lara Wolters (Member of the European Parliament)

13 Jun 2024 · CSDDD

Meeting with Mohammed Chahim (Member of the European Parliament)

18 Oct 2023 · COP28 - position of Dutch NGO's

Response to European Sustainability Reporting Standards

7 Jul 2023

Milieudefensie welcomes the opportunity to provide feedback on the draft delegated act (DA) including the first set of European Sustainability Reporting Standards (ESRS). Milieudefensie notes that the Commission has made significant modifications to the draft standards submitted by EFRAG. Three modifications in particular represent a significant reduction of the ambition level of the ESRS and raise serious concern about the DAs fitness for purpose: - The submission of all disclosure requirements and data points within each standard to materiality assessment by the undertaking; - The phasing-in of the requirement to disclose scope 3 GHG emissions, disclosure requirements on biodiversity, value-chain workers and affected communities for undertakings with less than 750 employees; - The conversion of a number of mandatory datapoints proposed by EFRAG, including biodiversity transition plans, into voluntary datapoints. The Commission motivates these modifications referring to a desire to rationalise, streamline and ensure proportionality. It claims the modifications result in a relatively modest cost saving of 230 million per year. Milieudefensie believes these modifications are detrimental to the efficacy of the disclosure framework. Disclosure of comprehensive, comparable, relevant and reliable information is necessary for the double purpose of reorienting capital flows towards sustainable investments, necessary to realize the objectives of the EU Green Deal, and increasing accountability of companies for their societal and environmental impacts. The modifications made by the Commission run counter to this double purpose. It will result in lower quality and lower comparability of reporting and cut off lenders and investors from crucial information they need to assess sustainability risk and impacts of counterparties and, ultimately, of their own portfolios. In addition, Milieudefensie believes the last-minute character of the modifications undermine the credibility of the multistakeholder process which resulted in the draft standards submitted by EFRAG. These standards were already a compromise that balanced the interests of various stakeholders involved in the process, as illustrated by the fact that the EFRAGs final drafts contained 45% less disclosure requirements and 50% less data points than its initial exposure drafts. With regard to the interests of smaller companies, the CSRD already provides for a phased-in application and lighter disclosure requirements for SMEs. The Commissions decision to further reduce the scope of the requirements, which are not justified from a technical perspective and do not build on any impact assessment, raises the suspicion it gave in to industry lobbying. Milieudefensie calls upon the Commission to: - maintain mandatory disclosure of all climate-related disclosure requirements and data points for all undertakings, by excluding ESRS E1 from the materiality assessment; - ensure that mandatory disclosures in other EU regulations are also mandatory in ESRS to ensure consistency and comparability; - restore the mandatory character of other datapoints proposed as mandatory by EFRAG, such as biodiversity transition plans; - require adequate transparency on the materiality assessment process and the results of that process; - remove the additional phase-in arrangements for undertakings with less than 750 employees with regard to scope 3 GHG emissions, biodiversity, value-chain workers and affected communities.
Read full response

Response to Initiative on EU taxonomy - environmental objective

3 May 2023

Attached file contains detailed feedback of Vereniging Milieudefensie (Friends of the Earth Netherlands) with regard to Aviation (manufacturing of aircraft, leasing of aircraft passenger and freight air transport).
Read full response

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Milieudefensie - Friends of the Earth Netherlands feedback on the draft taxonomy delegated act Overview Milieudefensie is concerned that de draft DA has severely weakened the recommendations on the Technical Expert Group (TEG) on several key activities. By ignoring the TEG’s science-based recommendations, the Commission risks to damage the taxonomy’s credibility and the EU Green Deal’s success beyond repair. As a matter of priority, the following points should be strengthened: Fossil fuels Fossil fuels clearly have no place in a climate taxonomy. The Commission should maintain the science-based threshold of 100g CO2-eq/kWh for all fossil fuels, including gas. In fact, this threshold should be tightened at least every 5 years as proposed by the TEG. The adaptation criteria for both substantial contribution and DNSH should be tightened to ensure no loopholes are created for gas investments. Bioenergy Problematically, the Commission has chosen to accept that almost all bioenergy feedstocks complying with the flawed Renewable Energy Directive (RED II) are considered sustainable. The RED II criteria are not science-based and insufficient to protect forests and the climate. Burning forest biomass or biomass crops usually does not reduce lifecycle emissions compared to burning fossil fuels. Burning purpose-grown crops in many cases actually increases emissions. Therefore, the Commission should exclude burning of forest biomass and purpose-grown crops from the taxonomy. Biofuels and biogas for transport The Commission weakens the TEG criteria by making nearly all feedstocks complying with the flawed RED II criteria eligible. While it excludes the use of food and feed crops in biofuel manufacturing, it doesn’t for biogas manufacturing. The Commission should revert to the TEG criteria and limit eligibility to Annex IX part A feedstocks. Strengthening the TEG criteria, the blanket exclusion of the use of food and feed crops for biofuel manufacturing should be extended to biogas. Inland water transport The Commission removed the tailpipe emissions intensity for inland passenger transport without setting new criteria to exclude conventional engines. It sets extremely weak criteria for inland freight transport, which would classify most existing vessels as sustainable and risks encouraging ‘business as usual’ in the transport sector being counted as sustainable. The Commission should reinstate the TEG criteria for passenger transport and increase the threshold for freight transport to 90%. Hydrogen The Commission has improved the TEG’s emission threshold. It should maintain the improved threshold and explicitly exclude hydrogen produced with fossil fuels. Livestock The livestock industry is highly carbon-intensive and strongly linked to deforestation. Moreover, it poses major animal welfare and human health concerns. The draft DA focuses excessively on technical criteria instead of on reduction of herd sizes. Milieudefensie believes livestock should be excluded from the taxonomy until robust criteria are developed to address its impact on climate, biodiversity and land used. Forestry The taxonomy heavily relies on the contested notion of sustainable forest management. The draft DA allows activities such as short-term rotation below 20 years, which is not climate-neutral due to the carbon released. Forestry operation should not qualify if they reduce forests’ carbon sink function, lead to irreversible forest degradation or to biodiversity loss. Afforestation and reforestation of forests are insufficient to replace forests lost to deforestation or highly degraded forests. The Commission should tighten forestry criteria to focus on protection and restoring existing natural forests in view of enriching biodiversity and carbon storage potential. It should specify that carbon storage must include carbon below and above ground. The former is usually neglected.
Read full response

Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

Milieudefensie/Friends of the Earth Netherlands welcomes the opportunity to provide feedback to the inception impact assessment for the climate change mitigation and adaptation taxonomy. We have the following recommendations: • Exclude the livestock sector and the use of biofuels in transport means that can also run on fossil fuels; • Strengthen criteria for forestry and bioenergy; • Keep nuclear power, fossil fuels and waste incineration out of the taxonomy; • Strengthen social and human rights safeguards. 1. Exclude the livestock sector and biofuels in transport means that can also run of fossil fuels We recommend to not include livestock activities in the taxonomy. The industry is highly carbon-intensive, emissive, polluting, and strongly linked to deforestation. In addition, there are major animal welfare and human health concerns. Including livestock risks slowing down the transition to a more sustainable, plant-based diet and the reduction of the number of animals, as required in Paris-compliant climate scenarios. We also recommend to make trucks, coaches, and vessels that use liquid biofuels or biogas ineligible under the taxonomy. Such vehicles and vessels can switch from using advanced biofuels one day to fossil fuels the next. As enforcement is impossible, the taxonomy should exclude them, as well as the related refuelling infrastructure. 2. Strengthen criteria for forestry, bioenergy, hydropower and passenger cars and vans For a number of activities, the criteria put forward by the TEG are not stringent enough and require tightening. Logging operations and forest management should not qualify if they reduce forests’ carbon sink function overall or lead to irreversible forest degradation or biodiversity loss. Forest management should generally be adapted to the respective site/soil/forest conditions. We also need to protect natural forests against deforestation and degradation. Reliance on certification schemes for establishing whether forestry activities are taxonomy-compliant is unrealistic and irresponsible. These schemes do not properly cover carbon stock management issues and it is even questionable whether they can guarantee good forest management, as there are serious problems with several of them. Hence, the Commission should forestry criteria. The Commission should also improve bioenergy feedstock criteria by removing feedstocks which will increase emissions compared to fossil fuels – tree trunks, stumps, energy crops and so called ‘low indirect land-use change-risk’ food and feed crops – and fuels based on fossil carbon. 3. Keep nuclear power, fossil fuels and waste incineration out A number of activities were rightly excluded by the TEG and should remain so. Nuclear power harms the taxonomy’s pollution prevention and circular objectives, due to the long-term impacts of nuclear waste, with regards to the “do no significant harm principle”. Fossil fuels operate on emissions that are far beyond the 100gCO2/KWh threshold identified by the TEG, a threshold that should be further lowered. Waste incineration undermines upper-tier activities of the waste hierarchy which are more protective of the climate. In the circular economy, much of what is currently used as incinerator feedstock will have to be recycled or composted. 4. Strengthen social and human rights safeguards While the taxonomy law clearly defines minimum safeguards to be complied with when applying the taxonomy, clear guidance on how these minimum safeguards should be applied concretely is missing. The positive impact of environmentally sustainable activities might not be as effective in case there will be underestimated, unforeseen and unintended negative social consequences. This could undermine the goal of a just transition. Strong social and human rights underpinning, which is now missing, would strengthen the uptake and application of the taxonomy for financing climate and environmentally sustainable economic activities.
Read full response

Response to FuelEU Maritime

23 Apr 2020

Milieudefensie - Friends of the Earth Netherlands supports the objective to reduce the emissions from the maritime sector by accelerating the uptake of sustainable alternative fuels and power. We agree with the European Commission that creating a predictable demand in this sector is essential for the investment and mass scale deployment of sustainable alternative fuels and power. We would like to make the following comments: - Crop-based biofuels are more damaging to the climate than fossil fuels. Their use should be banned. - The scalability of biofuels made from waste and residues is severely constrained by limited feedstock availability. They should be reserved for applications for which alternatives are unlikely to become available soon. - A blending mandate for the maritime sector presents severe environmental and technology lock-in risks. - An operational ship CO2 standard is a more practical, environmentally sustainable and economically cost-effective method to drive technology uptake in European shipping. We further elaborate on these points in the attached file.
Read full response

Response to ReFuelEU Aviation - Sustainable Aviation Fuels

20 Apr 2020

Milieudefensie - Friends of the Earth Netherlands welcomes the opportunity to give feedback on the inception impact assessment of the ReFuelEU Aviation initiative. Milieudefensie supports the objective to reduce the environmental footprint of the aviation sector. To bring the sector in line with the Paris Agreement, we believe mandatory greenhouse gas emission reduction targets are indispensable. Any mandate for advanced biofuels or electro-fuels should be part of an all-encompassing plan to freeze aviation’s emissions at 2020 levels and bring them down to zero by 2050. Such plan should also consider the non-CO2 climate impacts of aviation emissions. To get the sector on track an absolute emission ceiling for 2030 is required. The promotion of alternative fuels must not happen at the expense of more effective measures like reducing the overall number of flight movements. The introduction of a mandate for sustainable aviation fuels should be contingent on meeting certain conditions, including, but not limited to: • exclusion of crop-based biofuels and waste-based fossil fuels; • a mandate level set based on a credible assessment of the limits of available feedstocks, considering existing competing uses; • a mandate structured as a greenhouse gas emission reduction target to incentivize fuels which deliver the greatest emission reductions. Further elaboration on these three points can be found in the attached file. Many thanks for the consideration of our comments.
Read full response

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

15 Oct 2019 · Discussion on climate and biodiversity

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

8 Mar 2019

Dear Sir, Madam, The aim of the use of biofuel in Europe is to lower the climate impact of transport. The Globiom report showed that (through the waterbed effect) all 1st generation oil based biofuels have major “ILUC” emissions. So much so that combined with the direct emissions there is very little or often a negative impact: the use of these biofuels INCREASES the climate impact of transportation. The RED-recast aims to fase down 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 commission was tasked in Article 26(2) to deliver on this. We appreciate that a lot of effort has been put into it to meet the deadline. However, our analyses show that the proposed draft delegated act is not fit for purpose; it is not efficient, not effective, not enforceable. Furthermore it has build-in weaknesses (exemptions) could lead to the same level or even more palm oil biofuels being used then today. Recommendations: - The Commission should base its delegated act on the method of the “Carbon Benefits Index” which was published 12 December 2018 in Nature. (Assessing the efficiency of changes in land use for mitigating climate change, T.D. Searchinger et. al. ) The CBI measures how changes in the output types, output quantities and production processes of a hectare of land contribute to the global capacity to store carbon and to reduce total greenhouse gas emissions. The study applies the index to a range of land-use choices relevant to climate policy, such as biofuel production. The study finds that these choices can have much greater implications for the climate than previously understood because standard methods for evaluating the effects of land use on greenhouse gas emissions systematically underestimate the opportunity of land to store carbon if it is not used for agriculture. - All 1st generation oils should be categorized as crops in the ‘high ILUC risk’ category, therefore the Commission should adopt a lower threshold - at maximum 1 % - to decide what is significantly expanding on high carbon stocks or not. In it’s calculations it should incorporate the “waterbed effect” into the calculations for all vegetable oils. - The Commission should close the door for high ILUC risk biofuels to go to the low ILUC risk category. There is no available evidence that could provide for a workable and sufficiently robust system for certification. -The broad derogations regarding ‘unused’ land and ‘independent’ smallholders should be removed all together. These two derogations alone would make the whole delegated act useless! There is no such thing as ‘unused’ land in the areas that palm oil is grown: they are used for sustenance farming and / or for ecosystem services. And more often then not combined, where the families also live from the products of the forests they live in. And the to the ‘small holders’-back door. With all due respect, this is nonsense! First of all there is no relation of the risk of indirect deforestation or ILUC to size of a plantation or the type of land tenure have. Furthermore you define small holders as meaning “farmers independently conducting an agricultural activity … etc.” But all so-called ‘smallholders’ that produce for the biofuels market are part of the current business-model of the multinationals. These provide loans and plant material for the first 7 years, these provide fertilizers and pesticides. The smallholders are not independent – they are very dependent! And even more so when it comes to selling their oil: there is only on place that they can bring their fruits to: to the mill of that same multinational! Keeping these 2 derogations could lead to a business as usual situation and would make the whole delegated act useless! We are off course ready to answer any question or give assistance. Can you please tell us how you have used our feedback? Thank you!
Read full response