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Wildlife Conservation Society European Union office

WCS EU

WCS EU is a Belgian NGO dedicated to saving wildlife and wild places worldwide.

Lobbying Activity

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall), Paulina Dejmek Hack (Cabinet of Commissioner Jessika Roswall)

27 Oct 2025 · wildlife and biodiversity

WCS EU urges nature credits to fund conservation, not trading

30 Sept 2025
Topic — This consultation explores creating a roadmap for nature credits to fund biodiversity restoration.
Message — The group opposes credit trading, suggesting funds instead support Natura 2000 sites and international conservation. They demand credits only supplement public funding and utilize metrics based on ecological integrity.123
Why — Standardized nature credits would boost funding for the organization's global biodiversity and restoration initiatives.4
Impact — Commercial traders lose the ability to exchange credits as the group rejects their fungibility.5
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Response to Towards a Circular, Regenerative and Competitive Bioeconomy

23 Jun 2025

WCS EU welcomes this opportunity to provide feedback to inform the development of EU bioeconomy policies. WCS EU is a Belgian NGO supporting the conservation of landscapes and seascapes globally. Our response is also submitted on behalf of the Wildlife Conservation Society (WCS), the worlds largest field-based conservation organization, with which we are affiliated. We highlight here two vital considerations for new EU bioeconomy policies: 1. Building a successful bioeconomy sector requires protecting and enhancing the long-term resilience of the natural capital and biodiversity on which it depends. This often requires going beyond conservation of current biodiversity values to restoring ecosystems that support the natural resource base. A key focus should be the protection, conservation, and restoration of ecological integrity (defined as ecosystem structure, function, and composition), with a focus on areas of high ecological integrity. Such areas support biodiversity, cultural and social values, are resilient to climate change, and provide climate mitigation and adaptation benefits. It is critical that supporting the bioeconomy is not used to justify the unsustainable exploitation of wildlife species. A new EU bioeconomy strategy must therefore support the implementation of existing biodiversity policies, notably the Convention on Biological Diversity (CBD), the Kunming-Montreal Global Biodiversity Framework GBF), the EU Biodiversity Strategy to 2030, the EU Nature Restoration Regulation, the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), the European Ocean Pact, the EU Action Plan on protecting and restoring marine ecosystems, the Convention on the Conservation of Migratory Species of Wild Animals (CMS), the EU Deforestation Regulation, and the EU Action Plan against Wildlife Trafficking. In particular, the strategy should contribute to the implementation of Goal A of the GBF (and associated 8 targets), Substantially increase the area of natural ecosystems by maintaining, enhancing or restoring the integrity, connectivity and resilience of all ecosystems. 2. A new EU bioeconomy strategy must include the external dimension (i.e. outside of Europe), including support to develop the bioeconomy and enhance natural capital and biodiversity of partner countries. Most global biodiversity lies in the tropics and the ocean, but is highly impacted by EU policies, trade, and consumption patterns. For example, 10% of global deforestation is directly related to EU trade and consumption, although forest cover is increasing within the EU. The EU has a responsibility to reverse the negative impacts on biodiversity of its trade and consumption patterns, including through increased investments to protect and restore natural capital, which is also vital to the EUs own economy, prosperity and security. In many contexts, this will require a focus on ensuring and strengthening rights for Indigenous Peoples and local communities (IP&LCs) and increasing their capacity to manage and govern land and natural resources. It will also require support for investment and development pathways which are compatible with or enhance biodiversity, ecological integrity and the natural resource base. Support for research at the science-policy interface is required to increase knowledge and explore develop integrated approaches to development as outlined in the recent Assessment Report on the Interlinkages among Biodiversity, Water, Food and Health, by the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Service (IPBES).* Supporting the development of the bioeconomy in partner countries outside of the EU will contribute to achieving the green economy goals of the EU Global Gateway investment programme. * https://ict.ipbes.net/ipbes-ict-guide/data-and-knowledge-management/citations-of-ipbes-assessments/nexus-assessment
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Meeting with Tilly Metz (Member of the European Parliament)

28 Apr 2025 · One Health

Wildlife Conservation Society urges EU global ocean leadership

17 Feb 2025
Topic — The consultation seeks a vision for a holistic approach to ocean-related policies.
Message — The organization wants the EU to increase international environmental funding and support global ocean protection. They ask for clearer fishing rules that prioritize local food needs and reduce the accidental killing of marine life.123
Why — This would provide additional funding and political momentum for their worldwide conservation projects.4
Impact — Industrial fishing operations would face higher costs and stricter monitoring of their global catches.5
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Meeting with Humberto Delgado Rosa (Director Environment)

13 Feb 2025 · Introduction of the new Vice-President of the WCS and exchange on the plans of WCS for the short, medium and long-term

Response to Alignment of EU rules to recent decisions taken under CITES, the international convention on wildlife trade

12 Jul 2024

Please find our comments, together with definition of terms, in the uploaded attached document.
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Response to Better protecting sharks through sustainable fishing and trade

16 May 2024

We thank the European Commission for the opportunity to respond to this call for evidence on 'Better protecting sharks through sustainable fishing and trade'. We are pleased to submit the attached response of the WCS EU Office on behalf of the Wildlife Conservation Society (WCS), a global conservation organization to which we are affiliated.
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Meeting with Tilly Metz (Member of the European Parliament)

21 Feb 2024 · Pandemics and animal welfare

Response to Proposal for a Regulation - Secretariat-General

31 Aug 2023

WCS EU welcomes this opportunity to provide feedback on the mid-term review and revision of the Multiannual Financial Framework (MFF). We are pleased to see planned increases of the expenditure ceilings in the coming years under Heading 3 Natural Resources and the Environment and Heading 6 Neighbourhood and the World, but we believe these areas are still significantly underfunded in relation to the scale of the challenges ahead. Many challenges facing communities in the global south result from a complex interplay of related environmental crises which together undermine socio-economic development and achievement of the Sustainable Development Goals (SDGs). The latest reports from the Intergovernmental Panel on Climate Change (IPCC) and the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) highlight the urgency of addressing climate change, and stress the ongoing loss of biodiversity and the critical importance of conservation measures to protect ecosystems and human well-being, respectively. Furthermore, the top four global risks reported by the 2023 World Economic Forum Global Risks Report directly relate to the damage done to the environment, including climate change, biodiversity loss, and ecosystem collapse. The EU has already committed to tackling the climate and biodiversity crises through the MFF. In September 2021, European Commission President von der Leyen announced that the EU will double its funding for biodiversity globally, in particular for the most vulnerable countries, but more is needed. The EU needs to continue increasing spending on global biodiversity conservation through the MFF, in line with its commitments in the EU Biodiversity Strategy and under its international commitments in the Convention on Biological Diversity (CBD) and the Kunming-Montreal Global Biodiversity Framework (KM-GBF). In particular, it will be critical for the successful implementation of Target 3, which aims to ensure that at least 30% of land, inland water and sea areas, particularly areas of importance for biodiversity, are effectively conserved and managed, through systems of protected areas and other effective area-based conservation measures (OECMs), that benefits people and nature. It is also critical for the successful implementation of all goals and targets of the KM-GBF, particularly Goal A and Target 1, and the protection and retention of ecological integrity. The EU also needs to increase funding dedicated towards fighting wildlife trafficking as highlighted in the 2022 revised EU Action Plan against Wildlife Trafficking, and Target 5 of the KM-GBF which focuses on illegal and unsustainable wildlife trade and efforts to reduce the risk of pathogen spillover from wildlife. The EU NaturAfrica initiative and global flagship programmes like the Sustainable Wildlife Management (SWM) programme, led by FAO, and the Pacific Biodiversity and Sustainable Land-Seascapes (Pacific Bioscapes) programme are having a ground-breaking impact on the lives of people and the ecosystems on which they depend. The European Commission has put considerable effort into developing a series of strategic guidance documents on wildlife conservation, including the reports Larger than Elephants, Larger than Tigers, and Larger than Jaguars, which provide a highly comprehensive overview of needs and opportunities for wildlife conservation. Fully implementing the recommendations of these strategies will considerably scale up the EUs impact. As a healthy natural environment underpins livelihoods and sustainable development, it is crucial the EU invests further in the protection of high-integrity ecosystems, not only for biodiversity but also for the benefits to people related to health, food, agriculture, and social and economic development. This also includes the need to invest in marine protected areas and coastal fisheries to implement the EUs policy agenda on ocean governance.
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Response to European Critical Raw Materials Act

25 Nov 2022

The importance for the EU to secure a supply of critical raw materials to transition away from fossil fuels and toward energy independence is well understood. But future needs must be a) carefully assessed and influenced through demand-side management, b) not met principally through the continued extraction of raw materials, often with negative impacts on biodiversity and people and c) that sourcing is subject to high biodiversity, environmental and social standards and legislation. We highlight three key points for the CRMA and associated initiatives: 1.The need to promote a circular economy approach, source secondary over primary critical raw materials, and address demand-side dynamics through measures that promote demand reduction and sufficiency: The EU Circular Economy policies imply doing more with less, making better use of raw materials, and using secondary materials from recovery and recycling based on new technologies (e.g. from historically mined materials at brownfield sites), but adoption of these policies must be promoted in partner countries and the EU. Along with smart demand-side management, this would limit the need to extract primary materials, esp. in priority biodiversity conservation and climate management areas where negative impact should be avoided. A circular economy approach, aligned with the EU policy to Do No Significant Harm, should be informed by an overall mitigation hierarchy approach, at strategic and development project levels, designed in line with national and international nature and climate targets. 2.The need to require application of best practice biodiversity, environmental and social safeguards, integrated e.g. in trade agreements, development and multilateral initiatives: Sourcing of critical raw materials must be based on sound, mandatory safeguards, incl. where strategic partnerships with third countries are established. Safeguards should be based on best practice (e.g. IFC and World Bank Environmental and Social Standards, IRMA Responsible Mining Standard, Aluminium Stewardship Standards), and require adherence to the mitigation hierarchy, respect for no-go areas where impacts need to be avoided (priority areas for biodiversity, carbon storage, other ecosystem services), human rights, FPIC and labour provisions. Such safeguards are esp. critical where primary raw material extraction is envisaged. In crafting safeguards, care must be taken to ensure they are enforceable, will be monitored and enforced. The EU could consider new legislative proposals similar to the new legal proposal on tackling deforestation and forest degradation. 3.The opportunity to benefit from and build on initiatives supporting potential CRM supplier countries to strengthen and implement policies and systems founded on best practice in the mitigation hierarchy to address negative development impacts on people and nature and aim to achieve no net loss or net gain outcomes (e.g. COMBO+): Rapid economic development is occurring in many potential critical materials supplier countries with which the EU might consider strategic partnerships. These countries are also rich in globally important biodiversity. To help reconcile necessary development and nature conservation, relevant governments and their partners require urgent support in developing and implementing sound mitigation policy and practice to address negative impacts, conserve biodiversity and achieve good outcomes for people. Several such initiatives are underway, offering lessons learnt and opportunities for further investment and expansion, e.g. the Conservation, Mitigation and Biodiversity Offsets (COMBO+) Programme working with public, private sectors and civil society in 2 Asian and 4 African countries, incl. Guinea and Mozambique (see supporting doc). EU funding could be directed to support such initiatives in partner countries to mainstream strong mitigation policy and practice to help address impacts from mining critical materials.
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Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen) and Stichting BirdLife Europe and

5 Oct 2022 · Biodiversity and forests. Financing.

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

20 Sept 2022 · Implementation of biodiversity policies, including preparation of biodiversity COP15 and CITES COP19

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Ines Prainsack (Cabinet of Commissioner Stella Kyriakides)

20 Sept 2022 · One Health and Pandemic agreement

Response to EU strategic Framework for Global Health

19 Sept 2022

WCS EU is a Belgian NGO based in Brussels, affiliated with the Wildlife Conservation Society. WCS EU draws on WCS's field-based and scientific knowledge to support the development and implementation of EU policies and programmes, in support of global conservation objectives. With more than 100 years of hands-on veterinary work, disease surveillance and groundbreaking scientific research, WCS has been the pioneer in promoting wildlife health as critical to saving wildlife and wild places. WCS initiated and remains a leader in the One World – One Health interdisciplinary approach. To have a meaningful impact on significant reduction of the risk of future pandemics of zoonotic origin, all efforts must be made to prevent the pathogen spillover in the first place. The EU must promote and assist the global community, first, in protecting intact ecosystems and stopping deforestation and environmental encroachment and conversion to limit the human-wildlife interface, and second, in ending the commercial trade and sale in markets of wildlife for human consumption, particularly birds and mammals. Governments and multilateral agencies must break down their sectoral silos and collaborate around the common goal of preventing future pandemics at the source. The EU Commission should therefore establish a One Health dialogue that brings together all relevant Directorates-General (DGs) and stakeholders to establish up-to-date One Health strategies and action plans. Significant investments are necessary to bridge knowledge on modern holistic One Health framing and explore structural changes across public administrations in order to enable One Health approaches. Beyond a lack in One Health capacity at the present, the existing administrative units and associated workflows are highly siloed undermining cross-sectoral collaboration and One Health approaches. Building on a consensus One Health approach (e.g. based on the Berlin Principles and the One Health High-Level Expert Panel definition) we need cross-sectoral funding streams in order to mainstream One Health across all policies. With respect to Emerging Infectious Diseases (EIDs) veterinary and environmental health sectors are chronically under-resourced for zoonotic-pathogen emergence investigations and research but are critical in implementing the necessary One Health approach (e.g. investigations of wildlife, wildlife products, live animal markets, land-use change, species distribution and density). Last December, the World Health Assembly agreed to initiate a process to form an international pandemic instrument. The EU should fully engage and participate in the drafting and negotiations of the new convention, agreement or other international instrument under the Constitution of the World Health Organization (WHO) to strengthen pandemic prevention, preparedness and response. The EU should ensure that civil society and scientists are engaged in the negotiations, and make pandemic prevention at source a priority in this new WHO pandemic instrument. Increased support is needed to scale-up locally-produced, sustainable non-wildlife high quality, nutritious food, to enhance food security and reduce dependence on wild meat, particular for Indigenous Peoples and local communities (IPLCs), as one of a number of One Health approaches. The EU is already leading efforts in this area through the seven-year Sustainable Wildlife Management (SWM) Programme, funded by the EU and the Organisation of African, Caribbean and Pacific States (OACPS). SWM is developing innovative, collaborative, and scalable new models to conserve wildlife and improve food security for IPLCs. SWM is being implemented by the UN Food and Agriculture Organisation (FAO), the Centre for International Forestry Research (CIFOR), the French Agricultural Research Centre for International Development (CIRAD) and WCS. More targeted efforts are needed to support IPLCs, for example, through scaling up the EU SWM Programme.
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Meeting with Virginijus Sinkevičius (Commissioner) and

8 Sept 2022 · To discuss COP15, mainly focused on the road ahead to Montreal in December, as well as the topics of biodiversity funding and deforestation.

Response to Delegated act framing the programming of the Neighbourhood, Development and International Cooperation Instrument (NDICI)

31 May 2021

Please find attached WCS EU's response to the Public Consultation concerning the Neighbourhood, Development and International Cooperation Instrument (Delegated regulation).
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Meeting with Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius) and WWF European Policy Programme and

7 May 2021 · Discussion about Commission's legislative proposal on deforestation and forest degradation

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and

7 May 2021 · Deforestation

Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen) and WWF European Policy Programme and

30 Apr 2021 · upcoming regulation on deforestation

Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen) and ClientEarth AISBL and Conservation International Europe

29 Apr 2021 · Forest Partnerships

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and WWF European Policy Programme and

29 Apr 2021 · Deforestation and forest degradation.

Response to Wildlife trade – alignment of EU rules with recent decisions taken under the CITES convention and changes to EU ivory trade rules

24 Feb 2021

WCS EU thanks the European Commission for the opportunity to respond to this consultation on the new proposed amendments to Commission Regulation 865/2006 and the draft revised guidance document on the EU regime governing trade in ivory. We take this opportunity to re-emphasise that the link between the legal and illegal ivory trade is undeniable. The United Nations Office on Drugs and Crime (UNODC), for instance, concluded that “the trade in illicit ivory is only lucrative because there is a parallel licit supply, and ivory can be sold and used openly. Ivory would lose much of its marketability if buying it were unequivocally an illegal act, or if ownership of these status goods had to be concealed”.* Allowing any trade in ivory fuels further demand, reinforces the social acceptability of ivory and increases opportunities to launder illegal ivory. While we greatly appreciate that the European Commission’s proposed amendments are a step in the right direction, we are concerned that, unless several remaining loopholes are addressed, the new proposed measures and their good intentions could be significantly undermined: 1. The trade restrictions on worked ivory are only partially addressed in Commission Regulation 865/2006 (with the rest being in the guidance document), and those on raw ivory are currently only included in the guidance document. We strongly recommend that Commission Regulation 865/2006 be amended to ensure consistency and enforceability of the rules. 2. The use of the term ‘suspend’ (vs ‘prohibit’ or ‘ban’) may create the expectation that the suspension will someday be lifted, which could lead individuals to retain or stockpile ivory. We recommend the use of the terms ‘prohibit’ or ‘ban’. 3. The requirement that antique ivory can be traded with a certificate is still too broad. A de minimis provision further restricting the issuance of certificates for antique ivory is needed to avoid a flood of applications for certificates that will likely overwhelm authorities, thus increasing the risk of ivory from poached elephants or otherwise obtained illegally being laundered through the system and sold as antique. 4. Exceptions regarding pre-1975 musical instruments should only apply when the volume of ivory in the instrument is less than 20% of the total volume of the material of which the instrument is made. 5. A witness statement/affidavit or signed declaration from an applicant for a certificate to trade antique worked ivory should not be accepted as a satisfactory proof of legal acquisition. Declarations in support of legal acquisition/origin should be provided by independent approved/recognised experts only. The results of the last EU public consultation, which received approximately 90,000 responses, showed overwhelming support for tightening the current EU rules on ivory trade (83.5% of respondents). We therefore again call on the European Commission to further revise and strengthen the proposal currently on the table to deliver on the longstanding request of the European Parliament and EU citizens, and the majority of African elephant range States, and respond to the new EU Council Conclusions asking for the closure of the EU domestic ivory market. This constitutes a unique opportunity to demonstrate global leadership and to urge other countries around the world to do the same. Please find attached a joint NGO statement with specific recommendations to further tighten the EU ivory trade regime. * www.unodc.org/unodc/en/data-and-analysis/tocta-2010.html
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Response to Improving environmental protection through criminal law

29 Dec 2020

Please find attached WCS EU's response to the roadmap on the revision of the EU Environmental Crime Directive.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

3 Sept 2020 · Implementation of EU 2030 Biodiversity Strategy

Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen)

30 Apr 2020 · wildlife conservation and biodiversity

Response to Wildlife trafficking - EU action plan (evaluation)

18 Mar 2020

WCS EU welcomes the opportunity to provide feedback on this Roadmap. WCS EU is a Belgian NGO affiliated with the Wildlife Conservation Society (WCS), a global NGO working to deliver wildlife conservation programmes in over 60 countries, mainly in Africa, Asia, the Pacific and Latin America, and works with governments on programmes to address wildlife trafficking. We strongly supported the adoption of the EU Action Plan against wildlife trafficking in 2016 and welcome the important progress that has been made. However, we note that several actions have not yet been achieved and that wildlife trafficking continues around the world. As demonstrated by the current COVID-19 coronavirus outbreak, the legal and illegal trade in wild animals and their consumption as food are serious threats to public health and safety, causing unprecedented levels of social and economic upheaval on a global scale. EU Member States (MS) and other governments have failed to treat wildlife trafficking as a serious crime and are not yet dedicating the required level of resources needed to fight it. Action is still needed or pending on several areas, including on the ivory trade, reviewing the Environmental Crime Directive, action on Free Trade Agreements and providing the same level of resources long-term sustainable financing as has been made available to fight other serious crimes, such as drug trafficking. Continued action and long-term sustainable funding support by the EU are still needed beyond the timeframe of the action plan, which ends in 2020. We agree that it is critical for the EU to assess the effectiveness, efficiency, coherence, relevance and EU added value of the Action Plan, as outlined in the roadmap: Effectiveness and efficiency – we urge the EU to assess its actions taken thus far and the extent to which they were effective, and to identify where action is still needed. This should evaluate whether the EU and MS have been treating wildlife trafficking as a serious crime and identify where the EU and MS need to step up efforts. Similarly, the EU should assess more precisely the level of funding needed and where funding should be targeted, in order to more effectively combat wildlife trafficking both within the EU and in other countries. It is also crucial to understand what factors have hindered the achievement of the outstanding actions and address these factors moving forwards. Coherence – we urge the EU to assess whether the actions taken thus far were coherent with the recommendations in the recent DEVCO studies on biodiversity conservation, including the 2016 study “Larger than Elephants” for Africa, the study 2018 “Larger than Tigers” for Asia, and the 2019 study on the interaction between security and wildlife conservation in sub-Saharan Africa. Moving forward, we urge the EU to increase coherence with the DEVCO studies to ensure that funding is targeted most effectively. We also call on the EU to ensure the continuation of the Action Plan after 2020 and integrate it with an overarching post-2020 biodiversity framework which includes outstanding and new measures. Finally, we urge the EU to increase coherence with crime related policies by other Directorates-General so that the fight against wildlife trafficking is fully integrated across the Commission services. Such a public consultation process is vital. We therefore call on the Commission to develop a comprehensive consultation, with relevant questions that are easily understandable by the public, alongside further engagement with NGOs and institutions with scientific, technical, and field-based expertise on the issue. We call on the Commission to continue the consultation process in a timely way, especially given the problems still being caused by some wildlife markets as demonstrated by the current COVID-19 pandemic. We therefore urge the Commission to provide a clear timeframe on next steps, particularly as the current Action Plan ends soon.
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Response to Minimising the risk of deforestation and forest degradation associated with products placed on the EU market

4 Mar 2020

WCS EU welcomes this opportunity to provide feedback on the EU Roadmap regarding ‘Minimising the risk of deforestation and forest degradation associated with products placed on the EU market’. WCS EU is a Belgian NGO affiliated with the Wildlife Conservation Society (WCS), a global NGO working to deliver wildlife conservation programmes in over 60 countries, mainly in Africa, Asia, the Pacific and Latin America. We very much welcome this new proposed action by the EU which is urgently need to tackle the inter-related crises of deforestation, climate change and biodiversity loss. We would like to make the following recommendations concerning the initiative: 1. We are concerned by the suggestion that EU action could be reduced to supporting voluntary action and/or labelling. Voluntary initiatives have been underway for many years and have been shown to be inadequate to tackle the issue in isolation. Likewise labelling, even if mandatory, is time-consuming and costly to put into place in relation to its limited impact. Deforestation will not be solved by providing increased information to consumers but requires legally binding measures. 2. As stated in the roadmap, the problems of deforestation, climate change and biodiversity loss are closely related. Such an initiative should therefore aim to guarantee that products coming on to the EU market are not causing deforestation, forest degradation or biodiversity loss elsewhere. How a ‘deforestation-free’ product is defined is therefore very important, to ensure that it covers deforestation, forest degradation and biodiversity loss, and that any new regulation does not lead to the conversion, direct or indirect, of other important natural ecosystems. 3. The EU should leverage the impacts of this initiative so that its impacts on deforestation and forest degradation are as large as possible. A narrow focus on ‘cleaning-up’ European supply chains will not necessarily tackle the issue sufficiently, as, for example, multi-national enterprises may simply direct the exports of their sustainably-produced products towards the EU market whilst continuing to export products associated with deforestation to other regions. Leveraging this initiative to achieve the greatest impact on the problem could be achieved by: a. Supporting countries or jurisdictions to become deforestation-free. This would enable the problem to be tackled more holistically with supporting actions at the deforestation frontier, and would go beyond the EU simply switching to sourcing products from already sustainable areas. This also would also make it easier to put measures in place to ensure that products are free from forest degradation and biodiversity loss and support those regions and countries that are keeping their forests intact. b. Ensuring the issue is a priority in dialogues with other consuming regions and countries to encourage them to take similar measures, such as China, India and Brazil. 4. We welcome the commitment to public consultation in the roadmap, however, this should not be limited to consultation with EU citizens. Properly resourced consultations with stakeholders in partner countries is also required. Furthermore, the initiative needs to be linked to supported actions financed via EU development-cooperation programmes. This would help the EU leverage greater benefits from this initiative to tackle deforestation and biodiversity loss through accompanying actions, for example, by increasing the capacity and securing the rights of local communities and Indigenous Peoples to conserve and manage forests.
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Response to Climate Law

6 Feb 2020

WCS EU welcomes this opportunity to provide feedback on the Roadmap for a European Climate Law and the aim of achieving climate neutrality by 2050. WCS EU is a Belgian NGO affiliated with the Wildlife Conservation Society (WCS), a global NGO working to deliver wildlife conservation programmes in over 60 countries, mainly in Africa, Asia, the Pacific and Latin America. While it is broadly accepted that climate change will have critical negative impacts on biodiversity, the EU is still failing to recognise the important role played by natural ecosystems, particularly forests, in climate mitigation and adaptation. As stated by the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services’ (IPBES) Chairman, “Governments have focused on climate change far more than they have focused on loss of biodiversity or land degradation"[1], although all three are interconnected and equally important to human health and wellbeing. There is currently a lack of coherence between EU biodiversity commitments under the CBD and climate action under the UNFCCC. Natural solutions, such as forest protection and restoration, are already available at the scale needed to deliver 30% of the climate solution needed by 2030 but receive less than 3% of climate funding globally and very little attention in global and EU climate policy discussions [2]. A significant body of science now recognises that the last intact ecosystems on earth, both terrestrial and marine, are disproportionately important in tackling some of our most pressing global challenges. The nature of their intactness holds the key to why they carry an outsize impact on these values. They are globally irreplaceable for their contribution to climate change mitigation potential, biodiversity, ecosystem services, sustaining imperilled cultures, and their resilience in the face of climate change, and are often highly threatened [3]. Intact forests, peatlands and oceans, for example, help to mitigate the impact of climate change by absorbing carbon. The vast majority of these last, remaining intact ecosystems are found outside of the EU’s borders but are greatly impacted by policy-making and decisions taken within the EU. The EU cannot achieve carbon neutrality by exclusively focusing on activities occurring within its own borders but must also take account of the carbon emissions, deforestation and negative impacts on biodiversity caused by investments in and the consumption of commodities produced outside of its borders. In the context of the European Climate Law and the move towards achieving climate neutrality, the EU should therefore: • Assess the opportunities for nature-based solutions to deliver climate change policy objectives and formulate a set of EU nature-based solution policies for climate action – both within the EU but also outside, by supporting key governments in partner countries to prioritise forest conservation within their National Determined Contributions (NDCs) under the Paris Agreement, and by halting the loss of nature caused by EU overseas investments and commodity imports. • Expand the EU budget target for climate to ‘climate and environment’ and increase it to 50% to ensure that natural ecosystems are also funded as a core contribution to achieving climate mitigation and adaptation. This is particularly important for the new Neighbourhood, Development and International Cooperation Instrument (NDICI) which should direct climate finance towards the financing of nature-based solutions in partner countries. • Prioritise conservation of the world’s remaining intact forests and other high carbon, high biodiversity ecosystems in both the new climate law and EU biodiversity strategy to achieve ‘win win’ solutions for both biodiversity and climate. [1] www.bbc.com/news/science-environment-48104037 [2] https://nature4climate.org/ [3] Watson et al. (2018) The exceptional value of intact forests. Nature Ecology and Evolution
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Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

22 Jan 2020 · 1. CBD and EU biodiversity strategy, Implementation of the EU Communication on conservation and restoration of the world’s forests, Implementation and follow-up to the EU action plan on wildlife trafficking, CMS CoP, IUCN Congress

Response to EU 2030 Biodiversity Strategy

20 Jan 2020

WCS EU Feedback 1. General Comments: WCS EU welcomes this opportunity to provide feedback on the Roadmap for an EU Biodiversity Strategy to 2030. WCS EU is a Belgian NGO affiliated with the Wildlife Conservation Society (WCS), a global NGO working to deliver wildlife conservation programmes in over 60 countries, in Africa, Asia, the Pacific and the Americas. As WCS EU draws upon WCS’s global field expertise and experience in formulating policy recommendations we only focus on the external dimension of the future biodiversity strategy. We are concerned by the limited consultation on this issue despite its importance and the long-term nature of the goals and actions to be outlined. As the EU Biodiversity Strategy will set out how the EU will implement its contribution to achieving the global biodiversity targets to be adopted at the CBD COP15 in October 2020, it is unclear why a strategy is to be proposed in advance of both the COP and the evaluation of the existing EU Biodiversity Strategy to 2020. In addition, whilst recognising that it is essential that the EU protects and restores biodiversity within its own borders, the vast majority of global biodiversity lies outside of the EU, particularly in the tropics, and is highly impacted by EU policies, trade, investment and consumption patterns. The external dimension should therefore be prominent within a new EU post-2020 biodiversity strategy but we are not aware of substantive consultation with stakeholders on this aspect. Organisations working on the external dimension are not involved in the EU Coordination Group for Biodiversity and Nature, for example, as this group normally focuses on domestic issues. We therefore urge the Commission to provide a clear timeline on the process for adoption of its strategy and to organise a public consultation after this first publication, in advance of a comprehensive strategy being adopted after the CBD COP. 2. EU Position for the Global CBD Negotiations: WCS is engaged in discussions within the CBD regarding new global targets for biodiversity, post-2020 and we will separately send our comments on the CBD zero draft document. A number of position statements are already available at the following weblink, including a call for a post-2020 target on coral reefs and a global commitment to protect and conserve at least 30% of the ocean: https://www.wcs.org/our-work/solutions/international-policy. In particular, we urge the EU to promote a new global target on ecosystem integrity. Ecological integrity, or ecosystem completeness and functionality in relation to its natural state, is a foundational principle of international environmental law and policy, starting in Rio Principle 7, and continuing through the CBD (Aichi Target 10), the UNFCCC (the Paris Agreement) and other national and international policies. Ecosystem integrity can be evaluated on the basis of the presence of ecologically functional populations of native species and the quality and extent of habitat. Spatial analyses of anthropogenic disturbance and/or evaluation of other ecological indicators can also be used, particularly where species data is incomplete. Aichi Targets 5 and 10 address ecological integrity but have suffered from ambiguity or complexity that has led to relatively poor implementation. The EU should therefore support a clear and well-defined high-level outcome target on ecological integrity for the post-2020 framework. This can be supported by action-oriented targets with an increased level of ambition, for example committing to protect 30% of the planet’s land and sea within area-based conservation measures. 3. EU Biodiversity Strategy Recommendations: Please see the uploaded document for our detailed recommendations on the external dimension of a new EU biodiversity strategy to 2030.
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Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

15 Oct 2019 · discussion on sustainable development and biodiversity

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and WWF European Policy Programme and

3 Jul 2019 · discussion on EU action on fighting deforestation

Response to Environmental Crime Directive Evaluation

3 Apr 2019

WCS EU Response to the Roadmap: Evaluation of the Environmental Crime Directive WCS EU welcomes this roadmap and the proposal to evaluate the Environmental Crime Directive. Tackling wildlife trafficking has become a high priority for the EU and its Member States, as highlighted by the EU Agenda on Security 2016-2020, the EU Action Plan against Wildlife Trafficking adopted in 2016, and the increasing amount of overseas development aid dedicated to fighting wildlife trafficking in partner countries. However, the EU’s efforts to promote the issue globally are not being matched by efforts to tackle wildlife crime within the EU. We fully concur with the statements laid out in the section A of the roadmap, and we agree that the evaluation of the Environmental Crime Directive should focus on waste- and wildlife crime. Wildlife trafficking constitutes one of the most immediate threats to biodiversity in many parts of the world. Wildlife is being bought and sold across the globe on an increasingly large scale as multiple commodities, including pets, food, medicine, furs, feathers, curios, and skins. The EU has an important role to play in addressing wildlife trafficking, as it constitutes a destination market, a hub for trafficking in transit to other parts of the world, as well as the source region for illegal trade in some species. A recent UN Environment - Interpol report concluded that environmental crime constitutes a threat to peace and security, and often converges with other serious crimes such as corruption, cybercrime and financial crime (1). The revision of the EU Environmental Crime Directive is essential as it is currently insufficient to effectively address wildlife crimes. Low rates of prosecution and penalties make environmental crime a high-profit, low risk activity for criminal groups. This is compounded by the lack of financial and human resources to tackle environmental crime in many Member States. The EU needs to update its legislation to bring it in line with the 2014 UN Convention against Transnational Organized Crime (UNTOC) declaration (2), of which the EU and its Member States are signatories, and which calls on countries to treat wildlife and forest crimes as serious criminal offences. The EU must use financial investigation and anti-money laundering techniques to combat wildlife crime. While we have been encouraged by the role the EU has taken in tackling this issue to date, we call on the Commission to fulfil the commitments it has made in this area, and to fully review and revise the EU Environmental Crime Directive. We urge the Commission to release the report on the contribution of criminal law to the fight against environmental crime (3), which was expected in 2018, and to take it into account in the evaluation of the Directive. Precise information and data on prosecution rates, enforcement capacity, and penalties, in EU Member States are necessary in order to adequately evaluate the Directive. We welcome the public consultation outlined in section B of the roadmap and request that the Commission develops a full and comprehensive consultation, with relevant questions that are easily understandable by the public to gain a full picture of the current challenges and gaps in the Environmental Crime Directive. We also call on the Commission to engage with local, national, and international NGOs with considerable expertise on the issue. (1) https://www.interpol.int/en/News-and-Events/News/2016/Environmental-crime-threatening-peace-and-security-finds-new-INTERPOL-UN-Environment-report (2) http://cites.org/sites/default/files/eng/news/sundry/2014/london-wildlife-conference-declaration-140213.pdf (3) www.europarl.europa.eu/doceo/document/E-8-2018-001060-ASW_EN.html
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