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WWF European Policy Programme

WWF EPO

WWF European Policy Office leads a global network to shape EU environmental policies.

Lobbying Activity

Meeting with Gordan Bosanac (Member of the European Parliament, Shadow rapporteur)

29 Jan 2026 · Position of LIFE program and biodiversity conservation in the new MFF

Meeting with Anna Stürgkh (Member of the European Parliament)

27 Jan 2026 · MFF

Meeting with Ana Vasconcelos (Member of the European Parliament, Shadow rapporteur for opinion) and Transport and Environment (European Federation for Transport and Environment) and

26 Jan 2026 · Performance Regulation

Meeting with Rudi Kennes (Member of the European Parliament)

26 Jan 2026 · EU environmental policy

Meeting with Yvan Verougstraete (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

26 Jan 2026 · European Competitiveness Fund

Meeting with Daniel Freund (Member of the European Parliament, Shadow rapporteur)

20 Jan 2026 · Performance Framework

Meeting with Christian Ehler (Member of the European Parliament, Rapporteur) and Rolls-Royce and European Centre for International Political Economy

13 Jan 2026 · European Competitiveness Fund

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall) and ClientEarth AISBL

13 Jan 2026 · Permitting aspects of the Environment Omnibus and Grids Package

Meeting with Cristina Guarda (Member of the European Parliament)

12 Jan 2026 · LIFE funds

Meeting with Benedetta Scuderi (Member of the European Parliament, Shadow rapporteur)

12 Jan 2026 · European Competitiveness Fund

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

7 Jan 2026 · Delivering the green transition, EU Budget, Life Programme

Response to Delegated Act on the own funds requirements for market risk

16 Dec 2025

Our WWF contribution addresses the proposed postponement and possible review of the FRTB under Basel 3 in light of the growing impact of climate- and nature-related risks on market risk and financial stability. While the initiative focuses primarily on market risk calibration and international competitiveness, market risk is evolving rather than diminishing. Climate- and nature-related physical and transition risks are increasingly shaping market dynamics through abrupt asset repricing, higher volatility and correlation effects. Decisions to amend binding prudential requirements should therefore be grounded in a robust assessment of their implications for financial stability, including growing sustainability-related risks. Arguments that further delays are needed to preserve EU competitiveness warrant careful scrutiny. Oxfams analysis shows that large EU companies have significantly increased profits in recent years, suggesting that EU firms and by extension the banks are not facing widespread economic disadvantage that would justify further dilution of prudential standards. Moreover, prospects for meaningful international convergence with Basel III standards remain limited, particularly in the United States. Additional postponements therefore risk becoming de facto permanent, hollowing out Basel III standards and drawing the EU into a global race to the bottom. This underscores the need for a formal impact assessment, which is currently not foreseen. The FRTB has already been delayed twice, and any further delay should be justified by a sufficient analysis of costs and benefits. Such an assessment should explicitly consider financial stability implications, including the growing climate- and nature-related financial risks. Without this, repeated postponements risk undermining regulatory credibility and creating long-term uncertainty. Climate and nature risks increasingly constitute material sources of market risk. ECB analyses show that euro-area banks increasing exposure to physical and transition climate risks can lead to significant losses and these risks are now increasingly reflected in supervisory stress tests. These effects extend beyond credit risk, directly affecting market prices, volatility and systemic risk dynamics. Nature-related risks remain even less adequately captured. Research from ECB shows that around 72% of euro-area companies depend heavily on at least one ecosystem service, implying that nature loss could heavily impair firms profitability, with spillover effects for banks balance sheets. Analyses by civil society organisations, including the WWF Greening Financial Regulation Initiative and CDP, further highlight the concentration of exposures of large, systemically important banks to environmentally sensitive sectors, and the under-integration of climate and nature risks in prudential frameworks, suggesting that existing market-risk methodologies may underestimate these risks. Against this background, market risk capital requirements should not be weakened or indefinitely deferred at a time when climate- and nature-related drivers are intensifying. The FRTBs more risk-sensitive methodologies are well suited to capture non-linear shocks, volatility and correlation effects associated with these risks. Any review of its implementation should therefore strengthen, rather than dilute, the capacity of prudential rules to reflect these realities. In conclusion, EU banks are not demonstrably uncompetitive, while climate and nature risks are increasingly shaping market dynamics. Further postponement of the FRTB without a comprehensive impact assessment risks undermining financial stability and delaying the alignment of prudential frameworks with emerging sources of market risk. The Commission should ensure that any adjustments to the FRTB are evidence-based, time-limited, and consistent with the growing recognition of sustainability risks as material drivers of market risk.
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Meeting with Thomas Pellerin-Carlin (Member of the European Parliament, Shadow rapporteur)

11 Dec 2025 · Performance Regulation

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné) and European Environmental Bureau and

9 Dec 2025 · Exchange of views on the forthcoming Industrial Accelerator Act (IAA), and other relevant industrial policies.

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur) and Comité national des pêches maritimes et des élevages marins

8 Dec 2025 · Planification maritime

Response to EU taxonomy - Review of the environmental delegated act

5 Dec 2025

We welcome the Commissions initiative to review the EU Taxonomy Climate and Environmental Delegated Acts to improve clarity, usability, and cost-effectiveness. However, we express significant concern regarding the proposed process and the implications of simplification. 1. Omission of a Comprehensive Impact Assessment The decision not to conduct an Impact Assessment on the grounds that the amendments are limited to targeted, technical adjustments is problematic. Changes to the Technical Screening Criteria (TSC) directly determine which economic activities qualify as sustainable. Altering TSCs, including on Do No Significant Harm (DNSH) issues, fundamentally affects the objectives of the Taxonomy Regulation (Level 1), including on climate mitigation and pollution prevention. The claim that these changes are merely technical contradicts their real impact. The Commission also has three years of reporting data from non-financial undertakings and two years from financial undertakings, collected through National Information Points (and feeding into ESAP as from mid-2026). This provides a strong empirical basis for a full assessment. We therefore urge the Commission to use the complete dataset to perform a thorough impact assessment. Without it, the revisions risk undermining the scientific robustness and credibility of the framework. 2. Risk of Deregulation under the Banner of Simplification We are concerned that the political drive for simplification will lead to deregulation and further weakening of sustainability ambition. Past changessuch as repeated amendments to Appendix C and the progressive, radical narrowing of harmful substances listsillustrate this risk. Rather than weakening obligations, the Commission should support companies by providing free, open-source digital tools that would greatly simplify their taxonomy reporting efforts. Private actors, especially AI-based service providers, already offer advanced tools: interactive maps for climate adaptation, water, and biodiversity; and substance-checking systems with integrated pop-ups and contract-based follow-up mechanisms (that can be phased in through contracts as recommended by the Platforms market practices compendium). These tools make reporting easier without weakening requirements. We strongly encourage the Commission to invest in open source tools to genuinely simplify implementation, rather than cutting criteria. 3. Maintaining Coherence and Global Leadership Rushed simplification without proper assessment risks disconnecting TSC implementation from the Level 1 objectives of the Taxonomy Regulation: - Alignment with CSRD/ESRS. The TSC revision should be coordinated with the Commissions final list of ESRS datapoints. These frameworks are complementary and must be aligned where relevant. - Strategic Importance. Over 60 jurisdictions are developing taxonomies globally, often inspired by the EU model. A robust, credible Taxonomy offers the EU a competitive advantage and strengthens the position of EU companies in global markets. - Credibility Risk. Poorly assessed cuts of criteria could create confusion, weaken implementation, and ultimately erode trust in the taxonomy framework among companies and stakeholders. We are therefore concerned that the Commission may rush revisions, without adequate assessment ensuring an evidence-based approach, in a way that weakens the connection between the delegated acts and the core objectives of the Level 1 Taxonomy Regulation. We urge the Commission to prioritise scientific integrity and coherence over short-term deregulation to ensure the Taxonomy remains a credible tool for supporting the green transition. Our specific recommendations for activity-level TSCs are included in the attached PDF.
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Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

4 Dec 2025 · Climate Adaptation

Meeting with Jens Geier (Member of the European Parliament)

3 Dec 2025 · MMF & EU Budget

Meeting with Thomas Bajada (Member of the European Parliament)

2 Dec 2025 · Meeting on the next MFF

Meeting with Maria Ohisalo (Member of the European Parliament)

2 Dec 2025 · Environmental omnibus

Meeting with Stefan Köhler (Member of the European Parliament)

2 Dec 2025 · Politischer Austausch über LIFE-Förderprogramme

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur) and ClientEarth AISBL and Frank Bold Society

1 Dec 2025 · Omnibus I

Meeting with Yvan Verougstraete (Member of the European Parliament)

19 Nov 2025 · Loi deforestation

Meeting with César Luena (Member of the European Parliament) and Stichting BirdLife Europe and EuroNatur - Stiftung Europäisches Naturerbe

19 Nov 2025 · LIFE programme

Meeting with Martin Günther (Member of the European Parliament) and Greenpeace European Unit and

18 Nov 2025 · Exchange

Meeting with Gerben-Jan Gerbrandy (Member of the European Parliament) and Greenpeace European Unit

18 Nov 2025 · EUDR

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

17 Nov 2025 · Sustainability omnibus - update for civil society

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

13 Nov 2025 · EU Deforestation Regulation

Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Frank Bold Society

5 Nov 2025 · Omnibus negotiations/ESRS revision

Meeting with Alexander Bernhuber (Member of the European Parliament)

4 Nov 2025 · MFR und GAP 2028-2034

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

3 Nov 2025 · Sustainability omnibus - update for civil society

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and ClientEarth AISBL and

28 Oct 2025 · Sustainability omnibus and climate transition plans

WWF urges structural energy poverty solutions in EU anti-poverty strategy

24 Oct 2025
Topic — EU's first comprehensive strategy to reduce poverty and implement social rights.
Message — WWF calls for binding EU measures to assess and address energy poverty, shifting focus from price subsidies to deep renovation programs and clean heating systems. They recommend recognizing cooling needs and transport energy poverty in official definitions.123
Why — This would advance their climate agenda by linking renewable energy and energy efficiency to social policy.45
Impact — Fossil fuel interests lose as the strategy promotes clean heating over traditional energy subsidies.6
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Meeting with Jutta Paulus (Member of the European Parliament)

16 Oct 2025 · Biodiversity policies

WWF urges dedicated LIFE budget in EU spending plans

15 Oct 2025
Topic — EU's next long-term budget and funding programmes for competitiveness and environment.
Message — WWF requests a dedicated budget line for LIFE environmental projects within the EU Facility, implementation through multi-annual work programmes, and retention of bottom-up project approaches. They warn that merging LIFE into broader funds without ring-fenced money risks sidelining nature and climate action.123
Why — This would maintain predictable funding for environmental programs and help close the EUR 19 billion annual biodiversity financing gap.45
Impact — Industrial sectors lose if environmental priorities receive protected funding within competitiveness budgets.67
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WWF Urges Higher Green Spending and Stricter EU Budget Tracking

15 Oct 2025
Topic — Consultation on performance and monitoring for the post-2027 EU long-term budget.
Message — WWF requests raising the green spending target to half the budget with a tenth for nature. They demand a separate tracking system for biodiversity and the removal of harmful subsidies.123
Why — This ensures funding for nature restoration while preventing the inflation of reported green spending.45
Impact — Harmful sectors like aviation and industrial farming would lose access to misleading green funding.67
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WWF urges 60% climate spending and biodiversity ringfence in EU budget

15 Oct 2025
Topic — EU's post-2027 budget reform consolidating funds into National and Regional Partnership Plans.
Message — WWF requests Member States dedicate at least 60% of partnership plans to climate and environment with 15% ringfenced for biodiversity. They want country-specific spending goals set in advance and plans linked to restoration objectives. They also demand dedicated LIFE budget lines and multiannual work programmes to ensure predictable nature funding.1234
Why — This would secure predictable funding to close the €19 billion annual biodiversity financing gap.56
Impact — Industrial priorities risk crowding out nature projects under the Competitiveness Fund's narrow focus.78
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Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall), Paulina Dejmek Hack (Cabinet of Commissioner Jessika Roswall)

9 Oct 2025 · EUDR

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

7 Oct 2025 · Meeting with WWF

Meeting with Delara Burkhardt (Member of the European Parliament) and Greenpeace European Unit and

6 Oct 2025 · deforestation

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

2 Oct 2025 · Sustainability omnibus - update for civil society

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

2 Oct 2025 · Multiannual Financial Framework

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque) and Ingka Services A.B. and H M Hennes Mauritz AB

1 Oct 2025 · Value chain cap - Omnibus

Meeting with Terry Reintke (Member of the European Parliament) and European Environmental Bureau and

30 Sept 2025 · Climate and Environmental Policies

Meeting with Lena Schilling (Member of the European Parliament, Shadow rapporteur)

29 Sept 2025 · 2040 Targets and LULUCF

WWF: Nature Credits Must Complement Not Replace Public Funding

26 Sept 2025
Topic — The European Commission is exploring a framework for nature credits to fund restoration.
Message — WWF insists nature credits must complement public funding and not be used for offsetting. They call for mandatory EU regulation to ensure integrity and scale up funding.123
Why — A formal framework would steer more private investment toward the conservation goals WWF supports.4
Impact — Sectors receiving harmful subsidies, like bioenergy, would face significant loss of EU funding.5
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Meeting with Sirpa Pietikäinen (Member of the European Parliament) and Climate Leadership Coalition

25 Sept 2025 · EU Omnibus I

Meeting with Pascal Arimont (Member of the European Parliament) and Oxfam-en-Belgique / Oxfam-in-België

24 Sept 2025 · Roundtable on EU Deforestation Regulation

Meeting with Veronica Manfredi (Director Environment)

23 Sept 2025 · Omnibus on environmental legislation Water Resilience Strategy

WWF Warns EU Carbon Removal Rules Enable Climate Greenwashing

22 Sept 2025
Topic — EU methodologies for certifying permanent carbon removal activities including BECCS and biochar.
Message — WWF demands the Commission redesign BECCS and biochar methodologies to require full lifecycle assessments or restrict eligibility to fast-decaying wastes with no other uses. They want stricter reporting requirements on biomass feedstocks consistent with existing EU regulations.123
Why — This would prevent certification of activities that WWF believes actually increase emissions.4
Impact — Bioenergy operators lose access to carbon removal credits for forest biomass feedstocks.5
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Meeting with Felix Leinemann (Head of Unit Maritime Affairs and Fisheries)

22 Sept 2025 · European Ocean Pact

Meeting with Christian Ehler (Member of the European Parliament)

15 Sept 2025 · Environmental objectives in next MFF

WWF urges EU to enforce strict seafood import standards

12 Sept 2025
Topic — EU strategy for fisheries external action and ocean diplomacy approach.
Message — WWF requests mandatory turtle excluder devices for all tropical shrimp imports, mirror clauses in trade deals requiring imported products to meet EU sustainability standards, and strengthened import controls. They want full implementation of the WTO fisheries subsidies agreement prohibiting support for overfished stocks.1234
Why — This would reduce competitive pressure on European fishers from imports not meeting EU standards.56
Impact — Non-EU fishing operators lose market access if unable to meet higher environmental standards.7
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Meeting with Eric Mamer (Director-General Environment) and

11 Sept 2025 · Exchange of views on the a) simplification agenda and the forthcoming omnibus on environmental policies, b) new MFF proposal, and c) implementation efforts for Nature Restoration Regulation (NRR) and EU Deforestation Regulation (EUDR)

WWF EU urges binding targets to tackle energy poverty

10 Sept 2025
Topic — This initiative focuses on protecting and empowering consumers during the just energy transition.
Message — WWF EU advocates for binding EU targets to address energy poverty and improved public participation. They recommend integrating social criteria into renewable auctions to benefit local communities.12
Why — This strategy ensures social acceptance for renewables while securing funding for biodiversity conservation.34
Impact — Large energy developers would face increased costs from mandatory revenue-sharing and complex social requirements.5
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Meeting with Luca De Carli (Head of Unit Climate Action)

8 Sept 2025 · Revision of the European Climate Law

Response to Delegated Regulation supplementing the review of prudential rules for the insurance and reinsurance sector (Solvency II)

5 Sept 2025

While WWF EPO welcomes several proposals on climate risk in the Solvency II DA, we have serious concerns about unconditioned capital relief. 1) We welcome the adjusted parameters for natural-catastrophe capital requirements. Reliance on historical data understates the non-linear, systemic and long-term dynamics of climate change; we therefore support embedding forward-looking assessments and requiring undertakings to establish robust internal procedures that limit reliance on past data. 2) We are, however, very concerned that other proposed amendments - mainly lowering capital requirements and giving preferential treatment to long-term equity and securitisation - reward insurers without any certainty that the extra capacity will flow into sustainable investments. The Commission claims lower capital charges will channel savings into productive investments for EU resilience and competitiveness, but fails to evidence such a claim. In practice, insurers are more likely to invest the freed-up capital in highest-paying, easiest-to-deploy, carbon-intensive investments (including fossil fuels) than toward clean projects (which often still have lower returns). Compounding this, supervisors will not be mandated to monitor how capital is spent, with no consequences for non-alignment. The proposed capital-relief changes must be carefully calibrated to avoid channelling capital into high-emitting equity indices and dirty securitisation pools. Any facilitation should be conditional on climate criteria (e.g. transition plans). Otherwise, the reform may increase insurers' natural catastrophe risk and undermine the EUs 2030 and 2050 sustainability objectives. 3) Given securitisations role in the 2008 subprime crisis and its tendency to add uncertainty and tight market interconnections, we find lowering prudential risk factors for STS and non-STS deals very worrying. Our concern is heightened by the Commissions latest securitisation package, which excludes sustainability safeguards. The broader securitisation framework should be reviewed to include sustainability safeguards for climate and nature before reducing risk factors for market participants. 4) We want to draw the Commissions attention to EIOPAs November 2024 report, in which it recognises that the financial risks of fossil fuel investments are underestimated and recommends adjustments to solvency capital requirements for insurers. We urge the Commission to prioritise a review of Solvency II requirements in 2025 to address EIOPAs findings. If fossil-fuel transition risks remain underpriced, insurers investments will skew toward fossil assets, increasing disorderly transition and physical climate risks. This would challenge insurers' business models. Overall, these amendments allow riskier investments to help insurers generate more profit but may undermine their solvency and broader financial stability by increasing exposure to equities and securitised products while reducing capital buffers and easing disclosure. We therefore strongly oppose them. Boosting returns should not come at the expense of financial stability - especially given the sectors high returns - and, in the long term, this would undermine, not advance, the EUs resilience and competitiveness. We therefore call on the Commission to: Carefully calibrate the risk factor for equity and securitisation investments of insurers, notably by introducing sustainability-linked provisions and climate and nature conditionalities; Review the securitisation framework to include sustainability-linked safeguards for climate and nature, before reducing the securitisation risk factor to the market participants; Establish a robust, supervisor-led monitoring and enforcement system to ensure insurers capital flows align with EU sustainability objectives and that climate- and nature-related risks are effectively managed. Urgently implement higher capital requirements for fossil fuel assets as per EIOPA's recommendation.
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Response to European climate resilience and risk management law

4 Sept 2025

Protecting and enhancing natural ecosystems and all the services they provide is critical to achieving climate resilience and limiting the rise of global temperatures. Therefore, a key pillar of the new EU climate resilience framework should be using nature to help people adapt. Evidence attached to this feedback shows that natural ecosystems are effective to reduce vulnerability to climate change impacts, often at a comparable or lower cost than grey infrastructure. For instance, the large-scale reconnection of floodplains to rivers effectively reduced flood risk for communities (Sacramento, California; Elbe, Germany). Even on a small scale, green spaces in cities can reduce temperatures by a few degrees (Medellin, Columbia). Ecosystem-based adaptation also has co-benefits in other fields such as climate mitigation, health, biodiversity, and water management. For instance, allowing natural water dynamics in the floodplain along the Tisza river in Hungary enhances biomass production, increases carbon sequestration, and reduces greenhouse gas emissions while maintaining acceptable agricultural yields. Forests help intercept rain (especially at altitude and near the coast), replenish aquifers, and avoid and fight forest fires, on top of being carbon sinks. Ecosystem-based adaptation can also help socially vulnerable groups such as older people, children, low-income groups and disabled people (who tend to be disproportionately affected by the impacts of climate change) cope with climate change impacts, if equity is factored in their implementation - as shown by examples of river regeneration in River Alt (Liverpool, UK) or mangrove restoration (Bangladesh). Using nature to help people adapt can make a significant contribution towards Europes Water resilience strategy, the full implementation of the EUs water acquis, as well as the implementation of the Nature Restoration Law. To maintain - and enhance - the climate buffer that nature provides, it is essential that any rollbacks on existing environmental legislation are avoided, and that the new framework promotes the implementation of the existing environmental legislation, as well as new measures to strengthen the non-deterioration and sustainable management of natural ecosystems. The new framework should include indicators which enable to track progress towards adaptation based on the Global Goal for Adaptation, make sure that the adaptive capacity of the EU is preserved (i.e., the cover of natural forests, a buffer to cope with the impacts of heat, droughts and wildfires, and a rainfall regulator), avoid maladaptation, and monitor the carbon and nature footprint of adaptation measures. The new framework should include governance and compensation mechanisms to guarantee just resilience. It should require Member States to conduct effective public consultations when drafting and updating their national climate adaptation strategies or plans. People who are the most impacted by climate change, need to transition towards climate resilient activities (e.g. farmers using their land for retaining water vs. active agricultural production), or must be relocated, should be involved in the definition of adaptation measures. When necessary, they should also be compensated, including using sectoral EU funds - for instance through allowing farmers to receive CAP payments for retaining water on land, and not only for active agricultural production. The MFF needs to dedicate sufficient and earmarked EU funds to ecosystem-based adaptation, and to include a reinforced do-no-significant-harm principle to avoid maladaptation and adverse impacts on nature. Finally, it is critical that the new framework is based on science, including the European Climate Risk Assessment which should be regularly updated and should include an assessment of the impacts of current emission reduction trajectories on temperatures, resource availability and ecosystems health in different European regions.
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WWF urges dedicated EU funding programme for civil society

2 Sept 2025
Topic — EU strategy to strengthen civic space and protect civil society organisations.
Message — WWF calls for a stand-alone EU funding programme for civil society, increased operating grants that explicitly include advocacy, and systematic civic space impact assessments across all EU policies. They want the LIFE Programme maintained as key support for environmental groups.123
Why — This would secure predictable funding streams and legitimize their advocacy activities.45
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Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra), Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra) and

27 Aug 2025 · Carbon Farming and Carbon Removal Certification

Meeting with Lena Schilling (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

27 Aug 2025 · 2040 Targets

Response to Implementing Act on the provision applying as from January 2026 of the amended Fisheries Control Regulation

7 Aug 2025

WWF EU welcomes the opportunity to give feedback on the draft Implementing Regulation laying down detailed rules for the implementation of Council Regulation (EC) No 1224/2009 as regards access to waters and resources, control of fisheries, surveillance, inspection and enforcement, deduction of quotas and fishing efforts, data and information, and repealing Commission Implementing Regulation (EU) No 404/2011. We would like to share the policy recommendations from the Fish-X project which is a project funded by Horizon Europe to support the digital transition of small-scale fisheries related to monitoring, control and surveillance measures and to traceability requirements. We recommend the EU Commission to take the following points into account in the finalisation of the Implementing Act about interoperability, standardisation and improved quality of data collection. Further inputs can be found in the White Paper "The Digital Transition of small-scale fisheries in the European Union https://fish-x.eu/wp-content/uploads/Fish-X-White-Paper-1-%E2%80%93-The-Digital-Transition-of-SSF-in-the-EU-final.pdf and in another White Paper Leveraging fishery technology to safeguard marine resources and support small-scale fisheries activities https://fish-x.eu/wp-content/uploads/White-Paper-3-Leveraging-fishery-technology-to-safeguard-marine-resources-and-support-small-scale-fisheries-activities.pdf We are thankful for taking into consideration our feedback and we remain at your disposal for any further information.
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Response to Delegated Act on the provision applying as from January 2026 of the amended Fisheries Control Regulation

7 Aug 2025

WWF EU welcomes the opportunity to give feedback on the draft delegated act supplementing Council Regulation (EC) No 1224/2009 by laying down rules on the control of fisheries, on the marketing of fishery and aquaculture products and on the surveillance and inspection of fishing activities, enforcement and compliance We would like to share the policy recommendations from the Fish-X project which is a project funded by Horizon Europe to support the digital transition of small-scale fisheries related to monitoring, control and surveillance measures. We consider important to take the following points into consideration in the finalisation of the draft act: - Traceability requirements should be coherently applied as laid out in the EUs Marketing Standards for fishery and aquaculture products, the Common Market Organisation and the Fisheries Control Regulation. The requirements should apply to processed and prepared products, as is already done for fresh and frozen products, as well as to imported and domestically produced products. The information displayed to consumers should be standardised for all retail actors, including the food service sector. Supplying granular and reliable information, including more precise data on the catch area, is crucial for efficiently assessing the legality and safety of seafood products and ultimately improving fisheries management and catch traceability. - Adaptation to the needs of small-scale fisheries must be central to ensure the buy-in from this sector. Digital reporting tools should be easy to use and useful for fishers, for which co-designing is essential. Activities to raise awareness and build digital literacy towards traceability should be done to ensure proper implementation and compliance with relevant EU legislation. In addition, the benefits to small-scale fisheries from improved transparency and traceability should be made clear with regards to market access, product valorisation and fair economic return (amongst other potential uses and benefits). Seafood product labelling could turn traceability information collected along the full supply chain into eye-catching displays to promote products harvested by small-scale fishers and how these generate socio-economic benefits. - Improve data collection along the entirety of the value chain with comprehensive and robust data sets, including for processed and prepared seafood products. Subject to informed consent, privacy and General Data Protection Regulation (GDPR) requirements, collected data could be made available for scientific purposes, including the work conducted by scientific bodies such as the Scientific, Technical and Economic Committee for Fisheries (STECF) and the International Council for the Exploration of the Sea (ICES). Qualitative data collection would be beneficial for improving monitoring programs and overall transparency of the seafood industry. Ensure effective data infrastructure across the EU with strong mobile data coverage to support robust data collection, management and storage, complying with traceability requirements and standards. Data infrastructure should fit within SSF distribution along coastlines and the multiplicity of landing sites. Please find in attachment the policy recommendations produced by the Fish-X consortium. Further inputs can be found in the White Paper "Digital traceability driving sustainable seafood consumption in the European Union": https://fish-x.eu/wp-content/uploads/FINAL_FISH-X-WHITE-PAPER-2_Digital-traceability-1-1.pdf. We are thankful for taking into consideration our feedback and we remain at your disposal for any further information.
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Response to European Climate Law amendment

31 Jul 2025

WWF welcomes the Commissions proposal to adopt an EU 2040 climate target. Adopting this target is an important step towards achieving the climate-neutrality objective, and creates certainty and predictability for Member States, industries, investors and citizens. However, WWF is concerned about the lack of ambition of the climate target. The ESABCC recommends the EU to adopt a net 90-95% domestic target, within the EU borders. They also recognise that this range is not fully aligned with what would constitute a fair share of global mitigation efforts. In that context, the European Commission should have aimed for the highest end of the range recommended by the ESABCC. Indeed, even if the EU is currently emitting only 6% of global emissions, it is worth noting that the current per capita emissions of the EU is comparable to that of China, and this is without taking into account the historical responsibility of the EU in global emissions (17% in the 1850-2021 period). The use of international credits should be only additional to a minimum target of 95% domestic cut of greenhouse gas emissions (ESABCC). Including 3% of international credits of 1900-levels emissions within the 90% target does not constitute a fair approach to climate mitigation under the Paris Agreement, and undermines the EUs credibility in global climate negotiations. Moreover, it is worth noting that 3% of 1900-levels emissions represent around 30% of total 2040 emissions. This means that the EU is going to emit 30% more than with a 90% domestic target. It is worrying that the European Commission didnt conduct an impact assessment regarding these international offsets, and therefore not respecting the Better Regulation principles. Moreover, Article 6 of the European Climate Law itself states that the Commission shall assess the consistency of any draft measure or legislative proposal with the climate-neutrality objective, include that assessment in any impact assessment accompanying these measures or proposals, and make the result of that assessment publicly available at the time of adoption. By proposing the inclusion of these credits into the 90% target, the European Commission is playing a guessing game with the climate crisis, and this raises the question of whether this is legal or not to include such measures in the law. WWF is similarly concerned about the Commission proposal indicating that the future architecture should include incentives for permanent CDR in the EU ETS. The Commission has yet to publish an impact assessment regarding the impact of CDR integration in the EU ETS, therefore also not respecting the Better Regulation principles. The integration of domestic permanent CDR in the EU ETS risks undermining much needed emission reductions. A recent study from Sandbag (2025) outlines that CDR integration is not necessary for the ETS to function up to 2040. If emissions reductions are implemented for the ETS 1 sectors, this would lead to a surplus of 157 million European Union Allowances in 2040. Furthermore, current methodologies for permanent removals under the CRCF lack environmental robustness and integrity. In so far as natural sinks are concerned, the Commission proposal includes a reference to the need to take into account natural changes in the land sink. It is important that the co-legislators look into the real driver of the decline of the land sink, namely increase in harvesting levels (Migliavacca et al., 2025). Only by appropriately assessing these drivers can the EU comply with its international legally binding obligation to preserve and enhance natural sinks (Article 4.2 UNFCCC). Lastly, we would like to remind the EU has a legally binding obligation to set policies (starting from NDCs) that keep global warming below 1.5°C compared to pre-industrial times. These policies must reflect the highest possible ambition. Failure to do so might arise to an internationally wrongful act (ICJ AO on climate change, 2025).
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Meeting with Lena Schilling (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

24 Jul 2025 · 2040 Targets

Meeting with Costas Kadis (Commissioner) and

18 Jul 2025 · Implementation of the Western Mediterranean multi-annual Plan

WWF urges swift adoption of EU pollinator monitoring rules

17 Jul 2025
Topic — This consultation concerns a new standardized methodology for monitoring pollinator diversity and abundance.
Message — WWF supports the proposed methodology and calls for its immediate adoption. They advocate for integrating citizen science and providing technical assistance to Member States.12
Why — The organization gains a robust framework to hold Member States accountable for restoration.3
Impact — Pesticide manufacturers and intensive farmers may face stricter regulations based on the data.4
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Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and ClientEarth AISBL and

17 Jul 2025 · EUDR and its implementation

Meeting with Jessika Roswall (Commissioner) and

15 Jul 2025 · Exchange of views on the Common Agriculture Policy, the Water Resilience Strategy and simplification.

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

14 Jul 2025 · PAB and CTB

Meeting with Michael Erhart (Director Budget) and

10 Jul 2025 · Discussion on the future Multiannual Financial Framework

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur)

10 Jul 2025 · Omnibus I

WWF urges sustainable options for new EU investment products

8 Jul 2025
Topic — A proposal to create a European blueprint for retail savings and investment accounts.
Message — WWF recommends launching low-cost products where consumers can earmark investments for the environmental transition. They call for aligning these accounts with sustainability regulations to ensure a mandatory sustainable option. Furthermore, they seek to strengthen shareholder rights to participate in corporate transition strategies.123
Why — Earmarking would prevent green savings from being diverted to industries like defense.4
Impact — Financial distributors would lose profits from high fees and conflict-ridden commission models.5
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WWF urges shift from carbon capture to material saving technologies

8 Jul 2025
Topic — Evaluation of the EU Innovation Fund's effectiveness in supporting industrial climate action.
Message — WWF suggests the Fund should prioritize technologies that directly reduce emissions. They demand that material savings become a mandatory criterion equal to innovation.12
Why — This change would secure more financial support for circular economy and electrification projects.3
Impact — Large industrial polluters in the cement and chemical sectors would lose massive subsidies.45
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WWF EPO demands end to free industrial carbon allowances

8 Jul 2025
Topic — The EU is reviewing its emissions trading system and market stability reserve for 2026.
Message — WWF EPO requests a phase-out of free allowances and the exclusion of carbon removals. They demand that EU funds stop financing fossil gas and biomass projects. The group also calls for strengthening market stability mechanisms to maintain carbon prices.1234
Why — Higher carbon prices would drive industrial transformation and help meet upcoming climate targets.56
Impact — Industries losing free allowances and countries using funds for fossil gas would lose support.78
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WWF urges EU to scrap free industrial pollution permits

8 Jul 2025
Topic — The European Commission is seeking evidence on accelerating decarbonisation within energy-intensive industrial sectors.
Message — WWF demands phasing out free carbon allowances and excluding carbon capture from the act. They prioritize electrification and renewables over expensive technologies while opposing additional fast-track permitting rules. They argue current laws already address permitting sufficiently.123
Why — These requirements ensure that public money supports only environmentally sound and socially responsible projects.45
Impact — Heavy industrial polluters would lose their existing exemptions from paying for carbon emissions.6
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Meeting with Alexandre Adam (Cabinet of President Ursula von der Leyen) and Transport and Environment (European Federation for Transport and Environment) and

1 Jul 2025 · Exchange of views on the next MFF climate change priorities

Meeting with Manuela Ripa (Member of the European Parliament)

1 Jul 2025 · Omnibus Directive

Meeting with Per Clausen (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and Climate Action Network Europe

27 Jun 2025 · Meeting on the negotiations on the Clean Industrial Deal

Meeting with Ricard Ramon I Sumoy (Acting Head of Unit Agriculture and Rural Development) and European Environmental Bureau and

24 Jun 2025 · Exchange on the Multiannual Financial Framework, Common Agricultural Policy, the Livestock Workstream, and Food

WWF warns EU against repeating bioenergy mistakes in bioeconomy

12 Jun 2025
Topic — An initiative to update the EU Bioeconomy Strategy for a circular and climate-neutral economy.
Message — WWF urges the Commission to avoid incentivizing biomass uses that harm biodiversity or increase emissions. They recommend against binding material substitution targets. They emphasize prioritizing high-value, long-lasting applications over short-lived products.123
Why — This would safeguard natural ecosystems and prevent the further collapse of carbon sinks.4
Impact — Food producers and urban sectors lose as bioeconomy expansion increases competition for land.5
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Meeting with Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné)

12 Jun 2025 · SFDR

Meeting with Anne Funch Jensen (Cabinet of Commissioner Piotr Serafin) and Transport and Environment (European Federation for Transport and Environment) and

11 Jun 2025 · Exchange of views on the future Multiannual Financial Framework and other EU priorities

Meeting with Manuela Ripa (Member of the European Parliament) and Fairshare Educational Foundation (ShareAction)

5 Jun 2025 · Sustainable Finance

Response to European Affordable Housing Plan

2 Jun 2025

WWF welcomes the Commissions initiative to develop a European Affordable Housing Plan. We support its aim to address the housing crisis structural drivers, ensure access to decent and affordable housing for all, and contribute to the EUs energy, climate, and social goals. To succeed, the Plan must place the renovation of existing buildings, and especially its financing, at its core. As the consultation document rightly notes, the current shortage of affordable housing is explained by several factors, including rising energy costs, outdated building stock, and the challenge of delivering housing that is both affordable and sustainable. Residential buildings are responsible for 42% of EU energy consumption, with the majority built before modern energy performance standards. Renovation of these buildings is therefore a key solution to reducing energy bills, improving living conditions, strengthening energy security, and supporting local jobs. The link between energy renovation and housing affordability is clear. Households most affected by the housing crisis are usually those facing energy poverty, and are often locked into the most inefficient buildings. Energy renovation can significantly reduce housing costs while improving well-being and health. Yet, the current scale of renovation is well below what is needed. The Commission estimates an annual investment gap of 335 billion until 2030. If the Plan aims to unlock investment and increase housing supply, a dedicated financing architecture for renovation is not just relevant, but indispensable. The Plans objectives will not be met without directly addressing the financing challenge. We therefore recommend the Plan includes a tailored, EU-level financing strategy for renovation reflecting the diverse socioeconomic landscape across Member States. A one-size-fits-all model will not work. Instead, the Plan should propose a simple but comprehensive financing architecture integrating complementary public and private investment mechanisms, tailored to meet different financial needs across all segments of society. For energy-poor households, public grants must fully cover renovation costs, and these grants should be disbursed upfront to avoid excluding those unable to bear initial costs. For households with poor credit access, blended solutions combining grants and subsidised loans are essential, supported by de-risking tools (e.g. loan-loss reserves, guarantee funds). For households who can afford loans, public support should focus on tax incentives, on-bill repayment schemes and technical assistance. In all cases, public support must be used strategically to leverage private investment, while ensuring that those in greatest need are not left behind. In this regard, WWF calls on the Commission to adopt concrete measures as part of the European Affordable Housing Plan. These include establishing an EU Renovation Loan to provide long-term, affordable financing; creating a pan-European advance payment fund for disbursing renovation grants upfront; setting up an EU-wide renovation guarantee to lower financial risks for households and lenders; defining clear, harmonised criteria for green loans, green mortgages and energy renovation mortgages; and promoting the development of Mortgage Portfolio Standards with transparent benchmarks and timelines for financial institutions. These actions would directly contribute to the Plans aim to mobilise investment and improve housing access. To ensure effectiveness, key enabling conditions must also be addressed: better data on energy performance, one-stop shops, trained financial staff, and streamlined regulatory frameworks to reduce administrative burden. This Plan is a key opportunity to align social and climate objectives by ensuring all Europeans can access comfortable and affordable housing, which can only be met through energy efficiency. To achieve this, building renovation financing must be treated as a central pillar of the strategy.
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WWF demands mandatory fossil fuel exclusion in finance rules

30 May 2025
Topic — The EU is reviewing rules for sustainable finance disclosures and fund categories.
Message — WWF proposes replacing current fund articles with three categories requiring mandatory fossil fuel exclusions and science-based targets. They also demand mandatory sustainability disclosures for all financial products to prevent greenwashing.123
Why — These stricter rules would help the organisation direct global investment toward environmental restoration.4
Impact — Fossil fuel companies would lose access to capital from green-labeled investment funds.5
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Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and Greenpeace European Unit and

27 May 2025 · EUDR

Meeting with Axel Hellman (Cabinet of Commissioner Jessika Roswall), Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall) and

20 May 2025 · Exchange of views on the upcoming Ocean Pact and Water Resilience Strategy

WWF urges EU to ban fossil fuel and biomass funding

15 May 2025
Topic — The European Commission is evaluating the operating rules of the EU Modernisation Fund.
Message — WWF demands excluding all fossil fuel, nuclear, and large-scale biomass investments. They insist funding only goes to states with binding 2050 climate targets.12
Why — This would ensure that EU financial resources directly support WWF's core environmental mission.3
Impact — Gas and biomass developers would lose access to billions in European climate subsidies.4
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Meeting with Sebastian Everding (Member of the European Parliament)

14 May 2025 · Eventplanung: UNOC & the EU’s Road to 2030: Protecting and Restoring Ocean Health

Meeting with Per Clausen (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and Climate Action Network Europe

14 May 2025 · Meeting on the negotiations on the Clean Industrial Deal

Meeting with Per Clausen (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and Climate Action Network Europe

14 May 2025 · Meeting with NGOs working on the Clean Industrial Deal

Meeting with Hanna Gedin (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and Climate Action Network Europe

14 May 2025 · Clean Industrial Deal

Meeting with Michal Wiezik (Member of the European Parliament)

14 May 2025 · LIFE programme

WWF demands strict rules to stop deforestation regulation loopholes

13 May 2025
Topic — This consultation addresses updating the list of products covered by deforestation rules.
Message — WWF requests precise definitions for second-hand goods and guidance on evidence. They advocate for mandatory five-year record-keeping for all excluded used products.12
Why — Tighter definitions would prevent companies from bypassing environmental standards through fraud.3
Impact — Dishonest traders lose the ability to hide new products as second-hand.4
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Meeting with Bas Eickhout (Member of the European Parliament, Shadow rapporteur for opinion) and Transport and Environment (European Federation for Transport and Environment)

13 May 2025 · Taxonomy Regulation

Meeting with Sirpa Pietikäinen (Member of the European Parliament) and European Environmental Bureau and

6 May 2025 · Protection status of the wolf

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque) and Transport and Environment (European Federation for Transport and Environment)

29 Apr 2025 · Sustainability Omnibus

Meeting with Daniel Freund (Member of the European Parliament) and CONCORD Europe and Civil Society Europe

29 Apr 2025 · Steering Group Fundamental Rights

Meeting with Christophe Grudler (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and Climate Action Network Europe

25 Apr 2025 · Clean Industrial Deal

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall)

10 Apr 2025 · Nature-based solutions

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur)

7 Apr 2025 · Omnibus I

Meeting with Michael Bloss (Member of the European Parliament)

7 Apr 2025 · Klimapolitik

Meeting with Agnese Papadia (Cabinet of Commissioner Dan Jørgensen) and Efficient Buildings Europe and

7 Apr 2025 · Energy efficiency renovations of buildings, housinG

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

7 Apr 2025 · Multilateral Affairs

Meeting with Jessika Roswall (Commissioner) and

31 Mar 2025 · Biodiversity issues

WWF Urges Green Safeguards for EU Securitisation Reform

26 Mar 2025
Topic — This consultation seeks a holistic review of the European securitisation framework.
Message — WWF recommends that securitisation be structured to specifically channel financing into sustainable projects like building renovations. They suggest either packaging sustainable assets separately or improving transparency to help investors identify green assets. The framework must be aligned with EU sustainability rules to prevent greenwashing and support the green transition.123
Why — This ensures sustainable assets remain identifiable, protecting the credibility of climate-focused investments.45
Impact — High-carbon activities lose access to funding as capital is diverted to sustainable projects.6
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WWF urges EU to reject 10% taxonomy threshold for corporate reporting

25 Mar 2025
Topic — EU proposal to amend taxonomy reporting requirements for sustainable investments.
Message — WWF requests the Commission reject the proposed 10% materiality threshold, arguing it would exempt almost half of companies from revenue reporting and allow major oil and gas firms to avoid disclosing green revenues. They demand the threshold be lowered to maximum 2% for large companies, completion of the taxonomy framework with missing activities, and preservation of detailed pollution criteria in Appendix C.1234
Why — This would maintain WWF's ability to monitor corporate climate commitments and prevent greenwashing.56
Impact — Investors and the public lose transparency into corporate green performance and transition claims.78
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Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur) and Frank Bold Society

24 Mar 2025 · Omnibus I

Meeting with Mohammed Chahim (Member of the European Parliament, Shadow rapporteur for opinion)

24 Mar 2025 · LIFE program in the new MFF

Meeting with Stefan Berger (Member of the European Parliament) and Fairshare Educational Foundation (ShareAction)

19 Mar 2025 · Sustainable Finance

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

18 Mar 2025 · Sustainable finance

Meeting with Catherine Geslain-Laneelle (Director Agriculture and Rural Development)

18 Mar 2025 · WWF’s position paper on the next Multiannual Financial Framework

Meeting with Georgiana Capraru Ianus (Head of Unit Structural Reform Support)

14 Mar 2025 · Discussion on the future Multiannual Financial Framework

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen) and European Environmental Bureau and

13 Mar 2025 · Green Deal

Meeting with Bas Eickhout (Member of the European Parliament)

13 Mar 2025 · Taxonomy Delegated Acts

Meeting with Aurore Lalucq (Member of the European Parliament, Rapporteur) and Third Generation Environmentalism Ltd and Fairshare Educational Foundation (ShareAction)

6 Mar 2025 · Omnibus, Sustainable Finance, SIU

Meeting with Sarah Nelen (Acting Director Environment) and Human Rights Watch and

5 Mar 2025 · EUDR Risk Benchmarking System

Meeting with Rasmus Andresen (Member of the European Parliament)

5 Mar 2025 · Sustainable Finance

Meeting with Valérie Hayer (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

5 Mar 2025 · Green Deal

WWF Urges EU to Prioritise Nature-Based Water Resilience Solutions

4 Mar 2025
Topic — The consultation addresses a new European plan for managing water resources and scarcity.
Message — The EU must strictly enforce existing water laws by the 2027 deadline. Policymakers should prioritise nature-based solutions over traditional grey infrastructure. Harmful subsidies for water-intensive farming and hydropower must be phased out immediately.12
Why — Stronger environmental mandates would protect biodiversity and secure long-term conservation funding.3
Impact — Intensive agricultural businesses and the hydropower industry face reduced funding and stricter limits.4
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Meeting with Iratxe García Pérez (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

4 Mar 2025 · Just Transition

Meeting with Fabio De Masi (Member of the European Parliament) and Fairshare Educational Foundation (ShareAction)

3 Mar 2025 · Sustainable finance

Response to Savings and Investments Union

25 Feb 2025

1. Mobilising savings more effectively: We support the Commissions plans to consider launching simple and low-cost saving and investment products, especially as the Retail Investment Strategy will no longer nudge retail investments to financial markets. This failure is due to structural problems in the current retail investment market, including excessive layering and fees at product origination and the dominant inefficient distribution model that creates conflicts of interest due to its heavy reliance on inducements. We recommend to focus on streamlining existing simple investment products such as the Pan-European Personal Pension Product. Due care should be given to consumer choice by launching several products, whether savings- or investment-based, to avoid one-size-fits-all systems such as the French Livret A, which pools assets to finance social housing that were suddenly deviated to finance the defence industry. To avoid consumer detriment related to sudden reallocation based on political considerations, they should be able to earmark their investments for the environmental and other transitions that would benefit from SIU funding. We thus recommend to align the simple products framework to the forthcoming SFDR review, e.g. by always offering one sustainable option in line with the current SFDR Art 9. The SFDR itself should be revised to move towards a mandatory product categorisation system including a transition category with minimum criteria. While proposals to further stimulate securitisation in the EU might be seen by the Commission as a potential way to free up capital, we caution that increased use of securitisation will break the link between investor and investee, or borrowers in the case of packaged loans. This not only potentially hurts citizens who can no longer renegotiate a loan on which they are about to default, but especially goes against the other initiatives in the SIU and CMU that aim to strengthen the link between companies and their investors, e.g. on shareholder rights (see below). 2. Identify and remove barriers to cross-border activity: Beyond measures aimed at young and innovative and productive and innovative firms, we believe the scheduled review of the Shareholder Rights Directive II (SRD II) should be used to give investors a more streamlined and simplified way to exercise their rights, in particular for companies that have higher exposure to transition risks. The review of SRD II would help contribute to the SIUs objectives if it includes measures to engage on transition strategies, for instance by strengthening the rights of shareholders to table resolutions and participate in AGMs. 3. Enhance supervisory arrangements: The ESAs play an important role in developing European capital markets for the green and digital transitions. ESMA will also play a role as a direct supervisor of entities crucial for the transition, such as ESG rating agencies. However, the governance structure of the ESAs continues to promote national interests over the European one, despite some changes since the 2017 review of the ESA regulations. We therefore support measures for further harmonisation of EU supervision, and application of the single rulebook. This also means relying less on individual supervision arrangements which inevitably vary from one supervisory tradition or sector to the other, and more on more predictable harmonised rules. One example is the integration of manifestly material transition risks, which continue to rely on individual add-ons through a Pillar 2 (SREP and ORSA) surcharge, whereas EIOPA has quantified and recommended a dedicated prudential treatment for fossil fuel assets held by insurers as high as 40% for bonds and 17% for stocks. The reluctance by some EIOPA Board of Supervisors members to approve this study shows that a further review of the ESAs governance is needed, and supervision should be simplified by moving resources from the national to the European level.
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Meeting with Lynn Boylan (Member of the European Parliament)

25 Feb 2025 · Nature Restoration funding in upcoming MFF

Meeting with Christine Singer (Member of the European Parliament) and WWF Deutschland

24 Feb 2025 · MFF - ENVI part

Response to Implementing Act on non-price criteria in renewable energy auctions

21 Feb 2025

Environmental sustainability criteria: - WWF welcomes the incentives to tackle biodiversity loss and ecosystem collapse in auctions, mainly through the environmental sustainability criteria on biodiversity impact. However, while the draft Implementing Act stresses that Member States can include environmental sustainability criteria when appropriate, WWF recommends that these criteria are included in all renewable projects. - WWF welcomes that the Commission is highlighting the need for a robust monitoring system for criteria mitigating impacts on biodiversity. This should also be extended to the award phase and the monitoring of nature-positive contributions. However, the draft Implementing Act should clarify the methodology Member States should use when assessing these criteria. - WWF supports the request for data and information collected to be shared with the scientific community and public authorities. Social aspects: - While WWF acknowledges that the Implementing Act does not focus on social criteria, we believe that such criteria are essential to strengthen the resilience of projects. Auctions are an opportunity for renewable energy projects to be more inclusive and socially accepted. Social criteria should include citizens participation (eg, financial participation and access for renewable energy communities, engagement and participation of local communities), workers policy from bidders (eg, programs for vocational training, incentivise the use of reskilled workers and apprentices, promotion of traditional local activities, commitments to the professional integration of people experiencing particular social or professional difficulties), involvement of other stakeholders (eg, SMEs, academia, researchers). Responsible business conduct criteria should include fair, safe and competitive working conditions, and securing Indigenous peoples rights when relevant. WWF recommendations: - For auctions developed under the EU State Aid Guidelines on Climate and Energy, countries should make full use of the 30% threshold for non-price criteria in the award phase, and focus on ecological and social dimensions. For auctions not financially supported by public money, and therefore not covered by the threshold, the share of non-price criteria should exceed 30%. - States should use ecological and social non-price criteria as prequalification criteria to establish a minimum threshold of the pursued objective that all bidders in the auction must meet. - For offshore wind tenders, Member States should discuss the criteria used at sea basin level in order to harmonise the list of non-price criteria, while keeping some flexibility depending on the specificities of each wind farm's location (e.g., topology, size, ecosystems). States should set comprehensive ecological criteria in the prequalification and auction phases that address measures corresponding to all parts of the mitigation hierarchy (i.e. measures to avoid impacts, to reduce impacts and to restore and regenerate ecosystems), placing emphasis on avoidance first. - Social criteria should guarantee human and Indigenous peoples rights, local communities engagement, and strengthen local and regional competitiveness by promoting short supply chains, and the involvement of local workers. - Non-price criteria in auctions should be measurable and scorable and avoid ties among applicants, aiming to incentivise the best achievement of a given objective. - States relevant authorities ensuring compliance with the criteria must be defined, and non-compliance should lead to penalties.
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Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

20 Feb 2025 · Exchange on the upcoming Omnibus

Meeting with Chloé Ridel (Member of the European Parliament)

19 Feb 2025 · Biodiversité

Response to The European Oceans Pact

17 Feb 2025

EU seas are under immense pressure. Over decades, destructive practices, pollution, and overexploitation have pushed marine ecosystems to breaking point. In this context, WWF and 140 organisations have jointly put forward a plan to restore the health of our seas and ensure their resilience. The Oceans Pact is a unique opportunity to guarantee healthy oceans, ensure a just transition to low-impact activities and establish strong international ocean governance. 1.Strengthen implementation, compliance and enforcement of existing regulation: Establish EU Ocean and Seas Agency or a cooperation mechanism between Agencies and ocean-related monitoring systems to streamline data, ensure open access and issue regular reports on environmental status Increase resources for compliance and enforcement to address violations Strengthen the fisheries control system by including digital traceability of seafood products, engine power monitoring, and REM of vessels at high risk of violating EU fisheries rules Ensure full public transparency on the allocation of fisheries opportunities either by publishing annual EU level reports or by creating a new database with precise catch and effort data in a usable form per Member State Introduce mandatory non-price criteria on biodiversity, social aspects and circularity, and conduct annual assessments in offshore renewable energy auctions Protect and enhance the implementation of the current CFP which is the most comprehensive complementary legislation to marine conservation policies, and has played a key role for the EU in tackling global efforts to promote sustainable fisheries and healthy marine ecosystems 2.Policy coherence across ocean sectors: Strengthen and promote ecosystem-based management (EBM) across all relevant policy areas and sectors. Mandate and strengthen the use of ecosystem-based fisheries management and require improved scientific advice (based on ecosystem dynamics and inter-species interactions), to achieve objectives of relevant policy areas (e.g. MSFD, NRL) Make the environmental targets of the MSFD legally binding, for example through national nature restoration plans; strengthen coherence between climate, ocean, biodiversity and land-based policies/sectors (e.g. agriculture) in accordance with a source-to-sea approach Establish an Ocean Fund, curtailing subsidies to harmful activities with simpler access for nature projects and guaranteed funding for low-impact activities Promote transparency and integrate strong reporting and access to justice provisions 3.Ensure a just transition to a low impact blue economy and ensure long-term ocean health over short-term exploitation: Propose new legislation to restrict the import and trade of aquatic food products that cause harm to endangered species and bycatch of sensitive species, for example by including a mirror clause for environmental legislation to seafood entering the EU market with a specific TED regulation Propose an action plan for a just transition to a well-being blue economy that respects ecological limits Enshrine ecological limits into law, including binding 2030 targets to secure that at least 30% of EU seas is effectively protected, including at least 10% under strict protection Decommission before 2030 all harmful activities at sea prioritising EU MPAs including, but not limited to, bottom trawling and oil and gas platforms. Propose a ban on deep-sea mining in European seas and advocate for a moratorium within the International Seabed Authority and other international ocean governance bodies Monitor and regulate marine CDR activities at EU and international level in accordance with international agreements Enforce traceability provisions included in the Fisheries Control Regulation and improve seafood labelling, including aquaculture and the source of wild-captured feed, to prevent sourcing from IUU activities; ensure environmentally and socially responsible practices through a targeted revision of the CMO
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Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné), Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné) and

13 Feb 2025 · Clean Industrial Deal

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque) and Third Generation Environmentalism Ltd

12 Feb 2025 · Sustainability Omnibus

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis), Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis) and

10 Feb 2025 · Simplification

WWF Urges Mandatory Details in EU Nature Restoration Plans

7 Feb 2025
Topic — EU consultation on the standardized format for Member States' national nature restoration plans.
Message — WWF demands all legal requirements be mandatory within the uniform format to ensure accountability. Member States should provide concrete maps and scientific evidence to determine necessary restoration measures. Plans must also describe inclusive public participation and provide detailed estimates of financial needs.12
Why — Stricter reporting requirements would allow WWF to effectively monitor national progress and advocate for necessary funding.3
Impact — National governments lose the ability to use vague, generic descriptions to bypass their legal obligations.4
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Meeting with Valérie Hayer (Member of the European Parliament)

7 Feb 2025 · CFP post-2027

Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and

5 Feb 2025 · Water Resilience

Meeting with Grégory Allione (Member of the European Parliament, Shadow rapporteur)

4 Feb 2025 · Réunion WWF

Meeting with Christophe Hansen (Commissioner) and

3 Feb 2025 · Exchange of views on the Vision for Agriculture and Food and the European Board on Agriculture and Food

Meeting with Anthony Smith (Member of the European Parliament) and Climate Action Network Europe

3 Feb 2025 · Clean Industrial Deal

Meeting with Sigrid Friis (Member of the European Parliament)

31 Jan 2025 · Water Resilience

Meeting with Stefan Köhler (Member of the European Parliament, Shadow rapporteur) and Confederation of European Paper Industries

30 Jan 2025 · Politischer Austausch

Meeting with Jessika Roswall (Commissioner) and

22 Jan 2025 · Nature protection

Meeting with Maria Ohisalo (Member of the European Parliament) and Greenpeace European Unit and Suomen luonnonsuojeluliitto - The Finnish Association for Nature Conservation

22 Jan 2025 · Forest Monitoring

Meeting with João Oliveira (Member of the European Parliament, Shadow rapporteur) and Naturschutzbund Deutschland e.V.

17 Jan 2025 · Quadro Financeiro Plurianual pós-2027 e a sustentabilidade ambiental

Meeting with Željana Zovko (Member of the European Parliament)

15 Jan 2025 · Conference

Meeting with Francesca Arena (Cabinet of Commissioner Costas Kadis)

14 Jan 2025 · IUU fishing in French Guyana and by-catch of turtles

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament)

14 Jan 2025 · Pêche illegale et biodiversité Guyane

Meeting with André Rodrigues (Member of the European Parliament)

8 Jan 2025 · WWF EU Marine Event

Meeting with Matthias Ecke (Member of the European Parliament) and Climate Action Network Europe

18 Dec 2024 · Klima- und Industriepolitik

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

17 Dec 2024 · Upcoming guidance on transition plans

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Human Rights Watch and

12 Dec 2024 · Sustainable corporate reporting

Meeting with Mélissa Camara (Member of the European Parliament) and FUNDACION OCEANA

11 Dec 2024 · Follow the Fish

Meeting with Bruno Gonçalves (Member of the European Parliament) and Climate Action Network Europe

5 Dec 2024 · ITRE policies

Meeting with Thomas Bajada (Member of the European Parliament) and FUNDACION OCEANA and

3 Dec 2024 · Event on Seafood Labelling

Meeting with Benedetta Scuderi (Member of the European Parliament) and European Environmental Bureau and Climate Action Network Europe

20 Nov 2024 · Industrial transition

Meeting with Bruno Tobback (Member of the European Parliament) and Stichting BirdLife Europe

20 Nov 2024 · Bioenergy, Forests and Land Use

Meeting with Tom Berendsen (Member of the European Parliament) and European Environmental Bureau and Climate Action Network Europe

19 Nov 2024 · Industry transformation

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament) and European Environmental Bureau

19 Nov 2024 · Decarbonisation of industry

Meeting with Bas Eickhout (Member of the European Parliament)

13 Nov 2024 · MFF

Meeting with Nicolo Brignoli (Cabinet of Executive Vice-President Valdis Dombrovskis) and Third Generation Environmentalism Ltd and Fairshare Educational Foundation (ShareAction)

12 Nov 2024 · Sustainable finance

Meeting with Antoine Bégasse (Cabinet of Commissioner Mairead Mcguinness) and Third Generation Environmentalism Ltd and Fairshare Educational Foundation (ShareAction)

12 Nov 2024 · Capital markets, economic transition, corporate and sustainability

WWF Urges EU to Boost Green Renovation Loans

5 Nov 2024
Topic — The consultation concerns establishing a voluntary framework for banks to increase building renovation lending.
Message — WWF calls for science-based methodologies for banks to set targets aligned with climate goals. They prioritize renovating the worst-performing buildings and creating harmonized definitions for green loans.123
Why — Standardized targets and definitions allow the organization to achieve a zero-emission building stock.4
Impact — Banks may face higher costs for extensive staff training and energy performance data collection.56
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Meeting with Valérie Hayer (Member of the European Parliament) and European Environmental Bureau

5 Nov 2024 · Strategic Dialogue for the future of farming

Meeting with András Tivadar Kulja (Member of the European Parliament)

4 Nov 2024 · EU environmental policies on sustainable development

Meeting with Valdis Dombrovskis (Executive Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

28 Oct 2024 · Upcoming mandate, simplification and burden reduction, competitiveness and productivity, especially in the context of Green Deal.

Meeting with Sigrid Friis (Member of the European Parliament)

28 Oct 2024 · Biodiversity regulation

WWF urges stricter standards for fossil-based low-carbon fuels

25 Oct 2024
Topic — This consultation defines the greenhouse gas emission savings methodology for certifying low-carbon fuels.
Message — WWF EPO demands raising the greenhouse gas reduction threshold to 80% and setting a phase-out date by 2035. They argue fossil-based hydrogen using carbon capture should not be labeled as a climate solution. They also request stricter methane leakage measurements.123
Why — This ensures financial resources prioritize renewable energy instead of extending fossil fuel reliance.4
Impact — Fossil gas producers lose subsidies for hydrogen projects that utilize carbon capture technology.5
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Meeting with Sigrid Friis (Member of the European Parliament)

25 Oct 2024 · Deforestation Regulation

Meeting with Marie Toussaint (Member of the European Parliament)

23 Oct 2024 · Environmental crimes

Meeting with Per Clausen (Member of the European Parliament, Shadow rapporteur)

22 Oct 2024 · Meeting on the ongoing negotiations on the Forest Monitoring file

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

17 Oct 2024 · follow-up meeting EU green deal

Meeting with Sérgio Gonçalves (Member of the European Parliament)

16 Oct 2024 · Priorities for this mandate

Meeting with Michal Wiezik (Member of the European Parliament) and ClientEarth AISBL and

15 Oct 2024 · Ocean Pact

Meeting with Marie Toussaint (Member of the European Parliament) and Greenpeace European Unit and

15 Oct 2024 · deforestation

Meeting with Marie Toussaint (Member of the European Parliament) and Frank Bold Society

10 Oct 2024 · Sustainable finance

Meeting with Sara Matthieu (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

2 Oct 2024 · Commissioner hearings

Meeting with Cristina Guarda (Member of the European Parliament) and European Environmental Bureau and Stichting BirdLife Europe

2 Oct 2024 · Agricolture

Meeting with Lynn Boylan (Member of the European Parliament)

1 Oct 2024 · Biodiversity protection, renewable energy, social justice in climate action

Meeting with Alexander Bernhuber (Member of the European Parliament)

1 Oct 2024 · WWF-Beitrag zur Bewusstseinsbildung für Artenvielfalt

Meeting with Kristian Vigenin (Member of the European Parliament)

25 Sept 2024 · Introductory meeting

Meeting with Sara Matthieu (Member of the European Parliament) and European Environmental Bureau and Climate Action Network Europe

25 Sept 2024 · Industrial Policy

Meeting with Florika Fink-Hooijer (Director-General Environment) and Transport and Environment (European Federation for Transport and Environment) and

20 Sept 2024 · Priorities of the new College

Meeting with Delara Burkhardt (Member of the European Parliament) and Greenpeace European Unit and

18 Sept 2024 · EUDR

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament)

18 Sept 2024 · Pêche / Océan / Biodiversité

Meeting with Thomas Bajada (Member of the European Parliament) and ClientEarth AISBL and

11 Sept 2024 · Introductory Meeting with Blue NGOs

Response to Evaluation of the Common Fisheries Policy

6 Sept 2024

Please find attached WWF's feedback to the consultation about the evaluation of the Common Fisheries Policy. We remain at your disposal for more information.
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Response to Ex-post evaluation of European Maritime and Fisheries Fund (EMFF) 2014-2020

6 Sept 2024

The need to rethink and optimise the use of public subsidies is pivotal to ensure a prompt transition towards low-impact, socially responsible and economically viable fisheries, and ensure thriving and diversified coastal economies. Regrettably, a concerning share of the funds distributed through the EMFF and the EMFAF are considered capacity enhancing and/or environmentally harmful. At the EU level, between 5% and 12% of the EMFAF is channelled into biodiversity harmful subsidies, more than double the amount of the funding dedicated to protecting and restoring biodiversity - the very foundation of fisheries sustainability (1). In the Mediterranean, a striking 39% of EMFF allocations were capacity-enhancing subsidies, while just 5% of EMFF funding was unambiguously beneficial (2). In light of these figures, it is clear that both the EMFF and EMFAF have not been effectively nor coherently used to deliver on their own objectives and those of the Common Fisheries Policy. It is urgent for the EU to effectively eliminate all forms of harmful fisheries subsidies. The preparation of the operational programmes is of utmost importance. In 2021, NGOs had provided 15 recommendations to Member States to adopt fair, ambitious, innovative and revitalising operational programmes, necessary to deliver on the EUs fisheries and environmental objectives (3). According to our internal analyses, few Member States have adopted programmes generally aligned with these recommendations. This is a recurrent issue since, already under the EMFF, some of the biggest recipients had also failed to use the funds in conservation efforts to end overfishing and restore the marine environment. The European Commission needs to ensure that all operational programmes are strictly aligned with the EUs ambition towards sustainable fisheries and restored marine ecosystems, and any future iteration of the EMFAF must prohibit all forms of harmful subsidies while incentivising those that are unambiguously beneficial. The necessary efforts for EU fisheries to minimise their environmental impacts and maximise their socio-economic benefits are significant, and their incumbent costs cannot always only be borne by fishers themselves. This is particularly true for small-scale coastal fisheries, whose access to funding under both the EMFF and EMFAF has been difficult (4). Despite representing 75% of the total EU fleet, the small-scale coastal fishing fleet only received about 20% of the EMFF envelope. Member States also failed to sufficiently collect data and develop, when required, action plans for the development, competitiveness and sustainability of small-scale coastal fishing. In the Mediterranean, WWF has worked with small-scale fishers to help them access funding, successfully in most cases. But the barriers faced by small-scale fishers are significant, ranging from a lack of capital, complex application procedures, or lack of information about opportunities available. These issues must be addressed. The EMFF/EMFAF is a crucial yet limited source of EU funding to support the EUs sustainable fisheries and marine biodiversity protection and restoration objectives, and to ensure healthy seas upon which we all depend. Yet, it represents a negligible share of the total EU budget. The ocean covers of our planet and the EU has the worlds biggest maritime territory. Yet, out of the 1.211 trillion EUs long-term budget, the EMFAF is only attributed 7.8 billions. Given the significant work required to restore our seas and transition to sustainable, low-impact fisheries, this budget should be expanded and its use must be optimised. References: (1) WWF (2024), "Can your money do better?" (2) WWF (2024), "Rethinking fisheries subsidies" (3) WWF, ClientEarth, BirdLife, LIFE (2021), "15 Recommendations for spending the European Maritime Fisheries and Aquaculture Fund" (4) ClientEarth (2023), "Small-scale fishers revealed as least supported recipients of EU funds"
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Meeting with Sebastian Everding (Member of the European Parliament)

3 Sept 2024 · Introductory meeting

Meeting with Marie Toussaint (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

17 Jul 2024 · Green Deal and environmental issues

Meeting with Ville Niinistö (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

17 Jul 2024 · Upcoming 2040 climate legislation

WWF warns against industry pressure on EU carbon storage rules

16 Jul 2024
Topic — Establishing conditions for permanently bound carbon emissions in products under the EU ETS.
Message — WWF insists on a strict definition of permanence lasting several centuries and excluding natural carbonation processes. They urge the Commission to resist industry pressure and maintain a transparent whitelist for approved products.123
Why — Strict standards ensure that the EU ETS remains focused on direct emission reductions.4
Impact — Industrial operators using unproven technologies or natural carbonation would be barred from ETS benefits.5
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Meeting with Nina Carberry (Member of the European Parliament)

16 Jul 2024 · EU Green Deal

Meeting with Krzysztof Śmiszek (Member of the European Parliament)

16 Jul 2024 · Animal Welfare

Meeting with Lena Schilling (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

16 Jul 2024 · Climate and Enviroment Policy

Meeting with Thomas Waitz (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

16 Jul 2024 · Climate and Enviroment Policy

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament) and European Environmental Bureau and Stichting BirdLife Europe

11 Jul 2024 · Climate policies

WWF Urges EU to Strengthen Forest Carbon Sink Protections

9 Jul 2024
Topic — The evaluation assesses the effectiveness of EU land use and forestry rules.
Message — The group demands ending bioenergy subsidies and ensuring the protection of old-growth forests. They also seek to remove accounting flexibilities that allow countries to offset emissions elsewhere.123
Why — These changes would advance their core mission of halting global environmental degradation.45
Impact — The bioenergy industry loses financial support and faces restricted access to wood fuel.67
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Meeting with Jens Geier (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and European Environmental Bureau

9 Jul 2024 · Exchange on Expectations on the new European Parliament and EU Commission (EU Industry Policy, Global Trade, Green Deal, Energy Policy)

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and European Environmental Bureau and

25 Jun 2024 · Environmental priorities and maintaining course of Green Deal

Response to Application of the ‘do no significant harm’ principle to the Social Climate Fund and its possible future extension

28 May 2024

The introduction of the DNSH principle in the use of EU funds is important for ensuring environmental sustainability objectives are supported consistently. However without granular and mandatory guidelines, its implementation will remain weak and suboptimal. Based on detailed evidence provided in the annex, we believe that in guidance for the Social Climate Fund, the following should be considered as common principles: 1) Investments in fossil gas appliances or infrastructure (e.g. gas boilers, including for district heating systems) must be excluded, to avoid carbon lock in. DNSH guidance for RRF has not fully excluded the financing of fossil gas investments; these loopholes must be excluded under the SCF. The ESABCC report Towards climate neutrality stresses the need to avoid ambiguity on fossil fuel phase out. Gas boilers will lock in poor households into fossil fuel dependency but also likely growing bills. A stronger focus on customised renovation roadmaps would help avoid lock-ins and shallow retrofits. 2) As per RRF technical guidance, SCF measures should consider both direct and indirect impacts, and apply lifecycle considerations. E.g. schemes to reduce transport poverty via social leasing of electric vehicles should consider impacts of vehicle production, end-of-life management etc. 3) Do no social harm- measures and investments must not increase existing social inequalities or vulnerabilities. 4) Accessibility SCF-funded measures must be targeted and accessible to most vulnerable households; i.e. have minimal upfront costs that are a barrier to lowest income groups. 5) Consistency and coordination- Guidance should emphasize the importance of coordinated and socially-sensitive approach to policy development, link to e.g NECPs and LTS. Sector-specific DNSH guidance should include: 6) Assessment of impact of ETS2 on firewood use for heating homes. Previous energy price rises have led to (i)increases in illegal logging in RO, HU and BG threatening the fulfilment of 2030 LULUCF targets and further harming forests & (ii) increases in the price of firewood, which impact the lowest income households most. SCF Guidance should require relevant measures to support those households and communities already most dependent on firewood and safeguards to minimize illegal logging. 7) Clear targeting criteria to ensure that funds support lowest income category households, often living in least energy efficient housing. Specific renovation challenges in the rentals sector (landlord-tenant dilemma) should be recognized and safeguards put in place to avoid sharp rent increases or tenant displacement following renovation. 8) Transport measures should focus on low-carbon transport that avoids environmental damage through habitat fragmentation, and include public and intelligent transport. Any infrastructure projects must take into account biodiversity at the earliest possible stage of planning by first fully evaluating the environmental impact and cost of all options. Regarding future application of DNSH across all EU funds : 9) Application of DNSH across public funds is very relevant to ensure environmental and climate objectives are supported consistently especially in the context of the current climate and biodiversity crisis. Taxonomy Regulation criteria can apply to the SCF which is focused on sectors (buildings, transport) already covered. But some criteria are not science-based and/or have become inconsistent/obsolete and must be rapidly updated. EU must also exclude always environmentally harmful sectors, companies or economic activities from receiving any EU funds/incentives. Loopholes in DNSH approach in RRF and CP funds have allowed significant financing of fossil gas infrastructure in RRPs: loopholes must be eliminated in future DNSH application. 10) Voluntary DNSH guidance has had suboptimal results. It is necessary that the guidance becomes mandatory e.g. by Delegated Act of the MFF Regulation.
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Response to Better protecting sharks through sustainable fishing and trade

16 May 2024

The effectiveness of shark fin trade bans has been debated in academia as having a limited effect on shark mortalities as it is a frequent misconception that the trade in shark fins is the only threat to sharks. In fact, the global trade in shark meat exceeds the trade of fins in volume and value, where EU exports and imports account for around 22% of the total global trade (see attached). The top three bridging traders in the ray meat trade network are EU Member States (FR, ES, NL) and the top shark meat exporters are Portugal and Spain. Other products, such as oil and cartilage, as well as local consumption of shark and ray meat, not entering the international trade, further drive the demand and the overall mortality. WWF strongly opposes the practice of finning, and consequently fully supports the EUs Finning Regulation and fins-naturally attached policy. These regulations must be maintained and fully implemented. However, WWF notices that existing policies & measures are not sufficient to prevent the decrease in shark populations and urges the EU Commission to take swift and strong actions to strengthen shark conservation within EU waters and for the EU fleets worldwide. To sustainably manage and conserve shark and ray populations, WWF urges the EU to strengthen the implementation of policies focusing on transparency and traceability, delivery on existing fisheries control and data reporting schemes, and bycatch mitigation standards. Through improved, science-based fisheries management, including recovery plans for threatened species, the EU could renew its commitment to a Community Plan of Action for the Management and Conservation of Sharks. Additionally, the EU should further sustainable take in sharks and rays in regional fisheries bodies and quickly implement CITES regulations, which now include almost 90% of shark and ray species entering international trade. Further actions should be considered, particularly regarding unilateral trade measures. The recent revision of the EU Fisheries Control Regulation has strengthened the EUs catch certification scheme by requiring additional key data elements and introducing the mandatory use of IT CATCH (as of 2026). The latter will allow for automatic risk management and analysis. Imports or transhipment of shark and ray products should automatically be flagged as high-risk through this electronic system, particularly from countries known to have inadequate shark and ray management measures. These alerts would trigger additional checks and verifications for authorities in the importing Member State. WWF also supports the idea of a specific catch certificate for shark and ray products. WWF also supports a possible introduction of an EU-wide import ban for shark and ray products originating from countries with no FNA policy in place, by leveraging the EUs market power to incentivise regulatory improvements in exporting non-EU countries. This unilateral import ban should be promoted in other key market states in the global shark trade in an harmonised manner in order to increase incentives for exporting states to meet these requirements for market access. Until such regulation is enacted, WWF encourages the EU to make use of its Carding Scheme under the EU IUU Fishing Regulation to restrict imports from countries where IUU fishing activities targeting sharks and rays are known to occur, or where the legislative and enforcement framework is inadequate. A stand-alone ban in loose fin trade would not necessarily result in the intended reduction in shark mortality. Instead, it could divert the trade to less regulated markets outside the EU. A ban would also not address fisheries mortality, especially bycatch of threatened and protected species, and would not work without a wider fisheries management plan. More details on our recommendations for the improvement of EU shark and ray fisheries and the trade of their products will be presented in the public consultation.
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WWF opposes manure limit exemptions to protect EU water quality

9 May 2024
Topic — The Commission is consulting on amending nitrogen spreading limits for specific manure-based fertilizers.
Message — WWF opposes exempting RENURE fertilizers from nitrogen limits to prevent increased pollution. They advocate for reducing livestock and extending spreading limits to all nitrogen fertilizers.12
Why — Maintaining strict limits protects the environmental progress for which the organization has long campaigned.3
Impact — Large agro-industrial firms lose the regulatory flexibility needed to expand their intensive farming operations.4
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Response to Taking stock of the Judicial Training Strategy 2021-2024

29 Apr 2024

WWF's mission is to stop the degradation of the planets natural environment and to build a future in which humans live in harmony with nature. A key focus is fighting environmental crimes, especially those related to wildlife. As such, WWF engages regularly with enforcement and judicial authorities, organizing training, bringing cases to court, or supporting the adoption of new legislation (e.g.https://stopwildlifecrime.eu/). In 2008, the Environmental Crime Directive was adopted by the European Union. Yet, more than ten years later, the European Commission came to the conclusion that it did not have much effect on the ground. Despite being the third most lucrative crime category globally, the largest financial driver of conflict and a major contributor to the ongoing ecological crises, environmental crimes are still considered as inflicting little harm to our society. In fact, most crimes remain undetected and unpunished. Training is critical to address knowledge and skill gaps among judicial authorities to improve the effectiveness of the enforcement chain in dealing with environmental crimes. As these crimes are regulated at the Union level, and are often of a cross-border nature, harmonizing training at the regional level, using comparable standards, is necessary. The Judicial Training Strategy for 2021-2024 mentions the need for training and specialized knowledge on EU environmental legislation. However, in effect few training offers have focused on environmental law, and they were infrequent and generic. Based on our exchanges with practitioners and on the evaluation of the Environmental Crime Directive, it is clear that the current training offer is still insufficient, while staff are also not always aware of existing training opportunities. In addition, despite environmental crimes being one of the EMPACT priorities since 2018, this level of prioritization does not seem to be reflected in the judicial training strategy. The European Commission needs to put the environment at the forefront of its next Judicial Training Strategy. The judicial sector has a key role to play when it comes to supporting the EU environmental acquis, by ensuring that violations of EU law are addressed and appropriately sanctioned. In 2024, the revised Environmental Crime Directive will be officially adopted. The Strategy can prove an important ally in making sure it does not fall into the same pitfalls as the previous one by supporting the Directives provisions with regards to training and specialization of competent authorities in all Member States. Although training is needed for all judicial professionals, opportunities for judges seem less readily available, and this could be corrected in the future strategy. Besides, our experience shows that using real-life cases and judgements during training is highly valued by practitioners as it enables them to navigate through intricate scenarios that are more relevant to their day-to-day practice of the law. Developing dedicated train-the-trainer modules, mentorship programs, and online training accessible 24/7 from any location would also help build lasting capacity at the national level. In addition, offering joint training with other competent authorities (e.g. police, environmental inspectorate, etc.) could be carried out in the context of EMPACT to improve the cooperation and coordination along the enforcement chain. Relevant civil society organizations, academia and international organizations (e.g. UNODC) could also be helpful partners to develop dedicated training for judicial authorities given their expertise in that area. Finally, it is important to break silos by making sure that judicial professionals are trained on the linkages between environmental crimes and other crimes (e.g. corruption, organized crime, money laundering, cybercrime, etc.), as well as other areas of the Strategy (e.g. digitalization, asset recovery and confiscation, etc.).
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Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

23 Apr 2024 · Nature Restoration Law

Meeting with Maroš Šefčovič (Executive Vice-President)

21 Apr 2024 · Global Plastics Treaty negotiations

Meeting with Jessica Polfjärd (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and European Environmental Bureau

16 Apr 2024 · Fit for 55

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and Stichting BirdLife Europe

11 Apr 2024 · Implementation of the biodiversity pillar of the European Green Deal

Meeting with Helena Braun (Cabinet of Vice-President Maroš Šefčovič) and Stichting BirdLife Europe

11 Apr 2024 · Implementation of the biodiversity pillar of the European Green Deal

Meeting with Aurore Lalucq (Member of the European Parliament) and Climate Action Network Europe

20 Mar 2024 · Priorités du prochain mandat

Meeting with Kurt Vandenberghe (Director-General Climate Action) and Transport and Environment (European Federation for Transport and Environment) and

11 Mar 2024 · Discuss how to best advance the European Green Deal and ensure effective EU climate action

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

7 Mar 2024 · Sustainable Finance Framework

WWF Demands Nature-Centric Criteria for Renewable Energy Auctions

1 Mar 2024
Topic — EU guidance on designing qualitative non-price criteria for renewable energy auctions.
Message — WWF calls for excluding hydropower and biomass while prioritizing wind and solar energy. They advocate for mandatory non-price criteria focusing on biodiversity, circularity, and social equity. Additionally, they request robust monitoring systems to track long-term environmental impacts.123
Why — This would ensure that the rollout of renewables does not further degrade biodiversity.45
Impact — Companies developing hydropower or biomass projects would be barred from participation in auctions.6
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Response to Guidance to Member States and market actors to unlock private investments in energy efficiency (EED recast)

26 Feb 2024

WWF welcomes the opportunity to contribute to the EU Commission's call for evidence on the Guidance document for Member States and market actors to unlock private investment in energy efficiency, and issues the following recommendations in the document attached: 1. Ensure that financial instruments designed to finance energy efficiency improvements are tailored to the specific needs and characteristics of the different consumer segments. 2. Ensure that available financial tools aimed at incentivizing energy efficiency improvements are effectively used. 3. Develop innovative financial tools to address investment gaps in financing the renovation of the EU building stock. 4. Put the right enabling conditions in place
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Response to Guidance to facilitate the designation of renewables acceleration areas

23 Feb 2024

WWF is welcoming the publication of this Call for evidence on an important and timely topic. We very much welcome that this Call only focuses on wind and solar, as we strongly advocate for the exclusion of new hydropower facilities and biomass in Renewables Acceleration Areas (RAAs). The EU needs to massively deploy wind and solar energy to achieve our energy transition and move away from fossil fuels. To achieve our energy transition, EU Member States have to speed up permitting processes through better spatial planning and greater administrative capacity in permitting authorities, not by watering down environmental legislation and restricting public participation. Below is the table of content of the key points that need to be addressed by the Commission in its guidance on the designation of RAAs. Attached is the full document developing our points in addition to national examples of good practices and recommendations. 1.Member States should receive explicit and clear guidelines on the selection of RAAs a) Define the criteria of significant environmental impact and effective mitigation measures as part of the designation of RAAs - Article 15c §1(a) - Significant environmental impact - Article 15c §1(b): Effective mitigation measures b) Identification of sites c) Co-location d) Exclusion areas 2. Holistic spatial planning and mapping is key in designating RAAs National examples of methods and tools to identify sensitive areas and planning system 3. Design RAAs with and for people a) Engaging with citizens from the very beginning b) Administrative burden c) Skilled workforce 4. Implementation and monitoring will be crucial 5. Focus on wind and solar
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Meeting with Virginijus Sinkevičius (Commissioner) and

19 Feb 2024 · NGOs presented to the Commissioner their Manifesto: An Ocean of Change 2024, and in particular the idea of an Ocean Deal

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen) and Transport and Environment (European Federation for Transport and Environment) and

16 Feb 2024 · European Green Deal

Meeting with Thomas Waitz (Member of the European Parliament) and European Environmental Bureau

15 Feb 2024 · European Green Deal

Meeting with Maroš Šefčovič (Executive Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

30 Jan 2024 · Green Deal, 2040 climate target, strategic dialogue on the future of agriculture in the EU

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur)

30 Jan 2024 · Retail investment Strategy

Meeting with Anja Haga (Member of the European Parliament)

30 Jan 2024 · Nature Restoration Law

Meeting with Delara Burkhardt (Member of the European Parliament) and Stichting BirdLife Europe

23 Jan 2024 · future of EU Green Deal

Response to Managing EU climate risks

11 Jan 2024

Europe needs to accelerate cuts in emissions in order to stay within the limits set by the Paris Agreement. Warming up faster than other parts of the world, and being affected by more frequent and intense climate-related disasters, Europe also needs to strengthen its resilience to climate change impacts . Drought, floods and wildfires are largely rooted in the mismanagement of natural resources, but are aggravated by global warming. They threaten vital resources and activities, such as water supply, food systems, energy production. As an example, the floods in Greece in September 2023 affected over ¼ of the countrys agricultural production, and it is estimated that the land will need 5 years to become fertile again. Climate change strongly impacts our natural ecosystems and the services they provide. It impacts water availability and quality. It impacts the distribution of forest types and their tree species, and increases tree mortality through the rising frequency of pest outbreaks and the intensification of droughts, forest fires and wind-throw. It also impacts the ocean, causing sea level rise, marine heatwaves, hurricanes, which are putting marine ecosystems and human lives at a rising risk. All those impacts alter natures ability to contribute to societal resilience. Healthy freshwater ecosystems such as floodplains connected to rivers, or wetlands, naturally absorb, filter and store water which is so deeply needed in times of heat stress or drought, and provide natural buffers against floods, while drained wetlands are a major source of emissions. Healthy and diverse forests support the water cycle, absorb and store carbon and are less prone to wildfires and pest outbreaks. Healthy deltas, coastal vegetation and estuaries contribute to building robust, diverse coastlines which protect against sea level rise, salt water intrusion or storm surges. We call for a new EU Climate and Water Resilience Law, with strong ambition on freshwater, to set legal requirements for nature-based solutions and ecosystem-based adaptation. The new Law would create natural Water Reserves to protect critical water supplies and their catchments in water-stressed areas, provide adequate finance for protecting and restoring natural sponge landscapes such as wetlands, and contribute to setting sectoral water efficiency and abstraction reduction targets for all water users at basin level. We believe the new Law can help avoid maladaptation practices such as building new dams and dikes, building water reservoirs or implementing large-scale water transfers which only increases our vulnerability to climate change impacts in the long term. In addition, we call for the full enforcement of the Water Framework Directive and its systemic approach, and putting an end to subsidies that harm the resilience of our societies and ecosystems, such as the Common Agricultural Policys direct payments, which should be redirected to more sustainable practices, such as agroecology, agroforestry and Closer-to-Nature Forest management. Although the EU Climate Law obliges Member States to develop adaptation strategies and plans, it is not prescriptive enough, and the EU Adaptation Strategy is not legally binding. We urge the EU to adopt and implement a new climate adaptation framework which guides, coordinates and drives Member States action better than the EU Adaptation Strategy does, and prioritises nature-based solutions. An improved framework should also better guide Member States to strengthen the social measures required to ensure that most vulnerable communities and households are supported towards resilience and to ensure consistency between the various relevant EU policies. An independent, scientific Adaptation Panel, preferably created under the existing European Scientific Advisory Board on Climate Change, should be set up to screen all EU measures and legislative proposals and ensure the integration of climate change adaptation into all sector
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WWF demands product-based benchmarks to end industrial pollution subsidies

2 Jan 2024
Topic — The European Commission is updating rules for distributing free emission allowances under the ETS.
Message — WWF requests a shift from process-based to product-based benchmarks to treat all producers equally. They recommend merging various production stage benchmarks into single, final-product categories for steel and cement.123
Why — These stricter rules would accelerate industrial decarbonization and ensure higher climate ambition.4
Impact — High-polluting manufacturers would lose the financial benefit of free permits for inefficient processes.5
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Response to Postponement of deadlines within the Accounting Directive for the adoption of certain ESRS

18 Dec 2023

The European Commission has proposed to delay from 2024 to 2026 the adoption of sector-specific standards (ESRS Set 2) in the Corporate Sustainability Reporting Directive (CSRD) for companies sustainability reporting. I. The Commissions delaying proposal is counterproductive : it will increase not decrease the corporate sustainability reporting burden 1. Sector-specific standards represent guidance that will help companies to report along the ESRS Set 1: Sector-specific standards will facilitate the implementation of the ESRS Set 1. Delaying them would increase not decrease the reporting burden. Indeed, it was left to sector-specific standards to clarify what exactly and in what detail should be disclosed on material sustainability issues. Our experience is that when companies are required to report they want more not less guidance, in particular at sector level, to help decide what to focus on. By comparison, the UK Transition Task Force (TPT) published its final disclosure framework in October 2023; and in November, it already published seven pieces of Sector Deep Dive guidance for consultation: Oil & Gas, Electric Utilities, Food & Beverage, Metals & Mining, Asset Managers, Asset Owners, Banks (https://transitiontaskforce.net/sector-guidance/). 2. A delay does not bring any guaranty of better outcomes: Delaying the sector-specific standards does not guarantee minimized nor optimized reporting requirements. Merely extending the timeline won't automatically result in reduced reporting requirements. To ensure a highly qualitative ESRS, EFRAG needs to prioritize the development of sector-specific standards and allocate appropriate resources for it. 3. The EFRAG can deliver: In 2023, the EFRAG has made significant progress on 5 high-impact sector standards: oil and gas, mining, road transport, textiles, and agriculture, farming, fishing sectors. This makes their publication by 2024 possible. There is no credible justification for further delaying these almost ready standards. 4. Impeding adequate sustainability report and decision making from the financial sector: The financial sector relies on sustainability data for well-informed decision-making, risk assessment, and meeting its own reporting requirements. The proposed delay jeopardizes the timely availability of critical sustainability data, impeding comparability between peer companies, hence hindering investors and banks from properly integrating sustainability in their finance decisions, impeding them in turn to reallocate capital to reach the EU 2030 sustainability objectives. 5. Giving a hard time to auditors: The replacement of the mandatory core of sector-agnostic indicators with a materiality assessment regime requires the audit industry to assure a process and outcome without clear guidance from sector specific standards on typical material issues, which is extremely challenging. This will make it challenging for the audit industry. II. Three recommendations to reach the Commissions intended goal The EU should not postpone the adoption of sector-specific standards but sequence them in a phased-in approach: 1. By end of 2024 / early 2025 the EU Commission needs to adopt the five high impact sector standards that are already being prepared by the EFRAG: oil and gas, mining, road transport, textiles, and agriculture, farming, fishing sectors. This is feasible given the technical work already done by the EFRAG. 2. The Commission must provide a clear mandate for the EFRAG to prioritise the development of the other sector-specific standards on sustainability. They must be developed as soon as possible, starting in 2024. 3. By 2026, all the twenty high-impact sectors prioritised by the EFRAG should be adopted. The EFRAG can deliver these standards if it prioritises them. There is an urgent market need.
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Meeting with François-Xavier Bellamy (Member of the European Parliament)

6 Dec 2023 · Enjeux stratégiques de la pêche - sécurité, souveraineté et puissance économique

Meeting with Catherine Chabaud (Member of the European Parliament)

4 Dec 2023 · Plan d'action pour la protection et la restauration des écosystèmes marins en faveur d'une pêche durable et résiliente

WWF warns against weakening EU environmental reporting standards

30 Nov 2023
Topic — The European Commission aims to reduce legislative reporting requirements by 25%.
Message — WWF opposes reporting cuts and urges no delays for sector-specific standards. They suggest limiting streamlining to duplicates to maintain necessary climate transparency.123
Why — Strong reporting helps track progress toward 2030 and 2050 environmental targets.45
Impact — Investors and authorities lose the detailed data required to monitor climate transition progress.67
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Meeting with Marie Toussaint (Member of the European Parliament)

15 Nov 2023 · policy on water and biodiversity

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

15 Nov 2023 · to follow

Meeting with Isabel Carvalhais (Member of the European Parliament)

14 Nov 2023 · EU Action Plan for protecting and restoring marine ecosystems and ensuring sustainable and resilient fisheries

Meeting with Stéphane Séjourné (Member of the European Parliament) and Climate Action Network Europe and Reclaim Finance

7 Nov 2023 · Prospective européenne

Meeting with Maroš Šefčovič (Executive Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

7 Nov 2023 · Transition towards sustainable food systems

Meeting with César Luena (Member of the European Parliament, Rapporteur)

26 Oct 2023 · Nature Restoration Law

Meeting with Tiemo Wölken (Member of the European Parliament, Rapporteur) and European Environmental Bureau and Climate Action Network Europe

4 Oct 2023 · Net-Zero Industry Act (staff level)

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and ClientEarth AISBL and

4 Oct 2023 · Environmental and climate due diligence

Meeting with Caroline Roose (Member of the European Parliament, Shadow rapporteur) and European Anglers Alliance

2 Oct 2023 · Plan d'Action ressources halieutiques et écosystèmes marins

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen) and Third Generation Environmentalism Ltd and

28 Sept 2023 · Concerns on corporate sustainability reporting in view of the upcoming package on 25% reduction of reporting burden. They conveyed the message that sustainable finance should continue ensuring transparency for the green transition.

Response to Mid-term evaluation of the LIFE programme 2021-2027

15 Sept 2023

General objective: We strongly recommend to reinforce the use of the Nature-based Solutions (NbS) across the LIFE programme to guarantee high-quality interventions both for nature and people. While the specific priorities of the LIFE Nature and Biodiversity sub-programme includes NbS and ecosystem approaches, this approach is missing in the general objective and the specific objectives of the other sub-programmes. The implementation of NbS across all landscapes is key in achieving the objectives of major EU policy priorities, in particular the EU Biodiversity Strategy for 2030 and the EU Adaptation Strategy as a way to foster biodiversity and make Europe more climate-resilient. The implementation of NbS should therefore be mainstreamed throughout the programme as it presents a credible means to address key societal issues, such as biodiversity loss, climate change, and disaster risk reduction. Objectives of the sub-programme « Nature and Biodiversity »: Through the EU Biodiversity Strategy 2030 and the Kunming-Montreal Global Biodiversity Framework, the EU is committed to nature protection and the restoration of degraded ecosystems. The objectives of the sub-programme Nature and Biodiversity are fully aligned with this commitment. However, there is an imbalance between the high demands in the Nature & Biodiversity call focus and the lack of biodiversity protection mainstreaming in other sub-programmes, such as the Circular Economy and Quality programme. Biodiversity decline is a global issue whose urgency should be reflected in all parts of the programme. The specific objective aiming at enhancing the capacities of public and private actors and the involvement of civil society remains particularly relevant. The programme should include a dedicated support to increase capacity of CSOs to meaningfully contribute to national, regional, and global environmental policy development, ensure the public has access to transparent and credible information on climate issues or environmental degradation or that CSOs are better able to coordinate and cooperate in their local, national, and regional-level advocacy for preserving natural resources and tackling climate change. As stated in the specific priorities of the sub-programme, catalysing the large-scale deployment of successful solutions, improving access to finance and mobilising investment are key elements to address the biodiversity crisis. The preparation for delivering comprehensive large-scale solutions often requires lengthy and costly pre-feasibility/feasibility research, as well as extensive stakeholder engagement, yet little funding is dedicated to this important stage necessary for large-scale restoration projects. While the LIFE program recognises the importance of initial preparations, project costs devoted to this stage are limited. Devoted funding should finance the costs of the preliminary works, such as stakeholder mapping or baseline studies, to prepare the ground for projects delivering restoration at scale. Programmes modalities: Accessibility of the LIFE programme remains restricted for many CSOs due to the high co-financing requirement. In the light of the urgency of biodiversity decline and the pressing need for adaptation and mitigation measures, access issues to the programme should be reduced as much as possible, including reduced co-financing demands from CSOs. Despite the participation of Ukraine in the LIFE programme, it is particularly challenging for Ukrainian CSOs to access it under the same conditions as organisations based in the EU. Funding should be dedicated to enhance the capacity of Ukrainian CSOs to access the LIFE programme and the co-financing requirements should be waived, given the limited ability of Ukrainian CSOs to ensure stable financial sources.
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Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur) and Association for Financial Markets in Europe

15 Sept 2023 · Retail investment strategy

Meeting with Catherine Chabaud (Member of the European Parliament, Rapporteur for opinion)

12 Sept 2023 · Plan d'action pour la protection et la restauration des écosystèmes marins en faveur d'une pêche durable et résiliente

Meeting with Tiemo Wölken (Member of the European Parliament, Rapporteur) and European Environmental Bureau and Climate Action Network Europe

6 Sept 2023 · Net-Zero Industry Act (staff level)

WWF demands stricter transparency for industrial climate neutrality plans

1 Sept 2023
Topic — The consultation defines minimum content and format requirements for industrial climate neutrality plans.
Message — WWF insists climate neutrality plans be designed at installation level using a mandatory template. They want targets expressed in absolute terms and plans made public for external scrutiny.123
Why — This provides the organization with comparable data to monitor the actual decarbonization of individual factories.4
Impact — Inefficient industrial installations lose the ability to obscure their climate performance through vague reporting.5
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WWF Demands Carbon Capture Only for Hard-to-Abate Industrial Emissions

31 Aug 2023
Topic — Consultation assessing the role of carbon capture in decarbonising the EU economy.
Message — WWF seeks to limit carbon capture to unavoidable industrial sectors. They oppose using public money for projects that extend fossil fuel usage.12
Why — This approach prevents carbon capture from slowing the transition to renewable energy.3
Impact — Industrial polluters would lose billions in subsidies and free emission permits.4
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Meeting with Matthias Ecke (Member of the European Parliament, Shadow rapporteur for opinion) and European Environmental Bureau and Climate Action Network Europe

29 Aug 2023 · Net Zero Industry Act

Response to Review report on the Governance Regulation of the Energy Union and Climate Action

3 Aug 2023

WWF European Policy Office (EPO) welcomes the opportunity to contribute to the call for evidence on the review report on the Governance Regulation as announced by Article 45 of that regulation. Indeed, the 2018 Governance Regulation was not designed to support the full and irreversible economic decarbonisation of EU Member States by 2050 that has been adopted through the Green Deal, and is thus outdated. Additionally, since the adoption of the Governance Regulation, the EUs political, socio-economic and security context has drastically evolved: - the EU27 collectively committed to climate neutrality; - the 2030 target has been increased, and the Fit for 55 package has been adopted; - the European Green Deal came with a flurry of new energy strategies; - the EU is still trying to recover from the health and economic crisis (Next Generation EU); - the current geopolitical tensions deteriorated the energy security of supply of the EU and worsened the economic crisis (REPowerEU Plan); - the first and second iterations of National Energy and Climate Plans (NECPs) and national Long-Term Strategies (nLTSs) have shown many limits and issues that need to be addressed to deliver the climate and energy transition the EU needs to keep temperature increase to 1.5 °C. Substantial amendments to the Governance Regulation are essential if the EU is will to do its fair share under the Paris Agreement, meaning reducing greenhouse gas (GHG) emissions by at least 65 % gross by 2030 and achieving net-zero emissions by 2040 at the latest. Moreover, even to meet its current, inadequately ambitious climate targets, the EU needs to extensively reform this instrument. Key demands: - National framework climate laws play a vital role in ensuring effective climate governance. They transmit a clear signal to all sector of the economy about the imperative need to transition toward full decarbonisation, establish a stronger commitment to upholding the promises made, and maintain political will for the transition. Thus, the Governance Regulation should be amended to provide that Member States set an economy-wide national climate neutrality date. The Commission must assess whether the national climate-neutrality targets as well as nLTS are sufficient to collectively achieve the Union climate and energy targets. - National LTS should be the centrepiece of the climate governance framework since they provide an essential reference for political decision-making and point in the direction policies need to aim for. However, the iterative process regarding nLTSs is much lighter than NECPs, and 4 Member States did not submit their nLTSs yet. The Governance Regulation should be amended to align the elaboration process of nLTSs with the NECPs (detailed and binding template, country-specific recommendations, binding 5-year review). - The EU must develop a harmonised set of indicators to effectively measures progress towards climate neutrality. Thus, the Governance Regulation should set up an official monitoring system designed to inform policy-making, based on a comprehensive set of indicators, which looks at the structural changes under the emissions curve and their enabling conditions. - The Commission should evaluate the relevance of Energy Unions five dimensions within the current climate and energy landscape in the EU, and adapt the NECP drafting process/template in accordance with this assessment. It should also revise the minimum requirements of the Governance Regulation on NECPs climate and energy target to make sure they are fit for 1.5°C (65% reduction of GHG emissions by 2030 and net-zero emissions by 2040). - The Governance Regulation should increase consistency between NECPs, nLTSs, the EU LTS, and the EU-wide climate neutrality objective. - The Governance regulation should strengthen and concretise requirements for public participation, including in the formulation and evaluation of NECPs and nLTSs.
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and

18 Jul 2023 · European Reporting Sustainability Standards

WWF urges EU to reject climate-only sustainability reporting rules

7 Jul 2023
Topic — The European Commission is establishing standards for corporate sustainability and environmental reporting.
Message — WWF urges the Commission to eliminate voluntary reporting loopholes for nature protection plans. They also recommend reintroducing mandatory social metrics and removing delays for smaller firms.123
Why — Stricter rules would help banks and investors accurately measure the environmental risks of companies.4
Impact — Mid-sized companies would lose the ability to delay reporting on their environmental impacts.5
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Meeting with Pierre Karleskind (Member of the European Parliament, Committee chair)

29 Jun 2023 · pêche

WWF urges EU to exclude nuclear from clean tech act

27 Jun 2023
Topic — New EU legislation to accelerate the manufacturing of net-zero energy technologies.
Message — WWF demands the act focuses on renewables like solar and wind while excluding nuclear power. They request removing the overriding public interest clause to protect existing nature laws.123
Why — This would ensure public funding is concentrated on renewable deployment rather than nuclear.4
Impact — The nuclear industry loses financial support and its status as a strategic technology.5
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Meeting with Pascal Canfin (Member of the European Parliament) and European Environmental Bureau and

31 May 2023 · Green Deal

Meeting with Renaud Savignat (Cabinet of Commissioner Jutta Urpilainen) and CONCORD Europe and

25 May 2023 · MMF review process

Meeting with Christophe Grudler (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE

25 May 2023 · NZIA

Meeting with Tom Vandenkendelaere (Member of the European Parliament) and European Landowners' Organization asbl and Familienbetriebe Land und Forst Bayern e.V.

23 May 2023 · Nature restoration law

Meeting with Virginijus Sinkevičius (Commissioner) and

15 May 2023 · To discuss the Marine Action Plan

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

4 May 2023 · Retail Investment Strategy

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

4 May 2023 · Retail Investment Strategy and sustainability requirements

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness)

4 May 2023 · Retail Investment Strategy

Response to Initiative on EU taxonomy - environmental objective

3 May 2023

WWF EPO generally welcomes: The fact that the six objectives of the EU taxonomy are covered, not only climate change. The fact that the draft DA adequately reflects the Platforms technical recommendations or, in a few cases, improves it, leading to a green score for several activities in our assessment. We have major concerns with the four following issues: 1. We provided a red score (see attachment) for the following activities whose criteria are not science-based: Inland passenger/freight water transport; Aviation activities; Manufacture of plastic packaging goods (circular economy objective); Conservation, including restoration, of habitats, ecosystems and species. 2. The introduction of biodiversity offsets in the activity Conservation, including restoration, of habitats, ecosystems and species (Biodiversity objective) is a major concern and should be removed. 3. Many critical activities have been left out from the draft DA compared to the Platforms proposal (see attachment for specific comments and analysis). 4. Maintain Appendix C with no weakening which is It is extremely important for the protection of human health and the environment from pollution (see attachment for details). Finally, we have concerns on the following generic issues: 5. A substantial contribution criterion should not be equivalent to a Do No Significant (DNSH) criterion for the same issue. Environmentally-wise it is not consistent that substantial contribution equals to DNSH. 6. Anything which just meets a "legal" standard (e.g. in ETS or RED) is highly unlikely to be sufficient for a substantial contribution criteria. 7. Wherever the DA waters down the numerical recommendations of the Platform, the Commissions justification needs to be clear; in most cases it is not. 8. Wherever an "industry pathway" is used as a technical reference, it should be noted that this is highly unlikely to require a "significant contribution" (almost by definition as an entire industry is committed to it 9. There is a need to cross-reference substantial contribution criteria in activities where "taxonomy shopping" is possible, to ensure a level playing field in terms of environmental benefits. 10. Wherever an activity may be associated with significant environmental impacts along its value chain (notably outside the EU), it cannot be defined as significantly contributing to any of the six taxonomy objectives without ensuring that these impacts are avoided through adequate DNSH criteria. 11. Small "technical loopholes" can create enormous environmental damage, as the risk of "reverse engineering" of the taxonomy to find loopholes is already on-going. For example, this is the case with shipping criteria.
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Meeting with Tiemo Wölken (Member of the European Parliament)

24 Apr 2023 · EU-Lieferkettengesetz (staff level)

Meeting with Damien Carême (Member of the European Parliament, Shadow rapporteur)

19 Apr 2023 · Echanges de vues sur NZIA (Staff level)

Meeting with Silvia Modig (Member of the European Parliament, Rapporteur for opinion) and European Environmental Bureau and

19 Apr 2023 · Net Zero Industry Act (staff level)

Meeting with Pascal Canfin (Member of the European Parliament) and Bureau Européen des Unions de Consommateurs and

3 Apr 2023 · Green finance

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and Stichting BirdLife Europe and Compassion in World Farming Brussels

3 Apr 2023 · Taxonomy and agriculture

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Anthony Agotha (Cabinet of Executive Vice-President Frans Timmermans) and

29 Mar 2023 · EU-Norway energy cooperation

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

7 Mar 2023 · Sustainable food systems

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides) and European Environmental Bureau

7 Mar 2023 · Sustainable Food Systems

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur)

30 Jan 2023 · Environmental Crime

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

27 Jan 2023 · Packaged retail investment and insurance products (PRIIPs)

Meeting with Michal Wiezik (Member of the European Parliament)

12 Jan 2023 · Nature Restoration Law

Meeting with Marie Toussaint (Member of the European Parliament)

6 Jan 2023 · Due diligence

Meeting with Anne Sander (Member of the European Parliament, Rapporteur for opinion)

5 Jan 2023 · Nature Restoration Law

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and Stichting BirdLife Europe

19 Dec 2022 · The Habitats Directive and the protection status of the wolf in Europe

WWF: EU carbon removal plan risks enabling corporate greenwashing

16 Dec 2022
Topic — The European Commission is proposing a framework to certify sustainable carbon removals.
Message — WWF demands the proposal exclude carbon removal certificates from existing trading systems. They want tailored methodologies for removal activities and clear liability rules.123
Why — Strengthening these rules ensures that carbon removals support biodiversity and genuine climate goals.4
Impact — Large industrial polluters would be prevented from using reversible carbon removals to offset emissions.5
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

13 Dec 2022 · EU Regulatory consistency on Transition Plans

Response to Fitness check of how the Polluter Pays Principle is applied to the environment

9 Dec 2022

WWF welcomes the EUs initiative to consider how well the EU applies the Polluter Pays Principle (PPP), including by looking at the application of the principle at Member State level. The PPP is a cornerstone of EU environmental policy. To support the call for evidence, we focus in this reply on a number of policies where WWF is familiar with the application of the principle. We provide links to relevant publications and studies that can help the European Commission assess how well the PPP is applied (see in the attached pdf). This concerns in particular: - EU Emissions Trading System - Just Transition process - Common Agricultural Policy and the EU promotion of Agri-Food Products - Water Framework Directive - Fuel subsidies in the fisheries sector, via the Energy Taxation Directive In all of the above areas, WWF regrets to conclude that the PPP continues not to be applied or poorly applied, resulting into taxpayers paying to both directly and indirectly for the costs of pollution. It also results into unfair distribution across Member States of the costs resulting from pollution. WWF calls on the European Commission and Member States to better reflect the PPP in EU and national policies, in order to support the full achievement of the 8th Environment Action Programme, the European Green Deal, and their associated Union policies.
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Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur) and Growing Media Europe

6 Dec 2022 · Nature Restoration Law

Meeting with Sirpa Pietikäinen (Member of the European Parliament) and European Environmental Bureau and Stichting BirdLife Europe

10 Nov 2022 · Nature Restoration Law (NRL

Meeting with Arunas Ribokas (Cabinet of Commissioner Virginijus Sinkevičius) and Stichting BirdLife Europe and

10 Nov 2022 · the EU forest policy, including on biomass

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

7 Nov 2022 · EU green bond standard

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

29 Sept 2022 · Implementation of the EU biodiversity Strategy for 2030 and the Nature Restoration Law

Meeting with Damien Carême (Member of the European Parliament, Shadow rapporteur for opinion)

20 Sept 2022 · Devoir de vigilance des entreprises en matière de durabilité

Meeting with Virginijus Sinkevičius (Commissioner) and

19 Sept 2022 · To discuss the pollution incident that is currently ongoing along the Oder River

Meeting with Anna Deparnay-Grunenberg (Member of the European Parliament) and European Environmental Bureau and

8 Sept 2022 · exchange on RED II

Meeting with Caroline Roose (Member of the European Parliament, Rapporteur for opinion) and European Environmental Bureau and

1 Sept 2022 · Environmental Crime Directive (Protection of the environment through criminal law )

Meeting with Sara Cerdas (Member of the European Parliament) and ClientEarth AISBL and Stichting BirdLife Europe

1 Sept 2022 · Restauração da Natureza

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides)

25 Aug 2022 · VTC Meeting - Sustainable Food Systems and EAT4Change project.

Response to Implementing regulation on the Member States’ reporting of information foreseen in the Governance of the Energy Union

5 Aug 2022

NECPs are a cornerstone of EU climate governance architecture and their implementation is integral to achieving national and EU climate and energy targets, not least those in the Effort Sharing Regulation. Member States’ integrated national energy and climate progress reports must fully account for progress (or lack thereof) relative to all information provided in their NECP. It is particularly welcome that the reports will aggregate national data on remaining GHG emissions (economy-wide, in ESR, LULUCF sectors, etc.) as well as policies to phase out fossil fuels and their subsidies. However, the current draft implementing regulation defining the binding template for these reports contains several flaws which will likely affect the transparency and quality of reporting. We urge the Commission and Member States to adopt the following changes: 1. All information required should be ‘mandatory’ or ‘mandatory if available’ and the reason information is unavailable should be duly justified in writing by the Member State. It is unacceptable and is inconsistent with the European Green Deal that reporting on just transition aspects of NECPs is fully voluntary (Annex XX). 2. In Annex XX (just transition), the mandatory information to be provided should be expanded and designed to ensure Member States outline the potential benefits of the transition to climate neutrality (e.g. on reducing inequalities), instead of only focusing on negative impacts. While information should be provided on which sectors will grow and shrink, Member States should also provide information on the quality of new jobs and measures to ensure they provide similar quality, in line, for example, with the European Trade Union Confederation Resolution “Defining Quality Work: An ETUC action plan for more and better jobs” (2017). Furthermore, quality of life indicators should recognise the inherent value of nature and that only a transition aligned with limiting global average temperature rise to below 1.5°C, and which protects biodiversity, can be just. 3. Annex XXIII (multilevel dialogues) must be substantially improved: It must include reporting on how public consultations on draft and final NECPs and national long-term strategies (under art. 10 of the Governance Regulation) were conducted. It must also require much more information than simply “details” and potentially “progress” in establishing the dialogues – such as (i) steps taken to facilitate the dialogue, its duration and participants; (ii) topics discussed; (iii) a summary of the discussion and of the recommendations proposed; (iv) the steps planned in response. The elaboration process for NECPs and national long-term strategies was uneven, with some Member States submitting documents with incomplete information, after the timeline, or in the case of 5 national long-term strategies, not submitting them at all. We call on the Commission to be particularly vigilant and to use all its prerogatives under the Governance Regulation and the EU Treaties to enforce legally binding obligations giving effect to EU Law.
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Response to Protecting biodiversity: nature restoration targets

4 Aug 2022

WWF European Policy Office supports the legal proposal for a Nature Restoration Law as it is a huge opportunity to bring nature back to Europe, benefiting biodiversity, climate, and people alike. It is an important milestone to reverse the tide of both biodiversity loss and climate change, with the potential to make a real impact at the scales required if implemented in a timely and well considered manner. We therefore call on the European Parliament and the Council of the EU to adopt the proposed nature restoration Regulation without delay and to strengthen it where needed. The main points that require strengthening are the following: - Strengthening the governance to ensure that Member States can be held accountable for their contribution to the EU-wide overarching objective - Increase the ambition level of the area-based restoration targets in Art.4 and Art.5 (restoration of natural habitats) both at the level of timing (by when the restoration measures need to be implemented) and at the level of area to be restored. This is needed to make the ambition level of the proposal in line with the urgency of tackling both the biodiversity and climate crises. - The marine restoration targets are at risk of being unimplementable and empty in practice, because their restoration measures are dependent on the ineffective procedures of the Common Fisheries Policy for managing destructive fishing impacts. A safeguard mechanism should be added to ensure that Member States’ failure to reach an agreement for a joint recommendation does not undermine the implementation of effective restoration targets. Such a mechanism could, among others, set a time limit to the joint recommendations process and/or empower the Commission to break the Member States’ deadlock, if no timely agreement has been reached. - The nature restoration law needs to set quantified and time-bound targets to remove barriers. Member States should be required to restore 15% of river length ((178,000 km across the EU) into free-flowing rivers. The current text to address primarily obsolete barriers reduces the scope of the provision and should be deleted. Instead, the prioritisation of barriers should be made at national or river basin level via a case by case assessment, taking into consideration the specific purpose of the barrier and the ecological benefits of removal, as well as the need to ensure connectivity between marine and freshwater ecosystems. - Target 9(4) for the restoration of drained peatlands should be expanded to include other land uses beyond only agricultural use, such as forestry. There must be a clear obligation to restore all degraded peatlands regardless of current land use and clarification that all drained peatlands should be rewetted, as this is needed to effectively restore peatlands. In addition, the restoration targets for peatlands should be increased overall in relation to both timeframes and area. - For most of the indicator-based targets to restore agricultural and forest ecosystems (Art.9(2) and Art.10)) there are no quantified, time-bound objectives defined. Member States only need to achieve an increasing trend at national level and can define their own satisfactory level to be achieved. A clear framework and guidance on the minimum requirements for Member States to define these satisfactory levels is needed. - The legislative proposal should include an obligation for the Commission to assess existing EU funding support available for nature restoration and explore options to expand these, for example through the establishment of dedicated funding for nature restoration, pursuant to the mid-term review of the Multiannual Financial Framework. A more complete overview of our assessment of the legal proposal can be found in the attachment.
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Meeting with Virginijus Sinkevičius (Commissioner) and

19 Jul 2022 · To exchange views, upon NGO request, on the upcoming Action plan to conserve fisheries resources and protect marine ecosystems, on Commission implementing act on vulnerable marine ecosystems and on European eel status

Meeting with Ville Niinistö (Member of the European Parliament)

6 Jul 2022 · Deforestation

Meeting with Heidi Hautala (Member of the European Parliament, Rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and

5 Jul 2022 · Stakeholder meeting on corporate sustainability due diligence (staff level)

Meeting with Damien Carême (Member of the European Parliament, Shadow rapporteur for opinion) and EUROPEAN TRADE UNION CONFEDERATION and European Coalition for Corporate Justice

5 Jul 2022 · Devoir de vigilance des entreprises en matière de durabilité

Meeting with Anja Hazekamp (Member of the European Parliament)

28 Jun 2022 · photo action on deforestation

Meeting with Pascal Canfin (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

20 Jun 2022 · Fit for 55

Meeting with Sara Cerdas (Member of the European Parliament)

15 Jun 2022 · Prioridades na Proteção da Natureza

Meeting with Michael Bloss (Member of the European Parliament) and Carbon Market Watch

14 Jun 2022 · ETS

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur)

14 Jun 2022 · Due diligence

Meeting with Caroline Roose (Member of the European Parliament) and FUNDACION OCEANA and SURFRIDER FOUNDATION EUROPE

13 Jun 2022 · Conférence "There is no ocean B."

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur)

10 Jun 2022 · deforestation

Meeting with Pascal Canfin (Member of the European Parliament) and Climate Action Network Europe and Carbon Market Watch

7 Jun 2022 · Fit for 55

Meeting with Alfred Sant (Member of the European Parliament)

2 Jun 2022 · Taxonomy

Meeting with Ville Niinistö (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

2 Jun 2022 · LULUCF (staff level)

WWF Urges Full Ban on Inducements for Financial Advisors

30 May 2022
Topic — The consultation seeks to improve retail investor confidence and participation in EU capital markets.
Message — WWF calls for a ban on inducements and wants sustainable products to be the default choice. They also propose mandatory sustainability training for financial advisors.123
Why — This would channel significant retail capital into environmental projects while reducing the risk of greenwashing.45
Impact — Banks and non-independent advisors lose commission revenue and the ability to prioritize in-house products.67
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Nicolo Brignoli (Cabinet of Commissioner Mairead Mcguinness) and

25 May 2022 · Retail Investment Strategy

Meeting with Pascal Canfin (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and Climate Action Network Europe

13 May 2022 · Fit for 55

Meeting with Pierre Karleskind (Member of the European Parliament, Shadow rapporteur) and ClientEarth AISBL and FUNDACION OCEANA

10 May 2022 · Revision de la PCP

Meeting with Malte Gallée (Member of the European Parliament, Shadow rapporteur)

6 May 2022 · Revision of the Consumer Credit Directive (staff level)

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen) and Climate Action Network Europe and

5 May 2022 · Africa, climate and energy

Meeting with Michael Bloss (Member of the European Parliament) and Heinrich Böll Stiftung e.V. and Carbon Market Watch

20 Apr 2022 · ETS

Meeting with Pascal Canfin (Member of the European Parliament)

13 Apr 2022 · Green finance

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and Greenpeace European Unit and

4 Apr 2022 · deforestation

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

Please find attached the feedback from WWF EPO on the revision of the Energy Performance of Buildings Directive.
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Response to Sustainable corporate governance

30 Mar 2022

This directive is meant to hold businesses accountable for harming human rights and the environment, and in WWF’s view is critical for the success of the sustainable finance agenda and the European Green Deal. However, WWF is concerned that since it was initially announced, the proposal has lost its ambition. Notably, it will only apply to a tiny fraction of EU companies. What’s more, the directive’s name has been changed from Sustainable Corporate Governance to Sustainable Corporate Due Diligence, which reflects the fact that its focus has been reduced. We had great hopes when Commissioner Reynders committed to publishing a proposal on Sustainable Corporate Governance. It is urgent to move from corporate obligations to disclose, to corporate obligations to do: this would be a real game-changer. We deeply regret that the Commission surrendered on the issue of directors’ obligations to the pressure of conservative corporate lobbies and the Danish, Swedish and Finnish governments, among others. WWF is particularly alarmed that directors’ obligations are so vague. Now Member States, not directors, have to ensure that companies set up a plan to align their business model with the transition to a sustainable economy and the Paris Agreement 1.5°C goal. Unlike in earlier versions leaked to the media, there is no mandatory obligation to ensure that directors’ variable remuneration will be linked to the contribution of a director to the company’s sustainability. The directive will apply to companies above 500 employees and high-risk sector companies above 250 employees, leaving small and medium-sized enterprises (SMEs) out of the scope (especially in Article 15). SMEs represent 99.8% of the EU economy, and even those in high-risk sectors are not included despite their impact on the environment. In addition, the list of high-risk sectors is extremely narrow. For example power production, the sector with the largest emissions in the EU, is left aside. Surprisingly, this scope is very inconsistent with the one proposed by the Commission for the Corporate Sustainability Reporting Directive that includes listed SMEs. The Commission's proposal integrates a mandatory framework on environmental and human rights due diligence together with civil liability, which is essential because companies will need to assess and mitigate the sustainability risks and impacts identified across their value chain. However, WWF regrets that climate due diligence is not explicitly mentioned. Article 29, where the EC will submit a report 7 years after the entry into force to evaluate the effectiveness of adverse climate impacts. Referring to the most recent IPCC report, this is just unbelievable, EC seems to not understand the climate and environemtnal urgency we are facing. In addition, the proposal fails to require companies to set environmental science-based targets to align their business model with the relevant environmental goals and to provide the necessary detail to adopt a transition plan. It also fails to link the proposal with the CSRD's materiality determination exercise, before setting a plan and targets. Article 15 is definitely not legally sound, it is neither linked to the due diligence exercise, nor to the directors' duties, which is a big legal gap, especially regarding enforcement and liability. Article 15's requirements should be linked with the board's oversight in Article 26.
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Meeting with Sara Matthieu (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment)

23 Mar 2022 · Social Climate Fund

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur)

21 Mar 2022 · Environmental Crimes

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and Greenpeace European Unit and

18 Mar 2022 · deforestation

Meeting with Pascal Canfin (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

17 Mar 2022 · Fit for 55

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

16 Mar 2022

This letter is shared on behalf of the forum of mayors for a just transition after it was submitted to the Commission as part of a demand for greater support to coal regions/post-coal regions to implement a just transition. It is relevant to the soil health strategy, as outlined in response to the letter from Mr. Nicola De Michelis on the 10th of March 2022. WWF acts as the secretariat of the forum and supports the mayors. WWF Poland is not working directly on the soil health strategy and our response focuses on the specific issues around land contamination from mining activities, however, we acknowledge and support the responses also shared by other WWF offices to this consultation.
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Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and Greenpeace European Unit and

15 Mar 2022 · deforestation

Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius) and European Environmental Bureau and

4 Mar 2022 · EU Nature Restoration Law preparations

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and

4 Mar 2022 · EU Nature Restoration Law

Response to Improving environmental protection through criminal law

1 Mar 2022

WWF acknowledges that Directive 2008/99/EC on the protection of the environment through criminal law provided a harmonised framework to address environmental crimes in the European Union. Nonetheless, its implementation was limited, and environmental crimes remained largely under-detected, under-reported, and under-investigated, with sanction levels too low to be dissuasive. Hence, WWF welcomes the European Commission’s proposal for a Directive of the European Parliament and of the Council on the protection of the environment through criminal law and replacing Directive 2008/99/EC. This proposal represents an opportunity to provide the EU and Member States with the means to fulfil their commitments towards environmental protection. WWF is supportive of the proposal which contains a number of promising elements that need to be secured to ensure that the adopted Directive is strong and ambitious enough to effectively step up the fight against environmental crimes. In particular: * We welcome the broadening and updating of the scope of the Directive which reflects the evolution of the European legislation covering environmental crimes. * We support the specification of minimum thresholds for maximum sanctions, and the provisions relating to aggravating circumstances. * We also salute the holistic provisions relating to national strategies, reporting duties, training, investigative tools, allocation of resources, cooperation, and data collection. * We are also pleased to see that the proposal enshrines protection for environmental defenders. While acknowledging the progress made in the proposal, WWF would like to see improvements regarding: * The approach of designating offences under existing EU legislation means that the Directive will have to be amended every time new legislation is enacted, unless some reliable means can be found of cross-referencing the Directive whenever new legislation is adopted * The proposed list of elements to be taken into account when assessing “substantial damage” and “negligible quantity” should include the extent of the monetary gain associated with the offence, and evidence of organised criminal involvement. * We are concerned that attempted offences and offences committed with serious negligence are excluded in the case of sites and species protected under the Birds and Habitats Directives. * We believe that the import of a species listed on Annex C of Council Regulation (EC) No. 338/97 without the appropriate documentation (export permit or certificate of origin, depending on the country of export, and an import notification under the Regulation) should be included in the list of offences. * In the case of sanctions relating to offences committed by legal persons, the proposed minimum standard should be increased, so that maximum sanction of 15% of annual turnover is stipulated. * Aggravating circumstances should include cases of crime convergence (e.g. financial crimes, drug trafficking, etc.). Environmental crimes are often committed together with other criminal activities which should be reflected in the sanction levels and in the seriousness with which cases are prosecuted. * Provisions for the establishment of specialised coordination bodies in every Member State should be made. * Statistical data gathered at Member States’ level should be made public in full, rather than in summary form. * Jurisdiction should be extended as much as possible to increase environmental protection.
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Response to Alignment EU rules on capital requirements to international standards (prudential requirements and market discipline)

23 Feb 2022

WWF welcomes the European Commission proposal to complete implementation of the Basel III agreement in the European Union, a helpful step to ensure better financial stability after the financial crisis. The timetable proposed by the Commission means that the EU will add another two years to the Basel timeline and plans to fully apply the international agreement by 2030, which means 23 years will have passed since the onset of the financial crisis in 2007. We do hope that the European Union will be faster to address the impact that the climate crisis will have on financial stability, and this is our main concern with the current proposal. The proposal contains some helpful but optional provisions in the Pillar 2 and Pillar 3 assessment and disclosure of climate risk, including the explicit provision to give EBA the power to issue guidelines on the uniform inclusion of ESG risks in Article 98 (SREP). We also welcome the Pillar 2 provision that explicitly allows supervisors to use the EU-specific Systemic Risk Buffer (SyRB) to address "various kinds of systemic risks, including risks related to climate change". However, we are very disappointed that the Commission shies away from using the opportunity of opening up the EU's Capital Requirements legislation to address the impact of climate risk on financial stability across the industry. Dialogue and public disclosure is not enough -- Pillar 1 measures are needed to ensure the integration of climate risk in bank business models, given the role that they play in credit allocation. The Commission proposal to make EBA's forthcoming report on climate risk treatment in Pillar 1 more balanced and also look at the impact of harmful investments and other exposures, moving beyond the "green supporting factor", is welcome, but insufficient. While we recognize that other initiatives are being taken by central banks to make capital requirements in Pillar 1 more sensitive to climate risk and impact, waiting for EBA's assessment in June 2023 means a legislative proposal will only be presented during the next mandate, in 2025 earliest. Taking into account the time needed for negotiations and implementation, climate risk-sensitive capital requirements might be applied just ahead of the 2030 Paris agreement target, which is too late. We therefore call on co-legislators to amend the legislative proposal to better integrate climate risks for individual financial institutions in Pillar 1, also taking into account the climate-related externalities that their asset allocation policy creates in terms of systemic risk. This would reflect the double purpose of the CRD/CRR framework: to protect clients and other stakeholders of individual financial institutions, but also to protect taxpayers and society as a whole from instability of the financial system, with climate risk and stranded assets now becoming a primary financial stability concern. As a very minimal first step, co-legislators should introduce a "one-for-one" rule for investments in new fossil fuel projects, to stop further expanding the financial bubble of stranded assets which must be deflated in an orderly way to avoid a systemic crisis, once these assets are fully stranded.
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Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur)

23 Feb 2022 · Environmental crimes

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and Greenpeace European Unit and

23 Feb 2022 · deforestation

Meeting with Petros Kokkalis (Member of the European Parliament, Rapporteur)

22 Feb 2022 · Sustainable Development Goals

Response to Setting the Course for a Sustainable Blue Planet -Update of the International Ocean Governance Agenda

14 Feb 2022

WWF urges governments to leverage and build synergies across all relevant global fora and processes to advance ocean action. Opportunities following the One Ocean Summit include Our Ocean, the UN Ocean Conference, the Convention on Biological Diversity (CBD) COP15, UNFCCC COP 27 to set more ambitious Climate Plans which include the ocean, the World Trade Organisation (WTO) negotiations on harmful fisheries subsidies, the effort to start negotiations for a legally binding global agreement to combat plastic pollution at UNEA 5.2; the UN negotiations for a strong and robust Ocean Treaty in 2022 (BBNJ), the International Seabed Authority (ISA) with regard to the implementation of a deep sea mining moratorium, and the 2022 International Year of Artisanal Fisheries and Aquaculture (IYAFA 2022). A healthy and resilient ocean is critical to address our combined nature, climate and biodiversity crisis, and essential as we build our climate mitigation and adaptation toolkit. Public and private sector actors must recognize the value of a healthy ocean and commit to redouble their efforts to accelerate the effective protection, restoration and resilience of critical coastal and marine ecosystems. This includes blue carbon sequestration by the world’s oceanic and coastal ecosystems (aka. blue carbon) such as coral reefs, seagrass, salt marshes and mangroves, seabed sediments and others in the deep sea. These critical ecosystems include some of the ocean’s most productive and provide valuable natural infrastructure and ecosystem services including food, disaster reduction and livelihoods critical to support sustainable development well into the future. Enhance cross-sectoral and cross-jurisdictional cooperation among States and across bodies at global and regional scales to lead on ecosystem-based approach to maritime spatial planning which is key to achieve both climate and biodiversity goals. A strengthened integration of ocean-climate-biodiversity agendas, particularly in the context of the preparation and up to COP 26 of the UNFCCC, and the UN SDGs, as the protection of the ocean is central to the fight against climate change and biodiversity loss. This can be translated in particular into the integration of ocean conservation measures in the Nationally Determined Contributions (NDCs). Secure an ambitious and transformational post-2020 Global Biodiversity Framework with respect to marine and coastal biodiversity at the 15th meeting of the Conference of Parties (COP15) in 2022 with clear links to other relevant global agreements. This should include ensuring that at least 30% globally of land, inland waters, marine and coastal areas – especially those of particular importance for biodiversity, ecosystem functions and nature’s contributions to people – are conserved. This needs to be done through effectively and equitably managed, ecologically representative and well-connected systems of protected areas and other effective area-based conservation measures. Areas traditionally and collectively governed by indigenous peoples and local communities must be recognized and secured and their right to free, prior and informed consent respected. Secure and advance a legally binding global agreement to combat plastic pollution that sets national reduction targets, increases accountability and improves global standards. Secure an ambitious new global legally binding treaty on marine biodiversity of areas beyond national jurisdiction (BBNJ). Among other important elements, the treaty must include a designation process for networks of high seas marine protected areas. Failing to include this in the treaty would be a missed opportunity to fill an important gap in ocean governance. Secure a global moratorium on deep seabed mining. (see file attached for the rest of recommendations)
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Meeting with Stella Kyriakides (Commissioner) and ClientEarth AISBL and

31 Jan 2022 · VTC Meeting on the framework legislation on sustainable food systems

Meeting with Pär Holmgren (Member of the European Parliament, Rapporteur for opinion) and Transport and Environment (European Federation for Transport and Environment) and Climate Action Network Europe

31 Jan 2022 · Effort Sharing Regulation (staff level)

Response to European Strategy on international energy engagement

20 Dec 2021

The EU styles itself as a climate leader. However, to truly lead and to meet its Paris Agreement commitments, it must recognise its role in supporting global just energy transitions. While the EU has some of the world’s highest climate targets, it must go further: UNEP estimated emissions must reduce by 7.6% per year from 2019 to keep global warming below 1.5°C this century, equating to a 68% reduction in EU emissions by 2030. To reflect historical responsibility, targets should arguably be higher still. WWF proposes the international energy engagement strategy is guided by the Just Energy Transformation (JET) concept as advanced by WWF at COP26 (attached). JET recognises that we can no longer treat energy transitions separately from social justice because climate change impacts the most vulnerable worst, and hinders SDG progress. Energy transitions should be planned and implemented within the context of achieving a societal transformation to a just and equitable future. Only by keeping global heating within 1.5℃ can the worst climate change impacts be avoided. In addition to raising its 2030 emissions reduction targets to at least 65% versus 1990 levels, the EU must ensure that it promotes and encourages 1.5-aligned transitions internationally, meaning 2040 coal phase-out for developing countries and 2030 for all others. Likewise, the EU must lead by example. NECPs must be updated in line with the 1.5 target. In practice, this should mean 2030 coal phase out and a fossil-free, fully renewables-based power sector by 2035 in Europe. The section on international cooperation and finance in the JET paper is particularly relevant. The case study on page 34 calls for CBAM revenue to be recycled to support developing countries' transition. A global carbon pricing mechanism that guarantees fast, verifiable action towards green and just development is needed. The EU should also outline an action plan to increase its climate finance contribution to help exceed the $100 billion international climate finance commitment. EU international climate and energy finance, including through initiatives such as the Africa-EU Green Energy Initiative, should be guided by the SDGs. The EU must help ensure that energy investment promotes inclusive access to affordable, reliable, sustainable and modern energy in accordance with SDG 7, prioritising decentralised renewables and energy efficiency first. Investments should be planned strategically to be as low carbon, low cost and low conflict as possible, doing no significant harm and excluding fossil fuel support. Moreover, support should be long-term and comprehensive, go beyond projects and uphold climate justice and just transition best practice. The EU should support capacity in third countries to develop 1.5-aligned NDCs which drive synergies between social and environmental goals through SMART targets. They should be inclusively and transparently developed, knitting together energy transition with social policies and whole-economy just transition strategies leading to the creation of decent work and quality jobs. Finally, the EU might draw on the frameworks developed to streamline social, economic and environmental progress measurement as outlined by the 8th Environmental Action Programme. Finally, the EU-South Africa Just Energy Transition Partnership is touted as a model for international just transition support. To succeed, it must catalyse transformative change so that the transition leads to a system that is fairer than the last. In addition to the conditions above, the Partnership should support reforms that strengthen economic and social policy and should support only investments that protect or even enhance biodiversity, ecosystems and natural resources as the bedrock of human and planetary wellbeing. Finally, it must empower communities to design and implement their transition by requiring they are carefully consulted. Barriers to participation in energy transition design must be overcome.
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Meeting with Janusz Wojciechowski (Commissioner) and

16 Dec 2021 · CAP Strategic Plans and the European Green Deal’s objectives

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

26 Nov 2021 · nature restoration legislation

Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius) and ClientEarth AISBL

26 Nov 2021 · To discuss the nature restoration legislation

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans)

24 Nov 2021 · Taxonomy

Meeting with Rosa D'Amato (Member of the European Parliament, Shadow rapporteur)

23 Nov 2021 · Small-scale Fisheries

Meeting with Pascal Canfin (Member of the European Parliament)

17 Nov 2021 · Green finance

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Greenpeace European Unit and

9 Nov 2021 · Forestry

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Greenpeace European Unit

8 Nov 2021 · Taxonomy

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and Greenpeace European Unit

8 Nov 2021 · Sustainable Finance, Taxonomy

Meeting with Kevin Keary (Cabinet of Executive Vice-President Valdis Dombrovskis), Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis) and The Pew Charitable Trusts

4 Nov 2021 · WTO fisheries subsidies

Response to Preventing illegal trade in wildlife

29 Oct 2021

WWF appreciates what has been achieved through the previous Action Plan. It raised the profile of wildlife crime in EU Member States, and led to the adoption of a number of new measures by CITES Parties. It also led to increased funding to combat unsustainable and illegal trade from source countries, and to increased resources for the CITES Secretariat and for the International Consortium on Combating Wildlife Crime. Some of the shortcomings of the Plan have already been alluded to elsewhere; the uneven implementation by Member States, the absence of a formal monitoring and evaluation mechanism, the lack of a bespoke budget line, and the missed opportunity to identify greater synergies with other EU legislation, including that on timber imports and IUU fishing, as well as the Environmental Crime Directive. Important legislation will be under consideration in 2022 including the revision of the above-mentioned Directive as well as new laws relating to deforestation, digital services and due diligence for supply chains. Current EU legislation on asset forfeiture will also be up for revision. This offers an excellent opportunity for the revised Action Plan to establish synergies with and influence a range of other EU legislation. The European Commission needs to allocate much more resources to the future Plan. WWF is particularly concerned that two Seconded National Expert posts in the Commission’s CITES team remain vacant at the time of writing. This needs to be rectified urgently. Ultimately, however, much more needs to be done by Member States if the Action Plan is to be transformational. In particular, they must allocate more resources to combating wildlife crime. In addition, those that have not established maximum sentences for wildlife offences of at least four years - in line with the criteria for defining “organized crime” in the Convention against Transnational Organized Crime - must do so as a matter of urgency. As a global and regional organization, WWF is also ready to share its experience and conclusions in the expert survey which we believe will help in the preparation of the new Action Plan.
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Response to Food waste reduction targets

29 Oct 2021

A key element of the Farm to Fork Strategy, eliminating food loss and waste to the largest extent possible is an urgent and indispensable step towards more sustainable food in the EU. Therefore, WWF welcomes this European Commission initiative to establish legally binding targets to reduce food waste, and the opportunity to provide feedback on the inception impact assessment. The document rightly describes the context, problem and need of enhanced action in food waste reduction. In the last few years, the EU has taken important steps to reduce food waste, but progress is still too slow and a pace change is needed to meet our 2030 commitments. The setting of binding EU targets for food waste reduction is a much needed step to stimulate action by Member States and food businesses: from improving the measurement of food waste to establishing effective actions to reduce it, much remains to be done. EU food waste reduction targets should be at least as ambitious as Sustainable Development Goal 12.3, and aim to halve food loss and waste from farm to fork and from bait to plate by 2030. This will only be achievable by taking a whole food supply chain approach (Scope Option S1 in the document). A recent global report by WWF, “Driven to waste” estimated that as much as 15% of the food produced is wasted already at the farm stage, including during the harvest and slaughter operations. This research suggest that food loss on farms is an overlooked problem in Europe and other industrialised regions, which tend to focus on food waste happening at retail and consumer levels. For more information on this blind spot of EU action on food waste, please see: https://www.wwf.eu/?4049841/fifteen-per-cent-of-food-is-lost-before-leaving-the-farm-WWF-report The EU Common Agricultural and Fisheries Policies can be instrumental in achieving effective food waste reduction in the early stages of food production. Nevertheless, regulations to help reduce seafood by-catch by using more selective methods include numerous exemptions and monitoring problems, which are limiting its effectivity to reduce waste of blue foods. In agriculture, even if one of the explicit objectives of the future CAP is to address food waste, the lack of awareness on the magnitude of the issue will likely lead to it being side-lined by other competing priorities. Accordingly, we strongly recommend that the Impact Assessment looks into the options for better implementation of these policies so they can contribute to reducing food waste. Some of the action that Member States could consider planning through the CAP would be: i) revise existing subsidies and investment support, which could be leading to structural overproduction and market saturation; ii) use CAP sectoral interventions and rural development measures to fund knowledge exchange and innovation, as well as cooperation between actors in the supply chain; iii) support marketing strategies to minimize on-farm food waste and open markets which can absorb over-production. As regards the target setting process, and to appropriately take into account the different trajectories of Member States, legally binding targets should seek a fair contribution by all, provided that the collective target (option T3) for the EU to achieve a 50% food waste reduction target by 2030 is met (Step 2: Option 3). This could be fairly presented as the same obligation for all Member States (Option T1), by setting the target as achieving approximately the same level of food waste per capita in kg. In practice, this would mean different efforts (Option T2), as those already performing better would already be closer to that objective. A consistent and robust measurement of food waste across EU Member States will be needed in any case, to establish an accurate and reliable baseline of food waste levels for each country and the Union. Find attached the WWF-WRAP report on Halving Food Loss and Waste in the EU by 2030, with further insights.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and OXFAM INTERNATIONAL EU ADVOCACY OFFICE and

28 Oct 2021 · Sustainable corporate governance initiative

Response to Sustainable food system – setting up an EU framework

25 Oct 2021

WWF welcomes the Sustainable food system framework initiative and the opportunity to give feedback on the Inception Impact Assessment. Food systems are at the core of our societies and economies, but they are fundamentally unsustainable and conducive to unhealthy consumption choices. The way we produce and consume food is putting an impossible strain on the planet and, given the ongoing health, climate and biodiversity crises, the cost of inaction is already gigantic. By transforming food systems, we can make sure there’s enough nutritious food for every person - now and in the future. And we believe that public policies with appropriate governance, transparency and monitoring have a critical role to play in this urgent task. In Europe, policies affecting food systems have developed largely in silos in the last decades, leading to gaps and inconsistencies, environmentally harmful subsidies and the emergence of diet-related chronic diseases. In the absence of an overarching vision and governance framework for food systems, this situation could continue. Therefore, we consider it timely and necessary to create new EU framework legislation so that the social and environmental challenges associated with our unsustainable food system become a central element in all EU food-related policies. However, we regret that the creation of new legislation is just one of the four policy options outlined, as this option may not be sufficiently ambitious to address the aforementioned challenges. Therefore, we would recommend that a fifth option is considered for the impact assessment, which would include the elements of the fourth option, but would be completed with: i) additional action by national authorities in the aspects of food systems of their competence; ii) changes in agrifood and seafood trade rules, seeking full transparency and socio-environmental equitability; iii) binding health and sustainability obligations for large food businesses. It is important that the cost of inaction is set out in the impact assessment, including immediate and long term impacts on human and environmental health. Inaction can also be a result of poor policy implementation, as it happens with the Common Agricultural and Fisheries Policies, where environmental considerations remain marginal in the final decisions made by the implementing authorities, weakening their capacity to protect and sustainably use our land and ocean resources. With a wide public consultation announced for 2022, we would suggest that the Commission makes this questionnaire accessible for the general citizen by placing any technical question requiring in-depth knowledge of food systems or policy making in a separate optional section at the end of the questionnaire. It is also important that the options given to respondents are unbiased and reflect science-based recommendations to reach the targets the EU has set itself (e.g., Paris Agreement and the SDGs). When options offered do not permit these targets to be met, this should be made clear. A sustainability-labelling of foods placed in the EU markets is an interesting development, but will clearly not suffice to make our food systems sustainable, as it is excessively based on the informed consumer choice model. This new EU law should trigger new or revised Union and national legislation so that food environments, the structural factors that drive food choice, are modified, truly enabling people to make healthier, sustainable choices. To drive a system-wide transition, the EU will have to set up a long-term vision and strategy and support the efforts of all food system actors in this direction. Business opportunities and positive synergies must be sought, as well as mechanisms set up early on to identify, debate and manage trade-offs, in order to make a significant transformation of the food system (such as a shift towards more plant-based diets for health and sustainability reasons) politically acceptable and socially just.
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and

13 Oct 2021 · Transparent and inclusive process of CAP plans

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

29 Sept 2021 · Just transition in coal regions

Meeting with Mónica Silvana González (Member of the European Parliament)

22 Sept 2021 · Development Cooperation

Meeting with Pascal Canfin (Member of the European Parliament) and Positive Money Europe

21 Sept 2021 · Green finance

Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen), Renaud Savignat (Cabinet of Commissioner Jutta Urpilainen) and

17 Sept 2021 · upcoming proposal on sustainable corporate governance

Response to Amendment to the delegated act on the functioning of the Advisory Councils under the Common Fisheries Policy

10 Sept 2021

On behalf of the Coalition Clean Baltic, the Coalition for Fair Fisheries Arrangements, the European Anglers Alliance, GoodFish, Oceana, Sciaena, Seas at Risk, and WWF, we hereby respond to the 2021 European Commission’s public consultation on its draft delegated act on the functioning of Advisory Councils. Please find our complete feedback in the document attached. Abstract: The aforementioned organisations welcome the Commission’s draft Delegated Act (DA) and important efforts on the improvement of the functioning of the Advisory Councils (ACs), but would like to bring to your attention some fundamental improvements that are still needed to ensure both the functioning and the legitimacy of the ACs. Firstly, we believe that transparent, balanced and informed recommendations and suggestions by ACs are critical to comply with Art. 43(1) of the Common Fisheries Policy (CFP). The suggested amendments of article 4, 5 and the insertion of art. 7a, will support this. On the latter, failure to improve or address the issues identified by the independent performance review should be sanctioned and funding to the ACs should be withheld. Secondly, we believe that Art. 2(b) of the Annex, if adopted, would greatly alter the remit of ACs as defined by the CFP, and should therefore be removed. While we agree that engaging with stakeholders competing for different uses of the sea is indeed necessary, we believe there are other manners to build from the expertise of these stakeholders without derogating from the fisheries and aquaculture-specific remit of ACs. For instance, other stakeholders groups should be allowed to participate in the discussion as active observers, including within working groups, especially when the topic is relevant to their field. This would allow ACs to reach informed decisions without unduly side-lining the voice of fisheries and aquaculture experts working towards sustainability. To support the inclusive participation of stakeholders, a dedicated maritime forum could be established as a designated space where the users of the sea and civil society could be represented in a balanced manner to meet and discuss. Furthermore, we believe that in any case, organisations representing or having direct or indirect economic interests should be included into the sector organization group. Instead of adding up yet another group with potentially conflicting interests, the Commission should enhance the participation of low-impact fishers in the ACs. Thirdly, it is regrettable that the DA fails to address the persisting lack of compliance with the required 60/40 composition of General Assemblies and Executive Committees (as per 2(a) of Annex III to Regulation (EU) No 1380/2013). As this is difficult to achieve it is of even greater importance to regard best practices, e.g. seeking common ground. When consensus is not possible to reach, ACs must ensure minority positions and dissenting opinions are duly recorded, whilst striving to reach consensus. Finally, we believe that the Commission should guarantee the legitimacy of the ACs by ensuring a balanced and transparent structural organization and governance of the ACs, including the chairmanship, the preparation of documents, the assessment of potential conflicts of interest between participants and the conditions for membership and participation. We are convinced that all these improvements are necessary to create the conditions for a constructive structured dialogue in these ACs, which is an essential precondition for the full engagement and participation of our organisations.
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Meeting with Frans Timmermans (Executive Vice-President)

3 Sept 2021 · Preparation of COP26 and COP15, and the implementation of the European Green Deal

Response to Policy Statement 2022

26 Aug 2021

For our detailed position, please refer to the joint-NGO feedback submitted by Oceana (attached). WWF welcomes the EC’s report yet deplores the confirmation that overfishing has increased in EU waters. If “fisheries in the EU grow in sustainability”, they aren’t all doing so at a pace reflecting the urgency of the situation, or at all, and remedial measures to restore certain fish stocks will not suffice in themselves so long as quotas are set unsustainably. As we continue to distance ourselves from the legally prescribed 2020 deadline to end overfishing, marine ecosystems across EU waters remain at risk of collapse. Despite being a precondition to deliver on the CFP’s objectives, fishing limits are yet to all be set at sustainable levels, using an ecosystem-based approach to fisheries management in line with best scientific advice. Therefore, the usual recommendations remain unchanged: fishing opportunities must be set at or below MSY levels, or in accordance with the ICES data-limited precautionary approach where data is lacking. In fact, all TACs should be set at more precautionary levels to accommodate for uncertainties (e.g. unreported discards), inter-species interactions, and the increasing and cumulative pressures on marine ecosystems, such as climate change and pollution. To do so, the EU must notably work towards SSB levels of at least 40%, aiming for SSB50% for all EU stocks. In mixed fisheries, this means protecting the most vulnerable stock (i.e. by setting TACs of all species accordingly, or through area closure). WWF welcomes the EC’s willingness to further speed up work on the ecosystem effects of fishing. As rightly pointed out, the persisting control and enforcement challenges regarding the landing obligation allow for illegal discarding and overfishing to continue, putting the sustainability and financial viability of fisheries at risk. This must be addressed by enshrining the use of remote electronic monitoring tools within the revised Control Regulation, which provides the most effective and cost-efficient manner to improve monitoring and enforcement, paving the way towards a culture of compliance in all EU sea basins. Until then, the landing obligation cannot be assumed to be fully complied with and TACs must be set accordingly. Investments are needed to develop facilities to collect, manage and transform what should be compulsorily landed. Improving selectivity remains a critical necessity to reduce unwanted catches, and promote the implementation of the landing obligation. The EC’s evaluation of MS’ progress in implementing current by-catch reduction measures will support this. Nonetheless, the move towards more selective fishing techniques, and more generally towards low-impact fisheries, remains too slow and must be better incentivized. Whilst STECF concluded a slight improvement in the Mediterranean, it deplored the decreasing number of stock assessments, and fishing mortality remains more than twice above sustainable level. The data and reporting shortfalls must be addressed to ensure accurate and comprehensive management. The West Mediterranean MAP is, amongst others, a pivotal tool to ensure sustainable fisheries, but remains to be fully implemented. The 2025 MSY deadline is already a major drawback and simply cannot be missed. The communication reiterates that stocks that are sustainably caught lead to improved economic performances and salaries. The socio-economic dimension of the CFP remains too often overlooked and insufficiently understood by policy-makers and stakeholders, yet such understanding is key to guide policies that will restructure the EU fishing fleet and ensure balance between fishing capacity and opportunity, which, as mentioned, is still far from achieved. A better understanding of how socio-economic interacts with environmental sustainability is needed. The post COVID-19 recovery must include the recovery of EU fish stocks for the benefit of both people and the planet
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Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and

22 Jul 2021 · VTC meeting on Framework legislation for sustainable food systems

Meeting with Estelle Goeger (Cabinet of Commissioner Paolo Gentiloni)

1 Jul 2021 · SDGs

Meeting with Pascal Canfin (Member of the European Parliament) and Fédération Française de l'Assurance

24 Jun 2021 · Green finance

Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

17 Jun 2021 · Exchange on the upcoming proposals as part of the Fit-for-55 package

Meeting with Pascal Canfin (Member of the European Parliament) and Greenpeace European Unit

11 Jun 2021 · CAP

Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

10 Jun 2021 · Roundtable of the Clean Hydrogen Alliance: 3rd meeting of the co-chairs

Meeting with Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius) and Umweltorganisation WWF Central and Eastern Erurope

3 Jun 2021 · Dam Construction on Vistula River

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

WWF welcomes the EC’s draft DAs as they are very much aligned with ESAs proposal overall, that we found quite positive. The draft DAs should at the very least align with ESAs proposals. We are pleased to see the EC followed the ESAs’ idea to include templates for the different stakeholders having to disclose the info, which makes info more user-friendly, comparable and clear. However, it would be useful for users to have guidance on usability of the info provided in the templates or spreadsheet-based overviews like the TEG provided. Overall, we applaud the requirements to disclose the exposure by economic activity regarding all 6 environmental objectives; including the type of activity (if it is transitional or enabling); at the level of the undertaking or group (important to avoid focusing only on the greenest subsidiary) across all environmental objective by avoiding double counting. It’s also positive that all the additional supporting info accompanying the KPIs shall be disclosed in the same parts of the financial report or provide cross-references to the relevant parts. This is again necessary to make the users’ life easier when searching for taxonomy evidence. It’s positive that all stakeholders under scope should cover the annual reporting period of the previous year and the KPIs covering the previous 5 reporting periods: critical to compare between years and assess if the company is indeed transitioning, together with the undertaking’s future objectives and targets for the KPIs and their plans to achieve them. Info both in absolute terms and as a % shall be provided for all financial undertakings. However the proportion of turnover/capex/opex is missing for the NF undertakings and should be added. It’s important that the info on “DNSH” is included across all templates for all stakeholders. It’s also important that “taxonomy non-eligible” for NF undertaking and AM, and “taxonomy-eligible but not taxonomy-aligned” is included as well to provide more info to users. We strongly support the ESA's advice on reporting failure of DNSH criteria under Art. 8, whereby all companies falling under the CSRD will need to report per activity covered by the taxonomy. It’s very positive to see the inclusion in the template for financial undertakings the exposure to investee companies not falling under NFRD scope, including for those from non-EU countries. However, those may be included only from 1/1/2025, which is far too late to ensure a level playing field and should be shortened to 2023. A requirement for Board level approval for the activity-level investment plan(s) (for capex) is critical. The review to include public exposures to central governments and central banks only from 1/1/2025 is too late and should be shortened to 2023. In calculation of green investment/asset ratios, sovereign, sub-sovereign and supranational should be included in both the numerator and denominator. The review of SME exposure also comes from 1/1/2025 which is far too late and should be shortened to 2023. Even if the CSRD will potentially extend the scope to more SMEs, the EC should be way more ambitious including SMEs by providing them the necessary resources in order to comply with various disclosure requirements. Inclusion of taxonomy aligned SMEs in numerator is key. Critically, % capex and % turnover should never be added up or averaged, and remain 2 separate indicators, otherwise there is a huge risk of greenwashing. “Bonds issued under Union legislation on environmentally sustainable bonds and environmentally sustainable bonds issued under national legislation shall be included in the numerator of KPIs only up to the value of Taxonomy-aligned economic activities that the proceeds of those bonds finance”: this makes sense. However once the EU Green Bond Standard will be in place, a robust methodology to assess the taxonomy alignment will need to be set up, in particular with respect to verification of the underlying use-of-proceeds info.
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Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and European Environmental Bureau and

1 Jun 2021 · Restoration law

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

31 May 2021

Regarding the specific objectives and priority areas of cooperation per sub-region, based on the areas of cooperation listed in Annex II, we recommend to add following: Neighbourhood South Heading 3: Supporting a green transition, strengthening climate resilience, energy transition and security, and protecting the environment We recommend to add: explicit reference to Nature Based Solutions in the context of climate mitigation and adaptation At the nexus between biodiversity restoration and climate adaptation, a vast forest landscape restoration plan should be a flagship initiative for North Africa Add a specific reference to conservation and restoration of water ecosystems for water security would be especially relevant in the North Africa context - most water stressed region in the world and vastly degraded water catchments a specific reference to oceans/marine conservation (recovery of fisheries ecosystems; marine spatial planning; sustainable blue economy) elimination of plastic pollution
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Stichting BirdLife Europe and

19 May 2021 · Forests, climate and biodiversity

Meeting with Thierry Breton (Commissioner) and

19 May 2021 · Clean Hydrogen Alliance; Hydrogen Strategy

Response to Action plan to conserve fisheries resources and protect marine ecosystems

12 May 2021

The Action Plan (AP) must ensure the full and coherent implementation of both EU fisheries and environmental regulations, along with sufficient funding, to protect and restore the marine environment for the benefit of people and the planet. Thus: Address bycatch through the adoption of selectivity measures; spatial and temporal closures; the collection and publication of data using REM; and the mandatory use of mitigation tools (e.g. TEDs) for all fish products consumed in the EU. This must be set up urgently for populations of all ETP species. The AP must include specific, time bound targets on bycatch reduction. The EU must also update and harmonise the list of species that should be managed and protected by the different EU policies in line with the best scientific advice and with other lists of ETP species (e.g. RSCs, CMS, CITES). Develop a network of at least 30% effectively managed protected MPAs with at least 10% strictly protected, designated/improved to maximise and prioritize biodiversity protection and ecosystem restoration, according to the best available scientific advice. MPAs must also be created to protect the seabed and reach GES for seabed integrity under the MSFD. EBM must finally be implemented based on the rules of the CFP art. 2 (3). The EU must make use of CFP art. 11, 18 and 8, inter alia, to protect marine ecosystems in compliance with the MSFD, the BHD and other environmental regulations. To restore ecosystems, meet GES and align with the ambitions of the Biodiversity Strategy, limit the use of fishing gear most harmful to biodiversity by restricting and phasing out non-selective, harmful fishing gear and operations in EU waters and by EU operators, notably mobile bottom contacting gear. The AP must be used to align marine policies with the EU climate ambitions. Low-impact fishing must be better defined, funded (e.g. EMFAF, NextGenEU) and incentivized. Art. 17 must be observed to ensure allocation systems are fair and transparent, and include clear environmental, compliance, economic and importantly, social criteria. The AP must ensure a just and fair transition. The CFP’s MSY objective must be achieved by ensuring fishing limits are set at a maximum of BMSY (with BMSY at a minimum of 50% of Bmax) and reach SSB levels of 40% (aiming for 50%) for all EU stocks, to account for their ecological role and provide a buffer for climate change. To fulfil their role as tailored, ecosystem-based conservation measures based on the precautionary approach, MAPs must cover all fisheries comprehensively and include clear environmental and socio-economic objectives. They must also include selectivity and bycatch mitigation measures. Adopt the necessary fisheries management measures under art.6 of the Habitats Directive and as per CFP art. 11, and ensure the TMR implementation is in line with biodiversity objectives. Reduce fishing effort through temporal and spatial fisheries measures, including FRAs that can be counted as OECMs and contribute to the EU biodiversity/restoration targets, and integrate fisheries management measures in all MPAs. Align the internal and external dimensions of the CFP. In RFMOs, this means improved and harmonized management measures and standards by promoting EBM; data collection and traceability tools; better target reference points; and bycatch reduction measures; more transparency and better anti-IUU measures. SFPAs must be inclusive in their development and implementation, and ensure transparency and sufficient data collection. Fisheries products, both fresh and processed, must be traceable from ‘bait to plate’ using an effective digital system to create transparency, improve consumer information and help tackle IUU fishing and food fraud. The EU must reach a level playing field in terms of sustainable requirements between EU and non-EU operators. Fisheries control must be improved by mandating REM, e-logbooks and tracking vessels in all fisheries segments.
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Meeting with Charlina Vitcheva (Director-General Maritime Affairs and Fisheries) and FUNDACION OCEANA and

11 May 2021 · Discussion on IUU

Response to Revision of Non-Financial Reporting Directive

10 May 2021

WWF applauds the ambition the Commission has taken in this much awaited legislative proposal. More concretely, among very positive elements we see the following: 1. The extension of the scope of the Directive to include all large companies, both listed and non-listed which already makes a big difference in terms of the impacts large companies can have on people and planet. 2.A requirement to develop European generic and sector specific mandatory sustainability reporting standards. This is essential to ensure relevance, clarity and comparability of disclosed information and to address the specificities of high-risk sectors. 3. Clarification of the main reporting areas and the categories of information that companiesshould disclose is specified in greater detail. The principle of “double materiality” is also clarified and properly enshrined in the draft proposal. 4. The proposal provides a clear mandate to report on plans to ensure the compatibility of company business models and strategies with the transition towards a sustainable economy and with the limiting of global warming to 1.5 °C in line with the Paris Agreement. This is crucial forward-looking information that users will need in order to monitor if a company is actually taking the neccesary steps to achieve the EU sustainability goals. However, the proposal falls short on several parts: 1. Regarding point 4 above, the EC failed to integrate this requirement in the provisions on mandatory sustainability standards. This is extremely dangerous as the technical translation will not exist, meaning this information will either be left to corporate to decide how to report it or it will be non-existent. The precedent of SFDR where the "degree of alignment with PA" was not properly translated in to the RTS is key. 2.The scope regarding SMEs is too limited, as using "size" is not a relevant indicator regarding impact. We recommended the EC to rather include SMEs operating in high-impact sectors instead, which would still maintain the proportionality principle. This recommendation was included in the EFRAG's PTF NFRS report, of which WWF was a member. This will risk leaving smaller companies behind in terms of reallocation of capital. The EC should instead ensure they have the necessary resources to be able to comply with the new rules. 3. The exemption for large companies, which are part of corporate groups, is problematic. The proposed exemption is different from the rules for financial reporting, which do not exempt companies from publishing statutory financial accounts because they are also integrated into consolidated financial accounts. Throughout the EU, some sectors (such as the financial industry) are highly concentrated. Making disclosures subject to the determination of materiality at the group level may lead to non-disclosure of specific information on resilience and significant impacts of subsidiaries of such EU groups, resulting in lack of accountability at national level as well as to investors and stakeholders needing these insights. 4. The proposal includes the requirement for companies to report on sustainability due diligence, and actual and potential adverse impacts connected with the company’s value chain, though the information about value chain should be provided only ‘where appropriate’. In this respect, the proposal fails to specify the essential aspects that EU standards need to address in particular with regard to reporting on human rights, including disclosure of salient human rights issues, key elements for supply chains disclosures, and quality criteria for KPIs. The lack of clear directions would significantly hamper the development of the reporting standard given unsatisfactory level of reporting in this area and lower maturity of existing standards compared to the environmental area. 5. The proposal fails to specify the time horizon of targets and plans set and link it to the double materiality assessment,essential for meaningful information.
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Meeting with Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius) and Greenpeace European Unit 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

Response to Protecting the environment in the EU’s seas and oceans

6 May 2021

The flaws of the MSFD are due to poor implementation by MS to reach GES, not the framework itself. However the EC in their guidance should play a more effective role, an evaluation of the current situation/results is also needed. Despite 13 years since inception and 11 years since the MSFD deadline for transposition into national legislation, MS have missed main objectives, in particular reaching GES of EU marine waters by 2020, which MS had a decade to ensure effective implementation. The implementation by MS has been too slow due to limited ambition in setting up definitions, targets, thresholds, measures, and the lack of political will to adequately fund and enforce the necessary measures. This opinion is also reflected in the 2020 MSFD implementation report. Deadlines must be adhered to, and the reasons for the failure to achieve GES and the lack of effective protection for marine ecosystems must be addressed. In the report published by the European Court of Auditors they found that the MS visited had used only 6% of funding through the EMFF on measures directly related to conservation measures associated with the MSFD, B&H directives, and a further 8 % on measures indirectly related to conservation measures. In this context, WWF recommends Option 3 to “Strengthen implementation and enforcement of the Directive without changing its provisions” Revision of MSFD, even targeted ,may send the wrong signal to MS that are failing to meet their targets, providing opportunity to further weaken and or postpone the achievement of the GES. Points •The primary goal and scope of a review should be to reach GES in EU waters as soon as possible. •MS capacity building and deployment of resources needed to ensure achievement of the MSFD objectives. EC must provide simplified and improved guidance. •Thorough evaluation is needed of the MSFD to pinpoint needs to improve implementation and for all MS and other actors to remain committed to taking part in the process at all levels, including regional. •EU/regional coordination of MSFD is required as MS developed their own national set of indicators and thresholds preventing any comparability of GES in transboundary waters •The MSFD needs better implementation through support of legal acts and new initiatives that are coming, e.g. Biodiversity Action Plan and restoration targets. •Understand relationships between GES and FCS, to seek greater harmonisation of the two processes and outcomes. •Integration and identification of both synergies and inconsistencies between MSFD, MSPD, Nature Directives, WFD, CFP, CAP, Floods Directive and EU Adaptation Strategy in terms of good practices in implementation, and operational objectives/required actions (reporting, monitoring, etc.) •Identify interactions, overlaps and potential areas for closer coordination between the MSFD and other instruments and EU policy . •Enhance coherence with EU environmental agenda under EU Green Deal, in line with the new ambition of the EU 2030 BDS •The EC must provide clear guidance to MS to ensure that measures to comply with BHD, and Art 15 of the MSFD can be implemented, including the necessary scientific evidence and information to justify measures. •Improve coordination and synergy between provisions of Article 11 of the CFP and Art 15 of the MSFD •Greater alignment of funding from new EMFAF with MSFD to support conservation measures and achievement of GES •The EC, together with MS should identify regulatory and administrative changes necessary to protect sensitive species/habitats e.g. new listings, to facilitate faster application of conservation measures under the MSFD and other areas such as the CFP as recommended by the ECA. As reflected in the 2020 MSFD implementation report and in the 'FitnessCheck' evaluation of the EU B&H Directives, the major challenges to achieve GES/FCS are linked to implementation gaps and lack of ambition and resources, rather than significant problems in the policy framework.
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Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen) and Greenpeace European Unit and

30 Apr 2021 · upcoming regulation on deforestation

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Greenpeace European Unit and

29 Apr 2021 · Deforestation and forest degradation.

Meeting with Virginijus Sinkevičius (Commissioner) and

28 Apr 2021 · Bialowieza forest

Response to Social Economy Action Plan

26 Apr 2021

WWF welcomes the upcoming Action Plan on the Social Economy (AP), but calls for greater recognition of the need and opportunity for the social economy to contribute to EU environmental and climate objectives, including those enshrined in the European Green Deal and the United Nations’ 2030 Agenda for Sustainable Development. The Green Deal must be Europe’s compass for recovery. Even before the pandemic, the EU suffered structural inequalities as well as a looming biodiversity and climate crisis. By putting social and environmental goals before profit, the social economy can play a key role in the recovery to a more resilient, fair and resource-efficient society: but to do so, it must be sustainable and deliver its objectives within planetary boundaries. Neglecting environmental goals undermines wellbeing by eroding public goods and the support systems for health and prosperity. Definitions for social economy organisations should be consistent with do no significant harm criteria harm to environment and climate objectives as defined by the EU Technical Expert Group report of March 2020. A definition should make use of the criteria set in a science-based EU Sustainable Finance Taxonomy. The AP should include measures to promote social economy organisations supporting both environmental and social goals. This may include raising awareness of the opportunities to achieve social, environment and climate goals together. Initiatives using renewable energy (RES) to deliver community benefits (e.g. through revenues or reduced energy costs) are exemplary here, but not exclusive. A strong social economy ecosystem could strengthen local resilience, especially in transition regions, such as coal regions. These regions often suffer from significant environmental damage, structural socioeconomic problems such as skills shortages, poor health indicators and high unemployment. The social economy can boost regional resilience, even though many social enterprises are small and will be unlikely to play a major role in replacing employment when coal mines and plants first close. Many coal and carbon intensive regions have good grid infrastructure and energy heritage. JRC studies on clean energy in coal regions highlight their vast RES potential. Often decentralised, RES can be important vehicles for delivering both social and environmental goals. The AP should emphasise specific measures to support RES communities in all regions through capacity building, good practice sharing and strong policy frameworks and public procurement rules. Specific long-term, targeted measures for the social economy are needed in transition regions, including one-stop-shops and good practice identification. Dedicated research to identify potential sites and opportunities for RES communities can accelerate the uptake of opportunities. Finally, to build a supportive ecosystem for the social economy which also delivers on the EU Green Deal and drives a green and just recovery; the EU must advance a vision that goes beyond GDP and towards a Wellbeing Economy. The social economy can be part of this broad shift, which starts from the idea that public interests should determine economics, and not the other way around. Rather than pursuing economic growth through narrowly defined indicators such as GDP, a wellbeing economy monitors and values what truly matters: our health, nature, education and communities. The social economy puts social goals at its heart rather than profit, and the EU must do the same by making social and ecological goals and resilience central to progress and performance monitoring, notably in the European Semester. The AP should further contribute to EU achievement of the 2030 Agenda and its 17 Sustainable Development Goals. The AP should be fully aligned with the SDGs, in order to deliver not only on social and environmental goals but also the governance dimension of sustainable development, such as through inclusive governance and participation.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and European Environmental Bureau and

19 Apr 2021 · Industrial Strategy

Meeting with Frans Timmermans (Executive Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

19 Apr 2021 · Foreseen review of the renewable energy directive and use of forest biomass for energy production

Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen)

15 Apr 2021 · European Green Deal

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Transport and Environment (European Federation for Transport and Environment) and

14 Apr 2021 · Videoconference discussion on the use of biomass for energy, especially forest biomass, and on transport biofuels.

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and Stichting BirdLife Europe and

13 Apr 2021 · Preparation for the meeting with EVP Timmermans

Meeting with Pascal Canfin (Member of the European Parliament) and AXA and MAIF

7 Apr 2021 · Green finance

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

26 Mar 2021 · Taxonomy draft delegated act

Meeting with Pascal Canfin (Member of the European Parliament)

25 Mar 2021 · Climate Law

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

19 Mar 2021 · non-financial reporting

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

26 Feb 2021 · Just transition ideas for coal mining regions in Poland

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

10 Feb 2021 · Sustainable corporate governance

Meeting with Pascal Canfin (Member of the European Parliament)

10 Feb 2021 · Finance verte

Meeting with Virginijus Sinkevičius (Commissioner) and

3 Feb 2021 · To speak about the upcoming EU nature restoration law and its key importance for implementing the Biodiversity Strategy

Meeting with Pascal Canfin (Member of the European Parliament)

26 Jan 2021 · Green Deal

Meeting with Mairead McGuinness (Commissioner)

26 Jan 2021 · Sustainable Finance

Response to Navigation And Inland Waterway Action and Development in Europe (NAIADES) III Action Plan 2021-2027

15 Jan 2021

Given the key pressure that inland waterway infrastructure and operations can exert on aquatic ecosystems (see art 785 of SWD(2020)), we call on the European Commission to ensure full compliance of NAIADES III with environmental policies, in particular with the Water Framework Directive (WFD), the Floods Directive, the Habitats Directive and the objectives set by the EU Biodiversity Strategy (e.g. the target of restoring 25,000 km of free-flowing rivers). In its December 2020 resolution, the European Parliament noted “that the shift from road freight to inland waterways should be fully consistent with the non-deterioration principle of the WFD, as well as with other environmental legislation, including the Birds and Habitats Directives [...]”. It is important that NAIADES III does not foster projects that entail risks to nature and sustainable water use. We urge the European Commission to : - Broaden the definition of the “sustainable development of the inland waterway transport (IWT). Sustainability should not only be about meeting the Green Deal objectives in terms of modal shift, lower pollutants and greenhouse gas emissions, but also in terms of protecting biodiversity, ensuring resilience to climate change impacts and compliance with the “do no harm” principle. - Add to the list of problems that NAIADES III aims to address, hydromorphological and other environmental pressures on river bodies caused by IWT. Because of construction and dredging, IWT infrastructures frequently result in modification in the hydromorphology of rivers, fragmentation of ecosystems, disruption of ecological flow, habitat deterioration of protected species such as critically endangered sturgeons, or pollution of water and sediment. Hydromorphological pressures are the first pressure impeding the achievement of good surface water status under the WFD, and the WFD Fitness Check has already highlighted the need to better integrate it with other sectoral policies including the navigation policy. Also, the effects of ship-induced waves on aquatic ecosystems is an increasingly recognised issue the Action Plan should help addressing. - Outline more specifically how “integrative approaches among all water users towards ecologic, societal, economic and safety-related functions” will be promoted by NAIADES III. Member States should ensure that all relevant stakeholders, including environmental organisations, are engaged in the planning process for new navigation projects and maintenance measures to reach commonly accepted solutions and maximise synergies, by integrating nature restoration measures (as e.g. happened in the East of Vienna project) - Add to the list of objectives of NAIADES III a third objective (C) on bringing inland navigation in line with the EU environmental legislation. In particular, the action plan needs to be accompanied with an impact assessment of the projected development of inland waterways on the achievement of the Good Ecological Potential/Ecological Status); the management of flood risks; and the resilience to increasing water shortages and drought due to climate change. - Prioritise, in the list of navigation projects that will be eligible under the Action Plan for funding, those that ensure the maintenance of the natural hydromorphological processes ; the use of nature-based solutions ; habitat protection of endangered aquatic species; longer-term ecological impact monitoring; and restoration measures such as side channel reconnection. Strengthen the aspect of capacity building on environmental aspects for water engineers and administrators involved in designing, planning and implementing IWT projects. - Extend the scope of innovation from energy consumption and emissions only to innovative ship design for navigating feasibly under conditions of fluctuating and low water levels and with negligible impact on aquatic life (e.g. ship-induced waves). This will reduce the need for harmful infrastructure interventions.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski), Roberto Berutti (Cabinet of Commissioner Janusz Wojciechowski)

15 Jan 2021 · EU taxonomy

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

15 Jan 2021 · General discussion about the new Industrial Strategy, the EU ETS revision and Clean Hydrogen Alliance

Response to EU single access point for financial and non-financial information publicly disclosed by companies

14 Jan 2021

WWF strongly supports the European Commission’s intention to present a legislative proposal to build a European single access point for corporate data. This proposal will strengthen both the Capital Markets Union by improving cross-border investment opportunities as well as the Sustainable Finance Strategy by making sustainability information more easily accessible to interested stakeholders, including potential investors. In our view, the scope of the proposal must be as wide as possible, both in terms of number of companies covered, as well as in terms of the financial and sustainability information covered. To provide end investors with an integrated one-stop portal for identifying investment opportunities in all member states, the single access point’s database must include small companies, non-listed companies, and the data provided must include sustainability data. This means that the ESAP scope should be larger than the scope of the revised Non-Financial Reporting Directive (NFRD) – at least in a voluntary way for certain SMEs. The Commission’s inception impact assessment correctly states that covering only the EU's listed companies is not sufficient and that non-listed firms should also be included. Arguably, Member States are already collecting data from this group of companies and therefore it should be relatively easy to build a European database based on this data. To promote more sustainable investment choices, the public access point should put sustainability data on an equal footing with financial data, e.g. in terms of the amount of indicators available and the prominence of search, tagging and filtering options. This would allow investors including retail ones to look for investment opportunities in companies that have a certain sustainability performance. Practically, this means that the provisions related to financial data in the Transparency Directive, which already requires listed companies to prepare their annual reports in a single electronic format (ESEF), should be extended to sustainability information. The Business Registers Interconnection System (BRIS) project shows the limits of a system that is not built from scratch to facilitate the perspective of a potential cross-border investor, but instead was built on top of national registers as a search portal. The underlying data is not standardized, does not include sustainability data, and in many Member States the data is not even available from the portal but only from national systems where users must pay for downloading or receiving corporate reports. This is why the ESAP initiative should include legislative measures using Article 50 or 53 TFEU, so that all companies in the EU can be covered irrespective of existing national rules (notwithstanding the fair objective to avoid double reporting requirements). For civil society, broader, deeper and machine-readable corporate data is essential to facilitate scrutinizing sustainability impacts of EU companies. Stakeholders such as consumers and civil society have limited resources to pay for access to commercial databases or to spend time manually collecting, scraping and encoding sustainability data. The access point must be publicly accessible (i.e. as a website, not a subscription service) and free of charge for all citizens. Machine readability of data is also essential to spur the much-needed development of the ESG advice market. The single access point would allow ESG rating providers to focus on added value and analysis of corporate ESG data instead of mere data collection. The platform should allow for sector-specific information. Based on categorisation of NACE-codes, sensitive sectors as regards ESG risks and impacts should provide supplementary data that is available on the platform. The search function of the access point should align to disclosure practises prescribed in the forthcoming review of the Non-Financial Reporting Directive, including for sector-specific disclosures.
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

12 Jan 2021 · Delegated Act, taxonomy

Meeting with Virginijus Sinkevičius (Commissioner) and

12 Jan 2021 · To discuss the implementation of the Biodiversity strategy, the actions under the zero-pollution ambition as well as green funding under the new MFF and the recovery funds.

Response to 8th Environment Action Programme

21 Dec 2020

WWF European Policy Office believes that as it stands the 8th EAP proposal lacks the overall ambition and forward-looking actions to tackle environmental degradation and achieve the EU’s long-term aim of ‘living well, within the means of our planet’. The document attached provides recommendations for strengthening the proposal and reaching this long-term aim.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

15 Dec 2020 · European Green Deal implementation, with focus on product and forest policies

Meeting with Virginijus Sinkevičius (Commissioner) and

14 Dec 2020 · Handover of 1 ml signatures for action on deforestation

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

14 Dec 2020 · Handover of 1 mln signatures for action on deforestation

Response to Access to Justice in Environmental matters

10 Dec 2020

Delivery of the European Green Deal depends on the implementation and enforcement of EU environmental law by EU institutions. To ensure compliance, the EU needs strong mechanisms that allow civil society to hold EU institutions to account when they fail to deliver on their commitments. Presently, there are no effective means for the public to seek judicial review of EU acts that breach environmental law. We therefore welcome the Commission’s proposal to amend the Aarhus Regulation as a first step in remedying this situation. However, the current proposal is still missing very important elements and needs to be significantly improved by the co-legislators. It is widely accepted that the internal review mechanism contained in the Aarhus Regulation does not work because the definition of the acts that can be subject to review is too narrow. Since its adoption, the vast majority of the almost 50 NGO requests for internal review brought to the Commission were rejected as inadmissible and never assessed by the EU courts. These included decisions to approve substances used in pesticides, the list of new fossil fuel energy infrastructure projects (so-called ‘PCI list’), state aid that fuel climate change, or to set the total allowable catches of fish stocks in EU waters. Rather than ensuring that these acts can be subject to review in the future, it is still unclear whether the Commission’s proposal would remedy or maintain this situation. This is unacceptable. When EU bodies do not respect EU law, it must be unequivocally clear that the public can hold them to account. This is also a matter of international law. The Aarhus Convention Compliance Committee found the EU to be in violation of the access to justice provisions contained in the Aarhus Convention which the EU ratified in 2005. The EU will continue to be in breach of international law until the Aarhus regulation is fixed. The co-legislators need to amend the following aspect of the Commission’s proposal to remedy this situation: 1. Make acts that entail “implementing measures” and all acts that produce legal effects subject to internal review (Art 2.1g). The proposal’s definition of what constitutes an “administrative act” contains unjustified and unclear exclusions which could insulate many, if not most, acts of the EU bodies which contravene environmental law from review. This would undermine the benefit of the revised text. 2. Make State aid decisions subject to internal review (Art 2.2). The CJEU has explicitly confirmed that the Commission needs to ensure that its State aid decisions only authorise projects that comply with EU environmental law. NGOs must therefore be able to request an internal review if there is evidence that the Commission may have failed to do so. 3. Introduce cost protection and effective court review (Art 12). The proposal does not give NGOs cost protection when they lose in front of the Court, nor does it ensure that the Court will look at all of the substantive and procedural claims that an NGO may bring forward. Both of these issues are barriers to obtaining effective court remedies that need to be addressed in this amendment process. Furthermore, the Commission called in its Communication accompanying the legislative proposal (§ 33-34) for including equivalent rights of access to justice at national level in all EU pieces of environmental legislation. This would ensure democratic scrutiny over non-legislative acts of EU Member States taken in application of EU law. We therefore call on co-legislators to amend sectoral legislation through the revised Aarhus regulation, starting with the Governance regulation (2018/1999). Finally, the EU has formally sought the Compliance Committee’s advice on whether the proposal would address its non-compliance with the Aarhus Convention, which is due to be delivered in December 2020. We call on the co-legislators to take the Committee’s advice into due account before they adopt a negotiating position.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

Most EU Member States, with the exception of Cyprus, Malta and more recently Finland, give state aid to hydropower. In 2016-2017 in those countries, the weighted average support level to hydropower was comparable to the weighted average support level to onshore wind. In total, 4.3 billion euros of state aid went to hydropower in the EU and Norway in 2016-2017, under the form of feed-in tariffs, feed-in premiums, green certificates and investment grants (CEER, 2018). State Aid is fuelling hydropower projects that are comparatively more detrimental to the environment than other renewable energy sources. Last month’s State of Nature in the EU report by the European Environmental Agency found that the pressure caused by hydropower on habitats and species is larger than the one caused by wind and solar. State Aid is also supporting hydropower projects which would not be economically viable in their absence. This is particularly true for small hydropower plants (of a capacity below 10 MW) which constitute most of the plants currently planned and under construction. Many of such plants, built in remote streams or rivers, or rivers with a small flow, are economically viable only because they benefit from state aid (Lange, 2019) - all the more if they are equipped with fish protection devices. Under the current EEAG, new hydropower plants can benefit from state aid as long as they are in line with the Water Framework Directive and the conditions set out in its article 4(7). But this safeguard has not prevented state aid from being approved for many harmful projects, including in pristine or protected areas. It has to be noted in that regard that the EEAG does not include any direct reference to the Birds and Habitats Directive. In addition, small hydropower plants (like other renewable small installations) benefit from two exemptions under the current EEAG: plants producing less than 1 MW are exempted from tendering procedures, and plants producing less than 500 kW can still receive feed-in tariffs (while for larger plants aid should be granted in the form of a market premium, additional to the market price). This has fuelled the development of micro-hydropower plants that make a negligible contribution to renewable electricity generation, have a very poor funding efficiency, and yet are adding to the already large fragmentation of European rivers. The fact that hydropower development is promoted under the EEAG stands in the way of the implementation of the Water Framework Directive and the EU Biodiversity Strategy commitment to restore free-flowing rivers. Moreover, it is not cost effective as the fitness check on state aid modernisation showed that contrary to solar and wind, the amount of aid/kWh for hydropower has increased between 2014 and 2019. While we agree with the conclusions of the fitness check on state aid modernisation that “the EEAG [...] should be revised to better accompany the Green Deal in all its facets”, we ask hydropower facilities to be no longer eligible for state aid, both feed in tariffs (still allowed for plants below 0.5 MW), and other types of aid. This should at the very least apply to the construction of new hydropower plants. If some state aid to hydropower was to remain, then it should only finance either the ecological and technical improvement of existing hydropower plants if they are already in line with the minimum ecological requirements imposed by the legislation (WFD, Birds and Habitats directives, EIA, SEA, taxonomy), or their decommissioning. This should also apply retroactively to state aid schemes approved before the revision of the EEAG. In line with the cost-recovery and polluter pays principles, the responsibility to mitigate any deterioration to the water body should be borne primarily by hydropower companies, and state aid should be limited to complementing the efforts needed to achieve the environmental goals.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

10 Dec 2020 · Hydropower development and fit for 55 package

Response to Green Recovery for the Blue Economy (tentative)

7 Dec 2020

The European Green Deal provides an opportunity for the EU to lead by example and further shape the global economic, environmental and ocean governance agendas. The sustainable blue economy (SBE) roadmap must foster a transparent and integrated approach and a transformation of the marine and coastal economy to ensure long term social and economic benefits by placing environmental sustainability and inclusivity at the heart of decision making. Not least, it must ensure that future financing of the sustainable blue economy supports sustainable development pathways. It needs to be developed in a way that underpins the achievement of SDGs and the implementation of the Paris Agreement and the CBD biodiversity targets. It should also have targets and indicators based on best available science and an adequately resourced monitoring plan to support the effective implementation of the strategy. Attached is a concise list of elements that the roadmap must address to promote this transformation, outlining key priorities relating to (i) the process for sustainable blue economy planning; (ii) the financing of a sustainable blue economy and (iii) the protection of marine and coastal ecosystems and biodiversity.
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Response to Protecting biodiversity: nature restoration targets

1 Dec 2020

Habitat fragmentation, loss and degradation as a result of land and sea use change, through agricultural intensification, grey infrastructure developments, overfishing or intensified forestry is widespread. Further drivers of biodiversity loss, such as the over-exploitation of natural resources both on land and at sea, the effects of the climate crisis, pollution and invasive alien species also contribute to the decline of nature and nature’s contribution to people. Action is needed to bring back ‘high-quality’ nature by restoring degraded ecosystems to enable nature to recover and to improve the health and resilience of our ecosystems. WWF therefore welcomes the commitment in the 2030 EU Biodiversity Strategy to put forward a proposal for legally binding EU nature restoration targets. We have a 10 year window of opportunity to curb the negative trends. It is therefore important that the restoration law is compact, targeted and directly actionable in order to quickly lead to significant improvements. Trying to cover everything, including soil health, cropland and urban ecosystems is not going to be effective. In addition, trying to combine the objective to restore degraded ecosystems with ensuring the sustainable use of ecosystems will not bring the most added value. Other policies and legislative tools, like the CAP need to be reformed, and others like the CFP need to be better implemented to achieve sustainable use of ecosystems. In addition, it is clear that legally binding targets are necessary, as the voluntary commitment to restore 15% of degraded ecosystems in the 2020 biodiversity strategy has not delivered. The new law should be additional to the relevant EU Directives so as to not undermine or duplicate existing obligations that include restoration requirements. The legislation must explicitly go beyond what is already required by the Habitats Directive and other EU legislation (BD, WFD, MSFD). Restoration measures should also not be used to offset ecosystem degradation or habitat loss taking place elsewhere. The restoration law should create synergies between the biodiversity and climate crisis by putting a specific focus on biodiverse ecosystems with significant carbon storage and climate adaptation potential. Examples of such ecosystems include: forests, peatlands, floodplains, free-flowing rivers, wetlands, biodiversity-rich grasslands, coastal areas and marine ecosystems. Nonetheless, the primary objective of the law should remain on tackling biodiversity loss. The law should also enable the restoration of biodiverse ecosystems with lower carbon storage potential given their important contributions to biodiversity and ecosystem resilience. In addition to major biodiversity and climate mitigation and adaptation benefits, restoration activities also provide social and economic benefits such as sustainable jobs for local communities or recreation opportunities, and can contribute to our overall health and wellbeing. The restoration law should lay the groundwork for activities developed in conjunction with local stakeholders. The legislation should take measures to avoid increasing pressure on local livelihoods and take into account existing social dynamics. Investments in restoration activities and in avoiding land degradation generally exceed by far the costs. There is a clear case for restoration activities from an ecological, climate, social and economic perspective. The restoration targets should be to restore by 2030: 1. at least 650.000 km2 of land and at least 1.000.000 km2 of sea (15% of the EU land and sea area); 2. at least 25.000 km of free flowing rivers, and to scale-up this ambition to achieve 15% of rivers restored to a free-flowing state in 2030 through inter alia barrier removal and floodplain restoration; 3. include a target for CO2 removal by sinks, in addition to the 2030 emissions reduction target. These targets would need to be reached both at EU level and Member State level.
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

WWF fully supports strengthening the LULUCF Regulation in order to incentivise the substantial increases in carbon dioxide removal through the restoration of forests and other ecosystems that are urgently needed to limit global temperature rise to1.5°C. However WWF strongly opposes the suggestion that this be achieved by facilitating offsetting with the ESR or ETS sectors. Such an approach does not reflect the clear scientific evidence that removals in the land use sector are not as measurable, stable or permanent as emissions reductions in other economic sectors and cannot be considered interchangeable with them. It also ignores the serious deficiencies highlighted by NGOs (https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12247-Commission-Delegated-Regulation-amending-Annex-IV-to-the-LULUCF-Regulation/F552669) in the EU’s forest carbon accounting rules and risks delaying the emissions reductions in other sectors. The EU should instead set a separate and demanding target for removals in the land use sector, consistent with the ecosystem restoration approach set out in the biodiversity strategy, and keep non-CO2 emissions from agriculture within the scope of the ESR. Finally, the Commission does not appear to recognise the potential conflict between increasing carbon sequestration in soils and landscapes and increased extraction of biomass for energy or other purposes. For example no evidence is provided for the assertion that increased wood use in construction delivers climate benefits and should be better incentivised, which is worrying given the serious concerns on this issue that have been raised by scientists (https://www.documentcloud.org/documents/6889670-Scientist-Letter-to-Congress-8May20.html).
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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

The missing “Option zero”: keeping the existing climate architecture and strengthening the ESR WWF does not support any of the options described by the Commission and instead calls for the current scope of the ESR (including transport, buildings and agriculture) to be maintained and national targets to be increased in line with the new 2030 target. The ESR has proven to be an efficient tool to incentivise climate action: - At national level, the targets have been an important driver of domestic investment in things such as charging infrastructure, low emission zones and building renovation and have led to effective taxation reform in some countries. - They have also led to Member States supporting strong EU regulatory measures (e.g. CO2 standards) that facilitate their achievement. Both of these would be at risk if the ESR were repealed and doing so is therefore completely unacceptable. The EU should instead strengthen the regulation, by: - Scrapping the existing ‘flexibility’ mechanisms that allow the use of ETS allowances and (highly uncertain) LULUCF credits; - Strengthening the governance and compliance framework by including more transparent annual carbon budgets, fines and annual checks. - Creating a joint projects platform with the help of e.g. the EIB. As regards the options described by the European Commission, WWF’s views are as follows: - Under no circumstances should the ETS be extended to buildings and road transport. These sectors exhibit weak demand elasticity and such a move would likely deliver very little in the way of emission reductions while shifting the burden of the climate transition onto low income households – something that is not in the spirit of the European Green Deal and risks provoking a huge and unnecessary backlash. - Methane and nitrous oxide emissions from agriculture must remain part of the ESR. Including them in the LULUCF sector would reduce incentives for their reduction and, as recent wildfires have shown, removals in the land use sector are not stable or permanent and cannot be considered interchangeable with emissions reductions.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

WWF fully supports the revision of the EU ETS Directive in line with an increased 2030 emissions reduction target. Emissions from EIIs have been stagnating since 2012 (see recent European Court of Auditors https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=54392). Carbon pricing can drive deep reductions in the Energy Intensive Industries (EIIs) only if it ensures that the negative externalities of carbon emissions are fully reflected in the price of pollution. In order to strengthen the current carbon pricing framework, avoiding stranded assets tomorrow, and guarantee an EU ETS that is fit for purpose (i.e. delivers its share of emission reductions by 2030 and the full decarbonisation of the sector in the longer term) the reforms proposed by the European Commission must respect the following key principles: - The pace at which pollution is reduced annually must increase (an increase of the Linear Reduction Factor while rebasing the cap by 2023); - The Market Stability Reserve (MSR) must be strengthened; - Carbon leakage risk tiering must lead to reduced free allocations (ultimately moving to 100% auctioning and smart revenue reinvestments). Polluting for free in times of a crisis is unacceptable. - If a CBAM is implemented, free allocations must be immediately and completely phased-out to avoid windfall profits - 100% of EU ETS revenues must be spent on Climate Action, including modernisation funds, industrial innovation, and redistribution to ensure a just transition. This WWF EPO report (https://wwfeu.awsassets.panda.org/downloads/strategic_spending___how_the_ets_can_fund_fair_climate_action_jan_2020_full_report.pdf) sets out how the EU ETS can fund a fair Climate Action. The use of EU ETS revenues should also be integrated into the delivery of strategic objectives and plans, such as the territorial just transition plans, national reform and investment plans and updated NECPs. These strategies and plans must in turn be developed openly and inclusively, in full respect for the Partnership Principle as defined by the European Code of Conduct on Partnership. - Any extension of the sectors covered under the EU ETS must be limited to shipping, the full integration of the aviation sector and the possible integration of municipal waste incineration (https://zerowasteeurope.eu/wp-content/uploads/edd/2019/09/ZWE_Policy-briefing_The-impact-of-Waste-to-Energy-incineration-on-Climate.pdf). Under no circumstances should the ETS be extended to road transports & buildings (https://www.transportenvironment.org/sites/te/files/publications/Joint%20letter%20on%20road-building%20ETS%20-%20December%202019%20%281%29.pdf). In addition, the European Commission must push for decarbonisation of EIIs and build a successful low carbon industry in the EU by developing a strong EU Industrial policy (https://wwfeu.awsassets.panda.org/downloads/a_new_european_industrial_strategy___cmw_and_wwf_10_asks_final_march_2020.pdf) that goes beyond reforming the EU ETS (as this alone won’t drive the full decarbonisation of the EIIs) and contain the following measures: a strong public innovation policy targeted towards market introduction of low carbon technologies through a robust innovation fund, develop contracts for difference or alternative measures (subsidies to mitigate investment risk and support heavy industries dealing with higher operational costs of low carbon technologies) Footnote: as a protection against carbon leakage effects and higher costs, EIIs received free allowances under the Emissions trading scheme. While the power sector, which must purchase its allowances, has decarbonised steadily year after year, industrial emissions have stagnated since 2012. A recently published report by the European Court of Auditors (see link above) concluded that the current EU ETS free allocation system did not provide an incentive to the EU Industries to be decarbonised.
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

26 Nov 2020 · Sustainable finance priorities

Meeting with Estelle Goeger (Cabinet of Commissioner Paolo Gentiloni)

13 Nov 2020 · Sustainable Development Goals

Meeting with Pascal Canfin (Member of the European Parliament) and Greenpeace European Unit

12 Nov 2020 · CAP

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Landowners' Organization asbl

10 Nov 2020 · European Green Deal, agriculture and the 3 billion trees initiative

Meeting with Charlina Vitcheva (Director-General Maritime Affairs and Fisheries)

10 Nov 2020 · Presentation of WWF's work, their priorities for the Mediterranean and cooperation with DG MARE

Response to Sustainable corporate governance

4 Nov 2020

"In the Action 10 of its Action Plan, the Commission committed to assess “(i) the possible need to require corporate boards to develop and disclose a sustainability strategy, including appropriate due diligence throughout the supply chain, and measurable sustainability targets; and (ii) the possible need to clarify the rules according to which directors are expected to act in the company's long-term interest”. WWF was pleased to see the Commission’s commitment to publish a much-needed legislative initiative in Q1 2021. We were also pleased to see the Commission’s commitment to review the Non-Financial Reporting Directive at the same time. It is important to ensure consistency among these two initiatives. As indicated in the Commission study on due diligence in the supply chain, it is high time to move beyond mere corporate disclosure and bring in changes to EU company law that can systemically change corporate behavior and strengthen corporate accountability. WWF specifically recommends the following: 1. In order to counteract the pressures imposed on directors by financial markets to maximise short-term shareholder value, increase director accountability and ensure a proper consideration of corporate long-term interests and sustainability risks: a) Directors should be subject to a legally binding obligation to develop, disclose and implement, on behalf of the company, a forward-looking corporate sustainability strategy that identifies and addresses material environmental and social issues and significant impacts connected to the company’s business model, operations and supply chain. b) Directors should identify and set as part of the business strategy, measurable, specific, time-bound and science-based sustainability targets aligned with overarching public goals (such as the goals of the Paris Agreement on climate change) relevant to the company’s business model, and time-bound transition plans to implement them. c) In order to ensure that the strategy covers the most relevant matters, the law should specify a minimum, sector-specific set of issues and public objectives that should be addressed. d) A specified, significant percentage of the KPIs and remuneration of executive management should be linked to the achievement of the targets set in the company’s sustainability strategy e) Remunerating executives with company’s shares should be discouraged and regulated in order to remove incentives to focus on short-term strategies to maximise share price such as share buy backs and paying excessive dividends at the expense of company’s economic health and ability to invest across all types of capitals needed for its success and sustainability. 2. New horizontal legislation on mandatory human rights and environmental corporate due diligence: strong EU rules should help ensure robust, resilient and sustainable value chains and investments by requiring that all companies in all sectors, including finance, address the environmental, social and governance risks they cause, contribute or are directly linked to. It is necessary in particular to implement the ‘do no harm’ oath of the European Green Deal, as well as ensure that there are liability rules for harm arising out of human rights and environmental abuses. Rules should ensure that due diligence processes be developed and conducted, at all stages, with full involvement of all rights- and stakeholders, including trade unions, civil society and women’s organisations, human rights defenders and indigenous peoples. Rightsholders throughout global value chains must, crucially, have meaningful access to remedy, backed by effective grievance frameworks and including judicial remedy before EU Member States’ courts. The work on this new horizontal legislation is very complementary to the process led by DG ENV on “Minimising the risk of deforestation and forest degradation associated with products placed on the EU market” – both approaches are necessary and should be kept separate."
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Meeting with Pascal Canfin (Member of the European Parliament) and Positive Money Europe

3 Nov 2020 · Green finance

Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

The latest State of Nature in the EU report found out that pollution of air, water and soil from different origins affects most habitats, particularly in the Atlantic and Continental regions. We believe the zero-pollution action plan should: • Include as a central instrument the large-scale deployment of nature-based solutions (NbS) as a systemic solution to tackle air, water and soil pollution. Despite growing evidence of nature’s ability to filter pollutants harmful to human health and to natural ecosystems, in addition to providing various co-benefits for biodiversity, climate adaptation, climate mitigation, well-being, the current policy framework has been insufficient to deliver a proper uptake of NbS. In rural areas, NbS can address diffuse pollution of water coming mainly from agriculture as they can remove nutrients through biological processing and reduce runoff. Green interventions in the landscape also address degraded soil and can contribute improving both soil quality for agriculture and biodiversity conservation. In those areas, the action plan should foster and support the integration of NbS in farmlands (constructed wetlands or small ponds, or riparian buffers along streams) and along rivers (reconnection of rivers to their floodplains). For that, the action plan should make use of different policy instruments and processes available (CAP strategic plans, measures on restoration foreseen under the Biodiversity Strategy, Common Implementation Strategy process under the Water Framework Directive) to set targets or incentives for the uptake of NbS under each of those instruments. In urban areas, sustainable urban drainage systems such as retention basins, filtering strips, filtering canals, vegetated canals, planted retention areas, ponds can also reduce water pollution from storm water overflows and urban runoff. Such solutions also contribute to the reduction of air pollution. ● Improve policy coherence, especially with industrial policies. The European Commission should review the Industrial Emission Directive (IED) to include greenhouse gas performance standards and introduce binding energy efficiency standards based on the best in-class solutions within a given industrial activity. Besides, the current development of the hydrogen economy as envisaged by the EC represents a significant potential impact on water and land resources. Sustainability criteria must be put in place. For instance, the WWF water-risk filter could be used for choosing a site to host electrolysers, in order to not increase the water-stress and already existing biodiversity hotspots. In the field of water, the action plan should also deliver on the revision of the lists of pollutants affecting surface and groundwaters under the EQS and groundwater Directive, as recommended by the conclusions of the 2019 Fitness Check of EU Water legislation. ● Have as a key principle tackling pollution at source. Implementing and enforcing the ‘polluter pays’ principle and enhancing the responsibility of polluters is a priority. In the area of water, the Commission should require Member States to make sure water taxes and tariffs reflect the polluter/ user pays principle to drive change in the behaviour of users and polluters. ● Outline specific measures to strengthen implementation and enforcement of existing legislation, especially in policy areas where implementation is the lowest, such as the Water Framework Directive. In this field, the Commission should screen the third River Basin Management Plans to be developed by Member States by the end of 2021, and ask Member States to revise any plan which would not contain guarantees that surface, groundwater, transitional and coastal waters will be in good status by 2027, including reviewing the use of exemptions. Regarding enforcement, the European Commission should set itself targets on the reduction of the number of pending complaints and infringement proceedings linked to pollution.
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Meeting with Pascal Canfin (Member of the European Parliament) and Fédération Nationale des Syndicats d'Exploitants Agricoles

19 Oct 2020 · CAP

Meeting with Frauke Hoss (Cabinet of Vice-President Maroš Šefčovič) and EUROPEAN TRADE UNION CONFEDERATION and Naturschutzbund Deutschland e.V.

14 Oct 2020 · Better Regulation Agenda

Meeting with Janusz Wojciechowski (Commissioner) and

13 Oct 2020 · CAP reform and Farm to Fork Strategy.

Meeting with Pascal Canfin (Member of the European Parliament) and Greenpeace European Unit

12 Oct 2020 · CAP

Meeting with Iratxe García Pérez (Member of the European Parliament)

7 Oct 2020 · The Recovery and Resilience Mechanism

Meeting with Pascal Canfin (Member of the European Parliament)

29 Sept 2020 · Green Deal

Meeting with Pascal Canfin (Member of the European Parliament) and Climate Action Network Europe

24 Sept 2020 · Climate law

Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen), Renaud Savignat (Cabinet of Commissioner Jutta Urpilainen) and

23 Sept 2020 · Making the European Green Deal work for International Partnerships

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

WWF welcomes the fact that the Commission has recognised that REDII is not consistent with the achievement of the EU’s 2030 GHG target or with the goals of the Paris Agreement and needs to be reformed. The points within the legislation that need urgently to be amended are as follows: - The 2030 RES target needs to be increased to at least 50% in order to be consistent with the goals of the Paris Agreement; - The rules on bioenergy need to be completely revamped, in order that they only incentivise those types of bioenergy that are likely to deliver significant, near term reductions compared to fossil fuels. Specifically, and in the absence of bioenergy emissions being accounted for at the point of combustion, the EU should phase out all incentives for purpose-based biofuel or energy crops and for the burning of tree trunks and stumps. - Other renewable fuels should only be incentivised under the RED where they are produced from fully renewable, excess renewable electricity and do not rely on a fossil source of carbon in any way. - We recognise that increasing offshore renewable energy production will be an essential part of the future energy transition towards a resilient and fully decarbonised economy. But it is crucial when developing offshore renewables that an integrated approach be adopted, that marine space be used carefully, and that ocean resilience be supported by staying within ecosystem boundaries. On this basis, and as a first principle, future renewable energy developments should not be placed within Marine Protected Areas (MPAs) and other ecologically valuable areas for sensitive species and habitats and/or that provide climate refugia. In countries where renewable energy projects already lie within MPAs or are at the stage of having an environmental impact and appropriate assessment carried out, the environmental impacts of these projects should be robustly assessed on a science-based case-by-case basis according to the relevant nature conservation legislation, and be subject to the precautionary principle. - A ban should be introduced on the development of any new hydropower within the EU. New hydropower would provide negligible benefits in terms of power sector decarbonisation, but with freshwater migratory fish populations having collapsed by a catastrophic 93% in Europe since 1970, and dams, weirs and other barriers being amongst the key drivers, the development of greenfield hydropower is incompatible with the Biodiversity Strategy proposal and its commitment to restore free-flowing rivers. Incentives and investment should instead be moved into the refurbishment of existing plants to lessen their impact on biodiversity, or to low-cost, low carbon, low-impact alternatives, such as appropriately sited solar and wind power.
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Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

18 Sept 2020 · Exchange of views on High Nature Value Farming

Meeting with Charlina Vitcheva (Director-General Maritime Affairs and Fisheries) and ClientEarth AISBL and

16 Sept 2020 · Workings of the Advisory Councils

Meeting with Anthony Agotha (Cabinet of Executive Vice-President Frans Timmermans), Damyana Stoynova (Cabinet of Executive Vice-President Frans Timmermans), Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and

9 Sept 2020 · The Green Deal implemetation with view to external relations

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

8 Sept 2020

More concretely, WWF believes that the Commission’s Delegated Act on taxonomy-related disclosures by undertakings under the NFRD should follow three objectives: 1. The first objective is to ensure that all undertakings under the NFRD scope disclose their contribution to each of the six taxonomy objectives, and specify the type of activity it relates to (own performance, transition or enabling). Indeed, the Article 8 requires companies to disclose “information on how and to what extent the undertaking’s activities are associated with economic activities that qualify as environmentally sustainable under Articles 3 and 9 of this Regulation”. It is critical that the EC builds on this requirement “on how and to what extent”, in order to ensure a level of corporate disclosure that will enable financial market participants to comply with their own taxonomy disclosure requirements as per Articles 5-7 of the TR. It should be noted that companies will have to reach this level of granularity in all cases to measure their total taxonomy exposure, so disclosing it does not create any additional burden to companies. We also recommend to disclose specifically when activities of the company contribute to several objectives of the taxonomy, to ensure this relevant information is made public but avoid risks of double counting. Finally, the total (aggregated) taxonomy exposure should be disclosed. Companies should specify their exposure in euro and in percentage of their total activities. Please find our recommendation of template attached. 2. The EC should clarify specific indicators for financial institutions, as banks and listed insurance companies are in the NFRD scope and indicators for undertakings are not appropriate for FIs. We recommend the following indicators (similar to the ones proposed by the TEG in its final climate disclosures’ report) – [more in the attached document]: General: • Total amount (in M€) and share (in %, compared to total exposures) of financial assets funding / invested in environmentally sustainable economic activities according to the EU taxonomy or Total amount (in M€) and share (in %) of products and services deemed as environmentally sustainable according to the EU taxonomy, broken down by business line and by environmental objective (inspired by GRI-G4). Lending activities and investment activities (retail banks and corporate investment banks): • Total amount and share (in %) of the fixed income portfolios invested in green bond certified according to the EU Green Bond Standard if and when this standard is approved, or according to any other broadly recognised green bond framework, at year-end, divided by a 5-year rolling average of total amount of holdings in fixed income portfolios. Insurance: • Breakdown of underwriting exposure to environmentally sustainable activities according to the EU taxonomy, by lines of business to economic sectors (life / non-life / reinsurance). • Value (in M€) and share (in %) of underwriting products offered, related to environmentally sustainable activities (Non-life / reinsurance). 3. The third objective is that the EC should start assessing and developing an ‘unsustainable’ taxonomy, that is currently missing but called for explicitly by the ECB, all the ESAs, the NGFS, etc. The TR will be reviewed in 2021 in order to assess the possibility of developing such an unsustainable taxonomy, which will fully align with this requirement. In particular, the Article 17 of the TR on economic activities that significantly harm environmental objectives provides a foundation for this much-needed expansion of the taxonomy to cover unsustainable activities. Taxonomy disclosure will have to expand accordingly and enter into application as soon as the unsustainable taxonomy is developed technically by the Platform on sustainable finance.
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Meeting with Pascal Canfin (Member of the European Parliament)

8 Sept 2020 · Green Deal

Response to Revision of the Urban Wastewater Treatment Directive

20 Aug 2020

WWF EPO welcomes the revision of the Urban Waste Water Treatment Directive (UWWTD) and its objective of strengthening existing EU legislation for reducing the adverse effects of waste water and making the existing legislation fit for decades to come. We believe that sewage is one of the most widespread and ecologically damaging source of pollutants in the EU, and also the area where EU water legislation (UWWTD in conjunction with the Water Framework Directive) has had the greatest impact. Point source pollution, mainly from urban waste water discharge, is an important pressure on surface water bodies and therefore a more ambitious UWWTD will support the achievement of the Water Framework Directive (WFD)’ objectives. We support the Commission’s choice to address storm water overflows and untreated surface runoff as part of the policy options. Indeed, the UWWTD evaluation report pointed out storm water overflows as one of the main pressures that the directive has not optimally addressed. In addition, forecasts suggest that even relatively small increases in the global average temperature will result in an increase in the frequency of intense and damaging storms and floods. While we agree with the inclusion of preventive measures in the list of policy options proposed to deal with existing challenges, we believe that promoting the use of green infrastructure and nature-based solutions should be at the heart of the revised directive. Nature-based solutions (NbS), ranging from small-scale solutions such as porous pavements, vegetated roofs, rain gardens and rain barrels which slow and retain runoff, to wider-scale solutions such as the construction of wetlands, grassy swales and detention basins integrated in the urban landscape, are efficient solutions to deal with overflows, instead of relying on hard infrastructure or technological solutions only. In addition to attenuating runoff for larger areas, those NbS have multiple benefits, as evidenced by WWF’s report on “Working with Nature to reduce climate risk in Europe” attached, pages 36-39) and are relevant to address both existing and emerging challenges described in the roadmap. As NbS also increase the overall resilience of urban environment and infrastructure to the impacts of climate change, benefits in terms of climate adaptation should be added to the list of environmental impacts of the policy options. We agree with the Commission that revised and new EU fixed objectives are necessary policy options to to deal with existing, but also emerging sources of pollution. In particular, we urge the European Commission to introduce a wider-reaching definition of sensitive areas within the UWWTD in order to better protect the most vulnerable freshwater ecosystems and to improve alignment with the WFD. In particular, the revised directive should require Member States to introduce tertiary sewage treatment to protect especially vulnerable bathing, shellfish and nature areas. The revised directive should also address the vagueness definition of agglomerations and damaging sewage pollution from small settlements that are not fully covered by the UWWTD.
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Response to Offshore renewable energy strategy

13 Aug 2020

According to the latest science, the world is on a sinister course for an increase in global average temperature of over 3°C by 2100, with catastrophic consequences for human and natural life. To limit global temperature increase to 1.5°C as set in the Paris Agreement, the EU must reach climate neutrality by 2040, thereby eliminating fossil fuels and achieving a 100% renewables-based energy mix as soon as possible. The EU 2030 climate and energy targets are insufficient to meet this objective and so the European Commission’s offshore renewable energy Strategy should announce a revision of the Renewable Energy Directive by 31 June 2021. The Communication ‘A Clean Planet for all’ recognises that increasing offshore renewable energy production will be an essential part of the future energy transition towards a resilient and fully decarbonized economy. Huge efforts are needed to set up the enabling conditions at EU level for increasing substantially renewable energy capacity during this decade. The strategy should aim to encompass and distinguish between all forms of offshore energy production, such as offshore floating wind power and offshore floating solar power, which will require different regulatory approaches both in terms of environmental impact as well as financial support for innovation and deployment. The Strategy must also recognize the importance of regional cooperation and planning at a sea-basin scale and propose the establishment of regional High Level Groups based on the North Sea Energy Cooperation example for the Baltic Sea, the Black Sea and the Mediterranean Sea. Given the limited sea space and the electricity-intensity of hydrogen, priority should be given to direct electrification with renewables and shifting away from gas. Both onshore and offshore renewable hydrogen shall only be produced from a surplus of renewables capacity. The clean transition is overall expected to be positive for jobs, and the Strategy must ensure that renewable value chains such as the manufacturing of offshore renewable infrastructure, benefit regions which have been negatively impacted by the transition. Climate change will increasingly pressure the ocean, its ecosystems, and the services it provides to our societies. European seas already count amongst the most intensively used in the world and fail to reach Good Environmental Status and effective spatial protection targets. When developing offshore renewables, it is crucial to adopt an integrated approach, use marine space carefully and support ocean resilience by staying within ecosystem boundaries. As a first principle, future renewable energy developments should not be placed within Marine Protected Areas (MPAs) and other ecologically valuable areas for sensitive species and habitats and/or providing climate refugia. In countries where renewable energy projects already lie within MPAs or are at the stage of having an environmental impact and appropriate assessment carried out, the environmental impacts of these projects should be robustly assessed on a case-by-case basis according to the relevant nature conservation legislation, science-based and subject to the precautionary principle. Offshore renewables development must be included in ecosystem-based marine spatial plans factoring the cumulative impact assessments of other human activities on both national and regional scales, guided by sensitivity mappings and based on a participatory approach considering socio-economic factors. It must be complemented with a robust and independent monitoring of impacts, favor best-proven technologies and be accompanied by broad-scale research into new technologies to address any adverse impacts on ecosystems. Finally, the Strategy should be developed in alignment with a coherent and accelerated action plan for marine conservation and restoration, delivering on existing European and international conservation objectives and creating further carrying capacity for marine ecosystems.
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Meeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan)

22 Jul 2020 · EU-UK future trade relations, TPR

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

17 Jul 2020 · Coal Mayors’ Forum and scheduled activities

Meeting with Virginijus Sinkevičius (Commissioner) and

16 Jul 2020 · To discuss the fishing opportunities exercise for 2021, in particular for the Baltic Sea, as well as issues related to the Biodiversity Strategy.

Response to Integration of sustainability risks and factors related to alternative investment fund managers

6 Jul 2020

As mentioned in several NGO briefings on the next steps for the Sustainable Finance Action Plan, completing Action 7 ‘Clarifying institutional investors’ and asset managers’ More is definitely needed in these three aspects: • It is necessary to develop an overarching vision for what these clarifications are meant to achieve. Notably, the end-goal of how these duties should be developed must include a prominent role for responsible stewardship in linking the financial system with tangible changes in the real economy (i.e. investee companies). In this regard, several HLEG recommendations are not fully implemented yet; • Several pieces of legislation need to be amended to properly reflect investor duties, in addition to the Disclosure Regulation for investors; • Due diligence by investors needs to be a clear and robust requirement for all institutional investors. Disclosure of due diligence policies, while essential (including pursuant to the recently adopted Disclosure Regulation), is not enough alone to deliver the necessary comprehensive reform. The Commission’s amendments to Directive 2010/43/EU are also more comprehensively integrated than those in MiFID II and IDD. There are several relevant aspects that have been included there, but are missing in the Solvency II amendments for example. In amendment (3), related to Article 22, paragraph 3, the Commission mentions the following: “AIFMs shall retain the necessary resources and expertise for the effective integration of sustainability risks.” This is a relevant amendment that has not been added in other Delegated Acts (except for UCITS). There is a big gap regarding fund managers’ (among others, like financial advisers) sustainability expertise, so this is relevant to mainstream sustainability in the financial sector’s system. There is also a very interesting link to the Disclosure Regulation’s (EU) 2019/2088 requirements to principal adverse impacts, also because AIFMs are under the scope, but it is missing in Solvency II’s amendments. As WWF we believe the Commission needs to table a Level 1 legislative review in order to properly integrate sustainability-related risks, opportunities and impacts in this Directive. As sustainability issues are quite recent in EU financial legislation, many financial institutions will need more granular requirements as to how to actually assess their sustainability risks and impacts. Extra guidance is supposed to come from the ESAs, but until now we have been quite disappointed with the technical advice to the amendments in all the Directives and Regulations.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Regulation (EU) 2017/565)

6 Jul 2020

The European Commission has added in all the considered Articles ‘including any sustainability preferences’ (especially for the product governance obligations – Delegated Directive (EU) 2017/593) or ‘including his or her sustainability preferences/factors’ (in the Delegated Directive (EU) 2017/565 on organisational requirements and operating conditions for investment firms, Delegated Directive (EU) 2017/2358 and 2017/2359 on insurance distribution). Investment firms that provide financial advice and portfolio management should have more granular requirements in the Delegated Acts to recommend suitable sustainable products, ask the client for its detailed sustainability preferences and avoid conflict of interests. There should be a ‘do not harm’ principle applied to investment firms regarding sustainability, even beyond retail investors’ preferences. Reopening several regulations as from 2021-2022, also at Level 1, is necessary to ensure a consistent EU approach and to develop a robust framework. Six complementary issues need to be addressed: 1. Monitor whether financial advisers properly ask retail clients about their sustainability preferences, on the basis of the new MIFID II and IDD Delegated Acts. We believe that the ESAs should produce a template questionnaire to provide more granular guidance to financial advisers, in order to improve compliance and reduce risks of liabilities. 2. Disclose sustainability information in a clear, standardised and accessible manner to non-expert retail investors. For example, the climate temperature score of a given fund (showing whether the fund is aligned with a Paris-compliant 1,5°C or well below 2°C pathway, or is heading towards climate chaos above +4°C), with a thermometer-shaped indicator, should be systematically presented to retail investors. There are now tools in the market enabling such analysis. 3. Avoid greenwashing and risks of market abuse by establishing minimum standards for sustainably denominated funds, as recommended by the HLEG its in priority recommendation on retail investment: “The Commission should protect retail investors by preparing an analysis of minimum SRI standards, in line with the EU sustainability taxonomy, to be respected by manufacturers and targeting all funds — including managed mutual funds or equivalent investment vehicles bearing a sustainable denomination — provided they comply with UCITS. Such analysis could later on feed into the PRIIPs and potentially the UCITS V regulations.” 4. Ensure that the development of fintech, that will very probably play an increasingly important role in retail investment, can safely benefit retail investors to help them better identify which financial products best correspond to their sustainability preferences, e.g. through online robo-advisors and apps. 5. Require that ESG funds are systematically proposed as a default retail option, given the overwhelming majority of 70% or more of retail investors who want their money to be invested in a sustainable way, as found by many studies very consistently over the last years . 6. Ensure that remuneration/incentives of investment advisers are aligned with sustainability issues and they are regularly trained. Investment advisers should be prevented from setting financial incentives which go counter the development of sustainable investment products, (e.g. if the staff is incentivized to sell ‘business as usual’ investment products discarding sustainability issues).
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Response to Integration of sustainability risks and factors in relation to the business of insurance and reinsurance

6 Jul 2020

The European Commission’s amendments to the Delegated Regulation (EU) 2015/35 are better integrated in WWF’s view compared to those on MiFID II and IDD Delegated Directives. Solvency II needs to be further clarified and tightened in terms of sustainability-related risks, opportunities and impacts. The Commission has better remarked the sustainability-related risks side, but we are still struggling to see specific requirements on opportunities and impact, which are crucial in terms of sustainability integration in insurance-based investment decision making processes. What we are also missing in this Delegated Act is to at least mirror (and rather improve) the sustainability requirements of the prudential rules for banks (CRR/CRD) in Solvency II, notably the disclosure requirement of ESG-related risks. Solvency II should be amended as well to better integrate the growing risks of physical climate impacts and the lack of resilience of certain physical assets to climate disruption. This is a part that the Commission could definitely improve and make more granular and specific in this Delegated Act. The HLEG on Sustainable Finance specifically warned against using the broad concept of integration of ESG factors/ risks and rather recommended the ESAs to mandate the extension of the time horizon of the risk analysis in line with the time horizon of beneficiaries’ investments (See table on page 42 of the HLEG Final report). This would allow the risk analysis to capture all long-term, non-linear and non-cyclical risks (including any sustainability-related risks such as climate-related risks). This HLEG recommendation should have been reflected in the Commission’s amendments, as it is a key issue that can tackle short termism and sustainability materiality.
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Response to Integration of sustainability risks and factors in relation to insurance undertakings and insurance distributors

6 Jul 2020

The European Commission has added in all the considered Articles ‘including any sustainability preferences’ (especially for the product governance obligations – Delegated Directive (EU) 2017/593) or ‘including his or her sustainability preferences/factors’ (in the Delegated Directive (EU) 2017/565 on organisational requirements and operating conditions for investment firms, Delegated Directive (EU) 2017/2358 and 2017/2359 on insurance distribution). Investment firms that provide financial advice and portfolio management should have more granular requirements in the Delegated Acts to recommend suitable sustainable products, ask the client for its detailed sustainability preferences and avoid conflict of interests. There should be a ‘do not harm’ principle applied to investment firms regarding sustainability, even beyond retail investors’ preferences. Reopening several regulations as from 2021-2022, also at Level 1, is necessary to ensure a consistent EU approach and to develop a robust framework. Six complementary issues need to be addressed: 1. Monitor whether financial advisers properly ask retail clients about their sustainability preferences, on the basis of the new MIFID II and IDD Delegated Acts. We believe that the ESAs should produce a template questionnaire to provide more granular guidance to financial advisers, in order to improve compliance and reduce risks of liabilities. 2. Disclose sustainability information in a clear, standardised and accessible manner to non-expert retail investors. For example, the climate temperature score of a given fund (showing whether the fund is aligned with a Paris-compliant 1,5°C or well below 2°C pathway, or is heading towards climate chaos above +4°C), with a thermometer-shaped indicator, should be systematically presented to retail investors. There are now tools in the market enabling such analysis. 3. Avoid greenwashing and risks of market abuse by establishing minimum standards for sustainably denominated funds, as recommended by the HLEG its in priority recommendation on retail investment: “The Commission should protect retail investors by preparing an analysis of minimum SRI standards, in line with the EU sustainability taxonomy, to be respected by manufacturers and targeting all funds — including managed mutual funds or equivalent investment vehicles bearing a sustainable denomination — provided they comply with UCITS. Such analysis could later on feed into the PRIIPs and potentially the UCITS V regulations.” 4. Ensure that the development of fintech, that will very probably play an increasingly important role in retail investment, can safely benefit retail investors to help them better identify which financial products best correspond to their sustainability preferences, e.g. through online robo-advisors and apps. 5. Require that ESG funds are systematically proposed as a default retail option, given the overwhelming majority of 70% or more of retail investors who want their money to be invested in a sustainable way, as found by many studies very consistently over the last years . 6. Ensure that remuneration/incentives of investment advisers are aligned with sustainability issues and they are regularly trained. Investment advisers should be prevented from setting financial incentives which go counter the development of sustainable investment products, (e.g. if the staff is incentivized to sell ‘business as usual’ investment products discarding sustainability issues).
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Directive (EU) 2017/593)

6 Jul 2020

The European Commission has added in all the considered Articles ‘including any sustainability preferences’ (especially for the product governance obligations – Delegated Directive (EU) 2017/593) or ‘including his or her sustainability preferences/factors’ (in the Delegated Directive (EU) 2017/565 on organisational requirements and operating conditions for investment firms, Delegated Directive (EU) 2017/2358 and 2017/2359 on insurance distribution). Investment firms that provide financial advice and portfolio management should have more granular requirements in the Delegated Acts to recommend suitable sustainable products, ask the client for its detailed sustainability preferences and avoid conflict of interests. There should be a ‘do not harm’ principle applied to investment firms regarding sustainability, even beyond retail investors’ preferences. Reopening several regulations as from 2021-2022, also at Level 1, is necessary to ensure a consistent EU approach and to develop a robust framework. Six complementary issues need to be addressed: 1. Monitor whether financial advisers properly ask retail clients about their sustainability preferences, on the basis of the new MIFID II and IDD Delegated Acts. We believe that the ESAs should produce a template questionnaire to provide more granular guidance to financial advisers, in order to improve compliance and reduce risks of liabilities. 2. Disclose sustainability information in a clear, standardised and accessible manner to non-expert retail investors. For example, the climate temperature score of a given fund (showing whether the fund is aligned with a Paris-compliant 1,5°C or well below 2°C pathway, or is heading towards climate chaos above +4°C), with a thermometer-shaped indicator, should be systematically presented to retail investors. There are now tools in the market enabling such analysis. 3. Avoid greenwashing and risks of market abuse by establishing minimum standards for sustainably denominated funds, as recommended by the HLEG its in priority recommendation on retail investment: “The Commission should protect retail investors by preparing an analysis of minimum SRI standards, in line with the EU sustainability taxonomy, to be respected by manufacturers and targeting all funds — including managed mutual funds or equivalent investment vehicles bearing a sustainable denomination — provided they comply with UCITS. Such analysis could later on feed into the PRIIPs and potentially the UCITS V regulations.” 4. Ensure that the development of fintech, that will very probably play an increasingly important role in retail investment, can safely benefit retail investors to help them better identify which financial products best correspond to their sustainability preferences, e.g. through online robo-advisors and apps. 5. Require that ESG funds are systematically proposed as a default retail option, given the overwhelming majority of 70% or more of retail investors who want their money to be invested in a sustainable way, as found by many studies very consistently over the last years . 6. Ensure that remuneration/incentives of investment advisers are aligned with sustainability issues and they are regularly trained. Investment advisers should be prevented from setting financial incentives which go counter the development of sustainable investment products, (e.g. if the staff is incentivized to sell ‘business as usual’ investment products discarding sustainability issues).
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Response to Integration of sustainability risks and factors for undertakings for collective investment in transferable securities

6 Jul 2020

As mentioned in several NGO briefings on the next steps for the Sustainable Finance Action Plan, completing Action 7 ‘Clarifying institutional investors’ and asset managers’ duties still requires significant improvements, in particular on the following three issues: • It is necessary to develop an overarching vision for what these clarifications are meant to achieve. Notably, the end-goal of how these duties should be developed must include a prominent role for responsible stewardship in linking the financial system with tangible changes in the real economy (i.e. investee companies). In this regard, several HLEG recommendations are not fully implemented yet; • Several pieces of legislation need to be amended to properly reflect investor duties, in addition to the Disclosure Regulation for investors; • Due diligence by investors needs to be a clear and robust requirement for all institutional investors. Disclosure of due diligence policies, while essential (including pursuant to the recently adopted Disclosure Regulation), is not enough alone to deliver the necessary comprehensive reform. Given the increasing introduction of UCITS that claim to have sustainability criteria or impacts, regulation and supervision are needed to verify the claimed impacts. The Commission’s amendments to Directive 2010/43/EU are also more comprehensively integrated than those in MiFID II and IDD. There are several relevant aspects that have been included there, but are missing in the Solvency II amendments for example. In amendment (3), related to Article 5, paragraph 5, the Commission mentions the following: “Member States shall ensure that management companies retain the necessary resources and expertise for the effective integration of sustainability risks.” This is a relevant amendment that has not been added in other Delegated Acts (except for AIFM). There is a big gap regarding fund managers’ (among others, like financial advisers) sustainability expertise, so this is relevant to mainstream sustainability in the financial sector’s system. There is also a very interesting link to the Disclosure Regulation’s (EU) 2019/2088 requirements to principal adverse impacts, also because UCITS are under the scope, but it is missing in Solvency II amendments. As WWF we believe the Commission needs to table a Level 1 legislative review in order to properly integrate sustainability-related risks, opportunities and impacts in this Directive. As sustainability issues are quite recent in EU financial legislation, many financial institutions will need more granular requirements as to how to actually assess their sustainability risks and impacts. Extra guidance is supposed to come from the ESAs, but until now we have been quite disappointed with the technical advice to the amendments in all the Directives and Regulations.
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Meeting with Benoît Biteau (Member of the European Parliament, Shadow rapporteur)

24 Jun 2020 · PAC & Eau

Meeting with Pascal Canfin (Member of the European Parliament)

11 Jun 2020 · Green finance

Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen), Renaud Savignat (Cabinet of Commissioner Jutta Urpilainen) and

10 Jun 2020 · European Green Deal, COVID-19 and development cooperation

Response to A EU hydrogen strategy

8 Jun 2020

To achieve climate neutrality in line with IPCC requests and by 2040, it is clear that the phase-out of fossil fuel (including gas) in all sectors should start. Hydrogen should not be used as a trojan horse to promote gas infrastructure and business as usual. Hydrogen production powered by nuclear or gas should not be supported. Thus, Carbon Capture and Storage (CCS) deployment must be limited to process emissions for which there are no alternative mitigation options, considering its environmental and technological risks, as well as its high capital and operational cost. It should adhere to strict environmental and social safeguards. On the other hand, electrification of industrial processes, new data centres and targeted renewable hydrogen (powered by Solar and Wind) production will require a strong investment in additional renewable energy production. Hydrogen production by electrolysis is currently costly. The current cost of electricity produced by renewable energy sources is the main barrier to the deployment of the production of renewable hydrogen through electrolysis. Renewable hydrogen is expected to become more competitive than blue hydrogen only by 2035 in China. However, the production of renewable hydrogen should not compete with the production of renewable electricity that could be directly used to decarbonise key sectors such as heating and transport. Renewable hydrogen must therefore in any case use 100% additional renewable electricity. Over 95% of current hydrogen production is fossil fuels based, and not carbon-neutral. Production of renewable hydrogen is currently costly and resources are limited. Hence, support should be given only to funding for renewable hydrogen projects and infrastructures for sectors where emissions reductions is most difficult: hard-to-abate sectors like basic chemicals and steel, aviation, shipping and heavy good vehicles. Priority should be given to direct electrification with renewables and shifting away from gas where feasible (i.e transport and heating). Thus, it would be of most importance to prepare grid operators through an effective EU energy infrastructure planning to adapt their infrastructure to enable a swift transition to a 100% renewables supply. Given the current post-COVID 19 context, it is of most importance to not return to pre-COVID damaging and polluting economies. We need to think of it as helping a transformation to a cleaner, healthier and stronger industry, making net zero carbon and circular products in cleaner production processes, and providing sustainable jobs as pushed in both the Industrial Strategy and the Circular Economy Action Plan. Therefore, it is essential to build-up a no regrets scenario for future investments in renewable hydrogen deployment, excluding fossil-fuels investments lock-in. The upcoming EC Hydrogen Strategy should focuses on: • Support only funding for renewable hydrogen projects and infrastructures (excluding fossil fuels) • Give priority to domestic EU production of renewable hydrogen (from surplus of renewable electricity) • Define clear sustainability criteria and processes of import export which account for the carbon and environmental footprint of traded hydrogen • Develop a lead market in the EU for deployment of renewable hydrogen technologies before 2030 • Where technically feasible, electrification and energy efficiency should be given priority over hydrogen to decarbonise all sectors by 2040 (i.e. transport and heating) • Define targeted use of renewable hydrogen as resources will be limited to sectors which cannot achieve decarbonisation otherwise such as some Energy Intensive Industries (i.e steel and basic chemicals), aviation, shipping and heavy good vehicles • Build up the Clean Hydrogen Alliance in a transparent way, including civil society representatives in shaping the objectives and timeline of the future Clean Hydrogen Alliance Please, see attached WWF EPO statement on the upcoming Hydrogen Strategy
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Response to Union renewable Financing mechanism

3 Jun 2020

The Renewable Energy Financing mechanism should fully take into account the contribution of the supported renewable energy projects towards meeting environmental objectives. Only in such conditions can renewable energy develop rapidly and be considered as sustainable. Directive 2018/2001 on Renewable Energy states that “the coherence between the objectives of this Directive and the Union's other environmental law should be ensured.” However, the draft implementing act on the Renewable Energy Financing mechanism does not contain the necessary guarantees that the mechanism will only finance projects that are in line with the EU environmental legislation. In particular, recent research has shown the alarming surge in hydropower development in Europe, and its disastrous impact on the ecological status of rivers and freshwater biodiversity (WWF, RiverWatch, EuroNatur, GEOTA, Hydropower pressure on European rivers: The story in numbers, 2019, attached). Despite the EU being already saturated with more than 19,000 hydropower plants, over 5,800 additional plants are planned or under construction, 33% of which are located in protected areas. 91% of all those plants recorded by the study are small plants, which produce negligible amounts of energy (less than 10MW). The recently published EU Biodiversity Strategy has acknowledged that “greater efforts are needed to restore freshwater ecosystems and the natural functions of rivers in order to achieve the objectives of the Water Framework Directive”, and that “this can be done by removing or adjusting barriers that prevent the passage of migrating fish and improving the flow of water and sediments”. Member States are actually requested to review impoundment permits to implement ecological flows in order to achieve good status or potential of all surface waters and good status of all groundwater by 2027. In this respect, we recommend: ● Including in the Implementing regulation a requirement that projects financed by the mechanism must respect Directive 2000/60/EC (Water Framework Directive) and in particular Article 4(7) thereof, which lays down criteria in relation to allowing new modifications of bodies of water; the Environmental Impact Assessment Directive; the Strategic Environmental Impact Directive; and the Birds and Habitats Directives. This requirement should apply to the commitment by host Member States, the eligibility criteria established in the calls for proposals issued by the European Commission, the evaluation procedure for submitted projects, and the grant award procedure. ● Including in the Implementing regulation a requirement that selected projects should fall under national energy planning schemes and related safeguards. ● Including in the Implementing regulation a hydropower-specific requirement excluding greenfield hydropower projects from the Financing mechanism, considering their negative environmental impact. The Renewable Energy Financing Mechanism should only benefit hydropower projects consisting in the refurbishment of existing hydropower plants. ● Using the sustainable investment taxonomy criteria as eligibility criteria for all projects, and not only those receiving support from private sector contribution (recital 14). This is to ensure that any harmful spending which can originate from broad sector-level support is avoided. Hydropower projects also have a disastrous impact on communities, leaving riverbeds dry and local people with a sharp decrease in water available for irrigation/animals to drink/ recreational use. Therefore, we recommend: ● Including in the draft regulation information on how and when environmental, social and integrity due diligence will be carried out on the candidate projects, as well as mechanisms to ensure citizens’ access to environmental information and public participation in environmental decision-making, in line with the provisions of the Aarhus Convention.
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Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

25 May 2020 · Video call meeting - Farm to Fork Strategy Assessment Workshop with the Food Coalition

Meeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan)

13 May 2020 · EU-UK future relations - environment (+ Birdlife)

Response to Climate Law

30 Apr 2020

WWF EPO believes that the draft law contains a number of important omissions, particularly as regards the nearer term – something that has led to it being branded “surrender" by youth climate activists. An assessment of the draft law and the omissions it contains is attached. The draft legislation would require the European Commission to consider increasing the EU’s 40% emissions reduction target for 2030, but defers it to September 2020 and implies that any increase should be to no more than 50-55%. According to the latest UNEP emissions gap report, the world must now reduce greenhouse gas emissions by 7.6% each year if we are to limit the world’s global temperature increase to 1.5°C within the next decade – which translates roughly into a 65% climate target by 2030. Additionally, the draft law defers proposals on adjusting EU climate legislation to June 2021. It is also far from clear whether the law will prompt any changes in the next decade to EU policies that actively undermine climate goals, for example the billions spent supporting gas infrastructure, unsustainable levels of livestock production and types of bioenergy that increase emissions compared to fossil fuels. Finally, the draft law lacks an independent expert body to scrutinize and provide advice on climate policy-making; and it lacks strong provisions on public participation through participatory democracy and on access to justice.
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Meeting with Valdis Dombrovskis (Executive Vice-President) and

24 Apr 2020 · Economic recovery, sustainable finance taxonomy, EIB energy lending policy, Just Transition Mechanism, Industrial Strategy, Integrating SDGs in the European Semester

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

17 Apr 2020 · Sustainable recovery after Covid-19

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

17 Apr 2020 · Exchange of views on CAP and Green Deal

Meeting with Thierry Breton (Commissioner) and Transport and Environment (European Federation for Transport and Environment) and

15 Apr 2020 · Priorities for the Coronavirus recovery

Response to 2030 Climate Target Plan

14 Apr 2020

The Inception Impact Assessment on the 2030 climate target must align the EU’s climate efforts to a pathway compatible to limiting global temperatures to 1.5°C and to a just transition which leaves no one behind. The Commission’s impact assessment proposes to assess the impact of increasing the 2030 climate target from 40% to at least 50% and towards 55% in a responsible way. But the latest scientific evidence shows that this target range is clearly inadequate to limit global temperatures to 1.5°C as agreed by the European Union under the Paris Agreement. As the UNEP Emissions Gap Report 2019 makes clear, global emissions need to be cut by 7.6% per year, starting now, in order to limit global warming to 1.5°C. For the EU – even without taking into account equity-related issues such as per capita emissions or responsibility for historical emissions – this means a cut of 68% by 2030 relative to 1990 levels. WWF’s position is that the EU should be aiming to cut emissions by 2030 by at least 65%, and to review this target following the global stocktake under the Paris Agreement in 2023. WWF therefore calls for the Inception Impact Assessment to assess the impacts of increasing the 2030 EU GHG reductions target to 65%. Increasing the pace of decarbonisation in light of the Paris Agreement’s objective to limit global temperatures to 1.5°C is also in line with the principle of a just transition which leaves no one behind. Ensuring a just transition does not equate to slowing the transition nor reducing its ambition. Indeed, in many cases, higher ambition accompanied by a managed, supported and planned transition can bring more benefits to communities and the most vulnerable than by taking a slower route to climate neutrality. This is for 2 principle reasons: first, climate change most negatively impacts the most vulnerable and least able to adapt in society and second, a slower route locks communities into a longer, more costly transition. So-called bridging technologies such as fossil gas require significant investments which can take up to 30 years to be recuperated and the infrastructure is of little to no use in a fully-climate neutral system. The burden of the climate impacts and the costs of potentially stranded assets are paid by taxpayers rather than the polluters. When setting ambition, it is therefore essential to consider the need for decisive, substantial and consistent financing of investments to enable a faster and more direct transition. Investments in energy efficiency accelerate the transition and represent no regret solutions generating many jobs and simultaneously addressing energy poverty. Likewise, significant, early and direct support to renewables heating systems including notably by subsidising a direct switch from coal to heat pumps or other renewable heat sources will assist vulnerable and poorer communities and reduce the overall cost of the transition. A just transition means that the transition to climate neutrality leaves no one behind. Costs are equitably shared and benefits spread equally. Put another way, it means that inequalities do no increase, or may even be decreased by the transition. The costs of the transition should be considered over the long term and any public support should be targeted at no regret options in the transition that place the wellbeing and empowerment of people first.
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Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and Stichting BirdLife Europe

6 Apr 2020 · Better regulation and green deal implementation

Response to Carbon Border Adjustment Mechanism

31 Mar 2020

As WWF EPO, we wish to submit the attached statement to answer the inception impact assessment on the Border Carbon Adjustment Mechanism (BCA). Our main arguments are summarized below. 1) If introduced, the BCA must be implemented as an alternative to free allocation and within a wider set of policies to ensure the decarbonisation of industry 2) WWF EPO recognises that the BCA could play different catalyzer roles in contributing to EU’s industrial decarbonisation, and influence third countries to join the club, by: raising revenues, act as an incentive for trading partners to implement their own carbon pricing measures, and encourage current non-compliant third-countries partners to take action in complying with EU environmental norms & protections. 3) However, this highly depends on how the BCA will be designed and whether it will be based on the current carbon price. In the absence of an effective carbon price , the implementation of a BCA cannot guarantee that it will play an important role in driving the EU industry’s decarbonisation. Only with a significant and rising carbon price, a BCA could really encourage investments in low-carbon technologies both in the EU and internationally and potentially act on prices for commodities. In the current COVID-19 context, the carbon price is sinking and has reached its lowest levels since July 2018 (16 euros per tonne), and will barely recover in 2020. Stabilising the ETS price, at an effective level, seems to be a priority prior to implement any BCA. The fall of the EU ETS price will have an impact on public income from auctioning revenues and therefore on the funding of the Innovation fund. Measures to ensure that rapid carbon price falls are avoided need to be introduced for the phase four of the ETS (2021-2030). 4) Despite the implementation of a carbon leakage list by the European Commission (EC) for sectors qualified at risk, the evidence for the occurrence of carbon leakage as defined by the EU ETS Directive and due to its implementation has been extensively argued. Our diagnosis is that, in the absence of a significant carbon price, there is a risk of an investment leakage rather than a carbon leakage in Europe. 5) If a BCA is considered as an instrument to mitigate carbon leakage, its impact should be evaluate in a full assessment on all carbon leakage options in order to allow comparison between those options. 6) In designing a BCA, we ask that, such measure should: • Be designed and implemented as an alternative to free allocation of allowances in the ETS. A phase-in of BCA needs to be linked to phase out free allocation.The EC Communication on the European Green Deal is proposing the BCA as an alternative to free allocation. We support this proposal; • Be designed in a way that it would cover only energy-intensive sectors under EU ETS, mainly steel, cement, and basic chemicals; • Be part of a wider set of policies to enable and promote the investment in low carbon industrial processes, energy efficiency measures and renewable energies to achieve the decarbonisation of industry. The introduction of BCA is not the solution to tackle the lack of investment in low-carbon technologies. In order to build a successful low carbon industry within the EU, it is key to develop a clear policy framework containing the following measures: -a strong public innovation policy targeted towards market introduction of low carbon technologies, which will ensure investments in low carbon technologies through a robust innovation fund and exclude support for fossil lock-in technologies -contracts for difference or alternative measures such as subsidies to mitigate investment risks and support heavy industries dealing with the higher operational costs of low carbon technologies -obligation to purchase low carbon materials through public procurement and introduction of norms, quotas and standards for low carbon materials to create a lead market for low carbon technologies
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Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen) and Climate Action Network Europe and

26 Mar 2020 · international dimension of the European Green Deal

Response to Farm to Fork Strategy

15 Mar 2020

WWF strongly believes that a comprehensive transition towards sustainable food systems is needed to address some of the existential threats we face. Together with other civil society organisations, WWF-European Policy Office views the Farm to Fork Strategy as an important opportunity to deliver a coherent response to food-related challenges and pave the way towards an integrated, sustainable food policy for the European Union. The breadth of policy initiatives needed to transition to more sustainable food systems is very large, expanding beyond the core areas of work of WWF. Therefore this is a non-exhaustive piece of feedback on 10 key aspects where we find we can provide more valuable input. Find the list of items below, and a detailed response in the attachment. 1- Duration and governance of the Farm to Fork strategy. 2- Setting the direction of travel and using the CAP to deliver on the objectives. 3- Fertilisation, nutrients, water and climate. 4- Freshwater use for irrigation. 5- Farmland biodiversity. 6- Seafood and fisheries. 7- Food loss and waste. 8- EU’s food footprint abroad. 9- Less and better: healthy sustainable diets. 10- Financing the transition.
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Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

12 Mar 2020

The Just Transition Fund (JTF) and Mechanism (JTM) can, if well-designed – enable and even catalyse a just transition – but it can equally be a red herring if it allows fossil-fuel lock-in. To deliver, it must: 1) Require clear, ambitious timelines - including a pre-2030 coal phase-out Climate change negatively impacts the poorest most. To meet the Paris Agreement commitment to stay below 1.5°C, the EU must phase-out coal by 2030 (1) and accelerate its transition to climate neutrality. Member States failing to commit to EU climate neutrality goals should not receive JTF funds. TJTPs including clear and binding timelines increase investor certainty. They can accelerate the transition and reduce overall transition costs by incentivising investment. The example of the Ruhr in WWF’s paper (2) shows how uncertainty caused delay and increased cost: coal companies held onto land, preventing new, sustainable investments while coal was subsidised. TJTPs must underpin all JTM activities. A 2020 Spanish Court of Auditors report on use of regional transition funds underlines the need for strong administrative and technical controls, objectives and quality criteria for project selection (3). Arguably, the lack of such controls has led to the inefficient use of €1.7 billion. The development of TJTPs must be transparent and reflect the full application of the Partnership Principle (4). If local stakeholders and communities, including municipalities and civil society, are engaged in the transition process; plans will be better-informed and their implementation supported. 2) Ensure all public finance and policy support is aligned with the transition We welcome that the funding will be additional to the EU budget 25% climate mainstreaming. However, the current proposal does not reflect the transition speed targeted by the Member States or regions, nor whether existing public funds are coherently spent. E.g. from 2005 to 2016, Poland invested €18.8 billion in the coal industry, but only €5.42 billion in renewables (6). Moreover, of €13.9 billion in ETS revenues in 2018, €4.6 billion was not spent on climate action consistent with a just transition by Member States (e.g. home insulation/renewables) (7). Incoherent spending raises transition costs. Member States committing to faster fossil installation closure rates should thus be awarded higher JTF allocations. 3) Exclude fossil fuels and nuclear as inconsistent with just transition Fossil fuel investment is always inconsistent with just transition. By crowding-out investments which would permit regions to move directly to clean, sustainable solutions, it risks fossil fuel infrastructure lock-in, raising overall costs. It also sends incoherent signals to investors. Existing EU gas infrastructure is sufficient (8) and investment delays more sustainable investments in renewables, including in heating. Existing fossil infrastructure also already exceeds carbon budgets consistent with meeting the Paris Agreement goals (9). Nuclear is environmentally harmful, particularly as no long-term secure storage solution exists and it provides few jobs relative to investment. Recent reports also show it costs more and increases emissions relative to renewables (10). Including nuclear in a non-Euratom Regulation would set a dangerous precedent. Sources: 1.UNEP Emissions Gap Report 2019 2.Just Transition to climate neutrality – doing right by the regions (WWF, 2020) 3.Informe de fiscalización sobre las ayudas a la reactivación de las comarcas mineras 2006 – 2017 del tribunal de cuentas español (Spanish Court of Auditors, 2020) 4.Seven Golden Rules (Europe Beyond Coal, 2019) 5.Poles Apart (WWF, 2019) 6.Strategic Spending: the untapped potential of the European Emissions Trading System to fund climate action (WWF) 7.An updated analysis on gas supply security in the EU energy transition (Artelys, 2020) 8.Can the Climate afford Europe’s gas addiction? (FoE, 2017) 9.World Nuclear Industry Status Report 2019
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Response to Minimising the risk of deforestation and forest degradation associated with products placed on the EU market

2 Mar 2020

WWF EPO comments on roadmap: The 5 year assessment report of the New York Declaration on forests states that an area of tree cover size of the United Kingdom was lost every year between 2014-2018, with new hotspots emerging in Africa and highest losses still in Latin America: the average annual tree cover loss in the tropics between 2014 and 2018 led to 4.7 gigatons of emitted carbon – more than the whole of the EU carbon emissions in 2017. We welcome that the EU, as a leading market for agriculture commodities and products, wants to take action to address its footprint. To ensure a thorough assessment of policy options, we would like to provide the following feedback towards the EU roadmap: Seeing as an aim the minimization of the EU’s contribution to deforestation and forest degradation worldwide is very much welcome, however, this minimization will not be achieved by only “promoting” the consumption of deforestation-free products on the EU market. Measures taken by the EU should ensure that no products linked to deforestation, forest degradation, conversion of natural ecosystems or their degradation are placed on the European market, enabling the EU to fulfill their international commitments such as under SDG 15, UNFCCC or CBD. To achieve this, binding regulatory measures are necessary. Voluntary measures will not be able to reach out to the whole market and have failed until now: out of the of 350 most influential companies in forest risk commodity supply chains (covering palm oil, soy, cattle, timber and pulp and paper) analyzed by Global Canopy, 40% don’t have commitments and of the others none is on track to achieve their supply-chain commitments by 2020. The voluntary measures to be analyzed in the impact assessment should therefore be considered as complementing the development of new legislation but not replacing it. Concerning the preliminary assessment of expected impacts, we recommend to take into account the following points when carrying out the full impact assessment: Establish links with the EC Communication “Stepping up Action to Protect and Restore the World’s forests” is essential. Among its proposed actions, the communication includes a specific set of measures directed towards producer countries, which are complementary to the proposed policy options and should therefore influence the analysis of expected impacts. Likely economic and social impacts should not only address the potential negative but also the positive impacts, such as a level market playing field, better transparency especially for those companies further down the supply chain or more secure livelihood for smallholders through long-term contracts. Determining, whether a product is free from deforestation or ecosystem conversion should not be the responsibility of the consumer but that of governments. A poll from 2019 also showed that 87% of consumers polled in 25 EU Member States support regulatory measures. Likely environmental impacts should directly focus on forests and other ecosystems. Recent data shows that consumption of globally traded agricultural commodities like soy and palm oil is one of the primary causes of deforestation and biodiversity loss in some of the world’s most species-rich ecosystems. Therefore, EU action, including legislation, should also address other ecosystems, such as grasslands and savannahs. Likely impacts to fundamental rights should be directly addressed by EU measures and therefore be thoroughly analyzed in the impact assessment. Including human rights elements into EU legislative measures will support local and indigenous peoples. Likely impacts on simplification/administrative burden should not only focus on the policy option of due diligence but impacts for all policy options presented should be thoroughly assessed. This should include both negative and positive impacts and differentiate between the legal text/framework of the option and its implementation and enforcement.
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Response to Illegal logging – evaluation of EU rules (fitness check)

28 Feb 2020

WWF feedback The intention of both the EUTR and the FLEGT regulation is to fight illegal logging and related trade. A fitness check of the regulations therefore needs to address this overarching objective thoroughly and equally from an economic, social and environmental perspective. EUTR Apparently the fitness check will mainly focus on the implementation of the EUTR over the last years. We strongly recommend to also include an evaluation of the implications on whether and how the findings of the first evaluation of the EUTR in 2016 have been addressed such as the enlargement of the product scope, for which an impact assessment was started but where results still have not been presented. Analyzing the integration of recommendations previously made (or lack of integration) will help to put the fitness check into perspective. From our perspective, especially an enlargement of the product scope to cover all products is necessary. The fitness check should make a clear differentiation between the legal text and the application of the EUTR in practice across the EU Member States differentiating between the intention of the law and its enforcement. The application and implementation of the law at national level should be a main focus, including national legislation, methodology and quality of checks and prosecution as major shortcomings have been detected there. An assessment of efficiency of the interventions should not only determine the costs for companies or competent authorities but also include economic, social and environmental benefits of the legislation. FLEGT The fitness check needs to be linked to the EU FLEGT Action plan and its goals, which places particular emphasis on governance reforms and capacity building, cooperation and demand side measures. An assessment without keeping the overall goals of the Action Plan in mind could lead to conclusions not reflecting the overall framework of FLEGT. Also, experience with application of the legislation is limited as only one country has so far implemented the FLEGT licensing scheme. Concerning the different elements of the evaluation and related questions, we would like to make the following suggestions for additional questions: Effectiveness Have all recommendations from the first evaluation of the EUTR in 2016 been addressed by the European Commission or the EU Member States, including the assessment of enlarging the product scope? Clarify the existing question on meeting the objectives further: To what extent have environmental, social and economic objectives of the regulations been met? Are penalties applied at EU MS level proportionate, dissuasive and proportionate? Are the checks being carried out in EU MS supporting the achievement of the objective of the EUTR or the FLEGT regulation? Are checks and controls properly followed up and is there clarity about when to issue sanctions or notice of remedial action? Are substantiated concerns properly taken into account? Efficiency What were cost benefits for companies obtained from the application of the EUTR such as through levelling the playing field for companies, reduction of reputational risk or more transparency along supply chains? Coherence What actions did the European Commission undertake to ensure coherent implementation of the regulations across EU Member States? Are EU Member States providing efficient financial means to implement the laws in line with the commitment (acceptance of the regulations) they made to address the trade in illegal timber? Relevance In how far do the interventions help the EU to achieve international commitments such as the CBD, UNFCC or else? What environmental and social benefits have been obtained through the intervention until now and what benefits could still be obtained in the future? European Added value What is the European added value gained through a common approach towards illegal logging through trade measures and protecting the environment in Europe and beyond?
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

20 Feb 2020 · InvestEU regulation and green bond issuance programme

Meeting with Karolina Herbout-Borczak (Cabinet of Commissioner Stella Kyriakides), Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and

19 Feb 2020 · Sustainable food systems

Meeting with Daniel Calleja Crespo (Director-General Environment)

17 Feb 2020 · Nature restoration

Response to Revision of Non-Financial Reporting Directive

12 Feb 2020

WWF would definitely choose option 3. Sector-specific Key Performance Indicators (KPIs) Problem: The NFRD fails to provide any granular, sector-specific guidance as to what they should be trying to illustrate. Problematically, a ‘one size fits all’ approach does not work with sustainability indicators. Solution: The NFRD 2.0 should include identified mandatory sector-specific sustainability KPIs – as few and as strategic as possible – to ensure comparability between comparable companies or business models. Such KPIs at sector-level would complement not contradict a high-level standardized reporting framework for all companies. Title and format Problem: The title of the current legislation, ‘Non-Financial’, is inaccurate. There is ample evidence that some ESG-related risks are materially financial, or will become so in the short, mid or long term. Solution: The name of the new proposal should be: sustainability-related information. The sector-specific standardization of few KPIs mean that a Directive will not be the right format anymore: a regulation will be more relevant. Scope Problem: The Accounting Directive uses an average threshold of 250 employees, while the NFRD uses a 500: this is inconsistent and there is no meaningful justification about this difference. The NFRD narrows the scope to listed companies only, which is not meaningful: whether the company is listed or not is not a relevant factor about whether its sustainability risks and impacts are high or low, and whether the company manages and discloses them properly. Solution: The definition of 'large undertakings' in the NFRD 2.0 should be lowered to 250 employees.The NFRD 2.0 should apply to all large undertakings regardless if they are listed or not. In ‘high-risk’ sectors on specific ESG issues, all companies should report irrespective of their size. Such ‘high-risk’ sectors should be defined in an NFRD 2.0. delegated act. Flexibility and comparability Problem: To date, there is very limited harmonisation and standardization of sustainability reporting frameworks at EU level. This makes sustainability information difficult to compare and thus of limited interest and use for investment decision-making. The NFRD fails to recommend a common reporting framework. It includes a ‘comply or explain’ clause, which makes the reporting requirement weak. Solution: The NFRD 2.0 should set up a standardised high-level reporting framework wherever possible, and, where impossible at least a harmonized reporting framework (e.g. consistent with TCFD, SDGs, etc.). WWF supports the recommendation of the TEG final report with three reporting levels: in WWF view these three levels should be 1) ‘shall’ disclose’ (mandatory); 2) ‘should disclose’ (recommended); 3) ‘may disclose’ (additional). The ‘comply or explain’ clause should not apply to the first level of disclosure. Supervision and enforcement Problem: The NFRD is vague on the implications of non-compliance, as its transposition has created very uneven approaches depending on the Member State. Solution: The NFRD 2.0 should strengthen the requirements and guidance on monitoring and enforcement by public authorities. The Commission should periodically review reporting requirements to ensure their effectiveness based on monitoring and analysis of company reports (e.g. through the EFRAG Reporting Lab). Location of disclosure: Problem: The NFRD does not require the non-financial statement to be part of the annual report. Solution: Integrated reporting: The NFRD 2.0 should ensure that the material sustainability information is published in the mainstream financial report. Assurance and verification: Problem: Verification of the content is not provided for in the legislation, which is a flaw as there is a lack of supervision and monitoring on what companies are disclosing. Solution: The NFRD 2.0 should ensure increased assurance of data, especially for environmental issues that can be quantified.
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Response to Climate Law

4 Feb 2020

Au vu de l'urgence climatique, la loi Climat européenne devra: Viser un objectif de réduction des émissions de gaz à effet de serre d'au moins 65% pour 2030 ainsi que la neutralité carbone pour 2040. Ces objectifs sont alignés avec la science ainsi qu'avec le rapport du PNUE " Emissions gap report 2019". Pour atteindre la neutralité climatique en 2040, il faut inscrire aussi dans la loi climat, en plus d'une réduction rapide des émissions, l'objectif d'un doublement des puits de carbone d'ici 2030 (absorption du carbone) basé sur des solutions fondées sur la nature comme la restauration d'écosystèmes. Prévoir un système de révision à la hausse de ces objectifs tous les 5 ans pour pouvoir tenir compte de l'évolution des connaissances scientifiques et technologiques. Supprimer ou modifier toute politique européenne, notamment les politiques sectorielles - ETS, efficacité énergétique, énergie renouvelable, agriculture, commerce, transport, usages des sols...- qui serait incohérente avec les objectifs européens pour 2030 ou 2040. Cela est d'autant plus urgent pour les politiques qui actuellement sapent les objectifs européens Mettre en place une instance scientifique indépendante pour suivre les objectifs européens, analyser les plans et politiques mis en place pour les atteindre, conseiller sur leur évolution.
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Meeting with Marlene Rosemarie Madsen (Cabinet of Commissioner Elisa Ferreira)

4 Feb 2020 · Just transition mechanism and technical support

Meeting with Virginijus Sinkevičius (Commissioner) and

29 Jan 2020 · To discuss illegal, unreported and unregulated fishing

Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

23 Jan 2020 · EU Biodiversity Strategy, Stepping up EU action to protect and restore the world's forests, Blue economy and international oceans governance, - Follow up of the WFD Fitness Check.

Response to EU 2030 Biodiversity Strategy

20 Jan 2020

WWF welcomes the ambition of the EC to curtail biodiversity loss and to present the EU’s ambition for the post-2020 global biodiversity framework and EU commitments to address the main causes of biodiversity loss. For the 2030 Biodiversity Strategy to be effective, the following is needed: - The biodiversity strategy must set out legally binding targets for the EU and its Member States, on how the EU and Member States intend to halt the loss of biodiversity and help restore nature, both in the EU and globally, by 2030. - The strategy should make full use of the existing EU environmental acquis and ensure Member States fully implement environmental and nature legislation (BHD, MSFD, MSPD and WFD). The EC must ensure adequate staff capacity is in place to handle complaints and bring infringement cases forward to the European Court of Justice at a scale commensurate with the crisis. - The strategy should contain tools for mobilising investment to ensure sufficient additional financing for nature conservation and restoration. The EU needs to fully phase out all environmentally harmful subsidies like those fueling overfishing, intensification of agriculture and hydropower development. As regards to the elements proposed in the roadmap, WWF’ main comments are: - Merely “promoting” the sustainable use of forest, agriculture, etc. is not ambitious, as changes in how land and sea are used, and direct exploitation of natural resources, are the two most impactful drivers of biodiversity loss. - Intensive agriculture and forestry, unsustainable fisheries and hydropower development have a devastating impact. The biodiversity strategy needs to contain SMART and enforceable targets to effectively address the main drivers of biodiversity loss. - Special attention is needed to identify interventions and funding from the CAP to minimise negative impacts of intensive agriculture (including safeguards to prevent perverse subsidies) and incentivise adoption and maintenance of agro-ecological and HNVF practices. - The elements proposed are very EU focused while EU consumption is leading to destruction of biodiversity in other regions. EU consumption represents 10% of the global share of deforestation embodied in total final consumption of commodities like palm oil, beef, soy, cocoa, etc. and this number does not even include the destruction of other ecosystems. - A focus on the implementation and enforcement of existing environmental and nature legislation (BHD, MSFD, MSPD, WFD) is missing. The following objectives and commitments should be included in the strategy: - Ensuring that by 2030 all species protected under the HD are in a favourable or improved conservation status and that all species protected under the BD show a secure or improved status. - Ensuring that by 2030, well managed and connected PA’s cover at least 30% of the EU’s land and sea including 10% non-intervention areas/no-take zones. - A new EU law to restore nature for biodiversity and climate with focus on restoration of natural forests, peatlands, floodplains, wetlands, biodiversity rich grasslands, coastal zones, degraded seafloor and marine areas to help mitigate and adapt to climate change, and provide a home for European species. - Bringing the vast majority of EU surface and ground waters back to good health by 2027 at the very latest, as set out by the WFD and in line with the zero pollution commitment in the Green Deal. This implies not revising the WFD and strengthening its implementation, including by removing barriers (like obsolete dams) from rivers. - Urgently achieving GES in EU marine waters committed for 2020 and protecting the resource base upon which marine economic and social activities depend as set out by the MSFD. - New legislation stopping products that lead to deforestation, ecosystem destruction and human rights violations from being placed on the EU market. WWF's asks on the global biodiversity framework attached.
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Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

14 Jan 2020 · Discussion on EU Biodiversity Policy

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

14 Jan 2020 · EU biodiversity policy

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and Third Generation Environmentalism Ltd

17 Dec 2019 · Just Transition

Meeting with Agne Razmislaviciute-Palioniene (Cabinet of Commissioner Virginijus Sinkevičius), Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius)

12 Dec 2019 · EU's upcoming marine and environmental priorities for the coming years

Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius)

5 Dec 2019 · To exchange views on biodiversity and water in the context of Fitness Check of the Water Framework Directive/WFD

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

26 Nov 2019 · discussion on deforestation and forest policies

Meeting with Anthony Agotha (Cabinet of First Vice-President Frans Timmermans) and ClientEarth AISBL and

20 Nov 2019 · Exchange of views on sustainability, climate change and maritime issues

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

7 Oct 2019 · Green finance, EC plan on Sustainable Investment

Meeting with Daniel Calleja Crespo (Director-General Environment)

6 Sept 2019 · Water Framework Directive, Fitness check, biodiversity, nature

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

1 Aug 2019 · discussion on UN General Assembly side event ''Nature and people''

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and Fern

30 Jul 2019 · discussion on UN General Assembly & EU action on forest protection

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and Greenpeace European Unit and

3 Jul 2019 · discussion on EU action on fighting deforestation

Meeting with Miguel Arias Cañete (Commissioner) and Climate Action Network Europe and

4 Jun 2019 · Debate on the strategic agenda and its relevance for climate and energy, NECP recommendations

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

11 Apr 2019 · discussion on deforestration

Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella), Sebastien Paquot (Cabinet of Vice-President Karmenu Vella)

11 Apr 2019 · Deforestation

Response to Update of the list of Invasive Alien Species of Union concern

5 Apr 2019

Invasive alien species pose greater risks than previously thought for biodiversity, human health and economies. There are around 14.000 alien species present in Europe, and the rate of new introductions has accelerated and is still increasing. At least 15 % of these alien species are known to have a negative ecological or economic impact. They have become the 2nd major cause of biodiversity loss, and one up to three of the European native species listed as critically endangered by the IUCN Red List of Threatened Species, are in danger because of invasive alien species. Besides these enormous ecological impacts, invasive alien species have a cost to the European Union of at least EUR 12,000 million annually. WWF EPO welcomes every effort that European Commission and Member States make for tackling the threat of invasive alien species to nature, and therefore, the organization wants to express its support to the inclusion of new invasive alien species into the list. The positive impact of the Invasive Alien Species Regulation will depend on the political ambition of the List of Invasive Alien Species of Union Concern, which should include the most harmful species with a higher impact on biodiversity, and those that are not yet present in the EU or are in the early stages of invasion. Considering the precautionary principle and the importance of prevention, and taking into account that the 18 species proposed for inclusion meet the criteria of article 4.3. of the IAS Regulation, including a scientifically robust risk assessment which demonstrate its impacts on biodiversity, WWF wants to express its support to the inclusion of all 18 invasive alien species into the list. However, WWF wants to express its disappointment on the fact that the American mink is not being proposed for listing. The American mink is a species that has a massive impact on the European environment and the scientific evidence shown in the risk assessment clearly indicates that this species should be an immediate priority for inclusion on the Union List. The fact that the listing of this species is being blocked by Member States, using economic arguments, is undermining the effectiveness of the IAS regulation. There are many other species that are considered to be priority species for listing according to the Scientific report “A prioritised list of invasive alien species to assist the effective implementation of EU legislation” (Carboneras et at., 2017). It is therefore important that the process of risk assessments and listing of those species is continued, and the European Commission should invest sufficient resources in the following years to make this happen.
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Response to Environmental Crime Directive Evaluation

5 Apr 2019

WWF European Policy Office welcomes the publication of the roadmap for the evaluation of Directive 2008/99/EC on the protection of the environment through criminal law, also known as the Environmental Crime Directive. This evaluation was already planned by the European Commission in the context of the EU Agenda on Security as well as the EU Action Plan against wildlife trafficking. Therefore, it is positive to see the EU take further action in this area, beyond those already ongoing listed in the roadmap. The directive was adopted in 2008 and Member States had until the end of 2010 to transpose it. It aims to ensure that criminal law measures are in place in each Member State for violations of a long list of EU environmental legislation listed in its annex A. This legislation includes the Birds and Habitats directives, the Water Framework directive and the Wildlife Trade regulations, among others. The roadmap states that the focus of the evaluation will be on waste and wildlife crime. While we agree that these are important to address, the evaluation should not overlook the other areas covered by the legislation, and should also look into gaps relating to EU environmental legislation not currently listed under Annex A, such as the EU Timber Regulation. The scope of the focus should also be defined – i.e. whether wildlife crime is limited to violations of the Wildlife Trade regulations or broadly defined to cover violations of all nature legislation. According to the Directive’s preamble, in order to achieve effective protection of the environment, there is a particular need for more dissuasive penalties for environmentally harmful activities as the existing systems of penalties have not been sufficient to achieve complete compliance with the laws. The transnational nature of many environmental crimes further justifies the need for a strong legal framework at EU level. WWF also welcomes the intention stated in the roadmap to focus on the coherence with other instruments in the areas of criminal law, as environmental crime often happens in convergence with other forms of criminality, such as organised crime, financial crime and corruption. In terms of evaluating the Directive’s efficiency, the costs of the crimes involved for should also be taken into account, and not only the costs for Member States to implement the Directive. The benefits of implementing the Directive should be given the same significance in the evaluation as costs. In terms of consultation, efforts should be taken to consult with civil society and non-governmental organisations, especially those in Member States that have a lot of on the ground experience of witnessing the impacts of environmental crime. WWF further hopes that this evaluation will lead to better collection, dissemination and transparency of data on types of environmental crimes committed, prosecution rates and sentences given in the EU.
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Meeting with Andrew Bianco (Cabinet of Vice-President Karmenu Vella), Juergen Mueller (Cabinet of Vice-President Karmenu Vella)

12 Mar 2019 · Biodiversity

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

8 Mar 2019

WWF objects in the strongest possible terms to the European Commission’s draft delegated regulation on high (and ‘low’) ILUC bioenergy feedstocks and believes that it should be withdrawn. It is based on seriously flawed analysis, risks setting extremely damaging precedents and is completely unacceptable as an attempt to deliver on the goals of the Paris Agreement, the sustainable development goals and other EU commitments. As explained in detail in a 2017 WWF briefing paper that reviews the scientific evidence (http://d2ouvy59p0dg6k.cloudfront.net/downloads/eu_bioenergy_policy___wwf_briefing_paper___final_4.pdf) any use of land (abandoned or otherwise) for purpose-grown biofuel crops will be counterproductive in climate terms compared to food production or carbon sequestration, even accounting for displacement of fossil fuels. On this basis - and notwithstanding other important issues such as social or biodiversity impacts - all such biofuels, regardless of crop type, can be expected to increase emissions compared to fossil fuels. The Commission’s attempts to distinguish between such ‘first generation’ biofuels, none of which should be considered ‘low-ILUC’, are meaningless and should be abandoned. In addition: - Using a global average for the expansion of crops into land with high carbon stocks masks the high levels that can exist in any one country or region; - The lack of an impact assessment, including any examination of the land use or GHG impacts of allowing other vegetable oil crops while phasing out palm oil, which is 4 to 10 times more productive, is unacceptable. - In a global market for agricultural commodities it is impossible to attribute increases in yield to a specific EU bioenergy policy, and absurd to suggest that such increases could have been so caused even if they occurred as much as 10 years prior to certification; and - The fact that biofuel feedstocks may have been produced by smallholders is irrelevant to the climate impact of such biofuels; - There is no attempt to explore which feedstocks, for example potentially intermediate crops, might genuinely be low ILUC - The definition of abandoned land, which is crucial to reducing the threat of conversion of grasslands and savannahs, is weak and open to abuse. As mentioned above, these points are specific to the climate impacts of EU biofuel policy and do not cover broader environmental or social issues related to crop production (whether in the EU or elsewhere, and whether for energy or other purposes).
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Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella)

27 Feb 2019 · Deforestation

Meeting with Karmenu Vella (Commissioner) and

5 Feb 2019 · IUU Fishing

Meeting with Daniel Calleja Crespo (Director-General Environment)

28 Jan 2019 · Biodiversity

Response to Stepping up EU Action against Deforestation and Forest Degradation

15 Jan 2019

WWF welcomes the European Commission’s initiative to step up EU action against deforestation and forest degradation as expressed in the roadmap, following numerous calls by NGOs, civil society organisations and clear demands by the European Parliament and EU Member States. Nevertheless, we are of the opinion that the measures proposed in the roadmap will not live up to the challenge. A comprehensive set of measures is needed to reduce the EU's footprint WWF supports the need for better mainstreaming of deforestation considerations through EU policies. Deforestation and forest degradation are linked to numerous EU policy sectors such as environment, climate, trade, agriculture and development but the focus of the roadmap on better coherence between existing policies and better implementation of existing approaches alone will not be sufficient, neither will an approach that does not address the destruction of other ecosystems (savannahs, grasslands). The measures proposed in the roadmap can form a good basis but better mainstreaming has to include new policy measures, as deforestation and forest degradation are currently not thoroughly addressed in EU policies. Action should include (but not be limited to): ● clear and binding rules to ensure forest risk commodities being placed on the EU market are sustainably produced and deforestation-free ● transparency concerning investments of public and private actors that could fuel deforestation ● take advantage of existing industry commitments or interest in developing new ones and support the development of ambitious goals and implementation of these commitments. ● support for producing countries in addressing the challenges to reduce deforestation, forest degradation and ecosystem destruction, including support and protection of the rights of smallholders and indigenous people, and compliance with international human rights norms New incentives are needed to reduce overconsumption and reduce waste in the EU. The different measures should be complementary and mutually reinforcing and therefore be bundled in a new Action Plan. Why regulatory measures are needed Regulatory measures are needed to close the gaps existing in current EU and Member States’ policies as currently there is no legislation at EU level that addresses deforestation. Binding measures on forest risk commodities will help companies to fulfill their commitments, create a level playing field, eliminate ambiguities and clarify where legal requirements are applicable, provide long term clarity to all stakeholders and assurance to consumers who don’t want to unwittingly buy products responsible for serious negative environmental and social impacts. In the EC funded study Feasibility study on options to step up EU action against deforestation from March 2018, the EC had already looked into different actions and policy options, including further legislation. Despite its higher cost, the study concludes that measures including new legislation would have the greatest impact and that relying on existing policies, measures and legislation would be the less effective option. A strong communication to fulfill the EU’s commitments WWF considers it crucial that the upcoming communication on deforestation supports the implementation of the EU’s international commitments such as the Paris Climate Agreement, the Convention on Biological Diversity or the Agenda 2030 for sustainable development and establishes links between the different commitments. It should also explore what other measures need to be taken to be in line in fulfilling the EU’s commitments. The aim of EU action against deforestation should be to meaningfully reduce the EU’s footprint, tackle the drivers of deforestation, forest degradation and destruction of other ecosystems, whilst at the same time deliver sustainable, resource-efficient production and consumption, and support human rights, governance and land tenure.
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Response to Environmental Implementation Review 2019: common implementation challenges across the EU

23 Nov 2018

The Environmental Implementation Review is a valuable initiative in terms of identifying and reporting on the structural gaps to the national implementation of environmental legislation. The findings of the first Review, published in early 2017, were largely in line with WWF’s long-standing assessment of the issue. WWF considers however that the Environmental Implementation Review should by no means be considered as a replacement for effective means to get Member States to comply with legislation such as opening infringement cases against Member States who are found to not be complying with EU environmental legislation, and especially against Member States that show a lack of political will to comply with EU law. The Commission should always seek to fulfil its role as guardian of the Treaties and step up the use of legal action to put a halt to the poor implementation of EU legislation. In this regard, the Commission’s internal guidance to pursue infringements only on “strategic” cases. In order to further improve the quality of the Environmental Implementation Review for 2019, WWF recommends the Commission to expand the scope of review by including other areas such as timber and illegal fisheries laws, as well as the fight against wildlife trade. The Commission should furthermore ensure stakeholders are allowed to participate in the Review and subsequent legal action as civil society can be a reliable source of information on national implementation – since Member States have a tendency to report overly positive on their performance.
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Meeting with Miguel Arias Cañete (Commissioner) and Climate Action Network Europe and

27 Sept 2018 · Long-Term Strategy, Preparations for COP24 and October ENV Council

Response to Institutional investors' and asset managers' duties regarding sustainability

23 Aug 2018

WWF European Policy Office welcomes the European Commission’s opportunity to give feedback on the proposal for a regulation on the establishment of a framework to facilitate sustainable investment. It is a positive step of the Commission, consistent with the EU Sustainable Finance Action Plan. We would like to make the following comments to the Commission’s legislative proposal: 1. We believe that this legislative proposal is a key opportunity to plan a process for establishing a complementary ‘brown taxonomy’ listing unsustainable activities. Such a brown taxonomy would be developed in a similar way with a Technical Expert Group. Timewise, it would be relevant to start such a process once the green taxonomy-related process is close to be achieved, ie in end 2019-2020. It is important to note that the market is already using different types of brown taxonomies: for example ESG analysts and data providers increasingly have their in-house brown taxonomies as they are assessing the green and brown revenues of listed companies and selling such data to investors. Assessing brown revenues of companies implies the use of a brown taxonomy. The Credit Rating Agencies have their in-house brown taxonomies as well: for example Moody’s published its heatmap in November 2015 already, assessing sector credit risk and exposure to five categories of environmental risks. Last but not least, some central banks and financial supervisors are starting as well to call for brown taxonomies to be developed. Most recently, the Governor of the Banque de France, François Villeroy de Galhau, called publicly for such a taxonomy to be established . Similarly to an official EU green taxonomy, an EU brown taxonomy will have multiple benefits: avoid EU market fragmentation, provide much greater clarity to both issuers and financial institutions as to what are brown activities, and be a building block for multiple opportunities of financial products to accelerate the necessary shift from brown to green finance – that the green taxonomy alone cannot solve. 2. As much as possible, the taxonomy needs to be dynamic in order to reflect latest environmental science, and avoid a rigid static list. The long term governance mechanism to regularly update the list of activities is very positive and CSOs with relevant expertise should be part of such a mechanism. The taxonomy should be updated at the latest every three years to properly capture the latest environmental and climate science, technological innovation, etc. While it is more complex, there should also be efforts to capture regional differences. The aim should be to increasingly reflect environmental and climate science-based pathways and build on forward-looking scenario analysis everywhere possible, as key overarching principles and frameworks to define which activities can be deemed green at a certain point in time and how their classification should evolve. 3. The taxonomy should be conservative, in the sense that if a given activity is deemed green by some stakeholders but is controversial for others that are providing science-based evidence for their concerns, such an activity should not be included in the taxonomy. In order to have a credible taxonomy that can serve as a robust basis for financial products and avoid greenwashing risks, vested interests should not pollute the taxonomy. 4. The taxonomy should be designed for use for all financial stakeholders including banks – not only investors. The taxonomy should notably be easy to use in equity investment processes, bond investment processes, lending processes, direct investment processes into real assets and project finance. 5. The do no harm principle on social issues should be strengthened and broadened, as it only focuses on labour rights currently.
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Response to Institutional investors' and asset managers' duties regarding sustainability

22 Aug 2018

WWF welcomes the European Commission’s opportunity to give feedback on proposal for a regulation on disclosures relating to sustainable investments and sustainability risks and amending Directive (EU)2016/2341. WWF welcomes the fact that the Commission is moving forward with many of the ‘key actions’ numbered in the EU Sustainable Finance Action Plan, including partly ‘Action 7: Clarifying institutional investors' and asset managers' duties’. WWF is supportive of the general proposal and strongly agrees that disclosure requirements should be strengthened. However, we believe that the proposal does not integrate properly and fully the HLEG recommendations on investor duties, and we have several recommendations to improve the proposal: • In order to shift to a sustainable financial system, it is too limited to require more disclosure for the ESG investment niche only. The regulation should require sustainability disclosure for all products. The regulation should not simply increase the disclosure burden to the financial products with a sustainable investment target. This can be reflected in Articles 1 and 4. • Critically, the impact of the investment or financial product on the environment and society should be disclosed, not only the methodology to integrate ESG factors: impact disclosure should be added to process disclosure (Article 4). • Impact disclosure should notably include the degree of alignment of the investment or financial product with the Paris Agreement, and the exposure of the financial product to the taxonomy (Article 4). • It should be clarified in the regulation that the materiality of ESG risks should be assessed, consistently with the investment timeframe of the client/member (Article 3). • Regarding the ‘sustainable investment’ definition, we believe it is too weak and that many investments will be deemed sustainable while in fact they are not, not avoiding ‘greenwashing’. A ‘do no harm’ principle for environmental and social objectives (that is actually reflected in the taxonomy regulation) is missing. The ‘sustainable investment’ definition should be completed to ensure that an investment that is beneficial for e.g. the environment is not counterproductive for social or governance objectives (Article 2). • A ‘sustainability risk’ definition is missing from the proposal. It is important to add it for clarification: the impact of ESG issues on the investment return is important, but also the impact of the investment or financial product on the environment and society (Article 2). • For investments with a climate target, the proposal focuses on the ‘low carbon emissions exposure’, which does not necessarily assess nor ensure the alignment with the Paris Agreement. The ‘targeted degree of alignment with Paris Agreement goals’ should be integrated (Article 5). • The following HLEG’s recommendation ‘Pension funds / Asset managers should ensure that they have a sound understanding of the broad range of interests of their members and beneficiaries, including ESG factors” ’ is not integrated in the proposal and should be added (Article 10). • The following HLEG’s recommendation ‘Whether financially material or not, the preferences of clients, members and beneficiaries shall be pro-actively sought and incorporated into investors’ investment decision-making and the demands that they, in turn, make on the asset managers and other participants with which they interact to deliver their obligations to clients’ is not integrated in the proposal and should be added (Article 10).
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Response to Institutional investors' and asset managers' duties regarding sustainability

22 Aug 2018

WWF welcomes the European Commission’s opportunity to give feedback on the proposal for a regulation amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks to create a new category of benchmarks which will provide investors with better information on the carbon footprint of their investments. It is already a first step that the Commission is moving forward with many of the ‘key actions’ numbered in the EU Sustainable Finance Action Plan, specifically ‘Action 5: Developing sustainability benchmarks’. However, WWF is highly concerned with several specific parts of the Commission’s proposal, and believe that other parts do not properly integrate the HLEG final recommendations. We therefore make the three main following recommendations to improve the proposal: 1. Ensure sustainability disclosure for the mainstream, not for the niche: The Commission’s proposal requires that the benchmark statement shall contain an explanation of how environmental, social and governance (ESG) factors are reflected (amending Article 27 of the Benchmark regulation ‘Benchmark statement’), but only for benchmarks or family of benchmarks “which pursue or take into account ESG objectives”. It therefore focuses on the niche of ESG benchmarks (a tiny 0,3% of the market according to the Index industry Association (IIA), Survey 30 June 2017) – without providing a clear explanation why and a clear definition of ESG benchmarks. It implicitly means that for the mainstream, there would be no additional disclosure obligation on sustainability issues. This goes against the objective of mainstreaming sustainable finance, which implies that for all benchmarks there should be an obligation to disclose how sustainability factors are integrated in the methodology. Otherwise it is very likely that the ESG issue will remain a niche issue for the market. 2. Ensure impact disclosure not only process disclosure on sustainability: The Commission introduces disclosure requirements that focus on the methodology of benchmarks. While this is positive, it will not give the investors any information about the impact or the alignment of the benchmarks to sustainability objectives. This is largely paradoxical, as the integration of ESG factors in financial products is frequently aimed at aligning with or even contributing to certain ESG objectives, for example to align with the Paris Agreement or with Sustainable Development Goals (SDGs). As recommended by the HLEG, the sustainability impact, contribution or alignment of a benchmark is a critical element that should be disclosed. It can be argued that it is still challenging to assess the impact or alignment of a benchmark to certain ESG objectives. While this is partly the case indeed, it should be noted that a growing number of tools and methodologies are being quickly developed to enable index providers to assess such an impact. For example, the Sustainable Energy Investment metric tool (SEI) , an open-source tool developed with Horizon 2020 funds from the EU budget, enables index providers to assess how far a given benchmark is aligned with the 2°C climate scenario from the International Energy Agency (which is usually considered as a reference scenario by financial institutions) or with any climate scenario that is sufficiently granular . A requirement to disclose the sustainability impact or alignment of benchmarks will also act as a major driver to accelerate methodological innovation in the market in order to better assess such impacts. 3. Ensure that climate benchmarks focus on the right issue: The proposal would notably include ‘the method for the calculation of carbon emissions and carbon savings’. This means that the EC choses one single approach and metric for climate benchmarks: the carbon footprint of underlying assets (and related carbon savings). By doing so it also omits to make explicit the need to assess the contribution or alignment with the objectives of the PA.
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Response to Multiannual Financial Framework: Proposal for the Neighbourhood, Development and International Cooperation Instrument

16 Aug 2018

The proposal of a Neighbourhood, Development and International Cooperation instrument (NDICI), with its simplification and overall increase in amounts for external action, could offer the EU an opportunity to play a stronger and more effective role as responsible global actor, in line with its principles and values. However, a number of shortcomings in the regulation risk undermining EU’s ability to live up to its international commitments and truly champion sustainable development globally and the fight against climate change and environmental degradation on which prosperity, stability and wellbeing depend. Improvements should be made and our main recommendations are summarized in the submission attached in line with the following: 1) Strengthen NDICI commitment to sustainable development by: - including clear and explicit references to the promotion of sustainable development, fight against poverty and inequalities, climate change and protection of the environment in the objectives of the regulation to ensure they are at the heart of the instrument, in line with the EU consensus on development. - developing a framework that would help operationalize the SDGs in an integrated way, rather than listing sectors of intervention in the annexes which risk promoting “siloed” approaches. This would also strengthen and complement the commitment to mainstream climate change, environmental protection, and gender equality across the instrument and to promote interlinkages between SDGs to deliver co-benefits. 2) Increase NDICI ambition in tackling climate change and protecting the environment at all levels by: - Recognizing the urgency of tackling environmental degradation and biodiversity loss as well as climate change, as a precondition to achieve sustainable development. In our view a more ambitious 50% spending target for climate and environment related objectives should be set, to support actions with clear and identifiable co-benefits across sectors. For further recommendations on co-benefits and why investing in nature is crucial for promoting sustainable development and fighting climate change please refer to a Joint NGO statement which WWF contributed to and is integrated at the end of our submission. - Adding this 50% target to the main articles of the regulation, instead of leaving it in the recitals, to confirm EU’s ambition in playing a leadership role in fighting these global challenges as well as to help ensuring that the large geographic pillar of NDICI will effectively contribute to these efforts and integrate environment, biodiversity and climate action among the sectors of support under bilateral and regional cooperation. - Ensuring that future thematic programmes receive significant allocations and continue to add values to geographic ones for example by supporting actions at the global level; actions that combine interventions at different levels, from local to global, because the nature of the challenge, such as environmental and climate ones, goes beyond national borders; or pilot and innovation actions that can add value to bilateral/regional cooperation efforts to promote the transition to a low carbon, resource efficient economy. The proposed reduction in thematic programmes should not result in a reduction of EU’s crucial and traditional support to environment, biodiversity and climate action. - Strengthening throughout the NDICI, across geographic and thematic programmes, the support to civil society, including environmental activists and indigenous peoples, as key sustainable development actors that promote solutions and foster innovation to fight climate change, protect the environment and ensure the sustainable and equitable use of natural resources at the local, national and global levels - Reintroducing key safeguards of the current EFSD regulation, in relation to transparency, accountability, eligibility, climate and environmental screening, which have been removed from EFSD+
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Response to Evaluation of the EU Biodiversity Strategy to 2020

18 Jul 2018

Both the 2015 Mid-term evaluation of the EU Biodiversity Strategy and the 2018 IPBES Regional assessment for Europe and Central Asia confirmed the continuing decline of biodiversity and the degradation of ecosystem services in the EU and globally. Biodiversity loss is one of the most critical environmental threats alongside climate change and the two are inextricably linked. WWF-EPO agrees with the overall process and scope of the final evaluation of the EU 2020 Biodiversity Strategy and is looking forward to contribute to this process. The evaluation should form the basis for ambitious policy commitments post 2020 for the EU and globally. However, it is worrying that the final evaluation will only be ready at the end of 2020. The preliminary findings need to be available and discussed as soon as possible in 2019, to integrate this into the debate on the post 2020 CBD framework. Regarding the purpose and scope of the evaluation, we would like to underline the following points: The mid-term review assessing progress under the EU biodiversity strategy concluded that the 2020 biodiversity targets can only be reached if implementation and enforcement efforts become considerably bolder and more ambitious. It also pointed out to the need for more effective integration underpinned by adequate funding. WWF supports this analysis: the evaluation must focus on the main gaps related to implementation, enforcement, financing and policy coherence. It is very clear that measures adopted to address unsustainable agriculture and fishing activities, among the main drivers of terrestrial and marine biodiversity loss in Europe, have been largely insufficient to reverse the situation. The evaluation should have a specific focus on how to make the future Common Agricultural Policy and Common Fisheries Policy proposals more coherent with ecosystem and biodiversity conservation. Also the important finance gap for nature conservation is a main barrier. The evaluation should have a specific focus on how to ensure the EU budget after 2020 will target and deliver better on biodiversity aspects across the board. It is important to include the evaluation of potential EU policy gaps, as existing policies, even with higher effectiveness, might not be enough to fully address biodiversity decline. Specifically in relation to Target 2 to maintain and restore ecosystems, it is clear that voluntary mechanisms are not sufficient and a legally binding initiative for large scale ecosystem restoration is needed. The reasons preventing the achievement of Target 3, which is related to species and habitats related to agriculture with very worrying trends, should be carefully assessed, both as regards the impacts of intensive agriculture and the loss of extensive High Nature Value farming in Europe. Regarding Target 4, which is specifically related to the marine environment, existing legally binding initiatives need to be enforced, and subject to proper control and monitoring. The role the EU needs to play to tackle biodiversity loss globally is not well reflected in the presented scope of the roadmap and should be given more attention, also in relation to the EU’s role e.g. through exporting its footprint. The EU has been supporting biodiversity conservation globally through its development cooperation instruments, although the exact level of this support is unclear from the available data. Finance must be stepped up in the next Budget period to support biodiversity and climate action as well as the implementation of the SDGs in Europe and in third countries. However, financial support in itself is not enough if EU policies continue to aggravate biodiversity loss in third countries. For example, the EU is driving degradation and loss of forests, peatlands and other ecosystems (e.g. savannahs) through our import and consumption of agricultural products such as soy and palm oil, but action to address this is inadequate.
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Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis), Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

11 Jul 2018 · Sustainable Finance

Meeting with Stefano Manservisi (Director-General Directorate-General for International Partnerships)

26 Jun 2018 · report on successful WWF projects implemented with EU funding and discussion on issues of common interests such as climate change, biodiversity and Sustainable Development Goals

Response to Institutional investors' and asset managers' duties regarding sustainability

21 Jun 2018

WWF welcomes the European Commission’s opportunity to give feedback on amendments to delegated acts under the Markets in Financial Instruments Directive (MiFID II) and the Insurance Distribution Directive to include ESG considerations into the advice that investment firms and insurance distributors offer to individual clients. It is already a first step that the Commission is moving forward with many of the ‘key actions’ numbered in the EU Sustainable Finance Action Plan, including ‘Action 4: Incorporating sustainability when providing financial advice’. Having revised the proposed amendments on MiFID II Delegated Regulation, we welcome that investment advisors would be required to take into account the client’s investment objectives, including any ESG preferences. However, we are concerned that the proposed amendments across the articles may be inconsistent or lead to different interpretations by investment firms, with the wording used such as ‘where relevant’ or ‘including ESG preferences, if any’. With this wording, investment firms providing investment advice and portfolio management could interpret the consideration of clients’ ESG preferences as a ‘comply or explain’ exercise, which would could significantly weaken the whole purpose of the delegated acts. The wording “where relevant” should be removed from the text, and the wording about ESG preferences should be framed as “including any ESG preferences” to ensure consistency. In addition, WWF believes that the Commission has not fully integrated the HLEG’s recommendation on investment advice. The HLEG recommended the following: • ‘Require investment advisers to ask about, and then respond to, retail investors’ preferences about the sustainable impact of their investments, as a routine component of financial advice.’- The European Commission follows the first part where client’s ESG preferences are taken into account. However, the HLEG includes ‘the sustainable impact of their investments’ which is not only the impacts of ESG preferences on the investment, but also the impacts on the environment and society. In addition, it also recommends to ‘then respond to’ which means not only to take ESG preferences into account, but act upon it and this is not reflected clearly enough in the Commission’s proposed delegated act. The Commission should therefore add the issue of sustainability impact of investment in the proposed delegated acts. • ‘Facilitate retail investor choice by increasing transparency on the sustainability impact and processes of retail funds. The Commission should request all funds, destined for the retail market to disclose clear and understandable information on their sustainability impact, as well as information on the exercise of voting rights.’- The European Commission’s amendments of MiFID II / IDD Delegated Regulations include provisions where ‘investment firms have to provide a report to the retail client on how the recommendation meets the client’s objectives, including ESG preferences, if any.’ This inclusion of ESG preferences regarding disclosure of investment firms to retail clients is not matching the HLEG’s recommendation. What the HLEG recommended is a mainstream approach across all funds where investment firms systematically disclose the sustainability impact and processes of the funds. The HLEG recommends as a first step for funds to disclose ‘their strategy and portfolio exposure in relation to climate-related risks and opportunities’. The Commission should therefore add the issue of disclosure of sustainability impacts in the proposed delegated acts.
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Response to Institutional investors' and asset managers' duties regarding sustainability

21 Jun 2018

WWF welcomes the European Commission’s opportunity to give feedback on amendments to delegated acts under the Markets in Financial Instruments Directive (MiFID II) and the Insurance Distribution Directive to include ESG considerations into the advice that investment firms and insurance distributors offer to individual clients. It is already a first step that the Commission is moving forward with many of the ‘key actions’ numbered in the EU Sustainable Finance Action Plan, including ‘Action 4: Incorporating sustainability when providing financial advice’. Having revised the proposed amendments on MiFID II Delegated Regulation, we welcome that investment advisors would be required to take into account the client’s investment objectives, including any ESG preferences. However, we are concerned that the proposed amendments across the articles may be inconsistent or lead to different interpretations by investment firms, with the wording used such as ‘where relevant’ or ‘including ESG preferences, if any’. With this wording, investment firms providing investment advice and portfolio management could interpret the consideration of clients’ ESG preferences as a ‘comply or explain’ exercise, which would could significantly weaken the whole purpose of the delegated acts. The wording “where relevant” should be removed from the text, and the wording about ESG preferences should be framed as “including any ESG preferences” to ensure consistency. In addition, WWF believes that the Commission has not fully integrated the HLEG’s recommendation on investment advice. The HLEG recommended the following: • ‘Require investment advisers to ask about, and then respond to, retail investors’ preferences about the sustainable impact of their investments, as a routine component of financial advice.’- The European Commission follows the first part where client’s ESG preferences are taken into account. However, the HLEG includes ‘the sustainable impact of their investments’ which is not only the impacts of ESG preferences on the investment, but also the impacts on the environment and society. In addition, it also recommends to ‘then respond to’ which means not only to take ESG preferences into account, but act upon it and this is not reflected clearly enough in the Commission’s proposed delegated act. The Commission should therefore add the issue of sustainability impact of investment in the proposed delegated acts. • ‘Facilitate retail investor choice by increasing transparency on the sustainability impact and processes of retail funds. The Commission should request all funds, destined for the retail market to disclose clear and understandable information on their sustainability impact, as well as information on the exercise of voting rights.’- The European Commission’s amendments of MiFID II / IDD Delegated Regulations include provisions where ‘investment firms have to provide a report to the retail client on how the recommendation meets the client’s objectives, including ESG preferences, if any.’ This inclusion of ESG preferences regarding disclosure of investment firms to retail clients is not matching the HLEG’s recommendation. What the HLEG recommended is a mainstream approach across all funds where investment firms systematically disclose the sustainability impact and processes of the funds. The HLEG recommends as a first step for funds to disclose ‘their strategy and portfolio exposure in relation to climate-related risks and opportunities’. The Commission should therefore add the issue of disclosure of sustainability impacts in the proposed delegated acts.
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Meeting with Miguel Arias Cañete (Commissioner) and Climate Action Network Europe and

13 Jun 2018 · MOCA, Petersberg Dialogue, Trilogues, Long Term decarbonisation Strategy

Meeting with Andrew Bianco (Cabinet of Vice-President Karmenu Vella)

28 May 2018 · Wolf

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis) and Greenpeace European Unit and European Public Health Alliance

25 Apr 2018 · Common Agricultural Policy reform

Meeting with Isaac Valero Ladron (Cabinet of Vice-President Miguel Arias Cañete)

13 Apr 2018 · Aspects of European Council agenda

Meeting with Anthony Agotha (Cabinet of First Vice-President Frans Timmermans) and European Environmental Bureau and Stichting BirdLife Europe

16 Mar 2018 · Exchange of views on Future of Food and Farming

Response to Fitness check on public reporting by companies

7 Mar 2018

Regarding ‘Consultation of citizens and stakeholders’ in page 3, WWF will focus mainly on point 2 ‘Whether the financial and non-financial disclosures in the area of Environmental, Social and Governance (ESG) reporting by companies are fit for purpose, including as regards sustainability disclosures’ and on some key accounting issues related to sustainability in point 1. As emphasized by the EU High Level Expert Group on sustainable finance, improving corporate reporting on sustainability issues is a key enabling condition for a sustainable financial system. The review of the Non-Financial Reporting Directive (NFRD) as part of the Fitness Check is crucial as there are still important weaknesses in the legislation that are impeding relevant sustainability data to be produced and used properly. We urge the Commission to have a more ambitious timeline, with a 2020 deadline for the NFRD review to be completed. The Commission needs to ensure that the upcoming review of the NFRD serves as an opportunity for the development of robust ESG metrics - forward-looking, impact-oriented, and primarily sector-specific - as well as reliable processes for the evaluation of ESG-related risk. These processes would, in turn, encourage investors to effectively engage with companies on sustainability issues, as well as inform their stewardship activities. Clarifying the duties of company directors and of investors is a complementary critical step in ensuring that companies are protected from the dictate to maximise short-term shareholder value at the expense of longer term sustainability issues. We concretely recommend the Commission: • The NFRD review starting in 2018 is crucial for the EU’s ability to deliver, by 2020, a comprehensive and useful EU climate disclosure regime that is aligned with the TCFD recommendations and ensuring an EU level playing field by harmonising climate reporting. The review should result in mandatory TCFD-aligned reporting requirements by 2020 at the latest, which would allow for businesses to prepare over a reasonable period; • In parallel, the Commission should actively ask, together with relevant stakeholder, the International Organization of Securities Commissions (IOSCO) to issue a recommendation that listing requirements from stock exchanges integrate TCFD recommendations for listed companies. This is critical to ultimately ensure a global implementation of the TCFD recommendation - not limited to the EU companies; • Through the NFRD review, ensure standardised, comparable, forward-looking and meaningful disclosure by setting up a few Key Performance Indicators (KPIs) for all sectors and sector-specific KPIs to report the most critical ESG issues specific to each sector. They are critical to ensure strategic reporting on the most important issues by sector, ensure comparability between peers, and streamline reporting requirements to substantially limit reporting costs; • Multi-stakeholder groups should be convened by the Commission at sector or subsector level with a one-year mandate to define the limited set of sector-specific KPIs for ESG reporting to be as meaningful, strategic and streamlined as possible; • The Commission should rename the NFRD as the “Sustainability reporting directive” and change wording on ‘non-financial’ reporting accordingly, as it is now well evidenced that a part of ESG factors are financially material. ‘Non-financial’ reporting is therefore partly misleading, and very counter-productive for the robust integration of ESG issues into reporting and investments processes.
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Meeting with Kathiana Ghio (Cabinet of Vice-President Karmenu Vella) and European Environmental Bureau and Stichting BirdLife Europe

28 Feb 2018 · Future of LIFE & Biodiversity in the context of MFF

Meeting with Florentine Hopmeier (Cabinet of Vice-President Jyrki Katainen)

28 Feb 2018 · Sustainable Europe 2030

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

28 Feb 2018 · discussion on sustainable Europe 2030

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella) and Greenpeace European Unit and

11 Jan 2018 · Fisheries Control Regulation

Response to EU Pollinators Initiative

21 Dec 2017

WWF welcomes the decision to launch an initiative to tackle the rapid decline of pollinators in Europe. The EU needs a framework to protect Europe’s declining pollinators, and it is essential that the issue is elevated to a political level. Strong political will is required to agree on concrete effective actions and achieve real change. It is clear that governance ensuring a holistic approach to the protection of pollinators is currently lacking. The EU Pollinators Initiative needs to establish an effective governance system to ensure coordinated and collaborative action at the EU and MS levels for effectively addressing drivers and pressures of pollinators decline and introduce measurable changes benefiting pollinators and biodiversity at large. The initiative should comprise both legally binding measures (e.g. changes to relevant EU acquis, for instance on pesticides) as well as voluntary elements (exchange of knowledge and best practices). The aim of the initiative should be to establish an integrated EU approach to tackle the decline of pollinators by raising its political profile, increasing the effectiveness of EU policies and evaluating potential EU policy gaps for pollinators. It is important to include the evaluation of potential EU policy gaps, as existing policies, even with higher effectiveness, might not be enough to fully address the decline of pollinators. Besides the three specific objectives mentioned in the roadmap, a fourth specific objective should be added: promote the use of EU funding streams to achieve the objectives of the pollinator initiative. This should include: 1) an estimation of the financial needs to fund a comprehensive strategy for pollinators and its follow up; 2) the evaluation of the potential of existing EU funding streams to support the implementation of the strategy for pollinators; 3) a proposal on how to better channel EU resources to implement the EU pollinator initiative. To tackle pollinators decline, changes in agricultural practices are essential – creating healthy diverse ecosystems, which will also be good for farming; increasing heterogeneity in agricultural landscapes and promoting diversified farming systems; protection and restoration of wildflower-rich ecosystems. The EU Pollinators Initiative should facilitate restoration of essential pollinators’ habitats. The creation of a Trans-European Network for Green Infrastructure could also help in this respect. Harmful subsidies and incentives in the Common Agriculture Policy that have a direct or indirect impact on pollinators should be addressed and replaced by incentives for practices benefitting pollinators. It is of utmost importance to include actions on pesticides in the EU Pollinators Initiative, both relating to the sustainable use of pesticides (i.e. reduction of pesticide use) and the pesticides approval process. Specifically; the Sustainable Use of Pesticides Directive should be enforced to ensure that MS adopt clear quantitative targets, timetables and measures to minimise pesticide use and increase the uptake of Integrated Pest Management with priority given to prevention and non-chemical methods of control. A better implementation of the Regulation concerning the placing of plant protection products on the market in particular on the (re)authorization of active substances is also needed. These authorizations shall take into account all available data, including academic studies, published within the last ten years. The robustness of the EU pesticide approval ‘test method’ for pollinators should be reviewed and a stronger evidence base for a wider range of pollinator species considered. The pollinator initiative should also make current restrictions on neonicotinoid insecticides permanent and extend them to all crops and make sure that the current existing link between farm advice and income from pesticides use is broken, so that farmers get genuine independent advice.
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Meeting with Anthony Agotha (Cabinet of First Vice-President Frans Timmermans), Helena Braun (Cabinet of First Vice-President Frans Timmermans) and Stichting BirdLife Europe

7 Dec 2017 · CAP Communication

Response to Evaluation of the General Union Environment Action Programme to 2020 (7th EAP)

5 Dec 2017

WWF European Policy Office (EPO) welcomes the launch of a roadmap for the evaluation of the General Union Environment Action Programme to 2020 (7th EAP). The consultation strategy outlined in the roadmap (a public consultation open to all, targeted stakeholder consultation and Member State consultation) is robust. WWF EPO is ready to contribute its expertise to these consultations. Sustainability relies on a clear environmental legislative framework in place, supported by implementing policies. With its 7th EAP, the EU acknowledged the need to address the most pressing environmental problems that we face today and provided the strategic direction for the environmental and climate policy progress that needs to be achieved by 2020. The 7th EAP sets an agenda that, if properly implemented, could transform Europe into a sustainable and low-carbon economy that contributes to the wellbeing of its people. This evaluation of the 7th EAP presents a timely opportunity to raise the profile of the commitments the EU and its Member States have taken, and should lead to taking corrective and/or additional measures to fully implement this programme. The roadmap notes that “the purpose of this evaluation is to assess the 7th EAP and submit a report based on this evaluation to the European Parliament and to the Council”. It should be noted that the European Parliament is currently in the process of developing an implementation report on the 7th EAP, which should be adopted in the first quarter of 2018. An in-depth study was carried out by the European Parliament’s Research Service to form the evidence base of this report, for which stakeholders were consulted. Results from this research, as well as other recent evaluations such as the fitness check of the Nature Directives, pointed out that coherence and financing are major challenges. These should be considered as input for the evaluation. Regarding of the five evaluation questions’ categories, a number of additional questions could be considered. For example, under “coherence”, the role other EU policies play in the achievement of the 7th EAP’s objectives should be explored.
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Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan)

28 Sept 2017 · Prepare Water and Agriculture event on 28 September 2017

Meeting with Miguel Arias Cañete (Commissioner) and Transport and Environment (European Federation for Transport and Environment) and

26 Sept 2017 · Clean energy package, cars and vans, international agenda

Meeting with Daniel Calleja Crespo (Director-General Environment) and European Environmental Bureau and Stichting BirdLife Europe

5 Sept 2017 · Better implementation, Biodiversity and CAP

Response to Evaluation of the impact of the CAP on climate change and greenhouse gas emissions

7 Jul 2017

Overall, WWF welcomes this initiative and Roadmap, as food and agriculture remain a major source of GHG emissions and the CAP plays a key role in European farming. We would like to make two main suggestions to the roadmap proposed, in order to make it more useful and complete (please see file attached for further details and justification): 1/ ON LIVESTOCK PRODUCTION. To tackle this issue appropriately, we suggest including an additional point in (C.2) Issues to be examined, in the final section on Causal Analysis, as follows: - To what extent have CAP measures supporting livestock farming and feed production been contributing to or frustrating climate objectives? #Analysis of the climate impacts of CAP support to feed and livestock production, including the different farm types (e.g., grassland based vs feed based), livestock species, and types of feed. #Analysis of environmental and agronomic trade-offs and interrelations beyond climate and feed/livestock production: grassland management, integration with crop production, animal welfare, import of commodities, etc. #Identification of best policies in support of an environmentally sustainable and climate resilient livestock sector, including those aimed at improving lifestyle choices and dietary habits. 2- ON INTEGRATIVE ASPECTS. From our view, integrative aspects and the identification of subsidies going against climate objectives would be best addressed in the Section on Coherence of (C.2) Issues to be examined of the Roadmap. Therefore, we would propose two additional points in that section on Coherence, as follows: - (9.c) What are the CAP measures which are directly or indirectly could be identified as frustrating climate objectives? - (Additional point / 11.) To what extent have CAP measures identified as having a positive/negative impact towards climate action have been delivering or have the potential to deliver on other environmental challenges? #Sustainable use of water. #Soil and nutrient management. #Biodiversity conservation. #Impacts of imported commodities. #Other environmental challenges. Please see file attached for further details and justification.
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Meeting with Phil Hogan (Commissioner)

27 Jun 2017 · Opening office

Meeting with Juergen Mueller (Cabinet of Vice-President Karmenu Vella)

10 May 2017 · Discussion on EEB's studies' findings and the CAP post 2020

Meeting with Karmenu Vella (Commissioner) and

2 May 2017 · Blue Economy Financing Principles

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and European Environmental Bureau

6 Apr 2017 · Biodiversity

Meeting with Jyrki Katainen (Vice-President) and Friends of the Earth Europe and

3 Apr 2017 · Sustainability finance in the mid-term review of the Capital Markets Union

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella)

8 Mar 2017 · Blue Economy, Our Ocean Conference 2017

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu) and European Environmental Bureau and Stichting BirdLife Europe

16 Feb 2017 · Commission's Action Plan for Nature, People and the Economy

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and Transport and Environment (European Federation for Transport and Environment) and

1 Feb 2017 · A Union of Democratic Change; Energy Union; Jobs, Growth and Investment; A stronger Global Actor

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella)

25 Jan 2017 · Ocean Governance, IUU, Our Ocean Conference 2017.

Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan)

12 Jan 2017 · WWF policy programme

Meeting with Ioana Diaconescu (Cabinet of Commissioner Pierre Moscovici)

10 Jan 2017 · Debt relief for a living economy, in Greece

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)

19 Dec 2016 · Sustainable development

Meeting with Martin Selmayr (Cabinet of President Jean-Claude Juncker), Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and Notre Europe - Institut Jacques Delors / Notre Europe - Jacques Delors Institute

8 Dec 2016 · Current EU policy issues

Meeting with Miguel Arias Cañete (Commissioner) and Climate Action Network Europe and

18 Nov 2016 · COP22

Meeting with Valdis Dombrovskis (Vice-President) and

17 Nov 2016 · sustainable/green finance

Meeting with Miguel Arias Cañete (Commissioner) and Climate Action Network Europe and

17 Nov 2016 · COP 22

Meeting with Miguel Arias Cañete (Commissioner) and Climate Action Network Europe and

15 Nov 2016 · COP 22

Meeting with Miguel Arias Cañete (Commissioner) and Climate Action Network Europe and

14 Nov 2016 · COP 22

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella)

8 Nov 2016 · Ocean governance, sustainable blue growth in the mediterranean

Meeting with Miguel Arias Cañete (Commissioner) and Climate Action Network Europe and Greenpeace European Unit

8 Nov 2016 · COP 22 and the winter energy package

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella)

27 Oct 2016 · Ocean Governance, Our Ocean 2017

Meeting with Valdis Dombrovskis (Vice-President) and

27 Oct 2016 · Sustainable Finance; CMU

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

26 Oct 2016 · Capital Markets Union

Meeting with Joao Aguiar Machado (Director-General Maritime Affairs and Fisheries) and European Community Shipowners' Associations and

18 Oct 2016 · Shipping of Shark Products

Response to Interservice consultation on a Commission proposal for the GES Decision

11 Oct 2016

We would like to bring to your attention some fundamental improvements that are still needed to ensure that the revised Decision leads to a more effective implementation of the MSFD. We recognise that the proposed draft Decision is an improvement upon Decision 2010/477/EU by providing for a clearer and simpler approach to the determination and assessment of GES. We welcome the greater importance given to regional and EU-level processes, increasing chances of a coherent implementation of the MSFD. However, we are concerned that the search for clarity and simplicity risks lowering the overall level of ambition of the Directive. We therefore urgently request you to consider the following: 1. Include a clear safeguard mechanism for the setting of threshold values: The revised Decision relies extensively on the setting of ‘threshold values’ as the intrinsic mechanism by which Member States are to determine GES. In the present text, there is neither an independent process that is established to recommend these values, nor is the European Commission empowered to review and agree to these values. Furthermore, Member States are left to put forward these values without any clear guidance on timeline. The use of the expression ‘as soon as possible’ leaves far too much room for interpretation and a cut-off date is essential to ensure that Member States do not indefinitely delay doing so. Finally, the application of the precautionary principle, as per Article 4(1), should also apply at national level and not just at regional/EU level, reflecting the potential risks to the marine environment, the need to be consistent across different criteria when they relate to the same ecosystem element, and the necessity to make use of best available science. 2. Include a control mechanism in case Member States decide not to use secondary criteria: The current text gives a large degree of discretion to Member States in the selection and use of secondary criteria. This is not compensated by an appropriate control mechanism that would guarantee that this selection is made in the circumstances foreseen by the Decision, i.e. as complement to a primary criterion or when the marine environment is at risk of not achieving or not maintaining GES. This is particularly worrying when considering that certain Descriptors are now covered only by secondary criteria. At least, Member States should be required to provide the Commission with a justification for their selection, as is foreseen in Article 3(1) for the primary criteria. 3. Ensure that the revised Decision is fully coherent with other EU policies and objectives: Inconsistencies have been identified, which are extremely worrying at this late stage in the process. Specifically, the language used for criterion D3C1 on fishing mortality needs to be brought in line with the language used in Article 2(2) of the CFP Regulation. We also strongly object to the possibility given to Member States to define a ‘maximum allowable extent’ of habitat loss under criteria D6C4 and D6C5. Allowing Member States to set an acceptable level of habitat loss is contrary to the spirit of the Directive, as well as to the ‘Not Net Loss’ objective of the EU Biodiversity Strategy and the objective of the Convention on Biological Diversity to halt biodiversity loss. Finally, we have come to understand that the ongoing public consultation is a mere ticking box exercise without any scope for the responses to be taken on board in the final text. While we appreciate the efforts made by the Commission to organise in March 2016 a stakeholder consultation involving the observers of the MSCG, this cannot be seen as a replacement for an open public consultation. We request an evaluation of how the feedback collected during the public consultation is reflected in the final Decision. You will find our more detailed comments at: http://seas-at-risk.org/images/pdf/Other_pdfs/NGO_comments_GES_decision_Oct2016.pdf
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Meeting with Joao Aguiar Machado (Director-General Maritime Affairs and Fisheries) and FUNDACION OCEANA and

28 Sept 2016 · South Western Waters Advisory Council

Meeting with Karmenu Vella (Commissioner)

2 Sept 2016 · Ocean Governance, Blue Growth,

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella)

17 Aug 2016 · Ocean Governance

Meeting with Miguel Arias Cañete (Commissioner) and Climate Action Network Europe and

14 Jul 2016 · ESD/LULUCF- Energy efficiency - update- Ratification Paris Agreement

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and European Environmental Bureau and

12 Jul 2016 · Climate Action and Energy

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

7 Jul 2016 · Green finance

Meeting with Daniel Calleja Crespo (Director-General Environment) and Grupo de Estudos de Ordenamento do Território e Ambiente and

28 Apr 2016 · RN2000, Natura Network Management, Fitness check of Nature Directives

Meeting with Joao Aguiar Machado (Director-General Maritime Affairs and Fisheries)

27 Apr 2016 · Sharks

Meeting with Jonathan Faull (Director-General Taskforce on Article 50 negotiations with the United Kingdom)

25 Apr 2016 · UK Referendum

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker) and MARSH McLENNAN COMPANIES FRANCE and WWF - UK

5 Apr 2016 · Capital Markets Union

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Climate Action Network Europe and

21 Mar 2016 · Phasing out support to fossil fuels

Meeting with Miguel Gil Tertre (Cabinet of Vice-President Jyrki Katainen) and CEE Bankwatch Network and Green Budget Europe AISBL

17 Mar 2016 · EU Semester

Meeting with Miguel Arias Cañete (Commissioner) and Transport and Environment (European Federation for Transport and Environment) and

11 Mar 2016 · Implications of the Paris Agreement in the EU climate and energy policies

Meeting with Juergen Mueller (Cabinet of Vice-President Karmenu Vella) and European Environmental Bureau and Stichting BirdLife Europe

23 Feb 2016 · Nature Refit, SDGs, Air Quality

Meeting with Kilian Gross (Digital Economy)

28 Jan 2016 · energy efficiency

Meeting with Kilian Gross (Digital Economy)

28 Jan 2016 · energy efficiency, gas package

Meeting with Miguel Arias Cañete (Commissioner) and Transport and Environment (European Federation for Transport and Environment) and

21 Jan 2016 · COP21 and oncoming legislative package

Meeting with Ann Mettler (Director-General Inspire, Debate, Engage and Accelerate Action) and CONCORD Europe

12 Jan 2016 · Implementation of the 2030 Agenda for Sustainable Development in the EU

Meeting with Miguel Arias Cañete (Commissioner) and Climate Action Network Europe and

10 Dec 2015 · State of play climate negotiations COP21

Meeting with Miguel Arias Cañete (Commissioner) and Climate Action Network Europe and

9 Dec 2015 · state of play climate negotiations COP21

Meeting with Miguel Arias Cañete (Commissioner) and Climate Action Network Europe and

8 Dec 2015 · State of play Climate negotiations

Meeting with Miguel Arias Cañete (Commissioner) and Climate Action Network Europe and

6 Dec 2015 · COP21

Meeting with Miguel Arias Cañete (Commissioner) and Climate Action Network Europe and

25 Nov 2015 · COP21 PARIS

Meeting with Joao Aguiar Machado (Director-General Maritime Affairs and Fisheries) and Greenpeace European Unit and

10 Nov 2015 · Implementation of CFP / fighting against IUU

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

9 Oct 2015 · Forest

Meeting with Daniel Calleja Crespo (Director-General Environment)

5 Oct 2015 · Fitness check of Nature Directives & Biodiverisy Objectives

Meeting with Karmenu Vella (Commissioner) and Greenpeace European Unit and

28 Sept 2015 · Ocean Governance, IUU

Meeting with Karmenu Vella (Commissioner) and Greenpeace European Unit and

22 Sept 2015 · Common Fisheries Policy

Meeting with Miguel Arias Cañete (Commissioner) and

17 Sept 2015 · Environment Council Preparation

Meeting with Miguel Arias Cañete (Commissioner) and

4 Sept 2015 · International Climate negotiations and Commission Working Programme

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

25 Aug 2015 · Governance in 2030 Energy Union

Meeting with Karmenu Vella (Commissioner) and Greenpeace European Unit and

23 Jun 2015 · Ocean Governance

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella) and The Pew Charitable Trusts

15 Jun 2015 · Illegal, Unreported and Unregulated Fishing, Ocean Governance

Meeting with Valdis Dombrovskis (Vice-President) and

5 May 2015 · Environmental aspects of the European semester

Meeting with Valdis Dombrovskis (Vice-President) and

5 May 2015 · Environmental aspects of the European semester

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella) and The Pew Charitable Trusts and Environmental Justice Foundation

30 Apr 2015 · IUU fishing

Meeting with Miguel Arias Cañete (Commissioner) and

30 Apr 2015 · International climate talks and EU climate diplomacy. State of play of legislative files

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella)

24 Apr 2015 · IUU fishing

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström)

21 Apr 2015 · Export credits for coal plants / climate change

Meeting with Antoine Kasel (Cabinet of President Jean-Claude Juncker)

6 Mar 2015 · European Semester

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and European Environmental Bureau and

20 Feb 2015 · Post 2015

Meeting with Frans Timmermans (First Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

13 Feb 2015 · Meeting with Representatives of Green 10 on CWP 2015

Meeting with Karmenu Vella (Commissioner) and ClientEarth AISBL and

4 Feb 2015 · Blue and green growth, Marine Strategy Framework Directive, Marine litter, Aquaculture, Seabed mining

Meeting with Vytenis Andriukaitis (Commissioner) and

30 Jan 2015 · The Food Chain, Innovation and Challenges, Food Information to Consumers, Nutrition, and Food Waste, Animal Health, Animal Welfare and Plant Health

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)

26 Jan 2015 · Energy Union

Meeting with Karmenu Vella (Commissioner) and FUNDACION OCEANA and The Pew Charitable Trusts

19 Jan 2015 · Illegal, Unreported and Unregulated Fishing

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and Greenpeace European Unit and Fern

19 Jan 2015 · Deforestation

Meeting with Miguel Arias Cañete (Commissioner) and

15 Jan 2015 · Follow-up to Lima and climate action diplomacy up to Paris / Energy Union (state of play)

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

12 Jan 2015 · EU2020 and European Semester

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and Transport and Environment (European Federation for Transport and Environment) and

18 Dec 2014 · Energy Union

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella)

12 Dec 2014 · Illegal, Unreported and Unregulated fishing

Meeting with Karl-Friedrich Falkenberg (Director-General Environment)

11 Dec 2014 · Timber regulations

Meeting with Karmenu Vella (Commissioner) and

4 Dec 2014 · Implementation of the reformed Common Fisheries Policy, Ocean Governance, Deep Sea Access

Meeting with Karl-Friedrich Falkenberg (Director-General Environment)

3 Dec 2014 · WWF european Board Chairs

Meeting with Miguel Arias Cañete (Commissioner) and

13 Nov 2014 · Lima climate talks; climate and energy priorities