Austrian Chamber of Agriculture

The Austrian Chamber of Agriculture emphasizes the urgent need to defossilize the European Unions economy, to reduce the dependencies on fossil-based and critical raw materials. In times of geopolitical insecurities and vulnerable supply changes, defossilization and the reduction of dependencies are essential to strengthen and expand resilience and economic viability in the EU-27.

The Austrian Chamber of Agriculture welcomes the opportunity to submit the following initial assessment regarding the European Commission proposal to amend the “Renewable Energy Directive (REDIII)” – part of the “Fit for 55” package: The REDIII draft proposed by the EC sets the target of doubling the share of renewable energy in the gross final energy demand of the EU27 from 20% in 2020 to 40% in 2030.

Biogenic energy sources are by far the most important contributors to renewable energy sources, both at EU level and in each Member State. The European Union’s framework conditions must therefore be geared towards the positive development of all bioenergy technologies.

Filed in German · English published by the European Commission

Packaging waste from food is directly linked to our "modern" way of living: with long value chains, convenience food, food on the go, fast food etc. It is necessary to introduce legal rules to reduce packaging waste to force the industry to innovate and not just take the cheapest solution.

On behalf of the Austrian Chamber of Agriculture, BIO AUSTRIA, and the IG-Bio-Control Bodies, I would like to submit the following concise proposals within the framework of the simplification process for Regulation (EU) 2018/848. These proposals would lay the foundation also for a restructuring of the secondary legislation system and could contribute to greater clarity on specific interpretive issues.

From the view of the Austrian Chamber of Agriculture we would like to comment as follows: - We agree on the proposal for a revision of the Waste Directive with regard to food waste as it was presented and justified by the Commission.

As Chamber of Agriculture we welcome the initiative to reduce food waste. Looking at the figures estimated the amount of wasted resources through discarded food is enormous and achieving improvements pivotal. The over-arching principle should be to choose those methods and means which reach the envisaged goals as efficient, effective and quick as possible.

As representatives of Austria’s agriculture and forestry, sustainability is a key concern and we therefore welcome initiatives to promote environmental protection and human rights not only within the EU, but also globally, and to prevent the violation of these goods. However, there are some substantive elements of the proposal that need to be revised.

Filed in German · English published by the European Commission

The EU is pursuing a number of approaches to achieving its ambitious climate targets, with CO2 sequestering in particular as a means of achieving targets, in addition to avoiding greenhouse gas emissions. In order to compensate for residual emissions that are difficult to reduce, CO2 removals from the atmosphere and permanent storage in geological reservoirs, ecosystems or products are necessary.

Filed in German · English published by the European Commission

The term ‘first mover’ comes from economics and refers to companies that are the first to enter the market with an innovative product or service. In the economy, these companies create new standards and can thus gain significant competitive advantages. However, they also bear a high risk, as innovations or novelties often suffer from childhood illnesses.

Filed in German · English published by the European Commission

The ETS currently covers around 10.000 energy-intensive installations responsible for about 40 % of GHG emissions in the EU. In our view, the necessary tightening of greenhouse gas emissions in high-emission sectors, in particular fossil GHG emissions, has been partially implemented, but is insufficient in view of the increased climate target.

Filed in German · English published by the European Commission

I refer to the entire opinion in annex, which covers all open policy areas and includes general policy considerations. On the revision of the ETS trading system (Directive 2003/87/EC) We support the intention to broaden the policy area of the ETS. However, the energy-intensive installation-based approach based on the polluter pays principle should be maintained.

Filed in German · English published by the European Commission

Once again, the focus of this initiative is very much on the excessive push for the use of electrical energy. The challenging areas of heating, cooling and transport identified in the paper cannot be so easily and above all fully electrified, especially in the short time required.

Filed in German · English published by the European Commission

As the draft regulation has already been published and submitted to the other EU institutions we lack the understanding of this feedback process. Never before the European Commission (EC) has asked for a public feedback in this way after the proposal being already published. Therefore, we do not understand how the EC will make use of it.

Preserving biodiversity is important for all areas of life, including agriculture and forestry. We would like to refer to the Annex and would like to highlight the following point: The roadmap is not suitable as a direction The terminology used already raises many questions: What is natural? What are degraded ecosystems?

Filed in German · English published by the European Commission

The Austrian Chamber of Agriculture supports the aim of this regulation which is stopping global deforestation but underlines that its current requirements are neither fit for purpose nor proportionate as they exempt EU farmers and foresters from any market interaction if they do not prove that their area is deforestation free (although the pastures and soy fields have been arable land since centuries and the forest…

Rückmeldung Omnibus-Paket Wien, 04. Mai 2026 1. Allgemeines zur Mitteilung: Vereinfachungen für eine nachhaltige Wettbewerbsfähigkeit Die Landwirtschaftskammer Österreich begrüßt grundsätzlich die Zielsetzung der Kommission, regulatorische Komplexität zu reduzieren und die Wettbewerbsfähigkeit zu stärken.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Stellungnahme der Landwirtschaftskammer Österreich Roadmap to Nature Credits Wien, 30. September 2025 Wird ein System zur Vergabe von Nature Credits eingeführt, muss dieses einen echten Beitrag zur Förderung der Biodiversität und zum Schutz natürlicher Ressourcen leisten und die entsprechenden Leistung der Land- und Forstwirt:innen honorieren.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

On behalf of the Austrian Chamber of Agriculture I would like to react as follows: "breakfast directives" o Honey Directive: The proposal goes into the right direction but not far enough. There is a need for better information on the origin in that cases where several countries are involved in mixed honeys.

On behalf of the Austrian Chamber of Agriculture we would like to react to your request as follows: breakfast directives: o Honey Directive: The proposal goes into the right direction but not far enough. There is a need for better information on the origin in that cases where several countries are involved in mixed honeys.

In principle, the European Commission’s reflections on making air transport more sustainable and, in this context, in particular a requirement for the incorporation of sustainable aviation fuels, are supported. However, we recommend using fuels that are or may be available at the required scale. Biofuels from biomass, both conventional and advanced (waste-based) are already available alternatives.

Filed in German · English published by the European Commission

The Austrian Chamber of Agriculture welcomes the objective of establishing uniform guidance for the application of the DNSH principle within the EU budget. Harmonisation can help simplify the currently differing requirements. However, it is crucial that the new guidance does not lead to increased complexity. The criteria and control mechanisms must be designed as simple as possible.

We welcome the updated nitrous oxide efficacy values and also the introduction of a 45 gCO/MJ bonus for biomethane from manure. The planned amendments to Annexes V and VI of the Renewable Energy Directive (RED III) raise some questions and serious concerns about regulatory consistency and fairness.

Filed in German · English published by the European Commission

In view of the continuing deterioration of climate change with the continued untapped release of fossil CO2 caused by the exploitation of underground coal, oil and natural gas deposits, the agricultural and forestry sectors must urgently focus on maintaining our livelihoods in the region.

Filed in German · English published by the European Commission

I refer to the entire opinion in annex, which covers all open policy areas and includes general policy considerations. On the revision of the LULUCF Regulation The age class distribution in forests (partial population ageing), the evolution of tree species, as well as the increasing biotic and abiotic damage events, inevitably lead to lower CO2 uptake during the forest conversion phase, towards climate-resilient…

Filed in German · English published by the European Commission

Further development of the LULUCF Regulation Mitigating climate change and its consequences is undoubtedly the biggest challenge for mankind today. Climate change (droughts, storms, pests, etc.) also threatens forest ecosystems themselves.

Filed in German · English published by the European Commission

The forestry and wood sectors make a significant and often underestimated contribution to climate action. In Austria, this contribution has accumulated to around 990 mio. tonnes of CO since 1990, which have been removed from the atmosphere or not additionally emitted due to active forest management. This effect results from the increase in forest growing stock (from approx. 900 Mio. m³ in 1990 to about 1.2 bn.

The Austrian Chamber of Agriculture welcomes the willingness and ambition of the European Commission to strengthen the position of farmers in the supply chain. However, this must not create new red tape, but only real benefits for farmers.

Filed in German · English published by the European Commission

We would be able to provide the following feedback from the Austrian Chamber of Agriculture in the context of the consultation on the proposed Delegated Act. The Austrian Chamber of Agriculture fully supports the letter from the 16 Member States, including Germany, France, Italy, the Netherlands and Austria, dated 15 October 2024, to the EC, DG Energy.

Filed in German · English published by the European Commission

In the opinion of the Austrian Chamber of Agriculture, there are fundamental concerns about this draft: • New scope threatens legal certainty The proposal provides that environmental NGOs may in future also challenge administrative acts of general interest. The definition covers all administrative acts, irrespective of their policy objectives or legal bases.

Filed in German · English published by the European Commission

The Austrian Chamber of Agriculture respects the principles of the Aarhus Convention. Access to information, public participation and access to administrative or judicial procedures for decisions that have a significant impact on the environment are important for public participation.

Looking at the historical development of the GI system for food, wines and spirits it was (and is) still a challenge to establish and secure this special type of intellectual property. There are still lots of problems (international agreements, practical implementation, fraud etc.) to solve. The non-food and craft sector is very diverse between the various crafts and different from food.

The draft legal text which lies on the table is the outcome of a long-lasting process led by the Commission and pro-actively accompanied by many stakeholders like Copa-Cogeca to which the Austrian Chamber of Agriculture is a member.

The Austrian Chamber of Agriculture supports the basic idea behind the further development of the Farm Accountancy Data Network to create a solid and comparable data base across the EU for the presentation, communication and further development of the performance of the CAP. The possibility of providing financial incentives for participating farms to compensate them for their expenses is particularly positive.

Filed in German · English published by the European Commission

FADN has been and is an important tool in assessing the economic and financial situation of European farmers, which still lags 53% behind the wages/loans of EU economic average. If the FSDN as follow-up of the FADN has the aim to address the F2F targets it is of utmost importance that those targets have to undergo a comprehensive impact assessment regarding its impact on food security as well as the economic…

With regard to the material effects, the distinction between Articles 9 (2) and 9 (3) indicates a deliberate assessment of a significant environmental threshold, in particular not an equality of all environmental measures.

The UTP directive together with the national implementing legislation (and the possibility to adapt the legislation to the national needs and specificities) provides a crucial instrument to foster the position of the weaker partners in the supply chain especially that of primary producers.

Round-blown treeworms should not be included in the list because they are well suited to climate adaptation measures that become necessary. For the purpose of greening façades, which are placed under controlled conditions as a result of the increasing number of heat days, it seems appropriate to use it. Round-blown tree spices should also not be included in the list.

Filed in German · English published by the European Commission

The Austrian Chamber of Agriculture supports the proposed amendments. As it is becoming increasingly difficult to ensure a comprehensive supply of physical veterinarians, an increase in flexibility while using up-to-date technological methods is to be welcomed.

Filed in German · English published by the European Commission

The LULUCF regulation and its insufficient consideration of climate change effects and external factors in scenario development, the omission of substitution effects through biogenic materials and energy sources, and methodologically inaccurate sectoral allocations are leading to incorrect assumptions about the actual sink performance of the LULUCF sector and thus to illusory regulation targets.