BirdLife Europe and Central Asia

To ensure the Climate Law is an effective tool for climate governance, the Climate Law, in addition to enshrining a long-term climate target into law, should govern ambitious policy making to deliver on the European Green Deal and should avoid specific pitfalls related watering down the speed or ambition of climate action.

BirdLife Europe supports the European Commission’s initiative for a Climate Law enshrining a legally binding climate neutrality commitment for Europe, with decarbonisation plan and specific time commitments, into law. Doing so will confirm the commitment of the EU and its member states to the Paris Agreement targets.

BirdLife welcomes this regulation which is a first attempt to create a financial system to enhance the carbon removals, although we consider that this should be done mainly by enhancing the natural ecosystems which are precious carbon sinks.

BirdLife Europe and Central Asia welcomes this Directive as it sets to address the greenwashing we are currently attesting in every sector. Although the general direction of the law is the right one, we think that some aspects are either overlooked or need to be improved. Today there is a profusion of different labels, competing and adding more confusion to the consumer .

BirdLife, WWF, EEB and Client Earth strongly welcome the Commission's legal proposal for the Nature Restoration Law, because it is a big opportunity and leverage to bring nature back to Europe, for the benefits of biodiversity, climate and people. The proposal has the potential to make a real impact at the required scales, if implemented in a timely and well-considered manner.

BirdLife welcomes the initiative for binding restoration targets and recommends the following: A. Aspects guiding the next steps 1. With this restoration initiative, the Commission should focus on binding nature restoration targets. 2. The also mentioned possibility of an EU wide methodology to map and assess ecosystems and their delivery on soil, pollination etc.

The proposed provisions in the Regulation for the speeding up of environmental assessments (part of the Environmental Omnibus package) risk fundamentally altering the architecture of EU environmental law and creating long-term systemic risks when it comes to nature and wider environmental protection, and access to justice.

Despite its existing framework to protect the marine environment, the EU is not on track to reach its environmental targets and to halt marine biodiversity loss by 2030 , due mainly to a lack of policy coherence, poor implementation, and siloed governance.

BirdLife Europe and Central Asia | EU Consultation Response | 09/2025 Ref. Ares(2025)8233627 - 30/09/2025 BirdLife consultation response: Nature Credits Roadmap Setting the Scene – What role can Nature Credits play? The nature crisis is accelerating, and attention increasingly turning away from it – with dramatic costs.

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

Europe's housing challenges demand effective action. Simplification can help improve housing availability and affordability by removing barriers to renovation and vacancy conversion. However, simplification should not sacrifice health and environmental standards to blindly boost new construction; this is detrimental. Simply boosting new construction will not address the roots of the housing crisis.

BirdLife Europe urges using nature-based solutions (NbS) for climate adaptation and disaster risk reduction, as recommended by the 2021 European Climate Risk Assessment. Nature is our best ally against effects of climate change by increasing resilience and providing many other societal benefits. Grey solutions risk having contrasting effects, while NbS reduce such risks.

Birdlife contribution to the call for evidence highlights the importance of grid modernisation to meet climate and renewable energy targets, while insisting that this must not come at the cost of nature. Grid expansion and upgrades must respect existing EU environmental legislation and actively contribute to biodiversity protection and restoration.

BirdLife Europe welcomes the application of the DNSH principle to the Multiannual Financial Framework. Effective DNSH implementation requires that EU spending contributes to climate and nature objectives, with robust, science-based criteria applied to all six objectives. All DNSH criteria must be met before EU funds are disbursed.

We welcome the Commissions initiative to set out a strategy for heating and cooling that delivers affordability, resilience and climate integrity. To achieve this, the strategy must put energy efficiency first, prioritise clean, non-polluting solutions, and avoid reliance on bioenergy. Heating and cooling account for half of the EUs energy demand, with 70% still met by fossil fuels.

BirdLife welcomes the proposal for the revised TEN-E Regulation. The European Commissions` decision to take out the energy infrastructure categories for natural gas projects and oil transport projects is a necessary step forward. A study by Artelys (2020) found that existing gas infrastructure is able to meet future gas demand scenarios.

BirdLife Europe and Central Asia welcomes the European Commission’s attempt to revise the TEN-E Regulation. Our recommendations to the TEN-E Inception Impact Assessment are: 1) Revise the TEN-E Regulation in line with the Green New Deal, the Climate Neutrality Objective by 2050, the Climate Law and the Paris Agreement, the EU-Nature Directives, the SEA- and IEA-Directives as well as the new Biodiversity-Strategy in…

Fishing remains a cultural and economic mainstay across Europe, but its survival directly depends on functioning ecosystems. The common notion of balancing environmental, economic, and social interests as equal pillars is misleadingenvironmental limits are not merely one consideration among others but the essential bedrock on which lasting social wellbeing and economic livelihoods depend.

We welcome the strengthening of the LULUCF regulation with the aim to protect and restore the forests needed to sequester carbon dioxide in the effort to keep climate change below 1.5 degrees. However, this must not lead to a decrease of efforts to reduce emissions in other sectors with the hope of off-setting them through LULUCF removals.

The EUs forests are increasingly under pressure even though the area covered by forests is increasing. The current definition of forest can be misleading, as it can include land that is used, or has recently been used for agriculture, as well as monoculture non-native plantations and even tree-less areas (i.e., clearcuts where forest regeneration is planned).

BirdLife supports the prompt and effective designation and operation of RAAs in line with the more detailed comments in the attached document. This will require a step-change in the performance of public authorities and the renewables sector, with significant advances in public awareness, involvement and participation in the climate energy agenda in Member States.

MEMBER STATES NEED TO INCREASE THEIR LULUCF AMBITIONS. Data shows that the worrying declining trend of the LULUCF sink persists and Member States are not taking effective measures to reverse this . As a consequence, the EU is not projected to meet the 2030 obligations with existing measures in place .

Dear Commission, As an organisation working on protecting the environment we know about the importance of access to justice for ensuring compliance with EU law and to address the ecological crisis, both at Member State / EU level. We therefore very much welcome the Commission consultation on the Roadmap. We’d like to stress the following points: A.

BirdLife welcomes this vital initiative. Urgent EU action is essential to help keep natural and intact forests standing if global biodiversity objectives, Sustainable Development Goals and the Paris Agreement are to be met. The EU has a global responsibility to play a leadership role as one of the primary markets for forest commodities. BirdLife has the following comments: 1.

Despite claims that the proposal is intended to benefit farmers, it primarily reduces administrative burdens for Member States while weakening the Commissions oversight of CAP spending and undermining key environmental safeguards - measures that ultimately do not serve farmers long-term interests.

The CAP, as the EUs main tool shaping land use, has a key role in addressing environmental and climate challenges. This is where it can bring clear EU added value, requiring coordinated EU action to protect shared natural resources and meet common environmental goals. It is also essential for the long-term viability and resilience of farming systems.

BirdLife Europe welcomes European Commission’s intention to transform Farm Accountancy Data Network (FADN) into a Farm Sustainability Data Network (FSDN) and enhance data collection by adding environmental and social data at farm level. We also welcome the intentions to allow interoperability with other databases.

BirdLife Europe has a lot of experience with implementing the Aarhus Convention, both on the ground through complaints and court cases of its members and at EU level. We therefore would like to give the following input to the European Commission’s Inception Impact Assessment: The EU is a party to the Aarhus Convention in its own right; it therefore constitutes an integral part of the EU legal order.

As the main funding mechanism aiming to ensure the long-term sustainability of EU fisheries, the EMFAF plays a crucial role in supporting the Common Fisheries Policy, effectively protecting the marine environment, and fostering the resilience of the fishing sector.

The EEA is, together with the Eionet network, a key institution and network tool to provide the knowledge and data needed to prepare, develop, implement and monitor environmental policies across Europe. It helps ensure the scientific basis for good policymaking at EU and national levels. EEAs work and expertise are highly respected and followed by many experts and authorities in the environmental field.

BirdLife Europe echoes calls for the EUTR fitness check to assess the legislation in light of its environmental goals and legal basis (Art. 192 TFEU), and in terms of its contribution to the EU’s forest protection objectives.

Funding through LIFE is highly efficient: investing through co-financing projects pays off many times over, in the form of enabling ecosystem services, job creation and improving environmental democracy. LIFE has made a significant contribution to saving species from extinction, such as the Spanish Imperial Eagle.

BirdLife Europe and Central Asia welcomes the Commission’s proposal revising the directive. Strengthening the protection of the environment through criminal law is essential to support the enforcement of the European Green Deal, and places the EU as a leader in the fight against global biodiversity loss and climate change.