The Central Union of Agricultural Producers and Forest Owners (MTK)

MTK finds the overall paper and its goals acceptable and supports them. From the perspective of the Finnish farmers and forest owners the current state of the European circular economy has the following problems: 1. The price of circular material is almost always more than virgin material.

MTK is in favour of a separate minimum share for advanced biofuels and biogas produced from raw materials in Part A of Annex IX. MTK is also in favour of abolishing double counting. Finland has already abandoned double counting in the past, and the blending obligation rates applied in Finland are significantly higher than those imposed by the EU.

Central Union of Agricultural Producers and Forest Owners in Finland (MTK) welcomes the European Commissions initiative to prepare a Right to Stay communication. The possibility to live, work, and build ones future in their home region is a key part of territorial cohesion, equal opportunities, and social sustainability in the European Union.

The Union of Agricultural Producers and Forest Owners (MTK) want to thank for the opportunity to comment the technical screening criteria on the EU taxonomy climate delegated act. MTK has previously emphasized in the preparation of taxonomy criteria the importance of criteria being encouraging, practically applicable, and accessible. Only in this way can taxonomy achieve broad usability and impact.

MTK supports the European Commission’s proposal to update the Basic Regulation on organic production as it clarifies the existing legal basis and strengthens its internal coherence. Coordinated and structurally clearer provisions will make the whole easier to understand and support consistent implementation of regulation across all production sectors.

Filed in Finnish · English published by the European Commission

Justification for the Revision of Regulation (EU) 2018/848 on Organic Production Finlands Perspective The European Commissions intention to revise Regulation (EU) 2018/848 presents a timely and necessary opportunity to address regulatory provisions that have proven problematic in practice and that hinder the development and competitiveness of organic production, particularly in Nordic conditions.

Central Union of Agricultural Producers and Forest Owners MTK ry Anssi Kainulainen Ref. Ares(2023)771673 - 02/02/2023 2.2.2023 European Commission Feedback to COM on Certification of Carbon Removals – EU rules Central Union of Agricultural Producers and Forest Owner’s (MTK) considers, that It is a good that the legislative initiative that has been taken is voluntary for operators to participate.

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

The role of the EU in the certification of carbon removals To secure in the long run the possibility for landowners to sell their carbon credits also internationally and outside the EU we need credible, transparent, and market-based solutions.

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

The Carbon Limit Mechanism (CBAM) is an important part of the overall effort to ensure a level playing field for the EU’s own operators as part of the implementation of the EU Green Deal. From the perspective of the Central Union of Agricultural and Forestry Producers (MTK), the process highlights the following: 1. The EU tool shall implement this objective at the least possible administrative cost. 2.

Filed in Finnish · English published by the European Commission

I'm representing the Central Union of Agricultural Producers and Forest Owners (MTK). MTK is an interest organisation representing farmers, forest owners and rural entrepreneurs in Finland. MTK has over 316 000 members in local agricultural producers’ organisations and regional forest management associations. In principle the CBAM could be an excellent measure to avoid carbon leakage in all sectors.

The Union of Agricultural Producers and Forest Owners (MTK) want to thank for the opportunity to comment the revision regarding the technical screening criteria on the EU taxonomy climate delegated act. MTK has previously emphasized in the preparation of taxonomy criteria the importance of criteria being encouraging, practically applicable, and accessible.

The Central Union of Agricultural Producers and Forest Owners (MTK) Ref. Ares(2022)5821597 - 19/08/2022 1 (5) Helsinki, Finland 19th August 2022 MTK’s feedback on the proposal for a regulation on nature restoration The Central Union of Agricultural Producers and Forest Owners (MTK) thanks for the opportunity to give feedback on the proposal for a regulation on nature restoration.

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

The Central Union of Agricultural Producers and Forest Owners (MTK) Ref. Ares(2020)7228899 - 01/12/2020 1/2 Helsinki, Finland 1 December 2020 st MTK’s feedback on the Roadmap “Protecting biodiversity: nature restoration targets under EU Biodiversity Strategy” (Inception Impact Assessment) MTK supports the main goal of the EU Biodiversity Strategy 2030 which aims at halting the loss of biodiversity.

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

The Union of Agricultural Producers and Forest Owners MTK thanks for the opportunity to comment the Commissions proposal for the European Climate Law amendment. MTK supports the EU overall climate target for 2040.

The Environment Omnibus is a good starting point for reducing the administrative burden related to environmental legislation, but further work is needed. The Commissions own Vision for Agriculture and Food recognises the urgent need for cross-cutting simplification beyond the CAP; however, in practice, this proposal delivers only very limited relief.

MTK welcomes the European Commissions roadmap regarding the development of nature credits. Nationally and internationally, there is an urgent need to find innovative and widely acceptable solutions to better protect biodiversity and to arrange adequate funding for action. According to MTK, voluntary nature value market is a central part of reaching success.

Statement by the Central Union of Agricultural Producers and Forest Owners (MTK), Finland MTK considers the update of the EU arctic Policy necessary. The geopolitical changes following Russias invasion of Ukraine have significantly affected the operating environment in arctic regions, increasing the importance of security policy. The EU must therefore update its arctic-related policies. 1.

RENURE has been discussed for a long time, and it is good to finally see a proposal. The proposal can be supported from the Finnish point of view, although it does not have much significance in Finland for the time being.

MTK welcomes COM proposal to review LULUCF EU rules. MTK's feed-back includes aspects of proposed calculation methodology, ambition level, compatibility with Paris Agreement, compatibility with coming initiative on restoring sustainable carbon cycles, voluntary carbon market mechanisms, general flexibility, establishing AFOLU, flexibilities of the framwork and environmental integrity.

The key elements for forests to combat the climate change are Substitution, Sequestration and Storage. Forests are unique in doing all this at the same time. All sectors must carry responsibility in the path towards climate neutrality by 2050.

Central Union of Agricultural Producers and Forest Owners (MTK) Ref. Ares(2024)932051 - 07/02/2024 Forest Monitoring Framework for Resilient Forests Commission’s feedback Forest Monitoring Framework for Resilient European Forests The Central Union of Agricultural Producers and Forest Owners MTK welcomes to express views on the Forest Monitoring Regulation proposed by the European Commission in November 2023.

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

The Central Union of Agricultural Producers and Forest Owners (MTK) welcomes the initiative of the Commission to have an impact assessment of the proposal for a new legislative proposal on EU Forest Observation Reporting and Data Collection to ensure a coordinated EU forest monitoring, data collection and reporting system.

The Finnish Union of Agricultural Producers and Forest Owners (MTK) would like to emphasize the role of sustainable forest management and a strong bioeconomy sector for achieving the EU climate targets after 2030. MTK welcomes the agreed target for climate mitigation by 90% by 2040.

Achieving good environmental status in the marine environment, while simplifying the implementation of the Directive and reducing the administrative burden, is a good objective. It is necessary to reduce the administrative burden for operators other than public authorities, where this has been accumulated. It is important that the MSPD is aligned with the Maritime Spatial Planning Directive and the Ocean Act.

Filed in Finnish · English published by the European Commission

The Green Deal proposed by the EU Commission contains a wide range of climate actions. Quite a many of those presents new demands on the agriculture and forestry climate policy, while at the same time both the overall level of the EU financial framework for several years and the financial share of agriculture are threatened with cuts.

The Finnish Union of Agricultural Producers and Forest Owners (MTK) would like to emphasize the role of the sustainable forest management and a strong bioeconomy sector for achieving the EU climate targets for 2040. The entire answer can be found enclosed. Climate actions by forests are based with long-term processes and careful planning.

The Central Union of Agricultural Producers and Forest Owners (MTK) recognizes the importance of the general principles of the Aarhus Convention in relation to access to justice in environmental matters. However, the Commission’s initiative described in the roadmap includes actions that are not justifiable from the point of view of the Aarhus Convention.

The Central Union of Finnish farmers and forest owners appreciates and thanks Commission evaluation of EFSAs operation. Food safety is extremely important issue and EFSAs has done responsible work for it. Local circumstances should be better taken in to account. Specially we recognized this in poultry studies where Finnish production method was not taken into account.

Helsinki, the 27th of February 2019 Feedback on the European Commission inception impact assessment: Review of Agricultural State aid Guidelines and Review of the Agricultural Block Exemption Regulation The Central Union of Agricultural Producers and Forest Owners (MTK) welcomes the European Commission initiative to review the Agricultural State aid Guidelines and the Agricultural Block Exemption Regulation (ABER).