Deutscher Bauernverband e.V.

The German Farmers Association (DBV) welcomes the European Commissions initiative to develop a comprehensive strategy on the right to stay and strongly supports the objective. In this context, the DBV emphasises the importance of strengthening rural areas, ensuring equivalent living conditions, and aligning key EU policies and funding instruments to reduce regional disparities and promote sustainable development.

There is a general problem of too little organic livestock farming due to organic legislation. We have around 11-12 % of organic land in the EU. But we have only around 4-5 % organic livestock farming. Organic farming is largely in a 1-4 % niche (except extensive cattle rearing and laying hens with around 10 %). Organic livestock farming is therefore more than half lower than the proportion of organic land.

Filed in German · English published by the European Commission

In the view of the German Farmers’ Association, the changes proposed by the Commission are a first step in the right direction, but remain completely insufficient and do not reflect the actual situation in Germany and many European Member States.

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As the German Farmers’ Association, we recommend raising the maximum authorised weights for vehicles and vehicle combinations to 46 tonnes, for reasons of efficiency, but also for reasons of climate protection. In the agricultural sector, the transport of sugar beet, but also of other agricultural products, is particularly important.

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We expressly welcome the European Commission’s fundamental objective of simplifying environmental legislation and thereby strengthening the competitiveness of the sectors concerned. Many existing schemes are complex, sometimes contradictory or outdated and place a significant burden on farms. It is therefore positive that the Commission addresses this issue.

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Climate change mitigation and adaptation are global challenges. In principle, the German Farmers’ Association supports the objective of strengthening the EU’s resilience to the consequences of climate change. Agriculture and forestry are, like hardly any other sector, directly affected by the effects of climate change.

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The German Farmers’ Association clearly rejects the planned introduction of the DNSH principle (Do No Significant Harm) for environmental and climate concerns in agriculture. The DNSH principle does not fit the current challenges of agriculture and forestry either in time or systematically. Agriculture already makes a significant contribution to the environment, climate and biodiversity objectives.

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In principle, the German Farmers’ Association (DBV) welcomes the procedure as such and the specific draft of Annex III to the Nitrates Directive. The use of nitrogen from treated manure allows farmers to feed crops even more effectively and can not only help to reduce Europe’s dependence on imported fertilisers or the energy sources needed to produce these fertilisers, thereby ensuring food security.

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We would like to take advantage of the opportunity to participate in the consultation process and to comment on the outcome of the European Commission’s evaluation report on the UTP Directive and its further orientation. The UTP Directive was adopted in 2019 and transposed by Member States by 2021.

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The land sector plays a key role in achieving the socially desired and politically decided goal of climate neutrality in Europe. Only additional carbon sinks will it be possible to offset unavoidable residual emissions from, inter alia, construction and agriculture. However, from the point of view of the German Farmers’ Association, it is important to put this achievement on a broad footing.

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Due to the impact of Regulation (EC) No 2100/94 on Community plant variety rights on German agriculture, the German Farmers’ Association e.V. refers to the invitation to comment on the re-evaluation of the Regulation. First of all, the German Farmers’ Association e.V. warmly welcomes the regular evaluation of the Regulation in order to bring about any improvements.

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The German Farmers’ Association (DBV) is commenting on the mid-term evaluation of the CAP 2023-2027. The CAP influences economic stability, has an impact on the EU’s internal market, targets environmental performance and the sustainability of farms. The experience from 2023-2025 clearly shows that the CAP remains a key pillar of European agriculture.

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The German Farmers’ Association recognises the importance of climate protection and the fundamental role of the land use, land use change and forestry (LULUCF) sector in supporting European climate goals. At the same time, since the revision of the LULUCF Regulation in 2021, significant challenges to offset residual cross-sectoral emissions have been transferred to actors in this single sector.

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The German Farmers’ Association welcomes the European Commission’s initiative to remove the obligation to register plant protection products in the geospatial application. The current regime creates significant additional costs and commits resources without creating any discernible added value for the environment or administration.

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The German Farmers’ Association (DBV) thanks the European Commission for the opportunity to submit an opinion in the context of the Call for Evidence on the further development of EU Integrated Farm Statistics (2030-2039) and Regulation (EU) 2018/1091. I. Introductory comments, Regulation (EU) 2018/1091 provides the legal basis for the surveys in 2020, 2023 and 2026.

Filed in German · English published by the European Commission