The Institute for Agriculture and Trade Policy (IATP) welcomes the opportunity to give feedback to the European Commissions proposal for a Carbon Removal Certification Framework. We would like to highlight twelve major concerns about the proposal and urge the European Commission to consider those moving forward: 1.
IAT
Institute for Agriculture and Trade Policy (IATP) Europe
NGO · Germany · EU Transparency Register 653202437126-60
8
positions filed
in the 665 files tracked
7
legislative files
of 665 tracked
6
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1106 non-governmental organisations on this site, they rank #183 by legislative files engaged, a count of participation, not a measure of influence.
2.2
declared lobbying FTE
self-declared
–
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2020
in the register since
Declares membership of
- Climate Action Network Europe/International https://caneurope.org/our-members/
- Food Policy Coalition https://foodpolicycoalition.eu/participants/
- Climate Land Ambition & Rights Alliance https://www.clara.earth/
- Real Zero Europe https://www.realzeroeurope.org/#who-are-we
- Agroecology Europe https://www.agroecology-europe.org/
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Non-governmental organisations
- Registered as
- Institute for Agriculture and Trade Policy (IATP)
- Head office
- Minneapolis, United states
- EU office
- Berlin
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Institute for Agriculture and Trade Policy (IATP) Europe filed 8 positions between 2 May 2022 and 4 May 2026, across 7 of the 665 legislative files tracked here, attaching a full position paper 6 times.
2022 · 1 filed2023 · 1 filed2025 · 1 filed2026 · 5 filed
What they argued
Berlin, 02 May 2022 Call for evidence: EU Carbon Removals Certification Framework The Institute for Agriculture and Trade Policy (IATP) welcomes the opportunity to give feedback on the planned carbon removal certification framework. We urge the European Commission (EC) to fundamentally rethink its approach on integrating carbon removals into the EU climate framework.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Institute for Agriculture and Trade Policy (IATP) Europe welcomes the EUs efforts to make its 2040 climate target legally binding. Europe is the worlds fastest-warming continent. Climate extremes, especially drought, are already costing farmers billions per year and will only get more frequent and more severe without strong action to cut climate pollution.
The Institute for Agriculture and Trade Policy (IATP) Europe welcomes the application of the Do No Significant Harm (DNSH) principle across EU spending in the next long-term budget; however, we are concerned about the proposed blanket exemption of some farm subsidies from adhering to this principle.
The European office of the Institute for Agriculture and Trade Policy welcomes the opportunity to provide feedback on the European Commissions proposal of the review of Annex V and Annex VI of the Renewable Energy Directive (Directive (EU) 2018/2001). Please find our comments in the file attached.
To support the strategic planning needed to unlock the potential of the food and farming sector to deliver climate action, the revised Governance Regulation should: (1) Set an EU-wide emissions reduction target for agriculture and mandate the development of Member State level sectoral targets.
To unlock the potential of the food and farming sector to deliver climate action and assist with meeting national targets, the future legislative framework should: (1) Set an EU-wide emissions reduction target for agriculture and mandate the development of Member State level sectoral targets.
The UTP Directive is a step in the right direction, but further improvements are needed to protect farmers and ensure fair prices. (1) Add buying below the cost of sustainable production to the UTP blacklist. Farmers hold little power in the food value chain and are often forced to accept unfair terms or risk losing buyers or letting perishables go to waste.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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Everything on this page comes from Institute for Agriculture and Trade Policy (IATP) Europe’s own submissions to the European Commission. We have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.