WWF European Policy Office

WWF EPO is pleased to answer to the European Commission's public consultation on the Industrial Accelerator Act (IAA). The IAA is the first flagship proposal under the EUs Clean Industrial Deal and a key test of Europes new industrial strategy.

Please, find the WWF response to the call for evidence attached. Below a summary of our answer: The WWF European Policy Office (EPO) welcomes the opportunity to contribute to the call for evidence on the Industrial Decarbonisation Accelerator Act (IDAA), which aims to tackle the obstacles Energy-Intensive Industries face in their decarbonisation efforts.

WWF welcomes the fact that the Commission has recognised that REDII is not consistent with the achievement of the EU’s 2030 GHG target or with the goals of the Paris Agreement and needs to be reformed. The points within the legislation that need urgently to be amended are as follows: - The 2030 RES target needs to be increased to at least 50% in order to be consistent with the goals of the Paris Agreement; - The…

We welcome the Commissions initiative to review the EU Taxonomy Climate and Environmental Delegated Acts to improve clarity, usability, and cost-effectiveness. However, we express significant concern regarding the proposed process and the implications of simplification. 1.

29 MARCH 2022 WWF welcomes the opportunity to provide feedback, which we focus on four key financial issues related to the revision of the Energy Performance of Buildings Directive (EPBD). The aim is to ensure that the right financial incentives are put in place to meet the EU’s climate and energy objectives, by encouraging consumers to renovate their homes and ultimately reduce their energy bills.

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

Briefing paper on LIFE in the next Multiannual Financial Framework (MFF) September 2025 Introduction LIFE is the EU’s only funding programme exclusively dedicated to the environment and climate. For over thirty years, it has played a pivotal role in supporting the implementation of EU environmental and climate legislation, while delivering measurable benefits for biodiversity and local communities across Member…

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

WWF strongly welcomes European Commissions decision to uphold the core outcomes of the EFRAG multi-stakeholder negotiation process. By preserving double materiality and the fair presentation principle, the EC safeguards the EUs leadership in sustainability reporting. These choices are aligned and supported by the ECB and the FRA.

WWF EPO believes that the draft law contains a number of important omissions, particularly as regards the nearer term – something that has led to it being branded “surrender" by youth climate activists. An assessment of the draft law and the omissions it contains is attached.

In view of the climate emergency, European climate law will have to: Aiming for a greenhouse gas emission reduction target of at least 65 % for 2030 and carbon neutrality for 2040. These objectives are aligned with science and with the UNEP Emissions Gap Report 2019 report.

Filed in French · English published by the European Commission

The law must — Securing a greenhouse gas emission reduction target of at least 65 % for 2030 and carbon neutrality for 2040. These objectives are aligned with science and with the UNEP Emissions Gap Report 2019 report.

Filed in French · English published by the European Commission

The law must — Securing a greenhouse gas emission reduction target of at least 65 % for 2030 and carbon neutrality for 2040. These objectives are aligned with science and with the UNEP Emissions Gap Report 2019 report.

Filed in French · English published by the European Commission

In view of the climate emergency, European climate law will have to: Aiming for a greenhouse gas emission reduction target of at least 65 % for 2030 and carbon neutrality for 2040. These objectives are aligned with science and with the UNEP Emissions Gap Report 2019 report.

Filed in French · English published by the European Commission

In view of the climate emergency, European climate law will have to: — Securing a greenhouse gas emission reduction target of at least 65 % for 2030 and carbon neutrality for 2040. These objectives are aligned with science and with the UNEP Emissions Gap Report 2019 report.

Filed in French · English published by the European Commission

We are facing a climate emergency. As the EU Foreign Affairs Council of ministers said on 20 January: "Climate change is an existential threat to humanity and biodiversity across all countries and regions and requires an urgent collective response".

A key element of the Farm to Fork Strategy, eliminating food loss and waste to the largest extent possible is an urgent and indispensable step towards more sustainable food in the EU. Therefore, WWF welcomes this European Commission initiative to establish legally binding targets to reduce food waste, and the opportunity to provide feedback on the inception impact assessment.

This directive is meant to hold businesses accountable for harming human rights and the environment, and in WWF’s view is critical for the success of the sustainable finance agenda and the European Green Deal. However, WWF is concerned that since it was initially announced, the proposal has lost its ambition. Notably, it will only apply to a tiny fraction of EU companies.

"In the Action 10 of its Action Plan, the Commission committed to assess “(i) the possible need to require corporate boards to develop and disclose a sustainability strategy, including appropriate due diligence throughout the supply chain, and measurable sustainability targets; and (ii) the possible need to clarify the rules according to which directors are expected to act in the company's long-term interest”.

The proposal does not answer key questions when it comes to CDR. This proposal merely establishes a basic framework, leaving key questions unanswered and concepts undefined. The proposal lacks clarity on the role of removals in the EU climate framework which is particularly worrying.

Please find attached WWF EU response to the call for evidence on the EU ETS 1 and MSR. The WWF European Policy Office (EPO) welcomes the opportunity to contribute to the call for evidence on the revision of the EU Emissions Trading System 1 (EU ETS for maritime, aviation and stationary installations (power and industry sectors) and the Market Stability Reserve (MSR), which aims at collecting evidence ahead of the…

As WWF EPO, we wish to submit the attached statement to answer the inception impact assessment on the Border Carbon Adjustment Mechanism (BCA). Our main arguments are summarized below. 1) If introduced, the BCA must be implemented as an alternative to free allocation and within a wider set of policies to ensure the decarbonisation of industry 2) WWF EPO recognises that the BCA could play different catalyzer roles in…

WWF European Policy Office (EPO) welcomes the opportunity to contribute to the European Commissions public consultation on the proposed revision of the EU ETS Benchmarks Regulation for the 20262030 period, as foreseen under the 2022 revision of the EU Emissions Trading System (EU ETS).

WWF fully supports the revision of the EU ETS Directive in line with an increased 2030 emissions reduction target. Emissions from EIIs have been stagnating since 2012 (see recent European Court of Auditors https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=54392).

The WWF European network has compiled evidence in the attached document on the current state of renewable energy across Member States, as well as on key considerations for the post2030 renewable energy framework. Considering the very short deadline, additional info could be provided to Unit C1 & C2 of DG ENER in the coming weeks.

WWF European Policy Office welcomes the opportunity to respond to this consultation on the review of the EU Taxonomy technical screening criteria. We support the EU Taxonomy as a cornerstone of the EU sustainable finance framework and recognise the Commission's efforts to update the criteria across all three taxonomy delegated acts.

WWF welcomes the Commissions proposal to revise the Sustainable Finance Disclosure Regulation (SFDR), which is a necessary step to move towards a more credible, transparent and operational framework. We particularly welcome (1) the establishment of a clear categorisation system, with specific criteria and requirements, (2) robust fossil fuel expansion exclusions in the Sustainable and Transition category, and (3)…

The SFDR is a critical part of the EU sustainable finance framework and has been very successful to raise awareness of investors on sustainability issues. Our WWF targeted recommendations focus on the very specific areas that need improvement.

The EU SingleUse Plastics (SUP) Directive is a key instrument to curb plastic pollution and has already helped reduce marine litter across EU sea basins, while also stimulating research and entrepreneurship. Its overall impact is positive, yet implementation remains uneven across Member States due to delayed transposition, fragmented national approaches, weak enforcement, and grey areas.

WWF European Policy Office supports the legal proposal for a Nature Restoration Law as it is a huge opportunity to bring nature back to Europe, benefiting biodiversity, climate, and people alike. It is an important milestone to reverse the tide of both biodiversity loss and climate change, with the potential to make a real impact at the scales required if implemented in a timely and well considered manner.

Habitat fragmentation, loss and degradation as a result of land and sea use change, through agricultural intensification, grey infrastructure developments, overfishing or intensified forestry is widespread. Further drivers of biodiversity loss, such as the over-exploitation of natural resources both on land and at sea, the effects of the climate crisis, pollution and invasive alien species also contribute to the…

WWF welcomes the Commissions proposal to adopt an EU 2040 climate target. Adopting this target is an important step towards achieving the climate-neutrality objective, and creates certainty and predictability for Member States, industries, investors and citizens. However, WWF is concerned about the lack of ambition of the climate target.

The proposed approach to maintain the initial list of relevant commodities and products in the EUDR scope and to exclude certain products only on the basis that they are not made of relevant commodities will support the implementation of the legislation.

WWF European Policy Office welcomes the European Commission’s opportunity to give feedback on the proposal for a regulation on the establishment of a framework to facilitate sustainable investment. It is a positive step of the Commission, consistent with the EU Sustainable Finance Action Plan. We would like to make the following comments to the Commission’s legislative proposal: 1.

WWF welcomes the European Commission’s opportunity to give feedback on the proposal for a regulation amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks to create a new category of benchmarks which will provide investors with better information on the carbon footprint of their investments.

WWF welcomes the European Commission’s opportunity to give feedback on proposal for a regulation on disclosures relating to sustainable investments and sustainability risks and amending Directive (EU)2016/2341. WWF welcomes the fact that the Commission is moving forward with many of the ‘key actions’ numbered in the EU Sustainable Finance Action Plan, including partly ‘Action 7: Clarifying institutional investors'…

WWF welcomes the European Commission’s opportunity to give feedback on amendments to delegated acts under the Markets in Financial Instruments Directive (MiFID II) and the Insurance Distribution Directive to include ESG considerations into the advice that investment firms and insurance distributors offer to individual clients.

WWF welcomes the European Commission’s opportunity to give feedback on amendments to delegated acts under the Markets in Financial Instruments Directive (MiFID II) and the Insurance Distribution Directive to include ESG considerations into the advice that investment firms and insurance distributors offer to individual clients.

WWF applauds the ambition the Commission has taken in this much awaited legislative proposal. More concretely, among very positive elements we see the following: 1. The extension of the scope of the Directive to include all large companies, both listed and non-listed which already makes a big difference in terms of the impacts large companies can have on people and planet.

WWF would definitely choose option 3. Sector-specific Key Performance Indicators (KPIs) Problem: The NFRD fails to provide any granular, sector-specific guidance as to what they should be trying to illustrate. Problematically, a ‘one size fits all’ approach does not work with sustainability indicators.

The announcement in the United Nations Ocean Conference (UNOC) in Nice in 2025 that the European Commission would publish an Ocean Act with legally binding commitments represented a watershed moment for marine protection.

WWFs response to the public consultation on the nature credits roadmap For WWF there are 5 key principles that need to be complied with to ensure that nature credits genuinely benefit both nature and people, and that companies funding them continue to reduce the impact of their operations. 1.

WWF supports efforts to boost the European manufacturing of clean technologies and the development of skills in those sectors - such as renewables, batteries, heat pumps and renewable hydrogen for targeted sectors - in order for the EU to achieve its 2030 climate targets and accelerate the transition towards climate neutrality.

Protecting and enhancing natural ecosystems and all the services they provide is critical to achieving climate resilience and limiting the rise of global temperatures. Therefore, a key pillar of the new EU climate resilience framework should be using nature to help people adapt.

WWF EPO welcomes the revision of the Urban Waste Water Treatment Directive (UWWTD) and its objective of strengthening existing EU legislation for reducing the adverse effects of waste water and making the existing legislation fit for decades to come.

WWF European Policy Office would like to raise major concerns about the European Commissions agenda to rationalise reporting requirements, because of two major risks: 1. While the Commission specifies that this should be done without undermining the policy objectives, the WWF European Policy Office experience in the last three decades is that there is a frequent confusion sometimes on purpose between reducing…

WWF considers that the competitiveness of the EU banking sector should be assessed not only by banks profitability or market position, but by their ability to support a productive, resilient and sustainable European economy. Financial stability is a precondition for competitiveness.

First, impressions of what constitutes and promotes bank competitiveness should be carefully reconsidered. Research on historical credit guidance policies shows that many advanced European economies steered bank lending toward productive sectors from the post-war period until the 1980s, ensuring bank credit supported investment and economic growth.

WWF European Policy Office (EPO) welcomes the opportunity to contribute to the call for evidence from the European Commission on the 2040 Vision for fisheries and aquaculture. As announced in the Commissioner Kadis Mission letter and the European Ocean Pact, this vision is crucial to set a long-term direction for the fisheries and aquaculture sectors while preserving our planets ecosystem health and marine resources…

WWF is concerned that the proposed amendment of the nitrates directive allowing inorganic fertilisers from livestock manure (known as "RENURE" fertilisers) to be exempted from the 170 kgN/ha spreading limit, may not result in a reduction in the nitrogen load in the water bodies. We are concerned that the proposed amendment might have a rebound effect and stimulate higher livestock numbers.

The Water Resilience R&I strategy represents an opportunity to channel resources towards the protection and restoration of the water cycle, one of the key objectives of the Water Resilience Strategy. In this respect, a key objective of the strategy should be to go beyond individual nature-based solutions in freshwater ecosystems towards restoring entire hydrological systems at the level of the landscape.

WWF fully supports strengthening the LULUCF Regulation in order to incentivise the substantial increases in carbon dioxide removal through the restoration of forests and other ecosystems that are urgently needed to limit global temperature rise to1.5°C. However WWF strongly opposes the suggestion that this be achieved by facilitating offsetting with the ESR or ETS sectors.

WWF welcomes the Commissions initiative to establish a strengthened energy efficiency framework for the post-2030 period. In this contribution, WWF focuses on the financing dimension, as this represents the main barrier to the effective implementation and scaling-up of existing EU energy efficiency legislation.

WWF is welcoming the publication of this Call for evidence on an important and timely topic. We very much welcome that this Call only focuses on wind and solar, as we strongly advocate for the exclusion of new hydropower facilities and biomass in Renewables Acceleration Areas (RAAs). The EU needs to massively deploy wind and solar energy to achieve our energy transition and move away from fossil fuels.

We strongly appreciate the Commission's commitment to a horizontal Retail Investment Strategy, which could become one of this mandate's flagship projects in financial services. Indeed, with increasing retail investor participation in financial markets and given developments in digitalisation and automation of retail financial service distribution, the Commission should ensure that the EU legislative framework builds…

WWF EU welcomes the opportunity to contribute to the development of the Quality Jobs Act via the following reflections on the just transition area of the initiative as requested through the Call for Evidence. Please find attached a note with our analysis of the situation, implications for the Quality Jobs Act and sources of evidence.

Healthy oceans are the key element of climate resilience, food security, and long-term economic prosperity in Europe. The revision of the Marine Strategy Framework Directive (MSFD) is a key opportunity to reset the goal towards Good Environmental Status (GES) by 2034 and align marine European governance with the European Unions (EU) broader vision for protecting at least 30% of its oceans, with 10% under strict…

The Just Transition Fund (JTF) and Mechanism (JTM) can, if well-designed – enable and even catalyse a just transition – but it can equally be a red herring if it allows fossil-fuel lock-in. To deliver, it must: 1) Require clear, ambitious timelines - including a pre-2030 coal phase-out Climate change negatively impacts the poorest most.

WWF European Policy Office welcomes the opportunity to participate in this call for evidence on the land use, land use change and forestry (LULUCF) Regulation. The LULUCF sector plays a key role in achieving the EU climate neutrality objective; and it needs to be preserved. Overall, the sector has acted as a net CO2 sink for the EU since 1990.

Delivery of the European Green Deal depends on the implementation and enforcement of EU environmental law by EU institutions. To ensure compliance, the EU needs strong mechanisms that allow civil society to hold EU institutions to account when they fail to deliver on their commitments. Presently, there are no effective means for the public to seek judicial review of EU acts that breach environmental law.

WWF welcomes the European Commission proposal to complete implementation of the Basel III agreement in the European Union, a helpful step to ensure better financial stability after the financial crisis. The timetable proposed by the Commission means that the EU will add another two years to the Basel timeline and plans to fully apply the international agreement by 2030, which means 23 years will have passed since…

WWF EPO comments on roadmap: The 5 year assessment report of the New York Declaration on forests states that an area of tree cover size of the United Kingdom was lost every year between 2014-2018, with new hotspots emerging in Africa and highest losses still in Latin America: the average annual tree cover loss in the tropics between 2014 and 2018 led to 4.7 gigatons of emitted carbon – more than the whole of the EU…

WWF welcomes the European Commission’s initiative to step up EU action against deforestation and forest degradation as expressed in the roadmap, following numerous calls by NGOs, civil society organisations and clear demands by the European Parliament and EU Member States. Nevertheless, we are of the opinion that the measures proposed in the roadmap will not live up to the challenge.

The European Commission has proposed to delay from 2024 to 2026 the adoption of sector-specific standards (ESRS Set 2) in the Corporate Sustainability Reporting Directive (CSRD) for companies sustainability reporting. I. The Commissions delaying proposal is counterproductive : it will increase not decrease the corporate sustainability reporting burden 1.

WWF Briefing paper on the Performance Regulation September 2025 Introduction The EU’s new Performance Regulation — a framework for tracking budget spending and performance across the whole Multiannual Financial Framework (MFF) — is a positive step forward. It lays out key principles and priorities that should be applied consistently across the EU budget.

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

WWF strongly supports the European Commission’s intention to present a legislative proposal to build a European single access point for corporate data. This proposal will strengthen both the Capital Markets Union by improving cross-border investment opportunities as well as the Sustainable Finance Strategy by making sustainability information more easily accessible to interested stakeholders, including potential…

WWF welcomes the opportunity to contribute to the EU Commissions call for evidence for the EPBD Delegated Act (DA) on the portfolio framework to increase lending for renovations. To ensure the DA effectively supports the EUs decarbonization and energy goals, we recommend focusing on four key areas.

The need to rethink and optimise the use of public subsidies is pivotal to ensure a prompt transition towards low-impact, socially responsible and economically viable fisheries, and ensure thriving and diversified coastal economies. Regrettably, a concerning share of the funds distributed through the EMFF and the EMFAF are considered capacity enhancing and/or environmentally harmful.

WWF European Policy Office strongly supports the continued work of the European Environment Agency (EEA) and the European Environment Information and Observation Network (Eionet). The EEA plays a vital role in supporting the European Union's objectives.

WWF feedback The intention of both the EUTR and the FLEGT regulation is to fight illegal logging and related trade. A fitness check of the regulations therefore needs to address this overarching objective thoroughly and equally from an economic, social and environmental perspective. EUTR Apparently the fitness check will mainly focus on the implementation of the EUTR over the last years.

WWF European Policy Office believes that as it stands the 8th EAP proposal lacks the overall ambition and forward-looking actions to tackle environmental degradation and achieve the EU’s long-term aim of ‘living well, within the means of our planet’. The document attached provides recommendations for strengthening the proposal and reaching this long-term aim.

General objective: We strongly recommend to reinforce the use of the Nature-based Solutions (NbS) across the LIFE programme to guarantee high-quality interventions both for nature and people. While the specific priorities of the LIFE Nature and Biodiversity sub-programme includes NbS and ecosystem approaches, this approach is missing in the general objective and the specific objectives of the other sub-programmes.

WWF acknowledges that Directive 2008/99/EC on the protection of the environment through criminal law provided a harmonised framework to address environmental crimes in the European Union. Nonetheless, its implementation was limited, and environmental crimes remained largely under-detected, under-reported, and under-investigated, with sanction levels too low to be dissuasive.

For our detailed position, please refer to the joint-NGO feedback submitted by Oceana (attached). WWF welcomes the EC’s report yet deplores the confirmation that overfishing has increased in EU waters. If “fisheries in the EU grow in sustainability”, they aren’t all doing so at a pace reflecting the urgency of the situation, or at all, and remedial measures to restore certain fish stocks will not suffice in…

WWF strongly opposes the proposed repeal of the so-called 5% rule in Regulations (EU) 2016/1139, (EU) 2018/973 and (EU) 2019/472. The proposal goes against international and european law and the principles found therein, most notably the precautionary approach, and as such, this correction, as labelled by the European Commission, is deemed inconsistent with other Union policies, contrary to what is stated in the…

WWF appreciates what has been achieved through the previous Action Plan. It raised the profile of wildlife crime in EU Member States, and led to the adoption of a number of new measures by CITES Parties. It also led to increased funding to combat unsustainable and illegal trade from source countries, and to increased resources for the CITES Secretariat and for the International Consortium on Combating Wildlife…