RGO are co-signatories on a briefing to the EU Commission and the member states, which proposes that the new deforestation regulation from the EU should contain the category "Other wooded land". This would lead to a significant expansion of the protected area, since almost a billion hectares of land is classified as 'other wooded land'.

If the category is not included in the regulation, there is a risk that deforestation and conversion of forests will be accelerated.

Read the full response to the consultation below.

Two: European Commission Executive Vice-President for the European Green Deal Maroš Šefčovič
Cc: Commissioner for the Environment Virginius Sinkevicius, Commissioner for Health & Food Safety Stella Kyriakides, Commissioner for Agriculture Janus Wojciechowski,
Minister for the Ecological Transition of Spain Teresa Ribera and Chair of the Committee on the Environment, Public Health and Food Safety Pascal Canfin

Re: Completing the European Green Deal: The Commission's initiative for an Integrated Nutrients Management Action Plan
Brussels, 13 September 2023

Dear Executive Vice President,
Following your recent appointment as the Executive Vice-President for the European Green Deal and your task to bring the European Green Deal forward, I am writing, on behalf of the undersigned, regarding the Commission's initiative for an Integrated Nutrient Management Action Plan (INMAP) , which should set the path for the EU to achieve its objective to cut nutrient losses in half by 2030. The INMAP was originally announced to be published in autumn 2022 but seems to face delays despite ample evidence that urgent action is needed to ensure that this key component of the European Green Deal is delivered swiftly.

The European Commission announced the INMAP in the Circular Economy Action Plan in March 2020, "with a view to ensuring more sustainable application of nutrients and stimulating the markets for recovered nutrients". In the Biodiversity Strategy and the Farm to Fork Strategy (F2F), presented in May 2020, and the Zero Pollution Action Plan published in May 2021, the Commission committed to reduce nutrient losses by at least 50% by 2030, while ensuring no deterioration in soil fertility. The INMAP is currently announced to be presented in second quarter 2023 but has not been published yet.

The need for urgent action is obvious, the European Environmental Agency has estimated losses of nitrogen and phosphorus in Europe to exceed safe and sustainable levels by a factor of 3.3 and 2 respectively.1 More than 30% of EU surface water, and more than 80 % of EU marine waters are eutrophic, while 14% of groundwater exceed legal nitrate thresholds for drinking water.2 The cost for water pollution due to nutrient pollution in the EU amounts to €22 billion annually.3 It is also clear that integrated nitrogen management is needed to achieve the Net Zero target.
Modeling by the Commission's own science and knowledge service, the Joint Research Center (JRC) has revealed that measures under existing legislation and policies, even if fully implemented, will only reduce the nutrient load to sea by 13% and 17% for N and P respectively.4 This is far from the 50% reduction target and clearly shows that policy measures beyond existing legislation are urgently needed in order to achieve the 2030 targets.

The Biodiversity, F2F strategies and Zero Pollution Action Plan all foresee a cut in fertilizer use "by at least 20%". However, science points to much greater reductions to be needed. The JRC, in its Knowledge for Integrated Nutrient Management Action Plan report, concludes that the EU should reduce its annual mineral fertilizer input of N and P by about 60% to reach sustainable nutrient flows.5
Such cuts can sound daunting, but empirical evidence points to the fact that fertilizer use can often be cut significantly without affecting yields6 and modeling studies have found that phasing out synthetic fertilizers use in the EU is realistic as part of a transition to agroecological farming, accompanied by a cut in food waste and a shift to sustainable diets.7 Nutrient recovery from organic waste streams can contribute significantly to replacing synthetic fertilizers and the INMAP should address EU end-of-life criteria and markets for secondary raw materials. Such a transition of the food production system would also bring massive co-benefits by reducing the EU's dependency on imports of fertilizer and feed in order to achieve strategic autonomy, slashing pollution by other agro-chemicals (pesticides and anti-microbials), and cutting water use by the sector.
To achieve this, bold action and clear directions are needed. We therefore urge the Commission to keep to its promise to deliver the INMAP and to listen to scientific expertise for setting the path until 2030 and beyond.
Several of our organizations contributed to the 2022 public consultation on the INMAP, where we presented thorough evidence of the issues at hand and comprehensive recommendations for how the EU could achieve genuine strategic autonomy in nutrients management and ultimately food production.

In light of a summer that yet again was marked by extreme weather events made more intense by climate change, we once again reach out to you to ask you to deliver actions that safeguard our food, water and climate security in the long term.

Yours sincerely,
Patrick ten Brink
EEB Secretary General

CSO/NGO signatories
Agroecology Europe
AirClim
Corporate Europe Observatory
Eurogroup for Animals
European Anglers Alliance
Four Paws
Green Transition Denmark
IATP
ifoam extension
Wetlands International Europe

Academic signatures
Prof. Dr. Martin J Wassen & Dr. Jerry van Dijk, Utrecht University
Dr Kevin Hicks, Stockholm Environment Institute at York, University of York, UK

Footnotes:
1 EEA Report No 1/2020: Is Europe living within the limits of our planet — European Environment Agency
2 European Commission, (2021), Report on the implementation of the Nitrates Directive for the period 2016-2019
3 European Commission, (2021), Green taxation and other economic Instruments: Internalising environmental costs to make the polluter pay
4 Joint Research Centre, (2023), Knowledge for Integrated Nutrient Management Action Plan (INMAP) (JRC 2023)
5 JRC 2023
6 Anthropocene magazine, (2019), Here's how precision agriculture could help farmers reduce fertilizer use
7 See for example: IDDRI (2018) An agro-ecological Europe by 2050: multifunctional agriculture for healthy eating and Billen et al. (2021) One Earth perspective Vol 4:6, pp 839-850 https://doi.org/10.1016/j.oneear.2021.05.008

This means similar legislation to that introduced in Denmark from the turn of the year, where climate impact from all phases of the building's life cycle is taken into account and regulated at EU level.

The background for the letter is that the EPBD is currently under review. The commission has played with a proposal to start calculating the WLC, and the council has not proposed any changes to this. Since the revision must be implemented over the next few years, and is expected to only come into force in the Member States around 2027, we believe that it is crucial that one goes a step further. In addition, the revision-after-this-revision will come into force at the beginning of the 2030s at the earliest. It is a very long time to wait for regulation and incentive structures for the European construction industry in relation to the climate goals. We therefore believe that it is in the interest of the climate and construction to ensure joint regulation during this period.