Copa and Cogeca represent 22 million farmers and their family members as well as 22,000 cooperatives that provide 446 million EU citizens with safe, nutritious, high-quality, sustainable, and affordable food every day.
Farmers, forest owners and their cooperatives are the first to feel the impact of climate change and biodiversity loss. Mobilising more investments is vital for them in facing increasing challenges today and in the future and in making their contribution in reverting this trend and at the same time ensuring food security.
The agri-food sector, now more than ever, needs to be able to count on incentives and investments towards more sustainable production methods and adaptation measures, use of smarter technologies and digitalisation. Ensuring access to sustainable and traditional finance is of paramount importance and imperative, especially under the new circumstance created by the COVID-19 pandemic and the war in Ukraine where agriculture need to respond to increasing demand on food production while continuing their transition towards a more resource efficient and competitive economy.
Copa and Cogeca acknowledge the efforts made by the EU institutions in mobilising financial resources to deliver on the policy objectives of the European Green Deal to have a more sustainable and climate resilient economy, whilst respecting international commitments. Sustainability with its three pillars has for long been central and reflected in the Union project, the Treaty on European Union and the Treaty of the Functioning of the European Union (TFEU). This is also stressed in the Regulation (EU) 2019/2088 on the establishment of a framework to facilitate sustainable investment.
Lack of practical experience
While recognising the ambition of the policy objectives linked to the Sustainable Finance package, Copa and Cogeca stress that the technical criteria included in the recommendations on the Platform on sustainable finance for biodiversity in agriculture, once again, do not take stock and recognise the work done by farmers and their cooperatives. This is mainly due to the lack of representativeness of our sectors expert within this advisory body, which consequentially lacks of use of practical experience and knowledge regarding the work done by farmers to enhance the sustainability in agriculture sector.
Unrealistic stance and lack of coherence
With the publication of the Technical Working Group’ report, which includes recommendations on technical screening criteria for the biodiversity objective, the Platform on Sustainable finance takes an unrealistic stance on the agricultural sectors. The recommendation lack coherence with CAP and are disconnected to agronomic practices, and with the reality on the ground. This
risks of becoming overly prescriptive while ignoring the diversity of agricultural practices and the local needs. Investments need to be targeted locally, based on SWOT analysis and needs assessment. It is not acceptable for us to have recommendations for a piece of secondary legislation provisions emerging from non-legally binding acts. This approach will not support the transition and endanger the competitiveness of the sectors and food and biomass security.
The lack of representativeness of farmers and agri-cooperatives during the whole process, the unwillingness to take into due consideration constructive and science-based proposals and suggestions including the ones submitted during the public consultation is clearly perceived and regrettable.
Thus, these recommendations risk to pose major challenges for Member States, the agricultural sector and the financial institutions from a usability point of view. Moreover, the recommendations also are counterproductive as they endanger the real objective of the sustainable finance regulation, because the very limited number of economic activities that according to the proposed criteria can be defined as substantially contributing to the environmental goals, would not be financed, for an evident increase of the economic risk, which investors would not undertake as this activity are not economically viable.
Agricultural management differs from financial management, a lot
Copa and Cogeca call therefore on the Commission for a strong rethinking of the overall approach used by this advisory body. The appropriate definitions for which economic activities can be considered as environmentally sustainable should be based on legally binding legislation in place, on sectorial discussions and work that duly take into consideration the technical, legal and economical basic assumptions.
Thus, we indeed contend the report for its unrealistic criteria and consequent targets. The recommendations are not implementable and endanger the EU food and biomass security, the viability of rural areas with loss of jobs and the competitiveness of the agri-foods sectors, as well as discouraging the willingness of investors to drive capitals towards our sectors.
Sustainability needs coherence
The EU cannot demand farmers and agri-cooperatives to continue improving their practices to become even more sustainable and, at the same time introduce provisions which would prevent farmers from taking up such investments. This proves a lack of coherence and an ambition which goes beyond any realistic and practical approach. We would like to recall that any additional provisions that are stricter than those under the CAP and relevant EU binding legislation, that involve unfeasible criteria and that request the use of data that is unavailable as well as the proposed farm sustainability plans and compliance mechanisms, are simply unacceptable.
The Platform, as Advisory body should duly consider that Regulation 2020/852 states that when establishing and updating the technical screening criteria, the Commission should consider “relevant Union law”. This element is the driving component of their mandate, and recommendations aiming at defining technical screening criteria which are not in line and compatible with existing measures, in particular the CAP, are simply unacceptable.
No new targets without an impact assessment
Copa and Cogeca ascertain that many of the recommendations addressing our sectors are anticipating elements which are key in other topical policy developments. We indeed took note that that the quantified criteria proposed by the Platform are based on the reduction targets of the Farm to Fork and Biodiversity Strategies to be achieved at EU level, but we are certainly astonished on how these targets are simply transposed at farm level. Consequently, Copa andCogeca underline that before setting unrealistic targets and criteria, a comprehensive and cumulative impact assessment, notably on food security and competitiveness and a feasibility analysis are together a condition sine qua non.
Such an impact assessment is indeed of paramount importance prior the adoption of the technical criteria. To the contrary, the logical reasoning that links the problem, its underlying causes, the objectives, and a range of policy options to tackle the problem is completely missing and there is not clarity on the economic and social impacts (how and on who will be affected) and on the overall competitiveness of European enterprises.
Copa and Cogeca would like to stress once again that all interconnected legislative acts linked to the Sustainable Finance regulations should facilitate access to finance to drive the transition and avoid red-tape and increase of cost for both sustainable and traditional financial services.
Favour the transition – together with farmers (experts “on the ground”)
To avoid overly burdensome compliance costs on economic operators, the Platform and the Commission should bear in mind that it is necessary to provide sufficient legal certainty and clarity, that are practicable and easy to apply. Therefore, all criteria and proposals that will be presented by the Commission should be realistic and science-based and more importantly designed to favour the transition.
To conclude, it would be necessary that the Commission fundamentally revises the recommendations on agricultural activities with agricultural stakeholders and experts from the field. We strongly encourage the Commission to have an open and a balanced discussion with experts for the next steps and to gather information from the field to establish technical screening criteria and define substantial contributions that are feasible.
European farmers and agri- cooperatives cannot support the Platform recommendations.
Artigo publicado originalmente em Copa Cogeca.
