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330 Organisations Ask the European Commission to Save Green Elements of the CAP

Updated: Mar 21

BeeLife co-signed a letter to the European Commission along with 229 European organisations stating important concerns over the future of sustainability and green measures in the Common Agricultural Policy (CAP). The European Commission and the Belgian Presidency of the Council of the EU recently announced proposals to modify green measures in the CAP, which lack transparency and create problematic results for the future resilience of EU farming.

European Commission

President Ursula von der Leyen

Directorate-General for Health and Food Safety B-1049Brussels


6 March 2024



Subject: Joint letter to the EU Commission to reconsider the loosening of the CAP’s green architecture


We, the undersigned European coalitions1 and civil society organisations, who work every day for an agroecological and fair transition toward sustainable food systems, including a better Common Agricultural Policy (CAP) in line with the European Green Deal, are deeply concerned by the latest measures taken by the European Commission and the recentannouncements made by both the EC and the Belgian Presidency of the Council regarding the green architecture of the CAP. We also want to express our discontent regarding the lack of transparency and public involvement that characterisedtheir preparation.

On 12 February 2024, the Commission adopted an Implementing Regulation for a derogation on the application of thestandard for Good Agricultural and Environmental Conditions of land 8 (GAEC 8). The derogation allows Member States to waive the condition to dedicate at least 4% of arable land at farm level to non-productive areas in order to receive CAP subsidies. This puts an already declining biodiversity in further jeopardy, especially biodiversity linked to farming areas,and exposes agricultural activities to even further risks.

One week later, on 22 February, the Commission announced it was envisioning a set of initiatives to reduce theadministrative burden on farmers. Among those initiatives were a suite of short-term and mid-term measures to further relax GAEC rules and exempt 65% of the CAP beneficiaries from controls related to compliance with GAECs. TheCommission also proposed to eliminate the requirement that farmers must submit individual applications for aerial spraying of pesticides2. This is an incomprehensible move by an institution that is responsible for ensuring long-term food security and health, as well as ensuring that EU funds contribute to achieving the environmental and social sustainability of theCAP.

On Monday 26 February, following the AGRIFISH Council meeting, the Belgian Presidency and the Commissioner forAgriculture announced that they would propose additional measures to grant even more flexibility on the conditionalityrequirements. Commissioner Wojciechowski stated he would consider the idea of transferring conditionality requirements(GAEC 1, 6, 7, 8) to voluntary eco-schemes3.

If implemented, the initiatives envisaged by the Commission will encourage Member States to undermine their obligation to support the environmental and climate ambition4 of their CAP Strategic Plans, compared to the 2014- 2020 period, thus undermining the EU’s overall capacity to achieve several objectives5 of the current CAP. Rather, they would constitute a roll back compared to the previous CAP period which, as clearly stated by the European Court of Auditors, did not manage tohalt the decline of biodiversity6. The fact that the Commissioner announced farmers would not be controlled to comply with the conditionality requirements to receive CAP payments is of great concern because of the importance of these basic GAEC standards (see Annex below) in moving towards a more resilient, healthy and sustainable agricultural productionmodel.

As such, the Commission is about to dismantle conditionality requirements that are based on unequivocal scientificevidence, and which it has explicitly acknowledged as being essential tools to address current climate, environmental, andbiodiversity issues. The EU’s own Better Regulation Guidelines require it to abide by certain principles in legislativedecision-making, which include the evidence-based approach and policy coherence.7 Furthermore, adopting a series of short-term and medium-term measures that will induce repeated changes in the way CAP funds are distributed will not offerbeneficiaries a proper level of legal certainty.

Farmers’ protests cannot be used as an excuse to loosen the green architecture of the CAP, nor should environmentalstandards become a scapegoat to avoid addressing the lack of social and economic sustainability in the currentagricultural system. Farmers are taking to the streets for many reasons. They are concerned about cheap imports (by free trade agreements like EU-Mercosur) that do not comply with EU environmental and animal welfare standards, as well asdue to the unfair economic distribution within the agrifood chain in which they are the most impacted and least benefited. Many farmers are also protesting because CAP subsidies still favour agroindustrial models, rather than supportingagricultural models of production that contribute to improved socio-environmental sustainability. However, despite this, the Commission’s solution and answer is to put an end to conditionality requirements, which is unacceptable. There are many types of farmers, and dismantling the green architecture of the CAP will not help them in the long-term.

Instead of adopting proposals that jeopardise the resilience of EU farming, we urge your Commission to stay focused on measures that have a real potential to provide fair incomes to farmers and repurpose funds (especially direct area- based payments in Pillar I) to enable producers to embrace an agro-ecological and fair transition, with a medium and long-term plan. CAP National Strategic Plans have much room for improvement to achieve a fairer distribution of subsidies to support the most vulnerable farmers who are in need of public funding, and who provide the greatest socio-environmentalvalue by providing public goods for society as a whole.

Finally, we want to draw your attention to the fact that the “non-paper” laying down the Commission’s plans to furtherderogate from, and revise the CAP regulations, was not made accessible to the public by your services and was discussed behind closed doors during the AGRIFISH Council meeting. Transparency and participation are some of the core principles of the EU’s legislative decision-making8, rooted in the democratic principles of the Treaty on European Union (TEU).9 We deeply regret the lack of these elements in the process of formulating these options. We call on the Commission to guarantee the meaningful consultation of all concerned stakeholders, including NGOs and scientists, ahead of the formulation of any upcoming legislative and policy initiatives on agriculture, in line with Union law and best practicesdeveloped under the Better Regulation guidelines.

President von der Leyen, we urge you to abandon plans to dismantle the CAP's green architecture and comeforward with a systemic approach to respond to the diversity of farmers' protests and problems, embracing socio-economic, environmental, and governance flaws of European agri-food and rural systems. When formulating policyoptions, we call on your Commission to adopt an evidence-based and coherent approach in line with the EU’s commitments on biodiversity and climate change, as well as the objectives set out in the EU Biodiversity Strategy for 2030and the Farm to Fork Strategy derived from the European Green Deal. Your political action should follow the evidence published on your own website: “Biodiversity relies on agriculture, agriculture relies on biodiversity.”10



Sincerely Yours,


The European Coalitions and Organisations involved



1  The European Coalitions are made up of dozens of united organisations. We are more than 335 organisations signing the Letter.

3  The budget for the eco-schemes is insufficient and must be increased from 25% to at least 50% in order to continue to meetEurope's climate and environmental objectives; even more in the event of a further softening of conditionality.

4  As required by Article 105, CAP Strategic Plan Regulation (Regulation (EU) 2021/2115).

5  Namely the specific objectives on climate, natural resources and biodiversity, see Article 6 (1) (d-f) of the CAP Strategic PlanRegulation (Regulation (EU) 2021/2115).

7 Better Regulation Guidelines, Ch. I, Section I, p. 5-6. 8 Better Regulation Guidelines, Ch. I, Section I, p. 5-6. 9 See in particularArticles 10(3) and 11(2) TEU.






-        GAEC 1: aims to protect permanent grassland to preserve carbon stock. In November 2019, the EUCommission published a report stating that “the overall biodiversity importance” of permanent grasslandsis “very high”.

-        GAEC 6: has the objective to ensure minimum soil cover to avoid soil remaining bare during the most sensitive

periods of the year, therefore protecting the land. According to the EU Commission, 60-70% of soils areunhealthy in Europe and 50 billion euros are lost every year due to soil degradation.

-        GAEC 7: fosters crop rotation in arable land to preserve soil potential. According to a report published by the

EU Commission more than 10 years ago, “a higher diversity in crop rotations allows breaking pest/weed cycles.(…) Thus, crop rotations have the potential to lead to a reduction in chemical inputs”.

-        GAEC 8: compels farmers to devote a minimum share of at least 4 % of arable land at farm level to non-productive elements, including but not restricted to land lying fallow. Five years ago, the Commission published a report based on scientific evidence that stated that “fallow lands are essential to biodiversity” and “provide moreoptions for species in terms of food and breeding habitat”.


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