European Commission

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. [...] Finally, we want to draw your attention to the fact that the “non-paper” laying down the Commission’s plans to further derogate 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 practices developed under the Better Regulation guidelines. [...] When formulating policy options, 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 2030 and the Farm to Fork Strategy derived from the European Green Deal.