EEB Feedback to the EU Commission Roadmap towards Nature Credits

This document outlines the EEB’s feedback to the European Commission’s ‘Roadmap towards Nature Credits’.

The feedback critically examines the use of nature credits in EU environmental policy, highlighting their limited potential and significant risks – including the commodification and financialisation of ecosystems. It argues that biodiversity is too complex and site-specific for market-based instruments, and stresses that nature credits must not replace public funding, legal enforcement, or the elimination of harmful subsidies.

The paper warns that even high-integrity credit schemes require strong safeguards to prevent greenwashing, land grabbing, and social inequities. It calls for non-tradable, locally grounded credits used only as a last resort, and explores alternative non-market approaches like granting legal personhood to natural elements. The response urges the EU to ensure nature credit markets do not undermine environmental protection or sustainability goals.