Biodiversity Policy Engagement Analysis
Biodiversity Policy Engagement Overview: The Federation of German Industries (BDI) has a moderate level of engagement on biodiversity-related policy. BDI has mixed top-line messaging on biodiversity loss, but has predominantly lobbied to weaken regulation which aims to prevent biodiversity loss.
Top-line Messaging on Biodiversity Loss: In a July 2023 article on its website, BDI recognizes some of the science of biodiversity loss. However, in a March 2021 consultation response to the European Commission, BDI appeared to downplay the role of human influence on biodiversity loss, stating that the loss of soil biodiversity in Germany was “not at all important”.
In May 2021, BDI signed a joint statement made by the ‘B7’ which advocated for government policy to respond to biodiversity loss. A further statement by the ‘B7’ in April 2023 stated broad support for the Kunming-Montreal Global Biodiversity Framework.
Engagement with Biodiversity-Related Regulations: BDI has engaged on a range of EU and German policy with impacts on biodiversity. In a 2020 consultation response to the European Commission on the 2030 Biodiversity Strategy, BDI rejected the idea of binding targets for nature restoration at the EU level or the need for new intervention on biodiversity loss, suggesting that it would be better to supplement existing regulation rather than propose new policy.
BDI has lobbied against supply chain due diligence regulations with links to drivers of biodiversity loss. In a February 2023 position paper, BDI advocated for a weakening of the EU’s Corporate Sustainability Due Diligence Directive, which would introduce a duty to prevent a variety of negative environmental impacts. Furthermore, a 2021 Euractiv article quoted the BDI CEO criticizing the German Supply Chain Act, which includes prohibitions on certain chemicals and requirements on hazardous waste.
BDI has also advocated against a number of regulations that would prevent biodiversity loss due to pollution. BDI opposed the EU Soil Strategy in consultation responses in March 2021 and October 2022. BDI also opposed the need for the EU’s Zero Pollution Action plan in consultation responses in October 2020 and February 2021. In a September 2021 position paper, BDI opposed the proposed restrictions on PFAS (also known as ‘forever chemicals’) under the EU Chemicals Strategy. BDI further opposed restrictions on PFAS proposed by EU Member States in an April 2023 position paper.
BDI has taken more mixed positions on policy relating to land use change. In a 2023 website article, BDI did not appear to support habitat restoration and protection under the EU's Nature Restoration Law. However, a 2020 website article supported measures to reduce deforestation under the EU-Mercosur free trade agreement.
Positioning on Statutory Protection of Wildlife: BDI appears to have had limited engagement on the statutory protection of wildlife. However, a 2020 website article appeared to advocate for greater consideration of economic factors when making decisions relating to species protection.