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CAP 2021-27: Comparative analysis of environmental performance of COMENVI and COMAGRI reports

AUTHORS: Faustine Bas-Defossez – Stephen Meredith

The position of the European Parliament on the CAP 2021-27 is currently under discussion by MEPs based on the European Commission’s Common Agricultural Policy (CAP) Proposals for the 2021-27 period, published in June 2018. This CAP reform presents a renewed opportunity to put environmental and climate action at the heart of the next CAP.  

The agriculture Committee (COMAGRI) leads the shaping of Parliament’s position, to be ratified by MEPs ahead of negotiations with the Commission and AGRI Council. For the first time, the Committee on Environment, Public Health and Food Safety (COMENVI) has associated status on the main CAP file concerning all elements related to the environment.

IEEP has conducted an analysis of the proposals made by both committees in terms of their environment and climate performance. The main findings are outlined below.


  • There are several ways in which the European Parliament’s final position can help to enhance the Commission’s CAP proposals and increase their environmental and climate ambition.
  • However, the COMAGRI and COMENVI proposals differ starkly in terms of their appetite to maintain or increase the level of ambition.
  • With the notable exception of some encouraging changes on advice and training, the COMAGRI report as it stands, risks going back on previous environmental and climate achievements and could prompt Member States to continue business as usual.
  • A number of the amendments proposed by COMENVI could go a long way to ensuring that a sound legal framework capable of mainstreaming environmental/climate action across the sector after 2020 is put in place.

IEEP analysis of the two reports has found that:


  • Many of the COMAGRI report’s amendments have limited potential to increase the CAP’s environmental and climate performance (being either too vague or not ambitious enough).
  • As they stand, the amendments would not put forward the necessary elements to turn the Commission’s proposals from rhetoric to concrete action and in many respects they risk maintaining a damaging status quo.
  • The report adds some particularly concerning changes to the Commission’s proposals, that would reduce the next CAP’s ambition for the environmental and climate action, notably concerning the green architecture and other area based payments.
  • Not only does COMAGRI not clarify or strengthen the minimum threshold for the basic payments, it also deletes the proposed Farm Sustainability Tool for Nutrients and the standard relating to the minimum share of agricultural area devoted to non-productive features or areas from conditionality. As there is currently a requirement under greening to devote a minimum percentage of land to Ecological Focus Areas, such an amendment risks leading to a step backward on previous achievements.
  • The report also proposes to ring fence 60% of Pillar 1 for basic payments and only allocates 20% for the eco-scheme which is a step backwards in comparison with the current 30% allocated to greening in Pillar 1.
  • Under Pillar 2, payments for areas facing natural or other area-specific constraints (ANCs) could continue to make up a significant proportion of the environmental spend. This seriously risks further increasing the lack of coherence between the income support tools, and the environmental/climate interventions and accompanying needs, and hence overall the environmental and climate performance of the policy.
  • On a positive side, the COMAGRI amendments on advice and knowledge are encouraging, adequately tackling some of the gaps in the Commission’s proposal by seeking to make clear links between farm extension and with the overall green architecture. The most notable feature is a stronger emphasis being placed on knowledge and advice services – under the CSP for the eco-scheme. 


  • The COMENVI report’s amendments present very encouraging changes that have the potential to turn the Commission’s proposals into a new delivery approach in which all CAP support (both Pillar 1 and Pillar 2) is better focused on environmental performance, delivering results against a set of meaningful EU objectives in light of national and regionally identified needs.
  • As it stands the report sets the Commission’s proposals on the right path to help improve the next CAP’s performance in delivering environmental and climate outcomes and ultimately helping to secure stable agro-ecosystems and long-term food production.
  • A number of conditionality standards and requirements are strengthened while their design based on environmental and climate needs is maintained with a stronger link made to EU environmental legislation and a greater emphasis on Commission oversight.
  • The report also proposes to strengthen the coherence between the CAP objectives and the existing EU environmental and climate legislation.
  • It proposes a number of very encouraging amendments on partnership and stakeholder involvement during the preparation and monitoring of the CSPs and ring fences 30% of Pillar 1 for the eco-scheme, while increasing the minimum spending in Pillar 2 for environment and climate from 30 to 40%. This includes the obligation for Member States to reserve a minimum amount of EAFRD for agri-environment-climate commitments and Natura 2000/WFD payments that contribute directly to the CAP’s biodiversity and ecosystem services.


The report should be cited as follows: Bas-Defossez F and Meredith S (2019) CAP 2021-27: A comparative analysis of the environmental performance of the COMENVI and COMAGRI reports on the Commission’s proposals, report for NABU by IEEP.

This report was commissioned by Naturschutzbund Deutschland (NABU) and financially supported by the German Federal Ministry for the Environment, Nature Conservation and Nuclear Safety (BMU).

Files to download

IEEP AGRI ENVI analysis September 2019

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