Dear Mme Schomaker,
Dear focal points,
Subject: The CBD's Role in Securing Multilateral Regulation for
Biodiversity: doing better than past Mainstreaming Processes
We, the undersigned organizations, are deeply concerned about the driving forces behind
biodiversity loss and human rights violations, especially regarding corporations that
operate in sectors such as food and agriculture, forestry, mining, energy, infrastructure,
and finance, amongst others. We believe it is essential that the UN multilateral system,
and the Convention on Biological Diversity (CBD), in particular, address those negative
social and environmental impacts by defining stringent and enforceable regulations for
all sectors. This must ensure that no business is allowed to have damaging impacts on
nature and people anywhere and that the combined impacts of all business cease to
exceed planetary boundaries.
We note that many countries—particularly those most impacted by biodiversity loss in
the Global South—are unable to enforce stringent environmental regulations due to
economic dependencies, including debt-related pressures. Such situations can lead to
a race to the bottom in environmental regulation, which will further destroy biodiversity
and have severe social impacts everywhere. We believe the CBD should take the lead in
ensuring that all countries adopt stringent policies.
We had high hopes for the mainstreaming processes to address the impacts of all sectors
on biodiversity. However, we have observed, in the mainstreaming decisions of COP 13
and 14, as well as in the mainstreaming process, which proposed the Long-Term Strategic
Approach to Mainstreaming (LTAM) and its Action Plan (AP), that these documents did
not result in evidence- and science-based proposals for regulations that can be enforced
in all countries. On the contrary, the documents, especially the LTAM and its AP,
contained many proposals that would further undermine the environment and people’s
rights, and allow corporations to continue unchecked growth and environmental
degradation. This included false solutions such as Nature-based Solutions, NaturePositive, Biodiversity OYsetting, TNFD, Voluntary Certification, No Net Loss and Net
Gain, multi-stakeholder platforms, and others.
This was the result of an unbalanced and untransparent process, which allowed for the
input of corporate actors, without Parties ever discussing the content of the resulting
papers in plenary, and with little involvement from rightsholders or civil society in the
whole process.
We believe “mainstreaming biodiversity in all sectors” should always have meant
multilateral coordination towards strong environmental regulation, but never has. We,
therefore, call for the CBD to set up a new process at COP 16, with the meaningful
engagement of Indigenous Peoples, local communities, women, youth, other
rightsholders and civil society, to develop global policies that ensure all countries apply
robust regulations to prevent further biodiversity destruction in a multilaterally
coordinated way. The objective and suggested name of this process would be “ensuring
coherent multilateral regulation to protect biodiversity”.
Sincerely yours,
International organisations
- Econexus
- Greenpeace
- Friends of the Earth International
- Global Youth Biodiversity Network
- Third World Network
- Women4Biodiversity
National Organisations
- Association For Promotion Sustainable Development - France
- Awinakola Foundation - Canada
- Friends of the Earth Canada
- JA!Justica Ambiental - Mozambique
- Milieudefensie - The Netherlands
- POLLINIS - France
- ProNatura - Switserland
- Rainforest Action Network - US