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25.11.2009 Studies

Through the Green Smokescreen

BirdLife International, 2009


  • Examination of how the cross compliance conditions attached to the Single Farm Payment are implemented in the member states.
  • Detailed suggestions on how more effective cross compliance conditions should look like.


  • At the EU/design level, the report criticizes 1) a lack of clear environmental objectives and targets, 2) a lack of guidance on how member states should translate cross compliance into specific obligations applicable at farm level, 3) the exclusion of second pillar payments with potentially serious environmental impacts from the scope of the policy, 4) the lack of an obligation to involve stakeholders from civil society in national implementation and 5) a lack of reporting, monitoring and evaluation of policy outcomes.
  • At member state/implementation level, the report points to 1) insufficient and ineffective controls, 2) inadequate provision to share information on breaches of relevant legislation across different public authorities, 3) inconsistent payment reductions which are usually small and not proportional to the environmental damage. This laxity can be partly explained by the fact that member states can retain only 25% of the payment reductions they impose on ‘their’ farmers.
  • Furthermore, the report highlights the failure in securing proper protection of permanent pasture.
  • Some cross compliance conditions even harm the environment (especially the obligation to remove 'unwanted vegetation').