Luxembourg’s National Restoration Plan: Mouvement Ecologique submits a statement

The EU Nature Restoration Law requires all EU Member States, from 2024 onwards, to restore degraded ecosystems by 2050 and to achieve initial interim targets as early as 2030. As a key implementation tool, each Member State must draw up a National Restoration Plan (NRP) and submit it to the European Commission by September 2026. The Luxembourg Ministry of the Environment had put a first draft out for public consultation until 6 April 2026.

The Mouvement Ecologique has taken advantage of this consultation and submitted a formal response (available on the right under ‘Downloads’).

This statement is entirely in line with the work carried out in recent years. As a reminder: two years ago, when the new government took office, a detailed brochure on the biodiversity crisis in Luxembourg was published, analysing the key obstacles to nature conservation. These included the slow implementation of the 3rd National Plan for Nature Protection (PNPN3), the lack of inter-ministerial cooperation and structural hurdles in legislation. It is sobering to note that these well-known obstacles are once again not even addressed in the current NRP draft, let alone tackled, and that such shortcomings are thus carried over from one plan to the next.

First and foremost, however, it must be emphasised that Luxembourg deserves credit for having created, with the PNPN3 years ago, a pioneering, binding instrument for nature conservation ( ). Its objectives regarding the conservation and restoration of habitats and species’ habitats are still valid and must be  maintained . What is clearly open to criticism in the NRP, however, is that it completely ignores the fact that the PNPN3 is already being inadequately implemented today. An honest, preliminary analysis of the obstacles – why targets are being missed, what structural, financial and political barriers exist – would have been necessary so that countermeasures could have been taken in the NRP. Instead, the same targets are being transferred to a new format without identifying or addressing the causes of the failure.

Similarly, the changes required in the agricultural sector – as the most significant driver of biodiversity and the success of restoration measures – have not been sufficiently analysed , nor have instruments been proposed to steer the sector in the right direction . Concrete measures such as pesticide reduction, a reform of agricultural subsidies and the introduction of a public interest premium for farmers are notably absent.

In general, the plan lacks concrete measures. The section on measures – the heart of any restoration plan – is largely absent from the draft. It was merely stated that it would be drawn up in parallel with the consultation. Consequently, it was not available for inspection during the public consultation on the NRP. This makes meaningful public participation effectively impossible.

It is also surprising, for example, that the detailed recommendations for action from the national grassland strategy, which has been available for Luxembourg since 2020, were not incorporated into the NRP.

Finally, the search area framework – the maps showing where which habitats are to be restored – is methodologically unclear. The underlying data is missing.

The Mouvement Ecologique concludes that, primarily due to the partial lack of content , the public consultation on the NRP must be cancelled and carried out again once the document has been finalised. The statement was submitted on 05/05/26 and the Mouvement Ecologique is available for further technical discussion regarding the NRP.

12.05.26