Algemene Nederlandse Vereniging van Eierhandelaren en Eiproductfabrikanten
Anevei
Anevei behartigt de belangen van haar leden zijnde Eierhandelaren, Eierverzamelaars, - exporteurs en Eiproduct fabrikanten en handelaren in de ruimste zins des woords.
ID: 50748354145-40
Lobbying Activity
Response to Revision of EU marketing standards for agricultural products
15 Feb 2021
Anevei’s position on and input for ‘The evaluation of the European Marketing standards on Eggs’
First and foremost Anevei, the Dutch organisation of egg packers, egg graders and egg traders, and egg processors, wants to express her appreciation in being given the opportunity to comment on the evaluation of the European Marketing standards for eggs through the “Have your say system”.
Secondly Anevei wants to emphasize that the marketing standards for eggs created a level playing field within the European Union, crucial to the competitiveness of the European egg sector as a whole. For the international trade it creates a clear level of production standards to be fulfilled on the European market. However, there are some points we would like to see changed.
1. 16 weeks period in case of housing order:
Seen the latest outbreaks during the winters of e.g. 2015 -2016 and 2020-2021 AI outbreaks last longer than a 16 weeks period. This harms
the continuity and the sustainability of the sector.
2. Solar panels in the outdoor area
Solar panels in the outdoor area has two functions: providing shelter from natural elements (predators) as well as increasing sustainability
of the sector (energy supply). Of course the number of panels per hectare can be limited.
3. NON EU-regulations compliant Eggs and Egg products:
a. Currently, egg packaging has to mention whether or not they contain non-EU eggs (Reg. 589/2007). However, there are no requirements
concerning the size of this particular print. We feel that minimum text sizes have to be taken up in legislation in order for this important
information to be readable.
b. If non-EU compliant eggs are used for producing egg products then egg products should be marketed similarly to eggs as being non-
compliant with EU rules – to be printed on the packaging.
4. Stamping of eggs on the farm:
In the Netherlands and Germany quality systems oblige farmers to do so and this has reduced fraud with egg codes drastically. Secondly in
case of a crisis this offers a very reliable system to track and trace the involved eggs. The stamping of eggs should become an obligation t
throughout Europe. Thus preventing the trade of unmarked eggs and facilitating fraud by using wrong egg codes and housing systems.
5. Sell by and best before dates:
Only a best before date would be enough. The sell by date leads to food waste, since the few eggs which are not sold at 21 days are just
thrown away (The quantities are too small to be sold to egg processors).
6. Eggs and egg products only to be derived from eggs from Gallus gallus:
With the development of novel foods and non-animal protein, the egg is protected according to the definitions in EU/589/2007. Initially one
would assume that ‘egg products’ are also protected as they are made from eggs. Unfortunately this is not the case, egg related products
like ‘omelette’ are not protected. The industry wants to see this regulated in the new marketing standards.
In conclusion, the marketing standards for eggs have proven to be effective and should be maintained while undergoing some modifications to adapt them to today’s and future evolutions of the sector
In the attached letter the above arguments are explained further.
Read full responseResponse to Organics production rules
2 Dec 2019
Our biggest concern is the proposed amendment increasing the withdrawal period for veterinary medicines to a minimum of 48 hrs. This implies that eggs laid during the application of a veterinary medicine and up to a period of 48 hrs after that cannot be sold as organic. This will have disastrous effects on the sector (see attachment). The use of veterinary medicines is already strictly regulated with few alternatives available. Such an amendment could bring about unwanted behaviour e.g. encourage unregistered use of veterinary medicines, unwillingness to use medicines amongst laying hens causing unnecessary suffering of individual hens.
We kindly request the Commission that the proposed amendment introducing a withdrawal period of 48 hrs is revisited and discussed with the sector to find proposed solutions which could be adopted by the sector.
Secondly: It is vital that a 350 metres radius form the building is allowed for the free range area.
Read full responseResponse to Amendment of marketing standards for free range eggs
4 Sept 2017
1.a. We are glad the 12 weeks is increased to 16 weeks, but this is not enough - the last outbreak the housing order in the Netherlands lasted over 20 weeks (as in many other EU countries). This prevented a lot of unnecessary culling of birds, but resulted in important financial damage for farmers as well as egg traders and egg processors.
With a correct labelling of egg boxes the consumers can be informed properly on the situation.
1.b. We would prefer to see the organic regulation to be adopted to this situation. Organic eggs can be sold as organic during a housing order imposed by the official authorities. Since free range farmers in the Netherlands all have a veranda or Wintergarten, a kind of free range is still maintained!
2. Second amendment is the proposed 16 wks period starts when a new flock is housed in laying accommodation - and this should be at the onset of lay! According to the Eu law a regarding hen become a layer hen when the flock is at 50% production. It is preferable to use the same definitions in different regulations. The marketing standards refer to laying hens not to rearing henns.
3. We request the EU-Commission, to amend point 1.a) second indent in the Annex II of the text of the published proposal amending the marketing norms for eggs. In the proposal the extension of the time limit for the marketing refers exclusively to official orders to keep poultry indoors. The valid wording so far "In case of other restrictions“ is not included in the current proposal but this text is in the the Regulation today.
This would mean, in our opinion, that other exceptional circumstances, such as floods or exceptional weather conditions, would lead to the hens staying in the barn without a transitional period before the loss of the free-range status. Only the official order to keep poultry indoors are imposed on the basis of EU law (namely EU veterinary Law). For all other restrictions, such as extreme weather, there is no legal basis.
With the present wording of the proposal the marketing standards for eggs would be changed a substantial way and this was not intended according to the EU-Commission.
Read full response