Associação Brasileira de Proteína Animal
ABPA
ABPA is a non-profit organization composed of the Brazilian producers and exporters of poultrymeat, pigmeat and eggs.
ID: 487640615574-32
Lobbying Activity
Response to Acceptance of supply contracts as proof of origin for certain tariff rate quotas
2 Oct 2025
No que se refere à alteração do método para comprovação de origem das cotas referentes às ordens *09.4410 e 09.4420 (carne de aves in natura)*, *por não serem cotas de administração compartilhada*, a ABPA não se opõe à possível alteração proposta pela Comissão Europeia. No entanto, salientamos que o setor brasileiro não identificou disrupções no fluxo comercial, nem dificuldades na utilização dos contingentes pautais relacionados à adoção do Certificado de Origem Digital. Inclusive, os volumes dos contingentes pautais referentes ao ano de 2024 foram plenamente preenchidos, assim como no 1º trimestre de 2025. Já os volumes referentes ao 2º e 3º trimestres do ano-cota vigente, estes infelizmente ainda não foram preenchidos em sua totalidade devido à restrição imposta pela União Europeia às importações de carne de aves in natura, em razão do registro de um caso de influenza aviária de alta patogenicidade em maio/25, no estado do RS. Assim, a Associação é favorável à manutenção da adoção do Certificado de Origem Digital como prova de origem para as cotas de ordens 09.4410 e 09.4420, de modo à manter a *padronização dos procedimentos adotados na administração de todas as TRQ* acordadas entre Brasil e União Europeia, e facilitar os trâmites operacionais; mas não se opõem na eventualidade da Comissão Europeia decidir alterar o procedimento para estas TRQs específicas (09.4410 e 09.4420). Ademais, também gostaríamos reiterar quanto à necessidade de manutenção do Certificado de Origem Digital para as cotas de frango salgado e processado (ordens 09.4211; 09.4217; 09.4251; 09.4214; 09.4252 e 09.4253), respeitando o acordo firmado entre Brasil e União Europeia no que tange à administração compartilhada do sistema destas referidas cotas.
Read full responseResponse to EU rules on official controls - update to allow controls of imports for the use of certain antimicrobials
28 Apr 2021
ABPA - the largest organization uniting poultry, pork and egg producers in Brazil and one of the biggest organizations of animal protein worldwide- welcomes the chance to comment on the proposal to update the EU Food & Feed Official Controls Regulation to allow for checks on antimicrobial use in imported animals and animal products.
ABPA is committed to provide the highest level of animal health, public health and environmental protection by fighting against antimicrobial resistance as well as to promote a responsible use of antimicrobials in animals. Nonetheless, ABPA calls on the Commission to guarantee that the proposal does not lead to undue burdens on imports which could restrict trade and violate international agreements the EU have ratified.
Besides, ABPA draws attention to the fact that the proposal uses the term “antimicrobials” in the recitals while Regulation 2019/6 uses the term “antimicrobial medicinal products”, which refers to therapeutic antibiotics used for treat bacterial infections as defined in Article 2 of Regulation 2019/6. The use of “antimicrobials” is a very broad term and includes antifungals and antivirals veterinary medicines on the WHO list of Critically Important Antimicrobials for Human Medicine, Appendix 2. Therefore, in order to ensure legal certainty, ABPA calls on the Commission to ensure consistency between the two regulations and use only the term “antimicrobial medical products”
Read full responseResponse to Setting of nutrient profiles
28 Jan 2021
The Brazilian Association of Animal Protein (ABPA) welcomes the opportunity to provide feedback on the revision of rules on information provided to consumers. Please find ABPA's feedback attached.
Read full responseResponse to Tariff quotas with licences
16 Aug 2019
The Brazilian Animal Protein Association (ABPA) is the largest Brazilian organisation representing the animal protein industry with over 135 members. As a result, ABPA is responsible for the embarkation of an annual average of more than four million tonnes of poultry meat - of which 3.3% heads towards the EU – destined to almost 150 countries. In 2018, almost 40 percent of the UE poultry meat imports originated in Brazil.
The current tariff rate quotas (TRQs) management system is an example of a balanced and effective system that has allowed Brazilian exporters to access the European market, develop a business as exporters while offering European consumers access to a quality product that complements the supply of EU domestic products.
While we welcome the proposal to make the system more efficient, we remain greatly concerned about the implications of Article 9 of the Delegated Regulation, which establishes the application of a reference quantity to quota considered as over-demanded. We express regret that the questions and arguments that we have raised before, both in letters and meetings with the Commission services, have not been addressed so far. Therefore, we would like to reiterate our concerns:
Limiting the total volume of licenses that an operator can apply for to a previous performance (DA , Article 9, Paragraph 3), automatically creates a situation where not all the volume that should be available for that specific period gets distributed even if there is demand for it. This provision prevents operators from having full access to the quantities available for application under each subperiod of a quota year (commonly referred to as the “30-30-20-20" rule set out in Regulation (EC) 616/2007 of 4 June 2007).
Article 9, Paragraph 8 of the Delegated Regulation provides for a suspension of the reference requirement if by the ninth month of a quota period the total quantity applied for is lower than the quantity still available. However, this would continue to create a situation of under-utilization of the quotas. In practical terms, if we consider that the new system set up in the second paragraph of Article 9 will enter into force on 1st of July 2020, it would mean that new applications for licences not distributed in the first nine months of a quota year could not be made before 1st April 2021. As production plants have limited capacity, there would not be any possibility for substantial additional volumes to be produced and subsequently released onto the EU market over such a short period of time.
This tight timeline for application, production and release of products implies a high risk for operators applying for licenses. As a result, the quantities still available for application in the last quarter would remain unused.It is true that the Commission proposes two clauses to ensure that the reference quantity do not hinder the full use of the TRQs concerned (Article 9, Paragraph 9 and Article 10, Paragraph 5). However, it is unlikely that this would apply to some poultry TRQs (e.g. 09.4211 and 09.4214), as their situation of underfill in the last period is due rather to political and market reasons.
In view of the above, ABPA urges the Commission to allow for 100% distribution of licenses at every quarter once there is demand for such. This could be done through an increase of the reference quantity period (reference of one full year valid for application for each quarter) or allowing for redistribution of non-allocated licenses at the end of each license application period. Otherwise, the new system would hinder the full access to the quotas entitled to Brazil.
Finally, ABPA would like, once again, to emphasize, that the new system introduced in Article 9 will create a discrimination between applicants and avoid entrance of new comers, which is contrary to the non-discriminatory principle established by the agreement on the TRQs between Brazil and the EU.
Read full responseResponse to Tariff quotas with licences
16 Aug 2019
The Brazilian Animal Protein Association (ABPA) is the largest Brazilian organisation representing the animal protein industry with over 135 members. As a result, ABPA is responsible for the embarkation of an annual average of more than four million tonnes of poultry meat - of which 3.3% heads towards the EU – destined to almost 150 countries. In 2018, almost 40 percent of the UE poultry meat imports originated in Brazil.
ABPA would like to express concern with regard to Annex I to the Implementing Regulation, which lists the quotas considered as over-subscribed and, as a consequence, subject to the requirement of reference quontity (Article 9 of the Delegated Regulation). ABPA has questioned on multiple occasions the method used by the European Commission to include certain poultry under the category of over-demanded. The following example demonstrates why:
Frozen salted poultrymeat (09.4211) and cooked about 57 % (09.4214) from Brazil are considered as over-subscribed quotas and, therefore, are included in Annex I. From the outset, taking into account the last figures related to the allocation of licences of two types of meat (including ‘salted’) as highly demanded/oversubscribed is hardly admissible. As highlighted in the document attached below, in the last two quota periods (2017-2018 and 2018-2019) these quotas have not been filled due to different reasons (delisting of plants in the case of frozen salted and market reasons in the case of cooked above 57 %). The case of cooked above % 57 is even more evident, as it has never been fully utilized.
In view of this, under the new system operators would have limited access to the full quota from the first-subperiod, as their application will be subject to their performance in the two previous periods (requirement of reference quantity foreseen in Article 9 of the Delegated Act).
Given this situation, ABPA calls upon the Commission to reconsider the criteria used for the qualification of certain poultry TRQs as highly demanded, and particular the above-mentioned TRQs.
Read full response18 Dec 2017
The Brazilian Association of Animal Protein (ABPA), representing over 130 companies in the meat sector, presents several insights to the European Commission to argue why formaldehyde provides relevant benefits on the production of poultry and swine based products. Formaldehyde based products have been used for more than 25 years by different companies in Brazil for poultry and swine without any damage on performance and reproduction, and we can provide the Commission with updated articles and reports showing benefits of the treatment of diets with Salmex (33% formaldehyde) concluding that is not only safe but there are benefits on the use for poultry and swine products. In fact, in January and July 2014 the EFSA concluded that at specific concentrations the use of formaldehyde would be safe for chickens and piglets.
Regarding workers security, the use of formaldehyde raised further concerns for the safety of its users. We confirm to the Commission that during the production process of feed, operators do not get in direct contact with formaldehyde, being stored in a specific deposit in the external area of the plant where it is injected and mixed through metering pumps, all of these together with the provision of all proceedings and security equipment that must be used in order to avoid adverse effects to human health. As any other chemical product, to avoid the breath of dust from the production process, the use of protection equipment is mandatory and, considering its liquid form (using Salmex as example), for feed application it is used a completely closed and safe system, from the production plant, logistics and specific system for feed application by spraying, that eliminates the risk of direct contact of people with the product and promotes very low to zero levels of vapor around the feed equipment. In the framework of Union legislation on health and safety at work, the Scientific Committee on Occupational Exposure Limits established by Commission Decision 2014/113/EU11 pronounced itself on a limit value for formaldehyde based on a mode-of-action assessment. The limits settled down by EU are much lower than any other countries (including Brazil), and also this levels of limit settled do not consider the mandatory use of protection equipment (facial and breathing masks) in feed plant sector.
The proposed replacement approach, given the possible risks for users, suggests formic acid as an alternative substitute. Nevertheless, it is not considering that formaldehyde is an extraordinary low-cost bactericide, it is not possible to consider formic acid as an effective alternative to replace it when we consider salmonella and other bacterial controls in feed. That is because formic acid poses a high operational risk and requires special security measures for its application. Differences in their application must be remarked, as well as the lower bactericide level of formic acid, which implies a higher dosage with a higher cost, including higher corrosive levels for equipment.
In this sense, ABPA requires the European Commission to carry out relevant research and impact assessment studies before taking any final decision on the authorization of formaldehyde.
ABPA remains at Commission´s disposal to provide further evidence that support formaldehyde as an effective tool for Salmonella control in poultry and swine feed. In case the Commission finally bans the use of formaldehyde, a reasonable transition period to adapt the current stock and formulations to the new requirements would be necessary.
Read full responseMeeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström)
30 Mar 2015 · Poultry and pig sector in Brazil