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Association de l'Aviculture, de l'Industrie et du Commerce de Volailles dans les Pays de l'Union Europeenne asbl

AVEC

AVEC represents the interests of European poultry processors and the poultry trade industry.

Lobbying Activity

Poultry industry warns against losing control over trade origin rules

2 Dec 2025
Topic — EU evaluation of rules determining product nationality for customs and trade policy.
Message — The association requests a generalised framework governing all tariff quotas to prevent partner countries from using origin certification as a trade policy tool. They warn that self-certification without proper EU oversight allows exporters to control market access and capture duty differentials.123
Why — This would prevent partner countries from concentrating market access among selected exporters and protect their sourcing independence.456
Impact — EU poultry producers lose when foreign exporters gain unfair market advantages through concentrated quota access.78
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EU poultry industry seeks permanent flexibility in organic rules

17 Nov 2025
Topic — This consultation reviews EU organic trade rules and simplifies organic production requirements.
Message — The associations request making the use of non-organic chicks and five percent non-organic feed permanent. They also propose removing mandatory outdoor access for breeder flocks to ensure biosecurity.123
Why — This would reduce production costs and provide long-term investment security for farmers.4
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Meeting with Benoit Cassart (Member of the European Parliament)

5 Nov 2025 · Politique de santé animal - Normes de commercialisation

EU Poultry Sector Urges Vaccination Over Mass Culling in Health Crisis Plan

29 Oct 2025
Topic — EU plan for coordinated prevention, preparedness and response to cross-border health threats.
Message — The association requests an EU-wide prevention plan prioritizing vaccination and biosecurity over mass culling for animal diseases. They call for coordinated surveillance networks, rapid vaccination strategies across Member States, and dedicated funding for preventive measures rather than reactive responses.123
Why — This would reduce devastating economic losses from outbreaks and preserve poultry flocks and livelihoods.456
Impact — Current mass culling policies devastate farmers through lost livelihoods and impose mental health tolls on agricultural workers.78
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Response to Food and Feed Safety Simplification Omnibus

14 Oct 2025

Please find attached the contribution of AVEC - The Voice of the European Poultry Meat Association.
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Meeting with Brigitte Misonne (Acting Director Agriculture and Rural Development)

30 Sept 2025 · Exchange of views on poultry marketing standards, origin labelling, meat designations and promotion

EU Poultry Industry Welcomes Supply Contracts as Proof of Origin

29 Sept 2025
Topic — New EU regulation accepting supply contracts as proof of origin for poultry tariff quotas.
Message — The association requests extending supply contracts as proof of origin to all poultry tariff rate quotas, not just those currently proposed. They want the EU to maintain exclusive control over quota management and prevent third countries from implementing parallel allocation mechanisms.123
Why — This would give them fairer access to import quotas and reduce competitive distortions.45
Impact — Brazilian and other third-country exporters lose control over allocating EU market access.6
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Poultry industry urges EU to reject fur farming ban

25 Jul 2025
Topic — Evaluation of a potential ban on fur farming in the European Union.
Message — The association urges the Commission to refrain from an outright ban and instead implement harmonized welfare standards. They argue fur farming provides a vital outlet for poultry by-products within the circular economy.12
Why — Maintaining fur farms prevents higher waste disposal costs for poultry meat processors.3
Impact — Rural communities would suffer from the destruction of local value chains and employment.45
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Response to Modernisation of the EU legislation for on-farm animal welfare for certain animals

16 Jul 2025

Please find attached the feedback of AVEC, ELPHA and EPB to the call for evidence.
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Meeting with Brigitte Misonne (Acting Director Agriculture and Rural Development)

14 May 2025 · Exchange of views on the livestock workstream announced in the EU Vision for Agriculture and Food

Meeting with Olivér Várhelyi (Commissioner) and

13 May 2025 · Animal health and welfare

Meeting with Alisa Tiganj (Cabinet of Commissioner Christophe Hansen) and European farmers and

30 Apr 2025 · • ELV five recommendations for the Vision for the Future of EU Agriculture and for the mandate • Presentation of ELV (European Livestock Voice) • Exchange of views: Vision for the future of Livestock • EU Trade policy review: State of play

Meeting with Catherine Geslain-Laneelle (Director Agriculture and Rural Development)

18 Mar 2025 · Exchange of views on issues considered relevant by the Danish Poultry Meat federation, notably on the Vision for agriculture and food.

Meeting with Bernard Van Goethem (Director Health and Food Safety) and

18 Mar 2025 · Update on revision of animal welfare legislation and animal welfare during transport. For Animal Health, interest in EU rule simplification, including revision of surveillance requirements after vaccination.

Meeting with Maroš Šefčovič (Commissioner) and

13 Mar 2025 · Negotiations with Ukraine under Article 29 of the Association Agreement (tariff liberalisation) – Position of European agricultural stakeholders (sugar, poultry, eggs, ethanol, maize, wheat and honey)

Meeting with Christophe Hansen (Commissioner) and

13 Feb 2025 · Review of the EU-Ukraine Deep and Comprehensive Free Trade Area (DCFTA)

Meeting with Zaneta Vegnere (Cabinet of Commissioner Valdis Dombrovskis)

11 Feb 2025 · exchange of views on the market pressures stemming from the eggs and poultry produce from Ukraine

Meeting with Frank Bollen (Head of Unit Agriculture and Rural Development)

4 Feb 2025 · Review of the EU-Ukraine Deep and Comprehensive Free Trade Area (DCFTA)

Meeting with Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič) and European Live Poultry and Hatching Egg Association and Association of the European Poultry Breeders

23 Jan 2025 · Discussion on the poultry industry, its trade components and challenges, the need for policy intervention.

Meeting with Diego Canga Fano (Acting Deputy Director-General Agriculture and Rural Development)

23 Jan 2025 · European poultry program

Meeting with Sandra Gallina (Director-General Health and Food Safety) and

23 Jan 2025 · Highly pathogenic avian influenza & Animal welfare.

Meeting with Mihail Dumitru (Deputy Director-General Agriculture and Rural Development) and

22 Jan 2025 · Stocktaking of key issues in the poultry sector

Meeting with Sabine Weyand (Director-General Trade) and European Live Poultry and Hatching Egg Association and Association of the European Poultry Breeders

22 Jan 2025 · Current issues in the European poultry meat sector.

Meeting with Benoit Cassart (Member of the European Parliament, Shadow rapporteur)

4 Dec 2024 · Animal transport

Response to Modifying provisions relating to the promotion of agricultural products

11 Oct 2024

AVEC welcomes the opportunity to provide feedback on the modification of the Delegated Regulation (EU) 2015/1829. While we welcome the Commissions proposed changes, especially on the continuation rules and on the reduction of the administrative burden, they remain insufficient in addressing the longstanding issues faced by the participants of these programs. In particular, regarding the "continuation rules" in the modification of Article 1, paragraph 4, although the delegated acts provide some necessary improvements, they do not fully correct the impossibility for an organization to participate on 2 consecutive programs. From a communication perspective, maintaining a certain level of continuity is essential to ensure that promotion messages effectively reach their target audiences. Additionally, all evaluation studies of the programs in which AVEC or its members have participated show a strong demand from the consumers for more information (studies are available under request). Therefore the one-year break after two consecutive campaigns is problematic to ensure this level of continuity. Moreover, while the introduction of the possibility to use lump sum as an alternative method for calculation of eligible costs may reduce administrative burden, there are too many requirements in the application, implementation, and reporting processes of the campaigns that are overly bureaucratic. Over the past years, AVEC and its members have faced an increase in administrative burdens and monitoring procedures, rather than a reduction. This has resulted in more time being spent on administrative tasks rather than executive work, leading many of our members to reconsider applying to new Promotion programs. This is extremely worrying trend that the EU Commission must address. In addition, we strongly deplore the absence of budget for MULTI programs this year. This is unacceptable, especially at a time when raising awareness and informing citizens about the agrifood sector's efforts to adopt more sustainable production methods is crucial. MULTI programs are the cornerstone of the Promotion policy and represent the true added value of EU Promotion initiatives. We urge policy makers to put back similar budget than last year for MULTI programs (AWP 2023). Last but not least, we would like to reiterate that the promotion of agricultural products should continue to support all agricultural sectors without discrimination, including meat and conventional products. We hope our suggestions will be taken into consideration and remain available to further explain our contribution.
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Meeting with Valérie Hayer (Member of the European Parliament) and ENTREPRENEURS DES TERRITOIRES FNEDT

4 Oct 2024 · Divers

European poultry industry opposes further tariff cuts for Ukraine

26 Sept 2024
Topic — Accelerating mutual elimination of customs duties under the EU-Ukraine Association Agreement.
Message — The association opposes further trade liberalisation for poultry meat with Ukraine. They argue market access has already been adjusted upward significantly and should not be modified until Ukraine's EU accession. They request the Commission acknowledge poultry as a sensitive sector and carefully consider appropriateness of additional access.123
Why — This would protect EU producers from price decreases and maintain their investment capacity.4
Impact — Ukrainian poultry exporters lose additional market access to the European Union.
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Meeting with Maria Noichl (Member of the European Parliament)

2 Jul 2024 · Poultry sector

Response to Amendment of some rules applicable to the reference quantity requirement

19 Jun 2024

Subject: Regulation (EU) 2020/760 lays down rules for EU importers to apply for import licences. AVEC welcomes the modification proposed by the European Commission on the Regulation (EU) 2020/760 lays down rules for EU importers to apply for import licences. The Autonomous Trade Measures (ATM), decided to support Ukrainian economy following the Russian aggression has had unintended consequences on the dynamics of TRQ import licenses in the EU. The trade liberalisation resulting from this mechanism has led to a situation where massive imports from Ukraine (way above initial TRQ) have been used to create reference quantities that qualify (as foreseen in Delegated regulation (EU) 2020/760) for licenses for other TRQs giving operators importing from Ukraine an unfair advantage compared to their competitors. Obviously, this was not the intention of the legislators during the revision of the TRQ management legislation and this is why we support the Commission in its intention to avoid this possibility. Our preferred solution would have been to create a mechanism where imports on zero duty outside quotas and without licence system would never qualify as reference quantity, but we believe that the solution proposed by the Commission will address these concerns.
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Meeting with Janusz Wojciechowski (Commissioner) and

22 Apr 2024 · EU Promotion Policy These meetings were hold during the whole HLM

Response to Protection of animals during transport

11 Apr 2024

Please find attached AVEC, ELPHA and EPB comments on the proposal. Thank you.
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Response to Evaluation of the European Food Safety Authority (EFSA) 2017-2024

5 Apr 2024

Please find AVEC/ELPHA/EPB feedback attached. Thanks.
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Response to Evaluation of the Animal Health Law

3 Apr 2024

Please find attached AVEC/ELPHA/EPB feedback. Thank you.
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Meeting with Olivér Várhelyi (Commissioner) and

7 Mar 2024 · Ukraine

Meeting with Janusz Wojciechowski (Commissioner) and European farmers and

10 Jan 2024 · Meeting with EU associations representing different sectors and actors presenting a proposal for a mechanism to protect sugar, cereals/oilseeds, poultry meat and eggs farmers/producers from severe market disturbance linked to imports from Ukraine.

Meeting with Janusz Wojciechowski (Commissioner) and Vereniging van de Nederlandse Pluimveeverwerkende Industrie

6 Jun 2023 · Presentation on safeguard measures on imported poultry meat from Ukraine

European Meat Industry Urges Exemptions for Recycled Packaging Mandates

24 Apr 2023
Topic — The European Commission is reviewing rules for packaging design and waste prevention.
Message — The associations request exemptions from mandatory recycled plastic content for fresh meat. They also advocate for harmonized labels to avoid higher production costs.123
Why — Avoiding these rules prevents food safety risks and reduces packaging expenses.45
Impact — Environmental groups lose as the meat industry delays transition to circular packaging.6
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Meeting with Janusz Wojciechowski (Commissioner) and

10 Jan 2023 · Sustainability of the poultry sector, reciprocity in trade agreements, imports from Ukraine, future promotion policy, and more generally the future of livestock and meat production in EU.

Meeting with Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis), Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

15 Dec 2022 · Trade liberalisation with Ukraine

Meeting with Janusz Wojciechowski (Commissioner) and

23 Jun 2022 · Lifting of all tariffs and quotas for poultry meat imports from Ukraine

Response to Application of EU health and environmental standards to imported agricultural and agri-food products

10 Mar 2022

AVEC favours the implementation of a strong reciprocity policy in the EU trade with third countries, especially in light of the reinforcement of the EU legislation in all aspects of sustainability. It is about the credibility of the EU in its fight against climate change, it is about giving its EU producers equal chances to compete and it is about preserving the EU citizens from products produced under lower standards. AVEC believes that reciprocal rules are WTO compatible as long as there is no discrimination towards third countries and that EU producers and third country's ones are put on an equal footing. To achieve this objective, the best option consists in requiring that imported products fully (or if not possible partially) comply with EU legislations and to include specific provisions directly in each legislation (e.g. legislation on welfare at the time of killing). The revision of many EU legislations (on animal welfare, marketing standards, labelling) in the context of the implementation of the farm to fork strategy is a great opportunity for that. Lastly, this must go hand in hand with stricter controls on imported products to make sure third countries respect these measures.
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Meeting with Janusz Wojciechowski (Commissioner) and

27 Jan 2022 · 2022 Annual Work Programme of the EU Promotion Policy

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

20 Jan 2022 · Discussion on sustainable livestock

Meeting with Christiane Kirketerp De Viron (Cabinet of Commissioner Johannes Hahn) and European agri-cooperatives and

14 Dec 2021 · Agricultural Promotion Policy

Response to Food waste reduction targets

29 Oct 2021

AVEC representing the EU poultry meat sector would like to thank the Commission for giving us the opportunity to comment on this inception impact assessment on the proposal for a revision of Directive 2008/98/EC on waste – part on food waste reduction target. Our association supports the objective of food waste reduction of as part of the Green Deal and the Farm to Fork Strategy in order to make a better use of natural resources and reduce our overall environmental impact. Our position is available in the attachment.
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Response to Sustainable food system – setting up an EU framework

26 Oct 2021

AVEC representing the EU poultry meat sector and ELPHA representing the European Live Poultry and Hatching eggs association would like to thank the Commission for giving us the opportunity to comment on this inception impact assessment on the Sustainable food system framework initiative. Our associations support the objectives of Farm to Fork Strategy and the overall objective of the Sustainable food system framework initiative of ensuring that all foods placed on the EU market increasingly become sustainable. Climate change is already a reality and the objective of reducing the environmental footprint of the Union food system should be seen as a priority in line with the objectives of the Paris agreement. Our sector is committed to engage in the transition towards more sustainable production and to be part of the solution when it comes to green deal and farm to fork policies. Please find attached our position.
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Response to Authorisation to feed poultry with processed animal protein derived from farmed insects or domestic porcine animals

31 Mar 2021

Consultation on the Commission draft regulation providing for the authorisation to feed non-ruminants with ruminant collagen / gelatine and with proteins from insects, pigs and poultry AVEC, the association representing the EU poultry meat fully supports this EU Commission draft regulation amending Regulation (EC) 999/2001 amending Annex IV to Regulation (EC) No 999/2001 of the European Parliament and of the Council as regards the prohibition to feed non-ruminant farmed animals, other than fur animals, with protein derived from animals. AVEC is of the opinion that this proposal acknowledges the absence of food safety risk for the authorization of these products, as described in the EFSA opinion, and offers a legislative framework that is offering a high level of security for all the actors in the food chain. Based on this prerequisite, AVEC welcomes the possibility to diversify its feed supply by using porcine Processed Animal Proteins which are an important source of highly concentrated proteins. PAPs are a highly beneficial source of protein for the feed ration, due to its amino-acids repartition and high digestibility. On the other side, we expect poultry PAPs to be a similar excellent source of protein for the pig ration, and to create a new outlet for our producers for their poultry by-products. Members of AVEC guarantee a high level of food safety, which is closely linked to feed safety. Sophisticated and effective control mechanisms are already established in the feed supply chains of its members. We are able to apply these procedures within our procurement processes to PAP immediately. Therefore we are able to ensure feed safety within our existing quality assurance programs. We also very much welcome the opening of the possibility to use insects in our feed, which is a natural source of protein for poultry and has a promising potential for the poultry sector. We hope that this authorization is the first step for the development of the sector, that should be encouraged by the Commission. Lastly, we believe this proposal is in line with the objectives of the green deal/farm to fork strategy, by increasing the circularity of our sectors and the possibility for EU producers to source their protein feed in the EU. The current strong increase in demand on the global commodity market for protein-rich feed is a fundamental challenge for the European agriculture. Globalisation, climate change and the increasing demand from developing and emerging markets will probably lead to an intensification of this trend in the future. Therefore, offering solutions for sourcing protein feed from EU based sources, is a step in the right direction, and the EU authorities should go further into that direction.
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Response to Information and promotion measures for agricultural and food products in the internal market and in non-EU countries

9 Mar 2021

The European Poultry Meat Sector takes the opportunity to provide comments (please see Annex) on the European Commission's Inception Impact Assessment on "EU farm and food products – review of policy on promotion inside and outside the EU".
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Response to Contingency plan for ensuring food supply and food security

13 Jan 2021

AVEC, the Association of Poultry Processors and Poultry Trade in the EU welcomes the initiative of the EU Commission – to create an EU food supply and food security – contingency plan. AVEC supports the creation of a common EU food crisis response mechanism – and we find that it is of huge importance that all the stakeholders in the food chain will participate in the permanent forum, together with the Commission and the Member States. Please find attached AVEC's feedback to the initiative.
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Response to New authorized inputs and extended derogation for non-organic pullets and non-organic protein feed in organic production

17 Nov 2020

AVEC representing EU poultry meat sector and ELPHA representing the European Live Poultry and hatching eggs associations very much support the extension by 1 year of the two derogations defined in Regulation (EC) 889/2008 (article 42b and 43): 1) on the use of non-organically reared pullets for egg production 2) on the use of maximum 5% of non-organic protein feed These derogations are primordial to give sufficient flexibilities to producers to maintain the level of European organic poultry and eggs production in 2021, before the implementation of the new Regulation that will apply in the start of 2022.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

AVEC (transparency number 9803788883-16), representing the EU poultry meat sector, would like to thank the Commission to give use the possibility to provide feedbacks on this public consultation on the upcoming legislative proposal on substantiating green claims. Over the last decades, our producers have been successful in improving to a large extend the environmental performance of the poultry meat sector and they are continuously working to continue in that path. We therefore support the efforts from the Commission to provide more transparency on the use of green claims. However, we would have some reservations in relation to the proposed methodology in the consultation, namely the product environmental Footprint (PEF). We believe that, to become a methodology that would be used as the reference, some important improvements should be put in place: 1) We think that product comparability should be limited to like-products using the same Product Environmental Footprint Category Rules (PEFCR). 2) The Commission should clarify the role of the PEF-initiative in the proposed sustainable labelling framework 3) For the meat sector, it is important to recognize the full contribution of the sector to the circular economy. In fact, in the poultry production, nothing is wasted, and all non-edible parts of the animals are used for many different purposes. In particular, the manure is a very important element for fertilizing crops, especially in the perspective of the reduction of chemical fertilizers (cf farm to fork strategy). It is also used for producing green energy such as biogas. 4) The distribution of allocation of the environmental performance of an animal at slaughterhouse level is described on page 88-92 in the JRC PEF Method. According to this allocation rule, the mass fractions being allocated to the different categories (human consumption, skin/hides, various by-products, etc.) are fixed. Furthermore, company specific data is not allowed to determine the distribution of mass fractions for individual slaughterhouses. By doing so, it makes it impossible for a slaughterhouse to be rewarded, if it increases the percentage of an animal going to human consumption (in line with recommendations of the waste hierarchy). There is therefore no incentive for the slaughterhouses to improve their practices and reduce the fraction of non-edible parts of the animals. 5) On the issue of allocation of co-production/products, the method should be transparent, easy to implement and provide an incentive to increase the environmental performance of the sector. 6) The allocation method selected for meat at slaughterhouse level in the JRC PEF Method (see page 88-92), is economic allocation. This is problematic as it is based on a fixed ratio/price indexation for the different categories. The meat sector is taking the vast majority of the environmental impact compared to other sectors (approx. between 93 – 99% depending the species). No matter what they do to improve their environmental impact, slaughterhouses will know that their efforts will not be recognized due to the allocation method. This is very much problematic. 7) Economic allocation brings additional issues since the price of meat and especially poultry meat is fluctuating very much and to different levels in the different EU countries. Therefore, there would be a need for regular updates on the prices to have reliable ratio, which would make the use of the methodology complex and burdensome. 8) Lastly, the EU should make sure that a global harmonized method should be developed to substantiate green claims. Therefore, it is important to look at international initiatives that are developed such as the FAO LEAP. We hope that our comments will be taken into account and our sector is determines to demonstrate that when it comes to green deal and sustainable farm to fork, poultry meat is part of the solution.
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Poultry industry seeks trade alignment in animal welfare review

28 Jul 2020
Topic — The European Commission is evaluating if current animal welfare rules meet sustainability goals.
Message — AVEC wants welfare rules aligned with trade policy and based on science. They also request economic assessments of any legislative changes.123
Why — Reciprocal trade standards would protect EU producers from cheaper foreign imports.45
Impact — Third-country exporters would lose their competitive advantage over European poultry farmers.6
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Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski)

9 Jul 2020 · Concerns on how the EU Poultry Meat Sector will recover from the COVID-19 crisis.

Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives and European Live Poultry and Hatching Egg Association

8 May 2020 · To discuss measures taken from the EU Commission to support the EU Poultry Sector in the context of the COVID-19 crisis.

Response to Farm to Fork Strategy

6 Mar 2020

AVEC, (European Poultry Meat Sector) welcomes the European Commission’s Green Deal and the Farm to Fork strategy covering the whole agri-food chain, from producers to consumers. As stakeholder in the European food production, we appreciate the holistic approach proposed to address the climate crisis. To effectively improve sustainability, a careful assessment based on evidence, not emotions, is needed. We find that it is important to highlight, that we produce meat in a very efficient and climate smart way in the EU, contrary to most other places in the rest of the world. Therefore, reduction of the meat production in the EU must be carefully assessed, as it could lead to increase of production in the rest of the world and to higher emissions seen on a global perspective. It is also worth noticing that poultry meat is produced with high standards on food safety, animal health, animal welfare and environmental protection in the EU, leading to higher producing costs than in third countries. Further demands will lead to a decrease in the European Poultry Meat Production – which means loss of EU jobs, mainly in rural areas - and to higher imports from third countries of products produced with lower standards. Food insecurity remains an issue for over 36 million EU citizens who cannot afford a quality meal every second day. Poultry meat is a very important and affordable source of protein and is an essential part of a balanced diet. Low-income consumers should still have access to Poultry meat produced under basic but strong EU welfare standards. The EU welfare standards - which have been made based on science - are incorporated in legislation. This is not the case in many other parts of the world. The impact on the environment of poultry meat production is low, and the benefits of having poultry meat in the human diet (low fat, high nutritional value, complete protein supply) is too often underestimated. We believe that organic production has a role to play in order to meet growing consumer demands. However, it is important to note that there are ecological trade-offs implied by an increase of organic agriculture, should be considered. Organic poultry meat production demands more feed and water per kg produced meat than the conventional production and this leads to higher emissions. We welcome the initiative of the Commission to help consumers choose healthy and sustainable diets by providing better food information. In this context it is important to highlight that mandatory labelling of origin EU/Non-EU on all products containing poultry meat in all part of the chain is needed. While the out of home consumption of poultry meat is growing (restaurants, catering,…), this part of the market is largely supplied with imported poultry meat from 3rd countries, where the same legislation as in the EU does not apply or is not sufficiently controlled. There is no labelling of origin for this segment of the market. We strongly support the EU One Health Action Plan against Antimicrobial Resistance (AMR). In the effort to reduce the use of antibiotics in the veterinary sector it is of huge importance to find a balance – since animal welfare decrease if an animal is not treated if it becomes ill. The European Poultry Meat Sector encourages to use - As little as possible, but as much as necessary. It is of huge importance to find a way to feed a much larger world population in 2050 without damaging our planet and the EU has a crucial role to play in that matter. We believe that a truly holistic approach is needed to balance these tensions and achieve the climate action that is needed whilst preserving Europe’s capacity to produce enough food for an ever-growing population. The European Poultry Meat Sector looks forward to working closely with the Commission, to develop the best sustainable Farm to Fork Strategy possible and remains at your disposal to discuss them in more detail.
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Response to Minimising the risk of deforestation and forest degradation associated with products placed on the EU market

4 Mar 2020

AVEC (EU poultry meat sector) shares the EU-Commission’s objective to fight against deforestation, improve biodiversity, prevent violations to human rights and limit greenhouse gas emissions. As regards poultry meat, soy is an essential part of the feed ration, contributing to a balanced protein supply for the animals. While very often soy supply is associated with deforestation risks, our members are working in close collaboration with feed suppliers to make sure that supply comes from fully legitimate agricultural production in the producing countries. In particular they support initiatives from the feed sector (FEFAC) such as Soy Sourcing Guidelines in order to accommodate the promotion of certified deforestation-free supply chains. AVEC is also keen on supporting public-private collaboration with exporting countries to increase their capacity to deliver on tackling deforestation. However it has to be reminded that for the market year 2018/2019, 74 % of imported soybean meal used in feed in the EU are coming from areas that have a low to negligible deforestation risk. In that context, AVEC would recommend the Commission to favour legislations that encourage investment in sustainable supply chains (including certification and public-private sector agreements) and refrain from any ‘penalty systems’ that only stimulate the geographical avoidance of deforestation-risks. Most importantly, the Commission must make sure that any measure decided will apply identically to imported products. If we take the example of poultry meat, an important part of the imports (mainly coming from Brazil, Thailand and Ukraine) ends up in processed food/restaurant/catering where information on the origin and other aspects of the production are not made available to the final consumers. Therefore, we have to avoid that such an EU-policy would end up in decreasing the competitiveness of EU producers while increasing imports of products that perform worse on these aspects. This is why an impact assessment with a broad consultation of the economic operators that will be impacted by the measures is crucial. Last but not least these measures should go hand to hand with measures aiming at decreasing the dependency of the EU livestock sector to soy from third country, by developing alternative sources of protein in the EU. In particular: -by developing a major protein plan in the EU that aims at increase significantly the production of protein feed on the EU territory -by allowing new protein feed to emerge (such as insects) -by reintroducing the use of non-ruminant Processed Animal Protein for pork and poultry
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Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Karolina Herbout-Borczak (Cabinet of Commissioner Stella Kyriakides)

12 Feb 2020 · Farm to Fork Strategy

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

12 Feb 2020 · The role of the poultry sector in the Green Deal

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

12 Feb 2020 · The role the European Poultry Meat Production can play in the Green Deal and the Sustainable Farm to Fork Strategy

Meeting with Janusz Wojciechowski (Commissioner)

23 Jan 2020 · Sustainability from Farm to Fork

Meeting with Phil Hogan (Commissioner)

10 Sept 2019 · Agri Matters

Response to Tariff quotas with licences

22 Aug 2019

AVEC, representing the poultry meat sector in the EU, would like to thank the Commission for offering us the possibility to provide feedback on this regulation. Poultry meat sector: For the poultry meat TRQs, AVEC expects that the new proposal will create a complete shift of value of the TRQs at the expense of the EU to the profit of suppliers from third countries (mainly Brazil and Thailand); those may have the opportunity to take full control of the TRQs, excluding de facto the role of all EU SMEs and the EU poultry industry, therefore achieving a much more powerful role in the EU poultry market. Through the current proposal, third country producers will be stimulated to significantly increase their exports outside of quota as they are instantly rewarded with a bigger piece of the quota pie. Today already 25 % of the breast meat consumed in the EU is imported from Third countries. With this shift of power, third countries producers will be able to set the price of breast meat in the EU market. The consequences will be: -the exclusion of the EU SMEs from the TRQs within 5/6 years; -the increase of the equalisation effect. Thanks to the increase of the quota rent, the 3rd country exporters will sell more high-value products (such as the breast) in the EU, with full-duty payment. The Commission now suggests to overcome this by only allowing imports of a certain GN code from a certain origin to qualify as reference quantities for a new application of that same product. Ie. only Thai cooked poultry qualifies as reference for Thai cooked poultry licenses. This will completely lock up the market and will basically give current operators a license for life with no possibility for newcomers to access the quotas and that can only be threatened by imports at full duty by third country producers. All flexibility will be lost and in case of animal diseases in third countries operators in the EU might get completely stuck. Further, third country producers could decide to take control by only offering on duty paid basis leaving importers with licenses they cannot use and no escape possibilities to other origins or products. To limit those adverse effects and in order for the Commission to guarantee market stability, 2 important modifications should be brought to these proposals: -Introduce as much flexibility as possible: there should not be like-for-like on GN codes and origin. Instead qualification should be possible with all GN codes that are within the group of over-demanded TRQs. -Exports should qualify as reference. Qualification through exports is the only way through which EU operators can hope to maintain some balance of power with the large 3rd country producers. In the current regulations where there is no reference system for most TRQs, companies qualify to apply for quota through exports. The general rules of the new Commissions proposal also include exports. Excluding exports as qualification for the poultry quota would therefore be an unnecessary concession to third countries. Last but not least, we believe that the uncertainty and the risk of a hard Brexit should lead the Commission to wait until more clarity on the future relation between EU and UK is defined. A no deal scenario would have significant negative consequences on the stability of the EU poultry meat market (EU 27 exports 500 000 T to UK, while UK imports 220 000 T from third countries) and therefore applying these new legislations before Brexit will bring unnecessary additional risk and uncertainty on the poultry meat market. General comments: As a more general comment, AVEC suggests that the details of the requirement for reference quantity should be moved from the Delegated Act to the Implementing Act so as to improve the flexibility of the TRQ administration.
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Response to Tariff quotas with licences

22 Aug 2019

AVEC, representing the poultry meat sector in the EU, would like to thank the Commission for offering us the possibility to provide feedback on this regulation. Poultry meat sector: For the poultry meat TRQs, AVEC expects that the new proposal will create a complete shift of value of the TRQs at the expense of the EU to the profit of suppliers from third countries (mainly Brazil and Thailand); those may have the opportunity to take full control of the TRQs, excluding de facto the role of all EU SMEs and the EU poultry industry, therefore achieving a much more powerful role in the EU poultry market. Through the current proposal, third country producers will be stimulated to significantly increase their exports outside of quota as they are instantly rewarded with a bigger piece of the quota pie. Today already 25 % of the breast meat consumed in the EU is imported from Third countries. With this shift of power, third countries producers will be able to set the price of breast meat in the EU market. The consequences will be: -the exclusion of the EU SMEs from the TRQs within 5/6 years; -the increase of the equalisation effect. Thanks to the increase of the quota rent, the 3rd country exporters will sell more high-value products (such as the breast) in the EU, with full-duty payment. The Commission now suggests to overcome this by only allowing imports of a certain GN code from a certain origin to qualify as reference quantities for a new application of that same product. Ie. only Thai cooked poultry qualifies as reference for Thai cooked poultry licenses. This will completely lock up the market and will basically give current operators a license for life with no possibility for newcomers to access the quotas and that can only be threatened by imports at full duty by third country producers. All flexibility will be lost and in case of animal diseases in third countries operators in the EU might get completely stuck. Further, third country producers could decide to take control by only offering on duty paid basis leaving importers with licenses they cannot use and no escape possibilities to other origins or products. To limit those adverse effects and in order for the Commission to guarantee market stability, 2 important modifications should be brought to these proposals: -Introduce as much flexibility as possible: there should not be like-for-like on GN codes and origin. Instead qualification should be possible with all GN codes that are within the group of over-demanded TRQs. -Exports should qualify as reference. Qualification through exports is the only way through which EU operators can hope to maintain some balance of power with the large 3rd country producers. In the current regulations where there is no reference system for most TRQs, companies qualify to apply for quota through exports. The general rules of the new Commissions proposal also include exports. Excluding exports as qualification for the poultry quota would therefore be an unnecessary concession to third countries. Last but not least, we believe that the uncertainty and the risk of a hard Brexit should lead the Commission to wait until more clarity on the future relation between EU and UK is defined. A no deal scenario would have significant negative consequences on the stability of the EU poultry meat market (EU 27 exports 500 000 T to UK, while UK imports 220 000 T from third countries) and therefore applying these new legislations before Brexit will bring unnecessary additional risk and uncertainty on the poultry meat market. General comments: As a more general comment, AVEC suggests that the details of the requirement for reference quantity should be moved from the Delegated Act to the Implementing Act so as to improve the flexibility of the TRQ administration.
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Response to Enhancing Market transparency in the agri-food chain

19 Jun 2019

Overall for the poultry sector there is a very small spot market with fewer daily/week price fluctuations compared to eg pork prices. Virtually domestic sale is on long term contracts - typically 6 months to 1 year in which prices are not changed. Therefore, it does not make sense to report weekly prices, but more meaning with monthly prices. Another question could be whether there is a risk of publication of prices in the case of invitations to tender and contracts with retailers or food services. The market probably knows when contracts are completed and may, through publication of weekly prices, identify the individual contract. A prerequisite for being able to deliver prices that is meaningful and comparable is that it clearly defines product specifications. For whole chicken it must be specified within which weight limit price must be stated when producing whole chickens weighing from 1 to 2 kg as the kilo price is not the same (small chickens are more expensive per kilo). For chicken breast and thigh meat it must be clarified if it is with or without added water/marinated, and whether it is the price with or without skin. For thigh meat it is furthermore highly relevant to define which cut to be reported, as there is a large price difference on the upper, lower and back legs. In addition, it must also be clearly defined, whether prices are for fresh or if frost must be reported as a weighted price with fresh meat ... fresh meat has a much higher price than frozen. In addition there may be major differences in price structures on sizes and cuts, so a price comparison across national borders may be difficult if intended. Therefore, it may also be problematic to publish figures that may not be directly comparable between countries. It should be clarified whether national / EU laws provide the basis for compulsory acquisition of prices agreed on long contracts between two private actors (slaughterhouse and retail), which will be published. Regarding the 2 % threshold (national production of organic meat below 2 % of total EU production is exempted from reporting prices) for reporting organic poultry meat prices in Annex ii, it is unclear how this is to be determined as long as no reliable figure for total EU production of organic broilers exists. In general terms AVEC is supportive of exempting Member States from reporting when the national production is below 2 % of the EU production for species of poultry meat. Should the proposal go through it is of paramount importance that price information is also collected from poultry meat imported from third countries.
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Response to Evaluation of the EU Animal Welfare Strategy (2012-2015)

12 Jun 2019

The Association of Poultry Processors and Poultry Trade in the EU countries (AVEC), the European Live Poultry and Hatching Egg Association (ELPHA) and the European Poultry Breeders Association (EPB) thanks the European Commission for the opportunity to comment on this consultation on evaluation of the 2012-15 EU Strategy for Protection and Welfare of Animals. AVEC, ELPHA and EPB expects to be engaged in the evaluation process via surveys, interviews and focus groups like we also expect to take part in a stakeholder conference/ workshop/ seminar which we find will be a very important part of the evaluation process. AVEC, ELPHA and EPB finds that the suggested evaluation criteria: Relevance, Coherence, Effectiveness, Efficiency and EU added value are the right criteria. Under EU added value it should be considered if unfair competition from third countries leads to an uneven playing field, and if controls performed at the EU borders on imported meat from third countries is efficient in making sure that these imports comply with EU legislation on animal welfare.
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Response to The Information Management System for Official Controls regulation (IMSOC)

12 Jun 2019

The Association of Poultry Processors and Poultry Trade in the EU countries (AVEC) thanks the European Commission for the opportunity to comment on this consultation on the Information management system for official controls Regulation (IMSOC). AVEC welcomes that IMSOC provides a common computerised tool (iRASFF) for the exchange of information and the establishment of common rules for the contact points for the RASFF, AAC and food fraud networks. Regarding Article 9 Conditions for the granting of partial access to the IMSOC to third countries and international organisations – AVEC finds that it is very important that the EU has similar access to identical information from third countries, to grant access to EU data.
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Meeting with Anne Bucher (Director-General Health and Food Safety)

15 May 2019 · safety of imported foods, Ukraine (EU Audit, Animal Health), Brazil (flesh scandal)

Meeting with Vytenis Andriukaitis (Commissioner) and

26 Nov 2018 · Animal welfare, antimicrobial use, and the environmental impact of industrial broiler farming

Response to Establishing specific rules for official controls on meat & live bivalve mollusc production and relaying area

25 Oct 2018

AVEC acknowledges the considerable work done by Member States and Commission’ Services. However, we believe caution must be applied to the following point: DELEGATED ACTS: Article 7 – Criteria and conditions for the performance of post-mortem inspections and auditing activities under the responsibility of the official veterinarian, as provided for in Article 18(7)(e) and (i) of Regulation (EU) 2017/625 (d) the presence of the official veterinarian in the establishment is based on a risk analysis; AVEC asks for allowing the involvement of trained slaughterhouse staff under the responsibility of the official veterinarian, for ante and post-mortem inspections, in the delegated acts. Under certain conditions to respect: - Establishment/transmission to the official veterinarian in case of abnormalities observed during slaughter; - Unannounced inspections carried out on-site by the official veterinarian, based on a risk analysis; - Mandatory training of the staff responsible of ante and post-mortem inspection tasks; - Monitoring of microbiological analyzes/year, on carcasses and cuts, by the slaughterhouse.
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Response to Practical arrangements for official controls of food of animal origin

25 Oct 2018

AVEC acknowledges the considerable work done by Member States and Commission’ Services. We welcome the wording of Article 25 - Practical arrangements for post-mortem inspection of poultry. However, we believe caution must be applied to the following point: IMPLEMENTING ACTS: Article 46.1. - Suggested measures in case of non-compliance with requirements on good hygiene practices. AVEC suggests the deletion of the wording “including a reduction in the speed of slaughter” in article Article 46.1. There is evidence from Manufacturers and slaughterhouse operators that slowing down the speed of the slaughter line is not an effective corrective action to improve the hygiene status of carcasses; The poultry slaughterhouses have a fully automatic slaughter process, and the slaughtering machines function optimally at a certain line speed. The important matters for the hygiene status of the carcasses is whether the equipment is set up correctly for the size of the birds and whether all the equipment has the capacity for the chosen slaughter speed. The volumes that are to be slaughtered is decided a year in front – so lowering the slaughter speed would disturb the logistics and will hence lead to unaccepted animal welfare and in worst case also suboptimal quality and food safety. Besides that, lowering the line speed will also have negative consequences for quality because lowering the line speed will lead for example to a too long scalding and plucking time.
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Response to Evaluation of mandatory country of origin labelling for certain meats

12 Oct 2018

AVEC is supportive of this legislation and believes that the consumer has the right to know the origin of the meat. In relation to that, EU poultry meat producers believe that consumers should have better access to information about the origin of meat consumed in food services/mass catering as well as processed meat and meat used as an ingredient, especially when meat is imported from third countries. EU producers have to comply with very stringent EU rules, whereas imports from third countries may not be fully compliant with these same standards all along the food chain. Therefore, although EU producers recognise the complexity of such labelling, AVEC is advocating the mandatory labelling of all products containing poultry meat with the mention “EU” or “non EU”, along with the name of the country where the meat comes from outside the EU.
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Response to Certain methods for Salmonella testing and sampling in poultry

16 Aug 2018

AVEC generally welcomes the draft amending Regulation and the new alternative sampling methods. Nonetheless, we are satisfied with the implementation of the current Legislation and sampling methods. Namely, we would like to continue to use sampling socks in poultry houses with birds on the floor since it is more practical than using the cotton swabs and it is the most sensitive method for sampling flocks to detect Salmonella in those housing systems.
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Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan), Tom Tynan (Cabinet of Commissioner Phil Hogan)

10 Jan 2018 · Alignment of secondary legislation related to trade

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan), Tom Tynan (Cabinet of Commissioner Phil Hogan)

10 Jan 2018 · Business discussion

Response to Commission Implementing Regulation on special guarantees Salmonella broiler meat Denmark

27 Jul 2017

Letter with feed back on Consultation on the European Commission's proposal to extend the special guarantees for Salmonella spp. laid down in Regulation (EC) No 853/2004 of the European Parliament and of the Council on chicken meat destined for Denmark attached.
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Response to Commission Regulation laying down a Campylobacter process hygiene criterion

10 Mar 2017

a.v.e.c. generally welcomes the Commission decision to undertake a step by step approach making the process hygiene criteria gradually stricter in time. Moreover we strongly support the EC proposal to set a whole chain approach in this field where all stakeholders share the responsibility. Nevertheless a.v.e.c. would like to provide its comment on the following points: At farm level: alternative control measures should be considered based on the feedback from meat inspection. Corrective measures: Since it is widely known that it is difficult to reduce (even to influence) campylobacter numbers on chicken neck skin by improving only hygiene a.v.e.c. is interested to learn which corrective measures in case of non-compliance the Commission is considering effective. Concerning the tolerance and target setting – due to seasonality the EC sampling approach would lead to possible recurrent non compliances during the summer. Therefore a.v.e.c. is very much supporting a sample size of 5 which means that for each sample session of one week the (non)compliance will be determined, which in case of non-compliance will give a new opportunity to be compliant again in the next sampling and testing session. In addition concerning the temperature samples shall be transported to the laboratory (1-8°) we advise to consider a range between 0-4 degrees to have more reliable results. a.v.e.c. recommends waiting for the results of the testing implemented in the first period of at least 24 months and only after an evaluation of those results setting the final target. This knowledge and better insight on potential successful interventions shall be considered as baseline to set any stricter future target. National competence: the poultry industry is concerned regarding the implementation of recital 10 of EC Regulation 2073/2005 and in particular the interpretation of wording as “flexibility to apply a stricter process hygiene criterion” and “equivalency” might have in different member states, nonetheless we are confident that the European Commission and the member states will ensure a fair internal market avoiding creating an unbalanced level playing field. a.v.e.c. recommends: Sector update and research - considering the study recently launched by national authorities (ANSES, FR) we encourage the Commission to request EFSA to update the available data on campylobacter prevalence at European level and to provide an inventory of the tools available to tackle campylobacter. Scientific Conference - the European Commission in cooperation with a Council Presidency may organize a seminar in Brussels to present the state of the art on campylobacter and possibly a compared study on all countries using the same sampling method. The Seminar may give the opportunity to effectively exchange among different stakeholders (industries, institutions and researchers) with the aim to provide a direction for next steps in research. Consumer education - the European Commission may continue to invest in informing consumers on this topic and how to handle it. Decontamination - a.v.e.c. strongly believes that the image of poultry meat will be severely damaged with consumers if the industries are force to decontaminate poultry meat with chemicals. We thank you for considering our comments.
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Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development) and EuroCommerce and

20 Feb 2017 · Exchange of view in relation to Avian Flu

Meeting with Phil Hogan (Commissioner)

30 Sept 2016 · Address General Assembly

Meeting with Jean-Luc Demarty (Director-General Trade) and BREIZ EUROPE

8 Jun 2016 · Global situation in poultry trade

Meeting with Arunas Ribokas (Cabinet of Commissioner Vytenis Andriukaitis), Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and BREIZ EUROPE

8 Jun 2016 · Deboned meat products, campylobacter bacteria

Meeting with Arunas Ribokas (Cabinet of Commissioner Vytenis Andriukaitis), Arunas Vinciunas (Cabinet of Commissioner Vytenis Andriukaitis)

29 May 2015 · Food regulation

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström)

30 Apr 2015 · Sanitary and Phitosanitary issues in Trade negotiations

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan), Peter Power (Cabinet of Commissioner Phil Hogan), Tom Tynan (Cabinet of Commissioner Phil Hogan)

30 Apr 2015 · Challenges for the poultry meat industry