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Bundesverband der obst-, gemüse- und kartoffelverarbeitenden Industrie e.V.

BOGK

Dem Verband obliegt die Wahrung und Förderung der ideellen, wirtschaftlichen und fachlichen Interessen seiner Mitglieder.

Lobbying Activity

Meeting with Sebastian Everding (Member of the European Parliament)

6 Nov 2024 · Verarbeitetes Obst und Gemüse

Meeting with Norbert Lins (Member of the European Parliament) and Bundesverband der Deutschen Süßwarenindustrie

13 Feb 2024 · Strukturelles Zuckerdefizit der EU führt zu höherem Bedarf an Einfuhren - Diversifizierung der Bezugsquellen auch bei Zucker erforderlich

Meeting with Norbert Lins (Member of the European Parliament)

25 Oct 2023 · Breakfast Directive

Meeting with Norbert Lins (Member of the European Parliament)

25 Oct 2023 · Konfitürenrichtlinie, Verpackung und Verpackungsabfälle

Response to Sustainable use of pesticides – revision of the EU rules

18 Jul 2022

The Federal Association of the Fruit, Vegetable and Potato Processing Industry - BOGK - represents the interests of numerous companies as the sixth largest trade association in the field of food processing in Germany. First of all, we would like to thank you for the opportunity to comment on the planned draft regulation on the revision of the directive on the sustainable use of plant protection products as part of the EU stakeholder consultation. Overall, we view the implementation of the Green Deal and Farm to Fork strategy intended by the EU Commission very critically and with great concern. It is clear, that consumer health is the top priority when it comes to future sustainable use of plant protection products. Therefore, the principle of sustainable plant protection is already strictly observed by all companies in the fruit, vegetable and potato processing industry. We would like to point out that the European Union already has the strictest regulatory measures in the world for the approval, placing on the market and use of chemical plant protection products. A further tightening and concrete implementation of the existing plans would endanger the security of the supply of raw materials to industry due to the planned measures. This in turn would lead to less food being available for the people. In this context, we would like to refer once again to the current study by the University of Wageningen on the possible loss of yields or crop collapses. Among other things, it was also determined here, that the prices for plant production and their margins, which are exported from the EU, would change significantly. A possible slump in the harvest of up to 30 % seems particularly alarming against the background of the Russia-Ukraine war that is currently taking place. This is considered an example of the dramatically deteriorating nutritional situation of the world population with staple foods or foods, especially wheat. A lack of food supplies for the population would lead to an increased need for agricultural land if demand remained the same or increased significantly. This in turn would have to be offset by more imports (keyword: costs and carbon footprint). In addition, there would be a relocation of agricultural production to other regions of the world, which would have unintended consequences. In addition, a food offer based on regionality would no longer be possible. In addition, a blanket reduction of crop protection products by 50 % is not expedient in terms of integrated and sustainable plant protection. A differentiated view according to crop types, groups of active ingredients, possible alternatives, etc. is urgently recommended here. In terms of sustainable resistance management, it is imperative to have different active ingredients available against a pest. Even in sensitive areas, intelligent solutions between nature conservation and agriculture are more effective. This certainly requires more work than blanket bans, but seems advisable given the need to safeguard food production. The creation of alternatives within the planned time frame is also difficult to imagine. The regulatory hurdles for new active ingredients in the EU are now so high that e. g. in the past 10 years, only one new substance has been approved for an average of four substances that had to be withdrawn from the market. BOGK would therefore like to ask the EU Commission to counteract this development more intensively and to take the aspects outlined here into account when implementing sustainable plant protection in a regulation.
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