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CAOBISCO

CAOBISCO

CAOBISCO represents the European chocolate, biscuit, and confectionery industry.

Lobbying Activity

Meeting with Norbert Lins (Member of the European Parliament)

27 Jan 2026 · access to raw materials // diligence legislation and its implications // regulatory requirements that may hinder innovation and competitiveness

CAOBISCO urges EU to adopt value-based origin rules

1 Dec 2025
Topic — Evaluation of EU rules determining the nationality of imported products for trade policy.
Message — The industry calls for a return to simple, value-based rules of origin. They also propose adopting the change of tariff heading principle to recognize when a product is substantially transformed within Europe.12
Why — This would lower administrative burdens and restore access to trade agreement benefits.34
Impact — Manufacturers in countries with lower standards lose the advantage they gain from current rules.5
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CAOBISCO calls for harmonised rules in Circular Economy Act

6 Nov 2025
Topic — This consultation gathers evidence for legislation on sustainable production and circular business models.
Message — The association recommends aligning extended producer responsibility frameworks under a single coherent approach. They urge delaying recyclability declarations until 2030 to ensure legal certainty for manufacturers. Finally, they advocate for a central digital portal to streamline reporting across the EU.123
Why — Streamlined rules would reduce administrative costs and prevent double charging for packaging waste.45
Impact — National governments would lose autonomy over local waste fee structures and reporting requirements.6
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Meeting with Pascal Arimont (Member of the European Parliament)

4 Nov 2025 · Commission's proposal amending the EUDR

Meeting with Stefan Köhler (Member of the European Parliament)

3 Nov 2025 · Politischer Austausch zur EUDR

Meeting with Peter Liese (Member of the European Parliament) and Anew Climate

30 Oct 2025 · Austausch

Meeting with Yannis Maniatis (Member of the European Parliament)

3 Oct 2025 · Introductory Meeting

Meeting with Alexandra Nikolakopoulou (Head of Unit Health and Food Safety), Sabine Pelsser (Head of Unit Health and Food Safety) and

16 Sept 2025 · Specific conditions for the use of sweeteners in the food additive legislation, in particular, the requirement to replace sugars for the production of energy-reduced food

Meeting with Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič)

6 May 2025 · Chocolate, Biscuit and Confectionery Industries of Europe

Meeting with Antonella Rossetti (Cabinet of Commissioner Christophe Hansen)

22 Apr 2025 · Exchange of views on topics relevant for CAOBISCO: trade, deforestation and the role of food in the Vision for agriculture and Food, notably ultra processed food.

Meeting with Paolo Garzotti (Acting Director Trade)

27 Mar 2025 · Exchange of views about the Chocolate, Biscuit, and Confectionery Industries

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

10 Mar 2025 · Omnibus

CAOBISCO urges harmonised labelling to stop single market fragmentation

31 Jan 2025
Topic — The consultation addresses the further development of the European single market strategy.
Message — The association calls for uniform labelling standards for nutrition and recycling across Europe. They want the Commission to stop countries from creating conflicting national regulations.12
Why — Uniform rules would reduce costs by removing the need for country-specific packaging.34
Impact — Member states would lose the power to implement specific national health and environmental policies.56
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Response to Restrictions on bisphenol A (BPA) and other bisphenols in food contact materials

6 Mar 2024

CAOBISCO would like to thank the European Commission for the opportunity to contribute to the ongoing discussion on the regulatory measure on Bisphenol A (BPA) in addition to our input already made available to you 15th of September 2023. Based on the details provided at that time, we must reject the implementation of the current draft law as completely unrealistic in technical, practical and administrative terms. Safety of consumers is the fundamental objective of our business activities and we share the view that it is necessary to reduce the exposure of BPA to humans to a minimum. The levels of BPA, which can be considered unproblematic according to EFSA's worst-case assessment, can hardly be validly quantified in chocolate by any European laboratory. For this reason, we have chosen the well-established migration modeling approach to simulate the theoretically possible transfer of BPA from our moulds into chocolate. Two scenarios were chosen for the migration modeling performed by the company saferithm (Dr. Rainer Brandsch): worst-case, reflecting a potential failure of technical control systems, onset of sensory abnormality: chocolate in contact with mould for 1 hour at 40 °C: highest migration of BPA into chocolate at a level of ~ 1/3 of TDI established by EFSA industrial chocolate production, keeping in mind that cooling starts quickly after filling of moulds: chocolate in contact with mould for 30 min at 30 °C: highest migration of BPA into chocolate at a level of ~ 1/7 of TDI established by EFSA All details of the migration modeling, the calculation in relation to the TDI and cooling curves in chocolate production can be found in the appendix. In summary, it can be concluded that BPA from virgin polycarbonate moulds can only transfer to chocolate in quantities significantly below the TDI set by EFSA. The migration potential decreases steadily with further cycles (tens of thousands in the life cycle of a mould!). The calculation for industrial chocolate production thereby already greatly overestimates the transfer of BPA. The temperature of the chocolate drops quickly from approx. 30 °C immediately after filling and therefore only prevails for a short time within the dwell time of 30-60 minutes in the mould. The transfer of BPA from our moulds into chocolate must therefore be regarded as negligible and a ban of BPA in polycarbonate-based moulds would have no safety gain whatsoever on the population´s exposure to BPA. As it is absolutely critical to the evaluation, we must reiterate our concerns about alternative materials regarding especially physical food safety (plastic parts in chocolate). The economic and sustainability impact due to the impossibility to partially substitute moulds in chocolate machines (for technical reasons, a set of moulds must be completely replaced when changing materials) as well as the discrimination of the European chocolate production against the non-EU competition without serving the actual goal of the regulation in any way, makes a ban on BPA in chocolate moulds appear absolutely questionable and disproportionate. Finally, we would like to share an excerpt of a fundamental study carried out by the renowned Prof. Dr. Fernengel (see end of the appendix). He has compared other potentially usable thermoplastics and comes to the conclusion that there is no alternative to polycarbonate for chocolate moulds. We therefore ask the European Commission to consider an exception in the BPA regulation for polycarbonate-based moulds based on their criticality in the very specialized chocolate production and the negligible risk of BPA transfer far below the EFSA TDI in this niche application. In analogy to disodium salt of BPA to manufacture plastic polysulfone resins and BADGE for heavy-duty varnishes and coatings, we suggest to specifically authorize BPA as monomer for polycarbonate-based moulds by way of amendment to Regulation (EU) No 10/2011.
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CAOBISCO urges border control exemption for non-sugar confectionery

15 Mar 2023
Topic — The consultation reviews low-risk food products exempted from mandatory border control checks.
Message — CAOBISCO requests that non-sugar confectionery be exempted from official controls at border control posts. They believe these shelf-stable products present a low risk to human health.12
Why — Exemption from border controls would lower administrative costs and simplify trade processes.3
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Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur)

19 Jan 2023 · Forced Labour ban

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and Bundesverband der Deutschen Süßwarenindustrie

14 Nov 2022 · Corporate Sustainability Due Diligence

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Nestlé S.A.

10 Nov 2022 · due diligence, sustainable cocoa

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and

7 Nov 2022 · Corporate Sustainability Due Diligence

Response to Setting of nutrient profiles

2 Feb 2021

CAOBISCO, the association representing Chocolate, Biscuits and Confectionery of Europe, welcomes the opportunity to provide comments on the European Commission’s Inception Impact Assessment on the revision of the Food Information to Consumers Regulation (enclosed) and remains at the Commission’s disposal to provide any further information.
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CAOBISCO urges full border control exemptions for chocolate products

1 Feb 2021
Topic — Updated list of composite food products exempt from official checks at border posts.
Message — The association requests exempting all chocolate products from border checks without further distinction. They claim health certificates are not useful for processed products like biscuits.12
Why — This change would reduce administrative burdens and simplify trade for chocolate and confectionery manufacturers.3
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Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen) and European Cocoa Association

10 Nov 2020 · cocoa sustainability

Response to Farm to Fork Strategy

16 Mar 2020

CAOBISCO, the European chocolate, biscuits and confectionery industries strongly supports the green ambition pledged by the European Commission. Indeed, sustainable food production and consumption are indispensable conditions of making Europe the first climate-neutral continent. Food is essential for life, society, citizens and the economy; it should therefore be prioritised as a strategic sector for the European Union. Building on the high reputation and excellence of Europe’s food as safe, nutritious, culturally-diverse and of high quality, CAOBISCO recognises the need – and fully supports the EU’s commitment – to strengthen our global leadership in sustainability. CAOBISCO is fully committed to play a constructive and pro-active role in driving the transition towards more sustainable food systems. This can only be achieved through supportive policies which is truly holistic, co-ordinated, harmonised, co-owned, inclusive and science based. The policy must be continuously evaluated against its objectives and should include incentives for both consumers and businesses. For it to be successful, it must facilitate collaboration, partnership and open, forward-looking dialogue about opportunities, challenges and trade-offs, recognise Europe’s strength of diversity, ensure predictability, and enable the long-term economic viability and competitiveness of all players in the food chain. Work is not starting from scratch. With a central role between ‘Farm’ and ‘Fork’, CAOBISCO members are, amongst others, heavily investing in improving the environmental and nutritional footprint of their products, improving the circularity of products and packaging, promoting more sustainable consumption behaviours, minimising food losses, while ensuring safe, affordable, convenient and enjoyable food. Increased support for SMEs, a stronger Single Market for food and drinks, decreasing red tape and administrative burden through better regulation, research and innovation, and sustainable finance will be critical enablers for our sector to scale up, accelerate and deliver on tangible actions. The Farm to Fork Strategy presents a unique opportunity to support these efforts and minimise any barriers that food chain actors may face in contributing to the overall objective of more sustainable food systems.
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Response to Minimising the risk of deforestation and forest degradation associated with products placed on the EU market

3 Mar 2020

CAOBISCO members are committed to ensuring that their products are manufactured responsibly and to the highest standards, minimising environmental impact and respecting the human rights of those in their value chains. Many of CAOBISCO members have private initiatives that empower farmers and their communities to improve their income, become more productive and climate-resilient, protect the environment, combat deforestation, and respect human rights in the supply chain. These initiatives need to be accompanied by due diligence systems in order to identify and address social and environmental risks and impacts, seeking greater transparency along the supply chain. CAOBISCO members support an EU-wide due diligence approach, aligned with the UN Guiding Principles on Business and Human Rights, and with the OECD-FAO Guidance for Responsible Agricultural Supply Chains. Members support a comprehensive EU strategy that creates the enabling environment required to make progress. The EU must engage in dialogue with the respective origin countries to create the right framework of agreement needed to drive change. CAOBISCO believes due diligence is a shared responsibility for all supply chain actors, who must act collectively to achieve a sustainable industry from “farm to fork” and to address systemic environmental and human rights issues.
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CAOBISCO rejects pesticide rules for food chlorate residue limits

14 Feb 2019
Topic — The European Commission is consulting on maximum residue levels for chlorate in food.
Message — CAOBISCO sees no legal basis for regulating chlorate as a pesticide residue. Its presence comes from multiple sources like water and disinfection. They urge delaying discussions until the Drinking Water Directive review is finished.12
Why — Realistic limits would prevent unavoidable non-compliances and protect the existence of many food producers.34
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Response to Negotiation mandate for revising an agreement with the US on the import of hormone-free beef

24 Apr 2018

CAOBISCO, the Association of the Chocolate, Biscuits and Confectionery Industries of Europe, welcomes the publication of the European Commission Roadmap “Negotiation mandate for revising an agreement with the US on the import of hormone-free beef”. We would like to strongly support the EU to engage with the US in a constructive dialogue on this topic and support the Commission to find a mutually satisfactory solution with its US counterparts that is in line with WTO rules, and that could facilitate the eventual termination of this long-standing dispute. We support our umbrella organisation FoodDrinkEurope in its declaration that a situation whereby the US would withdraw from the current “Memorandum of Understanding” (MoU) and could re-impose trade sanctions on EU exports to the US must be avoided, as this would run the risk of disrupting the well-established EU-US trade relations. The US is for CAOBISCO its largest export market and a very important supplier of agri-food products in raw materials, ingredients and finished products. In 2016, CAOBISCO exports to the US represented a value of around €1.3 billion. Thank you in advance for your consideration and efforts to maintain stable transatlantic trade relations.
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Response to Commission Implementing Regulation on the provision of voluntary indication of origin or place of provenance of foods

26 Jan 2018

CAOBISCO, the European Association of Chocolate, Biscuit and Confectionery Industries of Europe, welcomes the opportunity to comment on the draft Commission Implementing Regulation on the provision of voluntary indication of origin or place of provenance of food (‘voluntary origin labelling’). Please see attached a complete document with our comments. Thank you in advance for considering them, and if you need any further information we remain at your entire disposal. Kind regards, Alice Costa Regulatory & Scientific Affairs Senior Manager
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CAOBISCO urges realistic acrylamide benchmarks for European bakery industry

6 Jul 2017
Topic — EU regulation setting mitigation measures and benchmarks to reduce acrylamide in food.
Message — The association requests more representative benchmarks that reflect product diversity and geographic variations. They urge officials to prioritize voluntary mitigation measures before introducing mandatory maximum limits.12
Why — Adjusting these standards would help manufacturers avoid compliance failures for diverse regional products.3
Impact — Consumers could face slower safety improvements if mandatory maximum levels are postponed.4
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CAOBISCO urges three-year transition for sugar-free bakery sweeteners

23 Jun 2017
Topic — Proposed update to European Union regulations concerning sweeteners in fine bakery products.
Message — CAOBISCO requests a suitable transitional period to keep no-added-sugar products on the market. They propose a three-year window following the entry into force of the regulation.12
Why — This prevents immediate product withdrawals and allows the industry to submit new dossiers.3
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