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Comité du commerce des céréales, aliments du bétail, oléagineux, huile d'olive, huiles et graisses et agrofournitures de l'U.E.

COCERAL

Coceral represents European grain, feed, rice, olive oil and agro-supply trade associations.

Lobbying Activity

Grain trade group COCERAL urges uniform food safety enforcement

14 Oct 2025
Topic — This consultation aims to simplify and clarify EU food and feed safety requirements.
Message — COCERAL requests harmonized enforcement of safety rules and longer transition periods for pesticide residue limits. They advocate for science-based regulations and ensuring that alternatives are available before banning substances.123
Why — Harmonized rules would reduce trade disruptions and lower compliance costs for grain traders.45
Impact — Environmental advocates lose if trade concerns prevent bans on hazardous imported pesticide residues.6
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Coceral demands clearer rules for pesticide residue sampling

28 Jul 2025
Topic — The initiative updates EU procedures for sampling and analyzing pesticide residues in food.
Message — Coceral requests the regulation applies only to official controls, not private testing. They want results delivered within a reasonable time. They also seek to remove inconsistent measurement uncertainty rules.123
Why — Uniform enforcement would prevent unfair treatment and provide greater legal certainty for operators.4
Impact — Food safety agencies would lose flexibility to apply stricter standards for high-risk residues.5
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Meeting with Johannes Van Den Bossche (Cabinet of Commissioner Christophe Hansen) and Fédération Européenne des Fabricants d'Aliments Composés and

15 Jul 2025 · Risk of supply shortages for critical EU Agrifood- & feed-imports linked to geopolitical turbulence and EUDR implementation

Meeting with Tiemo Wölken (Member of the European Parliament)

28 Apr 2025 · New Genomic Technics (Staff level

Meeting with Irene Sacristan Sanchez (Head of Unit Health and Food Safety) and Fédération Européenne des Fabricants d'Aliments Composés and The EU Vegetable Oil and Proteinmeal Industry

28 Apr 2025 · Commission proposal on plants obtained by certain new genomic techniques (NGT proposal)

Meeting with Fabien Santini (Head of Unit Agriculture and Rural Development), Koen Dillen (Head of Unit Agriculture and Rural Development)

9 Apr 2025 · CMO amendments

Meeting with Pierre Bascou (Deputy Director-General Agriculture and Rural Development) and Comité Européen des Entreprises Vins and

17 Mar 2025 · Exchange of views on the Vision for the Future of Agriculture and agri-food trade.

Meeting with Claire Bury (Deputy Director-General Health and Food Safety)

13 Mar 2025 · Vision for the future of agriculture

COCERAL warns contract revision clause threatens grain forward markets

28 Feb 2025
Topic — EU initiative to strengthen farmers' positions through changes to agricultural market regulations.
Message — COCERAL requests removing the contract revision clause for grains to protect forward trading. They also propose allowing contracts to be finalized after delivery and extending exemptions to medium-sized firms.123
Why — Removing the clause prevents traders from incurring losses on existing commercial commitments.4
Impact — Logistics firms and consumers could suffer from supply disruptions and higher food prices.5
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COCERAL urges excluding crops from expanded biofuel traceability database

6 Nov 2024
Topic — EU consultation on extending biofuel traceability to the point of raw material collection.
Message — COCERAL calls for excluding crops where traceability is already sufficient and requests a transitional implementation period. They argue the current proposal imposes disproportionate requirements on upstream operators.12
Why — Traders would avoid significant human resource requirements and high associated compliance costs.3
Impact — Farmers and small traders suffer from reduced market access and high administrative burdens.4
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Cereal trade body COCERAL urges duty-free imports from Ukraine

30 Sept 2024
Topic — This consultation addresses the reciprocal liberalisation of customs duties under the EU-Ukraine Association Agreement.
Message — COCERAL requests that tariff-rate quotas for cereals established under Annex I-A should be removed. They argue the safeguard measures procedure should be maintained as per the 2014 agreement. They also state the Commission must seek the end of national import bans.123
Why — This would allow cereals from Ukraine to be admitted for importation without customs duties.4
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Response to Evaluation and revision of the Weights and Dimensions Directive

28 Aug 2024

Please find attached feedback on Directive on Weights and Dimensions of commercial vehicles on behalf of COCERAL.
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Response to Changes to rules for some rice quotas, templates for certificates and to the quantity of a quota to export cheese

8 Jul 2024

COCERAL and its members would like to share its feedback on the Commission Implementing Regulation proposal amending Implementing Regulation (EU) 2020/761 with regard to the application of the reference quantity requirement for certain tariff quotas for rice. The draft regulation suggests that to ensure effective management of the selected tariff quotas, a reference quantity, as outlined in Art. 9 of Commission Delegated Regulation (EU) 2020/760, should be applied. COCERAL considers that this new measure would have a significant impact on the functioning of the rice sector. In order for the operators to prepare and build a proper foundation, the implementation of this draft regulation should be two years after entry into force. Furthermore, to ensure a level-playing field between operators, the new system should consider all the volumes imported by one operator, in- and out-of-quota when determining the reference quantities for the quotas. As such, we suggest applying a derogation from paragraph 2 and 3 in Art. 9 of Commission Delegated Regulation (EU) 2020/760 for the considered TRQs. Thank you for your consideration on this matter.
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Meeting with Magda Kopczynska (Director-General Mobility and Transport)

28 May 2024 · EU grain transport and related logistical issues

Meeting with Miriam Garcia Ferrer (Cabinet of Executive Vice-President Valdis Dombrovskis)

21 May 2024 · European Union Deforestation Regulation, Trade

COCERAL demands monitoring exemptions for grain storage in BPA ban

8 Mar 2024
Topic — This consultation addresses a proposed ban on bisphenol A in materials contacting food.
Message — The organization seeks clarification on heavy-duty coatings and exemptions for large storage units like silos and barges. They also request the right to maintain and repair existing infrastructure designed for long-term use.123
Why — Exemptions would prevent high monitoring costs and the expensive replacement of aging storage infrastructure.45
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Meeting with Florika Fink-Hooijer (Director-General Environment) and European Liaison Committee for Agriculture and agri-food trade

6 Mar 2024 · Short Introduction CELCAA and Policy Recommendations Strategic Dialogue on the future of Agriculture

Meeting with Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius) and European farmers and

9 Feb 2024 · Deforestation issues

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

8 Feb 2024 · Geopolitical situation in the Red Sea and its impact on the EU Market

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

8 Feb 2024 · The situation in the Red Sea

Response to Setting and reviewing maximum levels for certain undesirable substances in feed

2 Feb 2024

Dear sirs/madams, I am writing you on behalf of COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply. COCERAL welcomes the intention of the EU Commission to ensure a higher level of animal health protection, by reviewing the Annexes I and II to Directive 2002/32/EC of the European Parliament and of the Council as regards maximum levels and action thresholds for arsenic, cadmium, lead, nickel, rye ergot, delta-9-tetrahydrocannabinol, endosulfan, heptachlor, hexachlorbenzene, hexachlorohexane, dioxins and PCBs, Datura sp., certain coccidiostats and histomonostats and p-phenetidine in animal feed. COCERAL also welcomes the opportunity for business association to be consulted through the Have your say initiative on this legislative proposal, and with regard to each specific undesirable substance (of relevance for our members), would like to express its comments, as described in our position paper attached. Kind regards Gianluca Nurra COCERAL's Scientific and Technical Advisor
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Cereal traders urge EU to prevent NGT trade disruptions

3 Nov 2023
Topic — Legislation proposing a new framework for plants produced using specific genomic techniques.
Message — The organization argues Category 1 NGTs should be treated as conventional plants. They demand harmonized rules to prevent member states from creating hidden cultivation bans. Traders also require flexibility to manage imports from countries with different NGT regulations.123
Why — These changes would ensure legal certainty and maintain stable supply chains for traders.45
Impact — Organic producers lose the ability to enforce strict regional bans on NGT cultivation.6
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Meeting with Christophe Clergeau (Member of the European Parliament, Shadow rapporteur) and European farmers and

26 Oct 2023 · Table ronde avec les représentants de l'industrie sur la proposition de règlement sur les nouveaux OGM

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

7 Sept 2023 · Exchange of views on the situation of exports of grain from Ukraine through Solidarity Lanes

Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

7 Sept 2023 · information from COCERAL on grain export from Ukraine related issues

Meeting with Andreas Schneider (Cabinet of Commissioner Janusz Wojciechowski)

7 Jun 2023 · COCERAL’s Annual General meeting. Forum for exchange from a variety of perspectives.

Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

24 Apr 2023 · consequences of import restrictions with respect to grains on traders

Grain trade warns against advisory service separation in pesticide regulation

15 Sept 2022
Topic — New EU regulation on sustainable use of plant protection products and pesticide reduction.
Message — The organizations request flexibility in implementation of reduction targets, accounting for climate change and invasive species. They oppose mandatory separation of advisory services from pesticide dealers, arguing it would create inefficiency and potentially increase pesticide use. They support financing the transition through CAP eco-schemes and want crop-specific IPM rules that allow local adaptation.1234
Why — This would preserve their current business model of providing advice while selling pesticides to farmers.56
Impact — Environmental groups and public health advocates lose stricter controls on conflicts of interest in pesticide advice.7
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Meeting with Janusz Wojciechowski (Commissioner) and Archer Daniels Midland and BayWa Aktiengesellschaft

19 Jul 2022 · Facilitation of export of grains from Ukraine

Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

7 Jul 2022 · Exchange of views about food security

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

16 Mar 2022

COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply, welcomes the opportunity to share some elements in response to the Commission’s call for evidence on the application of health and environmental standards to imports of agricultural and food products. Please find them in our attached paper.
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Response to Maximum dimensions and weights in national and international traffic for certain road vehicles circulating within Union

1 Feb 2022

COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply would like to take the opportunity of this consultation to comment on the Directive 96/53/EC laying down for certain road vehicles circulating within the Union the maximum authorised dimensions in national and international traffic and the maximum authorised weights in international traffic. While we understand that this consultation deals with the codification of this directive, we would like to highlight an issue regarding cross-border transport. Some EU countries allow the circulation of 44 tonnes lorries on their internal roads, but the directive prohibits the border crossing of these lorries by limiting the maximum authorised weight in international traffic to 40 tonnes. This difference appears to be inconsistent to the idea of free movement of goods within the EU. As an example, we can focus on the trade of grains and raw materials intended for agriculture between France and the Benelux. Given the geographical proximity between the north of France and the Benelux, a substantial part of these exchanges is carried out by road. The limitation to 40 tonnes generates an increase in the number of trucks on the roads, which brings additional carbon emissions and pollution, as well as an increased risk linked to road traffic. One of the objectives of the EU Green Deal is to reduce the greenhouse gas emissions and to be the first climate-neutral continent by 2050. As such, the Commission is proposing a series of ambitious changes as regards to transport. It is indeed essential to relaunch and increase the use of rail and inland waterway transport for the transport of agri-bulk commodities. However, this can only be done through the improvement of land transport complementary with rail and river transport modes. Thus, it is essential to optimise road transport to its maximum capacity by removing the 40 tonnes limitation to cross-border transport.
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Response to Carbon Border Adjustment Mechanism

17 Nov 2021

Please see COCERAL's feedback in the attached file.
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Response to Sustainable food system – setting up an EU framework

26 Oct 2021

COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply welcomes the Commission’s policy Farm to Fork Strategy aiming towards a more sustainable food production. Representing almost 3,000 companies as part of COCERAL’s national members, our sector collects and trades a substantial volume of agricultural raw materials destined to the supply of the food and feed chains, as well as for technical and energy uses. Thanks to our central position in the EU supply chain, COCERAL and its members balance the different requests of the food, feed and non-food markets, from the farmers, processing industry and the consumers through the retailers’ demands. Our businesses thrive on seamless supply-chains, which need clarity, predictability and clear regulatory regimes in order to avoid disruption. While recognising the importance of transitioning towards a more EU sustainable food system, we call for alignment and coherence of different policies which are part of the Green Deal, with clear goals and measurable objectives over a defined timeline. Please find in the attachment COCERAL’s detailed comments regarding the Inception Impact Assessment.
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Meeting with Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski)

24 Sept 2021 · EU Farm to Fork strategy

Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

27 Jul 2021

COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply welcomes the EU's Green Deal agenda and its objective to achieve carbon neutrality in the EU by 2050. COCERAL through the consultation on detailed rules on voluntary schemes would like to take the opportunity to comment on Annex V of the draft act on the “methodology for determining the emission savings from soil carbon accumulation via improved agricultural management”. Please see our full contribution in the attached document.
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Response to Revision of EU marketing standards for agricultural products

15 Feb 2021

COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply appreciates the opportunity to respond to the Roadmap on the revision of EU marketing standards. The EU marketing standards are part of the Common Organisation of the Markets and apply to both EU and imported products. The objective of these standards are to be compliant with certain product characteristics, classification, production methods, packaging methods as well as labelling/marking requirements. According to the Commission’s evaluation of the marketing standards published in October 2020*, marketing standards “have generally been effective in achieving their intended objectives, without causing significant unintended/unexpected effects” for the sectors covered by these standards. In the case of grains and oilseeds, there are no EU marketing standards in effect. However, historical qualitative requirements are still used as a criterion for eligibility in market mechanisms, such as public intervention and private storage. At international level, CODEX Alimentarius standards exists for most grain and oilseeds products and trading contracts are signed based on the product quality. Through the EU Green Deal and Farm to Fork, the Commission is looking at a revision of marketing standards that could provide for the uptake and supply of sustainable agricultural products. In this Roadmap, the Commission clarifies that other actions are in place to increase sustainability aspects of the food supply chain. It adds that “any revision of marketing standards would have to be done in a way that complements these other actions and focus on the relative strength of what marketing standards can achieve.” Taking into account these comments, COCERAL would object to option 3, 4 and 5 that would include sustainable requirements in the current or potential new marketing standards. Indeed, adding further obligations to operators based on sustainable criterion would put a burden on the competitiveness of the EU agriculture sector. Operators risk missing out on new opportunities in markets, niche and/or where a premium could exist, or in the use of new technologies. The Commission had pointed this out in their 2020 Evaluation of the Marketing Standards, where “[Business associations and individual companies] were slightly less positive in their judgement on the effectiveness of EU marketing standards in increasing the scope for differentiated product valorisation and in accessing new and/or more remunerative marketing channels”. As such, adding new sustainable requirements would further decrease access to these outlets. As a conclusion, COCERAL supports the Commission’s aim in achieving a more sustainable EU food chain. Nevertheless, in this specific case, the priority should be on developing standards at international level. Other actions set out in the EU Farm to Fork would be more efficient in achieving the Commission’s objectives at EU level. COCERAL’s position will be further developed in the public consultation when published. *COMMISSION STAFF WORKING DOCUMENT EVALUATION of marketing standards (contained in the CMO Regulation, the ‘Breakfast Directives’ and CMO secondary legislation), published in October 2020: https://ec.europa.eu/info/sites/info/files/food-farming-fisheries/key_policies/documents/swd2020-230-evaluation-marketing-standards_en.pdf
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Response to Setting of nutrient profiles

3 Feb 2021

COCERAL is the European association representing the trade in cereals, rice, feedstuffs, oilseeds, olive oil, oils and fats and agrosupply. COCERAL thanks the Commission for the opportunity to comment at an early stage on the overall revision of the Food Information to Consumers Regulation, Reg. (EU) 1169/2011. Please find enclosed our contribution.
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Response to Contingency plan for ensuring food supply and food security

12 Jan 2021

The below feedback is a joint response from COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply and UNISTOCK, the European association of professional portside storekeepers for agribulk commodities. COCERAL-UNISTOCK welcomes the Commission’s initiative in developing a Contingency Plan to ensure food supply and food security across the EU in times of crises. Although the food supply was fully ensured in all EU Member States during the COVID-19 pandemic, several issues arose at the outset of the crisis, such as border controls within the Single Market and in ports, as well as limited transport options by trucks and railways within and between different Member States. While these aspects were solved through the EU Green Lanes and the recognition of food and feed as essential goods, it had potential to impair the EU’s agri-food trade. As such, COCERAL-UNISTOCK appreciates the Commission’s objective, within the EU Farm to Fork strategy, to develop guidelines and recommendations in order to have a coordinated approach responding to crisis and avoiding any shortage in the food supply to EU consumers. Coordination is key to ensure food security, which includes animal feed. Countries taking different measures at different times, not always communicating clearly and timely about them, closing their borders, and applying different treatment on the movement of goods creates confusion, delays and above all uncertainty. As such, we consider that the guidelines should include the following considerations: • The food and feed industry must fall under the category of ‘critical or essential’ and hence be subject to exemptions as is the case for other critical industries. This sector must be considered as a priority and given authorisation to circulate. • Transport of critical goods to and from the plants should stay operational. This imposes rules, protocols and safety equipment for the workers operating these transports. • Special port handling measures must be outlined regarding "on-board" crew quarantine to allow unloading of feed and food grain and oilseed/meal shipments. These protocols need to be implemented at harbour level, whether in EU or third countries, in direct discussions with port authorities and exporters/importers organisations. • People working in food and feed industry operations and supply chains face similar childcare challenges and should hence fall under the same treatment as other critical industries notably in countries where schools/childcare have been closed. • The EU must also ensure that the new Contingency Plan will be correctly implemented by all EU Member States and no divergence in the measures occurs. The creation of a permanent forum where the Commission and Member States can exchange on practices is a good step in this direction. In conclusion, while EU feed and food supply responded well to the challenges brought forward by COVID-19, better coordination through this new Contingency Plan will help lift any uncertainty for the operators if a new crisis arises.
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Response to New EU Soil Strategy - healthy soil for a healthy life

10 Dec 2020

COCERAL -the European association representing the agrifood trade of bulk commodities, thanks the Commission for the opportunity provided within this consultation. We praise the efforts of the EU institutions to deliver an overarching strategy on healthy soil and echoing the Farm to Fork ambitions. Such a strategic approach is indeed vital to maintaining sustainable food and feed supply chains, while better protecting the environmental assets and overall landscape of the EU. We recognise that soil is the centrepiece of healthy ecosystems, and for that, there is a clear need to further engage with other EC competent services working on the Farm to Fork on the reduction targets for fertilisers, plant protection products and biodiversity. A joint exercise is needed to tackle an increasingly complex and interconnected policy realm. The promised EU-wide methodology to map, assess and achieve good conditions of ecosystems, which include soils -could indeed be a key starting point. Only departing from reliable data within the available sources and fostering stronger cooperation across reliable entities will allow achieving such a challenging target. In turn, EU institutions need to consider actual risks and trade-offs (risks vs benefits) before delivering reduction targets of agronomical inputs, along with the importance of the protein content for the marketing of the cereals on domestic and export markets. Furthermore, COCERAL is concerned about the impact that land degradation and soil erosion could eventually have on the increasingly interconnected food and feed supply chains and expresses preoccupation for desertification in Southern Europe, often coupled with exogenous pests (e.g., Xylella Fastidiosa). This is even more relevant as soil erosion and degradation could further depress the supply of agricultural outputs in the near future, at a time when the reduction targets on plant protection products and fertilisers will have a concurrent impact. A proper assessment of all the ecosystem services provided by healthy soil, but also by agronomic inputs is therefore needed to avoid a purely ideological approach. In addition, we consider how Member States will have a clear role in addressing soil health, under the CAP reform and National Strategic Plans. This will in turn cover National Action Plans (ex-art. 4 of Reg. 1107/2009) and Integrated Pest Management. Hence, there is a widespread need for proper fine-tuning within and across all the relevant policy frameworks in place: this will deliver harmonisation of the different national soil protection regimes in place, avoiding distortion of the internal market. We are ultimately eager to see the Green Diplomacy of the EU institutions in action, and how the EU can orientate the debate, but at the same time considering the need for compliance with WTO rules. We remain at your disposal for further inputs and support on more specific requests.
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and COMITE EUROPEEN des FABRICANTS de SUCRE and

29 Oct 2020 · EU Biofuels Chain

COCERAL urges realistic pesticide rules to protect agrosupply competitiveness

7 Aug 2020
Topic — The consultation addresses revising EU rules for the sustainable use of pesticides.
Message — COCERAL calls for a stepwise approach that preserves competitiveness. They want harmonized rules across all EU Member States. Pesticide reduction should depend on the availability of biological alternatives.12
Why — A predictable regulatory framework would reduce bureaucratic burdens for agrosupply businesses.3
Impact — Environmental groups lose if pesticide reductions are delayed until biological alternatives are available.4
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Response to Hygiene rules on allergens, food redistribution and food safety culture

6 Aug 2020

COCERAL would like to comment on the Draft Regulation amending the Annexes to Regulation (EC) No 852/2004 of the European Parliament and of the Council on the hygiene of foodstuffs as regards food allergen management, redistribution of food and food safety culture. Regarding the first aspect, food allergen management, COCERAL very much welcomes the Commission approach for the sake of global harmonisation in adopting at least the very same international obligations as of the Codex Alimentarius Commission and reflecting the code of practice on food allergen management for food business operators. COCERAL believes that businesses are already ahead of specific provisions to deliver safe food and feed by implementing HACCP-like processes - in line with their general responsibility to provide safe food and feed. From the text, it is quite clear that there are no new requirements charged onto the operators who already deliver safe food and feed: the practices displayed under the new text are just the routinely ones under the Good Hygiene Practices. We would hence welcome the Commission to better highlight that this is the standard business behavior, as some publics could understand that these are new requirements whilst they are not. From a legal standpoint and for coherence, we, however, welcome the harmonisation with Codex provisions of Annexes I and II of Regulation (EC) No 852/2004 to include allergen-related requirements all along the food and feed supply chain, including mitigation and cleaning measures. With regard to the text of the Annex, COCERAL takes the opportunity to reflect on the new paragraph "5a " and "9" -with the provision to clean or check for the absence of any visible debris..." equipment, conveyances and/or containers used for the harvesting, transport or storage/processing, handling, transport or storage of one of the substances or products causing allergies or intolerances, referred to in Annex II to Regulation (EU) No 1169/2011. While COCERAL is fully supportive of a "farm to fork" overall approach, we acknowledge that complete segregation or control of the raw agri-food materials globally transported is the natural consequence from this assumption- but this is impossible due to the commodity market nature (bulking and adventitious co-mingling being common practices). At the same time, many by-products - despite this adventitious botanical cross-contamination resulting from commodities in principle leading to allergies or intolerances -as recognised under Annex II of the Reg. 1169- after processing are rightly not considered as posing hazards or requiring labelling (i.e., fully refined soybean oil, wheat-based glucose syrups including dextrose…). It is a relevant point for the food commodity market. With regard to " ‘CHAPTER XIa Food Safety Culture", COCERAL welcomes the overall progression in the field of food safety principles, as it comes under Codex Alimentarius specifications (CXC 1-1969). Global harmonisation is key for a level playing field and to develop the same food culture worldwide. At the same time, the points listed are already part of the current business mindset and operations, under the HACCP approach. COCERAL wishes to stress a few points of concern or otherwise, request for clarification:  Food business operators have yet to seize the consequences of the new food safety direction, which for sure is resource-intensive (education and permanent training). The Commission must consider the real costs for the economic players, on an already heavily hit sector in the COVID-19 aftermaths;  COCERAL asks the Commission to make clearer the meaning of "all employees in the business";  COCERAL considers compliance by food business operators as already in place. We ask to add the following point: "4. The above requirements shall be deemed as fulfilled where Food Business Operators can demonstrate certification with a recognised Food Safety System". (Full comments enclosed)
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Response to Trade policy review, including WTO reform initiative

13 Jul 2020

Representing the EU’s agricultural trade, COCERAL supports a fair and competitive EU trade agenda, which, most importantly, should help in ensuring a safe, affordable and high-quality supply of agri-food and feed products to and from the EU. In order to achieve that, the EU agri-food businesses must be provided with a stable and coherent regulatory environment in the areas of food safety and sustainability. Since the EU’s green agenda is guided by the recently published EU Farm to Fork and Biodiversity strategies, it is important for COCERAL members to see a thorough consideration of the trade-related initiatives under these strategies (including their impact) in the Commission’s Communication on the trade policy review. Additionally, a more resilient EU in a post-COVID-19 context should focus on further strengthening the EU food and feed supply chain. Although the food supply was fully ensured in all EU Member States during the pandemic, several issues surged at the outset of the crisis, such as border controls within the Single Market, as well as limited transport options by trucks and railways within and between different Member States. While these aspects were solved through the EU Green Lanes and the recognition of food and feed as critical goods, it had potential to impair the EU’s agri-food trade. COCERAL appreciates the EU Commission’s work on the WTO reform, including its efforts to modernise the multilateral organisation towards global trade rules adapted to the challenges of today’s economies. It is crucial for COCERAL members to keep the world’s trading system fair, predictable and based on common rules. Additionally, COCERAL supports the Commission’s efforts in: • strengthening the WTO’s monitoring role, • reforming the dispute settlement system, and • reinforcing the WTO’s support for sustainable trade policies worldwide. Overall, COCERAL fully supports the EU’s goal to address the challenges of economic recovery through its future trade policy. However, a thorough analysis on the trade-related initiatives under the EU’s Green agenda is required, including their potential impact on the EU’s food security and affordability.
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Meeting with Virginijus Sinkevičius (Commissioner) and

9 Jul 2020 · To discuss issues related to global deforestation, such as measures to tackle deforestation and initiatives related to supply chain sustainability.

Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski), Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and

22 Apr 2020 · Responsible sourcing of commodities aimed at avoiding deforestation or other adverse environmental and climate change impacts

Response to Farm to Fork Strategy

16 Mar 2020

COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply welcomes the Commission’s policy Farm to Fork Strategy aiming towards a more sustainable food production. Representing almost 3,000 companies as part of COCERAL’s national members, our sector collects and trades a substantial volume of agricultural raw materials destined to the supply of the food and feed chains, as well as for technical and energy uses. Thanks to our position in the EU supply chain, COCERAL and its members balance the different requests of the food, feed and non-food markets, from the farmers, processing industry and the consumers through the retailers’ demands. Our businesses thrive on seamless supply-chains, which need clarity, predictability and clear regulatory regimes in order to avoid disruption. While recognising the importance of transitioning towards a more EU sustainable food system, we call for alignment and coherence of different policies which are part of the Green Deal, with clear goals and measurable objectives over time. These policies need to be fit to address in parallel the challenges of the European agricultural production and the need to increase the competitiveness of the supply chains for the next decades. The EU is a major contributor to global food security. This key role can only be sustained if agriculture remains competitive and productive. Achieving sustainable food systems requires the integration of the three aspects of sustainability, i.e. environmental, economic and social. Please find attached COCERAL’s considerations on these three aspects. The Farm to Fork strategy as part of the overall EU Green Deal will be a pivotal framework for the whole food and feed supply chain in the next five to ten years. COCERAL looks forward to the publication of the Communication at the end of March to further examine the effects of this policy on our sector.
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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

COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply welcomes the Commission’s initiative aiming at minimising the risk of deforestation and forest degradation associated with products placed on the EU market. Representing almost 3,000 companies as part of COCERAL’s national members, the sector trades a substantial volume of agricultural raw materials destined to the supply of the food and feed chains, as well as for technical and energy uses. Through our sector’s commitments to several Sustainable Development Goals, COCERAL members have integrated targeted measures into their strategies and planning in order to decrease the impact of their activities on climate change and in order to reduce their environmental footprint. The operators, members of COCERAL, recognise their responsibility towards terrestrial ecosystems, and aim at constantly improving their sourcing in a more sustainable and responsible manner. COCERAL's full contribution to the consultation is in the attached file. Overall, COCERAL recognises the EU engagement in tackling effectively global deforestation. It is essential that it also encompasses efficient international dialogue and cooperation. COCERAL and its members will continue to follow the process and will further take part in this dialogue.
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Response to Fitness check on market access in Inland waterway transport

26 Aug 2019

COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply welcomes the Commission’s Fitness check on market access in inland waterway transport. Inland waterway transport is key to our work. Our aim is to move agricultural commodities from areas of surplus to areas of deficit efficiently. Due to the extreme heatwave this year and consequently to the very low water levels, inland navigation was not possible in some places in Europe. Vessels and barges were only loaded to a limited extent only. As a result, other logistical solutions were used such as freight trains or lorries, which meant a greater environmental impact but also higher costs for businesses. We look forward to the public consultation in 2020 to respond as a stakeholder and user of this transport system.
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Response to Tariff quotas with licences

22 Aug 2019

COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply welcomes the Commission’s initiative in launching a public consultation on the simplification of the Tariff Rates Quotas Management. This below response is to both consultations on the implementing and delegated draft regulations. A well-functioning management of the TRQ system is essential for operators in cereals and rice sectors. While the current system can represent a burden for public administrators, the few changes resulting from the harmonisation of the procedures to all sectors could be seen as challenging for operators. Firstly, regarding the period of submission of applications, the current system is well adapted to the grain market realities, where it gives flexibility to operators in the cereal trade to apply weekly to the quotas available. As such, we would oppose changes towards a monthly application. In the case of a monthly application, if the allocation of the licence happens towards the end of the month, timing flexibility to execute the contract needs to be given to the operators. Secondly, we welcome that most of the quotas in the cereals and rice sectors remain under the management of DG Agri, administered via applications and import licenses. At the same time, the barley quota (EU regulation n°2305/2003, quota number 09.4126), as being underutilised, will be managed under the “first come, first served” system. However, we consider that when the UK would become a 3rd country post-Brexit, we could see significant oversubscription as the UK is among one of the main suppliers of barley to EU27. In this case, we would consider keeping this barley under the import licence application. Lastly, regarding the rice quotas under the order numbers 09.4138, 09.4148, and 09.4168, for the sub-period staring from October, operators commented that period of validity of the licence is reduced compared to the previous sub-periods. If the transport of the merchandise is delayed due to weather conditions, it is possible that it arrives after the end of the quota period, when the licence is no longer valid. For the last sub-period starting from October, it is important to offer the same duration than the other sub-periods, i.e. to expire on the last calendar day of the month following the end of the sub-period. COCERAL stands by the current legal framework of TRQs management in the cereals and rice sector, which has proven to work properly. We consider that the current system is the simplest possible: it is predictable, transparent and provides the necessary confidence for performing trade.
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Response to Tariff quotas with licences

22 Aug 2019

COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply welcomes the Commission’s initiative in launching a public consultation on the simplification of the Tariff Rates Quotas Management. This below response is to both consultations on the implementing and delegated draft regulations. A well-functioning management of the TRQ system is essential for operators in cereals and rice sectors. While the current system can represent a burden for public administrators, the few changes resulting from the harmonisation of the procedures to all sectors could be seen as challenging for operators. Firstly, regarding the period of submission of applications, the current system is well adapted to the grain market realities, where it gives flexibility to operators in the cereal trade to apply weekly to the quotas available. As such, we would oppose changes towards a monthly application. In the case of a monthly application, if the allocation of the licence happens towards the end of the month, timing flexibility to execute the contract needs to be given to the operators. Secondly, we welcome that most of the quotas in the cereals and rice sectors remain under the management of DG Agri, administered via applications and import licenses. At the same time, the barley quota (EU regulation n°2305/2003, quota number 09.4126), as being underutilised, will be managed under the “first come, first served” system. However, we consider that when the UK would become a 3rd country post-Brexit, we could see significant oversubscription as the UK is among one of the main suppliers of barley to EU27. In this case, we would consider keeping this barley under the import licence application. Lastly, regarding the rice quotas under the order numbers 09.4138, 09.4148, and 09.4168, for the sub-period staring from October, operators commented that period of validity of the licence is reduced compared to the previous sub-periods. If the transport of the merchandise is delayed due to weather conditions, it is possible that it arrives after the end of the quota period, when the licence is no longer valid. For the last sub-period starting from October, it is important to offer the same duration than the other sub-periods, i.e. to expire on the last calendar day of the month following the end of the sub-period. COCERAL stands by the current legal framework of TRQs management in the cereals and rice sector, which has proven to work properly. We consider that the current system is the simplest possible: it is predictable, transparent and provides the necessary confidence for performing trade.
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Response to Temporary measures on entry into the Union of certain goods

16 Jul 2019

- COCERAL, the European association of cereals, feedstuff, and agrosupply trade welcomes the inclusiveness and transparency of this method of consultation and provides hereby its comments. COCERAL welcomes the 6 months window for reviewing the control frequency, in the interest of producers, traders and consumers. it is a significant change for products that are currently listed in Regulations (CE) 884/2014;(EU) 2017/186; and (EU) 2018/1660. - In terms of normative tenets enucleated, and overall of lexicon, we praise referring to the subsidiarity and proportionality principles. At the same time, when advocating powers to the EC, providing ground for harmonisation and a levelled playfield for all the economic players, it should carefully checked the overall capability to perform official controls under the very same rules and certification. Whilst this is for the most part secured in the Draft, with wide reference to Iso Standardisation and to the Official Controls regulation (Reg.2017/625), we propose the Commission consider further harmonization in place. - COCERAL asks the Commission to develop clear criteria for listing and delisting of products from the special measures providing data and information. For this purpose, a Guidance Document would be mostly welcome. For instance, the provisions (art. 3; art. 10) assuming that sampling and analysis may either be at the country of origin or at the country of the imported products is relevant to us, as Third Countries not having the same sampling and analysis capabilities in place than the European countries of destination could easily provide a lesser amount of info to the Commission. This info is paramount to update the controls frequency as stipulated under (whereas 19). How the European Commission intends to copy with this aspect is key. Proper programs to secure this should be clearly defined in the regulation and referred to, in the very interest of the entire food chain. Beyond formal and strict adherence to methodologies for sampling and testing/analysis, an on-going review of physical and human capabilities could allow to achieve the very goals the Commission set. - With regard to the art 1 (b), COCERAL asks for a specific section of the aforementioned Guidance by the Commission to better frame specifically cases of MRLs (pesticide residues) when there is no apparent health problem (and assuming that the scope of the regulation relies in “taking into account in particular the level of risk associated with the hazard under consideration”) and in order to have a equal behaviour of controls across the EU. - In the same direction, the weights in use by the Commission to take into account the different sources of risks and non-compliance, as considered under (whereas 19) could be made clearer and more straightforward. For instance, “reports and information received from third countries” and given credit as a source for updating the frequency of controls and emergency measures, is not clear in its meaning and could refer to either qualitative and quantitative data with different value in supporting the evidence. Rephrasing this and in case making reference to the proper hierarchy of the data could meliorate the overall value of the draft, within the aim of simplification and rationalization. At the same time, we regret that “consignment “ is granted a double definition depending upon the overall context (art. 12). COCERAL is not in favour of overlapping terms due to the possible loss of overall clarity and eventually legal certainty. - We ask the Commission to involve relevant stakeholders in trade issues in order to supply questions and answers (Q&A) to complement the aforementioned Guidance Document. -COCERAL asks for the liberty choose the country of controls, sampling and analysis. - Also, traders and food business operators should be able to choose private laboratories compliant with the formal requirements needed, in order to control the costs.
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Response to Enhancing Market transparency in the agri-food chain

19 Jun 2019

COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply welcomes the Commission’s initiative in launching a public consultation on the draft Implementing Regulation on Market Transparency. In the cereals sector, representative prices are already available and accessible to the public, institutions and all stakeholders in the supply chain. Our sector is familiar with the available tools to make strategical decisions and manage risks both for the short and longer term. However, COCERAL would have concerns if the request for more transparency is extended towards disclosing confidential company information regarding price structure. We understand the aim of this draft is to give better barging power to farmers in the supply chain. Compared to other agricultural sectors, commercial relations are different between farmers and traders in the grain and oilseed markets. Discussions are more balanced, and farmers have better leverage in negotiations with traders. For instance, a farmer can decide to store its goods until there is a better market situation to sell his products. It is important for COCERAL that confidentiality of data is maintained especially for products dealt by a very limited number of operators in one EU member state. As indicated in the draft Implementing Regulation, the idea that declaration of prices is limited to “Member States concerned are those producing or using more than 2% of the total Union corresponding production or use” must be preserved. Regarding the declaration of price for organic products, we see that quality requirements varies from one Member State to another. As such, prices would not be comparable, and aggregation would be impossible. COCERAL welcomes the steps made by the Commission in providing better information accessible to all through the creation of Market Observatories. The extension of these observatories to several sectors proves the interest in understanding the market. The focus of the observatories should continue in providing better and more reliable data, in quality and in periodicity. The Commission must continue to communicate the work of these observatories to all operators in the supply chain.
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Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development)

18 Sept 2018 · Introductory meeting

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan) and Fédération Européenne des Fabricants d'Aliments Composés

3 Sept 2018 · Update on trade issues

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and CropLife Europe and

17 May 2018 · Import tolerance, Commission's proposal on general food law, REFIT on pesticides

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

29 Nov 2017 · New breeding techniques

Meeting with Vytenis Andriukaitis (Commissioner) and Unistock Europe - Association of Professional Portside Storekeepers in the Food and Feed Chain

30 May 2017 · Discussion on science communication: how to present science-related topics to the general public ?

Meeting with Arunas Vinciunas (Cabinet of Commissioner Vytenis Andriukaitis), Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and

14 Dec 2016 · Dimethoate

Meeting with Cecile Billaux (Cabinet of Vice-President Cecilia Malmström)

5 Dec 2016 · trade in linseed

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

30 Sept 2016 · MIFID

Grain and oilseed industry urges risk-based endocrine disruptor criteria

28 Jul 2016
Topic — Establishing scientific criteria for identifying endocrine disrupting properties in plant protection products.
Message — The associations request including hazard characterisation and potency in the identification criteria. They advocate for a risk-based approach including exposure and socio-economic impacts.12
Why — This approach protects the industry from the withdrawal of economically important substances.34
Impact — European agricultural producers face lower yields and reduced productivity under the current proposal.5
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Meeting with Cecile Billaux (Cabinet of Vice-President Cecilia Malmström)

26 Feb 2016 · meeting COCERAL and European Rice Millers on Tricyclazole

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

26 Feb 2016 · Tricyclazole

Meeting with Jean-Luc Demarty (Director-General Trade)

17 Feb 2016 · TTIP and DCFTA with Ukraine

Meeting with Ladislav Miko (acting Director-General Health and Food Safety) and FoodDrinkEurope and

26 Feb 2015 · GM import authorizations

Meeting with Cecile Billaux (Cabinet of Vice-President Cecilia Malmström)

13 Feb 2015 · Trade negotiations and health

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

11 Feb 2015 · MiFID & MiFIR 2

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

11 Feb 2015 · MIFID 2

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis)

9 Dec 2014 · GMOs