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COMITE EUROPEEN des FABRICANTS de SUCRE

CEFS

CEFS is the main representative body for European sugar manufacturers.

Lobbying Activity

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)

4 Nov 2025 · specificities of the sugar industry when it comes to decarbonisation: seasonality, rural location, energy intensity

Response to Food and Feed Safety Simplification Omnibus

14 Oct 2025

CEFS, the European Association of Sugar Manufacturers, welcomes the opportunity to respond to the European Commissions call for evidence on the Food and Feed Safety Simplification Omnibus. The full contribution is attached to this submission. While CEFS support the initiative to reduce unnecessary regulatory burdens, ensuring that the high standards of food and feed safety, human and animal health, and environmental protection are upheld, CEFS would like to highlight key areas where simplification can be achieved, removing administrative inefficiencies and improving legal certainty for operators and competent authorities. Key Areas for Simplification: 1. Avoiding Regulatory Duplication in Water Use: Directive (EU) 2020/2184 requires specific exemptions for water use not fully compliant with drinking water standards. However, HACCP-based food safety management already ensures the safety of water. We propose that the HACCP assessment be sufficient to eliminate unnecessary exemption procedures. 2. Clarifying Footnote 1 of Regulation (EC) No 396/2005: Footnote 1 causes legal uncertainty regarding maximum residue levels (MRLs) for feed ingredients. We suggest replacing this with a harmonized provision allowing MRLs and processing factors established for food may serve as guidance values for feed; and where these levels are exceeded, the feed business operator should conduct a safety assessment, taking into account all circumstances. Furthermore, an exceeding of a MRLs established for food is not automatically leading to a withdrawal, a recall or a RASFF notification. Further measures depend on the safety assessment (pesticide, amount, target animal). 3. Proportional Enforcement of Food Law: Under Articles 19 and 20 of Regulation (EC) No 178/2002, notification to authorities should be required only when products have left the B2B sector and may reach consumers. Likewise, Article 138 of Regulation (EU) 2017/625 should clarify that competent authorities must carry out a safety assessment before ordering recalls or withdrawals from the market. Recalls triggered solely by technical non-compliance, such as minor exceedances or traces of unapproved or unregulated substances without safety implications, are disproportionate and contradict the General Food Laws principle that recalls apply only to unsafe food or feed. Clear guidance on these points would ensure enforcement remains risk-based and proportionate, reinforcing trust in both operators and authorities. 4. Streamlining Authorization of Food Enzymes: The current authorisation process for food enzymes under Regulation (EC) No 1332/2008 is lengthy and inflexible, creating unnecessary delays and hindering innovation. Despite EFSAs comprehensive safety assessments, approvals often cover only limited uses, leading to regulatory inefficiencies. We recommend simplifying the authorisation procedure for food enzymes to facilitate efficiency and market development, ensuring that a comprehensive EFSA safety assessment is followed by an authorisation that supports the widest safe application. 5. Efficient Approval Process for Plant Protection Products: The current approval process for plant protection products is lengthy and delays the availability of safer solutions. A more risk-based system, considering the overall benefits of products, would enhance innovation, food security, and resilience, particularly in the face of climate change. The principle of proportionality must remain central to EU food law. CEFS supports the Commissions efforts to simplify EU food and feed safety regulations. By removing unnecessary bureaucracy and ensuring proportional enforcement, we can achieve greater efficiency while maintaining safety. A balanced, risk-based approach will foster competitiveness, innovation, and consumer trust, all while ensuring a robust and sustainable food supply chain. The full contribution and our detailed feedback are attached for your consideration.
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Sugar manufacturers urge financial aid and flexibility for 2040

16 Sept 2025
Topic — Amending the European Climate Law to establish a 2040 climate target.
Message — CEFS requests substantial public financial support and early access to international emission credits. They advocate for proportionate burden-sharing for industries facing carbon leakage risks. They demand policy coherence between climate, industrial, and agricultural policies.123
Why — This approach reduces high capital costs and maintains the industry's global competitiveness.4
Impact — Environmental groups lose out if international credits dilute domestic reduction efforts.5
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EU Sugar Industry Seeks State Aid for Electricity Costs

5 Sept 2025
Topic — State aid guidelines for compensating electricity-intensive industries under EU emissions trading scheme.
Message — The sugar industry requests inclusion in the list of sectors eligible for indirect cost compensation under ETS. They argue electricity costs are crucial for their decarbonisation plans involving electrification of production processes. They criticise the short consultation period and call for more regular reviews with systematic stakeholder consultation.123
Why — This would reduce electricity costs needed to electrify heat production and decarbonise operations.45
Impact — Taxpayers in other sectors bear costs while sugar industry gets special treatment.
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Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

8 Jul 2025

The EU sugar industry reduced its CO2 emissions by 59 % between 1990 and 2021. By this metric, we are well on the way to meeting the objective of the ETS1 to reduce emissions by 62% by 2030. Sugar manufacturers recognise the importance of continued progress in reducing greenhouse gas emissions in order to reach climate neutrality by 2050. Large volumes of heat and electricity are required to produce beet sugar and co-products. Heat and electricity are generally provided by efficient Combined Heat and Power (CHP) systems. This form of self-supply is necessary in view of the deficit network situation in rural areas, and to ensure security of supply during the production campaign. In addition, sugar manufacturers operate lime kilns to produce quicklime and CO2 by decomposition of limestone (CaCO3) with heat into Calcium Oxide (CaO) and CO2. In-water suspended CaO and the CO2 are injected into sugar diffusion juice to re-carbonate the CaO to CaCO3 and precipitate non-sugar impurities. The resulting carbonated lime (also known as Sugar Factory Lime) is marketed as a soil additive and improver, since its alkaline pH reduces soil acidity. The CO2 is not emitted into the atmosphere but instead stored in the carbonated lime. As will be seen, this process is now covered by the ETS. The decarbonisation of EU beet sugar manufacturing requires energy efficiency improvements, electrification of sugar processes and the use of biomass, especially own-produced (from residues and waste). There is no one-size-fits-all solution. In recent years energy costs have made up over 30% of EU sugar manufacturing costs (versus c. 20% previously). Annual reductions in free allowances, combined with an increase in allowance prices, is aggravating the existing risk of carbon leakage. The increases in the Linear Reduction Factor and the maximum benchmark update rate brought about by the 2023 ETS review will put the sector under further pressure. Since the end of quotas in 2017 20 beet sugar factories have been closed and almost 5,000 direct industrial jobs lost. The costs of decarbonisation, combined with limited public support for investments, an unsuitable trade policy, declining beet yields, and stagnating sugar consumption, among other challenges, mean the EU sugar sector is under increasing and potentially unsustainable pressure. With these considerations in mind, CEFS has several requests regarding the ETS proposal - PLEASE SEE ATTACHED FOR OUR COMPLETE POSITION.
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European sugar sector demands strategic status for beet crops

23 Jun 2025
Topic — This consultation seeks views on updating the EU's circular bioeconomy strategy.
Message — The sector wants sugar officially classified as a strategic product to bolster food and energy sovereignty. They call for removing regulatory barriers and funding biorefineries to expand into bioplastics and green fuels.123
Why — This status would protect their market share and unlock new revenue streams.45
Impact — Foreign exporters face tougher trade restrictions and reduced access to European markets.67
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Meeting with Catherine Geslain-Laneelle (Director Agriculture and Rural Development)

20 Mar 2025 · Exchange of views on the implementation of the Vision for Agriculture and Food

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)

Response to Targeted amendment to the CMO and other CAP Regulations strengthening farmers position in the food supply chain

10 Mar 2025

SUMMARY CEFS consistent position is to maintain unchanged the current and longstanding provisions on contractualisation in Art. 125 and Annex X of the Single CMO Regulation, which take into account the unique specificities of the sugar sector and its contractualisation practices in a balanced and effective way. Beet sugar production is characterised by a mutually-dependent relationship between sugar manufacturers and growers owing to the unique characteristics of the sugar industry. These unique characteristics include: different options (factories have no option other than to process sugar beets, while sugar beet growers can choose to cultivate alternative crops), seasonality, logistical complexity, local sourcing, capital intensity, long lead times, a volatile sugar market, and a high proportion of cooperatives. Put simply, sugar factories rely on local sugar beet production and farmers rely on local sugar factories to provide an outlet for their sugar beet. Without sugar beet a sugar factory must close down and, due to the high costs of rebuilding or even restarting, is unlikely to reopen, leading to the loss of direct jobs on-site and revenue for farmers. This means that the economic stability of sugar manufacturers and growers is essential for the sectors success. Collaboration between sugar manufacturers and growers has always been essential for the sectors success and contractualisation in the sector has historically offered sugar beet growers more security than any other in the Single CMO Regulation. The changes proposed by the European Commission affecting Annex X could introduce significant disruptions to the established framework governing the sugar sector. The proposed amendments to Annex X and Art. 168 fail to respect the sugar sector's specificities and unique, exemplary framework and create significant legal, administrative, and competitive uncertainties. Instead of boosting the position of beet growers in the sugar supply chain, the proposal could have the effect of weakening the position of the upstream sugar supply chain (growers and manufacturers alike) to the benefit of sugar imports from third countries. We have specific concerns with the revision clause, indicator-based pricing, modification of wording of beet delivery contracts, and new references to producer organisations. More broadly, given the disruptive nature of the proposal, CEFS urges the European Commission to carry out a rigorous and careful impact analysis. You will find our complete position in annex.
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Response to European Water Resilience Strategy

4 Mar 2025

CEFS, the European Association of Sugar Manufacturers, is committed to proactive engagement in EU water resilience efforts. Addressing water scarcity, resource management, and industry adaptation. Water resilience is increasingly critical for EU industry, agriculture, and environmental sustainability. EU sugar manufacturers have long worked to reduce irrigation needs and optimise water use in sugar beet farming (position paper attached, Part I). Several elements are crucial to shape an EU Water Resil-ience Strategy, for which CEFS provides recommendations (position paper attached, Part II). Among our key principles for a future EU water resilience strategy (see our position attached for more explanation): A/ Set the focus at local level - Adopting a flexible regulatory framework that recognizes local variations and allow region-specific solutions rather than imposing rigid EU-wide rules. B/ Support industry-led solutions: - Identification of unsustainable water use through a hotspot-based approach, focusing on high water-stress areas. - Implementation of mitigation measures, in line with the FDM BREF), while maintaining food safety standards. - Adoption of water management and stewardship programmes. - Expansion of existing collaborations between sugar factories and local agriculture for efficient water redistribution. C/ Implementing existing water legislation - Effective implementation of the Water Framework Directive & other EU water-related policies. - The introduction of additional horizontal regulations should be avoided, as solutions to water challenges vary significantly by region. - Policy should prioritise targeted enforcement and improvement of current frameworks rather than imposing one-size-fits-all solutions. D/ Promote innovation in water reuse and recycling technologies - Support for innovation Foster the development of water recycling / reuse technologies and circular economy practices. - Water-Resilient Agriculture: Enhance efficiency and protect water quality, with a focus on water-intensive crops. - Targeted Funding: Allocate resources to water-saving technologies in high-stress areas and streamline industry-driven conservation funding. - Infrastructure Investment: Develop effective public piping networks and distribution systems for water reuse in agriculture. E/ Enhance monitoring & data collection - Improve industry-level water use monitoring, data collection and reporting to optimise conservation efforts. In addition, you will find an issue brief of the EU Beet Sugar Sustainability Partnership detailing how the EU sugar beet sector guarantees a sustainable water use at the bottom of CEFS' position paper attached, and at the following link: https://www.sustainablesugar.eu/s/Issue-Brief-web-Water-2021.pdf
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Meeting with Christophe Hansen (Commissioner) and

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

Sugar manufacturers urge simpler EU carbon market activity rules

9 Jan 2025
Topic — The consultation updates rules for adjusting free emission allowances based on activity changes.
Message — CEFS requests clear product definitions and the exclusion of by-products from activity calculations. They advocate for simplified procedures for integrated thermal schemes to avoid high measurement costs and request excluding process emissions.123
Why — This would reduce administrative burdens and prevent expensive investments in new measurement systems.45
Impact — Regulators lose granular data transparency needed to monitor industrial energy efficiency accurately.6
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Meeting with András Gyürk (Member of the European Parliament)

8 Nov 2024 · Overview of EU sugar industry priorities

Meeting with Valérie Hayer (Member of the European Parliament)

1 Oct 2024 · Sucre

European Sugar Manufacturers Oppose Tariff Cuts for Ukrainian Imports

30 Sept 2024
Topic — Accelerating mutual elimination of customs duties under EU-Ukraine Association Agreement.
Message — The association requests maintaining the current import quota of 20,070 tonnes for Ukrainian sugar until production standards align with EU regulations. They want export licenses limited to verified manufacturers and strict rules of origin to prevent third-party re-exports.123
Why — This would protect them from competition with lower-cost Ukrainian producers operating under less stringent regulations.45
Impact — Ukrainian sugar producers lose expanded market access and economic support during wartime.67
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Meeting with Katarína Roth Neveďalová (Member of the European Parliament)

26 Sept 2024 · Sustainable sugar production in the EU

Response to Amendment of the EU ETS Monitoring and Reporting Regulation (MRR) in response to the ETS revision/Fit For 55 (Batch 2)

29 Jul 2024

SUMMARY. FULL POSITION IN ATTACHMENT CEFS members operate lime kilns to produce quicklime and CO2 by decomposition of limestones (CaCO3) with heat into Calcium Oxide (CaO) and CO2. In water suspended CaO and the CO2 are injected into sugar diffusion juice to re-carbonate the CaO to CaCO3 and precipitate non-sugar impurities. The resulting carbonated lime (also known as sugar factory lime) is marketed as a soil additive and improver, since its alkaline pH reduces soil acidity. The carbon dioxide stored in carbonated lime can be considered permanently chemically bound, as in the original limestone. Given that the CO2 within the resulting CaCO3 is not released again during the sugar production process, Art. 49(1) and Annex IV, point 10, section A should not be amended. Any such amendment would: - contradict the Polluter Pays principle, since it would make operators (including sugar manufacturers) responsible for potential and unconfirmed future emissions that are not their own; and - not be legally coherent as taxing virtual downstream emissions and in case of use of secondary raw materials lead to double counting of emissions and/or taxation of biogenic carbon. Please find in attachment CEFS' complete position on the regulatory proposal.
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European sugar industry demands exemption from carbon accounting rules

16 Jul 2024
Topic — EU rules on when captured CO2 is considered permanently bound in products.
Message — CEFS requests that carbonated lime from sugar production be treated the same as natural limestone and exempt from emissions accounting. They want a negative list approach that excludes certain products from carbon accounting, arguing their carbonated lime is chemically identical to the original limestone.12
Why — This would eliminate their liability for emissions when carbonated lime is applied to soil.3
Impact — Climate accountability suffers as CO2 emissions from agricultural lime application go unaccounted.4
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Meeting with Olivér Várhelyi (Commissioner) and

7 Mar 2024 · Ukraine

Response to Restrictions on bisphenol A (BPA) and other bisphenols in food contact materials

6 Mar 2024

CEFS, the European Association of Sugar Manufacturers, takes note of the European Commissions draft Regulation on the use of BPA and other bisphenols in certain materials and articles intended to come into contact with food. Food safety is paramount for the European sugar industry, indispensable and beyond any compromise. Our members are committed to providing safe and high-quality food and ingredients to the European consumers while supporting measures to reduce exposure to toxic substances. However, CEFS would like to provide some comments related to the proposed draft Regulation by the European Commission, which need further reflections and/or clarifications. CEFS' detailed comments can be found in the attached document.
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Response to Revision of the definition of engineered nanomaterial in food

8 Jan 2024

CEFS, the European Association of Sugar Manufacturers, welcomes the opportunity to provide feedback on the European Commissions draft Delegated Act revising and updating the definition of engineered nanomaterials set out in the Novel Food Regulation (EU) 2015/2283. You can find here attached our detailed contribution to EC's draft proposal. Thank you very much in advance for your consideration.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis)

7 Jul 2022 · taxonomy of sustainable economic activities

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

16 Mar 2022

CEFS welcomes the European Commission’s call for evidence on the imports of agricultural and food products – applying health and environmental standards, which is at the core of the ongoing public discussion on how to apply mirror clauses in the EU’s trade policy. EU beet sugar producers already comply with the highest environmental and health standards in the world, which results in higher costs and an uneven playing field with third country producers. The EU Green Deal sets a number of objectives that risk stacking the deck even more in third countries’ favour. The Farm to Fork Strategy sets a target of a 50% reduction in pesticide and fertiliser use by 2030 and proliferating active substance bans offer an advantage to sugar produced in countries with more permissive plant protection regimes than the EU’s. The Commission’s proposal for a revision of the Emissions Trading System (ETS) Directive would require a 61% reduction in greenhouse gas emissions by 2030, compared to 2005 levels. Again, this risks disadvantaging EU sugar producers vis-à-vis sugar produced in countries without carbon pricing systems in place. In August 2021 the Commission’s own Joint Research Centre (JRC) study confirmed that the EU’s new environmental and climatic ambition could cause a reduction in EU agricultural production and an increase in imports of agricultural products from third countries that do not necessarily meet EU requirements. CEFS has repeatedly highlighted that the continuing and substantial opening of the EU market to imported sugar produced under lower health and environmental standards not only puts the sugar production in the EU at risk but also moves the Union away from reaching its climate objectives. Any product that violates EU sustainability norms (including environmental and health standards) has no place on the EU market. Our industry’s contribution to this call for evidence consists of two parts. First, sugar-specific examples of imports from countries that do not respect EU and health and environmental standards. Second, recommendations on specific EU legislative initiatives, which can lead to the practical implementation of mirror clauses to the benefit of the EU sugar sector and European agriculture in general.
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Meeting with Mairead McGuinness (Commissioner)

24 Feb 2021 · Taxonomy, Reconciling virtual & real economy.

Meeting with Thierry Breton (Commissioner) and

18 Feb 2021 · Pact for Skills roundtable with the representatives of agri-food sector

Meeting with Nicolas Schmit (Commissioner) and

18 Feb 2021 · Pact for Skills roundtable with the representatives of agri-food sector.

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and International Confederation of European Beet Growers and Agriculture & Progress Platform

15 Jan 2021 · Taxonomy draft delegated act

Meeting with Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski)

27 Nov 2020 · CEFS' reply to the Public Consultation on the Roadmap of the Action Plan for the development of the organic production

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and Comité du commerce des céréales, aliments du bétail, oléagineux, huile d'olive, huiles et graisses et agrofournitures de l'U.E. and

29 Oct 2020 · EU Biofuels Chain

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

6 May 2020 · Sustainable food systems

Meeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan), Kevin Keary (Cabinet of Commissioner Phil Hogan), Tom Tynan (Cabinet of Commissioner Phil Hogan)

18 Feb 2020 · FTA Australia and future relations EU-UK

Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski)

3 Feb 2020 · Cap, Green Deal

Meeting with Sabine Weyand (Director-General Trade)

15 Oct 2019 · Trade & Sugar Industry

Sugar industry urges flexible EU carbon emission allocation rules

9 Jul 2019
Topic — Rules for determining free carbon emission allocations to industrial installations are being revised.
Message — The industry requests using sugar entered as a generic indicator for measurements. They seek more flexibility and clarification on how efficiency investments are incentivized.12
Why — This would reduce technical measurement difficulties and lower the overall cost of compliance.34
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Response to Enhancing Market transparency in the agri-food chain

18 Jun 2019

We would like to submit a slightly revised contribution to this initiative, as follows: "At the very minimum, the publication of price information should be subject to a delay of two months (in addition to the existing delay of two months) to ensure that ongoing contract negotiations are not impacted." You will find in attachment our full revised contribution.
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Response to Towards the future Generalised Scheme of Preferences legal framework granting trade advantages to developing countries

22 May 2019

The current GSP provides sufficient support to LDCs and developing countries. The safeguard provisions must be effective, i.e. the Commission should be able to react in a timely manner. The respect of the conventions on labour and human rights, environment and governance principles need to be better monitored. In case of violation the COM should be able to take immediate steps to withdraw tariff preferences. CEFS reserves the right to provide more comprehensive input during the public consultation phase.
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Response to Establishment of a methodology of measurement of food waste

3 Apr 2019

CEFS, the association representing European sugar manufacturers, would like to ask the European Commission to clarify why “waste from sugar processing - 0204” is mentioned in Annex II of the draft delegated act establishing a common methodology and minimum quality requirements for the uniform measurement of levels of food waste generated in Member States. Indeed, this terminology implies that all wastes from sugar production are food waste, which is not the case. The European Waste Catalogue indeed lists four sub-groups of material under code 0204: -02 04 01 soil from cleaning and washing beet; -02 04 02 off-specification calcium carbonate; -02 04 03 sludges from on-site effluent treatment; -02 04 99 wastes not otherwise specified. Materials under these waste categories are not fit for any kind of human consumption and never were intended to. They are not part of the raw material sugar beet in the same way that banana peel is part of a banana or that bones are part of a steak. The raw material sugar beet is fully used to provide sugar, feed and raw material for the fermentation industry including ethanol production. Besides, calcium carbonate used as fertilizer is produced in the production step of “juice purification”, which off-spec charges (if any) are discarded as waste under code 02 04 02. No biological waste results from the process of sugar manufacturing; food waste is therefore not an issue for sugar manufacturers and should not be mentioned in the act. We therefore suggest the removal of the whole 0204-line.
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Meeting with Anne Bucher (Director-General Health and Food Safety)

3 Apr 2019 · Présentation du secteur sucrier européen

Response to Commission Regulation setting maximum residue levels for chlorate in or on certain products

14 Feb 2019

CEFS welcomes the possibility to provide comments on the draft Commission Regulation. In addition to the sugar products destined to food (as such or as ingredients), CEFS’ members are producers of a certain number of co-products (food products, feed materials and products used as substrate for the fermentation industry). CEFS is deeply concerned by the latest developments on chlorate. Indeed, while our end product (crystal sugar) is not a matter of concern thanks to the crystallisation step (purification), we face measurable levels of chlorate in our co-products higher than 0.01 mg/kg as proposed in the draft Regulation for sugar plants. CEFS is therefore calling for appropriate and balanced actions to be taken when it comes to chlorate and which would consider the following arguments: • As already highlighted by many sectors, Regulation (EC) 396/2005 is not the appropriate legal framework for the management of chlorate levels in foods. The possible presence of chlorate residues in food has been found to come from multiple sources but not as the result of its use as a pesticide. We do not believe that a feasible solution for MRLs can be achieved under Regulation (EC) 396/2005 as the structure this Regulation is not suitable for multiple source substances and especially chlorate for which several different entry points may occur across the supply chain (cultivation, harvest, processing) up to the final product intended for the consumer. • Consistency of EU legislation is important. CEFS thus urges the regulators to delay discussions on changes to pesticide MRLs until the finalization of the on-going review of the Drinking Water Directive. The conclusions of the REFIT exercise for the EU pesticides legislation should also be taken into account when considering MRLs for chlorate in foods. • We are concerned that the draft chlorate MRLs which are currently the subject of this public consultation are based on occurrence data, mainly on food as consumed, that do not reflect the presence of chlorate currently observed, in particular in processed ingredients. In the case of the sugar sector, sugar beet does not contain measurable levels of chlorate. CEFS’ members co-products are however impacted. Indeed, chlorate is not applied to raw materials. Chlorate maximum levels/limits should therefore not be set on raw commodities (e.g. sugar plants) but on processed products. • The draft Regulation does not take into account all points of entry of chlorate. In the case of the sugar sector, the presence of chlorate may be attributable in certain cases to the use of active chlorine for groundwater as well as a possible contamination by water coming from cooling systems which can also be treated with chlorine. But also, the entry of chlorate in the process may happen via processing aids use. Indeed, some processing aids are known to contain chlorate as a result of their manufacturing process. This is the case of sodium hydroxide (NaOH – caustic soda). The use of those processing aids is essential to the sugar process. The presence of chlorate as a residue of the manufacturing process of crucial processing aids should be duly taken into account as well as any other possible sources of chlorate. Indeed, the use of chlorinated water is inerrant and indispensable to the production process as well as the use of NaOH. To conclude, CEFS is calling for discussions on the setting of achievable Maximum Limits for chlorate, under the appropriate legal framework and having sufficiently assessed from a technical and legal standpoint the various origins of chlorates in the different sectors of the food industry. Should limits/levels for chlorate be set, they need to duly take into consideration all different entry points of chlorate during the sugar process and be set on the appropriate product as chlorate is not applied to raw agricultural commodities (sugar beet) as a plant protection product. Complete paper can be found enclosed.
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European sugar industry seeks protection from high carbon costs

16 Jan 2019
Topic — The Commission is revising rules for compensating industries for high electricity emission costs.
Message — CEFS requests the Commission consider the sugar industry a key actor for state aid. They want better protection against carbon leakage risks through compensation for indirect costs.12
Why — This revision would offer sugar manufacturers new possibilities to offset rising electricity costs.34
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Sugar manufacturers warn EU carbon rules penalize efficient energy use

23 Nov 2018
Topic — The European Commission is revising rules for free carbon emission allowances.
Message — The organization requests clearer guidance to protect manufacturers using efficient energy systems. They argue for unambiguous rules that prevent the reduction of free emission allowances.12
Why — Sugar producers would maintain their current financial support and avoid higher compliance costs.34
Impact — The environment loses as manufacturers may switch back to less efficient gas boilers.56
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European sugar producers seek more flexible carbon permit rules

17 Apr 2018
Topic — This consultation concerns the rules for allocating free emission permits to industrial sectors.
Message — The industry requests excluding low-production years from calculation averages to reflect current market output. They also want permit increases for higher production regardless of physical site expansions.12
Why — This would increase the number of free permits the sugar sector receives annually.3
Impact — The environment loses because production can increase without requiring any new green investment.4
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Response to Revision of the Drinking Water Directive (RECAST 2017)

29 Mar 2018

RESPONSE OF THE EU ASSOCIATION OF SUGAR MANUFACTURERS Our understanding is that the recast proposal of Directive 98/83/EC maintains its current scope and makes the necessary updates as regards drinking water: update of the list of followed parameters, introduction of a risk-based approach, improvement of transparency and access to up-to-date information for consumers, harmonization of the approval systems of materials and products in contact with drinking water. Based upon these facts, CEFS would like to raise the following points: 1. In the recitals of the directive it must be clarified that with regards to food production installations, the definition: “water intended for human consumption” shall cover water which is supplied to these installations (from an external water supplier or self-water provision) and used in contact with food. Process water, that is generated further on in the food production process such as condensates from evaporation of the sugar juices within a sugar factory (and subsequently used instead of fresh water in contact with food) therefore needs to be excluded from the definition. • Consequently, the definition of water used in food processing of Art. 2 (1) (b) of 98/83/EC must be maintained. 2. The deletion of Article 6 d) is not coherent with the reference to Article 2 of Reg. 178/2002 (General Food Law (GFL) Regulation) made in the recast. Recital 3 of the draft states that, from the point of compliance, water is considered as food. Recital 3 reflects the content of Article 2 to the GFL. However, for legal certainty, this needs to be mentioned directly in Article 6 and not only in the recital. Therefore, Article 6 (point of compliance) number d) need not to be deleted but must be changed into d) “in the case of water used in a food production undertaking with contact to the food at the point where the water is for the first time brought in contact with the food. Water that fulfills the quality criteria of annex 1-part A and B (microbiological and chemical quality) at the point of compliance should be deemed safe and suitable for a food production. 3. The exclusivity clause with regards to exceptions (Article 3 number 2a) has to be deleted, as in certain cases these water flows with non-potable water quality are used for both with and without contact to food i.e. “a) water intended exclusively for those purposes.” • For coherence with the definition of “food” as laid down in Article 2 to Regulation 178/2002 and the proposal we made in our second argument in relation to Article 6 d), we suggest adding an Article 3(1c) which would read “water used in a food production undertaking after the point of compliance (“process water).” 4. With regard to the risk assessment of supply (Article 7 number 1b and Article 9) it has to be clarified that this rule does not apply in case of self-provision of water for food production (e.g. production of demineralized water from well water) as in this case the obligations of the food legislation already apply and safeguard that only food which is safe is marketed. 5. With regards to the monitoring of water intended for human consumption (Article 11) it has to be clarified that this rule does not apply in case of self-provision of water for food production as the final food per se must be fit for human consumption. 6. Water used in a food production installation from self-water provision shall also be exempted from the information requirements of Article. 14 of the Regulation and Annex IV.
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Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development)

2 Feb 2018 · Echanges de vue sur les sujets d'actualité

Response to Commission Implementing Regulation on the provision of voluntary indication of origin or place of provenance of foods

30 Jan 2018

CEFS (Comité Européen des Fabricants de Sucre) represents EU sugar producers. Sugar is produced from sugar beet from the EU and sugar cane from the EU and third countries. The sugar produced by CEFS members is marketed as a single-ingredient product (e.g., sugar packs) and it can also be a food ingredient representing more than 50% of a food (e.g., sugar in confectionery). CEFS considers that, while the current version of the draft Implementing Regulation has been well improved, so far, the proposed options to indicate the origin of the primary ingredient have not been completely able to take into account all the constraints of the EU sugar sector. Therefore, our comments are the following: • We note that neither Article 2(a) nor Article 2(b) provide a solution for cases where (1) the origin of the primary ingredient varies frequently, so that this may sometimes be the same as the origin of the food and sometimes different, depending on the sourcing, (2) the primary ingredient has multiple origins that may also include the origin or provenance of the food product. Possible solutions to this would be the inclusions of the indication “and/or” in Art. 2(a), and the provision of more flexibility concerning the statement laid down in Art. 2(b) (e.g. allow for the use of statements such as “[primary ingredient] may come from various origins”, “[primary ingredient] may be of a different origin”, “[primary ingredient] partially of different origin” etc). • In addition, we feel that the existing legal framework is not properly taken into account. Indeed, from a legal point of view, the refining of raw sugar does not confer the origin to the sugar. This means that white sugar obtained in an EU country from raw sugar imported from a third country would have as origin that third country Finally, CEFS thinks that developing an interpretative Q&A is an important step in order to cover all specific and remaining interpretation issues that may arise from the adoption of the Implementing Regulation. This is a crucial step for the B2B communication between primary ingredient producers and the second transformation industry.
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Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

25 Oct 2017 · Concerns of the sugar sector

Meeting with Xavier Coget (Cabinet of Vice-President Jyrki Katainen)

9 Oct 2017 · EU - Mercosur FTA negotiations

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

19 Sept 2017 · Brazilian sugar - ethanol sector

Meeting with Cecilia Malmström (Commissioner) and International Confederation of European Beet Growers

7 Sept 2017 · Mexico and Mercosur FTAs negotiations

Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development)

24 May 2016 · Le marché du secteur du sucre

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström) and International Confederation of European Beet Growers

3 Mar 2016 · Trade & sugar

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

16 Dec 2015 · Sugar Issues

Meeting with Carlos Moedas (Commissioner) and European farmers and

2 Feb 2015 · Meeting with the European Bioeconomy Alliance on the Bioeconomy Strategy

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

16 Jan 2015 · Global Trade Aspects of the Sugar Sector

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

17 Dec 2014 · Priorities for agriculture and trade ahead of the end of single CMO for sugar in 2017. Outlets for out-of quota sugar