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Confédération des Fabricants de Levure de l'Union Européenne

COFALEC

Veille des projets règlementaires concernant notre secteur et plus largement celui de l'alimentaire et de l'agriculture.

Lobbying Activity

Response to Technical updates of the Emissions Trading Scheme (ETS) State aid guidelines

3 Sept 2025

COFALEC, as the European federation representing the yeast industry (Prodcom 10.891334), would like to draw attention to the specific situation of the sector represented, essential to the food industry, but at risk of not being eligible for the planned support due to the criteria currently in place. Context and Importance of the sector - During the 2018 assessment conducted within the EU ETS framework, the yeast sector was officially recognized as being at risk of carbon leakage. This outcome was achieved due to the recognition of our industrys specificities, particularly its high trade intensity (>20%) and carbon intensity (both direct and indirect emissions). This support was crucial in ensuring the competitiveness of the industry while enabling it to move forward onto a modernization trajectory aligned with the EUs climate ambitions. Today, our sector fully aligns with the priorities defined by the EUs Competitiveness Compass, that calls for targeted measures to support both the competitiveness and decarbonization of energy-intensive industries. It also emphasizes the importance of achieving a delicate balance between climate ambitions and the preservation of key industrial sectors within the EU. However, our analysis under this consultation reveals that, despite significant advancements in decarbonization by the yeast sector, we are currently unable to fully meet the established criteria, particularly regarding the intensity of indirect emissions. We believe this contradicts the stated objectives of supporting productive industries already engaged in concrete decarbonization efforts. Considering the above, to improve the consideration of our sector, we submit the following requests: 1. Recognize the Specificities of Prodcom Nomenclatures within NACE Sub-Sectors as in the EU ETS framework - The yeast sector (Prodcom 1089 1334) is a specific sub-sector of NACE 1089 (other food products) that warrants individualized evaluation. We request to the European Commission to include Prodcom nomenclatures in the granularity analysis for sectoral eligibility, as it was already done in 2018 within the EU ETS framework. Yeast production is a strategic activity that should not be conflated with the general category of "other food products. Its industrial process is distinct and is characterized by significant energy consumption, resulting in specific indirect emissions tied to its operations. 2. Renegotiate the Threshold for the Indirect Emissions Intensity Criterion, or Alternatively, Allow Eligibility Without Reopening the Update Procedure when Sectors Meet the Criteria (e.g., Year N+1) - Currently, our sector has an indirect emissions intensity ratio close to the threshold set at 1. We suggest: - The renegotiation and adjustment of this threshold to support high trade-intensive sub-sectors like the yeast sector, which have demonstrated a clear and proactive commitment to the low-carbon transition. - Guaranteed eligibility as soon as a sector meets the specified threshold, without waiting for the reopening of an updated procedure. As a reminder, the last update dates to 2013/2015. The revision of the criteria should also consider the electrification efforts undertaken by the industry. For example, the European yeast sector is currently involved in an ambitious decarbonization program, illustrated by projects such as the installation of high-powered heat pumps at some of our members facilities. These concrete efforts underscore our strong commitment to advancing toward a low-carbon industry. These adjustments to the criteria would ensure that our sector receives the vital support needed to reconcile competitiveness and energy transition, while maintaining its leadership in an increasingly competitive global market. We remain available to provide additional data or to collaborate actively to ensure that future rules are fully aligned with our shared objectives of industrial competitiveness and decarbonization.
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Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

7 Jul 2025

COFALEC, the Confederation of European Yeast Producers, welcomes the opportunity to contribute to the EUs review of the Emissions Trading System (ETS) and the Market Stability Reserve (MSR). As an energy-sensitive sector with both large and small industrial facilities, we are directly impacted by the EUs carbon pricing mechanisms. While we support the EUs climate neutrality objectives, we call for a stable, proportionate, and industry-sensitive framework that continues to enable decarbonisation without undermining competitiveness. Effectiveness of carbon leakage protection The current system of free allowances for sectors at risk of carbon leakage has worked effectively for yeast producers covered under ETS. These allowances are not passive subsidies but a vital instrument for enabling decarbonisation investments. Several COFALEC members have used them to implement tangible projects, including heat recovery systems and heat pumps, resulting in significant emissions reductions, in some cases exceeding 70% of site-level CO. Maintaining this system post-2030 is critical. Scope expansion oppose lowering the 20MW threshold COFALEC strongly opposes the proposed inclusion of installations with a thermal input below 20MW in ETS. Many yeast production facilities fall near or just below this threshold. Extending ETS to these smaller sites would impose heavy administrative and compliance burdens without delivering proportionate climate benefits, jeopardizing competitiveness. This is particularly concerning when considering the indirect effects of ETS II, which will already place additional pressure on smaller industrial players. We support simplification and consistency and urge that thresholds remain unchanged. Market Stability Reserve need for transparency We are concerned about the functioning of the MSR and its potential impact on allowance prices and availability post-2030. If MSR parameters are adjusted to tighten allowance supply significantly, this may reduce the pool of free allocations and raise costs disproportionately for smaller energy-sensitive sectors. We request greater transparency on how MSR reforms will balance market stability with industrial competitiveness. Interaction with non-EU carbon pricing systems With regard to potential interaction with non-European systems that are similar or comparable to the ETSor that ensure CO savingsany decision should include a sector-specific assessment. Such an evaluation should take into account the characteristics of complex food supply chains such as yeast production, as well as the costs, including administrative ones, that such approaches might entail. Integration of carbon removals We understand the Commission is exploring the inclusion of permanent carbon removal credits in the ETS. We recommend that any future mechanism maintains environmental integrity and avoids diverting attention from emissions reductions at source, particularly for smaller manufacturers with limited access to advanced technologies. Conclusion COFALEC calls on the European Commission to: Maintain current carbon leakage protection beyond 2030 Avoid lowering the 20MW ETS threshold and assess the indirect impact of ETS II Provide transparency and predictability on future MSR reforms Ensure any interaction with external carbon pricing or equivalent systems is preceded by a detailed sector-specific impact assessment, particularly for food supply chains Ensure simplification and policy coherence across ETS, ETS II, and other linked instruments COFALEC remains committed to supporting the EUs climate agenda and looks forward to further engagement on these issues.
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Response to Biotech Act

10 Jun 2025

COFALEC represents the European yeast industry as the Confederation of European yeast producers. The European yeast industry stands as the global leader in production volume, accounting for one-third of the worldwide yeast output. Established in 1959 and representing 29 production facilities across 22 EU Member States, the European yeast sector maintains its position as a global player, employing 3,500 individuals throughout Europe. COFALEC facilities produce over 1 million tonnes of yeast annually and 30% of production is distributed to markets outside Europe. The expansion of fermentation applications, particularly innovative yeast technologies, presents significant opportunities for advancing global sustainability, demonstrating the inherently sustainable nature of yeast-based solutions. COFALEC strongly supports the European Commission's Biotech Act initiative, which promises to strengthen Europe's position in biotechnology by establishing a streamlined, harmonized regulatory framework. This initiative should also enhance access to financing through effective public-private collaborations, foster innovation across the sector, and significantly accelerate market entry for novel products and technologies enabled by microorganisms. As a sector with deep historical roots in biotechnology, COFALEC believes the Biotech Act should focus on four essential pillars: 1. Strategic Recognition. Acknowledge biotechnologies as critical elements of EU competitiveness and resilience that address decarbonization challenges, enhance food security (through fermentation products such as yeast), and advance sustainability objectives. 2. Regulatory Efficiency Expedite market access and simplify authorization procedures by streamlining European regulatory processes to improve business viability while maintaining consumer confidence. We currently observe a troubling pattern of expanding regulatory requirements for product authorizations, resulting in prolonged evaluation periods and increased costs, directly undermining ROI and innovation capacity within the EU biotech ecosystem that aims to help EU to answer its objective for a sustainable food system. 3. Collaborative Innovation Strengthen public-private partnerships to foster long-term biotech innovation and research. These strategic alliances are essential for enabling technologies such as big data utilization (comprehensive databases, AI, modeling) and synthetic biology advancements such as NGT, while simultaneously driving strategic investments in biosolutions including alternative macronutrients (proteins) for Food & Feed, and plant care through biocontrol solutions. 4. Resource Security Safeguard biomass supplies for biotechnology applications by prioritizing biomass feedstock allocation for Food, Feed and Health to ensure long-term availability. We believe these recommendations complement the Commission's objectives of enhancing competitiveness while upholding safety standards, and we would welcome the opportunity to provide additional insights as the Biotech Act evolves.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

COFALEC is the Confederation of European yeast producers. Beyond the traditional applications of yeast in fermented food and drinks (bread, wine, beer), the European Yeast producers are committed to provide a wide range of solutions to achieve a more sustainable and low-carbon food chain. COFALEC supports the Green Deal’s ambition for climate neutrality in 2050 and the increased targets of renewable energy use in all the European union’s economic sectors. It appreciates the possibility to comment on the revision of this important EU renewable energy Directive. COFALEC welcomes and is relieved to see that the maximum share of food and feed crop usage to produce biofuels is proposed unchanged at 7%. This capping is a good compromise in terms raw material usage in food & feed versus energy. COFALEC also welcomes that this capping remains at member state level. It is essential to preserve this equilibrium in all member states. This capping also ensures that the future potential of expanding biofuels production lies with advanced biofuels based on industrial and biomass waste. COFALEC shares the Commission’s view that the change in the way the transport target is calculated, should indeed not affect these established limits. However, COFALEC would like to raise the following concerns regarding this proposal: 1. A too vague definition of residue - Given the importance of the notion of residue to define what is an advanced biofuel or biogas, this Directive should allow for much more precise definition to exclude high value coproducts with duly established and valued usage in food and feed usage. The current definition does not provide for such a clear distinction between low value residue and high value coproducts especially those used in the food and feed chain. - We strongly recommend to review the definition of residues (article 2 (43) to exclude high value coproducts and create a subgroup attached to the category “crop” to include them. High value food and feed uses should be prioritized over energy uses according to the waste hierarchy and its cascading principle. 2. The special case of molasses: they should and for good be excluded from the Annex IX The fact that molasses were included in the list of feedstocks to be reviewed with respect to their potential integration in the Annex IX is a proof that the current system does not provide sufficient safeguards to definitively prevent high-value co-products from being included in the list in Annex IX. Molasses are high value co-products generated during the sugar production process made from sugar beet in Europe. They contain a high sugar content (50%) and are also very rich in minerals (iron, calcium, magnesium and potassium…) making it an ideal food and feed product. Molasses are essential raw materials for the fermentation sectors and in particular the EU yeast industry which has no alternative to molasses and low green syrup to feed and multiply yeast as sugar sources. Molasses are already scarce in the EU with a structural deficit of supply. EU currently imports more than 30% of its need every year (1.8 Mt). Including molasses in the Annex IX would significantly increase the EU’s import dependency on this raw material and threaten the EU yeast sector in its entirety. Such sectors are, however, catalysts for essential innovation contributing to key European environmental strategies. Hence our sector strongly urges the Commission not to include molasses in the Annex IX of RED III to preserve its presence on the European territory. 3. The annex IX revision procedure COFALEC recommends the Commission to take the opportunity of RED II revision to allow to remove feedstock from the Annex IX during the regular revision exercise. Scientific and technical progress might trigger better use for raw material than for biofuels production.
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

COFALEC is the Confederation of yeast producers that represents the European Union yeast industry in Europe Essential to produce many emblematic fermented food (bread) and drink products (wine and beer), the yeast sector is also a key solution provider for healthy food and feed as well as sustainable agricultural practices. COFALEC welcomes the EU ambition to develop an harmonized green taxonomy system. This will be a powerful tool to support the growth of low carbon sector and accelerate the climate and ecological transition by helping target capital flows towards sustainable activities. This taxonomy and notably the Technical Screening Criteria (TSC) will allow for harmonization at Member States level regarding the required information from business and finance to identify sustainable activities. COFALEC appreciates the opportunity to provide feedback on this important work to ensure a European sustainable economy. We would like to emphasize a few key points to the current proposal: COFALEC would like to contribute in particular on the renewable energy component in the transport sector. First-generation biofuels are considered as transitional tools for decarbonizing transport. They are capped by European legislation and notably the European Directive for Renewable Energy (RED II) at 7% of the energy used in transport because they generate competition between food and fuel for the raw material usage and are responsible for indirect land usage generating negative environmental impacts and strong market disturbance in the food and feed sectors. COFALEC fully supports the Commission draft Delegated Acts (DA) which states that the TSCs should remain coherent with the sustainability criteria developed in RED II. As such first-generation bioethanol and biodiesel made from agricultural products used in food and feed should remain excluded from the Taxonomy-aligned activities. Only advanced biofuel, considered not to be based on food and feed products, should be included. To complement this approach, a full life-cycle assessment of all bioenergy feedstocks should be made to ensure compatibility with climate and emissions targets. The sector of the fermentation, including the yeast industry, provides efficient tools for the environmental transition and decarbonation of the economy in a wide range of sectors (food and feed chain, health, packaging, renewable energy, buildings, etc.). To provide some examples, the yeast sector can provide a wide range of products and services for the sustainability of the food chain (biofertilizers nondependent on fossil fuel, biofungicides, probiotics in livestock production to reduce antibiotics usage, new sources of plant-based proteins, etc.) The living systems of microorganisms (yeast and bacteria) used in the fermentation process serve as a low carbon impact production unit. They can produce organic acids, amino acids, proteins & enzymes, pharmaceutical ingredients, vitamins, bioplastics, bio resins and many other products through environmentally friendly processes. These related activities can provide services on 4 out of the 6 environmental dimensions targeted through the Green Taxonomy (climate change mitigation & transition to circular economy, pollution prevention, protection of biodiversity). The NACE code as it is structured and detailed does not allow to identify the activities generated by the fermentation sectors that could qualify as enabling sectors. Hence, COFALEC calls on the Commission to include these activities connected to the fermentation sector in the green taxonomy to strengthen their visibility as efficient tools to improve the environmental performances of the economy. These activities generated by the fermentation sector could be easily identified in the NACE classification as subclassification of certain codes to specify the part coming from fermentation.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

COFALEC, the European federation of Yeast producers, welcomes the initiative to review the EU Emissions Trading System Directive to align with the challenging -55% GHG reduction target by 2030 and to achieve carbon neutrality by 2050. COFALEC agrees with the proposal to broaden the scope of ETS to involve more economic sectors as we share the opinion that the efforts should be supported among the highest numbers. The Yeast sector is covered by the ETS system for a long time and it acknowledges the ETS efficiency to reduce carbon emissions. The functioning of the ETS system that takes into account all industrial sectors even the smaller sectors covered by a Prodcom 8-digits code, like the Yeast sector and lots of others sectors in food industry, should continue. Yeast sector was one of the first sector to assess its carbon footprint and develop its own Life Cycle Assessment, proof is of our long history of commitment towards a low-carbon industry. Our industry as a major exporter ask the EU to continue ensuring a level-playing field for our industries that have trade activities in regions outside the EU where carbon is not regulated.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

14 Jul 2020 · Yeast sector in the future European Green Deal and Farm to Fork Strategy