Confédération Européenne des Organisations Nationales de la Boulangerie et de la Pâtisserie
CEBP
CEBP represents more than 190,000 micro & SME craft bakeries and confectioneries, from 14 countries, employing over 2 million people in the EU.
ID: 710969625197-53
Lobbying Activity
Meeting with Giulia Del Brenna (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)
24 Oct 2025 · Exchange of views on challenges, problems and initiatives regarding European small bakeries and confectioners.
Response to Establishing a legal limit for the industrial trans fats content in foods
1 Nov 2018
European artisanal Bakers oppose the initiative of the Commission to introduce a limit of 2% of TFA content in food. The proposed legislation poses a severe problem. The current version of the proposed regulation is impossible to implement. Due to the small quantities of ingredients that artisanal bakers purchase from manufacturers and wholesalers it is often the case that there are no specifications given as to what the TFA content of an oil is, or at the least the seller will not guarantee that the delivered oil will be below the legal threshold. Since artisanal bakers do not have the testing infrastructure to control their ingredients, this would mean that a baker might unknowingly exceed the legal limit for TFA because of bad information from the supplier, and might then be fined for the infringement by the official control authority. Therefore, at the very least the Commission should introduce the following changes to the regulation to make it in some way manageable for artisanal bakers:
We propose a clarification in the regulation that fats and oils that are sold B2B may only exceed the threshold of 2% if the buyer explicitly requests it. Therefore there can still be flexibility for industrial producers that rely on a large variety of products, while artisanal manufacturers have a guarantee that they will not unknowingly use an oil or fat that exceeds the threshold.
Furthermore, reduction strategies regarding fried goods can have an adverse effect on the final product. Even when using compliant ingredients, the heat during the frying process might result in creating new TFA, which might cause the final product to slightly exceed the 2%. This can be avoided by frying at a lower temperature, which however will result in more fat absorption of the dough. Therefore, while the percentage of TFA might still be lower, the actual TFA content would still be higher that if it were fried at a higher temperature. While industrial production might give other mitigation possibilities, this is the only way to mitigate the risk of an elevated TFA production in an artisanal baking process. Surely this can be avoided by using stable oils in some products, but in many cases changing the oil would strongly alter the taste of the product. We would therefore propose that official controls should test the frying oil and the product before frying instead of the finished product. This would give certainty to the bakers while not significantly raising the TFA exposure of the consumer.
Thirdly, we see difficulties for low fat products such as whole grain bread with spelt grains on the crust. These seeds contain a lot of fat, and since they are on the crust they are exposed to very high temperatures during the baking process, which may cause TFA formation on the crust. Since these seeds make up a large percentage of the total fat content of the finished product, this may cause the entire product to exceed the threshold. We therefore propose to follow the example of the Austrian TFA legislation and to apply higher TFA thresholds for products with a very low total fat content.
Read full response7 Jul 2017
CEBP represents more than 190,000 small and medium-sized craft bakeries / confectioneries with over 2 million employees in the EU. Most of them are micro businesses. Craft, traditional bread has ever been a fundamental food in Europe and a main part of its diverse cultural heritage, linked to the territory and thus meaning a low carbon footprint. Therefore, craft bakeries / confectioneries in the EU should not be confronted with unfeasible requirements that no doubt would endanger traditional, regional recipes. All legal binding measurements and benchmark levels shall be based on scientific data and not on pragmatism.
Initially we want to thank the European Commission for this draft, since several improvements with respect to the demands of SMEs have been included, such as the exemption from continuous sampling and analysis of the acrylamide content in craft bakery wares -which would have become an unbearable financial burden for the most of our members - or the appreciation of extended yeast fermentation as a mitigation measure, which can be implemented easily in each craft bakery.
Since most scientific studies show that the presence of acrylamide is much lower in cereals than in potatoes and coffee, we suggest that point (3) of the introduction finishes as follows: “..such as potatoes, coffee beans and cereals”.
As regards introduction point (6), since HACCP methods are excessively expensive for micro FOBs, we consider that only the CoP of UEAPME –specifically designed for them- should be applicable to craft bakeries / confectioneries.
We welcome the clear classification of food businesses in Article 2 of the draft, especially in paragraph 2. Since the criterion “ready to eat food” has been removed and the delivery of “local retail establishments” doesn’t lead to an exemption from the application of annex II of the draft, most craft bakeries may fulfil the requirements of the draft regulation without any cost and time intensive requirements. Anyway, clear definitions of “local” and “interconnected operation” would be welcomed.
On the other hand, we deem it as worrying that avoiding a “dark roasting of the crust” is still enlisted in the mitigation measures in part A of annex II. The colour of the crust doesn’t have any influence on the content of acrylamide in bakery wares. A dark dough as a result of the use of dark ingredients will lead in every case to a dark crust, but this doesn’t mean that such a bread is “burnt” or “unhealthy”. Quite in contrary, wholegrain products, which are high in fibre and nutritionally highlighted as “healthy”, always have a darker crust since wholegrain flour is naturally darker than plain, white flour. Therefore, any regulation that incriminates dark products (e. g. wholegrain products) as “unhealthy” or otherwise adverse should be cancelled.
Anyway, the most adverse change compared to former revisions of the draft is the considerable lowering of the “benchmark values” for soft bread in annex IV. We can’t see any scientific approach for this; no newly published data is available. Former benchmark values have already been challenging enough for craft bakeries, but recent values are hazardous. Even the EFSA’s opinion concerning acrylamide in food in June 2015 states that “results from human studies provide limited and inconsistent evidence of increased risk of developing cancer in association with dietary exposure to acrylamide” and thus that “more research is needed to confirm these results from human studies”. Therefore, there’s no scientific background for this change in the legislative procedure.
That’s why we want to highlight that we explicitly deny any restrictions for single products that exceed these benchmark values, for example a withdrawal from the market. It should be made clearer that these benchmark values aren’t an indicator for food safety nor a legal limit. Any claims for a withdrawal of safe food from the market, thus leading to food waste, should be rejected by the EC.
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