Dutch Produce Association
DPA
Dutch Produce Association (DPA) is de sectorvereniging van de afzetorganisaties voor groenten, fruit en paddestoelen in Nederland.
ID: 18466902007-33
Lobbying Activity
7 Mar 2025
Dutch Produce Association is an industry body from the Netherlands that represents the interests of all recognized Fruit and Vegetables Producer Organisations in the Netherlands. Our number in EU- transparency register is 18466902007-33 DPA welcomes the opportunity to react on the REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) No 1308/2013, (EU) 2021/2115 and (EU) 2021/2116 as regards the strengthening of the position of farmers in the food supply chain. 1. Article 153 under b (2a) Regarding the Commissions' proposal on article 153 under b (2a): the main objective of a Producer Organization is concentration of supply and placing of products on the market by the producer organisation. We would like to emphasise this -as always- as the main objective of the PO. In the proposed text the current legislation is changed into "the objectives pursued". We think this is not specific enough for our F+V sector, so we propose to remain at the current text 2013/1308, 153.2bis and do not change it as proposed. 2. Article 88a. Optional terms for commercial modalities In article 88a proposals are made to define terms as "fair", "equitable" and "short supply chain". Currently these terms are used as marketing tools in wholesale/retail markets for promotional purposes. Besides the large and intensive EU-wide discussion of defining these terms, we foresee a large administrative burden and an intensive process of audits and inspections if this is to be regulated by authorities. The highly appreciated labels "organic" and/or "GI" are already in the markets. Creating these new labels ("fair", "equitable" and "short supply chain") and defining and controlling them by EU legislation will lead to more confusion for consumers , and an increase in prices. We are in favour of NOT regulating "optional terms of commercial modalities". This draft regulation is in direct conflict with the Green Claim Directive, which aims to empower consumers towards the green transition by regulating sustainability claims and tackling misleading claims with clear and reliable information. Products using terms like "fair" must have a label based on an independent certification system, audited by a third party in accordance with European rules, and apply to both EU and imported products. Since the Commission adopted Recommendation 2013/179/EU in 2013, the Product Environmental Footprint (PEF) method has been developed. This method helps companies make substantiated claims, reduce assessment costs and improve product comparisons. The fresh fruit and vegetable sector is and has been investing in developing Product Environmental Footprint Category Rules (PEFCR). Setting any other definitions as proposed in Article 88a will therefore undermine the objectives of Directive 2024/825. 3. In article 168 proposals are given on contractual relations. The fruit and vegetable supply chain is highly volatile and changes daily. Harvest times are dependent on weather conditions, produce is highly perishable, and the supply chain depends on the ripening process / maturity of the fruit and or vegetable (including seasonal supply). In this case we plead to exempt the fruit and vegetable sector completely - and more specifically EU 27 - from the proposed obligation of written contracts or offers (art. 168.6.b). Writing contracts for highly volatile daily trade, then uploading them in a MS system etc. will cost valuable time, perishables will lose quality and value, and the proposed increase of time will cause food loss in the supply chain. As the trade between producer and first buyer is inter EU MS, we do not think it wise to have a difference between MS regarding perishables under art. 168.9. In summary: we propose to move art. 168.b (for perishables such as Fruit and Vegetables) under a new article 168.5.e.
Read full responseMeeting with Tom Berendsen (Member of the European Parliament) and Land- en Tuinbouw Organisatie Nederland and Glastuinbouw Nederland
24 Oct 2023 · Agricultural and Horticultual Gathering (network event)
Response to Revision of EU marketing standards for agricultural products
16 Feb 2021
Reaction DPA on Impact Assessment on the revision of EU Marketing standards for Agricultural Products, revision of marketing standards
DPA represents the Dutch producer organisations for Fruit and Vegetables (F+V). Together with FPC she represents over 80 % of Dutch production, including traders, importers and exporters
We would like to give the following observations regarding the objectives and expected impacts
1. The marketing standards for F+V has been reformed 10 years ago. For now there is no reason to elaborate any adjustments. Standards do not lead to food waste in any case, they prevent food waste in the F+V chain. Some small adjustments can be made on the standards in future:
- Change and adapt of the legislation to new developments as E-commerce and modern packaging
- Improvement of the labelling legislation for mixed packaging (remove the obligation of the labelling of each country (of EU) origin and change for "country of origin: EU").
2. Besides existing legislation on marketing standards, European produce has to comply with EU legislation on plant health, food safety, animal welfare etc. etc. For the following reasons it is impossible to add "sustainability items" to the existing marketing standards on quality:
- Level playing field: all MS have different objectives in sustainability, produce is marketed all over the EU. Will internal borders appear in the EU market if a certain produce does not comply to internal regulations in a MS ?
- Extra time and costs for audits and inspections, to be paid by producers who cannot refund those costs.
- Due to the fact of extra costs for the MS, private labels such as GlobalGAP, have never been adopted by the EU to be a part of any legislation or regulation.
- There is still no clear European definition of sustainability. Therefore it will be complex to decide what criteria can be applied and which ones cannot be applied.
It seems to be more logical to develop a special program / label on sustainability aspects. The EU PEF (Product Environmental Footprint) will give good information of the impact of each product which is produced in a MS of the EU. See https://ec.europa.eu/environment/eussd/smgp/ef_pilots.htm and https://ec.europa.eu/environment/eussd/smgp/ef_transition.htm. For F+V in The Netherlands a clear methodology has been developed: https://www.wur.nl/en/Research-Results/Onderzoeksprojecten-LNV/Expertisegebieden/kennisonline/Methodology-for-environmental-footprint.htm
3. Fruit and Vegetables are already being considered as very healthy and sustainable products which do fit in every EU diet. Any additional marketing standards for F+V might give consumers a thought that some F+V is less healthy or less sustainable. A higher daily intake of F+V as part of a shift to a more plant based diet might lead to a more healthy society.
4. Introducing new marketing standards will not lead to an increase of the consumption of organic produce in the market as there is already an organic label.
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Read full responseResponse to Fruit and vegetables sectors - Recognition criteria of producer organisations and operational programmes
22 Dec 2020
Dutch Produce Association welcomes the initiative of the European Commission to amend Commission Delegated Regulation (EU) 2017/891. We agree with the proposals and changes but would like to point out that some issues are not taken into account yet:
1. To overcome a real administrative burden, in article 12 1.b) the word "concerned" should be deleted and replaced by "of which the PO is recognized". Volumes of type of certain type of produce that is marginal to the total gamma of the PO should be allowed to be marketed by the member itself.
2. Article 12.1 should be extended by an article D that for a member of the PO, regarding point a, b and c, it is allowed to promote through social media his own company / organisation, products produced, recipes, production methods etc. and other relevant information
3. New Fruit and Vegetable products are produced now by members of the PO, we would like to see that products such as Sweet potatoes, Ginger, Sweetcorn are taken into account under the CMO scheme
4. Actions on sustainable packaging should be eligible too // enabling the eligibility of sustainable packaging under the fruit and vegetable CMO. Usage and management of packaging aimed at reducing food waste and emission and increasing shelf life of fresh produce should be eligible
Read full responseMeeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)
24 Jan 2020 · The role of the fruits and vegetables sector in the Green Deal
Response to Enhancing Market transparency in the agri-food chain
19 Jun 2019
Dutch Producers Association represents the Dutch Producer Organizations (PO's Fruit and Vegetables). For the F+V sector we would like to give some detailed remarks about the proposals on adjustment of 1185/2017. Major aspect is to make clear definitions to the commodities involved and to bring 891/2017 and the proposal on 1185/2017 in line with each other. Some adjustment of 891/2017 are foreseen. This will lead to a better transparancy and less administrative burden and a thus better functioning of the market.
Read full responseResponse to Commission Regulation setting maximum residue levels for chlorate in or on certain products
18 Feb 2019
The Dutch Produce Association (DPA) is the Dutch sector association for marketing organisations of fruit, vegetables and mushrooms. We welcome the opportunity to react on the Commission proposal SANTE/10684/2015 Rev. 3 to amend Annex III to Regulation (EC) No 396/2005 as regards MRL for chlorate. Enclosed you will find our reaction.
Read full responseResponse to Specific Common Market Organisation rules in the fruits and vegetables sector
8 Feb 2017
Remarks Dutch Produce Association, 08.02.2017
We would like to thank the EC for the opportunity to give comments. The main reason for the proposed DA/IA is to comply to the Regulation 1308/13. We think a major step is made. Secondly, due to ongoing audits at the level of PO and interpretation of 543/11 lots of problems occurred in the recent years. MEP, politicians and the European Commission started in the EU a process of simplification and clarification to overcome this. Unfortunately, although we think a lot of things are improved, on some topics only small steps are made on clarification/simplification/interpretation. Our main concerns/remarks:
1. Marketing outside the PO: DA, Article 12.2: “The percentage shall not exceed 25% of the volume”. Due to audits we urge the EC to go back to the system of 25% of the sales (turnover). The bookkeeping and financial accounts of the famer and PO can prove in an audit all the sales. When farmers sell F+V to consumers it is hard to do accounting on volumes. Sometimes bags, baskets are sold per piece in stead of per volume. Text suggestion: “However Member States may set a lower percentage or change the 25% of volume, on the request of a PO, mutates mutandis into 25% of the total turnover of a producer member”.
2. Transnational PO: DA, Article 14.2: Re-movement of the headquarters of a TR-PO: We think that the period should be extended to the period of at least 2 operational programs. If a HQ is moved after 1 period, due to changed circumstances it might be moved again after the second OP. Secondly, proposed is that both Member States should agree. The content of an OP (and National Strategy) in both Member States is according to the local chosen strategy (local: the location of the headquarter) . The PO might be set back in their possibilities if a forced movement of the HQ should be made. Article 14.3 should be extended, we think that the full OP of the TR-PO should be under only 1 NS.
3. Recognition of a APO and OP: DA Article 19.5 We miss the expletive fact that the NS of the country in which the headquarter of the APO is located shall comply for all members of that APO.
4. Conditions for the extension of rules: DA, Article 68, under 1b We think that a derogation should be possible as well for Regulation 1308/2013, under article 164.4 under “d” and “k” When there is a market crises or need to change the process of market F+V due to consumer aspects (e.g. sustainability aspects) a MS should have the possibility to derogate in a more early stage then after 365 days. Secondly, we are worried about the procedure of approving the rules by the European Commission, in especially the timeframes that are not mentioned. Because of the importance of a quick measurement, a quick extension of the rules, we think that the maximum time for the European Commission to agree on the derogation should be a period of 1 month after the notification by the MS.
5. Unclear, multi-interpretable, no coherent text proposals on definition of fiscal depreciation period and specific costs
DA, Article 31.4: We think because of clear legislation the text should be changed. This article should only be taken into account during the period of “as mentioned in 31.5 under B” or as mentioned under 31.5 in the last part “However……..council”.
DA, Article 31.5 after point C “However…………Counsel” . For the purpose of clarification and no multi – interpretable regulation: If a MS set a period smaller/ shorter then fiscal depreciation period the following articles are involved: 31.6. last sentence, 31.5. (C ), 36.2.(B) and IA article 3.4
DA, Article 36.2 under b: See our remarks given at 31.5 Because of the purpose of clarification, in the text should be an addition after “…to in Article 31(5) : “until the end of the deprecation period or the by MS agreed term.
DA Article 2 (m): unclear definition, “income foregone” is multi-interpretable.
DPA represents over 80 % of Dutch F+V industry.
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