Euro Coop - European Community of Consumer Co-operatives
EURO COOP
Euro Coop promotes to the European institutions the economic and social objectives of Europe's consumer co-operatives.
ID: 3819438251-87
Lobbying Activity
Response to Legislation for plants produced by certain new genomic techniques
13 Jul 2023
We are concerned that the proposal reflects the initial intention of the EU Commission to deregulate some GMOs as defined by European Court of Justice, and that it's based on political considerations rather than scientific evidences. Practically, some genetic techniques can be used to generate plants that will be deemed safe assuming their genome could be the result of natural mutation or traditional mutation or breeding with compatible species. We find the assumption that the technique (ie NGTs) has not influence on the final result highly faulted and unjustified and the concept that if something can be produced in nature is safe equally profoundly wrong. In fact, the ways the molecular scissor are integrated into the receiving DNA are just the same as the conventional GMOs and are matter of concerns on their own regardless of the nature of the gene introduced. We don't understand how the number of nucleotides that can be inserted or replaced (20) has been chosen and we're certainly concerned that deletion can involve any number of nucleotides. This approach is a mechanistic one and ignores altogether the complexity and interconnection amongst different DNA regions and genes and possible unexpected effects. Although NGT-1 still will be banned from organic products, the lack of basic information and ex-post traceability and monitoring makes it quite difficult, if not impossible, to apply. Organic farmers will never know whether their neighbors use NGT-1 plants and contamination is quite unavoidable adding technical and administrative burdens to organic food producers. Furthermore, if an organic product is found to be or to contain an NGT-1, its subject to market withdrawal regardless of whether it is intentional or accidental making organic farming less appealing . The lack of any traceability and monitoring will make it almost impossible for the EU Commission to gather the necessary information from proponents / Member-States in view of preparing the monitoring report expected after the first 5 years. In particular, in the absence of strict pre-established criteria, it would be impossible to demonstrate risks to human / animal health and the environment due to the genetic modification in authorized / notified product(s). While NGT-2 will be subject to stricter conditions, as the text stands currently, it would be impossible to verify possible unexpected / side effects, because of the possibility offered to food/feed producers to be waived by the provision requiring detection and quantification methods and ex-post monitoring. We think that the self-evaluation left to proponent to decide whether it might or might not present any danger for human health based on their own environmental impact assessment is highly risky and inadequate. The new rules are likely to reduce the freedom of choice of food producers and consumers and to increase the uncontrolled widespread of plants and products whose safety is merely conceptual and lacks of scientific ground, On the other hand, Member-States will lose the right to ban cultivation on their territory or part f it for any NGT plants notified or authorized at the EU level. This could have very negative effects in those areas where particular (i.e. organic) food production occurs that could be challenged by the release of genetically modified varieties.
Read full responseMeeting with Kurt Vandenberghe (Director-General Climate Action) and European farmers and
27 Jun 2023 · Fit for 55
Response to Ensuring that hazardous chemicals banned in the European Union are not produced for export
15 May 2023
Euro Coop represents 20 members across Europe (15 in the EU) that are owned by some some 30 millions members of consumers' cooperatives. As Consumers' cooperatives, we share principles and values that are aimed to ensuring the highest level of safeguard for humans and environmental health. For that reason, we cannot accept that double standards are applied when it comes to dangerous substances that are banned for use in the EU but still produced for the export market. We do think that a fair approach should be one banning the production of chemicals whose use is forbidden within the EU .
Read full responseMeeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and Greenpeace European Unit and
3 May 2022 · New Genomic Techinques
Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and Greenpeace European Unit and
3 May 2022 · New genomic techniques
Response to Food waste reduction targets
29 Oct 2021
Euro Coop lauds the European Commission's initiative to take action against food loss and waste by setting legally binding targets to halve food waste across the EU by 2030. As ethics-based, values-led and principled-driven retailers, consumer co-operatives place sustainability in its economic, social and environmental dimensions at the core of their action.
In the past decade, reducing food waste has been a focal point for consumer co-operatives leading to optimized supply chains and own operations, establishing new partnerships, communicating better and differently with consumers. Different actions have been amplified by our members in Italy, Sweden, Spain, Finland, Norway, The Netherlands and UK.
Since 1844, Consumer co-ops are inherently committed to consumer education and to transparent, sustainable and responsible business undertaking. We believe we have a role to play in creating a “culture of food value” for our consumer-members and their local communities, which is indispensable to the transformation of our food systems.
The scope of the target should include the value chain in its entirety, otherwise,7 the attainment of the targets may be compromised. An integrated and systemic approach is believed to be the most appropriate in advancing the EU green ambitions. Furthermore, we fully support the Commission’s plans to achieve effective policy coherence so that any potential contradictions and/or overlaps be identified in due time.
Data indicate that the retail sector has been most successful in cutting food waste and is thereby the least contributor with only 5%. No one sector should shoulder the entire burden, so the responsibility must be shared by all economic operators, civil society organisations and national stakeholders.
Read full responseResponse to Sustainable food system – setting up an EU framework
26 Oct 2021
The below are general remarks. For detailed input please refer to the attached document.
Euro Coop welcomes the commitment to develop a framework law in the Farm to Fork Strategy and this Inception Impact Assessment (IIA). We share the Commission’s analysis of current regulatory and market failures, as well as of the possible positive impacts linked to the transition towards sustainable food systems. We welcome, in particular, the Commission's recognition of the need for new foundations in EU food policy. Our 2019 European Parliament Elections Manifesto identifies an EU Common Food Policy as a top priority.
Data unequivocally conclude that short-term approaches need to be avoided when focusing on the possible challenges of a food system transformation. Instead, addressing the failures of the current model is an urgent obligation. There are no other options if we want to ensure a future-proof EU agri-food sector.
We agree that the overall aim of the Sustainable Food System (SFS) law should be “to make the Union food system sustainable” through an integrated approach. This surely reflects the great progress the EU is making in advancing its green ambitions.
We consider as important the acknowledgment that the current food system is based on market failures and market distortions because true cost accounting is missing. Profit logic and power imbalances in the food chain are detrimental to society.
Euro Coop attributes top priority to the SFS law dossier, since our members are food operators with far-reaching social and environmental responsibility. Since 1844, consumer co-ops are inherently committed to consumer education and to transparent, sustainable and responsible business undertaking, which is why we believe we have a role to play in creating a “culture of food value” for our consumer-members and their local communities, which is indispensable to the transformation of our food systems.
Read full responseResponse to Animal welfare labelling for food
23 Aug 2021
Euro Coop welcomes this Inception Impact Assessment (IIA) and the Commission’s commitment under the Farm to Fork strategy to revise existing EU legislation on animal welfare. Indeed, the current legal framework results as outdated, not just in light of more recent scientific and technological developments, but also with respect to consumers’ understanding and expectations concerning the EU standards.
Euro Coop therefore supports the broadening of the scope of the legislation and shares the view that animal welfare has a major role to play in increasing food systems’ sustainability. To this end, Article 114 of the Treaty of the Functioning of the EU provides an appropriate legal basis for new legislation, alongside Article 13. In this sense, Euro Coop agrees on the need to expand the legal protection to other species not yet covered under the existing measures, in particular for farmed fish, and praises the integration of a Five Domains approach to guide further developments in the sector.
Please find our full response in the attached document.
Read full responseMeeting with Nicolas Schmit (Commissioner) and
15 Apr 2021 · Pact for skills roundtable with the retail sector.
Meeting with Thierry Breton (Commissioner) and EuroCommerce and
15 Apr 2021 · Skills roundtable with the retail sector
Response to Setting of nutrient profiles
3 Feb 2021
Euro Coop welcomes the EC Commission Inception impact assessment on food labelling and praises the commitment to define nutrient profiles, which shall support the harmonisation of health claims as well as of front-of-pack nutrition labelling (FOP). Although the FIC Regulation and the Nutrition and Health Claim Regulation provided a clear and effective legal framework in the area of food labelling, we acknowledge that a proliferation of labels currently leads to market fragmentation, misleading claims and challenges to consumers’ ability to make informed choices towards healthier and more sustainable food products. In light of that, we believe it is necessary to adopt new EU provisions and ensure they facilitate the achievement of the Farm to Fork’s objectives for a food systems transformation. In this regard, we appreciate the EU Commission’s attention to the digitalisation of labels as this could allow the inclusion of more comprehensive food information, while simplifying the display on the packaging.
Enabling consumers to meet the highest level of sustainability and health in their grocery shopping has always been a core priority for Euro Coop members, therefore they fully support the adoption of nutrient profiles at the EU level. Some of them have already set these criteria for labelling their own branded products and are willing to inform the process, the others are eager to engage in the discussion and implement them. While the discussions on nutrient profiles and FOP are inevitably interlinked, we encourage the EU Commission to prioritise the former matter without any further delay, if circumstances will require it.
Concerning the front-of-pack nutrition labelling, Euro Coop, who represents consumer co-operatives in 19 countries within and beyond the EU, considers it important to stress that science-based and independently established principles are the pre-conditions for harmonising nutritional information and fostering consensus under EU stewardship. To curb the obesity pandemic and improve consumers’ food literacy effectively, EU-level complementary actions are pivotal and shall cover other relevant areas, for example ensuring access for socio-economic disadvantaged groups, re-shaping food environments to tackle high exposure to unhealthy foods and investing in nutritional education (including use and interpretation of any EU mandatory FOP option). These areas are becoming even more important in light of the striking economic crisis linked to the COVID-19 pandemic. We would also support any analysis of FOP options carried out in a view to improve the underlying criteria, in particular in light to reflect regional and local nutritional specificities to a sufficient degree.
Euro Coop members have also recorded consumers' growing concern on the origin of the food they buy and they support EU-level action to harmonise information provided. Origin labelling could be a relevant tool also for encouraging shorter supply chains, although the accompanying message to consumers shall focus on favouring national/local foods as a means to improve sustainability and cherish national/local specialities, while clarifying further that the quality/safety standards are equal across the EU bloc.
Finally, we are fully committed to any initiative to help European households cutting food waste at home and we will contribute to the implementation of revised EU rules on data marking. To tackle this issue, consumer co-operatives highlight that consumer education is crucial to reduce the unnecessary discarding of food, especially as several studies pointed out that ‘best before’ products constitute a limited amount of the food wasted. We therefore encourage further research on information needed to foster consumer understanding of data marking.
Read full responseResponse to Farm to Fork Strategy
16 Mar 2020
Euro Coop welcomes the opportunity to provide the voice of our 30 million consumer-members to the consultation on theRoadmap for a Farm to Fork Strategy.
Engines of sustainability already exist. As operators in retail, consumer co-operatives utilize their distinct business model to engage, galvanize, inform and empower consumers, while fostering social responsibility and community belonging.
Being member-owned and democratically governed ensures the participation of consumers in the decision-making process and, thus, in the shaping of the food supply chain. Our governance model translates into a sustainable and responsible business conduct enshrined in the organisations’ Statutes. As such, consumer co-operatives are proven enablers of sustainable food systems as per the triple bottom line.
From a ‘Farm to Fork’ perspective, consumer co-operatives are a natural connector among every actor of the supply chain: on one side, their direct and long-term partnerships with primary producers foster sustainable farming practices, and on the other, their in-store initiatives facilitate more responsible patterns of consumption by increasing availability and access to healthy, sustainable and nutritious foods.
Championing radical transparency across the entire supply chain as means of maintaining highest consumer trust, Co-op own-brand products prioritize shorter supply chains, responsible sourcing and fair price policies to contribute to the livelihood of both farmers and consumers.
The core mission remains serving our consumer-members by meeting their needs and aspirations, enabling their informed choices underpinned by transparent labelling and innovative packaging solutions, which also enable proper recycling. Co-op own brand products represent the means to operationalise our principles, values and ethics. Co-ops’ societal commitment also sees decades-long programmes for developing school materials and vigorous awareness-raising of societal challenges, such as combating food waste and obesity, especially among children.
Key Euro Coop Priorities within the Farm to Fork Strategy:
1. The Strategy should reference examples of business models, such as consumer co-operative, conducive to the sustainability triple bottom line.
2. A prominent focus should be devoted to information and education as they are key aspects for effective change.
3. Mandatory front of pack (FOP) nutritional labelling and nutrient profiles.
4. Revitalising rural areas through sustainable food systems is of critical importance to achieving the Strategy and the Green Deal’s ambitions.
5. Stringent commitments to ensuring consumers and primary producers are protected from AMR.
6. Harmonisation of National Sustainable Dietary Guidelines.
7. Foster sustainable and healthy food environments.
8. It is adamant to apply the Circular Economy thinking.
For further information, please consult the attached document.
We wish you the very best in your work!
Read full responseMeeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)
27 Feb 2020 · Farm to Fork Strategy
Response to Fitness Check on endocrine disruptors
10 Jul 2019
Several consumer co-operatives across Europe have a long tradition of going beyond legislation in order to protect consumers from hazardous chemicals including EDCs, especially by rigorously applying the precautionary principle. For instance, Coop Denmark has banned EDCs in all private label products and Coop Italy has phased out per- and polyfluoroalkyl substances (PFAS) from all its own-branded personal care line. Coop Denmark has also recently extended PFAS banning to all its non own-brand suppliers. From its side, the S-Group in Finland applies the precautionary principle for the EDCs used in cosmetics, personal care products and household detergents. According to their quality requirements, substances evaluated by the EU or other leading official organizations as causing or potentially causing endocrine disruption must not be present in their private brand products.
Against this background, consumer co-operatives grouped in Euro Coop call on the European Commission to act more boldly and more swiftly when it comes to EDCs in order to better protect consumers and the environment. In this respect, we would like to draw its attention to the need to act on the following points:
1) Allocate more resources to the development of a “thorough research basis” on which to base policy on EDCs, especially when it comes to:
- Formulating clear definitions: this will allow the subsequent identification of the doses allowed into the manufacturing of a given consumer good - “safe level of exposure” – or, alternatively, determine that no safe level exists;
- Investigating how multiple endocrine disruptors can work together to create compounding effects (“cocktail effect”);
- Investigating the nexus between cosmetics and EDCs: sunscreens are for example under suspicion of containing EDCs. Whilst the connection is not clear, opt for safer alternatives which are already available on the market (e.g. under the Swan label);
2) Take a “group approach” in legislation. For example, for bisphenols, only Bisphenol A (BPA) is well regulated whilst it is not the same for several other bisphenols presenting the same problematics. Also, in the case of PFAS, EFSA has recently announced a lowering of the Tolerable Daily Intake (TDI) of 1750 times and regulative action from the EU is still lacking. Also in this case, a “group approach” could allow for a much needed swifter regulation to the benefit of consumers and the environment;
3) Consider the costs of inaction. Allowing hazardous and harmful chemicals into consumer goods has a derived cost for all EU-members. Formulate KPIs which include such costs will help securing the necessary EU and national funding for public research programmes as well as boost product innovation at company level;
4) Evaluate essential use for all harmful chemicals;
5) Keep the same requirements for recycled material as for the virgin one;
6) Develop testing methods in order to be able to assess consistently chemicals which are continuously created and put on the market untested; For instance, there is estimated 5000 different PFAS in global circulation, but by using harmonized testing standards we are only able to test for 45 specific PFAS in textiles;
7) Boost uptake of the EU Ecolabel or equivalent (e.g. Nordic Swan) and work for the criteria which allow for their obtention to be continuously strengthened following the latest scientific findings;
8) Better enforce legislation on imports from outside the EU as well as on consumer goods bought online;
9) Encourage an active dialogue among scientists, public authorities and private actors in the field;
10) Contribute to creating a marketplace which is more aware of the environmental and health challenges posed by hazardous chemicals through ad-hoc communications campaigns;
11) Boost B2B and business to regulators information exchange on hazardous chemicals;
12) Recognize the importance of early warnings and apply consistently the precautionary principle.
Read full responseResponse to Evaluation of Geographical Indications and Traditional Specialities Guaranteed protected in the EU
27 May 2019
Euro Coop is the voice of the co-operative retailers in Europe. Our association brings together the national associations of consumer co-operatives in 20 European countries. Euro Coop’s members together are Europe’s second strongest retail force – accounting for € 76 billion in annual turnover from sales. Euro Coop appreciates that EU countries’ food production offers an exceptional level and unique variety of food specialties; because of this the EU food sector is widely considered around the world as a synonym of excellence. The EU quality schemes are therefore of utmost importance for ensuring protection and recognition of high category products. In particular, quality schemes that link products to a certain territory or to a specific production technique ensure increased awareness in third countries’ markets of the special characteristics and advantages of EU products. This is crucial particularly for some of Euro Coop members, specifically when it comes to the ‘Made in Italy’ brand for foodstuffs. However, in an increasingly demanding market, this regime alone risks of being not sufficient and should be integrated by quality certifications of the companies that manufacture the products as well as by certifications for all the activities carried out along the different stages of the supply chain. We believe that the European Commission should propose standardized rules covering also the implementation of GI controls and the certification systems. Both activities are crucial for the functioning of the EU quality schemes regime but differ greatly across Member States. For example in some countries there are not control procedures specifically designed for verification of GIs and distinguished from the system of national controls on food safety, allocation of resources are not always sufficient, the sanction systems against the unlawful production or marketing of products are not equivalent in different Member States. The role that geographical indications and traditional specialties have played so far in adding value to high-quality EU food products remains fundamental and we welcome a debate on the necessary future improvements.
Read full responseResponse to Establishing a legal limit for the industrial trans fats content in foods
31 Oct 2018
Euro Coop appreciates the opportunity to comment on the Commission draft Regulation amending Annex III to Regulation (EC) No 1925/2006 of the European Parliament and of the Council.
Due to the undeniable negative effects of TFA consumption, which leads to the risk of developing cardiovascular diseases, Euro Coop welcomes the initiative of the EU Commission to introduce a legal limit on the TFA content of food. However, by echoing other stakeholders’ views, we also call on the EU Commission to clarify further whether the 2% of total fats limit applies to the final food product or to the ingredients used.
The core co-operative value that distinguishes consumer co-operatives from other retailers is that co-operatives are democratically-controlled by consumers, who are also members of the co-operative. Due to this, Euro Coop members have always placed a great importance on promoting healthy and nutritious food to consumers, particularly as a way to meet their needs and expectations.
In particular, Euro Coop members have launched several initiatives for reducing the consumption of TFAs among the EU population. These initiatives generally aim either at informing the consumer about the presence or absence of TFAs in certain foods, or at reformulating products so as to minimize their TFA content. Special attention is given to own brand products which present an additional guarantee to consumers as to the care that is given to formulate that particular product.
Due to this, Euro Coop considers that a mandatory EU wide regulatory measure, as it is proposed by the EU Commission, would limit market fragmentation within the EU by ensuring the legal compliance of all food business operators. Indeed, voluntary measures have not always proven to be effective in this domain. In addition, studies have shown how limited consumer awareness and understanding of TFAs currently is.
Therefore, removing the presence of industrially produced trans fatty acids from the food supply would have a direct positive effect on citizens’ public health and help saving healthcare costs. In light of these considerations, Euro Coop fully supports the introduction of a mandatory upper limit on TFAs as the most effective policy option.
Read full responseResponse to Bisphenol A in varnishes and coatings and plastics intended to come into contact with food
19 Sept 2017
Euro Coop welcomes the European Commission’s draft Regulation on Bisphenol A (BPA) in varnishes and coatings as well as in plastics intended to come into contact with food and the opportunity to comment on it.
Euro Coop - or the European Community of Consumer Co-operatives - brings together the national associations of consumer co-operatives in 19 European countries. Being its members mainly active in the food retail business, it has a keen interest in this most topical issue.
Consumer co-operatives were born from the desire to safeguard consumers’ interests by providing quality foods at reasonable prices and represent an entrepreneurial model whose primary goal is to satisfy consumers’ needs and expectations rather than to chase absolute profit goals. In this respect, all chemicals policies which affect consumers especially in the food area are of special concern to them.
Euro Coop policy on chemicals is basically grounded on the following principles:
- The precautionary principle: manufacturers or importers must ensure that any substance which is marketed in the EU does not adversely affect human health or the environment;
- Consumer protection: chemicals policy must be comprehensive and follow a life cycle approach, thereby including the phases of consumer use, dispersion and disposal;
- A full right to know, including which chemicals are present in products;
- A phase-out of persistent or bio-accumulative chemicals;
- A requirement to substitute less safe chemicals with safer alternatives;
- Producer responsibility: the burden of proof should be placed on producers who would have to prove that a substance is not harmful to the environment in its production, use and disposal;
- A development of criteria for persistency, bioaccumulation, and toxicity.
Against this background, many Euro Coop members have since long adopted full rounded chemicals policies which also touch upon the use of Bisphenol A. For example, the Basque consumer co-operative Eroski does not use BPA in any of its own-branded products, the Swedish Coop has eliminated the use of BPA in receipts and the Danish Coop has banned BPA and other bisphenols in June 2016, replacing them with epoxy lacquer in cans in co-operation with the Danish packaging industry association. As far as the Finnish consumer co-operative SOK is concerned, it is in the process of replacing all own-brand packaging materials containing BPA: the complete substitution will be finalised by 2018.
Euro Coop believes that, among the various food contact materials identified by EFSA in the BPA risk assessment, it is essential that plastics and coatings & varnishes for metal packaging are addressed first because of their widespread use in the EU market. This is even more important for metal packaging containing baby foods, for which it should be mandatory to avoid any contact between BPA and the food itself.
Besides these first urgent steps, Euro Coop deems that the final goal should be for the European Commission to come up with a full-fledged BPA policy which puts environment and consumers’ interests at its core and ultimately phase out not only BPA but all bisphenoles, given the likelihood for those to have similar hormone disrupting effects. This is ultimately even more relevant when – as in these cases - safer alternatives are already available and represent a viable commercial option.
About Euro Coop
Euro Coop is the voice of the co-operative retailers in Europe. Our associations brings together the national associations of consumer co-operatives in 19 European countries, which represent 4,500 local/regional co-operatives, employing 500,000 citizens across Europe and operating 36,000 stores which serve 32 million consumer-members daily. Euro Coop’s members together are Europe’s second strongest retail force – accounting for € 76 billion in annual turnover from sales. Its Secretariat is based in Brussels.
Read full responseMeeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis)
7 Jul 2017 · Euro Coop's 60th Anniversary & Academic Conference
Response to Changes to greening rules and clarifications of certain other direct payments' rules
12 Jan 2017
Ecological Focus Areas (EFAs) were created as per Article 44 of Regulation 1307/2013 in order “to safeguard and improve biodiversity on farms”. Euro Coop supports the statement by the European Economic and Social Committee that “the fact that the use of pesticides is to some extent permitted in ecological focus areas is diametrically opposed to the intention of greening agricultural policy: pesticides do not help to increase biodiversity but rather limit it”.
We welcome the addition of paragraph 10b to Article 45 to ban the use of plant protection products on some Ecological Focus Areas. We strongly believe that public money should be used to enhance public goods, welfare, and benefits in general. Hence, in this instance, no synthetic plant protection products should be used on EFAs. The so-called “plant protection products” like these have no place in areas specifically established to support biodiversity and the proper functioning of ecosystem services. As co-operative food retailers, we understand the importance of sustainable food production systems and all the resulting responsibilities and expectations of local communities. One of the core responsibilities to our members and customers in general in this area is food security, which is intrinsically dependent on biodiversity and properly functioning ecosystem services. To make a genuine transition to a green(er) economy, Euro Coop firmly believes that a ban on the use of plant protection products in Ecological Focus Areas is an absolute minimum.
Euro Coop, along with 10 other signatories, co-signed a letter on 9 April 2014 to Dacian Cioloş, then-Commissioner for Agriculture and Rural Development on the issue of the implementation of CAP and the enhancement of agro-ecological solutions. The letter specifically addressed the issue of banning synthetic pesticides and fertilisers on ecological focus areas.
Read full responseMeeting with Vytenis Andriukaitis (Commissioner) and
30 Jan 2015 · The Food Chain, Innovation and Challenges, Food Information to Consumers, Nutrition, and Food Waste, Animal Health, Animal Welfare and Plant Health