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European Dairy Association aisbl

EDA

The European Dairy Association represents the interests of milk processors across the European Union.

Lobbying Activity

European Dairy Association urges streamlined food safety rules to boost competitiveness

14 Oct 2025
Topic — Simplification of EU regulations on food safety, authorisations, and official controls.
Message — The association requests harmonized implementation of certificates and border controls, revised treatment requirements for centrifuge sludge, and clearer registration rules for dairy companies handling feed by-products. They argue current requirements create disproportionate burdens and discourage valorizing safe by-products as feed.123
Why — This would reduce administrative costs and enable profitable use of dairy by-products.45
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Meeting with Leopoldo Rubinacci (Deputy Director-General Trade)

9 Sept 2025 · Exchange about the current and future challenges of trade and agricultural policy for the European dairy sector.

Meeting with Olivér Várhelyi (Commissioner) and

8 Sept 2025 · Dairy sector’s key priorities in animal welfare and nutrition sectors

European Dairy Association opposes carbon farming credits in emissions trading system

4 Jul 2025
Topic — Review of EU Emissions Trading System and Market Stability Reserve by 2026.
Message — The association supports including permanent industrial carbon removals in ETS but opposes carbon farming credits. They want better incorporation of heat pumps in emission calculations and more subsidies for dairy-relevant technologies. They urge maintaining current thermal input thresholds.1234
Why — This would preserve regulatory stability and avoid unnecessary compliance challenges for dairy companies.5
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Meeting with Brigitte Misonne (Acting Director Agriculture and Rural Development)

24 Jun 2025 · EU policy issues of relevance for the dairy sector

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen)

24 Jun 2025 · Exchange of views on the Common Organization of Markets and the competitiveness and resilience of the dairy sector

European Dairy Association urges EU support for manure-based circularity

19 Jun 2025
Topic — The European Commission is consulting on the revised EU Bioeconomy Strategy for a circular economy.
Message — The association requests subsidies and the removal of legislative barriers to improve circular processing. They propose recognizing recovered nitrogen from manure as a substitute for chemical fertilizers. Furthermore, they demand simplified permitting for farm infrastructure upgrades.123
Why — This would lower operational costs for dairy processors and provide new revenue from manure digestion.45
Impact — Citizens lose food security if dairy land is diverted to prioritize fuel over food production.6
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Meeting with Michael Mcnamara (Member of the European Parliament)

12 May 2025 · Introduction

Meeting with Christophe Hansen (Commissioner) and

5 May 2025 · Targeted amendments to the CMO - EU dairy trade situation

Meeting with Jessika Van Leeuwen (Member of the European Parliament)

29 Apr 2025 · Exchange of views

Meeting with Pierre Bascou (Deputy Director-General Agriculture and Rural Development)

27 Mar 2025 · Vision for Agriculture and Food, Commission proposal for a targeted amendment to the CMO Regulation, Milk market situation, Trade related issues, Future MFF/CAP

European Dairy Association rejects mandatory milk producer contracts proposal

10 Mar 2025
Topic — EU initiative to amend agriculture regulations and strengthen farmer positions in food supply chains.
Message — EDA strongly opposes the introduction of compulsory written contracts between milk producers and buyers. They advocate for maintaining the current voluntary framework to ensure market flexibility and subsidiarity.12
Why — Maintaining the voluntary status quo avoids increased administrative burdens and protects established cooperative models.3
Impact — EU policy goals for faster price transmission and market transparency would be undermined.4
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Meeting with Elena Panichi (Head of Unit Agriculture and Rural Development)

5 Mar 2025 · Association Agreement EU-Mercosur

Meeting with Alexander Bernhuber (Member of the European Parliament)

19 Feb 2025 · Runder Tisch zu Nachhaltigkeit in der Molkereibranche

Meeting with Fabien Santini (Head of Unit Agriculture and Rural Development)

23 Jan 2025 · Commission proposal of 10 December 2024 on the Common Market Organisation Regulation

Meeting with Tomas Baert (Cabinet of President Ursula von der Leyen) and European farmers and

3 Dec 2024 · Trade tensions - strategic thinking for agri-food trade

Response to Further reciprocal tariff liberalisation under Art. 29 of the EU-Ukraine Association Agreement

11 Sept 2024

The European Dairy Association (EDA) has consistently supported the EU-Ukraine Association Agreement, as well as the introduction of the Autonomous Trade Measures (ATM). A regime that has been in force since June 2022, after the start of Russias unprovoked and unjustified full-scale invasion of Ukraine. This regime, aimed at fostering deeper economic ties between the European Union and Ukraine, has effectively integrated the Ukrainian dairy industry into the broader EU lactosphere. Our commitment to this integration was highlighted in the 2023 report, "Ukrainian Dairy as a Part of the EU Lactosphere" (see Annex 1), and further solidified by the signing of a Memorandum of Understanding (MoU) between the EDA and the Union of Dairy Enterprises of Ukraine (SMPU) on Europe Day 2024 (09 May) in Kyiv (see Annex 2) and we joined as observer the EU Integration Committee of the Ukrainian dairy sector. By aligning Ukrainian dairy standards and trade practices with those of the EU, the Ukrainian dairy sector has and will grow increasingly interconnected with the EU market. This relationship supports both sides by enhancing market opportunities, reinforcing supply chain resilience, and promoting shared standards of quality and safety. As a result, Ukrainian dairy is now de facto an integral component of the EUs dairy ecosystem. However, we recognize that the full liberalisation of trade between the EU and Ukraine is a complex process that requires careful management. The EDA is fully aware that the European Commission will follow a cautious approach, and that this will include product-specific safeguards to protect sensitive sectors, such as dairy, from potential market disruptions. These safeguards will of course cease to exist after Ukraines full integration into the EU single market is achieved. As a key player in European dairy, the EDA remains committed to supporting this integration process while ensuring that the interests of both EU and Ukrainian dairy stakeholders are safeguarded. We believe this careful balance will ensure a sustainable and mutually beneficial trade relationship moving forward. In a nutshell: - We support reciprocal free dairy trade and the protection of investments; - We support the advancing of the DCFTA (UA-EU free trade agreement) and the accession negotiations; - We advocate for a long-term integration of Ukrainian dairy in the European Single Market via a joint road map; - We will build up and strengthen the UA-EU dairy network for sharing best practices in improving productivity and quality at the production level, boosting demand and raising awareness at consumer level and for exchanging on the respective dairy-relevant legislative framework, retail and marketing standards at sectoral level in place; - We ask for the establishment of an Ukrainian dairy needs list in the context of the EU Rapid Damage and Needs Assessment within the Ukraine Facility Program; - We see the need to initiate a UA-EU dairy dialogue on ways how to integrate Ukrainian dairy & agriculture within the framework of the discussions on the framework of the integration of Ukraine in the future EU Common Agricultural Policy (CAP27).
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European Dairy Association urges equal status for manure-based fertilizers

16 May 2024
Topic — This consultation reviews rules for using fertilizing materials derived from livestock manure.
Message — The association requests that manure-derived fertilizers receive the same legal status as chemical fertilizers. They argue existing application limits are outdated and hinder nutrient recycling efforts.1
Why — Dairy farmers would lower waste management costs and generate new revenue from recycled products.2
Impact — Chemical fertilizer manufacturers face reduced demand as farmers switch to local, bio-based alternatives.34
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European Dairy Association Urges Update to Outdated Nitrate Rules

7 Mar 2024
Topic — Evaluation of EU rules protecting water quality from agricultural nitrate pollution.
Message — The dairy industry wants processed manure used as freely as chemical fertilisers. They argue old limits are outdated because new technology creates high-quality products from livestock waste.12
Why — This would create new revenue for farmers while reducing dependence on expensive imports.3
Impact — Chemical fertiliser manufacturers would face increased competition from recycled organic alternatives.4
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Meeting with Norbert Lins (Member of the European Parliament)

9 Nov 2023 · Panel discussion on future of dairy

European Dairy Association urges harmonized footprint rules for food

20 Jul 2023
Topic — Rules requiring companies to substantiate environmental claims using standardized footprint calculation methods.
Message — The association requests using the Product Environmental Footprint method as the primary standard. They also propose restricting comparisons to items within the same food category and including nutritional value.12
Why — This would allow the dairy sector to use its own pre-approved measurement rules.3
Impact — Consumers lose the ability to compare environmental impacts across different food categories.4
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Response to Updating the legislation related to the hygiene rules for products of animal origin

25 May 2023

The planned changes to update the abbreviation of the identity identifiers to "European Union" would mean immense costs and a very high effort, as the declarations of all packaging would have to be changed along with all documentation (transportation documentation, destruction of the packaging, technical changes, etc.). In addition, the change in the identity mark would have extreme implications for exporting dairies, as it would cause major hinder exports with regard to the respective national approvals as well as export registrations and documents. This will cause major obstacles inherent to those changes. The updating of the packaging, along with the updating of all documentation, would also cause obstruction of the products for various administrative and technical reasons until they fully comply. Even now, any change or even incongruity of the abbreviations "EG", "CE", "EC" triggers discussions again and again. Therefore, it would be possible if instead of many linguistic abbreviations for "EU" (UE etc.) A uniform abbreviation could be used throughout the EU: "EU". In any case, a long-term transition period (at least 10 years) is needed, as registrations that have just been allocated can only be re-approached with significant risks. The timing of the changeover in December 2028 is, therefore, insufficient.
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European Dairy Association urges exemptions from EU packaging reuse targets

21 Apr 2023
Topic — Revision of EU rules to improve packaging design and reduce waste in the internal market.
Message — They request deleting reuse targets and excluding dairy from deposit return systems. They want recycled plastic requirements delayed until food-safe recycling technologies are installed. The group also proposes keeping single-use packaging for condiments and coffee creamers.1234
Why — This would protect the industry from high costs and hurdles of washing containers.56
Impact — Environmental initiatives lose ground as the sector seeks to avoid single-use plastic bans.78
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European Dairy Association urges recognition for existing soil carbon

21 Mar 2023
Topic — The EU is developing a certification framework for monitoring and verifying sustainable carbon removals.
Message — EDA requests that the framework includes GHG reductions and rewards maintenance of existing soil carbon. They argue the system must be practically manageable and avoid unnecessary administrative burdens.123
Why — Dairy producers would gain a new income stream by monetizing existing pastureland carbon storage.45
Impact — Climate groups lose if credits are issued for existing practices without proving additionality.6
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

10 Oct 2022 · electricity prices

Response to Revision of the EU geographical indications(GI) systems in agricultural products and foodstuffs, wines and spirit drinks

27 Jun 2022

The European dairy is the guardian of a unique culinary heritage and a cultural treasure: next to the legal protection of dairy terms, like ‘milk’, ‘cheese’ or ‘whey’ more than 300 designations of cheeses and other dairy products are protected as Geographical Indications (GI) through the EU quality policy and the GI protection scheme. Thanks to the GI policy, European cheese and dairy products are rightly perceived as high quality by the consumer around the world and reflect the rich diversity of different traditions and regions in Europe. The European GIs framework protects all the consumers around the globe: GI products must comply with the strict requirements established by the product specifications to ensure the premium quality. This unique EU quality policy guarantees not only the specificity, but also the unrivalled qualities of GI products, like Danablu, Grana Padano, Camembert de Normandie, or Feta, to name a few of the iconic cheeses made in Europe, which are the flagships in promoting the whole EU cheese category internally as well as at global level. Moreover, the EU GI protection scheme is open for products from third countries. This scheme has proven its capacity to help especially smaller production areas to uncork the full potential of their unique savoir faire and their specific dairy products. And the recognition of our European protection scheme through various agreements with third countries underlines the global appreciation of our protected dairy products. In a nutshell: the European quality policy and its Geographical Indication system are part of a story of uniqueness and success. Nevertheless, the European Dairy Association (EDA) would like to provide the following comments on the European Commission’s review of the European quality policy. Internal discussions show that we tend to disagree with the idea of externalizing the management of the European quality scheme. In addition to the above mentioned more general statement, EDA would like to propose some technical amendments (please, see the enclosed file) to the proposal for a Regulation of the European Parliament and of the Council on European union geographical indications for wine, spirit drinks and agricultural products, and quality schemes for agricultural products, amending regulations (eu) no 1308/2013, (EU) 2017/1001 and (eu) 2019/787.
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European Dairy Association warns against stricter emission limits and farm inclusion

22 Jun 2022
Topic — The EU is updating industrial emissions rules to support zero pollution and climate goals.
Message — The organization wants to revise the rule requiring emission limits at the strictest end of the range. They also strongly oppose including cattle operations under the directive's scope. Instead, they suggest fine-tuning existing laws rather than adding new categories.12
Why — Avoiding these rules prevents high administrative costs and direct financial burdens on dairy farmers.34
Impact — Environmental groups and citizens lose protections against higher industrial pollution levels and agricultural emissions.5
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European Dairy Association wants rewards for intensive farming carbon removals

29 Apr 2022
Topic — The European Commission is proposing a framework to certify carbon removals from ecosystems and industry.
Message — The EDA requests that certification includes intensive farming and keeps removals within the food value chain to meet sector targets. They also advocate for rewarding frontrunners who have already sequestered large volumes of carbon in their soils.123
Why — This approach would turn carbon sequestration into a profitable business model while helping dairy producers offset their own livestock emissions.45
Impact — Non-agricultural industries lose access to offsets if carbon credits are restricted for use within the food value chain.6
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Meeting with Janusz Wojciechowski (Commissioner) and

27 Jan 2022 · 2022 Annual Work Programme of the EU Promotion Policy

Meeting with Christiane Kirketerp De Viron (Cabinet of Commissioner Johannes Hahn) and European agri-cooperatives and

14 Dec 2021 · Agricultural Promotion Policy

Response to Import conditions and border controls of trade samples and certain composite products

18 Nov 2021

The European Dairy Association (EDA) is the acknowledged voice of the European milk processing industry in Brussels. In this capacity, we welcome the opportunity to contribute to the consultation on border controls for food – import conditions and border controls of trade samples and certain composite products. Please find our contribution in the attached document.
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Response to Land use, land use change and forestry – review of EU rules

5 Nov 2021

EDA calls upon the EU Commission to develop cost-efficient policy tools in the context of the LULUCF revision. Such implementation tools should be in line with the EU environmental commitments and at the same time should not undermine food safety, quality, security, affordability and the European food culture, and should not damage nutrition and health. It is also important not to challenge the profitability of farming activities. Natural carbon sinks such as pasturelands, agricultural lands, peatlands, wetlands and forests will play a key role in the transition towards a carbon neutral continent by 2050 and a climate neutral land sector by 2035. Carbon sequestration of pastureland can offset a significant share of total dairy livestock emissions. Dairy producers can help reduce the greenhouse gas impact of their operations through efficient farm management which promotes soil carbon absorption. In this context, we believe it is important that carbon credits are kept inside the value chain of origin. This will encourage investments and innovation throughout the whole chain and on the other side contribute to the prevention of double counting and greenwashing claims. Moreover, adequate incentive should be provided to farmers for facilitating the uptake of more climate friendly agricultural and forestry practices, while the production of ecosystem services, including safe nutritious food, is maintained. Many existing projects at dairy farm level in Europe are aimed at enhancing carbon sequestration through developing reliable calculation methods and implementing carbon farming practices. EDA has also worked with the European Commission on exchanging best practices and contributing to the analysis and mapping of carbon farming approaches across Europe. Not only the European dairy sector has worked on enhancing its carbon sinks, but it has also significantly reduced its greenhouse gas emissions in the past decades. The carbon footprint per produced unit of milk in Europe is already among the lowest in the world and the sector is fully committed to further decrease its carbon intensity and contribute to the achievement of the EU GHG emissions reduction goals. It is fundamental to reach such objectives without compromising on food safety, security, quality, variety, nutritional value and traditions, which remain of paramount importance in our sector and in European agriculture in order to provide safe and affordable food, and in a sufficient amount, to all European citizens as well as to third-country nationals, thus helping end world hunger. Moreover, EDA is proud to highlight the relevance of dairy in the wide context of environmental actions–including climate, but also looking to the broader picture with water and land uses, biodiversity and animal welfare. The dairy industry is looking at the overall environmental assessment from a holistic point of view – to assure we do not improve on climate indicators while at the same time negatively impacting on other environmental components, e.g. water or land use. To do so, the dairy sector has developed the Dairy PEF (product environmental footprinting methodology), harmonising carbon/ climate assessment as well as 15 other environmental indicators. EDA has also actively contributed to the drafting of the sectorial BREF under the IED Directive by making a responsible commitment to find and adopt all the new technologies available not only to comply with the standards but also to improve them as much as possible. We look forward to our continuous contribution to the EU institutions work of building a coherent and consistent framework of actions to alleviate the evitable legal burden, protect the functioning of our European Single Market and build a better societal foundation with a scientific sound base.
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European Dairy Association calls for cost-efficient climate policy protecting food affordability

5 Nov 2021
Topic — EU Emissions Trading System revision to achieve 55% emission reduction by 2030.
Message — The association requests cost-efficient policy tools that protect food safety, affordability and farming profitability while meeting climate goals. They want clarification on decarbonisation conditionality and minimised administrative burdens. Access to sustainable energy infrastructure is essential for emission reductions without increasing energy demand.1234
Why — This would protect their economic viability and preserve financial resources for decarbonisation investments.56
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Response to Sustainable food system – setting up an EU framework

22 Oct 2021

The Green Deal and Farm to Fork strategies are intending a strive towards more Sustainable Food systems, in Europe and beyond. In the context of the preparation of a future legal framework on sustainable food systems, the European Dairy industry wishes to bring in some reflections and ideas for the upcoming assessment and work. Main principles  The recognition of food (and drink) as primary basic needs, and the priority of food and nutrition security for EU citizens, and beyond.  The EU food systems are numerous - this diversity is essential  Actors in the field need to find a reasonable place and pace  Keep a strong protective hand on the Single market Please see our further detailed comments in the attached paper.
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European Dairy Association urges carbon credits stay in-sector

7 Oct 2021
Topic — The initiative creates a framework to certify carbon removals and reward farmers' climate practices.
Message — The group requests cost-efficient tools that do not challenge the profitability of farming. They suggest keeping carbon credits inside the value chain of origin to drive innovation.12
Why — Keeping credits within the sector helps dairy companies offset their own emissions.3
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

1 Oct 2021 · Speech on sustainable food systems

Response to Animal welfare labelling for food

23 Aug 2021

The dairy industry is fully aware of the importance of the well-being of animals for all parts of the chain, from farmers to consumers, and it shares the concerns of the EU institutions to ensure the well-being of the animal throughout its life - a dairy cow stands for much more than an economic value only. Our European dairies partner on a daily basis with around 700,000 farmers across the whole Union. These committed dairy farmers look after more than 20 million dairy cows in our Union. Dairy cows are the core pillar of the economic, social and environmental basis of the dairy sector and are deserving our particular care and attention. Healthy dairy cattle, as well as sheep, goats and buffaloes assure the sustainability of our sector. Animal care is essential to produce safe and high-quality milk, just as it is essential to assure farm productivity and profitability. The essence of the well-being of dairy animals is followed when an animal is healthy, comfortable, well-fed and has access to clean drinking water, is safe, able to express normal behaviour and is not suffering unpleasant states such as pain, fear and distress. Such animal care practices include clean, dry and comfortable living conditions, nutritious and adapted diets, good medical care and less transport time. Animal welfare is also an integrated system and different profiles contribute to it, such as animal nutrition, health and environmental/climate aspects. There are several concrete examples where improved animal welfare favourably impacts the climate footprint of dairy farming. It is nevertheless important to ensure that improved animal welfare practices do not lead to negative trade-offs on animal health and on environmental components. Members of EDA have also been aligned for many years with initiatives either at national or corporate level, in accordance with the latest EU standards and legislation. The industry is committed to continuing improving the health and welfare of dairy cows and promoting animal care practices, as part of a sustainable European dairy sector, and we welcome science-based advice on where further improvements can be made. EDA has actively provided input to the work of the EU institutions on animal welfare and is also working with the EU Commission on mapping existing projects and schemes aimed at protecting and improving the health and welfare of dairy cows. We are also a full member of the EU Platform on Animal Welfare, where we bring forward our support of every effort in keeping dairy animals healthy. With regards to the revision of the European animal welfare legislation, we call upon the Commission to take into account the specificities of animal farming across Europe; dairy farming is part of the agricultural landscape in all 27 EU member states and present in basically all regions of our Union. This implies a huge variety of farming practices and farm management approaches according to the various types of climatic or environmental conditions. It is important to ensure that all future legislative proposals on this have a robust scientific basis before any decision is taken at political level in the EU. We would therefore encourage the Commission to conduct further research into the areas where scientific work still needs to be carried out before any recommendations on legislative proposals are delivered. We would also recommend that the Commission complete the whole fitness check exercise before taking any further steps regarding an assessment of EU animal welfare legislation. With regards to animal welfare labelling, we call upon the EU Commission to consider voluntary measures for communicating animal welfare protection in Europe. We look forward to our continuous contribution in the EU institutions work of building a coherent and consistent framework of actions to alleviate evitable legal burden, protect the functioning of our EU Single Market and build a better societal foundation with scientific sound base.
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Response to Review of the EU school fruit, vegetables and milk scheme - EU aid

26 Jul 2021

Introduction & Analysis The EU School Milk Scheme that was introduced in 1977 has gone through several reforms. Shaping children’s healthy eating habits is the core objective of the scheme. Emphasis is also placed on the educational dimension aiming at connecting children to agriculture as well as other important aspects such as health, local food chain, organic farming, sustainable production, and food waste. The EU school milk scheme plays an important role in communicating to future generations the benefits of dairy products. This scheme is important to both, the long-term sustainability of the dairy sector and the healthiness of the diet of the young generation. A review of the School Scheme in the perspective to enhance its contribution to sustainable, id est economically, socially, and environmentally sustainable, agri-food production and consumption is guaranteed due to the European dairy production and processing methods, which meet the highest sustainability standards for dairy of the world. This said, today, we do not have any definition of environmental sustainability. The mentioned “this initiative reviews the scheme (…) for the creation of a favourable food environment that makes it easier to choose healthy and sustainable diets” lack scientific substantiation. Dairy products are nutrient-rich and are excellent sources of high-quality protein, as well as calcium, phosphorous, potassium, iodine, vitamin B2 and B12. They also contain other essential nutrients such as magnesium; and other B vitamins (B3, B6, B9), as well as vitamin A. Therefore, milk and dairy play an important role as part of a healthy and balanced diet at all life stages, but especially for young people – see our EDA Factsheet on Nutrition. Dairy products have an essential place in children’s diet because they contribute to physical and cognitive development as well as health maintenance. The importance of dairy in children’s diets is highlighted by the separate and high daily dairy recommendations around Europe, on average the recommendation is 3-4 servings/day. In fact, in 18 of EU Member States do not even achieve the dairy uptake recommendations. There is therefore a clear underconsumption of all dairy products in 18 out of 23 countries – see our EDA Factsheet on Daily Dairy Recommendations. (...) Our EDA members found increasing complexities in deliveries of school scheme due to highly bureaucratic administrative work which, indeed, disincentivize to take part in the scheme. And this, consequently, increases the possibility of leaving children without their necessary daily dairy uptake in the EU. The introduction of a higher degree of flexibility in the national implementation of the scheme should for sure improve the uptake. Policy Options The review of the school scheme policy of the EU must be used to achieve two goals: 1. To educate EU next generation in terms of healthy eating habits and nutrition and on the EU farming and food system, 2. To suggest improvements to the current organization of the School Milk Scheme that can contribute to a better functioning in those Member States where it currently runs suboptimal. Only with a strategy focused on these two axes, the EU school scheme can deliver for the EU next generation in terms of both healthy diet and green deal ambitions. Conclusion The European Union must uncork the full potential of the scheme all over Europe. The review of the policy should be focused on reducing the administrative burdens in order to facilitate as broad as possible the uptake of EU scheme across the union.
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Response to Amendments of Regulation (EU) 2019/2122

17 Jun 2021

The European Dairy Association (EDA) is the acknowledged voice of the European milk processing industry in Brussels. In this capacity, we welcome the opportunity to contribute to the consultation on amending Delegated Regulation (EU) 2019/2122 as regards certain categories of goods posing low risk, goods that form part of passengers’ personal luggage and pet animals exempted from official controls at border control posts and amending that Delegated Regulation and Delegated Regulation (EU) 2019/2074 as regards references to certain repealed legislation. Please find our comments in the attached document.
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Meeting with Frans Timmermans (Executive Vice-President) and European farmers and

31 May 2021 · Exchange on Farm to Fork Strategy with European Livestock Voice

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Karolina Herbout-Borczak (Cabinet of Commissioner Stella Kyriakides)

27 Apr 2021 · VTC Meeting on Farm to Fork Strategy and labelling initiatives

Response to Agriculture - List of products and substances authorised in organic production

23 Apr 2021

Our full input is in attachment. Herewith is a summary. Regarding the (future) positive list of cleaning and disinfection agents in production and storage (Article 5 and Annex IV, Part C) • In general, EDA/EWPA are not supportive of a positive list for allowed cleaning and disinfection agents. For different situations/products there is a need to have different substances to clean/disinfect effectively. A restrictive list with forbidden substances would be a more favourable solution. In addition, a positive list of cleaning and disinfection agents is likely to limit innovation in this area. • The foreseen deadline of 2024 for the application of such list is not realistic as it would not give enough time to operators to adapt. • The scope of the positive list of cleaning and disinfection agents is not clear yet, but there are already discussions on substances that are to be included. If such a positive list is to be set, then the scope of this positive list should only be about the food contact surfaces that are specifically relevant for organic production. • Production sites can have production lines for both conventional and organic products; this legislation must in no way affect conventional products. • Food safety is the main priority also for organic production. It is of the utmost importance that for all different types of foods and processing methods in the whole chain an effective cleaning/disinfection routine, that is economically viable, is available. Regarding Annex IV, Part C In Annex IV, the wording “products for cleaning and disinfection” is not clear. EDA/EWPA suggest using the wording “products and substances for cleaning and disinfection”; this is also in line with the wording in other Annexes. Regarding authorised products and substances for use in the production of processed organic food and of yeast used as food or feed (Annex V, part B) The positive list of authorised non-organic agricultural ingredients to be used for the production of organic food has been significantly reduced compared to the old Organic Regulation. This will give challenges to companies that produce organic products and use these ingredients at the moment. EDA/EWPA request to reconsider to reinclude several ingredients from this positive list in general, and in particular spirulina/all algae. Regarding food additives and processing aids (Article 6 and Annex V, Part A) While EDA/EWPA welcomes the lists of Annex V, Part A since they keep the substances currently listed in regulation 889/2008, additional uses of some processing aids in organic dairy products could be considered. • Calcium chloride should be allowed as a processing aid in organic cheese production. Calcium chloride is frequently used as a processing aid in cheese production - it is added to cheese milk before renneting to enhance clotting of proteins. Calcium chloride is not consumed as such, it is only added during the manufacturing process for technological purposes. It does not leave any residues that could be harmful to human health in the final product and has no technological function in the end product. • Hydrochloric acid is currently only allowed as a processing aid for some Dutch cheeses. We believe that all European firm cheeses salted in brine should be allowed to use hydrochloric acid as a processing aid for the regulation of the pH of the brine bath. • As a basic principle the use of alkalising agents and acids for adjusting the pH during the manufacturing process, should not be depending on whether the raw material is of plant or animal origin. • Perlite, diatomaceous earth and cellulose are used as processing aids to filter the brine bath. This process is used for conventional cheeses but is very much wished for in the manufacturing of organic ripened cheeses too.
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Response to Conditions for derogation from mandatory accreditation of official laboratories

16 Apr 2021

The European Dairy Association (EDA) welcomes the EU Commission’s Delegated Regulation with regard to the cases and conditions under which competent authorities may designate official laboratories which do not fulfil the conditions in relation to all the methods they use for official controls or other official activities, and its overarching goal of further improving the flexibility already foreseen in Regulation (EU) 2017/625 and reducing the administrative and financial burden. The current Regulation (EU) 2017/625 authorises in article 41 some derogation to use a laboratory which do not fulfil the conditions referred to in point (e) of Article 37, which says that “lab should operate in accordance with the standard ISO/IEC 17025 and is accredited in accordance with that standard by a national accreditation body”. The objective of this new draft is to better detail in which condition this is possible, for 2 areas: (i) food contact materials, food additives, food enzymes, flavourings and feed additives and (ii) plant health. This can be justified for some emerging parameters, for which there is no laboratory accredited yet, as the parameter is emerging. This can also be the case for food contact materials where many regulated parameters do not have standardized method. Specifically, in Regulation (EU) 2017/625: • the Article 37(4) point (e) asks to use an accredited laboratory • the Article 37(5) point (a) asks to have the method part of the accreditation scope (so the method must be accredited) If the derogation refers only to Article 37(4) point (e), as it is written today, this leaves the possibility for competent authorities to use a non-accredited laboratory. In this respect, we would suggest for the derogation to also refer to article 37(5), point (a), to allow the use of a non-accredited method only in an accredited laboratory. In addition, we would like to put forward the following aspects for your further consideration: • In case of a litigation between a company and a third country, the analysis methods used has to be recognised and follow the official method validated by the authorities of the country. It will be impossible to judge between a result from an official method and a result from a non-official method. • Regarding specifically the dairy products, a non-accredited laboratory might not have the appropriate method to analyse the dairy matrix. This may result in having positive results on some analyses that do not use routine methods. • A list of official non-accredited laboratories used for official analysis has to be provided and be public. These laboratories shall be audited by the competent authorities. In case of litigation, an official accredited laboratory shall take the lead. • From an export point of view, if a laboratory does not use the official accredited method this could prevent the issue of the sanitary certificate. Overall, we would support that the official non-accredited laboratory could be used for analyses linked to the national control plan (and in case of litigation, the official accredited laboratory should take the lead), but all the analyses linked to export and to sanitary inspection of the plants shall be provided by the official accredited laboratory.
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Response to Information and promotion measures for agricultural and food products in the internal market and in non-EU countries

8 Mar 2021

EU promotion policy is of vital relevance for our EU dairy sector with our European self-sufficiency of an EU average of 112% in dairy (ten EU MS, like Croatia, Portugal or Spain are below dairy self-sufficiency, the other 12 EU MS, like Poland, Austria or Germany are above dairy self-sufficiency). 12% of our EU dairy produce is serving the international markets; the promotion of EU dairy excellence and quality (beyond the quality policy of the EU COM) has proven instrumental for the EU lactosphère in supporting the dairy sector in uncorking the potentials of the EU trade agreements and in highlighting the quality of our produce, assuring the best valorization of EU milk. When it comes to the effects on climate, biodiversity or environment, all EU agri-food products already must comply with EU Regulations and Directives in the field of climate, environment protection and animal welfare. Besides, there are various sustainable business practices, either regulated at EU level at national/regional or dairy level. Hence the announced review of the EU promotion policy should focus on promoting all EU production methods, that are all based on a sustainability approach. As much as the EU Food Law in 2004 did create the basis for our international success by establishing the most performant food safety law at global level, the Green Deal and the F2F strategy could have the potential to build the next level in adding to EU dairy excellence and safety the environmental sustainability volet. Already today the EU COM JRC confirms that we have with 1,3kg of CO2 per kg of milk produced in Europe the lowest CO2 footprint in global dairy. The environmental footprint of a (food) product is of huge complexity and cannot be reduced to a single indicator matrix. But when taking into account only this Green House Gas (GHG) emission indicator, conventional dairy even excels organic dairy. The promotion policy of the EU must be used to support all agricultural sectors to achieve two goals: 1. Create the added value for agri-food products in our Union and worldwide that European agriculture deserves and needs in order to be economically sustainable and to support our European agricultural model with our social, environmental and animal welfare standards, 2. Strengthen the awareness of the environmental and social sustainability of our EU food production, in all food categories, today, again: at EU and world level. Only with a strategy focused on these two axes, the EU Promotion Policy can integrate the European Green Deal ambitions and sustain the sustainability efforts of the whole EU agri-food chain. None of the ‘Policy Options’ outlined in the IIA by the EU COM seems to be fully aligned with these goals. As far as policy option n° 3 refers to the exclusion of certain sectors and the possible ineligibility of some products, we underline that EU Commissioner Janusz Wojciechowski clearly stated in a stakeholder meeting on 13th of January that (quote) “it is not my intention to exclude any type of products from the promotion program”. For policy option n° 2, the focus on ‘sustainable agricultural production and consumption’ (we presume ‘environmental sustainability’) within the Single Market promotion only makes sense when considering a wholistic environmental assessment of the products of all categories, as – for instance - delivered for dairy by the Dairy Product Environmental Footprint (PEF) project within the remit of DG ENVI. The competitivity focus of the international dimension mirrors the overarching goals of the CAP (see above). Policy option n° 1 seems to be the most flexible approach, even if the example of the 2021 work program is not pertinent since promotion programs and hence the promotion policy must align to a certain extent with the market developments in order to achieve its two overarching goals
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Response to Revision of EU marketing standards for agricultural products

10 Feb 2021

Introduction & Analysis Marketing Standards and common product definitions (sales descriptions and protected denominations) have proven very instrumental in assuring concise & transparent consumer information, guaranteeing a level playing field within the market competition and in facilitating trade. The extensive evaluations of marketing standards published by the EU Commission in November 2019 and October 2020, underline the effectiveness (quote: ‘success story’), efficiency (quote: ‘positive’), relevance (quote: ‘pertinent’) and coherence (quote: ‘positively’) of the existing marketing standards. This EU COM study finds that ‘significant added value’ is provided by marketing standards. The study also underlines the need for a better protection of dairy terms and points at a ‘limited awareness’ of marketing standards by consumers. Comprehensive dairy terms already exist and should continue to be protected against misuse. However, implementation by national authorities may vary and, in this area, and guidance could provide some degree of implementation standardisation. While acknowledging the added value (see above) of the EU marketing standards, the IAA Ares (2021)427166 published on 19 January 2021 by the competent EU services refers to the F2F strategy and the intention to review the marketing standards ‘to provide for the uptake and supply of sustainable agricultural products. So far, we have not yet seen any scientific definition of sustainable agricultural products’, nor does the IAA specify any criteria on environmental, social, and economic sustainability. Including into the set-up of product-related marketing standards ‘sustainability considerations’, id est production related criteria beyond the core production process of the defined produce (like ‘animal welfare’ or ‘environmental impact’) is not the raison d’être of a marketing standard, neither at EU nor at international level. (...) Conclusion The sophistication level of the “preliminary assessment of expected impacts” in section C of the IAA can be improved. The assumption that “sustainability-oriented” marketing standards could facilitate ‘recovery and redistribution by food banks’ is by far not the biggest enigma here. The EU Commission has placed the resilience of the agri-food chain on top of its priority list within the F2F strategy (see Roadmap “Contingency plan for ensuring food supply and food security” Ares(2020)7145362 - 27/11/2020), and we are surprised not to see an evaluation of the role EU marketing standards play in the facilitation of the food trade within the EU Single Market and hence in assuring food supply and food security in the IAA of a potential revision of our marketing standards.
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Response to Setting of nutrient profiles

2 Feb 2021

The European Dairy Association (EDA) welcomes the opportunity to provide comments on the European Commission’s Roadmap Inception Impact Assessment (IIA) on the Proposal for a revision of Regulation (EU) No 1169/2011 on the provision of food information to consumers (FIC). The European dairy sector has always been committed to ensure accurate, useful and credible information to the EU consumers. A full re-opening of the FIC Regulation is neither required nor desirable as the FIC Regulation is generally fit-for-purpose, while a partial revision and/or implementation of specific technical provisions may be considered. Please find enclosed our detailed comments on on FOPNL, nutrient profiles, origin labelling and date marking.
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Response to Contingency plan for ensuring food supply and food security

11 Jan 2021

The European Dairy Association (EDA) is not only the acknowledged voice of the European milk processing industry in Brussels, but also the benchmark for all sector-specific organisations in the field of agriculture in creating a European forum for both, high-level debates on the future of the European ”lactosphere” and in-depth analysis of today's dairy-related topics on the European agenda. Please find attached EDA's feedback to the EU initiative: EU food supply and food security – contingency plan
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Response to Revision of the EU geographical indications(GI) systems in agricultural products and foodstuffs, wines and spirit drinks

25 Nov 2020

1) Improving sustainable production under the schemes The GI system is set up to protect and promote specific product names, their unique characteristics, linked to their geographical origin as well as traditional know-how. The traditional, often centennial production methods, enshrined in the ‘cahier des charges’ guarantee the economic/social/environmentally sustainable production methods per se. This largely offsets the transport implied by the ‘regional’ link when enjoyed outside the defined production area. Any revision of the GI scheme must take into account the economic dimension of GIs. Agri-food products protected by GIs represent a sales value of €75 billion (EU COM data). In order to increase the added value of the system, it would be important to differentiate among GIs on the basis of their economic value, esp. in terms of international trade. We would therefore ask the Commission to reflect on the link between the economic dimension of GI and the relevant rights. 2) Improving enforcement Protection on internet is of vital importance. 3) Empowering producer groups The vast competences conferred to the producer groups (consorzii) both on the content of the specifications and on the marketing field are sufficient in today’s GI framework. 4) Reducing internet theft See n.2 5) Better tailoring schemes to producers in all EU regions The uneven uptake of the GI scheme across EU is caused by its historical development and is rooted in the different cultural background across MS. The TSG scheme was set up to accommodate the traditional products in MS with a less pronounced tendency for GIs, while being based on the GI principles. We are waiting to see if the latest adaptation of the TSG scheme results in a higher uptake. 6) Reviewing ways to promote and protect the EUs’ traditional food Traditional food products throughout the EU go far beyond the GI system – see inter alia the list of foodstuffs inscribed on the Representative List of the Intangible Cultural Heritage of Humanity (UNESCO World Heritage). 7) Speeding up registration procedures As already noted in the context of the amendment to Regulation (EU) No. 1151/2012, the EU COM should not only check applications for protection according to art. 50 Regulation (EU) No. 1151/2012 against obvious errors, but rather comprehensively, whether the requirements laid down in the regulation are actually being complied with. After some deadlines were already shortened in the last revision, this is still missing for the review period of the Commission after the consultation procedure has been concluded (art. 51). We therefore propose to add that the EU COM has to conclude, through the committee procedure according to art. 57, within at the latest 6 months after the conclusion of a consultation procedure in accordance with art. 51 par. 3 subpar. 2. This would avoid situations such as in the "Havarti" PGI protection procedure, where it took almost 5 years between the completion of the consultation and the registration decision. Additional comments: • Generic names: The issue of generic names is controversial at many levels, esp. when an application is made to protect compound names and the question arises as to whether part of the compound name is a generic name. There are examples for this. In art. 41 par. 3 of Regulation (EU) No. 1151/2012 it is already stated that the EU COM has the power to issue delegated acts with further provisions to determine the generic status of terms. The EU COM should finally proceed with this task to avoid numerous opposition procedures regarding compound names.
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Response to Model health certificates for certain categories of animals and goods

3 Nov 2020

The European Dairy Association (EDA) would like to thank the European Commission for the opportunity to take part in this consultation on Standard health certificates for animals & goods. Please find our contribution attached in PDF format.
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Response to Commission Delegated Regulation amending Annex IV to the LULUCF Regulation

14 Sept 2020

In the context of the European Green Deal, the dairy industry is committed to play its role within the new set of policy tools to further strengthen our full engagement and support to the efforts made at all levels of the supply chain. We are proud to already have presented an overview of our current efforts and work ahead in December 2019 (attached below). Enhancing carbon sequestration by the land use sector will be of paramount importance for achieving the updated climate targets. In this context, it is important to highlight the key role of natural carbon sinks such as pasturelands, agricultural lands, peatlands and wetlands in contributing to the sequestration of atmospheric CO2. As an example, carbon sequestration of pastureland can offset a significant share of dairy emissions. Dairy producers can help reduce GHG through efficient farm management which promotes soil carbon absorption. Permanent grassland already keeps carbon in places where else nothing could grow while providing efficiently very essential nutrients. Many existing projects at dairy farm level in Europe are aimed at enhancing carbon sequestration through developing reliable calculation methods and implementing carbon farming practices. Nevertheless, a common methodology to measure carbon sequestration at EU level is still missing. In this context, EDA is currently working with the European Commission on exchanging best practices and contributing to the analysis and mapping of carbon farming approaches across Europe. We look forward to our continuous contribution to the EU institutions work of building the right framework for supporting the new climate ambitions.
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Response to Environmental claims based on environmental footprint methods

27 Aug 2020

EDA supports the use of the Product Environmental Footprint (PEF) methodology to substantiate green claims in the EU. We support action by the EU Commission to integrate the PEF into existing or new policy instruments, to reward sustainable practices and limit the risk of credibility loss that the proliferation of green claims may cause. We believe the PEF should be the answer to the many issues the Green Deal and the EU environmental legislation aim to tackle, assuring a harmonised and realistic approach for all actors involved. To enable meaningful consumer choice, any type of information provided needs to reflect the complexity of the product and its production chain/process. Valuable consumer information needs to enable consumers to easily make responsible and confident decisions. This means that information needs to be understandable to informed consumers and unequivocal from a scientific perspective, as well as coherent with the overarching goal. To ensure the credibility of green claims, a harmonised voluntary system needs to have a clear framework and should only be applied where feasible and relevant. We favour a voluntary-mandatory approach: communication on environmental performance should be voluntary but conditioned to the PEF methodology (based on a sector-specific PEFCR). A regulatory framework must be set to require sectors to develop a PEFCR. As has always been the aim of the PEF this would ensure that any green claims made are valid, that comparability is restricted, and that assurance can be provided by member state authorities required to enforce this. EDA also supports the use of the PEF for assessing improvements in the environmental performance of a product over time. Due to uncertainties that persist in the methodology, it is not meaningful and realistic to compare products within the same category. We also ask for a clear prohibition and enforcement of comparative claims between products of different categories. The PEF is not meant to compare products from different categories also because relevant aspects of concern, e.g. regarding health, quality, and nutritional value are not included in its scope. We believe it is of paramount importance to indicate at least 3 or 5 impact categories when communicating environmental information, to have a clear and transparent picture of the overall environmental performance of a product and avoid negative trade-offs between environmental categories. Moreover, the limitations of the current PEF allow for business-internal and -general communication, but not for on-pack labelling. Digital means should also be explored for providing environmental information. The Dairy PEF, conducted by EDA and approved by the EU Commission and Member States in 2018, is a fundamental tool for driving environmental sustainable practices in the dairy sector and allowing to quantify the improvements, covering a broad list of environmental indicators. It represents the holistic and proactive approach taken by the sector in the field of environmental assessment and is currently the best way to provide environmental information in a credible and measurable way, while being always further refined to integrate more indicators. Jointly with other measures (e.g. nutritional content) it is a helpful tool to describe all benefits of food and the effort of producing high quality food. The Dairy PEF as it stands now is a good method for improvement calculation over time and internal assessment, as well as business-level relationships. It could thus be used for voluntary off-pack information to stakeholders. It is not ready to allow for meaningful and quantitative comparability between products, nor on-pack labelling. We look forward to our continuous contribution in the EU institutions work of building a coherent and consistent framework of actions to alleviate evitable legal burden, protect the functioning of our Single Market and build a better societal foundation with scientific sound base.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

5 Aug 2020

• The European Dairy Association (EDA) welcomes the Commissions effort to review the Packaging and Packaging Waste Directive, including the Essential Requirements, with a focus on ensuring a European framework for investments in new and cutting-edge packaging solutions, supporting the reduction of packaging waste and enhancing the sustainability of packaging in an economically viable manner. • The dairy industry is involved in many initiatives to further streamline the environmental impact of its packaging and strives to also find improved solutions for collection and recycling. Most dairy companies have targets on reusability, recyclability, composability, as well as recycled content, sorting and collection, design, and carbon footprint of packaging. • In view of the need to achieve an overall minimization of the environmental footprint, we support an integrated approach aimed at designing the most suitable group of measures, including amongst others design for sorting/recyclability, both quantitative and qualitative recycling targets in all Member States, and reduction of packaging waste for disposal. The latter should not be confused with packaging reduction. • We would like to help reflecting on a different angle of approach to the question of packaging. It may be more suitable, having in mind environmental impact and societal costs, to see for the best way to improve them on the longer term by defining an end-point (and suitable intermediate goals) for the whole economic chains to work towards. That would ensure the predictability and an economically viable industry-lead strive to a solution, assure addressing consequences and drivers of the current unsatisfactory situation and avoid undesired trade-offs. • The design of dairy packaging must assure safety and quality as a non-negotiable baseline, before addressing logistics, recyclability, and other criteria. Many dairy products require specific handling at production, in transportation and in the consumer’s home. This can only be achieved with the adequate packaging that safeguards the products from external influences and remains as light and practicable as possible. • When choosing the appropriate packaging for a product, companies consider the full life cycle of a product, encompassing the environmental pressures and benefits, the trade-offs, and areas for achieving improvements. In this framework, the choice to substitute packaging materials must be done carefully by taking a life cycle approach to assess on a case-by-case basis whether substituting totally or partly some packaging materials would result in in an overall better environmental performance through the full life-cycle of the product. • We use packaging to protect our food through the entire chain and shelf life. The environmental impact of the food inside the packaging exceeds that of the packaging by far. Food waste already is one of the main concerns regarding global GHG impact, and the Commission has the ambition to halve the per capita food waste by 2030. We urge the Commission to take no measures that could increase food waste. • Packaging design must consider the difficulties and costs of treatment of packaging waste (including collection and sorting) without overlooking food safety, food waste prevention, and consumer acceptance. This is a shared responsibility of all actors including municipalities for efficient infrastructures. • We support the Inception Impact Assessment in advocating for the harmonisation of rules on packaging across the internal market to preserve its integrity and allow for a smooth free movement of packaging and packaged goods. We agree that uncoordinated national measures would result in obstacles to the free movement of goods and hinder the development of markets for secondary raw materials. • Our full EDA response to this initiative is in attachment.
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Response to EU Methane Strategy

4 Aug 2020

In front of the European Commission strategy aimed at reducing methane emissions in the EU the European dairy industry sees the need to put forward certain aspects to be considered further. (Please see the full version in the attached document.) The European dairy sector has significantly reduced its greenhouse gas emissions in the past decades and we are fully committed to scale up our initiatives to limit the amount of methane that is released in the atmosphere from dairy operations. According to the official EU GHG inventory, a 27% reduction in absolute emissions of methane from enteric fermentation in dairy has been achieved from 1990 to 2017, thanks to the efforts of all actors within the chain. Carbon intensity has also significantly decreased in the same period. The dairy industry also contributes to the production of natural energy. Methane from manure can in fact generate heat, power and even be used as vehicular fuel. Moreover, dairy producers can help reduce the greenhouse gas impact through efficient farm management which promotes soil carbon sequestration. This can compensate a significant share of dairy livestock GHG emissions. The carbon footprint per produced unit of milk in Europe is already among the lowest in the world and the sector is fully committed to further decrease its carbon intensity and contribute to the achievement of the EU GHG emissions reduction goals. European dairies are frontrunners at global level when it comes to climate action and many dairy industries have already signed up for the commitment of carbon neutral dairy chain by 2050 or even 2035, with ambitious emissions reduction targets for 2030 or earlier. Still, the methane approach in particular needs to be seen in a wider context, and the EU Commission would need to further reflect upon the scientific basis before deciding on actions, to assure true change in the right direction for the safeguarding of our planet. In this context there is a clear movement supported by industry, political groups and scientific experts (amongst others work of the Oxford Martin School with IPCC author Prof Myles Allen) towards the re-assessment of methane - particularly biogenic methane from ruminants. It is important that any EU policy development should take this into account, especially considering the current basis for policies dates back more than 40 years. We would also request that the EU integrates movements in science on accounting not only on methane, but also on carbon sequestration potential of land and similar support of climate and planetary boundaries, as well as food and nutrition security. The special role of livestock has already been recognised by European legislators at many occasions. Moreover, EDA is proud to highlight the relevance of dairy in the wide context of environmental actions – including climate, but also looking to the broader picture with water and land uses, biodiversity and animal welfare, amongst others. The dairy industry is looking at the overall environmental assessment from a holistic point of view – to assure we do not improve on climate indicators while at the same time negatively impacting on other environmental components, e.g. water or land use. To do so, the dairy sector has developed the Dairy PEF (Product Environmental Footprinting methodology) in a EU Commission framework, harmonising carbon/ climate assessment as well as 15 other environmental indicators. Given all of the above aspects the possibility of not undergoing a thorough impact assessment of policies to be proposed is not acceptable. We therefore ask the EU Commission to assure a true and full assessment of the situation. In the context of the European Green Deal, EDA shares and fully supports the EU’s ambition to take coherent and forceful leadership at European and global level, as long as it is coherent and fully out fledged to a true long-term solution.
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Response to Climate Law

30 Apr 2020

EDA welcomes the European Commission proposal for a European Climate Law, aimed at enshrining the EU objective of climate neutrality by 2050 in legislation. We believe it is of utmost importance to have this long-term vision and we call upon the EU Commission to develop cost-efficient policy tools for implementing the strategy. Such implementation tools should be in line with the EU environmental commitments and at the same time should not undermine food safety and quality, as well as food security and affordability. The European dairy sector has significantly reduced its greenhouse gas emissions in the past decades. The carbon footprint per produced unit of milk in Europe is already among the lowest in the world and the sector is fully committed to further decrease its carbon intensity and contribute to the achievement of the EU GHG emissions reduction goals. European dairies are frontrunners at global level when it comes to climate action and many dairy industries have already signed up for the commitment of carbon neutral dairy chain by 2050 or even 2035. We are committed to reduce the environmental impact of our operations without compromising on food safety and security, which remain of paramount importance in our sector and in European agriculture in order to provide safe and affordable food to all European citizens. Actions aimed at reducing emissions in the dairy sector such as, among others, enhancing the carbon sequestration of natural carbon sinks (like grassland and pastureland) and increasing the use of electricity from renewable sources are of utmost importance for meeting climate goals. Natural carbon sinks such as pasturelands, agricultural lands, peatlands and wetlands will play a key role in the transition towards a carbon neutral continent by 2050. Carbon sequestration of pastureland can offset a significant share of dairy livestock emissions. Dairy producers can help reduce the greenhouse gas impact of their operations through efficient farm management which promotes soil carbon absorption. Permanent grassland already keeps carbon in places where else nothing could grow while providing efficiently very essential nutrients. Many existing projects at dairy farm level in Europe are aimed at enhancing carbon sequestration through developing reliable calculation methods and implementing carbon farming practices. EDA is also currently working with the European Commission on exchanging best practices and contributing to the analysis and mapping of carbon farming approaches across Europe. Moreover, EDA is proud to highlight the relevance of dairy in the wide context of environmental actions–including climate, but also looking to the broader picture with water and land uses, biodiversity and animal welfare. The dairy industry is looking at the overall environmental assessment from a holistic point of view – to assure we do not improve on climate indicators while at the same time negatively impacting on other environmental components, e.g. water or land use. To do so, the dairy sector has developed the Dairy PEF (product environmental footprinting methodology), harmonising carbon/ climate assessment as well as 15 other environmental indicators. We look forward to our continuous contribution in the EU institutions work of building a coherent and consistent framework of actions to alleviate evitable legal burden, protect the functioning of our European Single Market and build a better societal foundation with scientific sound base.
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Response to EU rules on industrial emissions - revision

21 Apr 2020

In the context of the European Green Deal, EDA shares and fully supports the EU’s ambition to take coherent and forceful leadership at European and global level. The dairy industry is committed to play its role within this new set of policy tools to further strengthen our full engagement and support to the efforts made at all levels of the supply chain. We are proud to already have presented an overview of our current efforts and work ahead in December 2019 (attached below). EDA welcomes the European Commission revision of the Industrial Emission Directive. We believe it is of utmost importance to increase the EU environmental commitments, without at the same time undermining food safety and quality. With regards to potential enlargement of the scope of the Directive, we believe that the relevant stakeholders and sectors should be adequately consulted, and assessments should be performed on the impacts of such possible future extensions. Moreover, the dairy industry is already part of the scope of the Directive, which requires the Best Available Techniques (BAT) Reference Document for the Food, Drink and Milk Industries. With regards to samples, they would need to be representative of the situation in all MS. The dairy sector’s commitment is to reduce the environmental footprint of our operations while continuing to provide nutritious, safe, and affordable products to the European and world citizens. We are in favour of a holistic approach to reduce the environmental footprint and increase the circularity of our operations, contributing to the achievement of the 2050 carbon neutrality objective. The agricultural and food sector, more specifically the dairy, is at the origin of circular production cycles, and the tradition of circular production is the daily experience in our sector. Moreover, EDA is proud to highlight the relevance of dairy in the wide context of environmental actions – including climate, water and land uses, biodiversity and animal welfare. The dairy industry is looking at the overall environmental assessment from a holistic point of view – to assure we do not improve on some indicators while at the same time negatively impacting on other environmental components. To do so, the dairy sector has developed the Dairy PEF (product environmental footprinting methodology), harmonising carbon/ climate assessment as well as 15 other environmental indicators. We look forward to our continuous contribution to the EU institutions work of building a coherent and consistent framework of actions to alleviate evitable legal burden, protect the functioning of our European Single Market and build a better societal foundation with scientific sound base.
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Response to 2030 Climate Target Plan

14 Apr 2020

In the context of the European Green Deal, EDA shares and fully supports the EU’s ambition to take coherent and forceful leadership at European and global level. The dairy industry is committed to play its role within this new set of policy tools to further strengthen our full engagement and support to the efforts made at all levels of the supply chain. We are proud to already have presented an overview of our current efforts and work ahead in December 2019 (attached below). EDA welcomes the European Commission initiative aimed at increasing the climate targets for 2030, in the transition towards EU climate neutrality by 2050. We believe it is of utmost importance to have intermediate targets in this long journey and we call upon the EU Commission to develop cost-efficient policy tools for implementing the strategy. Such implementation tools should be in line with the EU environmental commitments and at the same time should not undermine food safety and quality. The European dairy sector has significantly reduced its greenhouse gas emissions in the past decades. The carbon footprint per produced unit of milk in Europe is already among the lowest in the world and the sector is fully committed to further decrease its carbon intensity and contribute to the achievement of the EU GHG emissions reduction goals. European dairies are frontrunners at global level when it comes to climate action and many dairy industries have already signed up for the commitment of carbon neutral dairy chain by 2050 or even 2035, with ambitious emissions reduction targets for 2030 or earlier. We are committed to contribute to achieving the 2030 revised emission goals and we hope that the effort will be adequately shared amongst sectors and put in relation to the services provided. Within the sector, actions aimed at reducing emissions such as, among others, enhancing the carbon sequestration of natural carbon sinks (like pastureland) and increasing the use of electricity from renewable sources are of utmost importance for meeting climate goals. With regards to carbon sequestration, dairy producers can help reduce the greenhouse gas impact through efficient farm management which promotes soil carbon absorption. Permanent grassland already keeps carbon in places where else nothing could grow while providing efficiently very essential nutrients. Carbon sequestration can compensate a significant share of dairy livestock emissions. Moreover, EDA is proud to highlight the relevance of dairy in the wide context of environmental actions–including climate, but also looking to the broader picture with water and land uses, biodiversity and animal welfare. The dairy industry is looking at the overall environmental assessment from a holistic point of view – to assure we do not improve on climate indicators while at the same time negatively impacting on other environmental components, e.g. water or land use. To do so, the dairy sector has developed the Dairy PEF (product environmental footprinting methodology), harmonising carbon/ climate assessment as well as 15 other environmental indicators. The encompassing Farm to Fork strategy is also most welcome by the dairy industry. We are in favour of an integrated and fully aligned approach on all parts of the agri-food sector’s work and framework. To ensure a fully coherent and consistent approach we would favour all Green Deal initiatives relating to the agri-food sector to be tackled together within the Farm to Fork work. We look forward to our continuous contribution to the EU institutions work of building a coherent and consistent framework of actions to alleviate evitable legal burden, protect the functioning of our European Single Market and build a better societal foundation with scientific sound base.
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Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

7 Apr 2020 · Exchange of views on the dairy sector

Response to Carbon Border Adjustment Mechanism

31 Mar 2020

In the context of the European Green Deal, EDA shares and fully supports the EU’s ambition to take coherent and forceful leadership at European and global level. The dairy industry is committed to play its role within this new set of policy tools to further strengthen our full engagement and support to the efforts made at all levels of the supply chain. We are proud to already have presented an overview of our current efforts and work ahead in December 2019 (linked below). Our commitment is to reduce our environmental footprint while continuing to provide nutritious, safe, and affordable products to the European and world citizens. We welcome the roadmap initiative for a carbon border adjustment mechanism. The EU dairy sector shares the EU climate ambition of achieving a carbon neutral economy by 2050. We believe that economic and social sustainability should be equally ensured as well, in order to unfold the full potential of the new climate and environmental measures. EDA will be happy to see a carbon border tax assuring that the efforts of the EU producers are kept safe from unfair imports, and that will allow us to further improve our climate impact. We need to ensure that the European dairy remains competitive on the internal and external market across our journey towards carbon neutrality. However, we call the European Commission to ensure that any potential border adjustment mechanism is designed in compatibility with WTO and other international obligations of the EU. This in order to secure international trade flows. We would also ask to minimise any administrative burden linked to the proposed measure. We look forward to our continuous contribution in the EU institutions work of building a coherent and consistent framework of actions to alleviate evitable legal burden, protect the functioning of our European Single Market and build a better societal foundation with scientific sound base.
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Response to Farm to Fork Strategy

13 Mar 2020

The Farm to Fork strategy is most welcome by the EU dairy industry. We are in favour of an integrated and fully aligned approach on all parts of the agri-food sector’s work and framework. To ensure a fully coherent and consistent approach we would favour all Green Deal initiatives relating to the agri-food sector to be tackled together within the Farm to Fork work. Our commitment is to contribute to the achievement of a European sustainable food system, across the three qualitative pillars of sustainability, plus the economic one – that is social, nutrition, environment and economic, as highlighted in our Dairy sustainability synopsis. Therefore, we are committed to reduce our environmental footprint while continuing to provide nutritious, safe, and affordable products to the European and world citizens. The Dairy PEF (product environmental footprint) is a fundamental tool for driving environmentally sustainable practices in the dairy sector and allowing to quantify the improvements. The project covers a broad list of environmental indicators and represents the holistic and proactive approach taken by the sector in the field of environmental assessment. Jointly with other measures – e.g. nutritional content - it is a helpful tool to describe all benefits of food and the effort of producing high quality food. It is currently the best way to provide information on environmental indicators in a credible and measurable way, while being always further refined to integrate more indicators. It would be useful to make the PEF the tool for substantiating any green claims in the EU, for communication to citizens and consumers. In order to ensure the credibility of such claims, a harmonised voluntary system needs to have clear framework, and should be only applied where feasible and relevant. To enable meaningful consumer choice, any type of information provided (environmental / nutrition / origin / GMO / other) needs to reflect the complexity of the food product and its production chain/process. Valuable consumer information needs to enable consumers to make responsible and confident decisions. This means that information needs to be understandable to informed consumers and unequivocal from a scientific perspective, as well as coherent with the overarching goal. Digital means should be considered as a valid tool for providing information to consumers. We also call for maintaining harmonised EU rules on voluntary origin labelling for dairy. As part of the dairy sector commitment to a proactive and credible approach EDA has published Sectorial Guidelines for voluntary origin labelling of milk and dairy products (available on EDA website). With regards to nutrition labelling, we support the consumer right to be fully informed on nutritional properties of foods which is already harmonised via Food Information Regulation 1169/2011. However, EDA believes that currently existing additional voluntary labelling schemes are not aligned with dietary recommendations as they disregard e.g. nutrient richness of dairy. Furthermore, the agricultural and food sector, more specifically the dairy, is at the origin of circular production cycles. We are active in a wide field of topics to continuously improve our circular performance and we work with other sectors on issues such as packaging and recycling, by-products valorisation, water re-use and food waste reduction. We look forward to our continuous contribution in the EU institutions work of building a coherent and consistent framework of actions to alleviate evitable legal burden, protect the functioning of our European Single Market and build a better societal foundation with scientific sound base. The coordination of the many Green Deal aspects beyond the Farm to Fork strategy in existing experts’ group, such as the DG SANTE Advisory Group, is also most welcome.
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

4 Mar 2020 · Sustainable food systems

Response to Minimising the risk of deforestation and forest degradation associated with products placed on the EU market

3 Mar 2020

EDA welcomes the initiative aimed at minimising the EU’s contribution to deforestation and forest degradation worldwide, promoting the consumption of products from deforestation-free supply chains. The European dairy sector is aware of its impact beyond EU borders, even if often smaller per litre of milk than the impact of overseas production. For this reason, EDA is actively working with other stakeholders for the promotion of sustainable protein sourcing for feed, amongst other through deforestation-free value chains for soy sourcing. Many European dairy companies have already committed to eliminate deforestation in the supply chains. They include, for instance, targets on deforestation-free dairy value chains or covering all soy supply on responsibly sourced basis. Companies involved in dairy processing are also participating to cross-sectoral industry initiatives aimed at scaling up regenerative agricultural practices, boosting cultivated biodiversity, eliminating deforestation and restoring natural ecosystems. In the context of sustainable protein sourcing, EDA has conducted together with IFCN, the dairy research network, a study to understand the role of locally produced protein sources, like roughage, in the protein input to dairy cows in Europe. The results show that this environmentally and economically sustainable type of fodder provides 70% of the protein in the diet of dairy cows and is almost entirely grown on farm (95%), representing a key aspect for the environmental and economic sustainability of the European dairy sector. Moreover, EDA is proud to highlight the relevance of dairy in the wide context of environmental actions – including climate, but also looking to the broader picture with water and land uses, biodiversity and animal welfare. The dairy industry is looking at the overall environmental assessment from a holistic point of view – to assure we do not improve on environmental indicators while at the same time negatively impacting on other environmental components, e.g. water or land use. To do so, the dairy sector has developed the Dairy PEF (product environmental footprinting methodology), harmonising carbon/ climate assessment as well as 15 other environmental indicators, including amongst others water use, land use and biodiversity. We consider deforestation as already being part of the PEF methodology, but it needs more development as part of the biodiversity assessment. With regards to trade, EDA is also in favour of a reinforcement of the chapters on sustainable development in trade agreements concluded by the EU with third countries. Moreover, in the context of the European Green Deal, EDA shares and fully supports the EU’s ambition to take coherent and forceful leadership at European and global level. The dairy industry is committed to play its role within this new set of policy tools to further strengthen our full engagement and support to the efforts made at all levels of the supply chain. We are proud to already have presented an overview of our current efforts and work ahead in December 2019 (attached below). To ensure a fully coherent and consistent approach we would favour all the current and upcoming initiatives relating to the agri-food sector, including deforestation, to be tackled together within the Farm to Fork work. We look forward to our continuous contribution in the EU institutions work of building the right framework of actions to alleviate evitable legal burden, protect the functioning of our European Single Market and build a better societal foundation with scientific sound base.
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Response to Europe’s Beating Cancer Plan

3 Mar 2020

The European Dairy Association (EDA) welcomes the opportunity to contribute to the Roadmap on Europe’s Beating Cancer Plan, especially its focus on prevention and the important role of healthy and balanced diets in life-style related diseases such as cancer. Dairy products are naturally nutrient-rich foods and are recognised as an important part of healthy and balanced diets by the dietary guidelines in the EU and worldwide. We would like to invite the EU Commission to recognise the role of whole foods such as dairy in the positive contribution to prevention of diet-related diseases, including cancer. The latest World Cancer Report 2020 recognised that there is a strong evidence that higher intake of calcium and dairy products decreases risk of colorectal cancer. Colorectal cancer is the second most commonly occurring cancer in women and the third most commonly occurring cancer in men. High intake of milk and other dairy products (400 g/day of dairy overall, including 200 g/day of milk) together with other wholesome foods such as fruits and vegetables, whole grains, nuts and legumes, fish and other seafood, have been recognised as part of dietary patterns associated with a lower risk of colorectal cancer. The report explains that the mechanism behind this pattern is related to calcium which is naturally present high quantities in dairy. "Calcium binds to potentially toxic secondary bile acids in the intestinal lumen. In addition, intraluminal calcium binds to the calcium-sensing receptor, a cell surface receptor that is expressed on colonocytes and increases expression of E-cadherin, p21, and p27, which have anticancer effects". For additional information, we invite you to consult EDA Nutrition Factsheet on the role of dairy in helping to prevent lifestyle diseases as well as our other relevant publications: EDA Nutrition Factsheet on Health benefits and nutritional value of dairy, EDA Nutrition Factsheet on Nutrient-rich dairy, an affordable source of nutrition (links in the document attached or on our website http://eda.euromilk.org/fs/nutrition.html) EDA has always been fully engaged on nutrition and health topics with policy-makers, industry groups and other stakeholders to help make a positive impact on the overall public health. We remain available for any further cooperation and discussion on the topic of the role of dairy products in healthy, balanced and affordable diets.
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Response to Climate Law

6 Feb 2020

In the context of the European Green Deal, EDA shares and fully supports the EU ambition to take coherent and forceful leadership at European and global level. The dairy industry is committed to play its role within this new set of policy tools to further strengthen our full engagement and support to the efforts made at all levels of the supply chain. We are proud to already have presented an overview of our current efforts and work ahead in December 2019 (attached below). EDA welcomes the European Commission initiative aimed at enshrining the EU objective of climate neutrality by 2050 in legislation, as already mentioned in our EDA position paper of October 2019 on current environmental challenges and carbon neutrality. We believe it is of utmost importance to have this long-term vision and we call upon the EU Commission to develop cost-efficient policy tools for implementing the strategy. Such implementation tools should be in line with the EU environmental commitments and at the same time should not undermine food safety and quality. The European dairy sector has significantly reduced its greenhouse gas emissions in the past decades. The carbon footprint per produced unit of milk in Europe is already among the lowest in the world and the sector is fully committed to further decrease its carbon intensity and contribute to the achievement of the EU GHG emissions reduction goals. European dairies are frontrunners at global level when it comes to climate action and many dairy industries have already signed up for the commitment of carbon neutral dairy chain by 2050 or even 2035. We are also committed to contribute to achieving the 2030 revised emission goals and we hope that the effort will be adequately shared amongst sectors and put in relation to the services provided. Within the sector, actions aimed at reducing emissions such as, among others, enhancing the carbon sequestration of natural carbon sinks (like pastureland) and increasing the use of electricity from renewable sources are of utmost importance for meeting climate goals. Moreover, EDA is proud to highlight the relevance of dairy in the wide context of environmental actions–including climate, but also looking to the broader picture with water and land uses, biodiversity and animal welfare. The dairy industry is looking at the overall environmental assessment from a holistic point of view – to assure we do not improve on climate indicators while at the same time negatively impacting on other environmental components, e.g. water or land use. To do so, the dairy sector has developed the Dairy PEF (product environmental footprinting methodology), harmonising carbon/ climate assessment as well as 15 other environmental indicators. The encompassing Farm to Fork strategy is also most welcome from the dairy industry. We are in favour of an integrated and fully aligned approach on all parts of the agri-food sector’s work and framework. To ensure a fully coherent and consistent approach we would favour all Green Deal initiatives relating to the agri-food sector to be tackled together within the Farm to Fork work. We look forward to our continuous contribution in the EU institutions work of building a coherent and consistent framework of actions to alleviate evitable legal burden, protect the functioning of our European Single Market and build a better societal foundation with scientific sound base.
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Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides)

23 Jan 2020 · FARM TO FORK

Response to EU 2030 Biodiversity Strategy

17 Jan 2020

In the context of the European Green Deal, EDA shares and fully supports the EU’s ambition to take coherent and forceful leadership at European and global level. The dairy industry is committed to play its role within this new set of policy tools to further strengthen our full engagement and support to the efforts made at all levels of the supply chain. We are proud to already have presented an overview of our current efforts and work ahead in December 2019 (linked below). We welcome the roadmap initiative on a EU Biodiversity Strategy to 2030. The dairy sector plays a vital role at protecting biodiversity across the EU, managing the land and allowing biodiversity to prosper. The sector significantly contributes in halting and reversing land degradation. It is also a keystone in keeping the cultural landscape. EDA puts biodiversity at the forefront of relevant indications, having made it an obligatory part of the Dairy Product Environmental Footprint (PEF), and had it adopted by the EU Commission, Members States and NGOs. Further work is being conducted by the dairy sector on an adequate manner to further quantify biodiversity, as no fully harmonised assessment on equal data is yet possible. To ensure a fully coherent and consistent approach we would favour all Green Deal initiatives relating to the agri-food sector, including biodiversity, to be tackled together within the Farm to Fork work. We look forward to our continuous contribution in the EU institutions work of building the right framework of actions to alleviate evitable legal burden, protect the functioning of our European Single Market and build a better societal foundation with scientific sound base.
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Response to A new Circular Economy Action Plan

17 Jan 2020

In the context of the European Green Deal, EDA shares and fully supports the EU’s ambition to take coherent and forceful leadership at European and global level. The dairy industry is committed to play its role within this new set of policy tools to further strengthen our full engagement and support to the efforts made at all levels of the supply chain. We are proud to already have presented an overview of our current efforts and work ahead in December 2019 (linked below). We welcome the roadmap initiative for a New Circular Economy Action Plan. The agricultural and food sector, more specifically the dairy, is at the origin of circular production cycles, and the tradition of circular production is the daily experience in the dairy sector. We are active in a wide field of topics to continuously improve our circular performance and we work with other sectors on issues such as packaging and recycling, as well as on by-products valorisation and water re-use. Further reducing losses of food is also a continuous challenge that the dairy sector takes very seriously. In this context, adequate packaging that safeguards the products from external influences plays a key role in avoiding food waste and ensuring safety and quality as a non-negotiable baseline. Our commitment is to reduce our environmental footprint while continuing to provide nutritious, safe, and affordable products to the European and world citizens. The Dairy Product Environmental Footprint (PEF), as adopted by the EU Commission, Member States and NGOs, is a fundamental tool for driving environmentally sustainable practices in the dairy sector and allowing to quantify the improvements. It would be useful to make it the baseline for any relevant green claim in the EU, for communication to citizens and consumers. The encompassing Farm to Fork strategy is also most welcome from the dairy industry. We are in favour of an integrated and fully aligned approach on all parts of the agri-food sector’s work and framework. To ensure a fully coherent and consistent approach we would favour all Green Deal initiatives relating to the agri-food sector to be tackled together within the Farm to Fork work. We look forward to our continuous contribution in the EU institutions work of building a coherent and consistent framework of actions to alleviate evitable legal burden, protect the functioning of our European Single Market and build a better societal foundation with scientific sound base.
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Response to Amendment of products and substances allowed in organic production

2 Aug 2019

The European Dairy industry is much interested in the revision of the EU rule for organic foods with regards to the specific list of substances that can be used, being in public consultation. Due to the specificity of the dossier and its timing EDA will be happy to deliver a qualified input at a later moment to the European Commission.
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Response to Enhancing Market transparency in the agri-food chain

23 May 2019

We welcome the work done by the Commission in order to improve market transparency on the European agricultural markets, according to the recommendations of the Agricultural Markets Task Force. EDA had the opportunity to express its specific views in the expert meetings conducted along the consultation process. Today’s transparency in the dairy chain: Thanks to the mandatory communication from the Member States to the Commission in place for many years, the European dairy supply chain is already very transparent. The volumes of collected milk and the production of the main dairy products are communicated and published monthly for each Member State. Each week, the average ex-factory prices of the main dairy commodities: SMP, block butter, WMP, whey powder and main cheeses are communicated by each Member State and published by the Commission. The average milk prices paid to the farmers are communicated and published monthly for each Member State. All this information is provided by the dairy processors. EDA considers that extending prices communication to the prices received from the retailers for consumers dairy products would be extremely complex and would encourage downward pressures on the processors’ selling prices and thus on the dairy farmers’ income. Variety in end products Within each category of dairy products sold to the consumers, the products are extremely diversified and sold within a large range of prices corresponding to the various consumers’ needs and expectations. For example, for liquid milk, the different products differ as regards the process (pasteurized, ESL, UHT…), the fat content, specific content features (lactose-free, vitamin enriched, omega-3…), added ingredients (plain, chocolate, strawberry…), the pack type, the pack size, the origin of the raw milk, conditions of production (small farmers, mountain milk, grass-fed, GMO-free fed, fair trade), the type of brand (manufacturers’ brands, private labels, unbranded products). In addition to this diversity, the dairy consumer products are very different from a member state to another. So, comparing such prices inside a Member State and between member states is not relevant and would be misleading. Variety in selling prices over time: Moreover, defining an ex-factory selling price for a consumer product is not easy at all considering the sophistication of the negotiation process between the retailers and the suppliers: contracted price, invoiced price, different types of promotion budgets deducted at the national, regional and store levels, end-of-the-year discounts, international discounts… Publication of ceiling prices is harmful: In each member state, the dairy supply chain faces an extreme concentration of the retailers and is exposed to unfair trading practices well identified by the Commission. Expanding the scope of the current publication of raw milk and commodity prices to cover price, cost and margin of consumer products would not bring any benefit for the dairy farmers and inversely would create a high risk of collusion at the retailers’ level. From its members’ experiences, EDA wants to alert the Commission and the farmers’ stakeholders that, when an ex-factory price for a consumer product is published, this price is immediately considered by the retailers as a ceiling price in the coming negotiations with the suppliers. So, publishing ex-factory prices for consumer products would exert more downward pressure on prices in the dairy supply chain and would be detrimental to the suppliers’ margins and thus to the dairy farmers’ income. Furthermore, we have already seen examples of how the growth of discount businesses in the EU is driving down the markets using short-term tenders. Hence, in practice retailers will drive down the price across all products meaning that the dairy sector will struggle to recover the extra cost of new initiatives - often driven by consumer trends- like GMO-free,
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Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

9 Apr 2019 · EU dairy policy

Meeting with Phil Hogan (Commissioner)

16 Nov 2018 · Address Annual Convention

Response to Establishing a legal limit for the industrial trans fats content in foods

26 Oct 2018

EDA welcomes the Draft Commission Regulation amending Annex III to Regulation (EC) No 1925/2006 of the European Parliament and of the Council as regards trans fat, other than trans fat naturally occurring in animal fat, in foods intended for the final consumer. The European Dairy sector particularly appreciates the recognition of the specific situation of natural TFAs given that ruminant trans fats sources, such as dairy, generally contribute in a limited way to high total daily intakes. Ruminant trans fats are naturally present in foods in fixed, small proportions of ruminant fat and cannot be reduced in the fat and cannot therefore totally be avoided. Furthermore, with regards to the possible negative impact of such a limitation on the consumption of milk and dairy products, we are grateful the Commission acknowledged the important role milk and dairy products play in a balanced and healthy diet. Lower consumption of milk and dairy foods could have a negative impact on public health, including a reduced intake of essential nutrients such as high-quality protein, vitamins and minerals, e.g. calcium. Any measures or legislation in the context of limitation of natural TFAs would be therefore unhelpful and should be discouraged as negatively affecting consumption of dairy products and public health. Naturally occurring, rTFAs should be therefore always exempted from any legislative measure to limit TFA (including labelling). Annex See more in the EDA Q&A on TFA Additional scientific references: - Alexander D et al., Br J Nutr. 2016; 115(4): 737-50. Dairy consumption and CVD: a systematic review and meta-analysis - Drouin-Chartier JP, et al., Adv Nutr 2016; 7(6), Comprehensive Review of the Impact of Dairy Foods and Dairy Fat on Cardiometabolic Risk - Guo J, et al., Eur J Epidemiol 2017; 32(4): 269-287, Milk and dairy consumption and risk of cardiovascular diseases and all-cause mortality: dose-response meta-analysis of prospective cohort studies - Liang J, et al. Crit Rev Food Sci Nutr 2017, Biomarkers of dairy fat intake and risk of cardiovascular disease: a systematic review and meta-analysis of prospective studies - Wang Y and Proctor SD., Current issues surrounding the definition
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Response to Multiannual Financial Framework - AGRI Proposal (3/3) - Common Organisation of the Markets

1 Aug 2018

The European Dairy Association, the voice of dairy processors in the European Union, welcomes the proposals on the future of the CAP from the European Commission. The CAP is an essential part of the agriculture sector and especially of the dairy sector. Its implementation is key to the competitiveness of the dairy sector in the different regions of the EU. Furthermore, we welcome the focus on sustainability as this will be a vital topic for the development of the dairy sector in the future (socially, economically and environmentally). What is important is that the focus will shift from the rules and compliance to results and performance. Direct payments still play a vital role in stabilising income for individual farmers. Ultimately, the achievement of these ambitious goals under the CAP needs to be funded by sufficient budgets. The detailed remarks from the European Dairy Association to the Commission’s Consultations on the CAP Strategic Plans and on the Common Organisation of the Markets are attached.
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Response to Multiannual Financial Framework - CAP Strategic Plans

1 Aug 2018

The European Dairy Association, the voice of dairy processors in the European Union, welcomes the proposals on the future of the CAP from the European Commission. The CAP is an essential part of the agriculture sector and especially of the dairy sector. Its implementation is key to the competitiveness of the dairy sector in the different regions of the EU. Furthermore, we welcome the focus on sustainability as this will be a vital topic for the development of the dairy sector in the future (socially, economically and environmentally). What is important is that the focus will shift from the rules and compliance to results and performance. Direct payments still play a vital role in stabilising income for individual farmers. Ultimately, the achievement of these ambitious goals under the CAP needs to be funded by sufficient budgets. The detailed remarks from the European Dairy Association to the Commission’s Consultations on the CAP Strategic Plans and on the Common Organisation of the Markets are attached.
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Response to Reducing marine litter: action on single use plastics and fishing gear

23 Jul 2018

The dairy industry agrees with the overarching objective of reducing marine litter. Nevertheless, the European Dairy Association (EDA) asks for the proposal to be coherent with the current EU policy framework for packaging, proportionate in scope (10 most found Single Use Plastics (SUP) on European beaches) and clear in order to facilitate the implementation process. It is essential to take into account that for dairy products, packaging – including plastic packaging – has primarily a food safety functionality, and also plays an integral part in reducing food waste by keeping dairy products fresh and safe for longer. Hence, environmental and safety considerations will always need to be balanced. It also needs to be highlighted that dairy products are mostly consumed in household and do not contribute to plastic marine littering, and as such they shall not fall under the requirements of the proposed Directive. Notwithstanding, the dairy industry is involved in many initiatives to further streamline the environmental impact of its packaging and strives to also find improved solutions for collection and recycling. For further details on EDA position, please see the position paper attached.
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Response to Revision of the Drinking Water Directive (RECAST 2017)

30 Mar 2018

EDA comments on the EU Commission proposal for a revised Drinking Water Directive (DWD) EDA welcomes The European Dairy Association (EDA) welcomes the European Commission proposal for a revised Drinking Water Directive (DWD). For the dairy industry water is an essential resource, and safe food is based on safe water. At the same time the dairy industry is wishing to further strive in circularity and reuse more water internally. General context The European Dairy Association (EDA) welcomes the European Commission proposal for a revised Drinking Water Directive (DWD). The proposal is part of the COM Circular Economy Action Plan presented in December 2015. Indeed, it contributes to the transition to a circular economy, thus being in line with the fundamental circular economy mindset typical of the dairy sector (please see our statement: link). Safe drinking water is a public good, and EDA would like to reiterate the importance of drinking water for safe dairy products. Indeed, water is key element to assure safe and high-quality food production, as it is used in the dairy plants for heating, cooling, washing, and cleaning, always prioritising the highest hygienic standards and maximum safety in all sectors of production (see our factsheet: link). The dairy sector is fully committed to increasing the reuse of water all along the food production chain (please see our special factsheet: link) and wishes the Directive to set the right legislative context for this. The scope of the Directive proposal EDA welcomes the specific reference in recital 3 of the proposal (recital 10 of the previous directive 98/83/EC) which states that FBO’s water intake should fall in the scope of the Directive proposal. The Dairy industry considers as essential the clear reference within recital 3 to water used in food production as to be considered as food with the meaning of the second subparagraph of Article 2 of Regulation (EC) No 178/2002. The dairy sector wishes to increase the reuse of water all along the food production chain. Therefore, EDA reiterates its positive understanding that the accountability related to the water used in food production, whether it is reused or not, remains on FBO’s responsibility under the General Food Law Regulation (EC) No 178/2002. As a final remark on the scope of the Directive proposal, we would like to recall that the so called “cow water” is produced and used in the production of dairy products. Such water has always been considered fully as food with the meaning of the second subparagraph of Article 2 of Regulation (EC) No 178/2002. Therefore, we would appreciate a rewording of Article 2 paragraph 1 of the Directive proposal, specifically the words [all waters], in order to take into account our sector concern. Chlorates The European dairy industry wishes to recall that chlorination of potable water used in food processing plays an essential role in the control of microbial, viral or parasitic pathogens and limits the occurrence of foodborne diseases. Processing and cleaning water needs to contain sufficient residual concentrations of active substances to ensure microbiological quality and ensure the safety of food production and to prevent re-contamination of cleaned and disinfected surfaces. EDA is concerned that too strict limits for chlorates would require the reduction of disinfectants to concentrations below those considered as effective to achieve sufficient elimination of pathogens. The REFIT stakeholder platform requests proportionate risk management measures regarding the presence of chlorate in food, for details see: link. We, as EDA, believe that the reduction of the levels of chlorate in drinking water is a necessary step prior to the setting of maximum levels for chlorate in food without, however, undermining public health risks.
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Response to Commission Implementing Regulation on the provision of voluntary indication of origin or place of provenance of foods

1 Feb 2018

EDA comments on draft DG SANTE implementing act on rules for voluntary origin labelling EDA in principle welcomes the new version of the draft Implementing Regulation on rules for voluntary origin labelling (version published for public consultation from 4 January - 1 February 2018), especially because trademarks and geographical indications will not be covered by the scope of the Regulation (Art.1.2). We believe that this is a step in the right direction, showing the EU continues to maintain protection of the intellectual property of the European companies, as well as the EU quality schemes. However, the current draft text implies that specific rules on trademarks and GIs might be adopted in the future. We believe that the exclusion of trademarks and GIs should be permanent and therefore not be covered by any specific rules in the future. We would like to take this occasion to reiterate the position of the European dairy sector that trademarks, brand names and GIs should be clearly excluded from the scope of the Regulation, for the reasons explained in our detailed comments below. We would also like to take this occasion to encourage a rapid adoption of harmonised European rules on voluntary origin labelling in order to stop the process of disruption of the internal market caused by introduction of national rules on mandatory origin labelling in several Member States. Please see our detailed comments in the pdf file enclosed to this submission concerning the following points: 1. Trademarks and brand names should be excluded from the scope of any future specific rule mentioned in recital 7 and art. 1.2 2. Geographical indications (PDO, PGI, TSG) should be also excluded from the scope of the Regulation 3. Customary and generic names 4. De-localising indications under Art.26.2(a) should not be covered 5. Presentation of the information ***END**
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Response to Fitness Check of the Water Framework Directive and the Floods Directive

17 Nov 2017

EDA, the European Dairy Association, represents the dairy processors in the EU. EDA welcomes the Commission Fitness Check of the Water Framework Directive and the Floods Directive. For the dairy industry water is an essential resource, as it is stated in the roadmap saying “water is essential for many economic activities and for the environment”. Potable and drinking water are essential components to allow and maintain food safety and quality of dairy production and products, at all levels of the chain. We particularly welcome the recognition in the Roadmap of an “integrated assessment looking, inter alia, at the interplay of water with other policies, which started in mid-2017, as this is critical to ensure the setting of appropriate food related risk management measures to use of water”. One example being the eventual presence of chlorate agents in food resulting from the use of drinking water in food production. The REFIT stakeholder platform requests proportionate risk management measures regarding the presence of chlorate in food, for details see: https://ec.europa.eu/info/sites/info/files/xi10amultiple_use_chlorate.pdf . We are looking forward to further the discussions on the diverse aspects of water use in dairy production.
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Response to Initiative to improve the Food Supply Chain

21 Aug 2017

The dairy sector, the milk farmers and their milk processing dairies, are in a unique and specific situation. The specificities of the dairy sector at milk supply level have proven to be essential for the dairy sector and must be respected when considering setting up new horizontal rules. Unfair trade practices (UTPs) The partnership between dairy farmers and their milk processing dairies is either anchored in the statues of the farmer owned milk processing cooperatives, that process roughly 50% of the raw milk produced in the Union, or via the rules of the 2012 Milk Package, that guide the partnership for the privately-owned dairies and their milk suppliers. The highly competitive dairy environment ensures that private dairy companies broadly operate the same commercial practices with their supplying farmers as dairy co-ops. There is no evidence of any substantive difference in the commercial relationship with their milk suppliers between co-ops and private dairies. Arbitrary changes to contract terms or disregard of contractual commitments that characterise UTPs are not a common occurrence between dairy farmers and milk purchasers. As such, discussions on UTPs should focus on relationships between processors and customers (retail and food processing companies). Market transparency To improve the market transparency for all market participants, the Milk Market Observatory (MMO) was established in 2014 and has since then increased the transparency in the dairy sector. The MMO acts as an information exchange platform that involves all stakeholders in the EU dairy sector and through its existence, the EU Commission has significantly improved its capacities in terms of market monitoring and in terms of communication. Over the past two years, DG AGRI has greatly worked in getting more representative and reliable data with the help of the Member States who are requested to deliver the national milk market data in ‘real time’ to the EU Commission. The success of the MMO is underlined by the set-up of Market Observatories for three other product categories. Producer cooperation The dairy sector is already well organised with co-ops and private dairies with strong links between the milk producers and the milk processors. The proportion of milk accounted for by dairy co-ops and the strength of the relationship between dairy farmers and many private companies means that constructive relations within the milk supply chain are a reality. When it comes to enhanced cooperation between milk producers, the 2012 Milk Package strengthened the Producer Organisations and highlighted the role of farmer owned dairy cooperatives. The creation of Producer Organisations inevitably has to be left to the initiative of dairy farmers. There is already widespread knowledge of the availability of this option by dairy farmers. The creation of POs requires leadership, trust, sustained communication, administrative expertise, a willingness of farmers to commit their own financial resources and time. In considering options for the further development of POs and APOs it is important that their creation should remain at the discretion of dairy farmers and that individual dairy farmers supplying a private dairy company should not be compelled to join them if they do not wish to do so. We strongly believe that further regulation is not required in producer/purchaser relations in the dairy sector. We believe a better approach would be a focus on the competitiveness of the EU dairy sector. This would translate by ensuring the proper development of competitive EU markets whilst assisting dairy farmers to continually improve their international competitiveness. This would ensure the industry would be able to make the fullest possible contribution to EU growth and global food security.
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Response to Evaluation of marketing standards [Regulation (EU) No 1308/2013]

24 Jul 2017

Dear Ms Dos Reis, We are delighted to see DG AGRI underlining the utmost importance of common product definitions / products standards and of the protected dairy terms within the EU policies for consumer protection and product quality - this fully aligns with the overarching principles of the Single Market of our Union and the objectives of the CAP. We had the pleasure to discuss the topic at the Civil Dialogue Group MILK of DG AGRI (not mentioned in your roadmap of 28 June 2016) on 10NOV2015 and we had a follow up exchange with you esteemed colleague, M Sergiusz Waplak in January 2016 on that very topic. The completion of the Single Market and the high level of consumer protection and product quality requires our dairy marketing standards / common product definitions and protected dairy terms. We would love to see you evaluation also including the possibility for establishing a EU definition for cheese and for processed cheese (see enclosed two pager). It will be with a great pleasure that we will answer the public consultation announced for the first quarter of 2018 and in the meantime, we are - of course - ready to answer any question you may have wrt common product definitions / products standards and of the protected terms in our dairy sector. Again, thank you so much for this initiative, Vive l'Europe et vive le lait Alexander Alexander Anton Secretary General EDA – European Dairy Association 22 – 28, avenue d’Auderghem, 1040 Brussels Tel: +32 2 549 50 41 - Mobile: +32 475 590 422 aanton@euromilk.org - www.euromilk.org @EDA_Dairy @dairyanton Connect to the World of Dairy
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Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

6 Jul 2017 · Business discussion

Response to Specific rules concerning food replacing the whole daily diet for weight reduction purposes

17 Mar 2017

In light of the Commission work on the adoption of a delegated Regulation on total diet replacement for weight control, the European Whey Processors Association (EWPA) would like to reiterate support for the Commission proposal, in particular on the recommended minimum protein content of 75 g/day. The European Dairy Association (EDA) is fully supportive of the EWPA position. As the voice of the whey manufacturing industry in Europe, EWPA appreciates the opportunity to comment on the content of the proposed delegated act and welcomes the proposal of the Commission, in particular, where it establishes a minimum of 75g of high quality protein per day for products for Total Diet Replacement for weight control (TDR). The Commission proposal is also fully supported by the European dairy industry, represented by the European Dairy Association (EDA). Total Diet Replacements for weight control (TDR) are intended to be used by healthy overweight or obese adults who wish to lose weight and are generally regarded as an effective way to achieve weight reduction. The compositional advice of the European Food Safety Authority (EFSA) is based on widely accepted scientific evidence and it reflects the dietary advice that is widely considered efficacious. EFSA proposed a minimum protein content based on a Population Reference Intake for protein adjusted for the overweight or obese and set the minimum protein intake at 75 g/day. EWPA and EDA welcome the fact that science-based nutritional values proposed by EFSA have been also widely supported by the Member States in the Commission Expert Group. As concluded by the Scientific Opinion of EFSA, it is clear that protein requirements are closely linked to fat-free mass (FFM). Since FFM is higher in overweight and obese people, the protein requirements for this target group should be related to FFM. Next to that, the EFSA opinion includes scientific studies which support the importance of a high protein diet during energy-restriction to achieve weight loss and maintain FFM. Given the EFSA conclusions, EWPA and EDA believe that setting the minimum protein content at 75g/day would ensure that TDR products are safe and efficacious for their intended use. We have analysed certain concerns raised by manufacturers of TDR on the price and consumer taste acceptability and we believe that the cost increase, if any, would be negligible. We are sure that taste of products will not be negatively affected by the increase of protein content as milk and whey protein have a clean and neutral taste appreciated by the consumers. Milk proteins, including whey proteins, are high quality proteins which have a clean and acceptable taste. This neutral taste, along with the variety of speciality whey and dairy protein ingredients available, has always permitted for whey proteins to be incorporated into a wide variety of food applications at high concentrations delivering up to 100% of the energy of the food. This is the case for sports nutrition products where quality, taste and cost are important factors, yet products such as protein shakes and protein waters provide all the energy from whey protein. Furthermore, certain TDR products currently on the market in Europe, already meet the minimum 75 g protein/day based on a maximum energy intake of 600 kcal/day. Certainly, there is opportunity for this regulatory change to be managed positively. The main purpose of TDR products is to help overweight and obese adults to lose weight in a healthy way. The EFSA scientific opinion concludes that minimum daily protein intake of 75 g/day should be provided by TDR in order to achieve this objective. Our detailed comments are provided in the enclosed EWPA/EDA Position Paper. We would like to take this occasion to thank to the European Commission services for the opportunity to express our views in this open public consultation.
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Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

2 Dec 2016 · EDA Conference

Meeting with Phil Hogan (Commissioner)

2 Dec 2016 · Addressing Annual Convention

Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan)

10 Oct 2016 · Topics related to the milk & dairy processing sector

Meeting with Nils Behrndt (Cabinet of Vice-President Neven Mimica)

22 Sept 2016 · Dairy in development cooperation and European External Investment Plan

Meeting with Cecilia Malmström (Commissioner)

6 Sept 2016 · Trade for all strategy

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

19 Jul 2016 · AGRI Issues

Meeting with Phil Hogan (Commissioner)

19 Jul 2016 · Agri Matters

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

15 Jun 2016 · situation of dairy industry

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

13 Jun 2016 · Diary sector in FTAs

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis)

1 Jun 2016 · Animal welfare, Food waste, Origin labelling

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

30 May 2016 · Nutritional benefits

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

2 Dec 2015 · Business discussion

Meeting with Phil Hogan (Commissioner)

2 Dec 2015 · Dairy matters

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

10 Nov 2015 · Dairy in international markets

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

25 Feb 2015 · Agriculture policy and investments

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

18 Feb 2015 · Exchange on milk market situation; EDA commitment to transparency and cooperation : economic board of MMO, presidium of the CDG MILK & beyond; Dairy Policy & EDA dairy policy recommendations; “Dairy Policy for the 21st Century” – up-date on the EDA Conference of 18 March 2015; “2015 – A New Start for the European Dairy” – EDA Annual Convention 15 October 2015 in Edinburgh / UK

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

22 Jan 2015 · EU Dairy Sector in trade agreements

Meeting with Vytenis Andriukaitis (Commissioner) and

9 Jan 2015 · NUTRITION AND HEALTH CLAIMS, FOOD INFORMATION TO CONSUMERS – GENERAL OVERVIEW, ORIGIN LABELLING, TRANS FATTY ACIDS, NATIONAL APPROACHES AND SINGLE MARKET, FOOD WASTE REDUCTION, ANIMAL HEALTH AND WELFARE,