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European farmers

COPA

European farmers represents the voice of EU farmers and promotes their economic interests.

Lobbying Activity

Meeting with Brigitte Misonne (Acting Director Agriculture and Rural Development) and European agri-cooperatives

12 Jan 2026 · Pigmeat market situation

Meeting with Ursula von der Leyen (President) and European agri-cooperatives

18 Dec 2025 · Discussion of issues concerning the European agricultural sector

Meeting with Diego Canga Fano (Acting Deputy Director-General Agriculture and Rural Development)

17 Dec 2025 · Research and innovation for agriculture in the MFF.

Meeting with Victor Negrescu (Member of the European Parliament)

10 Dec 2025 · Securing the Eastern Flank: Ensuring a Level Playing Field for CEE Farmers

Meeting with Maxi Espeter (Cabinet of Commissioner Christophe Hansen) and European agri-cooperatives

2 Dec 2025 · Upcoming proposal on organic basic regulation

Meeting with Olivér Várhelyi (Commissioner) and

21 Nov 2025 · Plant protection products; simplification package; NGTs; EC initiatives and timeline in the area of animal welfare; Commission’s work in the area of animal health

Meeting with Brigitte Misonne (Acting Director Agriculture and Rural Development) and European agri-cooperatives

20 Nov 2025 · Stocktaking of the October Livestock Workstream meeting and preparation of the December one

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis) and European agri-cooperatives

20 Nov 2025 · CBAM

Meeting with David Cormand (Member of the European Parliament) and International Federation of Organic Agriculture Movements EU Regional Group and

19 Nov 2025 · Event: "This Land Is Our Land: Generational Renewal and Access to Land in Europe"

Meeting with Andrea Vettori (Head of Unit Environment) and European agri-cooperatives and

19 Nov 2025 · Guidance document on the species protection requirements of the Birds Directive

European Farmers Urge Flexible Rules for Organic Livestock Production

17 Nov 2025
Topic — EU policy revision aimed at simplifying organic farming rules and trade flows.
Message — They request extending the 5% non-organic protein feed derogation beyond 2026. They also propose removing medicine withdrawal rules and reducing outdoor space requirements.1234
Why — This would reduce their production costs and solve technical feed sourcing challenges.5
Impact — Consumer groups lose the assurance of strict natural standards if exemptions are expanded.6
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Meeting with Almut Bitterhof (Head of Unit Health and Food Safety) and European agri-cooperatives

12 Nov 2025 · COPA COGECA asked E4 for a meeting to express views on the ongoing Commission work on the SANTE Simplification Omnibus

Meeting with Esther De Lange (Cabinet of Commissioner Christophe Hansen)

11 Nov 2025 · Future CAP, MFF, EUDR, CBAM Ares(2025)9755411

Meeting with Irene Sacristan Sanchez (Head of Unit Health and Food Safety)

3 Nov 2025 · The Commission proposal on plants obtained by certain new genomic techniques (NGTs).

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall) and European agri-cooperatives

31 Oct 2025 · EUDR & Bioeconomy Strategy

Meeting with Johannes Van Den Bossche (Cabinet of Commissioner Christophe Hansen) and European agri-cooperatives

29 Oct 2025 · Exchange of views on files concerning international trade in agrifood

Meeting with Dorota Denning (Cabinet of Commissioner Valdis Dombrovskis) and European agri-cooperatives and

28 Oct 2025 · Roundtable on Simplification for Agricultural Innovation

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall) and European agri-cooperatives

23 Oct 2025 · EUDR

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall) and European agri-cooperatives

15 Oct 2025 · Nitrite directive; Industrial Emissions

Meeting with Maria Gafo Gomez-Zamalloa (Head of Unit Agriculture and Rural Development) and European agri-cooperatives

13 Oct 2025 · Plant protection products / omnibus simplification

Meeting with Claire Bury (Deputy Director-General Health and Food Safety) and

9 Oct 2025 · Exchange of views on the state of play of the interinstitutional negotiations on the Commission proposal for a Regulation on plants obtained by certain new genomic techniques (NGT proposal)

Meeting with Sandra Gallina (Director-General Health and Food Safety) and

8 Oct 2025 · Plant protection products - maintaining a competitive and resilient agricultural toolbox in the EU.

Meeting with Valdis Dombrovskis (Commissioner) and

3 Oct 2025 · Simplification of non-CAP legislation that affects agriculture and the food chain

European Farmers Back Poultry Import Reform With Strict Conditions

2 Oct 2025
Topic — EU regulation simplifying proof-of-origin requirements for poultry import quotas.
Message — Copa-Cogeca supports allowing supply contracts as proof of origin but demands robust safeguards. They want standard templates, risk-based audits, clear sanctions for misdeclared origin, and traceability requirements. They request the Commission monitor market effects for 12 months and retain exclusive EU control over quota management.1234
Why — This would improve their access to tariff quotas and reduce discriminatory practices by third countries.56
Impact — Third-country exporters face stricter controls and lose ability to manage quotas through national systems.7
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European Farmers Warn Plant Protection Rules Risk Fewer Products

2 Oct 2025
Topic — EU regulation updating safety assessment methods for pesticides and plant protection products.
Message — Copa and Cogeca request reconsideration of provisions that could unnecessarily restrict product availability. They argue stricter assessment methods and new exposure thresholds will reduce authorized products and create additional uncertainty. They want authorizations granted when honeybee colony viability and recovery are guaranteed.123
Why — This would preserve access to pest control tools farmers need for crop protection.4
Impact — Environmental and health groups lose stricter protections against pesticide exposure and colony damage.5
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European Farmers Warn Nature Credits Risk Undermining Food Production

30 Sept 2025
Topic — EU proposal to create market-based nature credits for biodiversity protection.
Message — The organization demands the Commission slow down and clarify fundamental questions before legislating. They want nature credits designed as complementary income, not replacement for productive land use. A dedicated Nature Restoration Fund outside CAP is essential to meet €11-12 billion annual costs.123
Why — This would protect their productive land use while accessing new income streams.45
Impact — Environmental groups lose stricter requirements if productive farming remains compatible with credits.6
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Meeting with Claire Bury (Deputy Director-General Health and Food Safety) and European agri-cooperatives

25 Sept 2025 · EFSA’s performance evaluation and SANTE simplification package

Meeting with Pierre Bascou (Deputy Director-General Agriculture and Rural Development) and European agri-cooperatives and AGPB

25 Sept 2025 · 1. Revision of Regulation 1107/2009 on plant protection products 2. Difficult economic situation of specialist cereals farmers

Meeting with Carla Tavares (Member of the European Parliament)

24 Sept 2025 · Introduction

Meeting with Fabien Santini (Head of Unit Agriculture and Rural Development) and European agri-cooperatives

24 Sept 2025 · Meeting requested by the COPA-COGECA Secretariat on the Commission’s proposals to amend the Common Market Organisation (CMO) Regulation (MFF post-2027).

Meeting with Olivér Várhelyi (Commissioner) and

22 Sept 2025 · Plant protection products, animal welfare, NGTs

Meeting with Brigitte Misonne (Acting Director Agriculture and Rural Development) and

22 Sept 2025 · Livestock workstream. & impact of developments in plant protection products (PPPs) on arable crops

Meeting with Stefan Leiner (Head of Unit Environment) and European agri-cooperatives

19 Sept 2025 · Exchange of views on simplification initiatives for the Industrial Emissions Directive

Meeting with Eric Mamer (Director-General Environment) and

19 Sept 2025 · Exchange of views on policy issues relevant to the agriculture and forestry sector

Meeting with Eric Mamer (Director-General Environment) and

19 Sept 2025 · Exchange of views on policy issues relevant to the agriculture and forestry sector

Meeting with Brigitte Misonne (Acting Director Agriculture and Rural Development) and European agri-cooperatives

12 Sept 2025 · Pigmeat market situation, trade irritants, livestock workstream

Meeting with Catherine Geslain-Laneelle (Director Agriculture and Rural Development) and European agri-cooperatives

11 Sept 2025 · Exchange on view on the Vision on Agriculture and Food

Meeting with Gijs Schilthuis (Director Agriculture and Rural Development) and European agri-cooperatives

4 Sept 2025 · Plant protection

Meeting with Ion Codescu (Head of Unit Environment) and European agri-cooperatives and

3 Sept 2025 · Exchange of views on the Commission’s draft amendment of the Nitrates Directive on RENURE

European farmers urge science-based rules to protect fur farming

31 Jul 2025
Topic — The Commission is assessing potential bans or new regulations on EU fur farming.
Message — The organization requests that any assessment be based on science rather than ideological pressure. They support harmonising welfare standards across the EU if they remain proportionate. They also advocate for using existing industry-led welfare certification data.12
Why — Preventing a ban allows the sector to protect 8,000 jobs and its annual exports.34
Impact — A ban would harm rural communities that depend on fur farming for employment.5
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Meeting with Michael Erhart (Director Budget)

18 Jul 2025 · Presentation of the MFF package proposal.

Meeting with Catherine Combette (Head of Unit Agriculture and Rural Development) and European agri-cooperatives

15 Jul 2025 · Exchange of views on on-going FTA negotiations with the Philippines, Australia, India, Indonesia and Thailand.

European Farmers Demand Safeguarded Budget for Generational Renewal

14 Jul 2025
Topic — Commission initiative to attract young farmers and address demographic challenges in agriculture.
Message — The organization opposes merging agricultural funding into a single EU fund. They demand a dedicated, inflation-adjusted budget to ensure farming remains a viable career.12
Why — A protected, separate budget ensures stable subsidies and financial support for their members.3
Impact — EU budget reformers lose the flexibility to reallocate funds away from traditional farming subsidies.4
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Meeting with Klaus Berend (Director Health and Food Safety) and

10 Jul 2025 · Exchange of views on the state of play of the interinstitutional negotiations on the Commission proposal for a Regulation on plants obtained by certain new genomic techniques (NGT proposal) - Patent-related aspects.

Response to Critical Medicines Act

4 Jul 2025

Copa-Cogeca welcomes the European Commissions initiative to strengthen the resilience of the supply chain for critical medicinal products, and its alignment with the EUs One Health approach. The proposal rightly recognises the interdependence of human, animal, and environmental health and the need for coordinated action across sectors. In line with the One Health framework, it is crucial to ensure that veterinary medicinal productsparticularly vaccinesare given equal importance to human medicinal products. The health of livestock and other animals is directly linked to public health, food safety, environmental protection, and the economic viability of Europes farming sector. Over 60% of new and emerging infectious diseases affecting humans are zoonotic in origin, underlining the need for a robust animal health strategy that prioritises disease prevention. Vaccination is a cornerstone of such a strategy. By preventing infectious diseases in animals, vaccination significantly reduces the need for antibiotic treatments, thereby contributing to the fight against antimicrobial resistance (AMR). AMR remains one of the greatest global threats to health and food security, with the World Organisation for Animal Health (WOAH) warning that by 2050, it could threaten the food security of two billion people and cause economic losses of up to $100 trillion. However, farmers across the EU continue to face shortages of key veterinary vaccines. These shortages not only hinder the adoption of preventive health strategies but also disrupt existing vaccination programmes on farms. The lack of availability of these products places animal health and welfare at risk, increases the likelihood of disease outbreaks, and ultimately compromises food security. Therefore, Copa-Cogeca strongly recommends that the proposed list of medicinal products of critical interest explicitly includes veterinary medicines, particularly veterinary vaccines. The criteria used to determine criticality should encompass animal health needs alongside human health needs. Where shortages of essential animal vaccines occur, the knock-on effects can be significant, jeopardising not only livestock health and productivity but also potentially leading to public health risks. We also call for a strengthened governance framework that ensures coordination between human and veterinary medicine regulators, industry stakeholders, and primary producers. This should include improved data collection and early warning systems for veterinary medicine shortages, as well as coordinated strategies for mitigating and managing such disruptions. In conclusion, addressing supply chain vulnerabilities and improving the availability of both human and veterinary medicinal products is essential for building a resilient health system. A fully integrated One Health approach that recognises the critical role of the agricultural sector is key to safeguarding health, sustainability, and food security in the European Union.
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Meeting with Claire Bury (Deputy Director-General Health and Food Safety) and

3 Jul 2025 · Exchange of views on the state of play of the interinstitutional negotiations on the Commission proposal for a Regulation on plants obtained by certain new genomic techniques (NGT proposal)

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

23 Jun 2025 · Meeting was with Walloon branch of COPA (FWA - Fédération Wallonne de l'Agriculture). Discussion items were - Green requirements under current CAP - Future of CAP - FTA with Mercosur (also impact of Ukraine agri products to EU Single Market)

Meeting with Elisabeth Werner (Director-General Agriculture and Rural Development) and European agri-cooperatives

17 Jun 2025 · Introductory meeting and general exchange of views on the future common agricultural policy

Meeting with Johannes Van Den Bossche (Cabinet of Commissioner Christophe Hansen) and European agri-cooperatives

11 Jun 2025 · International trade developments

Meeting with Bjoern Juretzki (Head of Unit Communications Networks, Content and Technology) and European agri-cooperatives

11 Jun 2025 · Discussion about the state of play of the Data Act implementation in the agricultural sector.

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen) and European agri-cooperatives

5 Jun 2025 · to follow

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen) and European agri-cooperatives

5 Jun 2025 · Exchange of views on the Multiannual Financial Framework (MFF) in relation to the Common Agricultural Policy (CAP) and the agri-food trade situation with Ukraine.

Meeting with Brigitte Misonne (Acting Director Agriculture and Rural Development) and European agri-cooperatives

28 May 2025 · Exchange of views on the EU Vision for Agriculture and Food, in particular the livestock workstream

Response to Wine package: Implementation of the recommendations of the High-Level Group on wine policy

26 May 2025

Copa and Cogeca welcome the Commissions legislative proposal on the so-called Wine Package and recognise it as a timely opportunity to support the EU wine sector during a period of structural crisis and market uncertainty. While many elements of the proposal are appreciated, Copa and Cogeca suggest targeted improvements to ensure that the reform remains efficient, inclusive, and practical for producers on the ground. Regarding planting and replanting authorisations, we fully support the exemption from administrative penalties for valid authorisations granted before January 2025 and the extension of replanting authorisation validity to eight years. However, we also call for the establishment of a fixed annual expiry date for all authorisationspreferably set on 31 Julyto simplify planning and monitoring. Furthermore, we advocate for making the simplified replanting procedure (currently optional under EU law) the standard rule across Member States, reducing unnecessary administrative burden for farmers. Copa and Cogeca also support the proposed limitation of new planting authorisations in areas where crisis measures have been implemented. This would allow Member States to align production potential with market demand. On the other hand, we strongly oppose introducing conditions that limit yield increases, both for replanting authorisations and for vineyard restructuring and conversion measures. Such restrictions would hinder innovation and harm the economic viability of wine productionparticularly for small and micro-enterprises. On labelling and marketing, Copa and Cogeca call for clearer definitions for categories such as alcohol-free, alcohol-free 0.0%, and alcohol-light wines. These terms should be clearly defined to avoid confusion, especially when translated across different EU languages. In addition, a transitional period should be introduced to allow wines from the 2026 harvest to comply with new labelling requirements without economic disruption. We also request that mandatory particulars appear only once on wine labels and that wines produced and intended solely for third-country markets be exempted from EU labelling obligations. Concerning crisis measures, Copa and Cogeca support the use of both EU and national funds and suggest setting a maximum threshold of 30% of the national wine budget for payments related to distillation and green harvesting. On rural development and diversification, Copa and Cogeca endorse the extension of wine tourism support to recognised Producer Groups managing GIs but ask that this also include producer organisations, cooperatives, and individual enterprisesactors who often play a key role in running local wine tourism initiatives. In terms of promotional activities, Copa and Cogeca support efforts to strengthen visibility in consolidated markets. However, we argue against imposing a non-renewable five-year time limit on promotional funding, as many producers require continued support to maintain their presence in competitive global markets. Finally, Copa and Cogeca call for cooperatives to be explicitly included among the beneficiaries eligible for investment support under Article 59 of the Strategic Plans Regulation. Cooperatives are often formed by small and micro-producers, and their role in strengthening the sectors sustainability and competitiveness must be fully recognised.
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Meeting with Jessika Roswall (Commissioner) and

26 May 2025 · Discussions on Water Resilience Strategy and Nature Credits

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall) and European agri-cooperatives

22 May 2025 · Discussions on Water Resilience Strategy and Nature Credits

Meeting with Piotr Serafin (Commissioner) and

20 May 2025 · Exchange of views on the future Multiannual Financial Framework and Common Agricultural Policy

Meeting with Flavio Facioni (Cabinet of Commissioner Olivér Várhelyi) and European agri-cooperatives

16 May 2025 · Animal Welfare, Animal Health, Plant Health

European farmers demand simpler deforestation rules for cattle and waste

13 May 2025
Topic — This consultation addresses proposed technical changes to the scope of the EU Deforestation Regulation.
Message — The organization requests simplifying cattle reporting by removing distinctions between pure-bred and other animals. They also propose exempting recycled materials and by-products from the regulation's scope.12
Why — Removing these requirements would reduce administrative work and reporting burdens for livestock farmers.3
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Meeting with Themis Christophidou (Director-General Regional and Urban Policy) and

6 May 2025 · Future of EU budget; MFF

Meeting with Alisa Tiganj (Cabinet of Commissioner Christophe Hansen) and European agri-cooperatives and

30 Apr 2025 · • ELV five recommendations for the Vision for the Future of EU Agriculture and for the mandate • Presentation of ELV (European Livestock Voice) • Exchange of views: Vision for the future of Livestock • EU Trade policy review: State of play

Meeting with Raphaël Glucksmann (Member of the European Parliament, Shadow rapporteur)

26 Apr 2025 · GSP

Meeting with Piotr Serafin (Commissioner) and

24 Apr 2025 · Exchange of views on access to EU Funding

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

23 Apr 2025 · Vision for Agriculture and Food and in particular, livestock workstream Future MFF/CAP

Meeting with Ion Codescu (Head of Unit Environment) and European agri-cooperatives

14 Apr 2025 · The meeting was organised at the request of the Copa-Cogeca about the Nitrates Directive

Meeting with Arash Saeidi (Member of the European Parliament) and European agri-cooperatives

9 Apr 2025 · Echange de point de vue

Meeting with Catherine Combette (Head of Unit Agriculture and Rural Development) and European agri-cooperatives

7 Apr 2025 · Exchange of views on on-going FTA negotiations with The Philippines, India and Thailand

Meeting with Brando Benifei (Member of the European Parliament) and Reuse and Recycling European Union Social Enterprises

7 Apr 2025 · Amendments to the public procurement INI Report

Meeting with Ana Carrero (Cabinet of Commissioner Piotr Serafin) and European agri-cooperatives

3 Apr 2025 · Exchange of views on the future Multiannual Financial Framework and other EU priorities.

Response to Measures related to specific plant pests

2 Apr 2025

The Commission has proposed extending measures on citrus fruits from Argentina, Brazil, South Africa, Uruguay, and Zimbabwe to prevent the spread of Phyllosticta citricarpa, the pathogen causing Black Spot disease, which poses a serious threat to EU citrus production. Copa and Cogeca have long been vigilant about this issue and have urged the Commission to strengthen border protections. While we welcomed the Regulation (EU) 2022/632, we believe further improvements are needed. We support the Commission's proposal to extend the regulation beyond its 31/03/2025 expiry date, as the risk remains high. The number of contaminated shipments continues to be alarmingly high, and the risk of introducing Phyllosticta citricarpa into EU agriculture persists. In addition to expressing our support, we would like to reiterate three proposals to further enhance the measures preventing the entry of this disease: Harmonisation and strengthening of import controls: There should be an alignment and enhancement of import controls across all Member States to ensure equal effectiveness in preventing the disease. The European Commission should assist Member States in detecting non-compliance with EU pest control measures. Reports on interceptions of quarantine pests and priority organisms: EFSA must provide reports on the number of interceptions of quarantine pests and priority organisms that trigger a halt to citrus imports in the EU. Consistency of controls for citrus fruits intended for processing: The same conditions and controls applied to citrus fruits imported for sale as fresh produce should also apply to those imported for processing. This will ensure uniformity in pest control measures for all citrus imports, regardless of their intended end-use. Copa and Cogeca would like to reiterate that we are not advocating for trade barriers, but rather for the protection of our crops in order to safeguard European citrus orchards and keep them free from quarantine pests. We are calling for coherence and proportionality in the measures taken. At a time when the European fruit sector is already grappling with significant challenges, including the reduction of authorisation of plant protection products and the increasing resistance of pests, it is crucial that Community measures be as effective as possible in preventing the entry of new pests. This approach is in line with what other countries are implementing when confronted with the same risks.
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Response to Equivalence of third countries’ requirements concerning pests of plants - Citrus sinensis from Israel

2 Apr 2025

The Commission's proposal to amend the Commission Implementing Regulation (EU) 2022/1659 seeks to indefinitely extend the possibility for citrus imports from Israel to the EU to be made under an alternative system approach, rather than the cold treatment specified in point 62.1(d) of Annex VII of Regulation 2019/2072 establishing uniform conditions for the implementation of Regulation (EU) 2016/2031 of the European Parliament and the Council, as regards protective measures against pests of plants, and repealing Commission Regulation (EC) No 690/2008 and amending Commission Implementing Regulation (EU) 2018/2019. In light of the detection of the "false colding moth" pest (Thaumatotibia leucotreta) in Israel, Copa and Cogeca strongly oppose any modification to the Commission Implementing Regulation (EU) 2022/1659. The current equivalence, which expires on 31 May 2025, should not be extended. From that date, Israel should be required to apply cold treatment to all plant products, including citrus, that could potentially carry this pest into the EU. The Commission tells us that the risk of the pest being transferred through fruit destined for juice is low. If we read the EFSA pest risk assessment report on Phyllosticta citicarpa referred to by the Commission, and after several considerations, and to summarise, if we go to the conclusions (pg 234 of the report): The Panel concludes that, without regulation, the number of infected fruit entering citrus growing regions and arriving within the maximum distance for spores to move to citrus trees is high and there is good temporal overlap between the timing of entry and the weather conditions suitable for rain splash and spore dispersal. Of the four main pathways, the levels of exposure resulting from these pathways is considered to be highest for the juice industry, ... "The Panel concludes that, without regulation, the number of infected fruits entering citrus- growing regions and travelling the maximum distance for spores to move to trees is high, and there is a good temporal overlap between the timing of entry and the weather conditions suitable for rain splash and spore dispersal. Of the four main routes, the resulting exposure levels are considered to be the highest in the juice industry.... Copa and Cogeca emphasize the significant risk of pest transmission posed by Israel, given its large citrus production and export volume to the EU. The European citrus sector, unified in its opposition to the Commission's proposal, demands that cold treatment be enforced on all plant products from countries where the pest is present, without exceptions for specific products like mandarins or countries like Israel. Furthermore, it is crucial that such treatments are carried out effectively. This approach aligns with the practices already implemented by other global import regions that require cold treatment for suppliers from contaminated countries. It is vital for the EU to adopt this mechanism to ensure the protection of European citrus orchards from pests that threaten both production and biodiversity. This will also help safeguard the environmental sustainability of the EUs agricultural sector.
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Meeting with Koen Dillen (Head of Unit Agriculture and Rural Development) and European agri-cooperatives

2 Apr 2025 · Insects/weeding management, Copa-Cogeca guiding principles on PPPs

Meeting with Andrea Gavinelli (Head of Unit Health and Food Safety)

31 Mar 2025 · Exchange of views on the revision of the animal welfare legislation in the poultry sector

Meeting with Elena Panichi (Head of Unit Agriculture and Rural Development) and European agri-cooperatives

27 Mar 2025 · Exchange of views on the current state of the trade agenda between the US and the EU following the mission of COPA COGECA President to the US

Meeting with Jessika Roswall (Commissioner) and

25 Mar 2025 · Roundtable “Water, Agriculture, and the Food Supply Chain”

Meeting with Piotr Rydzkowski (Head of Unit Trade) and BUSINESSEUROPE and

18 Mar 2025 · CSD Contact Group meeting-Overview of Trade priorities and rolling calendar

European farmers urge preservation of plant variety rights

14 Mar 2025
Topic — Evaluation of EU rules governing intellectual property rights for new plant varieties.
Message — The organization calls for maintaining the current plant variety system and seed reuse rights. They want the list of permitted crops updated and strongly oppose plant patenting.123
Why — Maintaining these exemptions allows farmers to keep costs low by avoiding expensive patent royalties.4
Impact — Large biotech firms lose potential licensing revenue and exclusive control over proprietary seed genetics.5
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Meeting with Catherine Geslain-Laneelle (Director Agriculture and Rural Development) and European agri-cooperatives

13 Mar 2025 · exchange of views on the vision on Agriculture and Food

Meeting with Maroš Šefčovič (Commissioner) and

13 Mar 2025 · Negotiations with Ukraine under Article 29 of the Association Agreement (tariff liberalisation) – Position of European agricultural stakeholders (sugar, poultry, eggs, ethanol, maize, wheat and honey)

Meeting with Johannes Van Den Bossche (Cabinet of Commissioner Christophe Hansen) and European agri-cooperatives

13 Mar 2025 · Exchange of views on issues considered relevant by Copa-Cogeca

European farmers demand priority water access for food security

4 Mar 2025
Topic — Strategic EU initiative to manage water scarcity and enhance aquatic ecosystem resilience.
Message — A water hierarchy should prioritize agricultural water use after drinking water for food supply. They request financial incentives for infrastructure rather than strict cutbacks and legal obligations. They also want to modify legislation to avoid bottlenecks in permitting.123
Why — Farmers would ensure fair and safe access to water and receive rewards for management.45
Impact — Environmental protection may suffer if strict water directives are modified to favor economic activity.67
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Meeting with Brigitte Misonne (Head of Unit Agriculture and Rural Development), Ricard Ramon I Sumoy (Acting Head of Unit Agriculture and Rural Development) and European agri-cooperatives

4 Mar 2025 · Copa-Cogeca’s Guiding Principles for the EU Livestock Sector in the 2024-2029 Mandate

Meeting with Eric Thévenard (Head of Unit Health and Food Safety) and European agri-cooperatives

4 Mar 2025 · Management of weeds in cereals

Meeting with Andrea Gavinelli (Head of Unit Health and Food Safety)

4 Mar 2025 · Meeting on the future of animal welfare and presentation of the “Guiding Principles for the EU Livestock Sector”

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

4 Mar 2025 · Future of CAP; future of EU climate policy; trade agreements

Meeting with Costas Kadis (Commissioner) and European agri-cooperatives

3 Mar 2025 · Courtesy meeting regarding fisheries and fish farming state in the EU

Meeting with Maria Pilar Aguar Fernandez (Director Health and Food Safety) and

27 Feb 2025 · • Climate change and new challenges (pests, weeds and diseases). • IPM support and dissemination to address challenges. • Access to market for biocontrol products • Electronic recording of pesticide use • MRLs

Meeting with Gijs Schilthuis (Director Agriculture and Rural Development) and European agri-cooperatives

25 Feb 2025 · Presentation of the "Guiding Principles for the EU Livestock Sector in the 2024-2029 Mandate" by Copa Cogeca Exchange of views on the Communication from the EC “A Vision for Agriculture and Food” released the 19 of February

Meeting with Jessika Roswall (Commissioner) and

20 Feb 2025 · Linkages between Commissioner’s portfolio area and agriculture

Meeting with Elisabetta Siracusa (Director Agriculture and Rural Development) and

13 Feb 2025 · International trade relations

Meeting with Christophe Hansen (Commissioner) and

13 Feb 2025 · Review of the EU-Ukraine Deep and Comprehensive Free Trade Area (DCFTA)

Meeting with Christine Singer (Member of the European Parliament)

12 Feb 2025 · Green Claims

Meeting with Esther De Lange (Cabinet of Commissioner Christophe Hansen)

12 Feb 2025 · Exchange of views on issues considered relevant by COPA-COGECA

Response to Veterinary medicines – list of essential substances for equine species

11 Feb 2025

Copa and Cogeca submit the following comments on the European Commissions draft Implementing Regulation regarding "Veterinary Medicines of Substances Essential for Horses and Other Equine Species (List)." This regulation establishes a list of substances deemed essential for the treatment of equine species or those offering added clinical benefits compared to other available treatment options. It also includes the provision that the withdrawal period for these substances in horses shall be six months, repealing the previous Commission Regulation (EC) No. 1950/2006. We recognize the importance of the list in ensuring proper care for horses and other equines. However, we believe it is necessary to extend this list to include additional drugs and active substances that are approved for use in horses, proven safe, and crucial for providing quality care in the fields of anesthesia, analgesia, and intensive care for horses and other equines destined for human consumption. The following substances should be considered for inclusion: acepromazine, atropine, bupivacaine, hyperbaric bupivacaine, buprenorphine, butorphanol, climazolam, desflurane, detomidine, dexamethasone, dexmedetomidine, diazepam, dobutamine, dopamine, esomeprazole, fentanyl, flumazenil, flunixin, gabapentin, halothane, hydromorphone, isoflurane, ketamine, ketoprofen, xylazine, levomethadone, lidocaine, lorazepam, medetomidine, meloxicam, meperidine, mepivacaine, methadone, midazolam, morphine, naloxone, naltrexone, omeprazole, pentazocine, pethidine, phenylbutazone, pregabalin, procaine, propofol, remifentanil, romifidine, ropivacaine, sevoflurane, s-ketamine, sulfentanil, thiopental, tiletamine, tramadol, transdermal fentanyl, zolazepam. We also note the proposed inclusion of substances like tetryzoline, synephrine, and polymyxin B. We support their inclusion on the list. However, methocarbamol, fusidic acid, and dexmedetomidine do not provide sufficient guarantees of non-toxicity, and we are opposed to their inclusion in their current form. Furthermore, we are strongly opposed to the removal of essential substances such as griseofulvin, sevoflurane, rifampicin, midazolam, Technetium (Tc99), buprenorphine, and ketoconazole from the current list. These substances are vital for the health and welfare of Equidae, while also ensuring public health and food safety. Their withdrawal would either permanently exclude many horses from slaughter or result in the lack of appropriate treatments. Finally, we strongly request that phenylbutazone be included in the list. Its clinical benefit in the treatment of pain in horses is universally recognized, and its safety in terms of food residues after a six-month withdrawal period has been scientifically demonstrated. Similarly, rifamycin and tenoic acid should be considered in the context of antimicrobial resistance and the One Health approach. Thank you very much for your consideration.
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Meeting with Mario Milouchev (Director Agriculture and Rural Development) and

11 Feb 2025 · Appointment of the new COPA-COGECA Secretary-General last September 2024; the new SC was interested to know the work of the Directorate D in DG AGRI

Meeting with Diego Canga Fano (Acting Deputy Director-General Agriculture and Rural Development) and European agri-cooperatives

11 Feb 2025 · Exchange of views on promotion policy, geographical indications, R&I and communication

Meeting with Irene Sacristan Sanchez (Head of Unit Health and Food Safety)

5 Feb 2025 · Exchange of views on the Commission proposal on plants obtained by certain new genomic techniques.

Meeting with Luis Carazo Jimenez (Head of Unit Agriculture and Rural Development) and European agri-cooperatives

4 Feb 2025 · Preparation of mission to Washington

European farmers oppose colour-coded hazard labels for pesticides

3 Feb 2025
Topic — This consultation seeks to update labelling requirements and improve risk communication for pesticides.
Message — The organization requests the removal of the proposed colour-coded hazard classification system. They believe professional users are already sufficiently trained to handle these products.12
Why — This would prevent retailers from excluding agricultural products based on hazard colour coding.34
Impact — End users lose the benefit of simplified visual warnings for potential health risks.5
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Meeting with Elisabetta Gualmini (Member of the European Parliament)

3 Feb 2025 · AGRI Committee

Response to Uniform format for national restoration plans

24 Jan 2025

Mapping: There should not be so many options when it comes to mapping; NUTS2 or NUTS3 should be enough; we should remove the 10x10km grids/1x1 grids/Free Polygons; as it will lead to a huge variability in the plans and how they will be presented; especially as they are not offered as additional on top of a common mapping system but only as optional. Typology of measures: Also regarding the document typology of measures, we are that this could be too restrictive as only measures within the HD system and many very strict measures were proposed. It should be stated that MS are not required to explicitly define their measures in the NRP according to this typology, and that this document is merely is for orientation purposes. Point 6.2.4.3: Habitat types where the current area is more than 2% smaller than the FRA are considered to be relevant for re-establishment measures according to this column. The question arises as to where this percentage comes from? (In our opinion this is very strict reporting method in the Habitats Directive, already 2% below the FRA is considered to be unfavourable. However, this should not automatically be taken into the draft format, especially if it is not explicitly addressed in the NRL). Socio-Economic Function of artificial barriers: where are socio-economic functions of artificial barriers for the connectivity of water (Art. 9) addressed? This must be considered according to Art. 9(1). Not all artificial barriers should automatically be considered as to be potentially removed. This is not addressed here or in Annex IV. Also, Point 9.2.4.1. should refer to Annex IV in the right column, not Annex III. Artificial Barriers: At what stage of the 2030 goal to 25,000km of free flowing rivers have we reached? Dam Removal Europe and other organisations and projects have been working on this issue; and with varying numbers of dams needing to be removed, and have already been removed; at what point are we to getting to the 25,000km goal and is there a guidance already being prepared to aid MS to decide on an action plan for removal of dam and other barriers to get to this goal in the next 5 years? Point 13.1.2.: many details of the description regarding planting 3 billion additional trees: this should be optional, as not mandated in Art. 15(3)(m), where only a description of the contribution to the commitment referred to in Article 13 shall be described in the NRP. Outside of the scope of the implementing act, but financing will be the main part to play in the implementation of this law, with supports, compensation, and incentives being necessary. As the NRPs will need to delineate these very clearly, it is extremely necessary for the European Commission and Member States to understand the need for a dedicated fund that cannot be challenged for restoration of nature. Likewise, it is clear that MS will need to do more accurate accounting of the estimates for restoring and maintaining those areas to be restored; plus those potential measures that are to be introduced to aim to reduce significant deterioration of habitats. At what stage can this be expected to be addressed? Rewetting: Member States shall, as appropriate, incentivize rewetting to make it an attractive option for farmers and private landowners and foster access to training and advice to farmers and other stakeholders on the benefits of rewetting peatland and on the options of subsequent land management and related opportunities. - There should be a box for describing how the MS is going to incentivize rewetting? Mapping: If the restoration measures on private land are based on voluntariness, it is not possible to map the private lands at the time the draft of the NRP is sent to the Commission. No private land can be on the map without agreement of the landowner. There is no description regarding the handling of ownership rights, rights of the land owners/land managers, and current land use.
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Meeting with Kerstin Rosenow (Head of Unit Agriculture and Rural Development)

21 Jan 2025 · Exchange of views on the opportunities for EU farmers provided by the EU Research and Innovation Framework Programs

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

14 Jan 2025 · Imports of nitrogen fertilisers from Russia

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

14 Jan 2025 · EU pork exports to China

Response to Derogations from import prohibitions - Calibrachoa and Petunia from Kenya

18 Dec 2024

Copa and Cogeca Contribution to the Consultation on Import Exemptions for Calibrachoa and Petunia Copa and Cogeca welcome the European Commission's initiative to propose import exemptions for Calibrachoa and Petunia from Kenya and Guatemala. These exemptions are of high economic importance to the European ornamental plant sector. Stable and high-quality supplies of cuttings from these third countries are essential for maintaining the competitiveness of European ornamental plant growers, including those in young plant production. However, we would like to highlight several concerns regarding the practical implementation of the proposed control mechanisms outlined in Article 3 of the Commissions draft. Post-import controls - Article 3(2) specifies that cuttings may only be supplied to officially registered nurseries, which are required to notify authorities of imports. - Article 3(3) requires that nurseries must be officially inspected at least once before further distribution. In cases of suspicion, tests for specific viruses must also be conducted. While these measures aim to ensure phytosanitary security, they impose a considerable organisational and logistical burden on nurseries and competent authorities. Regular inspections and associated documentation require significant resources, posing challenges to practical implementation. For example, weekly inspections over a period of up to 20 weeks are not feasible for nurseries and place excessive demands on authorities. Proposed Solution: enhanced controls in third countries We strongly advocate for an alternative approach to reduce the administrative and logistical challenges associated with post-import controls. Specifically, we propose that: - Comprehensive inspections be conducted at the propagation sites in third countries. - These pre-export inspections replace the need for frequent post-import checks at registered nurseries within the EU. This approach would significantly streamline the process, ensure the phytosanitary security of the Union, and alleviate the organisational and logistical burdens on nurseries and authorities. Copa and Cogeca call on the Commission to review the proposed control mechanisms and adopt a more pragmatic approach that balances phytosanitary security with the economic realities faced by nurseries and growers. We look forward to engaging further with the Commission to ensure that the proposed measures effectively support the European ornamental plant sector without creating unnecessary burdens.
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Response to Derogations from import prohibitions - Calibrachoa and Petunia from Guatemala

18 Dec 2024

Copa and Cogeca Contribution to the Consultation on Import Exemptions for Calibrachoa and Petunia Copa and Cogeca welcome the European Commission's initiative to propose import exemptions for Calibrachoa and Petunia from Kenya and Guatemala. These exemptions are of high economic importance to the European ornamental plant sector. Stable and high-quality supplies of cuttings from these third countries are essential for maintaining the competitiveness of European ornamental plant growers, including those in young plant production. However, we would like to highlight several concerns regarding the practical implementation of the proposed control mechanisms outlined in Article 3 of the Commissions draft. Post-import controls - Article 3(2) specifies that cuttings may only be supplied to officially registered nurseries, which are required to notify authorities of imports. - Article 3(3) requires that nurseries must be officially inspected at least once before further distribution. In cases of suspicion, tests for specific viruses must also be conducted. While these measures aim to ensure phytosanitary security, they impose a considerable organisational and logistical burden on nurseries and competent authorities. Regular inspections and associated documentation require significant resources, posing challenges to practical implementation. For example, weekly inspections over a period of up to 20 weeks are not feasible for nurseries and place excessive demands on authorities. Proposed Solution: enhanced controls in third countries We strongly advocate for an alternative approach to reduce the administrative and logistical challenges associated with post-import controls. Specifically, we propose that: - Comprehensive inspections be conducted at the propagation sites in third countries. - These pre-export inspections replace the need for frequent post-import checks at registered nurseries within the EU. This approach would significantly streamline the process, ensure the phytosanitary security of the Union, and alleviate the organisational and logistical burdens on nurseries and authorities. Copa and Cogeca call on the Commission to review the proposed control mechanisms and adopt a more pragmatic approach that balances phytosanitary security with the economic realities faced by nurseries and growers. We look forward to engaging further with the Commission to ensure that the proposed measures effectively support the European ornamental plant sector without creating unnecessary burdens.
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Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur) and European agri-cooperatives

4 Dec 2024 · Soil Monitoring Law

Meeting with Tomas Baert (Cabinet of President Ursula von der Leyen) and European agri-cooperatives and

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

Meeting with Karin Karlsbro (Member of the European Parliament) and European agri-cooperatives and Lantbrukarnas Riksförbund

19 Nov 2024 · Ukraine and agriculture

European farmers urge suspension of biofuels database expansion

7 Nov 2024
Topic — A proposal to extend fuel traceability to raw material collection points in agriculture.
Message — European farmers call on the Commission to suspend the draft regulation due to lack of workability. They recommend a pilot phase until 2026 to assess the technical IT systems. The proposal suggests prioritizing national databases to avoid duplicate reporting requirements.123
Why — This would limit bureaucracy and prevent farmers from having to fill in two separate databases.45
Impact — The Commission loses its immediate timeline for implementing comprehensive traceability across the supply chain.6
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Meeting with Arash Saeidi (Member of the European Parliament) and European agri-cooperatives

6 Nov 2024 · Echanges sur l'agriculture et la culture des céréales

Meeting with Tomas Baert (Cabinet of President Ursula von der Leyen) and European agri-cooperatives

23 Oct 2024 · China follow-up meeting

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur) and Policy Hub - Circularity for Apparel and Footwear

17 Oct 2024 · discussion on Green Claims Directive

Meeting with Maria Walsh (Member of the European Parliament)

15 Oct 2024 · Agriculture Policy

Meeting with Veronika Vrecionová (Member of the European Parliament, Committee chair) and European agri-cooperatives

2 Oct 2024 · Priorities of AGRI committee in the new mandate, priorities for next CAP planning period

European Farmers Urge Stricter Limits on Ukrainian Trade Liberalization

1 Oct 2024
Topic — Proposed acceleration of mutual customs duty elimination between the EU and Ukraine.
Message — The organization calls for the reintroduction of import quotas close to original 2016 levels for sensitive agricultural products. They demand that further market access be conditional on Ukraine implementing EU production, animal welfare, and labor standards.12
Why — These measures would protect EU farmers from price drops caused by cheaper imports.34
Impact — Ukrainian exporters and the national economy would face significant barriers to EU markets.56
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Meeting with Maria Walsh (Member of the European Parliament)

23 Sept 2024 · Agricultural Policy

Meeting with Elsi Katainen (Member of the European Parliament) and European agri-cooperatives

20 Sept 2024 · Current forest and bioeconomy issues

Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development) and European agri-cooperatives

19 Sept 2024 · exchange of views on the report produced by the Strategic Dialogue on the Future of EU Agriculture

Meeting with Janusz Wojciechowski (Commissioner) and

16 Sept 2024 · First meeting with new Secretary General. Topics: Food Chain, Deforestation Regulation, Strategic Dialogue.

Response to Measures related to specific plant pests - Xylella fastidiosa

29 Jul 2024

Copa and Cogeca propose a balanced approach regarding the revision of Regulation (EU) 2020/1201, which aims to control the spread of Xylella fastidiosa. Our position reflects the concerns and insights from agricultural stakeholders mainly located in Italy. However, the spread of Xylella fastidiosa is a great concern for growers of other Member States. The proposed regulation includes several positive adjustments based on the latest scientific knowledge and experiences gained in combating Xylella fastidiosa. For instance, the reduction of containment zones from 5 km to 2 km and the introduction of more advanced monitoring protocols are commendable steps that can enhance the effectiveness of disease control measures. Additionally, extending monitoring to new specified plant species and incorporating faster methodologies are forward-looking actions that should be supported. However, the implementation of these revisions poses significant challenges, particularly for small and micro businesses. The addition of species such as Lavandula (various types) and Salvia rosmarinus to the list of plants requiring stringent controls could lead to substantial economic and operational burdens. These species are extensively cultivated in specialized regions, and the immediate enforcement of the new regulations would disrupt the marketing and distribution processes, especially during peak seasons. This scenario is further complicated by the capacity constraints of public control and certification bodies, which may struggle to handle the increased workload within the proposed short timeframe. Moreover, scientific data from Puglia indicate that certain strains of Xylella fastidiosa, such as ST53, primarily affect olive trees. This highlights the need for a more nuanced regulatory approach that distinguishes between main host species and occasional hosts. Such differentiation would prevent unnecessary economic damage to agricultural sectors that are not affected by specific Xylella strains. In line with this, we encourage for Annex II to only list species sensitive to the Xylella strains present in each delimited area or to the Community strains of the subspecies in question. This targeted approach is supported by increased scientific evidence, which now allows for more precise identification and management of the bacterium. In summary, while the proposed regulation introduces necessary and scientifically sound measures to combat Xylella fastidiosa, it must also consider the economic and administrative impacts on affected agricultural businesses. Adequate timeframes for the implementation of these measures are crucial. We suggest a phased approach, starting with June 1, 2025, to ensure that both public authorities and agricultural enterprises can adjust effectively. Furthermore, support mechanisms should be put in place to mitigate the financial burden on growers and facilitate compliance with the new requirements.
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Meeting with Dubravka Šuica (Vice-President)

23 Jul 2024 · On the importance of strengthening EU agriculture & rural areas through optimising resources, supporting sustainable growth, addressing Demographic Changes and Increasing investment & innovation

Meeting with Miriam Garcia Ferrer (Cabinet of Executive Vice-President Valdis Dombrovskis), Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis)

11 Jul 2024 · recent CN investigations against EU industry

Meeting with Nicolas Schmit (Commissioner) and

10 Jul 2024 · Exchange on the COPA-COGECA EU election Manifesto “Repositioning Agriculture as a Strategic Asset for Europe”

Response to Update of State aid procedural rules, considering the EU’s international commitments, recent practice and case law

27 Jun 2024

Concerns regarding the development of the Aarhus Convention and EU state aid: Several of the recent findings put forward by the ACCC lack support in any primary source of law. The scope of the recent initiatives in this area clearly contains redefinitions and re-interpretations far beyond the original scope of the Convention. This also applies to the current initiative regarding EU state aid policy. With reference to the Aarhus convention, European farmers, and forest-owners have already experienced the development of a very extensive access to court proceedings for NGOs and members of the public to initiate legal processes in matters with negligible environmental impact such as ongoing and small-scale forestry and farming. These are matters that were never in the scope of the Convention. The development has resulted in an unbalanced implementation that leads to negative consequences for individuals, small enterprises, authorities and a sustainable development. Individuals and NGOs are becoming opponents by the broad use of access to court proceedings that hinder development in rural areas with limited possibilities of outcome for the local population. The question of EU state aid rules in relation to the Aarhus Convention, especially in connection with Article 9.3, has been the subject of several investigations across the EU. It has been used to limit the compensation that plays a major role in the protection of property rights, mainly by NGOs in connection with species protection where small-scale farmers and forest owners have had their property rights challenged and/or infringed. Rights that are free under national law, protected by the constitution and due to compensation when infringed. Until now, the efforts to challenge these rights to compensation, by the argumentation of EU environmental and State aid law, have not succeeded. This initiative opens for a challenging change in that aspect and may even be the main, but concealed, purpose. The right to compensation exists as part of the protection of property rights in national legal systems as well as in the ECHR and the EU Charter of fundamental rights. The negative effects of weakening the property rights of the European farmers and forest owners cannot be covered in this document but would be vast for both individuals as well as most aspects of society as a whole considering both food and energy security, economic, social as well as environmental aspects. It has been communicated by the Commission that status quo is not an option and therefore no impact assessments would be necessary. This is, in all regards, an unhelpful claim in matters of such profound importance for the citizens of the EU. This initiative is a result of a juridical argumentation for political purposes. The wording of the convention is clearly distorted and mixed up with political objectives regardless of the democratic systems set up as well as of consequences. We strongly request a political discussion as well as thorough analysis of the grounds of the proposed changes as well as the recent development of the implementation of the Convention.
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Meeting with Olivér Várhelyi (Commissioner) and

20 Jun 2024 · Agriculture in the context of EU enlargement

Meeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives

11 Jun 2024 · Informative Visit about the working methods of the European Commission and the Cabinet.

Meeting with Janusz Wojciechowski (Commissioner) and

11 Jun 2024 · To discuss the main elements of their Manifesto and some concrete ideas for actions for the future EU agricultural policy.

Response to Import of used cooking oils

28 May 2024

The imports of UCO and UCOME deprive the EU of more than 3 million tonnes of rapeseed meal. The Commission and the Member States must quickly stop fraudulent UCOME imports into the EU. Copa and Cogeca support the Commissions proposal regarding the requirements on imports of UCO for animal feedstuffs. However, this is only a partial solution regarding the use of UCO and UCOME in biofuel sector. Copa and Cogeca ask you to suspend double counting for waste vegetable oil eligible in Annex IX; ensure witness audits of the biofuel supply chain in general. Indonesia allows witness audits but not China, which exports to the EU; harmonise the definition of waste vegetable oil under Annex IX; ensure quality control on the standard EN 14214 for biodiesel imports.
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Response to Amendment of protective measures against pests of plants

28 May 2024

Please find attached the feedback from Copa and Cogeca, representing EU farmers and agri-cooperatives.
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European farmers call for faster adoption of RENURE rules

15 May 2024
Topic — Proposal to allow the use of nitrogen fertilisers recovered from processed livestock manure.
Message — Copa-Cogeca urges rapid adoption within six months and the removal of the 100 kg/ha application limit. They demand technology-neutral regulations focusing on fertiliser quality rather than specific processing techniques.123
Why — Producers would lower operational costs by substituting expensive synthetic imports with processed livestock manure.4
Impact — Environmental safeguards for sensitive sites could be weakened if specific protection requirements are removed.5
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Meeting with Janusz Wojciechowski (Commissioner) and

15 May 2024 · Meeting with various EU organisations (Copa-Cogeca) on deforestation

Meeting with Ursula von der Leyen (President) and European agri-cooperatives and Confederazione Generale dell'Agricoltura Italiana

26 Apr 2024 · Meeting with COPA President, Copa Vice-President COGECA President, Cogeca Vice-President, 1st Vice President Copa (Confagricoltura, Italy), Deputy Secretary General Copa-Cogeca

Meeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives

16 Apr 2024 · To exchange views on alternative proteins to animal-based foods which are often portrayed as more environmentally sustainable to EU animal production.

European farmers warn transport rules threaten food supply chains

11 Apr 2024
Topic — The EU is revising legislation on animal welfare standards during transport operations.
Message — Copa and Cogeca oppose the new journey time limits and temperature-based restrictions. They argue the proposal ignores practical experience and forces unfeasible structural changes.12
Why — Current rules avoid massive investment costs and significant logistics disruptions for farmers.34
Impact — Environmental objectives are undermined by a predicted increase in truck traffic and emissions.5
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Meeting with Janusz Wojciechowski (Commissioner) and European agri-cooperatives

22 Mar 2024 · To express to the Commission the growing concerns of EU farmers

Meeting with Maroš Šefčovič (Executive Vice-President) and European agri-cooperatives and

14 Mar 2024 · High level dialogue on forest-based bioeconomy

Meeting with Tiemo Wölken (Member of the European Parliament) and European agri-cooperatives

11 Mar 2024 · Green Claims Directive

Meeting with Olivér Várhelyi (Commissioner) and

7 Mar 2024 · Ukraine

Meeting with Lukas Visek (Cabinet of Vice-President Maroš Šefčovič) and European agri-cooperatives

20 Feb 2024 · Green Deal initiatives and agriculture

Meeting with Janusz Wojciechowski (Commissioner) and

14 Feb 2024 · ECR Spanish Delegation & Leaders of the Spanish Agri Association

Meeting with Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius) and European agri-cooperatives and

9 Feb 2024 · Deforestation issues

European farmers urge voluntary approach to forest monitoring

7 Feb 2024
Topic — The consultation establishes an EU-wide observation framework for monitoring forest conditions and management.
Message — The group rejects a binding regulation, preferring voluntary guidelines and coordination of national inventories. They oppose sharing detailed geolocated information to protect private property and business secrets. They argue that forestry management must remain a national competence for member states.123
Why — This would avoid significant administrative costs and prevent public access to sensitive business information.45
Impact — The public and environmental researchers would lose access to detailed, transparent forest data.6
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Response to Business in Europe: Framework for Income Taxation (BEFIT)

24 Jan 2024

Please find in attachment, Copa's reply to the BEFIT consultation.
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Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra) and European agri-cooperatives

22 Jan 2024 · Farming and climate action

Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra) and European agri-cooperatives

22 Jan 2024 · Agricultural Strategic Dialogue

Response to Revision of olive oil marketing standards

15 Jan 2024

Introduction The European Commission opened a feedback period (18 December 2023 15 January 2024) on draft delegated regulations on updating the marketing standards for Olive oil. We appreciate this opportunity and thank the Commission services for the possibility to give our feedback. The feedback concerns the new limit values for the characteristics of olive oil set out in Regulation (EU) 2022/2104, which are set in accordance with the IOC Trade Standard applying to olive oil and olive-pomace oil (IOC Trade Standard). The IOC Trade Standard changed with regard to one chemical parameter, Δ-7-stigmastenol, and Delegated Regulation (EU) 2022/2104 should be amended accordingly. Thus, the act amends Annex I of Delegated Regulation (EU) 2022/2104 with regard to the chemical parameter Δ-7-stigmastenol. Considering that a modification of the current legislative setting is open, we would like to consider suggestions further modifications that do not only relate to the Annex of the Delegated Regulation 2022/2104 and the issue of Δ-7-stigmastenol as it follows: 1. Article 3 Blends of olive oil with other vegetables - Delegated Regulation (UE) 2022/2104 Modify Art 3 of the Delegated regulation by extending national prohibition of such practices -the blends of olive oil with other vegetable oils- to the whole of the EU internal market. We consider that the modification of the regulations must contemplate the elimination of these mixtures throughout the European Union, as it is already the case in certain Member States. In this way, fraud will be easily avoided in such cases where the national market prohibits the actual process of blending on its territory, but not the sales of it. This practice violates the rationality of the correct functioning of the internal market within the Union. The justification is based on the effort made by companies and organizations in the sector to obtain a genuine and authentic product, differentiated by its quality, organoleptic characteristics and its health benefits, and from which other fat manufacturers try to take advantage. This practice may confuse consumers while putting at risk the image of the olive oil sector. insisting on the impossibility of detecting the percentage of the components of the mixture, and therefore, It is impossible to guarantee the consumer the veracity of the product they are purchasing, opening a wide window to fraud. 2. Article 4 Packaging Hermetic stop in Horeca - Delegated Regulation (UE) 2022/2104 Extend the obligation of paragraph 1 concerning the opening system that can no longer be sealed after the first time for packaging formats equal or exceeding five liters also to oils intended for consumption in restaurants, hospitals, canteens and other similar collective establishments. Maintaining the olive oil bottling requirement is essential in order not to jeopardize food safety and to fight against fraud and adulteration, as well as to create a level playing field on the market for EU producers.
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Meeting with Janusz Wojciechowski (Commissioner) and European agri-cooperatives and

10 Jan 2024 · Meeting with EU associations representing different sectors and actors presenting a proposal for a mechanism to protect sugar, cereals/oilseeds, poultry meat and eggs farmers/producers from severe market disturbance linked to imports from Ukraine.

Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development) and European agri-cooperatives

9 Jan 2024 · Exchange on current affairs, relating to the CAP, including the upcoming strategic dialogue

Meeting with Maroš Šefčovič (Executive Vice-President) and European Environmental Bureau and

9 Jan 2024 · Farm visit and roundtable with agri-food chain stakeholders

Meeting with Angelika Winzig (Member of the European Parliament, Shadow rapporteur) and European agri-cooperatives

8 Jan 2024 · Gigabit Infrastructure Act

Meeting with Andreas Schneider (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives

18 Dec 2023 · The upcoming preparation and decision on the renewal of the Autonomous Trade Measures with Ukraine.

Meeting with Miriam Garcia Ferrer (Cabinet of Executive Vice-President Valdis Dombrovskis) and European agri-cooperatives

18 Dec 2023 · agriculture; food industry

European farmers urge tougher rules against unfair trading practices

29 Nov 2023
Topic — The EU is evaluating rules protecting farmers from unfair practices in food supply chains.
Message — The group demands an expanded list of banned practices and the removal of size-based protection limits. They also want anonymous complaint systems to overcome the fear of retail retaliation.123
Why — Broader protections would help farmers recover billions lost to unfair commercial practices.4
Impact — Large retailers would lose the ability to unilaterally shift costs onto producers.5
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Meeting with Daniel Buda (Member of the European Parliament) and European agri-cooperatives

21 Nov 2023 · Agriculture

Meeting with Helena Braun (Cabinet of Vice-President Maroš Šefčovič), Lukas Visek (Cabinet of Vice-President Maroš Šefčovič) and European agri-cooperatives

13 Nov 2023 · The role of agriculture in the Green Deal

Meeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives

13 Nov 2023 · Future of livestock policies; animal welfare

Response to Cross-contamination levels and analytical methods for antimicrobials in feed

9 Nov 2023

Copa and Cogeca represent 22 million farmers and their family members as well as 22,000 cooperatives dedicated to providing safe, nutritious, high-quality, and affordable food. Feed is an essential component of it. We appreciate the opportunity to provide feedback to the public consultation on the draft delegated acts supplementing Regulation (EU) 2019/4 by establishing a harmonised level of cross-contamination of antimicrobial active substances in non-target feed, as well as methods of analysis of the antimicrobial active substances in the feed. Copa and Cogeca welcome the initiative on cross-contamination levels and analytical methods for antimicrobials in medicated feed. The proposed level of 1% carry-over is the most reasonable out of the options contemplated. However, we would like to underscore that meeting the target will be demanding and might lead operators to go out of business. Furthermore, Copa-Cogeca stresses that farmers need to be provided with information and certainty about the concentration of antimicrobial active substances in the feed they are using. More specifically, farmers should be informed of the restrictions on the use of feed to which a 1% cross-contamination applies (cannot be used during a certain production phase or period before slaughter during which it cannot be used). In the same vein, it is important to ensure compliance with the 1% threshold in the context of self-monitoring by downstream operators. Lastly, to facilitate the adaptation of operators to the new rules, it is necessary to provide for an adequate transition period.
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Meeting with Maroš Šefčovič (Executive Vice-President) and European agri-cooperatives

6 Nov 2023 · Transition towards sustainable food systems

European farmers urge major changes to proposed soil law

3 Nov 2023
Topic — The consultation addresses a proposed law to monitor, manage, and restore healthy soils across Europe.
Message — Copa-Cogeca calls for flexible management principles that avoid banning practices or removing land from production. They reject the one out, all out principle and demand removing soil health certificates.123
Why — Farmers avoid administrative costs and prevent their land value from decreasing due to public data.4
Impact — Environmental groups and regulators lose access to specific, non-anonymized data for monitoring soil degradation.5
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Response to Processed manure as component material in EU fertilising products

26 Oct 2023

Copa and Cogeca welcome the Commission draft Delegated regulation adding processed manure as a component material in the EU fertilising products regulation. This regulation would offer an opportunity to transport manure from surplus areas to deficit areas, after processing. It could offer alternative fertilising products to synthetic fertilisers on the market in deficit areas. But the question of using processed manure on farm in nitrate sensitive areas as a fertiliser replacement (Renure) of synthetic fertiliser is not resolved. The JRC report states that the current rules of the nitrate directive continue to apply, so it still remains animal manure. The processing of manure as a CMC 10 constitutive material of fertilising products will be mainly something for the larger manure processing installations and not something to be done on farm. The technical requirements before this manure could be used in the EU fertilising products seem approriate and reasonable to us. Copa and Cogeca would therefore like to repeat their position on Renure. The most advanced technology for nutrient recovery from livestock manure (RENURE - Nitrogen REcovered from maNURE) is not yet widely used due to the high costs associated with such processes as well as the transport and spreading of organic-based fertiliser on fields. Furthermore, the maximum level of nitrogen from livestock manure that can be applied under the Nitrates Directive also includes processed livestock manure. Therefore, the potential of organic fertilisers from livestock manure as a substitute for mineral fertilisers is considerably limited by the arbitrary definition of processed livestock manure in Article 2 of the Nitrates Directive 91/676/EEC. Therefore, Copa and Cogeca believe that the Commission should send a clear signal to farmers by making technical proposals for the safe use of RENURE materials above the threshold established for nitrate vulnerable zones by the Nitrates Directive (91/676/EEC). In this way, farmers would be able to strengthen the circular economy on their farms through innovative investments, reduce their dependence on fossil fuels and mineral fertilisers and lower their input costs.
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Meeting with Christophe Clergeau (Member of the European Parliament, Shadow rapporteur) and European agri-cooperatives and

26 Oct 2023 · Table ronde avec les représentants de l'industrie sur la proposition de règlement sur les nouveaux OGM

Response to Revision of the plant and forest reproductive material legislation

25 Oct 2023

The general objective of the Commissions proposal is to ensure, for all types of users, the availability of PRM of high quality and diversity of choice which is adapted to current and future projected climatic conditions. Furthermore, it aims to improve the single market on PRM and align the PRM legislation on the EGD objectives. Copa and Cogeca consider that the objective of increasing agricultural productivity has not changed. However, additional challenges have emerged, such as changes in climate and production. For this reason, the new legislative framework must make it possible to stimulate the development and make available on the European market varieties which are better adapted to these challenges. It also has to guarantee the production and availability in the EU of plant reproductive material (seeds, seedlings, bulbs, etc.) which is of a high market quality and phytosanitary quality. The aim of this proposal for regulation must also be to reduce costs. This aim is taken into account by allowing the Member States to cooperate within the same agro-climatic conditions. However, this aim has not been sufficiently taken into account. Copa and Cogeca are satisfied that the pillars of the current legislation, namely registration, certification, official controls and variety registers, have been maintained. A large number of details (definition of lot, rules for labelling, classification standards, etc.) must be fleshed out at a later date through secondary legislation, which gives room for flexibility. Copa and Cogeca request that all stakeholders be involved in the preparation of delegated acts. Copa and Cogeca support the Commissions proposals for a regulation on plant reproductive materials (PRM). The PRM and the NGT-plants legislation are closely interlinked. The proposed regulation on NGT plants alone is not sufficient to allow European farmers to have access to improved plant reproductive materials (PRM). PRM must be tested, certified and registered according to the PRM regulation to be placed on the EU market as plant varieties. The PRM is a very important piece of legislation as it will regulate the seed varieties placed on the market for the next 15 years. Copa and Cogeca advocate for amendments to the Commission proposals on PRM/FRM as follows: a) Update the list of species covered by the regulations b) Keep the categories of PRM and the possibility of grades c) Considering wine classification d) Additional checks on e-commerce e) Maintaining official controls under PRM/FRM, not in the horizontal legislation f) Limiting size of derogations g) Herbicides tolerant varieties/pest resistance/unfavourable agronomic effects: How to control implementation? h) Re-establishing seed statistics. Copa and Cogeca welcome the testing of sustainability, which is seen as a tool to satisfy the requirements of the sustainable food system. New varieties must offer additional benefits compared to existing varieties. Knowing that these varieties have been tested and evaluated according to established criteria is an extra guarantee for farmers. Yield is one of the basic properties included in the list of VSCU criteria, which is of the utmost importance for farmers, to give them the possibility of choosing the best agricultural and horticultural varieties. VSCU criteria must make it possible to meet ever higher quality, yield, nutritional and final processing demands and reduce the need for external inputs such as plant protection products and fertilisers. However, testing sustainability would generate costs that must be transferred from breeders to farmers and to the supply chain. The introduction of VSCU for fruit and vegetable species is a very important change. It would require specific infrastructure and procedures to be set up which differ from arable crop species that cost to the breeders and the Member States.The need for a longer transition period for implanting VSCU testing for fruit and vegetables must be recognized.
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Response to Legislation for plants produced by certain new genomic techniques

25 Oct 2023

Innovation in the plant breeding sector is among the levers that will enable European agriculture to successfully make the transition to a more resilient and sustainable form of farming. This legal proposal is, thus, key in contributing to the Farm to Fork and Biodiversity Strategy objectives such as improved pest-resilience, tolerance to climate change and environmental stress as well as enhanced nutrient and water-use efficiency and carbon sequestration. It should support European farmers across all sectors and regions in responsible production on a more sustainable basis while mitigating climate change and ensuring food affordability and security in the Union and beyond EU borders. Copa and Cogeca welcome the Commission's proposal for a regulation on new genomic techniques (NGT) and the proposals for a regulation on plant and forest reproductive material (PRM/FRM). These pieces of legislation are closely linked. The proposed regulation on NGT plants is sufficient in itself to give European farmers access to improved plant reproductive material. PRM and FRM must be tested, inspected, certified and registered before being placed on the EU market and sold to farmers, who may choose to grow them. The public and private sectors must support communication regarding consumers acceptance and confidence in new modern plant breeding techniques. Many countries around the world are already reviewing their regulations to give breeders access to these techniques by regulating and treating certain NBT plants and gene-edited products as conventional products. It is, therefore, essential to take into account scientific progress and to envisage the development of these plant varieties in the European Union without distorting competition with the rest of the world. In the near future, the EU will be importing products obtained from NBT plants, which is why an EU regulation on NBT products is highly needed and necessary. Copa and Cogeca advocate for amendments to the Commission proposal on NGT as follows: a) Category 1 NBT plants - The proposed criteria in annex I must be refined to take better account of the genetic specificities of each plant species and traits that are under the control of many genes. b) Labelling of category 1 NBT variety bags is not relevant for end consumers. Provisions relating to NGT cat 1 labels on seed bags must be removed. In addition, it creates extra costs that would be transferred to the supply chain and would unnecessarily increase the costs of PRM/FRM. As plants from category 1 cannot be distinguished from plants obtained through conventional breeding, category 1 NBGT plants must be regulated according to the rules of conventionally bred plants. c) The proposed sustainability criteria that incentivise category 2 NBT plants contradict the sustainability characteristics of the Value for Sustainable Cultivation and Use in PRM Regulation. The sustainability criteria set in Annex III must be harmonised between NGT and PRM regulations. d) The proposal falls short of the objective of full European harmonisation of the rules of coexistence. This approach would create considerable legal uncertainty and also contradict the basic idea of a European level playing field. e) The procedure for the testing of category 1 NBT currently falls under the GMO Directive. Taking this into account, derogation from GMO provisions on the testing of category 1 NBT plants in laboratory is necessary. This is in order to accelerate European farmers access to the use of better performing varieties. Copa and Cogeca call on co-legislators to come to a final agreement on these proposals before the election. Copa and Cogeca suggest using the terminology New Modern Breeding Techniques (NBTs) instead of New Genomic Techniques, which is more appropriate for a law that covers innovation in the plant breeding sector, which excludes transgenesis.
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Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and L'Oréal and Radisson Hotel Group

10 Oct 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Response to Certification for hops and hop products

27 Sept 2023

Copa and Cogeca would like to stress the following points of concern: 1. The certification authority designed by the Member State offices shall be allowed to officially certify hops qualities and to appoint third parties as certification centers. No other entity such as approved operators shall be given delegated powers to implement such an activity. We believe that only certification authorities or designated certification centers have the know-how and the administrative infrastructure already in place that will guarantee the high level of their services. Opening certification actives to actors rather than the certification centers risks putting in jeopardy the strong certification system that represents the building stone of the strong European hop production. Opening to the possibility of national level decisions would also risk fragmenting the quality certification of hops and it could lead to favor fraudulent practices. Overall, the certification system as it currently stands does not pose any administrative burden to producers and, on the opposite, assures them that the care and quality of their production will be strongly enforced and recognized. Despite the bulk of the costs must be bored by the hop growers and the processors, reputation, reliability, traceability, and credibility of their production depends on a strong certification system. 2. Any criteria (minimum requirements) regarding seed content shall be part of the certification. The current definition sets the threshold for identifying seedless hops when the seeds weight is lower than 2% of the whole weight of the hop. We do believe that this definition is appropriate, and it represents an indirect measure of quality. We welcome the provisions as set in the draft text. 3. Isomerized products shall be excluded from the certification. The difficulty in tracing the origin of hops once they had gone through isomerization as well as their processing method would prevent on-point and precise quality checks (in line with Art 1 (3), Reg 1850/2006). We argue this practice to be allowed but outside the scope of the certification standards. We welcome the provisions as set in the draft text. We propose the following changes to the text: Recital 3 Add A solid and certain certification system assures that the quality of European hops and hop products is respected and that European hop growers get recognition of their work, after the following phrase: Breweries pay great attention to the quality of the hops used in the brewing process because that ingredient has a big influence on the taste of the final product. Recital 6 Remove or by approved operators. Article 3 (m) Remove and approved operators. Article 3 (p) Remove the whole paragraph. Article 8 (1) Remove or by approved operators.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

26 Sept 2023

Reducing food waste is a global imperative and essential for securing a sustainable future. Its inclusion in the United Nations Sustainable Development Goals underscores the urgency of addressing it, with a view to ensuring responsible resource utilisation and mitigating climate change. Copa and Cogeca, representing 22 million farmers and their families and 22,000 agri-cooperatives, support the European Commissions ambition to deliver on UN SDG 12.3 of halving food waste at retail and consumption stages by 2030 and reduce food losses along the rest of the chain. They also reiterate the farmers and cooperatives commitment to preventing and reducing food losses and food waste. Copa and Cogeca welcome the Proposal for a Directive of the European Parliament and the Council amending Directive 2008/98/EC on waste presented on 5 July 2023 and laying down food waste reduction targets with a view to delivering on the UN SDG 12.3 and F2F Strategy commitments of halving food waste by 2030. They are pleased to note that, although ambitious, the proposal takes into consideration the specificities of the primary production (circumstances which are beyond the primary producers control that are both unforeseeable and unavoidable such as adverse weather conditions and last-minute changes or cancellations to orders from contractors) and stipulates no mandatory food waste reduction targets for it. This approach is both in line with UN SDG 12.3. and the ECs own impact assessment, while reflecting previous and ongoing efforts. Indeed, European farmers and their cooperatives are already making substantial strides in curbing food losses and waste by efficiently utilising natural resources and minimising food losses, while ensuring food security and strengthening the circular economy. Their commitment stems from a twofold conviction: a) nothing of value should be discarded without reason; b) food waste reduction is not only a social and environmental responsibility, but also an economic opportunity. In this spirit, agricultural products failing to meet EU legislation or market standards find alternative uses in accordance with the hierarchy established by the Directive EU 2018/851. Moreover, as agriculture, by its very nature, operates in a circular fashion, farmers and cooperatives are swiftly adapting to close the sustainability loop and firmly committed to promoting the model of the circular economy. Over the past decade, they have actively engaged in a multitude of projects, including the European ZeroW project, and programmes aimed at reducing food waste in the primary production and processing stages. More concretely, they have donated agricultural produce, worked on re-purposing unavoidable surplus produce that could not be donated (e.g. production of hand sanitizer with surplus wine or fertiliser with surplus fruits and vegetables), developed programmes focusing on finding new outlets for previously overlooked co-products, launched actions aimed at shortening the food chain by developing direct sales, collaborated with national authorities and academia to develop methods for food waste diagnosis, and participated in awareness campaigns to improve consumers understanding of the labelling. Copa and Cogeca also appreciate the stepwise approach, accompanied by annual monitoring, but regret the lack of a definition of food losses. To facilitate the implementation of the targets for the processing and the manufacturing stages, they call for guidelines, including definitions and delineations of food waste, byproducts, and animal byproducts used. Considering the challenges that remain on the representativeness of the year 2020 and the need for updated methodologies for quantifying food waste, Copa and Cogeca propose that the baseline year be set to 2022. Lastly, they underline that the pursuit of the food waste reduction objectives should not compromise the Unions food security or result in the replacement of domestic production with imports.
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Meeting with Isabel Carvalhais (Member of the European Parliament, Rapporteur)

20 Sept 2023 · Generational renewal in the EU farms of the future

Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur)

8 Sept 2023 · Carbon Farming

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Giorgos Rossides (Cabinet of Commissioner Stella Kyriakides), Ines Prainsack (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and European agri-cooperatives

28 Aug 2023 · Exchange with COPA-COGECA on the implementation of the Farm to Fork Strategy

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen) and European agri-cooperatives

28 Aug 2023 · on animal welfare

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and European agri-cooperatives

18 Jul 2023 · Trade impact of animal welfare legislation

Meeting with Ines Prainsack (Cabinet of Commissioner Stella Kyriakides), Karolina Herbout-Borczak (Cabinet of Commissioner Stella Kyriakides) and European agri-cooperatives

11 Jul 2023 · Meeting with COPA COGECA to discuss honey fraud and consumer information

Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and European agri-cooperatives

4 Jul 2023 · New Genomic Techniques (NGTs)

Meeting with Kurt Vandenberghe (Director-General Climate Action) and European agri-cooperatives and

27 Jun 2023 · Fit for 55

Meeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives

27 Jun 2023 · Animal welfare reform

Response to Revision of EU marketing standards for agricultural products

16 Jun 2023

Copa-Cogeca's observations are contained in the attached file.
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Meeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives

16 Jun 2023 · The European Commission's proposal on food waste

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European agri-cooperatives and

15 Jun 2023 · EU forest related policies, including the upcoming forest monitoring proposal

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and European agri-cooperatives and

15 Jun 2023 · EU forest related policies, including the upcoming forest monitoring proposal

Meeting with Ralf Kuhne (Cabinet of Commissioner Stella Kyriakides) and European agri-cooperatives

7 Jun 2023 · food waste

Response to Updating the legislation related to the hygiene rules for products of animal origin

25 May 2023

Copa and Cogeca represent 22 million farmers and their family members as well as 22,000 cooperatives dedicated to providing safe, nutritious, high-quality, and affordable food. We welcome the opportunity to provide feedback to the proposed draft Delegated Regulation updating food hygiene rules for products of animal origin (Annexes II and III to Regulation (EC) No 853/2004) with a view to reflecting the experience gained in the practical application of the rules and new scientific advice. Regulation (EC) 853/2004 currently limits the possibility for stunning and bleeding on the farm to extensively reared animals, thereby excluding most animals regularly handled by farmers and easily transported without risk. This is notwithstanding experience gained by farmers and competent authorities, as well as the increasing need to prevent any animal welfare issue during transport. In light of this, Copa-Cogeca support the possibility to slaughter and bleed ungulates, regularly handled by farmers, at the holding, provided that all the measures necessary to ensure hygiene and traceability are in place. This would be the case for animals that could be easily transported to the slaughterhouse without risk but are unfit for transport due to animal welfare issues. Extending this possibility to ovine and caprine animals and other ungulates reared under any condition of housing would significantly contribute to minimising food waste and improving animal welfare for vulnerable animals not fit for transport.
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Meeting with Janusz Wojciechowski (Commissioner) and

23 May 2023 · Meeting with the farmers from 5 frontline Member States (Bulgaria, Hungary, Poland, Romania, Slovakia) about the impact of imports of Ukrainian agricultural products

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and European agri-cooperatives

23 May 2023 · New genomic techniques and revision of legislation on seeds

Response to Revised marketing standards for fresh fruit and vegetables, bananas, nuts, dried fruit and pulses

17 May 2023

Copa Cogeca are in favour of maintaining an European regulation of fruit and vegetable marketing standards, with as many specific standards as possible, in favour of transparency and proper functioning of the EU single market and of value supply chain balance. Copa and Cogeca support the new provision in article 5.b regarding the mandatory indication of the country of origin. Copa and Cogeca understand the importance of origin labelling and the idea behind improving it by using larger and more visible characters to indicate the country (article 7 paragraph 1). However, this requirement would seem like regulatory overreach which interferes with the practical implementation of the marketing standards and should be avoided. We propose that when the country of origin is a Member State of the EU, the term "European Union" or the EU logo (in black and white) should appear next to the mention of the country, in order to highlight the fact that the produce is European. A transitional period should be introduced to allow operators to use up the stock of packaging materials and labels in compliance with the previous standards. Regarding the information particulars required by this regulation on marketing standards, Copa and Cogeca underline that the use of invoices for traceability checks is less effective than in the past. It has been replaced by much more performant particular digital traceability tools. Furthermore, invoices might continue to circulate among business operators after the consumption of the concerned produce, especially in the fresh produce market. Therefore, Copa and Cogeca request to replace the part of the sentence invoice and by Invoices or in article 6 paragraph 4. Regarding derogations for non-compliance with the marketing standards for fruit and vegetables, - an exception can apply within a given production area including transnational area as defined by the Member States concerned. If one of these concerned Member State has a different view, the provision remains not implementable. Therefore, Copa and Cogeca ask to delete the last part of the sentence 'as defined by the Member State(s) concerned' in article 5 paragraph 2; - a new exception is considered in situations of force majeure, it should only apply for fruit and vegetables produced in the EU Member States. Copa and Cogeca request that the requirement to mark preserving agent or other chemical substances used at post-harvest stage be eliminated from the citrus marketing standard, to ensure equal treatment for citrus and other types of fruit, which are actually using the same products but do not have to mark it. In the case of labelling clementine, the marketing standard indicates that the word clementine must be indicated on the label. It happens that some customers from certain countries, such as Poland or the Netherlands where the word clementine does not exist are demanding the suppliers not to use the term clementine when labelling despite the standard. Therefore, we ask to consider that the term clementine may be replaced by mandarine when the country use only the term mandarine. In the case of labelling pepper, Copa and Cogeca request that where it is specified that the packaging must include the indication: "Sweet peppers" if the content is not visible from the outside, the indication "Sweet Peppers" can be replaced by Peppers, which better adapts to consumer.
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Response to Review of poultry marketing standards

17 May 2023

Foie gras: We believe that citizens should be free to choose the food they wish to consume. To this end, each consumer should be able to make informed choices and protected from fraudulent practices. This is why Copa Cogeca together with the foie gras sector welcomes the draft delegated act on poultry meat, in particular, the definition of raw foie gras. Article 10: Copa and Cogeca support the proposed Delegated Regulation and particularly the protection conferred to free-range farming by imposing the exclusive use of the 3 terms referring to free-range, namely "free-range", "traditional free-range", "free-range total freedom". This way, labels referring to free-range farming will also be protected. We welcome as well the obligation for products other than those included in Article 2 of the proposed Delegated Regulation to use names which do not mislead the consumer by allowing confusion with those referred to in the Article or with indications provided for in Article 10. We understand that this extended labelling scope will have to be submitted by Member States to the Commission for validation (point 6. Art.10). We point out that flexibility is welcome as long as it is extensively documented. This proposal leaves the operator to write whatever they want on their labels, as long as it is not misleading the consumer. Prior authorisation by public authorities or controls is of utmost importance to avoid greenwashing, unfair competition among operators or a higher risk of misleading consumers.
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Response to Marking of eggs on farm as general rule

17 May 2023

Copa Cogeca is satisfied with the proposed rules on the marking on eggs on farm, as it generally reinforces the traceability and transparency of the sector. However, we would like to point out that reasons for preference of marking eggs at the first packing station include that the cost involved can be quite onerous for farmers to purchase the necessary equipment to mark eggs on farm. It also involves more bureaucracy for certain farmers, depending on the Member states. It is important to improve the traceability of eggs, but without funding this would be difficult for farmers to do. For this reason, we are in support of maintaining the possibility of derogations whereby the eggs produced on farm are marked at the packing centres. In addition, we encourage the Commission to find a solution so that eggs coming from third countries are properly marked and clearly indicates the origin.
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Response to Review of egg marketing standards

17 May 2023

Solar panels: Copa and Cogeca welcome the Commissions proposal to amend the marketing standard, so solar panels are authorised in free-range areas. This should not only be possible for laying hens but for all poultry, for example fattening turkeys. Inconsistency between egg standards and organic rules: Copa and Cogeca commend DG AGRI work in taking into account the evolution of avian influenza as a risk factor for producers of free-range eggs in the marketing standards. The rapid development and spread of HPAI has adversely affected the poultry farming sector, with some 50 million birds from affected farms in Europe culled last season. As the significant economic losses for farmers will have social repercussions in the long run, we welcome the Commissions proposal to align derogations between free-range an organic, by enabling consumers to buy free-range eggs from hens that have no outdoor access during veterinary restriction, even if it lasts longer than 16 weeks.
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Response to Review of egg marketing standards

17 May 2023

Definition of Eggs: Eggs and eggs containing products must be clearly defined so it is not confused with alternative plant based ingredients. As protected in the Commission Regulation (EU) 589/2008 eggs means eggs in shell other than broken, incubated or cooked eggs that are produced by hens of the species Gallus gallus and are fit for direct human consumption or for the preparation of egg products. Marketing standards should distinguish eggs as stated in the above definition from plant based alternatives.
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Response to Amendment of public health import conditions

15 May 2023

Copa and Cogeca represent 22 million farmers and their family members as well as 22,000 cooperatives dedicated to providing safe, nutritious, high-quality, and affordable food. Copa and Cogeca welcome the opportunity to provide feedback to the proposed Delegated Regulation (EU) 2022/2292 which lays down conditions for importing certain food from non-EU countries. The recently published DG SANTE/JRC/OLAF joint investigation confirmed what EU beekeepers have been suspecting for years, namely that nearly half (46%) of the imported honey consignments are suspicious of being adulterated with extraneous sugars. Furthermore, they showed that 57% of exporters in third countries that were controlled were flagged as having exported honey consignments suspected of being adulterated with extraneous sugars, whereas 2/3 of the implicated importers had imported at least one suspicious consignment. The above figures underline, inter alia, the necessity to organise reinforced checks on consignments of honey and apiculture products at Union border control posts for their import into the Union. Copa and Cogeca welcome the draft Delegated Regulation at hand which lays down measures (drawing up and keeping up to date list of third country establishments exporting honey to the Union) to address the issue. Copa and Cogeca believe that they will contribute to better addressing the issue of fraudulent imports of honey and other apiculture products intended for human consumption to the EU. Additionally, they will improve market transparency.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European agri-cooperatives

4 May 2023 · EU policies concerning forests, including nature restoration law

European farmers demand realistic green investment criteria for agriculture

3 May 2023
Topic — The EU is defining sustainable investment standards for water, circularity, pollution, and biodiversity.
Message — The group requests a rapid update of investment rules to better reflect agricultural realities. They emphasize that rules must align with existing farming policies to ensure competitiveness.12
Why — This would allow farmers to secure funding for traditional methods without facing unrealistic requirements.3
Impact — Nature restoration efforts may suffer if investment standards are weakened to protect conventional farming.4
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Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur) and European agri-cooperatives

25 Apr 2023 · Pesticide reduction, SUR, agricultural policy

Meeting with Frans Timmermans (Executive Vice-President) and European agri-cooperatives and

29 Mar 2023 · Forest owners’ perspectives regarding the state of forests in the EU and discussion about EU policies impacting forest-based bioeconomy activities

European farmers urge flexible targets for food and wine packaging

23 Mar 2023
Topic — The European Commission is revising rules to reduce packaging and improve recycling.
Message — The group calls for a revision of bans on single-use packaging for fresh produce. They also request excluding the wine sector from mandatory reuse and refill targets. Finally, they advocate for longer transition periods to ensure economic feasibility.123
Why — This would prevent increased production costs and protect the viability of agricultural cooperatives.45
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

17 Mar 2023 · Green Claims initiative

Meeting with Stella Kyriakides (Commissioner) and

6 Mar 2023 · EU animal welfare

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and European agri-cooperatives

27 Feb 2023 · New genomic techniques

Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and European agri-cooperatives

27 Feb 2023 · New Genomic Techniques

Response to Indication of wine ingredients and adaptation of the rules for geographical indications in the wine sector

22 Feb 2023

According to Regulation 2021/2117, from December 8th, 2023, all wines must be labelled with the appropriate energy, ingredients and nutrition values information . Copa and Cogeca (European farmers and agri-cooperatives) welcome the provisions adopted by the Commission in its Draft Delegated Regulation on the list of ingredients. However, we would like to reiterate and reaffirm our position on few points that do not seem to be guaranteed by the current wording. Notably: - the term 'sucrose' shall be indicated when sucrose is added in the production of wine as ingredient, in the areas where such practice is allowed; - Expanding the list of components of 'tirage liqueur' and 'expedition liqueur'; - Specify indications on the language to use for the labelling information; - wines that have already been produced before 08/1/2023 shall be allowed to be sold and circulate in the market until stocks are exhausted. hose wines (produced earlier than 08/12/2023, the ones that require longer processing periods i.e., barriques) shall be granted exemption from the labelling rules introduced by regulation 2021/2117.
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Meeting with Janusz Wojciechowski (Commissioner) and

17 Feb 2023 · Commissioner will intervene at the Copa and Cogeca joint Praesidia on the future CAP

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis), Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis) and European agri-cooperatives

13 Feb 2023 · The impact of Animal Welfare in the negotiation of trade

Meeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives

9 Feb 2023 · The issues related to animal welfare legislation reform: consultations, impact assessment, trade perspective.

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides) and European agri-cooperatives

8 Feb 2023 · Framework on Sustainable Food Systems (FSFS)

Meeting with Mairead McGuinness (Commissioner) and

17 Jan 2023 · Sustainable Finance

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

9 Jan 2023 · To exchange on the work of the Commission on the initiative on substantiating green claims

EU farmers urge faster ban on imported growth-promoting antibiotics

3 Jan 2023
Topic — This consultation addresses banning certain antimicrobial substances in animals imported into the Union.
Message — Copa and Cogeca want imports to follow EU antimicrobial bans. They claim the timeline is too long and demand concrete enforcement tools.123
Why — Ensuring reciprocity would protect EU producers from competition by lower-standard imports.4
Impact — Third-country producers lose market access unless they adopt expensive EU-style production standards.5
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Response to Amendments to some technical rules of management of tariff quotas

21 Dec 2022

Considering certain technical amendments to Regulation (EU) 2020/761 regarding the modification of the allocation of import quotas for processed mushroom imports from China, we would like to present the situation of the EU mushroom market in a broader context. The market of processed mushrooms in Europe is not showing an upward trend, on the contrary. For years, there has been a slight decrease in demand. In recent years, before the crisis caused by the Covid epidemic, there was also a relative decrease in prices and profitability of production caused by a high level of competition among European producers. The increase in production costs in the last years has led to an increase in market prices in Europe, which have not fully translated into an increase in the profitability of processed mushroom production. In recent years, imports of Chinese processed mushrooms into the European market have not been high, they have fluctuated within 2,000 T DMW per year. This level of imports did not disturb the market balance achieved by European producers and did not give cause for concern. The proposed deletion of the reference quantity mechanism of 15% of the total quota volume per importer risks larger quantities of processed mushrooms from China coming into the European market. Chinese producers will be more profitable than before due to the weakening of the competitiveness of European producers due to a significant increase in costs. There is a risk of Chinese imports displacing the high-quality processed mushrooms from the EU. Moreover, the U.S. Department of Commerce launched in April 2021 a procedure to determine whether processed mushrooms in packages up to 340 g from France, the Netherlands, Poland and Spain should be subject to additional anti-dumping duties. The procedure was concluded in November 2022 with a preliminary ruling imposing additional duties on exporters and importers in the abovementioned countries in the following amounts; *France 224.88% to 360.88% *Netherlands from 0 to 146.59% *Poland from 23.43 to 30.01% *Spain 10.28% to 40.7% Therefore, there is a very high probability of European exports to the United States being limited. Against this background, we are concerned about the recently initiated discussion in the European Commission about the possibility of changing the mechanisms granting European importers tariff quotas for the import of processed mushrooms from China into Europe. We therefore call on you to suspend the procedure to implement any change to the mechanisms regulating import quotas which might result in more processed mushroom imports from China coming into the European market in the short term. We consider that the timescale of the revision of the TRQ management for processed mushroom imports from China is not appropriate in the context of greater uncertainties.
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Meeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski), Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski) and

14 Dec 2022 · GMOs and NGTs

European Farmers Seek Clarity on Vessel Inspections

5 Dec 2022
Topic — The consultation establishes requirements for official controls to verify animal welfare on vessels.
Message — They ask if inspections apply when animals stay on vehicles during ferry transport. They also call for secure storage of trip recordings to prevent activist misuse.12
Why — This would avoid redundant checks and protect farmers from targeted animal rights activism.3
Impact — Animal rights groups may lose access to footage documenting welfare conditions during transport.4
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and European agri-cooperatives

4 Oct 2022 · EU Promotion Policy for agricultural goods

Response to Clarification of certain conditions applying to sectoral interventions under Common Agricultural Policy Strategic Plans

30 Sept 2022

You may find attached the contribution of Copa and Cogeca to this public consultation.
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Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Karolina Herbout-Borczak (Cabinet of Commissioner Stella Kyriakides) and European agri-cooperatives

27 Sept 2022 · VTC meeting: Revision of food labelling rules

European Farmers Warn Pesticide Limits Risk Global Food Shortages

16 Sept 2022
Topic — Consultation on updating EU regulations for the sustainable use of pesticides.
Message — They demand no chemical bans without feasible alternatives like bio-controls. The group rejects binding targets and blanket restrictions in sensitive areas.123
Why — This would protect agricultural yields and maintain the competitiveness of farmers.45
Impact — Environmental groups lose guaranteed reductions in chemical use and biodiversity protections.67
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Response to Changes to the vine planting authorisation scheme

7 Sept 2022

Copa-Cogeca welcomes the possibility to provide feedback on the draft Implementing Regulation amending Implementing Regulation (EU) 2018/274 and the draft Delegated Regulation amending and correcting Delegated Regulation (EU) 2018/273 with a view to reflecting the changes to the vine planting authorisation scheme decided in the latest CAP reform. We welcome the extension of the vine planting authorisation system until 2045 and the priority criteria Member States may apply at national or regional level for granting vine planting authorisations. The system of planting authorisations has proven its effectiveness and the extension will guarantee stability in plantings in the coming years. It is opportune to highlight a few elements contained in the draft Delegated Regulation that have generated concern among winegrowers and vine nurseries alike. More specifically, we welcome the introduction of a definition on “collection of vine varieties” in the draft Delegated Regulation, for they are critical for the preservation of genetic resources and consequently of biodiversity. However, collections should not only be places for the conservation of biodiversity but should also be functional for the sector and allow in-depth study, comparison, and varietal evaluation. The ceiling of 50 plants is too low and must therefore be increased to 100, as depending on the breeding system and the use of collection, 50 plants may be many or very few. Moreover, the variety collection should not only concern one wine-growing region. In addition to conservation and for the purposes of study, comparison and evaluation of varieties, the collection should also cover local varieties (cultivated, non-cultivated), comparison varieties (national or international), as well as new varieties obtained by various means (crossbreeding, from seed etc). On Art. 3, the two-hectare area covered by each collection limit is too restrictive and would result in many of the current collections being excluded. Considering that the maintenance of a collection is a costly endeavour, it is worthwhile providing for an appropriate size. Furthermore, for that reason one must consider that usually few collections are maintained in one country and there the varieties of various wine-producing regions are preserved. In the same article, it is appropriate to factor in the evolution that has been taking place in recent years with varieties from other countries being continuously introduced into cultivation. That said, it is important that the term ‘typical’ in “vine varieties which are typical of a certain wine-producing region” be defined. For clarity, the parameters for designating an area as “wine-producing region” need to be explicitly mentioned. Another change is the elimination of the requirement to demonstrate that the risk of devaluation in a specific PDO/PGI is "significant" in order to justify a limitation at the time of the annual granting of new plantings. In practice, it appears that the requirement remains the same, as the difference between demonstrating a devaluation or a significant devaluation is a subjective matter and a hard to make in any case. Regarding the changes to criterion referred to in Article 64(2)(h) of Regulation (EU) No 1308/2013, we would like to underline that the wine-growing holding should take into account the area planted with vines, grubbing-up decisions pending conversion into authorisations, unexpired replanting rights as well as the planting authorisations granted. In fine, we believe that the aforementioned suggestions can contribute to improving the draft Delegated Regulation and reflecting the needs and evolution as far as the collection of vine varieties and the criteria are concerned.
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Response to Fruit & vegetables EU financial assistance to producer organisations implementing market withdrawals

2 Sept 2022

Proposed amendments to article 17 of the Implementing Regulation (EU) n. 892/2017 - The amendment aims to transform the amounts for sorting and packaging costs for products withdrawn from the market for free distribution set out in Annex V from flat rates to maximum values. Copa and Cogeca are not in favour to this change which would represent an unnecessary burden for the POs / AOPs but also for the control activities, especially since the costs in question are generally small and the difference between the two calculation systems would not be substantial and however it would not be such as to justify these increased administrative burdens. Transforming these lump sums into maximum values would mean that for each product withdrawal the POs / AOPs should analytically document all the cost components incurred for the sorting and packaging of the product, which is extremely difficult because it would be necessary to quantify not only the cost of materials of packaging but also all the ancillary costs for sorting ranging from the use of personnel, use of energy, depreciation of plants, etc… These are low costs, difficult to document analytically and also difficult to verify during the control phase. The risk is that to avoid such an aggravation the POs choose not to resort to free distribution in favor of the poor people for the management of surpluses, which should instead be encouraged all the more at a time like the current one in which the economic crisis, increasingly widespread, is causing an increase throughout Europe of the population at risk of poverty to increase. Copa and Cogeca consider that it is not possible to approve now a regulation that has to be applied from April 1, 2022. The new conditions should apply from 2023 or at the earliest from the publication of the new regulation.
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Response to Fruit & vegetables EU financial assistance to producer organisations implementing market withdrawals (free distribution)

2 Sept 2022

Proposed amendments to art. 45 par. 1 of the Delegated Reg (EU) n.891/2017 The amendment provides that the withdrawal allowance for fruit and vegetables withdrawn from the market, added to the sorting and packaging costs, cannot exceed 80% of the average price of the fresh product determined in the "OP exit" phase in the previous three years. So far, this percentage limit (80%) is not provided and Article 45 par. 1 of Delegated Regulation 891/2017 which we propose to amend only establishes that the sum of indemnity, sorting, packaging and transport costs must not exceed the average price in the "OP exit" phase calculated in the previous three years. Copa and Cogeca are not in favour to the introduction of this limit which penalizes POs excessively as the current production costs of fruit and vegetables, and especially those of sorting and packaging (due to the increase in market disturbances in recent months) are much higher than the average prices of the last three years. In this way, an additional ceiling (80%) is introduced for the compensation of the product withdrawn from the market for free distribution while it would even be appropriate to remove the current ceiling (average price of the last three years) which, as mentioned, is no longer in line with reality. The risk is to make free distribution uneconomic and to force POs to no longer use this tool for the management of surpluses which, on the contrary, should be encouraged especially at a time like the current one in which the economic crisis, increasingly widespread, is causing an increase throughout Europe of the population at risk of poverty to increase. Copa and Cogeca consider that it is not possible to approve now a regulation that has to be applied from April 1, 2022. The new conditions should apply from 2023 or at the earliest from the publication of the new regulation.
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European farmers demand food security over unrealistic restoration targets

22 Aug 2022
Topic — This consultation proposes legally binding targets to restore Europe's degraded ecosystems by 2050.
Message — The organization calls for realistic targets and a dedicated financial mechanism for restoration. They demand measures remain voluntary to respect property rights and prioritize food security.123
Why — Maintaining active production protects agricultural revenues and prevents rising land prices.45
Impact — Environmental groups lose the swift, mandatory ecological recovery promised by the original regulation.6
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Response to Sustainable fishing in the EU: state of play and orientations for 2023

19 Aug 2022

Copa and Cogeca support the work done in the MEDAC. Please see attachment.
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European farmers demand import standards mirror EU production rules

28 Jul 2022
Topic — The consultation addresses import rules for pesticide residues and veterinary medicines from third countries.
Message — They argue that imports must mirror the high production standards required of EU farmers. They request identical process controls and more rigorous on-site inspections in third countries.12
Why — This would prevent EU farmers from being undercut by cheaper imports with lower standards.3
Impact — Third-country exporters would face significant new restrictions on their production methods and chemicals.4
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Response to European common agricultural policy network, governance

19 Jul 2022

The preliminary contribution of Copa-Cogeca on the Implementing decision regarding the governance of the European CAP Network is attached
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Copa-Cogeca warns against mandatory sustainability data for farmers

18 Jul 2022
Topic — Proposal to expand the Farm Accountancy Data Network to include sustainability and social metrics.
Message — The organization insists data provision should remain voluntary rather than mandatory to avoid excessive burdens. They argue the network must maintain a central focus on the economic situation of farms.12
Why — A voluntary system reduces compliance costs and prevents potential penalties for European farmers.3
Impact — EU regulators lose access to the comprehensive data required to monitor environmental targets.4
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Response to Evaluation of the rates and structures of excise duty on alcohol and alcoholic beverages

1 Jul 2022

We welcome the possibility to contribute to the ongoing evaluation and would hereby like to offer some context on the links between health, taxation and outcomes. First and foremost, it is critical to distinguish between use and abuse and recognise that harmful alcohol consumption has been steadily declining in the EU in the past decade. Tax and price increases are poorly suited to targeting the harmful use of alcohol and often achieve the opposite result. Increasing taxes would run counter to the current efforts of national authorities to curb fraud and counterfeiting. It would also nurture illicit markets and give rise to the consumption of unrecorded alcohol (cheaper but of lower quality) and, in turn, tax revenue losses. Such practices imply the use of illicit sales channels and consumers turning towards cheaper, low-quality products, thus translating into a reduced need for workers and a lower associated revenue. Efforts to reduce alcohol affordability would only penalise moderate consumers (vast majority) without addressing excessive drinking which is associated with burden of disease. Harmonisation objectives (reducing the tax differential between different types of products) fail to consider purchasing power in the different countries, their consumption patterns and cultural underpinnings, as well as the low substitutability of alcoholic beverages. Context and culture are paramount to shaping drinking patterns and preferences. Mediterranean countries, for instance, have the lowest prevalence of heavy episodic drinking and/or abuse despite applying zero or low excise duties on wine. Any increase in excise duty rates would result in the tax being passed on through lower prices paid for raw materials to farmers who receive a lower remuneration for their products. For agricultural producers whose business margins are tight due to strong competition, lower prices would directly affect their profitability, put at risk the sustainability of farms and discourage business activity. Wine taxation should be calculated based on volume and not on %vol to avoid distorting competition in the two categories and discriminating against areas of production (the final alcohol content in wine is contingent on climate conditions and grape varieties). Continuing to apply a zero-excise duty rate for wines makes sense for the following reasons: 1) wine production is a very demanding agricultural activity; 2) production costs far exceed those for other alcoholic beverages; 3) with almost 70% of EU wines being produced under a GI scheme, the costs of compliance with production specifications render winemaking highly costly. Lastly, viticulture plays a key role in the economic, social and environmental sustainability of rural areas as it creates jobs in places with otherwise limited local employment opportunities and prevents a rural exodus. Spirit drinks taxation is already high and should not be further increased. Doing so would discriminate against spirits which are the most highly taxed beverage category. It is misleading to assume that the consumption of spirits and liqueurs is more associated with a harmful use of alcohol compared to other alcohol beverages as there is no scientific evidence showing a correlation between alcohol strength and health. Harmful use of alcohol occurs in any category of alcoholic beverage regardless of its alcoholic strength. Small farm distilleries play a vital role in the socio-economic sustainability of the regions where they are produced. To conclude, we support the maintenance of the existing excise duty rules. The current framework has proven to be delivering on the objectives. Thanks to the flexibility they provide to Member States, they have succeeded in bridging the gaps between the different categories and the different national fiscal policies. Lastly, the right approach to tackling harmful consumption is through education and awareness.
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Response to Revision of the EU geographical indications(GI) systems in agricultural products and foodstuffs, wines and spirit drinks

28 Jun 2022

1. Delegation of power to EUIPO Copa and Cogeca believe that shifting competencies away from DG AGRI and towards an agency specialised in intellectual property rights and without the necessary knowledge of the specificities of the agricultural sector and the nature of GIs puts at risk this successful policy. Before involving EUIPO in GI management, the added value of such an involvement should be demonstrated, as well as the agency’s ability and expertise when it comes to conducting such work. The recent introduction of national level processing for certain amendments to GI specifications should simplify management of GIs. This simplification should mean there is no need to involve another agency. 2. Powers and functioning of producer groups Copa and Cogeca believe that the division into “producer groups” and “recognised producer groups”, with the latter being endowed with some additional rights, is worth considering as it could contribute to empowering producer groups. However, we believe that in order to work efficiently this structure should be clarified and more subsidiarity regarding their recognition and functionement should be given to Member States and producer groups themselves. Furthermore, we believe that no actor other than producers should be involved in the internal functioning of "producer groups" and "recognised producer groups", unless these groups decide otherwise. 3. Simplification and streamlining of procedures Regarding wine GIs, Copa and Cogeca believe that registration, amendments, cancellation, and protection provisions can be harmonised with those for agricultural products and spirit drinks, but the texts cannot be merged. It should remain in the CMO Regulation to ensure all provisions related to wine management remain in the same text to ensure coherence. 4. Sustainability Copa and Cogeca believe that the introduction of specific sustainability criteria for GIs should remain strictly voluntary. GIs are a scheme designed to guarantee the authenticity and the quality linked to a specific region and its savoir faire, there are other specific schemes for sustainability. Moreover, sustainability schemes are also used by producers of the same GI to differentiate their products on the market. Consequently, producer groups must have the possibility to adopt ad-hoc sustainability undertakings not directly included in the GI general specifications. If criteria for the recognition of sustainability standards for GIs are to be established, they should be directly included the in the Regulation. The EC should not be granted powers to adopt delegated acts based on an ex-post definition of sustainability which would apply retroactively to producers. This could create legal uncertainty for producer groups which already intend to establish sustainability undertakings. 5. Protection and controls Definition of evocation: Copa and Cogeca believe that protection of GIs against evocation is extremely important. Nevertheless, we are concerned that by introducing a very restrictive definition of evocation, the proposal might weaken this protection, as evocation is an evolving practice that cannot be encompassed by a very restrictive definition. We would thus recommend deleting the definition and instead relying on the European Court of Justice’s jurisprudence. 6. PDO and PGIs The Proposal removes the possibility of replacing trhe term "protected designation of origin" with the term "registered designation of origin". The term AOC is widely used by operators and known by consumers, we thus believe that it is important to maintain this possibility. 7. Support for new comers Copa and Cogeca also believe that the Regulation should establish an obligation for Member States and the Commission to provide GI producers with the expertise and administrative support necessary for GI registration, especially in regions that are under-represented in the GI scheme.
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Meeting with Janusz Wojciechowski (Commissioner) and

23 Jun 2022 · Lifting of all tariffs and quotas for poultry meat imports from Ukraine

Meeting with Dārta Tentere (Cabinet of Commissioner Mairead Mcguinness) and European agri-cooperatives

21 Jun 2022 · Sustainable finance, taxonomy

Meeting with Frans Timmermans (Executive Vice-President) and European agri-cooperatives

16 Jun 2022 · Sustainable food systems

Response to Measures related to the containment of the plant pest Grapevine flavescence dorée phytoplasma

15 Jun 2022

Copa-Cogeca welcomes the possibility to provide feedback to the proposed Implementing Regulation which aims to establish measures for the containment of the Grapevine flavescence dorée phytoplasma (pest) within the demarcated areas where its eradication is not possible. The activity of the nurseries producing vine propagating material is strictly interconnected with the presence of vineyards, which, given their capillarity, increasingly restrict the areas suitable to host the stock nurseries and nurseries. Therefore, these coexist with productive vineyards that are managed in different ways (traditional, organic, biodynamic, etc...) or even abandoned and neglected, of different sizes, belonging to family businesses, entrepreneurs or companies of various kinds and profession. In this context, it is very difficult to define infected areas and buffer zones and that it is not feasible, if not at enormous economic and social costs, to move the current nursery activity to pest-free areas. We are concerned that the hot water treatment could be made compulsory for hundreds of millions of plants with additional costs charged to nurserymen for a treatment still under evaluation. Production of pest-free plants does not solve the problem of the spread of the pest as the pest-free plants put in an environment where the pest and the Scaphoideus titanus Ball (vector) coexist, become rapidly infected, zeroing the good starting health situation. A rapid spread of the pest in vineyards is being witnessed by nurserymen working in vineyards. The spread has also been further accelerated by the lack of awareness of the danger of the disease, the reduction in the availability of active principles for fighting the vector and by the difficulty of managing the different methods for the use of pesticides inherent in the different types of vineyards (organic or integrated or traditional agriculture etc.). By contrast, the pest is well controlled in the stock nurseries and nurseries thanks to the considerable and steady attention paid by the Control Services and to the sensitivity of the nurserymen. The presence of pest-infected plants in the fruiting vineyards next to their nurseries and stock nurseries is significantly impacting on winegrowers because of the possible infections. Different strains of the pest are known, depending on the area of origin and diffusion. In the Eastern European countries, the strains of pest are different from those in the Mediterranean countries. Indeed, many strains are autochthonous. At least in the last years there has been no reported spread of flavescence dorée strains from Mediterranean countries to the Eastern European ones despite the importation of vine propagation material from the former. This confirms that nowadays the propagating material plays very little role in the spread of the pest. The fear of the spread of pest is understandable. However, the danger of such phytoplasma is far less acute than that of other quarantine diseases, for example: Xylella spp. That said, the approach to this disease cannot be similar to that adopted for, let’s say, Xylella. Rather, it must be tailored to the actual and specific hazard of flavescence dorée. Copa-Cogeca believes that provisions should be adopted to establish or strengthen specific interventions, such as mandatory phytosanitary treatments and the obligation to remove and destroy the infected plants, aimed at containing the spread of the pest, especially in the vineyards where there has not been adequate attention to plant diseases, as in the stock nurseries and nurseries of producers of vine propagation material the spread of such phytoplasma is currently well controlled. The removal or destruction must be carried out by the vineyard manager. In the event of non-compliance within 10 days from the moment the plants were found infected or from the notification, the removal or destruction of the infected plants shall be carried out by the competent authority.
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Meeting with Stella Kyriakides (Commissioner) and

15 Jun 2022 · Animal welfare

Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development) and European agri-cooperatives

10 Jun 2022 · Exchange of views on the state of food communication

European Farmers Oppose High-Risk Label for Agriculture Sector

23 May 2022
Topic — The consultation addresses a proposed directive on corporate sustainability due diligence and liability.
Message — Copa and Cogeca object to classifying agriculture as high-risk and request clearer definitions. They propose replacing sanctions with guidelines and exempting intra-EU supply relations from due diligence.1234
Why — Exemptions and guidelines would shield agricultural companies from significant administrative burdens and compliance costs.56
Impact — Small producers lose if large companies contractually transfer compliance costs onto them.7
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European Farmers Urge Keeping Specific Antimicrobials Available for Livestock

12 May 2022
Topic — This consultation designates specific antimicrobials to be reserved exclusively for treating human infections.
Message — The organization requests excluding certain antimicrobials like glycopeptides and macrocycles from the reserved human list. They argue these substances are essential for maintaining health in specific livestock species.1
Why — Farmers would maintain their ability to treat animals with essential medicines and avoid production losses.2
Impact — Human health may be compromised if these drugs continue to fuel antimicrobial resistance.3
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Response to A New European Innovation Agenda

10 May 2022

Copa and Cogeca welcome the opportunity to respond to the preparatory work for the New European Innovation Agenda. Please find attach our feedback.
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European farmers demand lower reporting burdens for forest monitoring

5 May 2022
Topic — Legislation establishing a coordinated EU framework for forest observation and strategic planning.
Message — Copa and Cogeca argue that any new framework must build upon existing national reporting to minimize overlaps. They request the Commission focus on reducing the administrative burden for forest owners. They oppose EU-level monitoring of detailed forest management activities.123
Why — Farmers would avoid significant costs associated with new, highly detailed data reporting requirements.4
Impact — The European Commission loses authority to approve national plans or monitor specific management practices.56
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European farmers urge rewards for carbon capture and biodiversity

1 May 2022
Topic — The European Commission is proposing a framework to certify and verify carbon removals.
Message — The organization demands that environmental benefits beyond carbon be recognized and rewarded. They suggest EU minimum standards to reduce complexity and legal uncertainty for farmers. They insist carbon credits must not allow industries to avoid direct emission reductions.123
Why — Certification would turn carbon removals into a stable additional income source for farmers.4
Impact — Industrial companies could be prevented from using agricultural credits to avoid decarbonization obligations.5
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Meeting with Thierry Breton (Commissioner) and European agri-cooperatives

28 Apr 2022 · Impact Russian invasion of Ukraine on agricultural sector

European farmers reject 'one-fits-all' EU fertiliser reduction targets

26 Apr 2022
Topic — EU plan to manage nitrogen and phosphorus to reduce environmental and water pollution.
Message — The organization opposes uniform reduction targets for fertilisers across the EU. They recommend focusing on precision farming and efficiency-based advisory services to reduce nutrient losses.12
Why — Avoiding mandatory cuts prevents potential yield losses and ensures farmers can maintain soil fertility.34
Impact — Environmental advocates lose the legal certainty of specific, EU-wide targets for reducing nutrient pollution.5
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Meeting with Frans Timmermans (Executive Vice-President) and European agri-cooperatives and

7 Apr 2022 · European Green Deal and forest related policies, including the new European Forest Strategy for 2030

Response to Recommendation for strengthened actions against antimicrobial resistance

24 Mar 2022

Copa and Cogeca, representing EU farmers and agri-cooperatives, welcomes the possibility offered by the Commission to contribute to this public consultation. Please find our full feedback in the PDF attached.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Landowners' Organization asbl and Conféderation Européenne des Propriétaires Forestiers

16 Mar 2022 · Preparation for EVP Timmermans’ meeting with the representatives of CEPF, COPA-COGECA and ELO on forest related policies

Response to Amendment of protective measures against pests of plants - Thaumatotibia leucotreta

9 Mar 2022

From Copa and Cogeca, representing EU farmers and cooperatives, we thank the Commission for the opportunity to answer to this public consultation. Please find our full feedback attached in PDF.
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Meeting with Janusz Wojciechowski (Commissioner) and

24 Feb 2022 · Pigmeat market management

Meeting with Wioletta Dunin-Majewska (Cabinet of Commissioner Elisa Ferreira) and FoodDrinkEurope and European Liaison Committee for Agriculture and agri-food trade

28 Jan 2022 · Revision of the promotion policy.

Meeting with Janusz Wojciechowski (Commissioner) and

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

Response to Measures related to Globodera

11 Jan 2022

From Copa and Cogeca representing EU farmers and agri-cooperatives, we thank the Commission for the opportunity to answer this public consultation. Please find our feedback in the PDF attached.
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Response to Measures related to Ralstonia

11 Jan 2022

From Copa and Cogeca representing EU farmers and agri-cooperatives, we thank the Commission for the opportunity to answer this public consultation. Please find our feedback in the PDF attached.
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and European agri-cooperatives

15 Dec 2021 · EU Promotion policy

Response to Amendment of data requirements for applications for the approval of active substances

23 Nov 2021

Copa and Cogeca welcome the possibility to give feedback in this consultation. Please find our contributión attached.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

The agriculture and forestry sectors are the only sectors capable of providing not only carbon sequestration but also alternatives through renewable raw materials to substitute fossil-based products. European farmers and agri-cooperatives are ready to play their part in delivering the ambitious EU climate objectives. These will only be achievable by putting in place efficient legislative instruments that build on the climate change mitigation potential of the land-based sectors. With the current Energy Taxation Directive (ETD), Member States may apply a level of taxation down to zero to energy products and electricity used for agricultural, horticultural or piscicultural works, and in forestry. The Commission draft maintains the possibility for derogations for energy products used for heating purposes and for electricity, used for agricultural, horticultural or aquaculture works, and in forestry it significantly increases the minimum levels allowed from day one, 1.1.2023, until 1.1.2033. Copa and Cogeca call for the current derogations concerning the levels of taxation to be maintained. The value of energy products used in agriculture, forestry and horticulture represents a significant share of agricultural costs. Therefore, an increase in the cost of agricultural inputs would have severe repercussions for the price of agricultural, horticultural and forestry products. This is not in the interest of EU consumers. Eliminating the zero-taxation linked to the use of energy products and electricity in agriculture, horticulture, and forestry would have an impact on the competitiveness of these sectors and would lead to these activities moving to third countries. This will be crucial particularly if the current trend of increasing production costs for farmers (i.e. feed, fertilisers, energy) continues to have a significant impact on agricultural income. In turn, this would result in investments in the sector falling through, which would lead to job losses in rural areas. Given that in the Member States the ETD exists alongside the EU emissions trading system (EU ETS), coherence between the levels of taxation needs to be guaranteed. The biofuels and bioliquids that adhere to the sustainability criteria and the energy produced from agricultural and forest biomass should not be hit by a CO2 tax because the CO2 emissions released during their combustion are deemed to be neutral. Copa and Cogeca positively welcome the proposal aiming to tax fuels based on their energy content (rates in euros/gigajoule) but call for this to only concern those of fossil origin to encourage investments in clean technologies. In addition, it would be unacceptable, to the say the least, for biofuels to be taxed more than equivalent fossil fuels with the same energy content. A tax based on the carbon intensity of the energy would be the right way to decarbonise the energy. Only the motor and heating fuels produced or derived from biomass that do not conform with the sustainability requirements of directive (EU) 2018/2001 and/or that pose a high indirect land use change-risk should be taxed at the same level as fossil fuels. No discrimination should be made between sustainable food or feed crop biofuels and advanced biofuels as long as they adhere to the sustainability criteria as laid out in Directive (EU) No 2018/2001 (RED II). Copa and Cogeca reaffirm their position according to which it is fundamental to provide for a derogation scheme specific to energy used in agriculture, horticulture and forestry and biofuels in the framework of the recast of directive 2003/96/EC on the taxation of energy products and electricity. They call for a reduction in excise duties for pure and directly or indirectly blended biofuels/bioliquids. Copa and Cogeca expect a commitment from the European Commission and Member States to maintain the reduction (or exemption where there is one) so that the sector can work based on a clear vision that allows for planning.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Biomass is the main source of renewable energy in the EU. Equipped with an appropriate toolbox, European agriculture and forestry have the potential to produce additional volumes of sustainable biomass in the EU by 2030. Copa and Cogeca want the role of certified sustainable agricultural and forest biomass to be strengthened in all the bioenergy sectors. They recommend a stable, long-term policy guaranteeing the existing and future investments as well as greater consistency between the different EU policies. Public support for conventional biofuels must continue by 2030 as they are a very effective way of decarbonising transport. We have always demanded a renewable energy incorporation obligation as provided for in RED. Copa and Cogeca have asked to maintain a European objective to decarbonise fossil fuels beyond 2020 (art.7a. FQD) and to link the proposal to RED. In order to send an ambitious and consistent signal concerning the decarbonisation of transport, all energy content multiplication factors must be removed for all types of transport. In addition to the proposal on B10, the Commission should propose to make E-10 mandatory at EU level and an overall EU strategy in favour of the standardisation of fuels with a high biofuel content. It must be possible for Member States to include conventional biofuels of European origin in the EU's RES target that are produced with European feedstocks and which generate co-products rich in plant protein, in animal feed or in cellulose, but which exceed the 7% threshold. Given the tensions on the livestock feed protein market, crop-based biofuels that provide high-quality protein and fodder co-products must be given preference. The Member States must not be given the option to reduce the 7% cap on crop-based biofuels and consequently the national RES target. Differentiation between the different conventional biofuel sectors must be rejected because it has a negative impact on European farmers' ambition to provide sustainable solutions to the fight against climate change. The contribution of advanced biofuels produced from feedstock will depend on the list of feedstocks drawn up in Annex IX. The production of renewable biogas is a domain in which the agricultural sector has enormous potential to help make the consumption of gas and the production of bioenergies greener by emphasising circularity and productive and innovative agricultural systems that offer greater soil protection. The farming sector stands ready to contribute, building on the good practices of cooperative models. Rigid regulatory constraints regarding the cascading principle cannot account for the complex interplay of the timber market and causes considerable market disruptions with huge disadvantages for the whole timber value chain. Previous experience on a national and regional level in the Member States has shown that rigid legal provisions on cascading use cannot be implemented in practice and lead to uncontrollable market distortions. This mandatory approach proposed is harmful to the market economy and we firmly oppose it. The new no-go areas for forest biomass are absurd. No-go areas for agriculture were initially created to avoid land use changes, but extending them to forest areas runs counter to their declared objective because there are no land use changes involved. Moreover, the term “highly biodiverse forests” remains undefined, which makes compliance controls difficult or impossible. The approach recommended by the OECD to demonstrate the sustainability of biomass is based on risk. This approach should also remain the basis for the implementation, as expressed in Directive (EU) 2018/2001. The new restrictions created by the no-go areas for biomass lead to incomprehensible restrictions for raw materials, which go beyond a risk-based approach.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

18 Nov 2021

Moving the aviation sector in a more sustainable direction is a major undertaking. This is why Copa and Cogeca call upon the Commission to focus on synergies rather than selecting specific winners. While e-fuels will without a doubt be important in the future, they depend on carbon molecules, which, in a decarbonised future, must come from biogenic sources. As a result, this Regulation should focus on intelligent ways of integrating and harnessing the full potential of agricultural, forest and aquacultural biomass and on the way in which it can be improved and multiplied through innovative conversion channels, including the use of renewable energies. Nordic GTL, among other research, represents an important contribution to this intelligent and integrated system approach. Given the time required to produce sustainable aviation fuels, those derived from waste and residues, from catch crops and arable crops are needed to reduced GHG emissions in the aviation sector in the short term. Copa and Cogeca support a blending mandate for sustainable aviation fuels and call for support for food and feed crop-based biofuels that are compliant with the sustainability criteria set out in Article 29 2) to 7). Any aeroplane leaving a European airport, be it an intercontinental or continental flight, must adhere to the blending obligation. In addition, Copa and Cogeca call for the fleet of cars and lorries used in the airports or by airlines to be obliged to use sustainably certified biofuels such as B100 or pure vegetable oil for lorries, as well as blends of bioethanol (E10, E20 and E85) and other biofuels of plant origin, in line with the RED II objectives. Copa and Cogeca strongly oppose the multiplier for the renewable energy content of biofuels used in aviation (article 27.2.c of directive (EU) No 2018/2001 or article 1.16)c) of this Regulation). This multiplier is nothing but an arithmetic charade that does not reduce greenhouse gas emissions in aviation by one single tonne.
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and European agri-cooperatives

15 Nov 2021 · Sustainable food systems

Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

Copa and Cogeca believe that the proposed revised regulation on CO2 standards for cars and vans is a missed opportunity to establish the principle of technology neutrality and recognize the cost-efficient role of certified crop-based and advanced biofuels such as biomethane. The revision of the EU CO2 reduction targets for cars and vans cannot continue to ignore the emissions savings being delivered by certified sustainable crop-based and advanced biofuels every day. This restrictive Tank-to-Wheel or “tailpipe approach” so far adopted by the Commission distorts competition among powertrain technologies and misleadingly labels electro mobility as emission-free. Such narrow technology approach is an obstacle to the decarbonization of the existing fleet where necessary. It also fails to incentivise crop-based and advanced biofuels and biogas, which are cost-efficient renewable energy sources with a lower carbon footprint compared to fossil fuels, by not acknowledging their biogenic energy content. The Commission’s proposals can be corrected by introducing elements of a wider Well-to-Wheel approach with a methodology that considers the nature of the energy powering vehicles, distinguishes between fossil and biogenic CO2, and accounts for the production and the full life cycle of electricity, including the production and recycling of batteries. The thermal engine using high biofuel content emit very little fossil CO2 and must continue to exist in combination with electrified solutions, to reduce CO2 emissions. The flex-E85 plug-in hybrid vehicle, for mixed use, in and out of town for long distances, offers better CO2 performance in most European countries, given that most of the electricity is still produced from fossil fuels. It is therefore a complement to the 100% electric vehicle adapted to short trips. Advanced biofuels such as biomethane can already make a concrete contribution to the decarbonization of the transport sector and stimulate a circular economy today. Copa and Cogeca ask an appropriate accounting mechanism for certified crop-based and advanced biofuels that will incentivise the vehicle industry to further invest in cost-effective and available solutions like higher biofuel blends and biomethane. The methodology must be comprehensive and fair to properly evaluate each alternative.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Confederation of European Paper Industries and

8 Nov 2021 · Forest based industries

Response to Food waste reduction targets

29 Oct 2021

Copa and Cogeca welcome the Commission proposal to fix reduction targets for Member States, however, this process needs to follow a carefully designed and incremental plan as set in Directive 851/2018/EC amending Directive 2008/99/EC on waste. Furthermore, the imbalances of power in the food value chain need to be taken into account as to ensure a fair repartition of responsibility between all actors. Scope: In the context of this initiative, and as expressed in article 9(6) of Directive 2008/99/EC, in 2023, the Commission will consider the feasibility of establishing food waste reduction targets for 2030. However, as established in article 8(g) of this same directive, the objective is to follow the objective of the Sustainable Development Goal (SDG) 12.3, which is to halve per capita food waste at the retail and consumer levels and reduce it at the production and processing stages. We thus would like to underline that when it comes to primary production and processing stages, the target set by both the directive and SGD 12.3 is to reduce food waste, but not by 50% as for the retail and consumers stages. These different levels reflect the fact that most of the food waste takes place at the consumers stage (more than 50%) and that the small part occurring in primary production (around 11%) is highly linked to policies at the retail stage. It is thus complicated for the primary stage to reduce its food waste compared to other stages. We thus strongly argue that food waste targets for primary production and processing stages should not be set at the same levels than for consumers and retail and we favour option S2 setting target covering only the retail and consumers stages. It is also important to underline that food losses are out of the scope of Directive 2008/99/EC and that food waste does not include plant prior to harvesting as expressed in article 3(4A) of the Directive referring to Article 2 of Regulation (EC) No 178/2002. In addition, agricultural material used in farming or for the production of energy are not considered as food waste as established by article 2(f) of Directive 2008/99/EC. Expression: The targets should be expressed in % of food waste reduction from the amount of food waste in the baseline year as absolute amounts are complicated to establish and we would have to fix different amounts per type of food waste on ensure their representativeness (e.g. the absolute amounts of waste for sugar beets in comparison to truffles). We do not support the baseline of 2020. Over the past years a lot of efforts have been made to reduce food waste, thus setting targets with 2020 as a basis would not take into account all the work achieved. 2020 as a basis could end in setting impossible targets as for some actors they have already reduced food waste to such an extent in the past 6 years that it would be impossible to reduce it much more. We believe that as set in Directive 2008/99/EC and in SDG 12.3, the baseline year for targets should be 2014 or 2015. Furthermore, 2020 will not be a representative year for food waste because of all the disturbances that occurred in food supply chains due to the COVID-19 crisis. The way the targets are set for member states: The targets level should be the same for all Member States as long as the baseline year is 2014 or 2015. This baseline is important considering that some Member States have heavily invested in food waste reduction over the past few years and it would thus be unfair not to take this into account by setting 2020 as baseline. Food waste occurring at primary production is highly impacted by elements independent of the will of primary producers such as unfair trading practices like the last minute cancellation of orders. Therefore, it is crucial that reduction targets and the repartition of the sub-objectives and actions to achieve them carefully considers the imbalances of power in the food value chain to ensure a fair repartition of responsibility for all actors.
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Meeting with Sandra Gallina (Director-General Health and Food Safety)

28 Oct 2021 · Farm to Fork Strategy

Response to Sustainable food system – setting up an EU framework

26 Oct 2021

In line with the objectives of Farm to Fork Strategy, the overall objective of this Sustainable Food System Framework Initiative is to ensure that all foods placed on the EU market increasingly become more sustainable. Copa and Cogeca fully support this overall objective and are dedicated to contributing to making EU food systems more sustainable. To achieve this objective, the Commission proposes to create a guiding framework that would ensure a coherent implementation of actions towards food sustainability across all sectors, actors, and aspects of food systems. Copa and Cogeca welcome this approach as we believe that to be successful, it needs to encompass the whole food value chain. Food sustainability is a very complex issue due to the interconnectivity between the three pillars of sustainability (environmental, social, and economic) and the large spectrum and diversity of sectors, products/commodities, actors, and legislation it englobes. Thus, at this stage, it is not yet possible to single out which would be the best approach to achieve the objective, including whether that would be one of the options proposed by the Commission. While choosing the best approach requires further discussion and analysis, we can already underline some essential elements that we consider important to take into account for any sustainability framework: • Need for a proper definition: It is essential that any framework on food sustainability provides a clear definition for food systems sustainability around which to harmonise and coordinate actions. This definition should encompass and give equal importance to all three pillars of sustainability (environmental, social, and economic). It should also allow for the adaptation to the particularities of each sector. • The right starting basis: It is very important to acknowledge what has already been achieved in terms of food production sustainability and to take it into account when fixing new objectives. • Inclusive approach: When it comes to methods and types of primary production, all of them should be included and should have the chance to contribute to improving the sustainability of food systems, whether we are talking about crops or livestock, intensive or extensive production. • Food security: Both EU and global food security needs to be considered in coherence with growing global population and demand for food. • Trade aspects: The framework needs to appraise trade aspects in a way to avoid sustainability leakages, maintaining EU’s products competitiveness while respecting WTO rules. • Additional costs and economic viability: The framework needs to ensure that any additional costs for farmers are compensated either through added value or financial incentives. If we are to maintain EU agriculture’s competitiveness, we need to ensure that it remains economically viable. We also need to ensure that farmers and agri-cooperatives have access to financial means, technologies to improve sustainable food production. • Fair repartition: The balance or imbalance between the different actors of the food value chain needs to be pondered. • A market driven approach: Improving the sustainability of food products will inevitably induce additional costs which will partly have to be paid by consumers. It is thus essential to ensure that changes match consumers demand and thus that they are implemented gradually along with consumers demand evolutions. • Avoid duplication and unnecessary work: The body of EU legislation, whether directly or indirectly linked to food systems sustainability, is already extremely large. Creating new legislation is not recommended since existing texts can simply be updated or when non-regulatory approaches can deliver efficient results. This would avoid duplication, as well as long and resources consuming legislative processes.
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Response to Sustainable food system – setting up an EU framework

26 Oct 2021

In line with the objectives of Farm to Fork Strategy, the overall objective of this Sustainable Food System Framework Initiative is to ensure that all foods placed on the EU market increasingly become more sustainable. Copa and Cogeca fully support this overall objective and are dedicated to contributing to making EU food systems more sustainable. To achieve this objective, the Commission proposes to create a guiding framework that would ensure a coherent implementation of actions towards food sustainability across all sectors, actors, and aspects of food systems. Copa and Cogeca welcome this approach as we believe that to be successful, it needs to encompass the whole food value chain. Food sustainability is a very complex issue due to the interconnectivity between the three pillars of sustainability (environmental, social, and economic) and the large spectrum and diversity of sectors, products/commodities, actors, and legislation it englobes. At this stage, it is not yet possible to single out which would be the best approach to achieve the objective, including whether that would be one of the options proposed by the Commission. However, we can already underline some essential elements that we consider important to take into account for any sustainability framework: • Need for a proper definition: It is essential that any framework on food sustainability provides a clear definition for food systems sustainability around which to harmonise and coordinate actions. This definition should encompass and give equal importance to all three pillars of sustainability (environmental, social, and economic). It should also allow for the adaptation to the particularities of each sector. • The right starting basis: It is very important to acknowledge what has already been achieved in terms of food production sustainability and to take it into account when fixing new objectives. • Inclusive approach: When it comes to methods and types of primary production, all of them should be included and should have the chance to contribute to improving the sustainability of food systems, whether we are talking about crops or livestock, intensive or extensive production. • Food security: Both EU and global food security needs to be considered in coherence with growing global population and demand for food. • Trade aspects: The framework needs to appraise trade aspects in a way to avoid sustainability leakages, maintaining EU’s products competitiveness while respecting WTO rules. • Additional costs and economic viability: The framework needs to ensure that any additional costs for farmers are compensated either through added value or financial incentives. If we are to maintain EU agriculture’s competitiveness, we need to ensure that it remains economically viable. We also need to ensure that farmers and agri-cooperatives have access to financial means, technologies to improve sustainable food production. • Fair repartition: The balance or imbalance between the different actors of the food value chain needs to be pondered. • A market driven approach: Improving the sustainability of food products will inevitably induce additional costs which will partly have to be paid by consumers. It is thus essential to ensure that changes match consumers demand and thus that they are implemented gradually along with consumers demand evolutions. • Avoid duplication and unnecessary work: The body of EU legislation, whether directly or indirectly linked to food systems sustainability, is already extremely large. Creating new legislation is not recommended since existing texts can simply be updated or when non-regulatory approaches can deliver efficient results. This would avoid duplication, as well as long and resources consuming legislative processes.
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Response to Restoring sustainable carbon cycles

7 Oct 2021

Carbon farming is an important part of the effort towards achieving climate neutrality by 2035, and to generate negative emissions thereafter. In this regard, Copa and Cogeca welcome the publication of Commission’s Roadmap on the Carbon Farming Initiative. Nonetheless, we call on the Commission and EU Member States to ensure that the agricultural and forestry sectors have the necessary toolbox, both technical and financial, and an adequate timeline to fully unlock their potential. We urge the Commission to explore options for the development of market-based carbon crediting schemes in a new business model. While European farmers, forest owners, and cooperatives are already taking initiatives to do carbon accounting, we note that agriculture, forestry and land use sectors cannot compensate for the entirety of fossil carbon emissions from other sectors. Moreover, the role and implications for the forestry sector need to be further clarified.
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Response to Carbon Border Adjustment Mechanism

4 Oct 2021

EU agriculture and forestry are among the most efficient and advanced in the world in terms of their commitment to the climate and the environment. As professionals in the field, we are and will be the first to be affected by climate change. We are also committed to making the EU climate-neutral by 2050, by reducing our emissions, producing biofuels, bioenergy and bio-based materials for other industries, and above all by increasing/maintaining the carbon sink that agriculture and forestry can provide by optimising CO2 absorption of ecosystems while replacing fossil fuels. Nevertheless, the production of food (incl. feed) remains central in line with Article 2 (b) of the Paris Agreement. One of the main risks that we will have to face because of the EU Green Deal is climate dumping from countries that will voluntarily or involuntarily progress slowly with their adoption of a greener agriculture. Therefore, we support the idea of setting up a CBAM for agricultural products, provided that certain conditions are met. From the farming perspective, the CBAM could work as a measure to prevent carbon leakage (CL), provided that it is in line with the European tariff system and agricultural expectations. The mechanism can help to prevent a disruption of competition, but this would require access to the latest available technologies. CL in agriculture must be successfully prevented without adding an excessive bureaucratic burden of carbon accounting all the while acknowledging that agriculture must be granted free baseline emissions, which are unavoidable as we are dealing with natural processes. While we must not refrain from using the CBAM against unfair competition from countries with lower environmental ambitions, we agree that the CBAM should not be used as a protectionist tool. It should be compatible with the WTO rules, thus ensuring that EU agriculture is not the target of retaliation. For the moment, this remains unclear. According to the Farm to Fork strategy, EU food is currently a global standard for food that is safe, plentiful, nutritious and of high quality. Maintaining this standard while remaining competitive is essential to enabling further investments in sustainability. From the EU farming perspective, it is crucial to ensure consistency within the agri-food value chain. Ultimately, only applying the CBAM to the main raw materials for crop production would be unfair and would lead to the opposite of the intended effect, namely massive CL to the detriment of EU agriculture. This CL will manifest itself in an increasing number of farmers ceasing production due to a reduced demand for EU food, which is indisputably one of the most sustainably produced sources of food. In addition, applying a CBAM to iron and steel products will lead to an increase in production costs given their use in agricultural equipment and machinery. To conclude, the Commission recognises that the ETS system, even if it is revised, will not be sufficient to prevent possible dumping from countries that do not share our climate ambitions. With the implementation of the Farm to Fork strategy, ensuring fair competition will become a growing cause for concern for the farming sector. Unfortunately, the current CBAM proposal would exacerbate this problem. Although we support the idea of setting up a CBAM for agricultural products, the Commission has decided to exclude agriculture. At the same time, the iron and steel products and fertiliser sectors are included. This unfair and double penalty for farmers will be unbearable. It should be rectified by excluding the fertiliser sector or developing a tool to prevent CL in agriculture. Please find the full contribution attached to this reply.
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Response to Fruit and vegetable production - more flexibility in the calculation of the value of damage caused by natural disaster

27 Sept 2021

Extreme weather conditions have had a strong impact on fruit and vegetable production in some regions of the EU. The 2021 stone fruit and pear harvests represent the smallest harvests on record in Europe in the last 30 years. Therefore, Copa and Cogeca would like to thank the Commission for the proposal for a delegated act that provides for additional flexibility in the calculation of the value of marketed production of producer organisations in the event of a reduction in the value of marketed production due to natural disasters, adverse climatic events and disease or pest infestations. However, the Commission’s measure is largely insufficient and inadequate. The seriousness of the recent adversities faced by the fruit and vegetable sector requires more than the 2021 confirmation of the derogation allowed the previous year. Measures such as raising the EU co-financing rate of operational programmes to 70% are required. However, Copa and Cogeca have identified a problem when it comes to the competent national authorities having to define requirements for both options (85%, 100%), notably: - proving that “those reasons were falling outside its responsibility and control” and - "that it has taken the necessary preventive measures against the natural disaster, climatic event, plant disease or pest infestation concerned". What will the requirements for the "competent national authorities" be when auditing compliance according to the conditions listed above? In short, we call for differentiation between the two percentages (85% and 100%) to be avoided and therefore for the higher percentage of 100% to be adopted. This would avoid having to demonstrate that the PO has adopted the preventive measures against disasters, plant diseases and pest infestations In addition, Copa and Cogeca would welcome an extension of all derogations introduced in 2020 concerning operational funds and operational programmes for the year 2021 as the producer organisations have learned how these derogations can be implemented. The greater flexibility indicated in the proposal, however, may prove to be ineffective. Indeed, in many cases, natural disasters, climatic adversities, plant diseases and pest infestations have taken their toll for consecutive years. For example, in northern Italy this is a recurring situation as many fruit crops were affected by frost and the Asian stink bug both in 2021 and in 2020. Pushing back the reference period for the calculation of the damaged product by one year does not solve the problem. To mitigate the effect of this, POs should at least be allowed to opt to take (as a basis for calculation) the two-year period preceding the reference year.
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Response to Organic food: production and use of non-organic, in-conversion and organic seedlings

15 Sept 2021

Following the publication of the consultation on “Organic food – production and use of non-organic, in-conversion and organic seedlings”, Copa and Cogeca would like to share with you our reaction. The main focus of this consultation is on availability of organic seedlings to be planted as plant reproductive material, “in-conversion seedlings”, marketed in compliance with Article 10(4), second subparagraph, point (a). As we know, the supply of organic seeds has been a difficult discussion due to its features. We have supported and welcomed the upcoming new Regulation 2018/848 and its efforts to harmonize the organic production, including the seed sector. However, as you know from the pending derogations outlined also in this draft delegated act, the reality requires a particular attention on different situation, which might differ from Member State to Member State. After consulting our members, we received several reactions to this consultation, especially coming from the horticulture and flowers sectors. From their reactions, we understood that the organic seeds and seedlings market is fragmentated. There are areas where the market is more advanced and thus prepared for future changes (as this draft would lay out); however, there are still some other areas in the EU where the market has been struggling to catch up. We have been collaborating and supporting the work that led to the creation of the basic act 2018/848, in which we have strong hopes for a better and stronger organic future. Nevertheless, due to the important renovation and innovations that the “Organic Regulation” will bring for the EU farmers and agri-cooperatives, Copa and Cogeca hereby ask you to take into account the diversity of the level of maturity of the national markets and ensure that the gap among these different markets will be reduced thanks to the European legislation and they will not be further jeopardized. We remain available for any further discussion on this matter.
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Response to European Bioeconomy Policy: Stocktaking and future developments

30 Jul 2021

We strongly believe that the circular bioeconomy provides concrete solutions to implement the EU Green Deal not only in terms of climate neutrality but also efficient use of resources through circularity, environmental protection, stimulating sustainable businesses, and providing additional revenue streams in rural areas. The agricultural and forestry sectors play a crucial role putting these solutions into practice. However, their commitment and contribution it is often forgotten in the debate on the development and implementation of a more biobased society. We must take stock of the lessons learnt from the implementation of the current EU Bioeconomy strategy and continue to promote a strong strategy at all levels in future. Member States and all relevant actors have been strongly encouraged to develop their strategies and create new business models for a greener and a more circular economy. Farmers and their cooperatives have increased their investment, innovation and cooperation in bio-based value chains and it is crucial that they be able to continue and unlock their full potential. The current strategy successfully created synergies between various policies from R&I to investment and more sustainable businesses, but more could be done in the future. A great step in this direction is the inclusion of bioeconomy as one of the main strategic objectives of the future CAP, which should be reflected in the national strategic plans. As regards R&I policies and tools, the new Circular Bio-based Europe Joint Undertaking is a great opportunity for farmers and agri-cooperatives. The farming community represented only 3% of the last BBI JU beneficiaries’ portfolio. The new partnership should become a key tool that provides real solutions for the agricultural and forestry sectors to boost their contribution. Farmers and cooperatives therefore need to have a strong and equal voice in this partnership and be considered important partners when it comes to reaching its goals in rural areas and providing concrete options for consumers. This partnership could also help create more circular economy synergies, but it should not be the only tool. The progress report will have circularity at its core, which is a positive development as the importance of circular bioeconomy has not been highlighted enough. In the 2020 Circular Economy Action Plan, bioeconomy is hardly mentioned. In general, the discussion of circular economy is too focused on “technical” resources and overlooks biological resources. The agricultural sector calls for hurdles in the current legislation to be amended to pave the way towards a bioeconomy. One concrete example is the current limitation on nutrient recovery by using animal manure to replace artificial fertilisers. The agricultural sector calls for concrete measures to develop value chains from primary sector (side) flows to (industrial) end users and promoting fair distribution of added value between all actors in the chain. Such value chains should then replace chains based on fossil raw materials. We strongly oppose the focus on the principle of cascading use for renewable biomass, as we do not believe that it promotes resource efficiency. European farmers, forest owners and their cooperatives fully support resource efficiency and further strengthening the bioeconomy. We support a wide spectrum of biomass uses, creating a competitive market environment, increasing innovation and promoting cost-efficient biomass use. The concept of cascading use may mean different things to different actors along the value chains. It is a top-down concept, which defines the use and value of biomass in a hierarchical manner. Biomass suppliers must continue to be able and free to decide to whom they sell their raw material.
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European farmers urge science-based approach to animal welfare revision

28 Jul 2021
Topic — Revision of EU legislation on farm animal welfare standards and labelling.
Message — The organisation requests that the Commission complete the fitness check before proposing new legislation, base all changes on independent scientific research, and ensure fair trade conditions with adequate transition periods. They emphasise that farmers need compensation for additional costs and adequate time to recover investments already made.1234
Why — This would give them more time to adapt systems without bearing unrecoverable costs from recent investments.567
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Response to Review of the EU school fruit, vegetables and milk scheme - EU aid

27 Jul 2021

Please find attached our contribution.
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Meeting with Janusz Wojciechowski (Commissioner) and

26 Jul 2021 · Food Systems Summit agenda; CAP ; carbon farming and CBAM

Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

23 Jul 2021

Copa and Cogeca are critical of the fact that the draft implementing rules have been published by the Commission significantly too late, as since 1st July 2021 the Renewable Energy Directive 2009/28/EC has no longer been in force. For a proper implementation and application of the Renewable Energy Directive (EU) 2018/2001 (RED II), all implementing provisions should have been in force by this date. In addition to the delay in RED II implementation due to outstanding implementing provisions, national implementation is still incomplete due to the lack of a legal basis. In our view, retroactive application as of 1st July 2021 is simply no longer possible. Indeed, the harvesting of cereals and oilseed rape has begun and is certified according to RED I. Retroactive certification is not possible any more as farmers and subsequent operators have concluded contracts for marketing as a prerequisite for fulfilling the statutory quota obligations in 2021 and 2022 and avoiding statutory penalties. It would be absurd for consumers to have to pay higher prices for fuels as a result of penalties. Moreover, the delayed implementation of RED II makes it necessary to grant extensive transition periods. This applies above all to biomass that was harvested before it came into force and/or biomass that is already in storage. Furthermore, a large number of companies need to be certified, especially in the area of biogas and solid biomass. Not only must the voluntary certification systems be recognised, but certification bodies must also be approved and auditors trained in sufficient numbers. Therefore, we demand that the legal uncertainties caused by the Commission by the late submission of the implementing provisions, and the recognition of the voluntary certification systems, which is yet to be finalised, do not lead to disadvantages for the economic operators. We also call for realistic, feasible and sufficiently timely application deadlines from the Commission. We recommend including the following amendments: Article 3(5): Deletion. Article 6 (b): No further public monitoring is required to ensure proper implementation by economic operators. Article 10(1): Remote audits should be possible. Article 11(1): These requirements will lead to serious difficulties in the certification process resulting in a longer accreditation period. Therefore, no sustainable biomass will be available and the MS will have to adjust their market share of renewable energies or their GHG reduction targets downwards accordingly. The change in the existing practice by introducing a binding accreditation obligation contradicts RED2 Article 30 (8) paragraph 2. Article 19(2) (m): The mass balance system must apply at the first collector level and not at individual farm level. Article 20(2) (c): The Decision 2010/335/UE must continue to apply and it must be updated according to Article 10 of C of annex V of the RED2. Annex IV: Wastes and residues from forestry and the forest industry are not completely included in the list. We ask for annex IX Part A and Part B of RED2 to be included. Annex V: We ask for the current flexibility to be maintained and suggest that this second approach is continued because the RED2 states that the soil analysis can constitute such evidence but is clearly not the only source. We ask for this annex to be withdrawn from the current draft IA, as the Commission should have more time to update the Decision 2010/335/UE. Annex VI: This annex to be withdrawn from the current draft IA, as the Commission should have more time to update the Decision 2010/335/UE. Annex VII: The potential GHG reduction achieved by substituting nitrogen fertiliser of fossil origin with digestate, biowaste must be taken into account in annex VII. Annex VIII: The methodology is not adapted to measure additional biomass from secondary crops. Deletion of this part of annex VIII. The value for nitrous oxide (N2O) must be 265 eq. rather than 298.
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Response to Revision of Food Information to Consumers for what concerns labelling rules on alcoholic beverages

22 Jul 2021

Copa and Cogeca represent 22 million farmers and their family members as well as 22,000 cooperatives dedicated to providing 446 million EU citizens with safe, nutritious, high-quality, and affordable food. We welcome the opportunity to comment on the European Commission’s Roadmap Inception Impact Assessment (IIA) on the revision of EU rules on food information provided to consumers for alcoholic beverages. We believe that EU rules on food labelling are critical for providing consumers with relevant, clear, and easy to understand information as well as for ensuring a level playing field for operators by harmonising rules and requirements at EU level. We support the overarching objectives for the revision of EU rules on food labelling. As rightfully underlined in the IIA, it is important to facilitate informed choices and thus help reduce harmful alcohol consumption and improve public health. We salute the fact that the initiative’s ultimate aspiration is to “reduce harmful alcohol consumption” and not the reduction of alcohol consumption per se. We believe that the revision of food labelling for alcoholic beverages should first and foremost ensure consistency between the recently agreed upon mandatory labelling rules in the framework of the CMO Regulation and the ongoing initiative related to the FIC Regulation which seeks to harmonise mandatory front-of-pack nutrition labelling. Furthermore, we wish to highlight that the voluntary commitments and efforts made by the operators in the alcoholic beverages sector to provide consumers with information on ingredients and nutrition go well beyond the current legal requirements. These detailed commitments were submitted to DG SANTE in 2018, following an invitation to engage in a self-regulatory approach (see Self-Regulatory proposal, the wine/aromatised wine products and spirits annexes). Position regarding the policy options proposed in the IIA In light of the reflections put forward above, Copa-Cogeca would favour a policy option similar to the Option 1, provided that it: • Reflects the co-legislators’ agreement on consumer information, agreed in the framework of the CAP reform, in the rules for the labelling of alcoholic beverages and ensures consistency. • Refrains from including the wine sector in the scope of the Regulation (EU) No 1169/2011 as mandatory labelling rules for wine and aromatised wine products have already been provided for in the framework of the CMO Regulation. Regulating the wine sector in the FIC Regulation as well would constitute a duplication of provisions that already exist in wine-specific regulations. • Allows for potentially all indications, except the energy value, to be provided off-label by electronic means identified on the label or packaging and not displayed with other information intended for sales or marketing purposes. Digital technologies offer flexibility and the opportunity to minimise the operational burden on small producers, while putting product information into a broader context. • Allows for the possibility to limit the on-label indications to the energy value only, in line with Article 30(4) of EU Regulation 1169/2011, as well as to provide the information per portion (alongside the mandatory provision of per 100 ml). A portion-based indication of energy would be most appropriate as people consume portions, the size of which varies from one product category to another. Moreover, the energy value should be indicated with the international symbol “E”, to facilitate communication and simplify translation requirements. • Acknowledges and takes into account concerted or independent voluntary initiatives developed and implemented by the operators, following the Commission’s decision to invite the alcoholic beverages sectors to come up with a self-regulatory scheme. • Considers the structure and heterogeneity of the spirits sector and foresees a longer transition period to allow small producers enough time to prepare.
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Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development) and European agri-cooperatives

19 Jul 2021 · Exchange of views

Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

Copa-Cogeca is the united voice of farmers and their agri-cooperatives. It represents 22 million farmers and their family members as well as 22,000 cooperatives operating in the agri-food, forestry, and fishery sector. The companies that Copa-Cogeca represent are mainly micro, small and medium enterprises. Copa and Cogeca members recognise that it is important for the enterprises to communicate their environmental, governance and social credentials and that dual materiality may become a key driver for the economic development of companies. However, there are some major implications that could derive from the revision of the current rules that we highlight in the attached document.
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Meeting with Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski)

14 Jul 2021 · Promotion Policy

Response to Revision of the plant and forest reproductive material legislation

9 Jul 2021

The Directives on PRM have proven their importance for decades. The system is important to secure steady and surely better yields, higher quality, and better resistance to plant pests that must not be undermined. Now is the time to move on and take the needed giant leap in creating even better varieties to meet demands from consumers, decision makers and not least farmers. Below, Copa and Cogeca’s views. • Maintaining the current list of species, which includes currently significant agricultural species subject to mandatory certification. The identification of varieties via biomarkers must be taken into account as an additional tool to accelerate breeding, but it cannot replace phenotypic observations, since those can be directly observed on fields by farmers. New varieties must offer additional benefits. Knowing that these varieties have been tested and evaluated according to established criteria is a form of assurance for farmers and agro-food chains. The usual values of each variety must be kept. New features that contribute to satisfying CAP’s and consumers’ demands should be tested. A provision that would enhance more the cooperation between MS within the same agro-climatic conditions would be appropriate. It is also vital for farmers to have a wide choice of seed variety suppliers and of affordable seeds, which are well adapted to the local conditions of all European regions. • Vegetables, fruit plants, all ornamental species are not subject to mandatory certification or VCU requirements. These provisions must remain unchanged. • Information on the use of NBTs should be easily accessible to farmers and consumers while the right to maintain confidential breeder information should be respected. Farmers must fulfil the obligations imposed by the supply chains and guarantee transparency to consumers. The system should be simple with a single entry point from which farmers can find all relevant information about the PRM to make informed decisions. • The registration of amateur and conservation varieties should be simplified, while guaranteeing users get the minimum information needed. The exchange in kind must be specified and framed so that it does not lead to a professional activity that would be exempt from the requirements relating to seed actors with regard to compliance with the Plant Health Regulation. The exchange of farm saved seeds among farmers must be absolutely prohibited or it should be regulated as in the case of marketed seeds for potatoes only. • It should be mandatory for organic heterogeneous material to be bred and multiplied under certified organic conditions. This measure would help with tracing this material back to its origin and ensure proper enforcement, consistency and proper consumer information. Organic heterogeneous material must not undermine the trust in the EU seeds marketing system. Care should be taken to ensure that the health status of heterogeneous material is in line with plant health legislation before cross-border marketing. Furthermore, more clarification is needed regarding new opportunities, fair competition, information to consumers, levels of heterogeneity and controls. • Endorsement of the principle of risk-based controls, need to reduce the administrative burden on farmers and cooperatives caused by legislation and controls. The private sector must be involved when defining all aspects related to implementation on official controls in specific sectors. Further bureaucratic burden and costs for official controls will not be accepted, as these are a public service. It is important to maintain the quality assurance that the EU standards offer to farmers, cooperatives, and agro-food chains. It is still important to provide national competent authorities with the necessary incentives to conduct cost-effective official controls. PRM must remain excluded from the official controls regulation. Amending existing official control rules for specific sectors would be the preferred option.
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Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners and

2 Jul 2021 · European Green Deal and the next EU Forest Strategy

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners and

2 Jul 2021 · European Green Deal and the next EU Forest Strategy

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives and

25 Jun 2021 · Forest strategy

Response to Organic food: certificate for operators located in third countries and list of control authorities

9 Jun 2021

Copa and Cogeca would like to add a part to Art. 2, point 1, letter c: "The third countries in which the product categories have origin their agricultural raw materials and origin where they are processed, provided that those third countries are not already covered for the product category or product concerned by an agreement on trade in organic products in accordance with Article 47 of Regulation (EU) 2018/848 or through an equivalence recognition in accordance with Article 48 of that Regulation".
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Response to Organic products - Annual reporting on controls and labelling

9 Jun 2021

Copa and Cogeca would like to suggest to add a part to Art. 2: Member States shall subsequently confirm in the electronic version of the standard model form in IMSOC that Section 9 of Part II of that form has been submitted in OFIS, and shall , at least once a year, make available to the public relevant information according to art. 11 point 1 of Reg. (EU) 625/2017.
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Meeting with Frans Timmermans (Executive Vice-President) and European agri-cooperatives and

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

Response to Organic production - Requirements for keeping records

11 May 2021

If we have to support a strong conversion to organic farming in the next 9 years, we should ensure a conversion as smooth, fast and easy as possible for European farmers and agri-cooperatives. Therefore, European legislations should not hamper the conversion and it should not act as a deterrent action. We must ensure that the necessary regulation will follow a simplification, while avoiding the creation of unnecessary red tape. In the draft regulation on record keeping, Copa and Cogeca have some questions on how the proposed legislation will simplify the bureaucracy approach for organic farmers. Many of our members may argue that parts of the proposed text may increase the time and efforts that organic farmers will have to dedicate to bureaucracy. This aspect can be observed in Part I of Annex II in the points 1.9.3, 1.10.2, 1.11, 1.12, in Part II of Annex II in points 1.4.4, 1.5.1.6, 1.5.2.7. In addition to these points, in Part II of Annex II, points 1.5.1.6 and 1.5.2.7 should be further explained as they might represent more complex procedures for organic farmers
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Response to EU rules on official controls - update to allow controls of imports for the use of certain antimicrobials

4 May 2021

From Copa and Cogeca we thank the opportunity given to provide feedback in this public consultation. Please find the full contribution attached in PDF
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Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

According to Article 29 (8) of Directive 2018/2001 on the promotion of the use of energy from renewable sources (RED II), the Commission should have adopted by 31st January 2021 the implementing act establishing the operational guidance on evidence for demonstrating compliance with the criteria laid down in paragraphs 6 and 7 of this article. This refers to biofuels, bioliquids and biomass fuels produced from forest biomass. The risk-based approach and its criteria for forest biomass is new and should be implemented by the Member States as of 1st July 2021. The operational guidance should be consistent with existing legislation and definitions at EU and national level and should also take into account the role of Member States and provide them with flexibility. The text proposed by the Commission not only arrives late in the process, but it includes many unclear elements and inconsistencies and goes beyond the risk-based approach. This could have a major impact on the implementation of the new rules as it could contribute to a loss of confidence and could create uncertainty for stakeholders. If the Commission plans to propose such detailed criteria, they should reach a joint agreement with the co-legislators. We find it difficult to understand how, with such an approach, the Commission would continue to promote the development of European forest resources to ensure that demand for sustainable raw materials for multiple purposes, including bioenergy, is met. European farmers and agri-cooperatives hope that the Commission will take into account all the concerns raised by the whole sector on this guidance document during the consultation process. Indeed, it is clear that the proposal creates a new detailed framework that goes far beyond guidance, the directive and national legislation. Please find enclosed some specific points that we would like to raise with regard to the text proposed by the Commission.
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Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and European agri-cooperatives and

28 Apr 2021 · to discuss the Preparation of the EU Forest Strategy

Response to Statistics on pesticides, as regards the list of active substances

26 Apr 2021

Copa and Cogeca would like to thank you for the opportunity to provide feedback on the current process to update the regulation concerning statistics on pesticides. Please find our full feedback attached in PDF.
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Meeting with Janusz Wojciechowski (Commissioner) and

22 Apr 2021 · Exchange of views on the future CAP negociations

Response to Authorisation to feed poultry with processed animal protein derived from farmed insects or domestic porcine animals

6 Apr 2021

In general, Copa and Cogeca strongly welcome the Commission’s draft regulation and thus the lifting of the ban on using pig Processed Animal Proteins (PAPs) in poultry feed, poultry PAPs in pig feed, insect PAPs in pig and poultry feed, and ruminant collagen/gelatine in non-ruminant feed. EFSA’s opinions have clearly demonstrated that the reintroduction of these PAPs is deemed safe if cross-contamination is prevented. Indeed, EFSA has evaluated the risk of BSE stemming from the use of poultry PAPs in pig feed and pig PAPs in poultry feed. They concluded that if the intra-species recycling ban is complied with, the risk of transmitting BSE to either non-ruminants or humans is negligible (EFSA Journal (2007) Journal number 576, 1-41). It is important to note that no naturally occurring TSE, including BSE, has ever been detected thus far in pigs and poultry. Furthermore, thanks to the Commission’s and EFSA’s work over the past few years, it is now possible to prevent cross-contamination owing to technological advances in analytical and diagnosis methods and the strict rules laid down in the Commission draft regulation. The sector will of course work hard to correctly implement these rules to ensure trust, transparency, and the highest level of safety. Reintroducing these PAPs for use in feed represents a considerable opportunity for the EU agricultural sectors, one that is in line with the Green Deal objectives. • Thanks to their high level of protein, PAPs represent an alternative to plant-based protein required for feed. This could thus be one of the elements that will help contribute to increase EU's self-sufficiency in feed protein supplies. • Most of the products used to produce PAPs are usually disposed of if not used for this purpose. The use of PAPs would thus optimise resources and prevent waste, which is fully in line with the objectives of the Farm to Fork Strategy and the Circular Economy Action Plan. • The animal health and welfare situation on poultry farms might benefit from the reintroduction of non-ruminant PAPs given that the latter constitute an important source of phosphorus-rich and highly digestible proteins. Phosphorus is a limited resource and the one extracted from plant sources has a much lower nutritional value than the one coming from animal sources. It is therefore an important source that should not be underestimated. It is important to underline that poultry and pigs are two omnivorous species. • This would create a new market for EU poultry, pig, and insect producers as well as for feed manufacturers. • Third country products of animal origin sourced from animals fed with PAPs are already available on the EU market. It is therefore important that our EU agricultural sector can benefit from the same right so as to avoid any unfair competition while being fully in line with the sustainability objective of the Farm to Fork Strategy. For the aforementioned reasons, Copa and Cogeca support this draft Commission Regulation amending Regulation (EC) 999/2001 amending Annex IV to Regulation (EC) No 999/2001. Nevertheless, the strict rules established to avoid cases of cross-contamination (such as dedicated single-species production facilities) and the issues with the analytical tools to control their enforcement (while the methods detect the presence of DNA, it can also be carried by authorised material like pig blood plasma in pig feed) might stifle the potential of these PAPs. It is therefore important to closely monitor their reintroduction and maintain a constant dialogue between operators and controlling authorities to ensure a smooth and efficient reintroduction and to adapt the processes and control methods where needed.
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Response to Information and promotion measures for agricultural and food products in the internal market and in non-EU countries

9 Mar 2021

Copa and Cogeca believe that the EU promotion policy has proven its ability to contribute to its primary objective, enhancing the competitiveness of EU agricultural products, as laid down in Article 2 of Regulation (EU) 1144/2014. We also believe that the Promotion Policy could be a good tool to both promote the EU’s already high sustainability standards worldwide and to encourage EU producers to increase the sustainability of their production even further. Nonetheless, we would like to underline some specific important elements to take into account regarding the objectives of this revision: Objective 1: refocus the policy objectives on increasing the sustainability of the food system and on nudging consumers towards sustainable choices or healthy diets Copa and Cogeca believe that the Promotion Policy can actively contribute to increasing the sustainability of the food system. However, the following elements need to be taken into account: - The contribution of the Promotion Policy can certainly be enhanced, but we need to underline that the Promotion Policy is already contributing to food sustainability thanks to the already high sustainability standards of EU products. Furthermore, we would like to insist on the fact that this sustainability objective should never compromise the first and main objective of this policy, which is the competitiveness of EU agricultural products, as stated in article 2 of Regulation (EU) 1144/2014 which is the legal basis for the EU Promotion Policy. - The sustainability of a product depends on its production method, while the healthiness of a food product depends on the way it is consumed and incorporated in an overall diet. Therefore, we strongly emphasize the fact that no agricultural good should be excluded from the Promotion Policy or face reduced support. We are thus strongly opposed to any reduction of support or exclusion of meat and wine. Furthermore, we would like to stress that EU products observe some of the highest standards when it comes to environmental sustainability and animal welfare. Therefore, if we were to stop the promotion of EU products like wine or meat, consumers would turn to similar non-EU products with considerably lower standards. We would thus indirectly promote less sustainable production. - To efficiently enhance the Promotion Policy’s contribution to food sustainability, it should proportionately support all agricultural practices showing commitment when it comes to sustainability. Disproportionately focusing on a single production method could prevent the others from contributing further to EU agricultural sustainability, which would reduce the overall capacity of the Promotion Policy to increase sustainability. - We call on the Commission to provide some clarity on this aspect by establishing a common understanding for sustainability in the framework of the EU Promotion Policy, in collaboration with the main actors concerned, i.e. the EU producers of agricultural goods. The fact that sustainability is composed of three interdependent pillars (environmental, economic, and social) should of course be the basis of this common understanding. Objective 2: streamlining the implementation process by harmonising the management of simple and multi programmes Copa and Cogeca supports the full management of both multi and simple programmes by Chafea. Position regarding the policy options proposed in the Inception Impact Assessment Copa and Cogeca would favour a policy similar to the first option “Building on the current success”. Indeed, we believe that the current legislative text on which the Promotion Policy is based is perfectly suited to enhancing its contribution to the sustainability of the food system through guidance to applicants and evaluators, and enhanced selection and evaluation criteria in favour of promotion programmes that are consistent with the Farm to Fork Strategy objectives. More detailed information is available in the document enclosed.
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Response to Laying down rules on equine passports

3 Mar 2021

Regarding article 38 of the Draft Implementing regulation, we note that the legislator has included a reference to the possibility of a lifetime exclusion of the equine animal from slaughter for human consumption, to be signed by the veterinarian in accordance to article 39,2. It is our understanding that, to better protect the freedom of the owner of the equine animal and reduce the risk of abandonment, these lifetime exclusions should be avoided. Instead, the Commission should re-examine the legislation regarding the medicines that should include a withdrawal period before the animal can get into the food chain, instead of a lifetime exclusion; to better adapt to the practical reality. This, followed by an increased vigilance during the six-month period towards the slaughter for human consumption status, would bring the necessary clarity and security, while giving the owner the freedom to decide.
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Meeting with Janusz Wojciechowski (Commissioner)

25 Feb 2021 · EU trade related issues: bilateral trade with the US, relations with Mercosur and the UK (post-Brexit).

Meeting with Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives

25 Feb 2021 · Meeting with Copa Cogeca on agri-food in aircraft dispute

Meeting with Thierry Breton (Commissioner) and

18 Feb 2021 · Pact for Skills roundtable with the representatives of agri-food sector

Meeting with Nicolas Schmit (Commissioner) and

18 Feb 2021 · Pact for Skills roundtable with the representatives of agri-food sector.

Response to Revision of EU marketing standards for agricultural products

16 Feb 2021

Copa and Cogeca generally welcome the Commission’s objectives for the revision of EU marketing standards for agricultural products. As rightfully underlined in the Commission IIA, it is extremely important to adapt, where it is necessary and convenient, marketing standards to new market realities, stakeholders’ needs, consumer preferences and available technologies. We also believe that sustainability constitutes one of the major challenges faced by our society and that marketing standards can in some circumstances actively and positively contribute to it in areas such as food waste, animal welfare or nutrition. We do not believe that streamlining the current legal instruments for marketing standards is necessary, as the diversification of the current legal instruments allows marketing standards to be adapted to needs and market realities that vary between sectors. In a nutshell, Copa-Cogeca, for all the reasons detailed in our reflections on the three objectives of this Inception Impact Assessment (please refer to the document attached), would favour a policy option similar to the fourth one proposed in the document, considering that it does not include simplification of the existing legislation by consolidating rules on marketing standards into fewer regulations. Therefore, we would favour a policy option that - Revises, where it is demonstrated that it is necessary, the current marketing standards taking into account technological change, new operators’ needs and consumer preferences; - Introduces new marketing standards for agricultural products where such rules can help adapt to technological change, new operators’ needs and consumer preferences; - Following an impact assessment, introduce sustainability criteria for certain marketing standards where and when: a. It is demonstrated that it is necessary and convenient and that it does not prevent market differentiation based on sustainability, animal welfare or nutrition. b. It does not contradict or duplicate other EU legislations; c. As long as the extra production costs they entail are reflected in the level of quality associated with the product as well as its market price. We also would like to underline that we are still missing EU definition for those sustainability critaria, which could lead to a fragmentation of the market. - Maintains separate legislation that addresses marketing standards for each sector. Please refer to the document attached for further explanations regarding our position and our reflection on the objectives of this Inception Impact Assessment on the revision of marketing standards. The document attached also detailed our position sector by sector.
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Meeting with Janusz Wojciechowski (Commissioner) and

16 Feb 2021 · Common Agriculture Policy reform.

Response to Pyrolysis and gasification materials in EU fertilising products

12 Feb 2021

Copa and Cogeca welcome the inclusion of STRUBIAS in the new Fertilisier Products Regulation and setting standards for STRUBIAS. The proposal will stimulate a common market for biofertilisers and promote the use of bio - residues for fertilizers and the improvement of soil fertility. It must be recognized that the use of STRUBIAS materials are not only an important way of recycling valuable plant nutrients, which is a vital part of the circular bioeconomy. As mentioned in the JRC report "Technical proposals for selected new fertiliser materials under the Fertiliser Products Regulation", STRUBIAS low nutrient materials can serve other fertiliser functions and thus help to improve the efficiency of nutrient uptake in the short or long term under specific situations. This is especially relevant for biochar. Biochar has some unique properties in terms of long-term carbon storage in soil and ensuring higher water capacity in the soil. The application of STRUBIAS materials (especially biochar) to soil will therefore have a direct positive impact on climate change through improved carbon storage in the soil. In some regions, the use of biochar will help mitigate some of the negative effects of climate change by improving soil drought resiliance. It is essential that all fertilsing products provide agronomic benefits and do no harm to soils and the harvested products that come from soils. It is questionable whether the thresholds (PAH, toxicity, …) are sufficient, especially for ndl-PCB (European biochar certificate is factor 4 stricter). EU EBC-Futter EBC-AgroBio EBC-Agro PAH16 6mg/kg TM 4+-2 mg/kg TM 4+-2 mg/kg TM 6,0+2,2mg/kg TM PCDD/F 20ng/kg TM 20ng/kg TM 20ng/kg TM 20ng/kg TM Ndl-PCB 0,8mg/kg TM 0,2mg/kg TM 0,2mg/kg TM 0,2mg/kg TM Cl 30 g/kg TM N/A N/A N/A TI 2 mg/kg TM N/A N/A N/A Temperature of 180°C for 2 seconds allows also HTC-biochar, which is not as stable in soils as pyrolysis-biochar (400-650°C). Test sampling must be sufficient. Only one per year required for small batches not sufficient in order to trace back STRUBIAS products. Biomass and processing data should be declared by the manufacturers. The proposed list of input materials for pyrolysis and gasification are found in annex 1, point 1. The list includes five types or classes of input materials (litra a-e). Litra a includes “living or dead organisms or parts thereof, which are unprocessed….”. This should include all products form agriculture and forestry. But to avoid any uncertainty and to prevent the list from being too restrictive, we will suggest a new litra a for the annex 1, point 1. a) agricultural biomass and forest biomass as defined in directive 2018/2001 on the promotion of the use of energy from renewable sources new b) other living or dead organisms than a) or parts thereof, which are--------------
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Response to Setting of nutrient profiles

3 Feb 2021

In general, Copa and Cogeca welcome the Commission’s policy proposals for a revision of Regulation (EU) No 1169/2011 on the provision of food information to consumers. In the comments below, we would like to present our position regarding the different options proposed as well as some aspects that we believe should be improved or further explored: Front-of-pack nutrition labelling (FOPNL): Regarding FOPNL, Copa and Cogeca welcome any measure that encourages and supports consumers to make healthier food choices and that provides them with better, more detailed and easy to understand information about the food they eat. Therefore, we believe that labelling schemes, used in addition to the mandatory nutrition declaration, have the potential to be a useful tool for consumers. However, in order to truly help consumers to achieve these objectives, such a system should follow the following principles: a) It should be based on solid science and follow dietary guidelines. b) It should allow a comparison of similar products. c) It should take into account the complexity of food products. d) If colour-coded, it should be positive and non-discriminating. e) It should be portion-based. f) It should be voluntary: for several categories of products, FOPNL would be inappropriate. g) It should be under continuous independent scientific guidance and evaluation. h) It should be a harmonised EU system. In light of these elements, we believe that none of the existing FOPNL systems that can be classified according to the four options listed in the roadmap (namely: 1. Numerical 2. Colour-coded 3. Endorsement logo 4. Graded indicators) can provide a satisfactory solution. Consequently, we call on the Commission to explore new options that use the best aspects of the existing ones, while including the elements the existing systems are still missing, which we mention in the attached feedback. We understand that the creation of this new option might require time and resources. However, we firmly believe that choosing an inappropriate FOPNL system for the sole reason that it is already being used in some countries poses a major risk with far-reaching consequences. The system that will be adopted will be in place for decades to come and thus influence the health of our future generations. Therefore, it is important to implement a sound and well-designed system, even if this might take slightly more time.In addition, we believe that any FOPNL system should be supported by communication with consumers. Nutrient profiles: We believe that it is important to find a way to avoid unhealthy products bearing nutrition and health claims and potentially misleading consumers. However, as stated in EFSA’s Scientific Opinion of February 2008 on nutrient profiles, we believe that there are shortcomings inherent to nutrient profiles that prevent them from being the solution to achieving this objective. Please see the document attached for a detailed explanation. Date marking Copa and Cogeca welcome the debate on date marking. Famers and agri-cooperatives believe that food waste is an important issue and many of them are actively engaged in initiatives to reduce it as much as possible. Considering that the misinterpretation of date marking by consumers could be responsible for up to 10% of EU food waste, exploring possible options to improve the current system is essential. When exploring those options, it is also essential to note that date marking is a complex issue that goes beyond food waste, as it is of course linked to food safety but also to food quality and the provision of accurate information to consumers. In light of these elements, Copa and Cogeca need time to assess the options proposed in the roadmap and cannot yet express an opinion in favour of specific one. Nevertheless, we are actively analysing and discussing the issue with the aim to find the best solution possible for food waste, food safety and food quality combined.
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Response to Setting of nutrient profiles

3 Feb 2021

In general, Copa and Cogeca welcome the Commission’s policy proposals for a revision of Regulation (EU) No 1169/2011 on the provision of food information to consumers. In the comments below, we would like to present our position regarding the different options proposed as well as some aspects that we believe should be improved or further explored: Front-of-pack nutrition labelling (FOPNL): Regarding FOPNL, Copa and Cogeca welcome any measure that encourages and supports consumers to make healthier food choices and that provides them with better, more detailed and easy to understand information about the food they eat. Therefore, we believe that labelling schemes, used in addition to the mandatory nutrition declaration, have the potential to be a useful tool for consumers. However, in order to truly help consumers to achieve these objectives, such a system should follow the following principles: a) It should be based on solid science and follow dietary guidelines. b) It should allow a comparison of similar products. c) It should take into account the complexity of food products. d) If colour-coded, it should be positive and non-discriminating. e) It should be portion-based. f) It should be voluntary: for several categories of products, FOPNL would be inappropriate. g) It should be under continuous independent scientific guidance and evaluation. h) It should be a harmonised EU system. In light of these elements, we believe that none of the existing FOPNL systems that can be classified according to the four options listed in the roadmap (namely: 1. Numerical 2. Colour-coded 3. Endorsement logo 4. Graded indicators) can provide a satisfactory solution. Consequently, we call on the Commission to explore new options that use the best aspects of the existing ones, while including the elements the existing systems are still missing, which we mention in the attached feedback. We understand that the creation of this new option might require time and resources. However, we firmly believe that choosing an inappropriate FOPNL system for the sole reason that it is already being used in some countries poses a major risk with far-reaching consequences. The system that will be adopted will be in place for decades to come and thus influence the health of our future generations. Therefore, it is important to implement a sound and well-designed system, even if this might take slightly more time.In addition, we believe that any FOPNL system should be supported by communication with consumers. Nutrient profiles: We believe that it is important to find a way to avoid unhealthy products bearing nutrition and health claims and potentially misleading consumers. However, as stated in EFSA’s Scientific Opinion of February 2008 on nutrient profiles, we believe that there are shortcomings inherent to nutrient profiles that prevent them from being the solution to achieving this objective. Please see the document attached for a detailed explanation. Date marking Copa and Cogeca welcome the debate on date marking. Famers and agri-cooperatives believe that food waste is an important issue and many of them are actively engaged in initiatives to reduce it as much as possible. Considering that the misinterpretation of date marking by consumers could be responsible for up to 10% of EU food waste, exploring possible options to improve the current system is essential. When exploring those options, it is also essential to note that date marking is a complex issue that goes beyond food waste, as it is of course linked to food safety but also to food quality and the provision of accurate information to consumers. In light of these elements, Copa and Cogeca need time to assess the options proposed in the roadmap and cannot yet express an opinion in favour of specific one. Nevertheless, we are actively analysing and discussing the issue with the aim to find the best solution possible for food waste, food safety and food quality combined.
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Meeting with Janusz Wojciechowski (Commissioner) and

3 Feb 2021 · New EU Forest Strategy.

Response to Feed additives - revision of EU rules

25 Jan 2021

Copa and Cogeca generally welcome the policy proposals and would like to comment on the following aspects: - We welcome the streamlining of the process to create new categories/functional groups that can reflect the new benefits of feed additives and provide suitable efficacy criteria. - If the definition of feed additives is reviewed, it should not be to the detriment of feed materials. All current feed materials (including micro-feed materials) should remain feed materials. - EU feed additives end users are completely dependent on imports for some specific feed additives not produced in the EU. Therefore, we would like to encourage the Commission to consider this issue and possible solutions. - We support the simplification of the authorisation procedure and the following policy proposals: Improve extrapolation from food to feed;Improve extrapolation from major to minor species;Obligation to share data to prevent the duplication of tests on vertebrates. Nevertheless, while the efficacy requirements can be simplified, efficacy still needs to be demonstrated. - Copa and Cogeca also believe that the authorisation procedure needs to be more predictable. Clearer information beforehand regarding the requirements and data needed for approval by EFSA would help. - Non-holder specific authorisations (generic): Copa and Cogeca welcome the roadmap’s proposal to offer a 3 to 5 years exclusivity right to the company proceeding with the authorisation before the authorisation becomes generic. We also approve the proposal to promote a system to split costs between the possible authorization users, but the end users, feed manufacturers and farmers, should not have to bear the aforementioned costs. We also welcome the proposal to grant a 3 to 5 years exclusivity right to the consortium of organisations that bore the costs of authorisation before the authorisation became generic. Furthermore, a mechanism should be put in place by the Commission to alert when feed additives authorizations are coming to their end and that no authorization renewal has been launched by feed additives manufacturers. - Authorisation renewal: Copa and Cogeca welcome the roadmap proposal to extend the duration of the authorisation period based on the risk profile of feed additives considering that a minimum 10 years authorization period remains for all feed additives regardless of their risk profile. However, we do not believe that the duration of this authorisation should be based on the sustainability effects of the feed additives. Indeed, all feed additives, including those that do not have sustainability effects, are important to livestock farming and should thus be treated equally. Another solution to the issue of authorisation renewal could be to only require an authorisation renewal when it is justified by safety and/or efficacy concerns, with a minimum 10 years authorisation period for all feed additives regardless of their risk profile. - We welcome the roadmap proposal to only keep the essential information on the physical label while ensuring that the rest of the labelling information is easily accessible via other means (i.e. electronic) as long as the information is clear and transparent for farmers and feed manufacturers. - We need consistency between the labelling of feed additives and premixes and the labelling of compound feed. The information provided with the feed additives and the premix should give all the information needed for a fair labelling of compound feed (including information on additive carriers). - Feed additive and premixture claims need a legal basis (the same as that of compound feed, Art. 11 of Regulation (EC) 767/2009). - A code of conduct on good labelling practices for feed additives and premixtures could be developed and should be in line with the FEFAC/Copa-Cogeca code on the labelling of compound feed. - Claims should remain possible for compound feed (not linked to the presence of feed additives).
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Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis) and European agri-cooperatives and

20 Jan 2021 · WTO aircraft dispute

Response to Contingency plan for ensuring food supply and food security

13 Jan 2021

For the sake of the Union’s integrity, it is fundamental to follow a common and coordinated approach at EU level. This approach must be based on the principles of a good functioning single market, solidarity, understanding and flexibility, all of which will lead us towards the Union’s economic recovery. Despite the COVID-19 pandemic, EU farmers and agri-cooperatives have been able to maintain a steady supply of safe, high-quality and nutritious food for citizens across the EU, thus ensuring food security. This required hard work and sacrifices throughout the food supply chain. The success of the Common Agricultural Policy and the resilience shown by the agri-food chain must be recognised and better reflected in EU policies, including the Farm to Fork Strategy (F2F) and the European Green Deal in general. Any policies that unilaterally weaken the competitiveness of European food systems and agriculture have to be avoided or offset by other policies (e.g. carbon border adjustment mechanisms or other appropriate mechanisms). As recognised by the Commission, “while the EU’s food supply chain was overall resilient, some specific sectors, products, and groups of workers suffered from higher levels of pressure from the crisis. Sectors came under pressure due to staff shortages, be it due to confinement measures, lack of access to cross-border or seasonal workers, restrictions on workplace conditions, or COVID-19 outbreaks (in particular in some processing plants), as well as challenges in production storage (e.g. aquaculture). Pressure also came from the almost overnight disappearance of large sections of key demand sources for these sectors or products, in particular from restaurants, hotels, and catering, as well as to mobility restrictions and to new sanitary requirements.” We acknowledge that previous measures taken by the Commission and Member States (e.g. green lanes, guidelines for seasonal workers, market measures) and the preparations made by the agri-food chain helped with regard to the functioning of the single market. Despite some initial bottlenecks during the early stages of the crisis, the relationship between the partners in the food chain has been strong and there has been good cooperation with Member State authorities and the Commission. While we welcomed the Commission’s initial market management package, more should have been and must be done. The current exceptional circumstances call for additional exceptional measures. An adequate level of support must be granted and must come from outside the CAP budget. While the market management measures taken were welcomed, they were not sufficient to support all the affected sectors. The Union’s medium to long-term response to the pandemic must be based on solid and robust solutions that take into consideration sustainability, climate change and improved biodiversity protection. It must also continue to strive to improve the Union’s single market and the functioning of the food supply chain. This is also true and fundamental for farmers, forest owners and their cooperatives as they continue to deliver agri-food products and fibre to EU consumers, while ensuring food security. In this context, it is crucial to provide the conditions for European farmers and agricooperatives to continue their activities. To this end, all measures that can safeguard and guarantee the functioning of the markets and agricultural activity need to be introduced. These fundamental principles must remain operational during normal times in order to maintain an efficient and resilient European food supply chain during crises. Copa and Cogeca welcome the fact that the Farm to Fork Strategy provides for the development of a contingency plan by the Commission. This is to be activated when there is a crisis that affects the entire or part of the EU food system and that puts food security in the EU in danger. You will find attached our feedback on the roadmap regarding the contingency plan.
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

Farmers, forest owners and their cooperatives need to count on a strong support to continue to invest in more sustainable production methods and adaptation measures and smarter technologies. Guaranteeing access to finance is key, including access to finance earmarked for the recovery from the COVID-19 pandemic. In this process, it is key to take stock of and recognise the existing legislation and the work done by farmers, forest owners and their cooperatives to improve sustainability in agriculture and forestry. This delegated act (DA) takes a strong stance on and a disproportionate approach to the agricultural and forestry sector, which is certainly not the main beneficiary of the financial products that Regulation 2020/852 focuses on. We clearly see that the Commission is using a DA, the role of which is to supplement certain non-essential elements of a legislative act, to regulate issues of high importance and to determine whether or not an economic activity is sustainable or significantly harms the environment. From a procedural perspective, the four-week period for consultation on a draft delegated act that is highly complex and detailed and that is not available in all EU languages is unacceptable. The proposal on the technical screening criteria is counterproductive and poses a challenge for Member States and the agricultural and forestry sector from a usability point of view. It also represents an unprecedented attempt to propose conflicting legislation and to enforce criteria that set a new policy in parallel with the Common Agricultural Policy (CAP), other sectoral regulations and national legislation. In fact, Regulation 2020/852 states that when establishing and updating the technical screening criteria, the Commission should take into account “relevant Union law”. The technical screening criteria must be in line and compatible with existing measures in the CAP, REDII and the Forest Europe criteria on Sustainable Forest Management, which are part of national legislation and voluntary forest certification schemes. In addition, they need to take into account the EU Bioeconomy Strategy and the bioeconomy sectors’ important role in fighting climate change and replacing fossil-based materials. Any additional provisions that are stricter than those already in place under the CAP, that involve unfeasible criteria and that request the use of data that is unavailable as well as the proposed farm sustainability plans and annual reporting and targets, are simply unacceptable. The existing reporting system for the CAP must be used. With regards to the bioenergy economic activities, the technical criteria are impractical, unworkable and, above all, require a disproportionate amount of effort. Large parts of the EU bioeconomy risk being deemed unsustainable for taxonomy purposes, even though their primary purpose is to produce, process and add value to renewable resources as feedstock to make innovative, value-added products and materials. The DA refers to the uses of agricultural raw materials for industrial and energy applications, such as plastics, biofuels for transport, biowaste and organic chemicals. We cannot accept that a key criterion is that “Food or feed crops are not used as bio-based feedstock for the manufacture” of these bio-based products and ingredients. In addition to these comments, we underline that as an indirect effect, there is an obvious risk of carbon leakage to third countries in the short and mid-term if investments are hindered by the defined criteria. For all these reasons, we call on the Commission to reconsider the technical criteria included in this DA. We finally reiterate the primary and nurturing role of agriculture and forestry in the transition towards a more sustainable economy. While ensuring food and bio-mass security, farmers and their cooperatives carry out effective adaptation and mitigation actions and ensure vitality of rural areas. Please find in attachment a detailed analysis.
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

Farmers, forest owners and their cooperatives need to count on a strong support to continue to invest in more sustainable production methods and adaptation measures and smarter technologies. Guaranteeing access to finance is key, including access to finance earmarked for the recovery from the COVID-19 pandemic. In this process, it is key to take stock of and recognise the existing legislation and the work done by farmers, forest owners and their cooperatives to improve sustainability in agriculture and forestry. This delegated act (DA) takes a strong stance on and a disproportionate approach to the agricultural and forestry sector, which is certainly not the main beneficiary of the financial products that Regulation 2020/852 focuses on. We clearly see that the Commission is using a DA, the role of which is to supplement certain non-essential elements of a legislative act, to regulate issues of high importance and to determine whether or not an economic activity is sustainable or significantly harms the environment. From a procedural perspective, the four-week period for consultation on a draft delegated act that is highly complex and detailed and that is not available in all EU languages is unacceptable. The proposal on the technical screening criteria is counterproductive and poses a challenge for Member States and the agricultural and forestry sector from a usability point of view. It also represents an unprecedented attempt to propose conflicting legislation and to enforce criteria that set a new policy in parallel with the Common Agricultural Policy (CAP), other sectoral regulations and national legislation. In fact, Regulation 2020/852 states that when establishing and updating the technical screening criteria, the Commission should take into account “relevant Union law”. The technical screening criteria must be in line and compatible with existing measures in the CAP, REDII and the Forest Europe criteria on Sustainable Forest Management, which are part of national legislation and voluntary forest certification schemes. In addition, they need to take into account the EU Bioeconomy Strategy and the bioeconomy sectors’ important role in fighting climate change and replacing fossil-based materials. Any additional provisions that are stricter than those already in place under the CAP, that involve unfeasible criteria and that request the use of data that is unavailable as well as the proposed farm sustainability plans and annual reporting and targets, are simply unacceptable. The existing reporting system for the CAP must be used. With regards to the bioenergy economic activities, the technical criteria are impractical, unworkable and, above all, require a disproportionate amount of effort. Large parts of the EU bioeconomy risk being deemed unsustainable for taxonomy purposes, even though their primary purpose is to produce, process and add value to renewable resources as feedstock to make innovative, value-added products and materials. The DA refers to the uses of agricultural raw materials for industrial and energy applications, such as plastics, biofuels for transport, biowaste and organic chemicals. We cannot accept that a key criterion is that “Food or feed crops are not used as bio-based feedstock for the manufacture” of these bio-based products and ingredients. In addition to these comments, we underline that as an indirect effect, there is an obvious risk of carbon leakage to third countries in the short and mid-term if investments are hindered by the defined criteria. For all these reasons, we call on the Commission to reconsider the technical criteria included in this DA. We finally reiterate the primary and nurturing role of agriculture and forestry in the transition towards a more sustainable economy. While ensuring food and bio-mass security, farmers and their cooperatives carry out effective adaptation and mitigation actions and ensure vitality of rural areas. Please find in attachment a detailed analysis.
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and European agri-cooperatives

16 Dec 2020 · Copa and Cogeca joint Praesidia meeting

Meeting with Mairead McGuinness (Commissioner) and

15 Dec 2020 · Financial sustainability

Response to New EU Soil Strategy - healthy soil for a healthy life

10 Dec 2020

COPA AND COGECA’S FEEDBACK ON THE ROADMAP “New Soil Strategy - healthy soil for a healthy life” Copa and Cogeca, organization representing European farmers and agri-cooperatives, appreciate the opportunity to comment on the roadmap on the update of the Soil Thematic Strategy. The New Soil Strategy should be the platform for information exchange, sharing of best practices and promotion of sustainable soil management at Community level which is in line with the subsidiarity and proportionality principles. In addition, the development of the Strategy must balance the social and economic as well as the environmental aspects of sustainable development and at the same time respect the right of ownership. You can find our detailed comments in the attached PDF document - EN(20)9451EN[1].
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Meeting with Janusz Wojciechowski (Commissioner) and

9 Dec 2020 · Common Agriculture Policy Reform

Response to EU Forest Strategy

4 Dec 2020

“To shape a future where all European forests are vital, productive and multifunctional. Where forests contribute effectively to sustainable development through ensuring human well-being, a healthy environment and economic development in Europe and across the globe. European farmers, forest owners and their cooperatives consider that the Oslo Ministerial Decision on European Forests 2020 should continue to be the vision for European Forests as well as for the EU Forest Strategy after 2020. The main guiding principles of the new EU forest strategy should be the same as those in the current strategy: sustainable forest management (SFM) and the multifunctional role of forests. It should further promote SFM and active forest management, whose definition, principles and detailed criteria have been agreed as part of the Forest Europe process, which is under continuous development, and are already an integral part of national legislations and voluntary certification systems. The future strategy should recognise and reward the deep commitment of forest owners and their cooperatives to guaranteeing SFM and providing so many ecosystem services. This should be accurately reflected in the strategy through concrete actions on the payments for ecosystem services, and strong and efficient communication with society on what sustainable and multifunctional forests mean in practice. Multifunctionality is much more than carbon storage and biodiverse forests. For example, in many Member States, they have to fulfil a protective role for society. It is essential that the strategy promotes increased investments in more practice-oriented research and innovation, including in technologies and digitalisation, and in knowledge transfer, training and advisory services. This should be accompanied by the promotion of cooperative models and cooperation to help the sector to better adapt and respond to the multiple functions that they need to fulfil. The roadmap presents a clear picture of the current functions of forests, the forest based-sector and the challenges encountered such as climate change and land abandonment. However, we believe that it fails to provide a balanced approach when it comes to how the future EU strategy will continue to support the sector in fulfilling its multifunctional role and in tackling these challenges. The key EU Forest Strategy objectives mentioned in the roadmap – afforestation, forest preservation and restoration – do not reflect the current and future needs of the sector. The priorities, including the financial means to reach them, need to be set in a balanced way that will help the sector to contribute to important EU objectives on climate change, biodiversity, bioeconomy and viable rural areas. It is clear from the evidence used for the roadmap that all-important policies such as the EU Bioeconomy Strategy and EU climate policies were not considered. The Forest Strategy needs to ensure that there are strong synergies between all the various EU strategies and policies affecting forests. This will guarantee viable, productive and multifunctional forests for future generations. Taking a silo approach and looking at forests from one single perspective will not send the right signal to an active and future-oriented sector. With regard to consistency, it is important that before ensuring a consistent approach between EU domestic policies and international commitments, we ensure a coherent and consistent approach between the various EU domestic policies affecting forests. In their report and conclusions on the future forest strategy, the European Parliament and the European Council respectively have sent a very strong message on these aspects.
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Meeting with Valdis Dombrovskis (Executive Vice-President) and European agri-cooperatives

4 Dec 2020 · - COPA-COGECA’s contribution to the public consultation on trade policy review - how farmers can further benefit from international trade - importance of level playing field - enforcement of FTAS - Mercosur agreement - Brexit negotiations - US

Meeting with Frans Timmermans (Executive Vice-President) and European agri-cooperatives

3 Dec 2020 · CAP and Green Deal

Response to Protecting biodiversity: nature restoration targets

1 Dec 2020

COPA AND COGECA’S FEEDBACK ON THE ROADMAP - “Protecting biodiversity: nature restoration targets under EU Biodiversity strategy” (Inception impact assessment) For Copa and Cogeca, organization representing European farmers and agri-cooperatives, it is very important that any legislative initiative that arises from the objectives set in the Biodiversity Strategy for 2030 is accompanied by a thorough and convincing impact assessments, based on the latest and robust scientific data, to show that policy measures put in place are likely to be effective for biodiversity as well as facilitating viable rural areas in coherence with other policies and their objectives. This is in line with the recently agreed Council Conclusions. Therefore, we welcome the Commission’s intention to prepare inception impact assessment on the EU nature restoration targets and the opportunity to comment on this roadmap. You can find our detailed comments in the attached PDF document (EN(20)8779EN1_final).
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

Copa and Cogeca and their member organizations support the overall ambition to act on climate change and find it essential that the agricultural and forestry sector contributes to the debate on climate action. European farmers, forest owners and their cooperatives have been successful in reducing green-house gas emissions and increasing the carbon sink significantly in past three decades and in contributing substantially to circular bioeconomy by replacing fossil-based products and materials. The constant improvement shall be continued by applying solutions from a more practice-oriented research, embracing innovative technologies, and creating a policy environment which enables cross-sectorial, fair cooperation. Agriculture and forestry play their crucial role in the EU’s joint effort to achieve the goal of the Paris Agreement to limit temperature rise to 1.5°C. However, increasing the flexibility for burden-sharing between sectors (‘option 2’) would rather lead to burden shift from carbon emitting sectors to natural adsorbing sectors. We would like to stress that compliance with the 2030-target is feasible by pursuing cost-effective reductions within the ETS-sectors and that we support the focus on carbon removals as a tool for achieving carbon neutrality. Carbon removals contain a great potential for complying with the targets for 2030 and 2050 and besides the vital funds allocated under the CAP, the mobilization of private funding is essential for that. A market-based carbon farming scheme is a promising approach to enhance the carbon sequestration potential of the farming sector. Improving farming and forestry’s carbon absorption-potential through active and smart management is in the focus of farmers’ and forest owners‘ efforts but this needs to be supported by the right tools and rewarded. We believe that the scenario (option 3) to combine the agricultural sector with the LULUCF sector into a climate policy pillar could be further examined. The pressure derived from the greenhouse-gas reduction trajectory would mount disproportionally on agriculture and the forestry sector. The strategic provision of food security cannot be compromised by the updated regulation. Such merger carries the risk to fade the distinction between natural emitting and natural adsorbing sectors, therefore in that case a separate public consultation is necessary regarding the regulation of that pillar. The Commission must examine thoroughly how to establish a climate policy pillar that takes into account the competitiveness and growth options within the agricultural and forestry sectors in the member states. We welcome the fact that the impact assessment will take into consideration the economic, social and environmental impacts, also in view of the COVID-19 crisis and recovery.
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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

Copa and Cogeca welcome the revision launched by the European Commission that covers Geographical Indication (GI) systems in agricultural products and foodstuffs, wines and spirit drinks. Geographical Indications (GIs) help to preserve and boost rural communities through their tradition, history and taste. They are also an important tool when exporting high-quality products to third countries. Indeed, the current schemes showcase and foster the diverse, rich and unique nature of agricultural production in the EU. Moreover, by preserving regional landscapes, strengthening rural communities both socially and economically, they contribute to increasing EU agriculture’s sustainability. However, as is the case with any good system, some of its aspects could be improved to further enhance their positive impact. Therefore, Copa and Cogeca believe that a revision of the GI systems that would improve their accessibility and positive impact on EU rural areas while increasing consumer trust and awareness is a great initiative. Given that farmers and agri-cooperatives, as producers of GI products, are the first ones concerned by this revision, we believe that it is essential to include them and put them at the centre of the revision process. We thus welcome our inclusion in the general consultation process and hope that farmers and agri-cooperatives will also be fully involved in targeted stakeholder consultations that will take place in the context of the impact assessment. More specifically, we would like to share our views regarding each of the main objectives of this revision as presented in the roadmap. Our views regarding those objective as well as some additional comments are available in the document attached.
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Meeting with Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis), Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis) and

25 Nov 2020 · EU-US trade relations

Meeting with Agne Razmislaviciute-Palioniene (Cabinet of Commissioner Virginijus Sinkevičius) and European agri-cooperatives and

25 Nov 2020 · Exchange of views on the upcoming EU Forest Strategy

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European agri-cooperatives and

25 Nov 2020 · Exchange of views on the upcoming EU Forest Strategy

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives and

25 Nov 2020 · Meeting with forest stakeholders on the review of the Forest Strategy

Response to Model health certificates for certain categories of animals and goods

3 Nov 2020

Dear Sir or Madam. From Copa and Cogeca, we thank the opportunity given by the Commission to give feedback about this topic. Please find attached our contribution in PDF format. Kind regards.
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Response to Revision of specific rules of food of animal origin

30 Oct 2020

Copa-Cogeca generally welcomes the modifications proposed by the Commission regarding the rules laid down in Annex III to Regulation 853/2004 and believes that they will offer more flexibility on hygiene requirements for meat, while maintaining the same high level of food safety. Nevertheless, Copa-Cogeca would like to underline two points that imperatively need to be addressed regarding this revision. 1. Copa-Cogeca believes that this revision will help the small but growing group of farmers wishing to do the first part of the slaughtering of cattle in the field to avoid the transport of live animals to the slaughterhouse in order to avoid unnecessary stress for the animals and the farmers as well as the impact of this stress on the quality of the meat. The financial investment for having an on-farm slaughtering plant is too costly for most farmers and this revision would thus provide an adapted alternative. However, we would like to point out that the requirement to have a veterinarian on site every time to witness the process of stunning and bleeding is too costly and unnecessary to ensure food safety and animal welfare compliance. Copa-Cogeca believes that we should favour the following solution: • The presence of a person trained and accredited by a veterinarian who would guarantee that the stunning and bleeding is done under correct hygienic and animal welfare conditions. This is already the case for poultry and lagomorph and it has been proven to work well. 2. When assessing the hygiene requirements for meat, Copa-Cogeca believes that it is of the utmost importance to stress the need to make permanent the derogation imbedded in Regulation 185/2017 laying down transitional measures for the application of certain provisions of Regulations (EC) No 853/2004 and (EC) No 854/2004 of the European Parliament and of the Council. We believe that it is especially important to ensure the permanence for the derogation laid down in article 2 of Regulation 185/2017 that states that “By way of derogation from Article 1(3)(d) of Regulation (EC) No 853/2004, the provisions laid down in that Regulation shall not apply to the direct supply, by the producer, of small quantities of meat from poultry and lagomorphs slaughtered on the farm to the final consumer or to local retail establishments directly supplying to the final consumer.” Currently, in accordance with this derogation, a large number of small poultry and lagomorphs farms across Europe slaughter and process themselves their animals in so called “non accredited slaughter establishments” for the final consumer or to supply local retail establishments directly supplying the final consumer. Those sales represent a vital part of the income of many small producers in Germany, Austria, France, the Netherlands and Romania who do not have the financial capacity to invest in accredited slaughter establishments. If the derogation was to end on 31 December 2020 as currently stated in Regulation 185/2017, this would endanger the economic viability of those farms and the local retailers relying on them. In France alone, the number of farms concerned is around 3500. Furthermore, we would like to underline that those “non accredited slaughter establishments” follow strict hygiene rules that are perfectly adapted to ensure food safety. The absence of any major food safety outbreaks related those establishments over the past years have clearly proven that they do not represent a threat for food safety. Therefore, for the viability of those small farms and the local retailers that depend on them, we would call upon the Commission to ensure that the derogation laid down in article 2 of Regulation 185/2017 is made permanent.
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Meeting with Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski)

27 Oct 2020 · VC meeting with new President COPA

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives

12 Oct 2020 · Agriculture Data Space.

Response to Long term vision for rural areas

9 Sept 2020

Copa-Cogeca, organisation representing the European farmers and their cooperatives, very much support the development of long term strategy for rural areas, seeing them as a priority that will need to be adressed to secure the future for the next generation. Rural areas are facing a unique challenge. As the urban-rural divide widens and more citizens move to cities, the workforce, potential as well as the future of rural areas is beginning to drain away. Basic services tend to follow suit due to the lack of demand. Nevertheless, rural area still represent a crucial backbone of society and economy also in the EU as they deliver high quality food and resources as well as cultural landscape for recreational use. The urban-rural divide should also encourage policy-makers to look at both sides of the equation and focus on bridging this gap. The symbiosis between urban and rural areas should be recognized and encouraged at all levels, such as housing, energy, employment, services, tourism and should create a multidimensional interaction that benefits both parties. All of this points to the fact that rural communities deserve special attention when preparing regional and national development strategies. Stimulating and facilitating additional investment in the sector is key. This means that rural areas will also deserve special attention in EU policy-making. As rural areas primarily represent the operating space of farmers and their cooperatives, their needs and their contributions have a rightful place in any strategy. The Cork 2.0 declaration from 2016 clearly put forward the need to address the challenges that rural areas are facing and to ensure that they remain attractive places in which to live and work by improving access to services and opportunities for rural citizens and fostering entrepreneurship in traditional rural domains as well as in new sectors of the economy. Now, with the European Green Deal and more recently with the impact of the COVID-19 pandemic, it is clear that rural areas will need even more attention and support to pave the way through the recovery and towards a brighter future. The long-term vision for rural areas, as part of the European Green Deal, should set out this direction for rural areas for the years to come. On the other hand, we have to bear in mind that many differences exist between rural areas even within the EU. The ‘one size fits all’ approach could not be applied in this case either. Therefore the objectives set out in the European Green Deal should be adjusted according to the characteristics of Member States, take into account the various paces of adaptation and ensure a level playing field for everyone.To make sure that farmers and agri-food cooperatives are at the heart of this vision, some key perspectives will need to be kept in mind. There are several areas to which the long term strategy on rural areas can contribute, such as generational renewal, broadband, smart villages concept, innovation, access to basic services and mobility, participation of rural women and gender equality, environment protection, climate change adaptation and mitigation, circular economy, marginalised areas, forestry, short value chains, business diversification, cooperation, advisory services and involvement of stakeholders. Please find all the suggestions and reactions from our side listed in the attached document.
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Response to Evaluation of the Sewage Sludge Directive 86/278/EEC

25 Aug 2020

Copa and Cogeca represent 22 million farmers and their family members as well as 22,000 cooperatives that are dedicated to providing 446 million EU citizens with safe, nutritious, high-quality and affordable food every day. Farmers, forest owners and their cooperatives are committed to the Paris Agreement and to contributing to the Sustainable Development Goals. Copa and Cogeca find that the Commission initiative to validate the 2014 evaluation is highly relevant both given the technological development since then, as well as changes in the political landscape with the introduction of initiatives such as the Bioeconomy Strategy, new fertilizer regulation and Farm-to-Fork Strategy. Copa and Cogeca agree that the 18 questions in the Commission´s roadmap guiding the content of the public consultation are suitable for the purpose of the hearing. Biological by-products and other side flows from industry and households can be returned to the biosphere through agriculture activities. Therefore, farmers, and agricultural production, play a key role in developing the circular bioeconomy. Threshold limits and restrictions on use must have critical focus in a possible revision of the Sewage Sludge Directive. All levels must reflect best practice in member countries to ensure optimal health and environmental safety. It is imperative that EU regulation on threshold limits and restrictions on use is dynamic to ensure that new knowledge on health and environmental effects can be reflected in regulation immediately. It must be possible to use sludge on agricultural soils without compromising the health of humans or animals or affecting the environment negatively. Therefore, European farmers have an interest in ambitious requirements to the contents of sludge. However, ambitious requirements must be balanced with cost efficient requirements to treatment of sludge, to avoid unnecessary technical or economic barriers to sludge application in fields. The agricultural sector should emphasise sludge as a valuable resource of nutrients that should be kept in the biological life cycle. However, authorities must ensure that the content of heavy metals, pollutants, drug residues and other potentially problematic compounds is minimised. Contamination of sludge or soils must be avoided effectively.
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Response to EU Methane Strategy

5 Aug 2020

Copa and Cogeca represent 22 million farmers and their family members as well as 22,000 cooperatives that are dedicated to providing 446 million EU citizens with safe, nutritious, high-quality and affordable food every day. Farmers, forest owners and their cooperatives are committed to the Paris Agreement and to contributing to the Sustainable Development Goals. Methane emissions from agriculture cannot be completely avoided because these greenhouse gases originate from natural processes. Methane decays in ten years to carbon dioxide and water and will return through photosynthesis to biomass (feed) and soil carbon thus being part of the natural carbon cycle in agriculture. Therefore carbon dioxide removals by feed biomass should be fully accounted to balance methane emissions in greenhouse gas accounting. Due to the nature of methane as a short lived greenhouse gas it is not accumulating in nor adding additional warming potential to the atmosphere. Using an accurate model of global warming potential is essential when short lived greenhouse gases are part of the model. The global warming potential model used today (GWP100) should be reconsidered in this respect. In the EU Methane Strategy priority has to be given to reduce the methane emissions from fossil sources. EU agriculture has roughly reduced its methane emissions by 20% since 1990 and in the same time increased its productivity by 25%. Copa and Cogeca agree that methane emissions are challenging to monitor, verify and report accurately, requiring clear methodologies to capture any mitigation efforts correctly. Any monitoring of methane emissions on farms must be simple and integrated in existing monitoring systems to avoid additional costs for farmers. Methane emissions in agriculture can be divided in two categories manure and enteric fermentation. Enteric fermentation can be reduced through diet, breeding and herd health, productivity, management, longevity and welfare. All these measures need a proper policy framework for new technologies and investments. Research and innovation in e.g. new breeding techniques and feed additives must be secured to keep EU agricultural production competitive and to avoid carbon leakage to third countries and higher climate impact on global level. National and EU legislation must ensure access to new technologies for the farming sector. Manure management and the use of manure as source of biogas has a significant methane reduction potential. When manure is used for biogas the emission reduction is above 100% in current greenhouse gas accounting rules compensating thus for other greenhouse gas emissions that are replaced by biogas. The energy density of manure is lower than in other organic biomass or waste. Given the low energetic value of manure and the high methane reduction potential of its use in biogas plants adequate incentives are urgently needed to support the wider uptake of this win-win technology. Cooperatives may play a key role in generating added value when raw biogas is valorised to compressed or liquefied biogas. A proper policy framework is necessary to boost innovation and research in new and scalable technology. EU waste legislation should encourage the use of manure and other agricultural residues as source of new products such as fertilisers, bedding material and bioenergy. The use of biogas digestate as fertiliser is increasing soil organic matter and thus improves the climate resilience of soils. A bio-based circular economy thus supports soil carbon sequestration and the reduction of methane and nitrous oxide emissions on farms. New business opportunities and increased income will serve not only farmers but also the whole rural community contributing to all three pillars of sustainable development (environmental, economic and social). This is an important part of the transition to a more sustainable agriculture and rural areas. It is possible only when right measures and funding will be available.
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Response to Sustainable use of pesticides – revision of the EU rules

30 Jul 2020

CORRIGENDUM OF PREVIOUS SUBMISSION. From Copa and Cogeca, representing farmers and agri-cooperatives in the EU, we welcome the opportunity to contribute to this consultation. You may find ourfeedback attached to this message. Many thanks.
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Copa and Cogeca urge harmonized rules and economic impact assessments

28 Jul 2020
Topic — The Commission is evaluating if current EU animal welfare rules are effective.
Message — The group requests a single, comprehensive EU Animal Welfare Framework Law to ensure uniform application. They emphasize that new rules must be science-based and include socio-economic impact assessments.12
Why — Harmonization would prevent market distortions and lower compliance costs for European producers.34
Impact — Non-EU producers would face restricted market access if they fail to meet standards.5
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Meeting with Ines Prainsack (Cabinet of Commissioner Stella Kyriakides), Karolina Herbout-Borczak (Cabinet of Commissioner Stella Kyriakides) and European agri-cooperatives

15 Jul 2020 · VC meeting: Exchange of views on honey in the context of EU actions on food fraud and food labelling under Farm to Fork.

Response to Update of measures to control Xylella fastidiosa

7 Jul 2020

Please find in the document here attached Copa & Cogeca's feedback on measures to control the bacterial pest Xylella fastidiosa (update).
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Response to EU Strategy on Adaptation to Climate Change

30 Jun 2020

Copa and Cogeca represent 22 million farmers and their family members as well as 22,000 cooperatives that are dedicated to providing 446 million EU citizens with safe, nutritious, high-quality and affordable food every day. Climate change is affecting every farmer across the globe. It is affecting our lives, communities and countries today, and will do so even more in the future. Weather events are becoming increasingly extreme and frequent, temperatures are on the rise and global greenhouse gas emissions are higher than ever. If no action is taken, the rise in the world’s average surface temperature is likely to exceed the limit of three degrees during the course of this century. Food production will be exposed to even more extreme weather conditions. Relocation of food production could lead to land abandonment and desertification in some regions of the world and may increase the need for arable land in areas that are now covered by forests. EU agriculture and forestry have significant potential to increase adaptation and mitigation efforts, to reduce their emissions, to sequester carbon and to boost economies in a sustainable manner. The future does not lie in decreasing productivity and shifting production as well as climate impacts (carbon leakage and water scarcity) to third countries. We have to make sure that the consumption of food and non-food production (bio-based fuels, chemicals and materials) complies with all the sustainable development goals including trade policy. Adaptation to climate change involves measures to reduce the impact of excessive rainfall, extreme heatwaves, spring frost and droughts on plant growth, carbon sequestration, biomass production and livestock rearing. Preventive measures such as irrigation or drainage, frost and hail control infrastructure, water rights, soil fertility (biological, chemical, physical) management and risk management tools have to be deployed to get a vast number of farmers on board. In times of severe drought, the water retention capability of peatland soil has to be acknowledged with regard to adaptation and food security. For some sectors, such as wine and forestry, it must be possible to adjust adaptation measures to the geographical specificities of production. Plant and livestock breeding ensure that the species and varieties best suited to different conditions are made available. European farmers and agri-cooperatives need to have access to technological advancements in order to overcome a number of challenges, such as remaining competitive, adapting to and mitigating climate change, and providing an adequate supply of high-quality food. New plant breeding techniques could improve the tolerance of plant varieties to water stress and pests. Each new breeding technique should be analysed and discussed by experts on a case-by-case basis and according to strict scientific criteria. We cannot afford to lose time by refraining from using cutting-edge technologies. Similarly, in forestry high-quality seedlings and adapted tree varieties improve adaptation to climate change and forest damage. Integrated pest management (including being able to rely on the use of authorised plant protection products) is a necessary adaptation measure to ensure food security in situations where diseases and pests are spreading, emerging and jeopardising food production. This includes being able to rely on the use of plant protection products that have been deemed safe by authorities. Voluntary measures, supported by public authorities or the private sector, that promote climate action and provide economic return for farmers should be encouraged by EU legislation. Every farmer should have the possibility to access the best adaptation measures tailored to their own needs and be able to count on both a set of available options and an adequate advisory system. This is particularly relevant given that each farm has its own features and needs related to climate resilience.
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Meeting with Ines Prainsack (Cabinet of Commissioner Stella Kyriakides) and European agri-cooperatives

30 Jun 2020 · VC meeting on African Swine Fever

Meeting with Virginijus Sinkevičius (Commissioner) and

19 Jun 2020 · To exchange the views regarding the Biodiversity Strategy.

Meeting with Stella Kyriakides (Commissioner) and European agri-cooperatives

18 Jun 2020 · VC Meeting on Farm to Fork Strategy

Meeting with Janusz Wojciechowski (Commissioner) and

2 Jun 2020 · the new MFF; the Recovery Plan; Farm to fork; the Biodiversity strategy

Meeting with Frans Timmermans (Executive Vice-President) and European agri-cooperatives

28 May 2020 · Farm to Fork Strategy

Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives

27 May 2020 · To present priority measures for the European honey sector.

Response to Organic food - use of in-conversion and non organic plant reproductive material

12 May 2020

We would like to highlight some of our comments and concerns regarding a few items in the draft delegated act on the use of in-conversion and non-organic plant reproductive material. We welcome the latest amendment of Annex II, Part I, item 1.8.5.3, which provides for the propagation of non-organic plant reproductive material for organic fruit and organic viticulture in a conventional way. This is very important, because there is not enough organic tree reproductive material available in any EU Member State. However, the proposed amendment does not take into consideration the specific requirements for the use of non-organic plant reproductive material in organic wine production. In fact, there is a common practice in central and western-central Europe, and probably in most other Member States, which consists of taking young grape vines out of the ground in autumn and then keeping them in cold storage for several months before planting them in early spring. In this cold storage, they are protected against fungal plant diseases with a fungicide. If this practice is not allowed anymore, it will create a severe shortage of suitable plant reproductive material for organic wine producers. We need a solution for this specific case, such as a transition period to solve the technical problems regarding the cold storage. European research projects are crucial for the development of these alternative techniques. In addition, we do not support the new sentence in the delegated act under item 1.8.5.3, which stipulates a new conversion period for the organic farmer when chemical treatment has been officially prescribed. This does not take into account the additional costs incurred by the farmer for the reconversion of the plot in question. A solution to compensate the organic farmer must be found for this case.
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Response to Climate Law

1 May 2020

Copa and Cogeca represent 22 million farmers and their family members as well as 22000 cooperatives that are dedicated to providing 446 million EU citizens with safe, nutritious, high-quality and affordable food every day. Farmers, forest owners and their cooperatives are committed to the Paris Agreement and to contributing to the Sustainable Development Goals. The proposed climate law should spell out the green sectors’ vital and unique roles in both mitigation and adaptation. Article 1 Any narrowing of the scope beyond the Paris Agreement should be carefully assessed. The EU’s climate objective must not lead to a relocation of production and emissions to third countries. This would increase emissions worldwide and thus thwart climate mitigation efforts. Carbon leakage, the loss of a level playing field for agriculture and forestry and the weakening of secure and stable food supply in the EU are risks that have to be taken into account when setting climate action ambitions. Climate mitigation is an international objective that has to be coordinated worldwide. Article 2 Increasing the EU’s climate target for 2030 is viewed sceptically given the short time frame and the current legislative framework (ESR, RED II, LULUCF Regulation) which was only adopted two years ago. In our opinion, it should be stipulated that only the European Union can be held responsible for failing to achieve the climate objectives and for taking sufficient measures to achieve them. If the European Union cannot be named as responsible, Member States have to be held responsible for failing to achieve the climate objectives and for taking sufficient measures to achieve them. Under no circumstances is it acceptable that individual farmers or companies are held responsible. As stated in Article 3 of this proposal, the best available and most recent scientific evidence has to be taken into account when defining the trajectory. It should also be acknowledged that accounting methods are key to assuming joint responsibility for achieving climate neutrality within and across sectors and countries. LULUCF accounting should be used first and foremost to compensate emissions within its sector of origin and only after this be extended to other LULUCF or non-LULUCF sectors. Article 3 Food production must be recognised in the trajectory of Article 3.3 of the regulation so as to reflect Article 2.1.b of the Paris Agreement, which states, “Increasing the ability to adapt to the adverse impacts of climate change and foster climate resilience and low greenhouse gas emissions development, in a manner that does not threaten food production”. The important role of food security has to be explicitly included in this article and not just in a footnote or in a recital. Article 4 Climate adaptation should be strengthened and Member States should develop and implement adaptation strategies. However, the particular vulnerability of forestry, agriculture and food systems to the adverse impacts of climate change should also be included in Article 4, and explicitly have to be included as a part of Member States’ adaptation strategies and plans. Article 5 The Commission shall conduct an impact assessment on how different sectors contribute to the trajectory and how they are affected. This would ensure an efficient stakeholder contribution to achieving climate neutrality. The Commission's assessments and reviews have to include the effects on food security, in line with the stipulations in the Paris Agreement. Article 8 We highlight the importance of including relevant stakeholders when it comes to shaping climate policy in agricultural, forestry and rural areas. An effective implementation of policy measures is only possible when all stakeholders’ voices are heard. Article 9 Given the importance of the trajectory defined in Article 3 of the regulation, it is not acceptable to give the Commission the power to adopt delegated acts and to prevent the European Parliament from intervening.
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

Copa and Cogeca represent 22 million farmers and their family members as well as 22,000 cooperatives that are dedicated to providing 446 million EU citizens with safe, nutritious, high-quality and affordable food every day. Farmers, forest owners and their cooperatives are the first to feel the impact of climate change. We are committed to the Paris Agreement and contributing to the Sustainable Development Goals. A farm sustainability management tool is being proposed for the agricultural sector. This tool can only be useful if it is part of CAP measures and CAP reporting with a clear monitoring, reporting and verification workload at farm level to demonstrate compliance with a sustainable agriculture. Copa and Cogeca insist on emphasising that the cost of complying with the taxonomy must be lower than the benefit a farmer or cooperative gains from the financing. In any case a substantial contribution to an even more sustainable agriculture will only be achieved if there is a clear economic incentive for farmers and cooperatives. This incentive must be market driven and respect the basic characteristics of agriculture (nature and biological processes) that cannot be completely controlled and will therefore always produce emissions. The technical screening criteria has to be in line and substitutable with existing sustainability measures in the CAP, REDII and SFM. Sustainability is already defined in sectorial regulation and must not be redefined for sustainable investment purposes. In this context, regarding CAP requirements as ‘DNSH compliant’ but not ‘substantially contributing’ is unacceptable. It implies that none of the existing greening measures and ecosystem services within the CAP are substantially contributing to climate change mitigation and adaptation. In the taxonomy report, the TEG Sustainable Finance mentions the principles put forward in the EU Forestry Strategy, which advance both the benefits of sustainable forest management and the multifunctional role of forests. The screening criteria have to take into account sustainable forest management practices and must not undermine the role forests play in the bioeconomy. In this respect, the scope of the taxonomy has to be enlarged to include “enabling” activities involving long-lived and harvested wood products. The taxonomy at this point does not go far enough, because it focuses only on “greening of” activities, to protect and enhance forest carbon stocks and sinks. Sustainable finance in forestry must not restrict itself to conservation practices. The administrative and economic burden of a proper audit every three years is disproportionate compared to the benefit a farmer gets. This is why the existing reporting approach must be used. The same challenge affects forestry, where there is no reason why this kind of reporting is necessary nearly ten times in one rotation period. New techniques are constantly being developed, and it is vital to be able to adapt the list and add new techniques/initiatives. Which initiatives are the optimal choice depends on geographical and climatic conditions, cultivation practice, etc. It is therefore essential that all initiatives on agricultural land are voluntary and based on choice to ensure that the individual farmers can decide what is best for their land and their business. Thus, good management practice should be ensured through highly qualified consultancy services and intelligent legislation providing flexibility for the farmer rather than rigid schedules and controls. Farmers that have already reduced emissions from production will find it harder to reduce them further than farmers who have not yet taken any steps to reduce emissions. It is therefore necessary to develop a system that assesses GHG emissions with the aim of achieving a common climate efficiency goal and not simply comparing them to emissions from a specific year in the past.
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Meeting with Janusz Wojciechowski (Commissioner) and

22 Apr 2020 · Covid19 and its consequences to the EU agriculture sector

Response to EU rules on industrial emissions - revision

21 Apr 2020

The EU Directive 2010/75 EU pursues the goal of enforcing the same level of environmental protection at a similar technological level throughout Europe. In accordance with this Directive, the EU Commission adopted Commission Implementing Decision (EU) 2017/302 of 15 February 2017 establishing BAT conclusions of the BREF documents as binding guidelines for livestock installations in the field of pig and poultry farming. These apply to farms with more than 40 000 places for poultry, more than 2 000 places for fattening pigs and more than 750 places for sows. Measures to reduce emission levels must therefore be taken in feeding, emissions reduction in the barn, manure storage and monitoring requirements according to BAT. Member States have four years (until 2021) to review and, if necessary, update permits. The implementation of a key piece of the IED framework is therefore not complete at this stage. We thus believe it is premature to carry out an evaluation of its impacts and we consider the plans to revise the Directive as unfounded. This is especially relevant considering the possibility of revision or tightening of the BAT conclusions, which were adopted through a lengthy, complicated and broad process and will be implemented through considerable investments by the agricultural sector. BREF implementation varies greatly between the different Member States, and the uniformity of the implementation needs to be given much more attention. BREFs are useful tools that contribute to improving the environmental performance of activities. The current system enables the evaluation of existing techniques and can be used to provide updated information on emerging techniques, but also to establish a dialogue between national and European bodies. However, the BREF shows some limitations and there are areas where the framework should be revised: some technical specificities or farming systems, regardless of their impact on the environment, are hardly or insufficiently considered and there are some difficulties regarding recognition of techniques as equivalent to BATs. These constraints may lead farms to abandoning some techniques or may prevent the implementation of environmentally friendly innovations. It also seems necessary to deepen the impact assessment on the economic and social aspects upstream of technical decisions. We see a need for uniform specifications across Europe for the requirements regarding emission reductions in animal husbandry and enhanced consistency of implementation across member states. Emissions from livestock are already covered by other legislative frameworks and good agricultural practices, such as methane in climate policy (Effort Sharing Regulation) and ammonia (from all livestock keeping, including pigs and poultry) in the NEC-directive. In order to avoid double regulation and red tape and to be able to provide efficient, effective and widely accepted EU legislation, the sectors included under the IED should be kept to an absolute minimum. We believe that it is not desirable to extend the current scope of this Directive to cattle or to smaller farm entities, however we deem it important to continue the work of improving practices through advice to farmers and voluntary measures that are adapted to farming systems. The integration of the decarbonisation of industry into the scope of IED must be approached very carefully. Without proper carbon accounting methodologies in agriculture which include soil carbon sequestration, justifying any decarbonisation for agricultural activities is not acceptable. Finally, as regards the coherence with other EU legislation, we would like to highlight a point regarding the E-PRTR component regarding data confidentiality. Today, in accordance with the regulation, most of the eligible data must be available to the public on the dedicated platform. The confidentiality declarations used by Member States must be harmonised across Member States.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

20 Apr 2020

The quote states that food and feed crops have a limited potential for decarbonisation, notably due to their indirect impacts on land use changes. Copa and Cogeca do not consider this statement by the Commission to be correct, since the EU has the strictest monitoring rules[2] in the world to ensure that the raw materials in question are sustainable and no change in land use occurs. As stated, the results of the Inception Impact Assessment demonstrated that waste-derived SAF can achieve emissions savings as high as 80% compared to conventional jet fuels. However, it is absolutely possible to produce jet fuels on the basis of food and feed crops with emissions saving of 80 %, provided renewable energy is used in the production processes. It is therefore completely unacceptable to make the injudicious decision to declare those raw materials “not desirable”. Moving the aviation sector in a more sustainable direction is a major undertaking. In light of this, Copa and Cogeca urge the Commission in the forthcoming process to focus more on synergies rather than picking specific winners. While electrofuels will undoubtedly be important in the future, they are dependent on carbon molecules which, in a decarbonised future, must come from biogenic sources. Therefore, the roadmap should focus on intelligent ways to integrate and harness the full potential of residues from agriculture, forestry and aquaculture and on how they can be upgraded and multiplied through innovative conversion pathways, including the use of renewable energy. Nordic GTL, among other research, represents an important contribution to this intelligent and integrated system approach[3]. Considering the time it takes to produce SAF, both waste-derived and crop-based sustainable aviation fuels are needed to lower GHG emissions in the aviation sector in the short term. Even though the roadmap mentions that “the aviation sector lacks immediate alternatives for commercial aircraft propulsion”, green solutions are already available on the market as drop-in fuels which are compatible with current aircraft engine technology. Drop-in fuels can be made from agricultural feedstock. EU fuel producers and biorefineries should be able to utilise all the feedstock mentioned in Annex V of the RED II Directive to produce drop-in aviation fuels; crop-based EU biofuels are part of the solution for decarbonising aviation, in particular, bioethanol (environmental performance). Drop-in fuels using sugar beet and other feedstock are already available in other countries such as the USA and Brazil (i.e. the Alcohol to jet process (ATJ) and/or the Synthesized iso-paraffins (SIP) hydroprocessing). It should be possible to utilise and to explore the potential of these processes as well as to develop new ones. Therefore, Copa and Cogeca support a blending mandate for Sustainable Aviation Fuels (SAF). The blending obligation should have to be met by every aeroplane leaving a European airport, no matter if the flight is an intercontinental or a continental flight. Additionally, Copa and Cogeca request that the fleet of cars and lorries operated at airports or by airlines be obligated to be fuelled with sustainable certified biofuels like B100 or pure VegOil for lorries as well as with bioethanol blends (E10; E20 and E85) and other crop-based biofuels in line with the RED II Directive targets. Copa and Cogeca strongly oppose the multiplier for the renewable energy content for biofuels[4] used in aviation. This multiplier amounts to nothing more than an arithmetic charade that does not decrease greenhouse gas emissions from aviation by one single tonne. Copa and Cogeca call for SAF to be compliant with the sustainability criteria set out in Article 29 2) to 7) of Directive (EU) No 2018/2001. Finally, Copa and Cogeca are strongly in favour of a coordination platform and an effective monitoring mechanism.
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Meeting with Thierry Breton (Commissioner) and

16 Apr 2020 · COVID crisis: exit and recovery of the agro-food ecosystem

Response to 2030 Climate Target Plan

15 Apr 2020

Copa and Cogeca represent 22 million farmers and their family members as well as 22,000 cooperatives that are dedicated to providing 446 million EU citizens with safe, nutritious, high-quality and affordable food every day. Copa and Cogeca welcome the European Climate Law proposal, which delivers a legal framework to achieve climate neutrality by 2050 in line with the Paris Agreement objectives. Farmers, forest owners and their cooperatives are committed to the Paris Agreement and to contributing to the Sustainable Development Goals. Article 3 of the proposed climate law broadly ignores the international position on climate action when it comes to food production. The Paris Agreement clearly states in article 2.1.b that climate targets must be achieved ‘in a manner that does not threaten food production’. This paramount issue should be addressed in the proposed climate law, given that food security remains a real geo-political risk, with the world currently having just over three months’ stocks of cereals. The special and strategic role of agriculture should be highlighted even more in the Climate Law by including the entire article 2.1b. “Increasing the ability to adapt to the advance impacts of climate change and foster climate resilience and low greenhouse gas emissions development, in a manner that does not threaten food production.’ The EU’s proposed climate law seeks to deliver climate-neutrality by 2050. There are significant issues regarding how this ‘climate neutrality’ will be determined. At present, the way methane is accounted for does not reflect the up to date science and farmers are not getting credit for the carbon sequestrated in soil and biomass. It is essential that these issues are addressed, to ensure that all emissions emitted and sequestered by the sector are to be correctly and fully accounted when defining carbon neutrality. The EU’s Green Deal as the strategic framework, and Farm to Fork Strategy and proposed Climate Law as implementing tools seek to address all the climate and environmental emergency in Europe declared by the European Parliament. However, addressing this emergency is lacking the necessary resources in the current MFF and CAP budget discussions. The current proposal of the European Commission to seek to drive increased climate ambition while at the same time proposing to cut the CAP budget by 14% is a complete contradiction. Farmers cannot be expected to do more with less. Further research and innovation should be supported to find technical solutions as much as possible to reduces greenhouse gas emissions in agriculture. A significant part of agricultural emissions are due to natural processes. Understanding these processes is crucial to mitigate emissions. The impact assessment should investigate possibilities for enhanced GHG sinks in agricultural soils and forest, including the necessary legislative framework and investments for Bioenergy with Carbon Capture and Storage, and in which the role of sinks can contribute to increase the 2030’s climate ambition. The special role of agriculture in climate action, as laid out in the Paris Agreement, has to be recognised in carbon crediting schemes. It is of crucial importance that farmers, forest owners and their cooperatives have an economic incentive to contribute to climate action. The opportunity to create additional income for farmers through carbon farming measures and privately funded carbon crediting schemes, might have the possibility to sustainably increase farm productivity in line with climate and soil biodiversity goals. It has to be noted that agriculture and forestry can majorly help to substitute fossil fuels through the use of by-products. The RED II Directive is lacking in ambition in terms of promoting access to the organic carbon market for biomass originating in European agriculture and forestry. It therefore undermines the achievement of the EU’s climate, energy, bioeconomy and circular economy objectives.
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Response to Statistics on Agricultural Input and Output

10 Apr 2020

Statistics, data collection and processing and information plays an important role when reporting back and evaluating the impact of policies and measures implemented in the agricultural sector, most importantly the CAP post 2020. Even as the discussion is still on-going on the CAP post 2020, it is clear that the new delivery model and more result oriented policy will bring about an increased need of reliable and readily available data on the progress, implementation and results. New emerging policies yet to be unveiled by the European Commission, such as the European Green Deal, and, in particular, the Farm to Fork and the Biodiversity strategies, will also require additional reporting and evaluating. As already stressed, we cannot put forward new policies impacting widely on the sector without having a proper impact assessment. In turn, we cannot have a proper impact assessment if we do not have the data available to evaluate it. This is especially relevant when it comes to the assessment of inputs to agricultural production, such as fertilizers and PPPs, as there are currently calls to limit them. Yet the data collection, especially on the PPPs, would need to be harmonised across Member States not only in terms of methodology but also in terms of the time frame period to reveal the real usage data of inputs. Relevantly for these policies, we would also need to know what is the current state of play before we would want to impose any kind of target, as that would seem premature. In terms of addressing these new needs, we would support the move to streamline and adapt the current legislative system and propose two new regulations that would replace it. This should also prevent the fact that some data are collected based only on gentleman’s agreement, and not on any legislative basis. The streamlined legislation should provide for a harmonised collection of data, coherent definitions across Member States and also opening the possibility to use other data than just surveys. In the time of continuous modernisation, there should be a possibility to unveil online surveys and use satellite data for those data that are collected as part of official statistic requirements. This would of course assume that there is internet connection available for those are responding, and as broadband only covers 50% of rural areas, this might be a particular issue. The burden of collecting data should also be addressed, as in this case it falls mostly on the farmers. We recognize the need for broad, reliable and up-to-date data, yet also recognise that this does not come automatically and some burden is indeed connected to this. All approaches must recognize the right of the originator to benefit from and be compensated for the use of data produced on the farm or during farming operations. The code of conduct also recognizes that the right on data produced on the farm or during farming operations is attributed to the farmer and may be used extensively by him/her; Data originator has a leading role in controlling the access to and use of data from their business and to benefit from sharing the data with any partner that wishes to use their data. The right of all parties to protect sensitive information via restrictions on further use or processing must be ensured. We would also favour the more optimised approach of using more modernised methods and also using the approach of “collect once, use many times”. Much of the burden also relies on the method being used, and in this sense we would also assume that introducing new thresholds for data collection would be a step in good direction. It is also necessary to improve synergies and efficiency between existing data sources in order to use all possible sources for production of agricultural statistics. Last but not least, the financing dedicated to agriculture statistics needs to be preserved in order to ensure a steady flow of information on the progress on the CAP post 2020 and other policies.
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Response to Access to Justice in Environmental matters

2 Apr 2020

COPA AND COGECA FEEDBACK ON THE ROADMAP “EU environmental law – better access to justice (updated rules)” COPA and COGECA support the general principles of the Aarhus Convention for providing access to information, public participation and access to administrative or juridical procedures for decisions with major impacts on the environment. However, we consider that the Aarhus Convention Compliance Committee (ACCC) has shown an unreasonably far-reaching interpretation of the obligations laid down by the Convention. The Union’s implementation of the Aarhus Convention was never intended to rest upon the Aarhus Regulation alone. What needs to be taken into account is that the judicial redress under primary Union law, including Article 267 TFEU, already ensures that access to justice in environmental matters at EU level is sufficiently granted. Compliance with the Convention cannot lead to a conflict with the primary law of the Union, its principles and adherence to the Treaties. Therefore, we believe that there is no need to amend the existing Regulation. Instead, the Commission should look jointly with Member States into non-legislative actions to address any potential obstacles to access to justice at EU level. A targeted revision of the Aarhus Regulation with amendments, including possible time extensions for the procedural steps, risks imposing unforeseeable delays, legal uncertainties, lack of protection of investments and large costs for individuals and SMEs.This has been confirmed by an external study, which indicates that, besides the challenging implementation, this approach would have a “moderate to very negative broader impact” on businesses and industry stakeholders. We therefore call for a more balanced and objective non-legislative approach, which strikes a balance between different interests so that a reasonable level of access to justice at EU level is guaranteed in the situations where it is of true importance. It is also important to highlight that the ACCC has not criticised the implementation of the Aarhus Convention at Member State level. Moreover, the Commission’s report clearly stated that access to justice in the Member States has been improving, in particular in response to CJEU case-law. Therefore, any kind of communication on access to justice in environmental matters in the Member States’ national courts should be reconsidered. We hope that our feedback will be taken into account in the further development and fine-tuning of this initiative.
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Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives

30 Mar 2020 · To exchange views on the consequences of African Swine Fever in the European market, and the possible measures and solutions to avoid any major disruption.

Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives

30 Mar 2020 · Pour présenter les différentes actions nécessaires pour améliorer la situation de marché alarmante du miel dans l’UE.

Response to Farm to Fork Strategy

16 Mar 2020

The Commission’s Communication on the European Green Deal approach has several axis that are very much linked to the agricultural sector. This approach is an opportunity but is also a challenge and raises various concerns. These aspects must be carefully analysed and considered. European farmers are key to managing the transition. The Farm to Fork Strategy will strengthen their efforts to tackle climate change, protect the environment and preserve biodiversity. It is fundamental that the policy formulation and implementation supports farmers and their cooperatives’ economic sustainability, improves the functioning of the markets while contributing to a more economically, environmentally and socially sustainable agri-food sector. It must be recognised that there are numerous production methods which bring additional benefits from a sustainability point of view. Copa and Cogeca will actively take part in the different consultations that will be launched regarding the Farm to Fork Strategy, following the publication of the Roadmap. As this initiative will have significant economic, social or environmental impacts, it is imperative that the Commission carry out impact assessments before taking any political or regulatory decision on establishing targets such as to reduce the use of pesticides, as well as the use of fertilisers and antibiotics. This will affect EU production. The Farm to Fork strategy for sustainable food must take into account all three pillars of sustainability (economic, social and environmental) in this broader discussion. This is the only way to recognise the contribution of agriculture and of rural areas to food and feed production as well as biofuels, textiles and reforestation. Agriculture and forestry can provide long-term solutions. Yet the current discussions often neglect these social and economic aspects and forget to include the human factor of farmers’ work. Any future strategy must follow a comprehensive agri-food chain approach and be based on independent science-based policymaking. This will support investment through predictability and consistency. European farmers and agri-cooperatives should be equipped with the right toolbox which should be developed hand in hand with cutting-edge scientific progress. Therefore, European farmers and agri-cooperatives must be given available, safe, effective and affordable tools. Increased investment into research and innovation at EU level may allow European farmers and agri-cooperatives to go further with the environmental sustainability of their production and should be always encouraged. While the Farm to Fork Strategy may provide new opportunities for operators in the food value chain, the Commission needs to explain whether “new technologies and scientific discoveries”, will include New Breeding Techniques, following the recent European Court of Justice’s decision. The Commission must also consider the potential of these techniques to improve sustainability along the food chain. Furthermore, it should be clarified how we are going to significantly reduce the use of pesticides and fertilisers when there is no mention of a list of “credible and realistic alternatives” in the Green Deal Communication. In this context, the next legislative proposals should contribute to reducing the competitive disadvantages that exist today in relation to production methods outside the EU and protecting European high standards that are internationally recognised as among the best in the world. Moreover, these proposals should be based on the solid science-based risk analysis paradigm and the precautionary principle. We cannot have food security without food safety. Furthermore, European production standards must be respected when it comes to trade and imports from third countries. Imported food that does not comply with relevant EU environmental standards should not be allowed on EU markets in order to maintain a level playing field.
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Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

12 Mar 2020

Copa and Cogeca are the united voice of farmers and agri-cooperatives in the EU. Together, we represent over 22 million farmers and their family members, as well as the interests of 22 000 agri-cooperatives. Farmers, forest owners and their cooperatives are the first to feel the impact of climate change. We are committed to the Paris Agreement and contributing to the Sustainable Development Goals. As stated in article 2.1.b of the Paris Agreement, climate action should not endanger food production. The Commission has just published a proposal for the European Climate Law. Article 3.3 of this regulation states: ‘When setting a trajectory in accordance with paragraph 1, the Commission shall consider the following: […] (e) fairness and solidarity between and within Member States; […] (g) investment needs and opportunities; (h) the need to ensure a just and socially fair transition; […].’ Once in force, this trajectory will, without doubt, have an impact on agriculture, forestry and rural areas. We emphasise that the Just Transition Fund must provide support for rural areas and businesses within the scope of article 4.2 of its Regulation. The fund should not only support transitions of geographically concentrated carbon intensive sectors, it must also support transitions of geographically diffuse carbon intensive sectors in rural areas. Just transition plans as laid out in article 7.1 of the regulation must therefore take into account territories with any type of facility associated with high greenhouse gas emissions, not only industrial ones. It is crucial to address the so called front-runner problem. Not only the developing countries and the high growth economies should be beneficiaries, but also front-runner countries with a high green transition ratio. These must be encouraged to contribute further and incentivised to continue developing new solutions. Alleviating the social and economic costs of the transition towards a climate neutral economy through economic reconversion of territories, reskilling and job seeking assistance for workers is of critical importance. However, this should not be used as an argument to justify further cuts to the Common Agriculture Policy in the 2021-2027 MFF, since it is already delivering in terms of environmental, social and economic sustainability. Due to the nature of the mechanism, it also of vital importance that the territorial just transition plans be steered at EU level and prepared in line with and annexed to programmes supported by the Just Transition Fund. Lastly, Copa and Cogeca insist that the dedicated transitional scheme under InvestEU respect the demand-driven nature of InvestEU, and that dedicated technical assistance is necessary for businesses that need to seize the provided financial opportunities.
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Response to Minimising the risk of deforestation and forest degradation associated with products placed on the EU market

4 Mar 2020

Copa and Cogeca are the united voice of farmers and agri-cooperatives in the EU. Together we represent over 22 million farmers and their family members and the interests of 22.000 agri-cooperatives. Copa and Cogeca understand the importance of the problems that European Commission is trying to tackle with this initiative. EU has already a lot of tools to fight against deforestation but we agree that more can be done in the future. We consider that the impact that deforestation has on local communities and on the violation of property rights is an important point that needs to be acknowledged. EU Agriculture sees its responsibility and emphasises that the transition to sustainable and deforestation-free supply chains has to be supported by consumer behavior and market forces to ensure continuation of sustainable investments and innovation in the sector. A level playing field for EU agricultural production and third country imports is a prerequisite to ensure that overall performance against deforestation globally is increased. As a study by the Commission shows EU consumption was responsible for 10% of worldwide deforestation between 1990-2008. In the same period the EU share of global GDP has been approximately 30% (IMF, World Economic Outlook Database). This indicates that deforestation-free supply chains should not only be achieved by diverting deforestation-free trade flows to the EU market. Special emphasis should be put on local governance to encourage deforestation-free economic activities at local level. Copa and Cogeca believe it is important to provide reliable and solid information to EU consumers. Therefore, it is of the outmost importance to avoid delivering simplistic messages not built on science-based criteria. In addition, as the safeguard of the EU internal market is of the outmost importance, each labelling legislative initiative has to be harmonized across the European Union, in order to avoid disruptive national laws that can damage the free trade within the European Union, creating unnecessary market barriers. Although certification schemes have been increasingly utilised in recent years to communicate with EU consumers, it is pivotal that each potential certification scheme would be utilised to share the premium price across all the food chain. Certification schemes have been too often imposed on primary producers in order to access specific retailers markets (pre-conditions), imposing the certifications costs to farmers and agri-cooperatives but with no sharing of the premium price that consumers are willing to pay, when they buy quality products responding to their e.g. social, ethical, environmental beliefs. Special attention should also be put into the REDII directive and the associated regulation. Under the current provisions, it is obvious to that there is a major risk that the use of palm oil for energy will increase, while European farmers, who respect high environmental standards, will face a cap on EU crop-based biofuels. Copa and Cogeca stated in May 2019, that “in the event that [palm oil] exports [from third countries] increase compared to 2019 levels and that deforestation continues, the delegated act [EU 2019/807] should be amended to integrate stricter criteria for the certification of low ILUC-risk feedstock and adequate safeguards to curb their expansion into high carbon stock land.”
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Meeting with Stella Kyriakides (Commissioner) and European agri-cooperatives

27 Feb 2020 · Farm to Fork Strategy

Meeting with Janusz Wojciechowski (Commissioner) and

20 Feb 2020 · Cap, Green Deal, Farm to Fork

Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski) and Wine Institute

19 Feb 2020 · French winegrowers cooperatives, CAP

Meeting with Frans Timmermans (Executive Vice-President) and European agri-cooperatives

13 Feb 2020 · Role of Agriculture in the Green Deal

Response to Amendment of the rules on post import checks for plants for planting.

7 Feb 2020

From Copa and Cogeca, representing EU farmers and agri-cooperatives, we are glad to have the opportunity to contribute to this consultation and we may accept the proposed Implemented Regulation. Our only remark in this regard would be that even whilst we are not against "additional checks" for imported plants, we hope that the new rules to be applied in this regard do not make additional costs for growers, as they already cover financially the biggest part of the current import checks.
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Response to Climate Law

6 Feb 2020

European farmers, forest owners and their cooperatives are the first to feel the impact of climate change. 22 million farmers and their family members and 23 000 agri-cooperatives are committed to the implementation of the Paris Agreement and support it as an essential part of the European and international political agenda. European Climate Law has to provide certainty and stability to the agricultural sector and take into account its capacity, potential and constraints when it comes to reducing greenhouse gas emissions. Copa and Cogeca agree that all sectors have to play their part and that incentives for developing climate-friendly and sustainable practices, products and technologies have to be strengthened. The EU farming model is based on diversified, local and family farm structures, and is among the most efficient farming systems in the world. As such it has allowed EU agriculture to increase its overall productivity by 25% since 1990 while reducing its GHG emissions by 20% over the same time period. Agriculture has decoupled its environmental impact from production growth. Still, today and in the future, more needs to be done to enhance adaptation and mitigation. The time has come to majorly step up sustainable intensification and take innovative action. We have to take the lead and pave the way for the food production of tomorrow. We want to provide European solutions for global challenges. We must show the way forward by producing more food with less environmental impact. Natural emissions from farming cannot be avoided completely, only reduced to a certain extent. However, they are part of a natural cycle, whereas fossil fuels disrupt this cycle. The difference between long-lived fossil fuel emissions and short-lived natural emissions from farming needs to be considered when designing climate policies. The Climate Law must focus on reducing fossil fuels. Any weakening of the EU’s current border protection for agricultural products could dramatically undermine efforts to reduce emissions and could well prevent a net global emissions reduction. Additionally, given increasing global pressure on agricultural systems due to climate change, EU agriculture will have to play a role in supplying sustainably produced food, feed and agricultural raw materials to disadvantaged parts of the world. Global emissions can benefit from a sustainable trade with EU agricultural products, which come with lower emission intensities than products from other parts of the world. Forestry and agriculture are the sectors that have great potential to offer when it comes to mitigating climate change and promoting the shift towards bio-economy – this potential needs to be recognised. The sector can deliver an overall climatic benefit to society by increasing carbon stored in long-lived wood products (e.g. in construction) and the carbon content in soils and by promoting circular approaches based on biogenic sources. Carbon credit schemes might provide financial incentives for climate mitigation in farming and CO2-sequestration in land use and forestry. Biogenic energy sources represent the main part in the portfolio of renewable energies in the EU. Ambitious dissemination and further technological development of bioenergy in all application areas (heating & cooling, mobility & electricity) is key to achieving climate goals. Each sector must reduce its GHG-emissions within the boundaries of its area of influence. Agriculture and forestry can contribute as a natural carbon sink, but this means that farmers’ and forest owners’ contribution must be remunerated. This must be provided for in European Climate Law. We also believe that the Commission should increase its efforts towards boosting research and innovation in agriculture. This could make a vital contribution to reducing emissions and improving efficiency. Innovation, research and practical solutions should be a supported with ambitious measures rather than becoming binding regulation.
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Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski)

21 Jan 2020 · CAP reform and Green Deal

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and European agri-cooperatives

21 Jan 2020 · Meeting to discuss EVP’s participation in the Praesidia meeting of COPA COGECA

Response to EU 2030 Biodiversity Strategy

17 Jan 2020

Copa-Cogeca’s feedback on the EU Biodiversity Strategy to 2030 Roadmap Copa-Cogeca, organisation representing European farmers and agri-cooperatives, welcomes the European Commission’s initiative for the strategy which will outline the EU position for the global negotiations and put forward EU commitments to address the causes of biodiversity loss by 2030. Biodiversity goes hand in hand with agriculture and forestry, and European farmers, forest owners and their cooperatives are committed to maintaining it! Together they have already made real progress on the climate and environment front, by reducing emissions, efficient use of resources and implementing more sustainable practices. Therefore, we need to continue to promote the sustainable use of forest and agriculture ecosystems (taking into account economic, social and environmental aspects), in Europe and in the rest of the world. It is because much biodiversity will be lost without active management in agriculture and forestry. As the recent scientific reports have showed, there is still work to be done to stop the loss of biodiversity. EU farmers, forest owners and their cooperatives are part of the solution and will continue to be committed partners in the conservation of biodiversity. However, since sources of biodiversity decline are diverse and multifactorial, they alone cannot stop the loss of biodiversity. This is a task for society as a whole and it requires governments, all economic sectors and consumers to play their part. For the European farmers and their cooperatives it is crucial that all biodiversity targets, while ambitious, are realistic and take into consideration the negative consequences of climate change in order to encourage efforts to achieve the global 2050 Vision for biodiversity: “living in harmony with nature”. We need sound and coherent policies, and sufficient and well-allocated funding in order to continue to contribute to different EU objectives and SDG Goals. As regards agriculture, we also have to take into account the objectives of the common agricultural policy set in the Article 39 TFEU. To ensure that any future targets are reached, it is necessary that relevant stakeholders (farmers, agri-cooperatives, forest and land owners, etc.) are involved from the start in the development of the framework and targeted implementation instruments and measures in 2021 follow up. Only proper stakeholder engagement process will secure their support and very much needed motivation for its implementation. This is in line with what was identified in the CBD’s Working Group Zero draft for the post 2020 framework as key experiences for successful implementation (“ensuring that implementation is participatory, inclusive…flexible” etc.). Therefore, stakeholder engagement on the framework itself (including the monitoring and mainstreaming) needs to go beyond this feedback and any sectorial targets (and related indicators) need to be agreed with relevant sectors’ representatives (on EU and national level) and backed up by the appropriate impact assessments (to avoid disproportionate burden). Our main messages concerning the future Strategy are further highlighted in the attached document. We hope that they will be taken into account. Only together can we buck the biodiversity loss trend!
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Response to Rules on plant passports

10 Jan 2020

Dear Sir or Madam. Please find attached in PDF the feedback to this consultation from Copa and Cogeca, representing EU farmers and agri-cooperatives. We would want to thank you again for the opportunity to participate in this consultation process. Best regards,
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Response to Support to European farmers - Transitional provisions

9 Jan 2020

COPA-COGECA CONTRIBUTION TO THE PUBLIC CONSULTATION “HAVE YOUR SAY” ON THE TRANSITION REGULATION First and foremost, a speedy decision on the transitional regulation is needed to provide stability, legal security and financial continuity to farmers and their cooperatives. Since it is not likely to have the future CAP implemented from 1st January 2021, it is important to agree and implement transitional arrangements that function as a bridge between the two set of rules – the current CAP and the future one in a timely manner. Any new measures and interventions should only come with the CAP post 2020. For this we need a clear commitment and a timely decision from the European Parliament and the Council. Another crucial point is the timeline of the transition regulation. As we are progressing with the CAP post 2020 work, the transition should ensure a smooth evolution of the rules and guarantee that Member States have the time to properly develop their Strategic Plans, that the European Commission has the time to approve them and that Member States can effectively implement them. In reality, this means that on the last day of the transition period, all Member States will have their Strategic Plans operational and ready to be deployed the next day. In this regard, we must also ensure an adequately timed progress on the CAP post 2020 work, clearing out any hurdles for the new rules. In addition, the transition should also allow farmers the time to adapt to the new rules and plan their agricultural activities accordingly. In this regard it is also important to provide Member States with the necessary technical assistance support (human resources and technologies) to prepare for an adequate implementation of the future CAP. In light of these arguments the transition period could be longer than 1 year. It should however be as short as possible but, under no circumstance, last more than 2 years. The transition regulation should also ensure the continuation of the most vital measures in Pillar II, such as the investment aid and agri-environment climate schemes. It should also provide clarification on how will the financing work during transition and how will continuity be guaranteed for multiannual commitments. The contracts for AECM specifically need to be extended by at least one year or longer in case of a longer transition. Additional technical questions need to be clarified such as the provision of sufficient leeway for the conclusion of the current RD programs to guarantee their full implementation. We welcome the amnesty clause introduced under Article 5 and see it as a positive gesture to pardon unintentional errors in calculations. We also welcome the provisions allowing the continuation of the SAPS system for direct payments and putting it on equal footing as the BPS system. A transitional national aid should also be extended for those Member States that request it. As this aid is included in the current legislative framework, it should be automatically extended also during the transition period. This will ensure certainty to concerned farmers and will avoid a sudden and substantial decrease of support. In addition, Member States could be given the option to interpret and implement, during the transition period, state aid related technical measures provided that there is no budgetary impact. Last but not least, the financial framework is what worries us the most. As we have stated before, we cannot accept that the CAP budget sees a cut of such proportions as the European Commission introduced in the MFF proposal. The CAP budget must be, at least, maintained in real terms. This also implies that during the transition period, there cannot be any cuts to the funding. Member States must be able to deliver to their farmers the direct payments in full and also continue to provide for the measures currently supported under Pillar II.
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and European agri-cooperatives

12 Dec 2019 · Green Deal and agriculture

Response to Organics production rules

29 Nov 2019

Copa-Cogeca’s working party on organic farming would like to raise the following points. - As regards the usable area, in several Member States a “veranda” is considered an integral part of the poultry house system which benefits from the same conditions as the indoor building, as required by Annex II, part II, point 1.6.1 of Regulation 2018/848, “Insulation, heating and ventilation of the building shall ensure that air circulation, dust level, temperature, relative air humidity and gas concentration are kept within limits which ensure the well-being of the animals”. Therefore, we understand that, in this case, they should be considered as being part of the indoor area of a poultry house and thus included in the usable area. - If the withdrawal period for vaccines, treatments for parasites and compulsory eradication schemes is increased to 48 hours after treatment, this will have detrimental consequences on the rearing of organic ruminants and monogastrics. Organic egg and dairy producers will see a dramatic loss in their income because the products produced during the withdrawal period will not be sold as organic. In the worst-case scenario, animal welfare will be jeopardised. Therefore, it should be clarified that where a zero-day withdrawal period applies for vaccines, treatments for parasites and compulsory eradication schemes, this should be maintained. - For parent birds and pullets, the open-air areas should be substituted by a roofed outdoor area in order to avoid significantly increasing the health risks for the birds and the costs for the organic farmers. - We fear that fixing the maximum for multi-tiered systems at three levels would hamper EU organic poultry production. Instead of limiting the number of levels, we believe that this should be regulated by fixing the maximum stocking density on the ground floor. This would give farmers the possibility to decide on the system best adapted to their climatic conditions and to innovate further in order to improve animal welfare. - In addition, there needs to be a 10-year transition period for all farms that are not yet compliant with the new requirements in the implementing act. This transition period should also apply to all farms compliant with national standards developed under the current organic regulation. - As regards the annex, the maximum flock size in a single compartment should be 12 500 pullets. For broilers, the stocking density in the outdoor area (for fixed houses and mobile houses) should be 2 m2/bird. For piglets of no more than 35 kg, the stocking density in the indoor area should be 0.02m2/kg. For brood sows, the stocking density in the outdoor area should remain at 1,9 m2/head.
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Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development) and European agri-cooperatives

30 Oct 2019 · Cap refrom post 2020, trade related aspects

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

24 Oct 2019 · CAP reform

Response to Listing regulated pests, plants, plant products and other objects

10 Sept 2019

Dear Sir or Madam. From Copa and Cogeca, the voice of EU farmers and agri-cooperatives, please find our feedback attached in PDF format. Thank you very much.
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Response to Tariff quotas with licences

22 Aug 2019

By default, Copa and Cogeca support efforts to simplify and modernise the current regulatory framework. Regarding the current proposal to simplify rules concerning reduced tariffs schemes we believe that the Commission must take in account the conclusions of the meeting of the Committee of agriculture and rural development of the European Parliament that took place on 19 February 2019, and the opinion of the EU stakeholders and revise the current proposal by maintaining some of the flexibility of the current system while providing the simplification aimed with the revision. The revised draft should:  include exports as reference for over demanded TRQs;  remove limitations on CN codes and origin for all over demanded TRQ’s;  move the details of the requirement for reference quantity from the “Delegated Act” to the “Implementing Act” so as to improve the future flexibility of the TRQ administration; TRQs are applied to products that are considered sensitive. Following more than 70 international trade agreement and other trade arrangements, the management of TRQs became an effective tool for market management, with direct impact on prices for producers. • According to our experts, the current proposal will drastically decrease the effectiveness of TRQ management as market management tool in order to help to balance our internal market for poultry. It will in fact provide an unnecessary concession to third countries multinationals. • In recent negotiations with Canada and Mexico, the EU negotiator understood the importance of retaining the power to manage TRQs. Therefore, has managed to retain the control of management of TRQs for new market access for sensitive sectors. Taking in account that currently 25% of the poultry breast consumed in the EU is imported (overall poultry imports amount to 900.000 tonnes of poultry meat), mostly from Brazil, Thailand and Ukraine, the proposed changes (to the existing TRQs) will, de facto, transfer the bargaining power from the EU to multinationals from third country exporters. • Operators can only increase their share of the allocated licenses by importing on full duty. Importing on full duty is impossible for EU SME importers, so they will lose market share. Third country producers (such as Brazil, Thailand or Ukraine) will be instantly rewarded with extra licenses for every kg of imports on full duty – and they have the economical capacity to do it. Only large 3rd country producers can build new reference quantities which will offer them dominance in the TRQs concerned. • Large 3rd country producers will take full control of quota within a matter of (few) years. The elimination of EU importing SMEs has an impact in the capacity to export EU produce to third countries. In addition, it will allow third country multinationals to build capacity in the EU market, through their subsidiaries, leading to an increase of EU imports from third countries (even) with full duty. With this shift of bargaining power, third countries multinationals will be able to set the price in the EU market. Thanks to the increase of the quota rent, the 3rd country exporters will sell more high-value products (such as the poultry breast) in the EU, with full-duty payment. For example, it’s important to keep in mind the dynamics of the EU market, each poultry breast imported into the EU leads to the replacement of one broiler in the EU. In a period of trade uncertainty and higher chances of Hard brexit, we call on the Commission to revise the draft according to the proposals of the EU agricultural sector.
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Response to Rules on official controls and measures in cases of non-compliance of certain categories of animals and goods from third

30 Jul 2019

From Copa and Cogeca, representing EU farmers and agri-cooperatives, please find attached in PDF our feedback to this consultation. Best regards,
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Meeting with Peter Wehrheim (Cabinet of Commissioner Phil Hogan)

15 Jul 2019 · climate change

Response to Fitness Check on endocrine disruptors

10 Jul 2019

Dear Sir or Madam. Thanks for the opportunity given for giving feedback on this Roadmap on Endocrine Disruptors. From Copa and Cogeca, representing EU farmers and agri-cooperatives please find attached our feedback. Best regards,
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Response to Animal disease notification, reporting, surveillance, eradication and disease-free status

3 Jul 2019

Dear Sir or Madam. Please find attached in PDF format, the feedback from Copa and Cogeca, representing european farmers and agri-cooperatives, to this public consultation on "Animal disease notification, reporting, surveillance, eradication and disease-free status" Best regards,
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Response to Enhancing Market transparency in the agri-food chain

19 Jun 2019

Copa and Cogeca consider that market transparency is fundamental for an efficient functioning of the food supply chain. Without market transparency the necessary tools to curb UTPs, to manage risk and tackle extreme price fluctuations cannot be implemented, will not be efficient, and all this to the detriment of farmers and agricultural cooperatives. An absence of transparency can lead to a misinterpretation of market signals and as a consequence a continuation of imbalances in the market. Ultimately this leads to continued downward pressure on prices and a high risk of market abuse from buyers towards their suppliers. In an increasingly market oriented agriculture clear, precise and timely information on market signals is necessary for all actors in the food chain, especially farmers and agri-cooperatives. This is relevant for the economic analysis of the sector including the calculation of the distribution of margins all along the food supply chain. In more concrete terms, and considering the questions raised, we believe that it is necessary to harmonise the criteria and sources for data collection at EU level. Only such a consistent approach would enable solid and accurate market analysis and information to be developed. Unfortunately we currently still see a degree of variability between MS. It is important to ensure timeliness of data collection and publication. Additional information is included in the attached document.
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European farmers urge market-oriented approach to animal welfare

14 Jun 2019
Topic — Evaluation of the EU strategy for protecting and improving animal welfare standards.
Message — Copa and Cogeca advocate for simple, outcome-based welfare indicators developed alongside farmers. They emphasize enforcing existing legislation over new rules to ensure a level playing field.12
Why — This would lower administrative burdens and prevent competitive disadvantages within the internal market.34
Impact — Small farms suffer as expensive new welfare investments often lead to closures.5
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Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen) and European agri-cooperatives

13 May 2019 · Common agricultural policy

Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development) and European agri-cooperatives

12 Apr 2019 · Exchange of views

Response to Rules on border control posts and measures to be taken in cases of non-compliant consignments of animals and goods

25 Mar 2019

CORRECTION TO PREVIOUS FEEDBACK: Dear all. Please find attached the feedback from COPA-COGECA. Best regards. Paula de Vera, Policy Advisor in Anima Health and Welfare.
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Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development) and European agri-cooperatives

14 Feb 2019 · exchange of view CAP

Meeting with Michel Barnier (Head of Task Force Task Force for Relations with the United Kingdom) and European agri-cooperatives and

4 Feb 2019 · Meeting with the Task Force for the Preparation and Conduct of the Negotiations with the United Kingdom under Article 50 TEU

Meeting with Michel Barnier (Head of Task Force Task Force for Relations with the United Kingdom) and European agri-cooperatives

29 Nov 2018 · Meeting with the Task Force for the Preparation and Conduct of the Negotiations with the United Kingdom under Article 50 TEU

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and European agri-cooperatives and Confédération Européenne des Vignerons Indépendants

21 Nov 2018 · Alcohol labelling

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and European agri-cooperatives

8 Nov 2018 · New breeding techniques

Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström) and European agri-cooperatives

8 Nov 2018 · on-going trade negotiations

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and European agri-cooperatives and Confédération Européenne des Vignerons Indépendants

8 Oct 2018 · Alcohol labelling

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

2 Oct 2018 · Wine labelling

Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development) and European agri-cooperatives

28 Sept 2018 · exchange of views

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and European agri-cooperatives and Confédération Européenne des Vignerons Indépendants

21 Sept 2018 · Alcohol labelling

Meeting with Peter Wehrheim (Cabinet of Commissioner Phil Hogan)

12 Sept 2018 · Follow up to launch of Code of Conduct on Agricultural data sharing

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and European agri-cooperatives

12 Sept 2018 · New breeding techniques

Meeting with Vytenis Andriukaitis (Commissioner) and

3 Sept 2018 · Alcohol labelling

Response to Listing high risk plants & plants for which a phytosanitary certificate is not required for introduction into the Union

27 Jul 2018

Copa-Cogeca welcomes the opportunity to contribute to this important piece of legislation. We welcome the efforts to simplify and clarify the current regulatory framework, with the aim of developing a legal basis that is more based on sound scientific and technical arguments with the aim at preventing actual risks. According to the EC, billions of plants and plant products are moved every year within the EU Single Market or are imported from non-EU countries. The economic benefits of such system have to be taken into consideration when discussing our plant health policy. However, we must also be aware of the possible threats of such movements. While globalisation is the source of many opportunities, it is also one of the greatest challenges that the EU faces today. EU farmers and agri-cooperatives operate in an increasingly market-orientated agriculture and pests and diseases stop at no borders. Copa-Cogeca highlights that preserving healthy plants in Europe and ensuring a competitive agricultural sector is in the interest of society as a whole. Increasing global food demand, scarce natural resources, the effects of climate change, the increasing movement of goods and people around the world, and the emergence and spread of new pests are just some of the key challenges facing European agriculture. In this respect, the current European system of official controls of imported plants, plant products and plants for planting failed to protect the European territory against the entry of several unknown pests in Europe (i.e. Xylella fastidiosa). In assessing the risks and establishing appropriate measures to tackle them, relevant economic factors should be taken into account. For instance, potential damage in terms of loss of production in the event of entry, establishment or spread of a pest or disease, as well as current trade flows and control of risks. The plant health regime has to be proportional and based on risk and robust scientific principles. Phytosanitary risks must be carefully monitored and, if necessary, imports which pose a pest risk of an unacceptable level for the Union territory must be restricted or even prohibited (articles 40 and 41). In this respect, in addition to the risk assessments, the list must be also based on the known number of interceptions. According to the number of interceptions (Europhyt), some genera/species such capsicum, citrus, malus, prunus (many), pyrus, momordica and mangifera shouldbe regulated. For a better balance of interests and according to article 42 (3) targeted third countries could be listed, if necessary. See Annex I for a more detailed list.. In this respect, the emergency control measures taken by the EU should be further aligned with this implementing act. Specially, in relation to Xanthomonas citri and Thaumatotibia leucotreta which are not regulated. The EU has to remain vigilant in relation to possible free trade agreements (i.e. Mercosur) which may open the door to an increased number of movements of infected plants and plant products towards the EU. Finally, more effective and standardised procedures at border control posts should aim to ensure that any restrictions are completed in a timely manner and with minimum restrictions to trade. Specific genera like ficus, cycas, ligustrum, lonicera, jasminum and acer have been imported for many years without significant interception records. EFSA, the European Commission and MS should ensure that there are no unjustified delays in the risk assessments which may create trade disruptions. Clearer guidance is needed for operators involved in new trade, to indicate where restrictions may be necessary, how to mitigate the risk and avoid undue delays. Finally, Copa-Cogeca would like to strongly encourage the EU to keep consistency amongst the different pieces of legislation (i.e. Invasive Alien Species) and initiatives (i.e. raising awareness for travellers, monitoring of pests and early eradication measures).
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Response to Evaluation of the EU agricultural promotion policy

27 Jul 2018

Copa and Cogeca welcome the evaluation of the EU agricultural promotion policy. The EU promotion policy is without a doubt an excellent tool to enhance the competitiveness of our sector. Throughout the years, it has proved to be a very important instrument for European farmers and agri-cooperatives to increase consumers’ awareness of the high quality and added value of our products and the merits of EU agriculture. European products are characterised by their diversity and quality, as well as by tradition, know-how and high standards of production. The EU promotion policy is indisputably an excellent tool to promote all of the above in the EU and in third countries. We welcome the fact that the evaluation is also covering Commission initiatives such as the high -level missions. When it comes to promoting EU products in third countries, we need to undertake continuous efforts and actions aimed at opening new markets and eliminating possible barriers to trade. Only once this is done can we fully exploit the potential of the promotion policy. This is why we strongly welcome the high-level missions that have already been organised as well as those yet to come. These excellent initiatives facilitate exchange and encourage the conclusion of agreements between European and global partners that are active in the agri-food sector all over the world. We believe that a key part of the evaluation should be devoted to looking at the experience of the actors involved in the preparation of programmes, including the different requirements of the policy (e.g. representativeness, origin, administrative requirements, etc.), the evaluation process and scope for possible simplification. The experience of the evaluators when assessing the proposals submitted during the calls as well as the feedback received by applicants on their proposals should also be analysed. Copa and Cogeca believe that establishing strategic priorities every year has been a good initiative to increase the impact of promotion and information campaigns all over the world. It makes it possible to take into account the trade agenda, emerging markets and export opportunities, but also the specificities of the different agricultural products and changing consumer trends. We therefore welcome the evaluation in this respect. Indeed, we need to ensure that the policy’s potential continues to be fully exploited and that the policy is tailored to future challenges (e.g. future Brexit market disruptions). The EU promotion policy is, in the majority of cases, a long-term policy. Consequently, when it comes to assessing the efficiency and effectiveness of promotion programmes, we would like to emphasise just how difficult it is to measure the impact of actions beyond their immediate effects, particularly given that some of these impacts take a long time to occur. For this reason, significant weight should be given to the output and result indicators. As already highlighted, the EU promotion policy is a key tool to promote EU agricultural products. For this reason, Copa and Cogeca believe that the selection of promotion programmes and the actions foreseen should focus specifically on primary production in the future, and that the efforts made by European farmers as the first producers of food should be underlined. In this respect, it would be important to evaluate existing statistics in order to ensure that the proposals selected relate to the different agriculture sectors, with a policy tailored their specificities. To conclude, Copa and Cogeca would like to reiterate their support for and commitment to this evaluation. We hope to have the opportunity to share the experience of EU farmers and their cooperatives with regard to the implementation of this essential piece of legislation. It is therefore very important to ensure that there is enough time for proper consultation and involvement of the different actors.
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Response to Proposal for a Regulation of the European Parliament and of the Council on minium requirements for water reuse

19 Jul 2018

Please read COPA and COGECA´s full reply in the attached document! As part of an integrated and participatory water management approach, that includes water savings and water use efficiency, COPA and COGECA consider that water reuse can provide a reliable and alternative source of clean water for agricultural irrigation. To increase the uptake of water reuse for agricultural irrigation, COPA and COGECA strongly believe that only a legal instrument with a fit-for-purpose approach will be able to achieve these goals. Only under such an approach, the quality requirements can be adjusted to the water´s future use, to crop type and irrigation practices, delivering a maximum of environmental and socio-economic benefits. Eventually, this will also help providing higher volumes of reclaimed water while keeping costs low. Furthermore, to unlock the full potential of water reuse in agriculture, we consider that the following points need to be considered: • Creating consumers’ trust about the quality of reused water is a key enabling factor for public acceptance and viable reuse in agriculture. Public acceptance for reusing water to irrigate crops decreases when public health and/or the environment are perceived to be at risk. Therefore, setting common minimum requirements are also expected to positively impact on public perception. • Next to the minimum requirements for substances covered in annex 1 table 2, Member States should, based on existing risks, strengthen measures to already reduce contamination of waste water with further substances (such as heavy metals, noro virus...) to avoid accumulation in fields and to protect consumers. • If the reused water contains nutrients, their type and amount must be specified by water suppliers as farmers have to comply with maximum nutrient loads arising from EU legislation. • Where contamination of agricultural land or of agricultural products is caused by the use of treated waste water, the respective operator of the waste water treatment plant should be responsible and required to compensate farmers. • The minimum requirements have been established by the European Commission with a focus on E-coli. However, also the Noro-virus for example can be an important threat. Therefore, in certain cases E-coli might not be the best indicator to analyze the safety of reclaimed water for human health and the environment. • Capital invested to set up irrigation infrastructures at collective or public level as well as at farm level are linked with significant cost that require specific financial support as well as stable and coherent policies. • To ensure safe water reuse, it is important not only to apply appropriate water quality standards according to the specific use, but also to ensure adequate and reliable functioning of water reuse systems and appropriate regulatory enforcement. • An important point remains to secure the provisions of a higher volume of "fit-for-purpose" reused waste water at bearable cost for water treatment plants and without any extra costs for farmers and agricultural water managers. • To give all relevant stakeholders sufficient time to adapt to the proposed regulation, it should apply only 18 months after its entry into force (vs. 12 months as proposed in Art 17).
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Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and European agri-cooperatives

9 Jul 2018 · Alcohol labelling

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

6 Jul 2018 · Discussion on current trade negotiations

Response to Initiative to improve the Food Supply Chain

13 Jun 2018

Copa welcomes this Commission’s proposal for a Directive to curb UTPs in the food supply chain. Purely voluntary systems did not work and we called for legislation to address this problem. We continue to see a recurrent use of UTPs all across Europe and several Member States have introduced national legislation to curb its use. Nevertheless, we need a European solution for what is clearly a European problem. Such a solution must not endanger the well-functioning legislative systems already in place in Member States. We need to improve the functioning of the food supply chain and we need to have a more balanced distribution of the consumer Euro along the food supply chain. The use of UTPs will not deliver on these objectives and will put at stake the viability and sustainability of the farming sector across the EU. This proposal for a Directive needs to: - create a level playing field for economic operators across the EU regardless of their economic size; - ensure a proper functioning of the internal market and prevent its fragmentation; - provide a “platform” to address transnational UTPs, and; - provide guidance and coordination to Member States in dealing with complex cases. Among these basic elements, the definition of UTPs is fundamental to have a definition of what is and constitutes UTPs. It is not so much the compilation of a list of UTPs (that cannot ever be exhaustive) that is relevant but capturing the principles and essence of any actions that are unfair, unethical and abusive in commercial relations in the food chain. Scope: the Directive should apply to all businesses and not only to SMEs suppliers and non-SMEs buyers. Coverage: Copa considers that a legislation aiming to improve the functioning of the food supply chain should cover food and non-food products derived from agricultural products listed in Annex I to the TFEU. An essential element is the control and enforcement. These should fall under the responsibility of an independent authority responsible for the monitoring and control of its implementation but most importantly the enforcement of the legislative provisions acting in a proactive and robust manner. This authority must be able to apply (and collect) any sanctions deemed necessary to correct or redress the situation in case of non-compliance with the rules. Sanctions should aim to: - Change the behaviour of the offender; - Eliminate any financial gain or benefit from noncompliance; - Be responsive and appropriate to the offender; - Proportionate to the nature of the offense and harm caused; - Restore the harm caused by noncompliance of the rules; - Deter future noncompliance. Economic sanctions applied must be sufficiently important to act as a deterrent thus preventing any further repetition of actions. Repeated behaviour must also be considered when determining the sanction. Non-economic sanctions could also be used. The “fear factor” also needs to be addressed and for that, anonymity must be provided so that those suffering from these practices can come forward and voice their problems. Furthermore, this authority must be able to receive anonymous complaints and initiate and conduct “ex-officio” investigations. Member States authorities should communicate to the EU level authority the cases under investigation and, upon completion, the decisions and, when applicable, the sanctions imposed. Farmers being the weakest link in the chain are suffering their impacts and they cannot endure this situation any longer. When unfair and unethical behaviour leads to financial gains, only legislation backed by proper enforcement can deliver the necessary results. We need a cultural change in business ethics. The European Commission and Member State authorities must implement a coordinated approach to prevent aggressive, unfair and abusive commercial practices that do not serve consumer interests.
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Meeting with Peter Wehrheim (Cabinet of Commissioner Phil Hogan)

7 Jun 2018 · role of Women farmers in future CAP and gender issues within the sector

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

6 Jun 2018 · CAP reform

Response to EU implementation of the Aarhus Convention in the area of access to justice in environmental matters

4 Jun 2018

COPA and COGECA, representing the interests of the European farmers and agri-cooperatives, support the general principles of the Aarhus Convention for providing access to information, public participation and access to administrative or juridical procedures for decisions with major impacts on the environment. However, we consider that the Aarhus Convention compliance Committee has shown an unreasonable far-reaching interpretation of the obligations laid down by the Convention. Based on its role and composition, it is obvious that the Committee strives to extend the scope of the convention beyond what was initially intended. We consider that neither the Convention´s background papers nor any primary source of law justify a situation where basically anyone who identifies itself of being concerned to initiate a lawsuit. In many Member States, the minimum requirements according to the convention are distorted to a very extensive access to court proceedings for environmental NGOs. Even on matters with very limited environmental impact such as small-scale forestry or farming activities, the Convention is used as a justification to start legal processes. This contrasts with Article 9, which is unequivocally aimed only at major activities. The consequences of this are unforeseeable delays, legal uncertainties, lack of protection of investments and large costs for individuals and SMEs. COPA and COGECA call for a more balanced and objective approach that takes into account the different national administrative and legal systems. We especially consider that the interpretation proposed in the Commission Notice leads to far reaching and negative consequences for project applicants, SMEs and society at large, especially when it comes to a balanced development of environmental, social and economic goals.
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Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

29 May 2018 · Discussion about the wine sector in the EU

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and European agri-cooperatives

29 May 2018 · Alcohol labelling

Meeting with Carl-Christian Buhr (Cabinet of Commissioner Mariya Gabriel) and European agri-cooperatives

23 Apr 2018 · Launching event of the EU code of conduct on agricultural data sharing

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and European agri-cooperatives and

10 Apr 2018 · Alcohol labelling

Meeting with Jyrki Katainen (Vice-President) and European agri-cooperatives

26 Mar 2018 · Food Supply Chain

Response to Update of the 2012 Bioeconomy Strategy

16 Mar 2018

Copa and Cogeca, representing the European farmers and agri-cooperatives, welcome the publication by the EU Commission of the Roadmap on the update of the Bioeconomy strategy, and underline the importance of the EU agriculture and forestry sectors to maximize the potential of bioeconomy in EU. We welcome the fact that the update aims to strengthen sustainability and deliver on jobs and growth as well as support valorization of local resources and involve more effectively primary producers in the supply chain. However, we fail to see in the eight action points presented in the roadmap how these issues will be addressed as none of the points cover issues related to primary producers and biomass availability and mobilisation. EU-grown sustainable biomass is the first enabler of an EU bioeconomy and further boosts the vitality of the entire value-chain. Promoting and supporting sustainable biomass production and mobilisation in the EU is key to further developing the bioeconomy. Involvement of primary producers in the structures of the bioeconomy initiatives and decision making processes is of utmost importance to strengthen partnerships between different actors of society and enhance public awareness of the sustainable use of biomass resources. We do consider that the importance of the bioeconomy is still underestimated at EU level and better policy coherence and coordination is still needed. There is a need for creating a stronger link between the updated EU Bioeconomy Strategy and the future CAP, the future Cohesion policy and also the EU Forest Strategy that is currently being reviewed by the Commission. The future Bioeconomy Strategy action plan should highlight the importance of the future CAP in supporting the further development of the bioeconomy. This could be by providing the right tools to promote active land management, prevent land abandonment, support investments to foster innovation and to stimulate precision farming and forestry for a more efficient use of resources. In addition, the role of the advisory services, knowledge transfer and training is crucial in helping farmers to increase the sustainability of their current business when producing biomass and to benefit from new business opportunities. The action plan should also ensure coherence with regional development policy post 2020. Enough funds should be provided to support infrastructure, broadband and services in rural areas to ensure efficient rural business. Progress in the bioeconomy can only be achieved if rural areas are attractive to live and work in for future generations. In the context of policy and incentives coherence, the revised strategy should also come up with concrete proposals on how to raise awareness and promote the benefits of bio-based products to stimulate market demand. In this context, the existing legislative and non-legislative sustainability framework for renewable raw materials should be acknowledged and promoted. In order to ensure a sustainable development of bioeconomy, we need to continue to support an efficient use of resources and to avoid any promotion of principles such as ‘’the cascade use’’ that goes against a market oriented economy. Any link between this approach and bioeconomy will be detrimental to the development of local supply chains and will lead to overly-prescriptive administrative burden. We believe that the European Commission should better promote the replacement of fossil-based raw materials with EU grown renewable materials in strategic sectors such as energy, construction, packaging, automotive, fertiliser and textile industries.
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Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis) and European agri-cooperatives

16 Mar 2018 · Unfair practices in the internal market, ASF, CAP reform

Meeting with Vytenis Andriukaitis (Commissioner) and

12 Mar 2018 · Alcohol labelling

Meeting with Vytenis Andriukaitis (Commissioner) and

22 Feb 2018 · African Swine Fever, Animal Welfare, Food waste

Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development) and European agri-cooperatives

13 Feb 2018 · Exchange of views on the future of the CAP and Civil Dialogue Groups

Response to Commission Implementing Regulation on the provision of voluntary indication of origin or place of provenance of foods

1 Feb 2018

Copa and Cogeca believe that the primary goal of food labelling is to provide consumers with coherent and transparent information to enable them to make informed choices. We, indeed, acknowledge that consumer demand for information on the place of the origin of food is becoming increasingly important to consumers and that there is significant potential for consumers to be misled. Recent consumer research has shown that local provenance is valued by consumers, is associated with quality, and that purchasing locally produced food products makes consumers feel that they contribute to the local economy and employment. Unfortunately, EU farmers and their Cooperatives have identified several cases on the market of operators that link their product to a particular origin without any real connection to the primary ingredient’s place of farming. This is why we would like to start by stressing that the logic behind Article 26.3 of Reg (EU) No 1169/2011 is to prevent such cases. Unfortunately, the article of the regulation per se is already providing enough flexibility to operators that do not want to disclose further information on the origin of the primary ingredient but simply want to say that it has a different origin to that of the final product. Copa and Cogeca regret the fact that the draft text is still too flexible and vague. To start, the draft does not provide any legal certainty on what is meant by “given origin”. It should be clearly specified in the scope that it means any indication provided in relation to the country of origin or place of provenance of a food such as statements, terms, pictorial presentation or symbols. Above all, no consistency and consequent legal obligation is enforced between the level of geographical detail given for the food and the one given for the primary ingredient. Previous versions of the draft were clearer in this respect. We understand the need to provide a viable solution, nevertheless there needs to be a minimum level of consistency between both origins. With the current draft, one can easily label the origin of food at a city or a regional level giving information on the primary ingredient at EU/non-EU level. We wonder whether this is relevant for consumers and helps to avoid misleading practices. Voluntary information on food origin cannot become a marketing tool for operators trying to differentiate on the market but who do not have all the relevant final product information or who simply do not want to disclose further information on the provenance of the main ingredient. To render markets more transparent and to enable consumers to make informed choices, it is essential to develop clear and strict rules on voluntary origin labelling and this implementing act should play a key role in this respect. We would like to stress that the origin of an agricultural product refers to the place where the product was harvested or where the animal was reared, i.e. the “place of farming”. For the sake of consumer transparency, it is also of paramount importance that a clear distinction is drawn between indicating the place of farming and the definition of country of origin, which refers to the place of the last substantial modification. Indeed, we also wonder how the definition of origin for those sectors that do not have sectorial legislation is going to be applied. For example, the origin of meat is clearly defined in EU legislation and operators can only refer to the word “Origin” if the animal was born, raised and slaughtered in the same place. Otherwise, the place of rearing and the place of slaughtering has to be further specified at Member State level. At the same time, it is not clear in the draft whether existing EU sectorial legislation will apply mutatis mutandis or operators will have the flexibility to choose the origin of the primary ingredient. Please read the attachment for further information and to see some examples of misleading practices.
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Meeting with Alina-Stefania Ujupan (Cabinet of Commissioner Mariya Gabriel)

30 Jan 2018 · Copa Praesidium meeting

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis) and European agri-cooperatives

30 Jan 2018 · African Swine Fever, Plant Protection Products and Health and Food Safety Issues related to trade

Response to Transparency and sustainability of the EU risk assessment model in the food chain

16 Jan 2018

Fifteen years after the adoption of the principles laid down in the General Food Law (GFL), EU farmers would like to stress once again their support for and commitment to these principles. We believe that this is a fundamental piece of legislation which sets the foundations for food and feed safety, in particular by ensuring a high level of protection of human health, protecting consumers against misleading and fraudulent practices, and guaranteeing the effective functioning of the internal market and an integrated approach from farm to fork. We also believe that one of the essential principles laid down was the need to ensure that decisions relating to safety are supported by sound scientific evidence. Indeed, the GFL established the European Food Safety Authority (EFSA) as the EU risk assessment body for food safety. For Copa, EFSA has played and should continue to play a central role in providing sound scientific opinions and guarantees to EU consumers. EFSA’s opinions and evaluations clearly require professional judgment, which needs to be achieved by respecting the highest standards of scientific expertise. Opinions adopted by EFSA are always the outcome of collective deliberations and it is important to consider the expertise, the excellence of the scientists and the quality of the research involved. It is therefore essential to continue to attract the best talent and new experts to EFSA’s work. When it comes to communication, it is vital that risk assessments and scientific reports in general are communicated in a balanced, professional and pragmatic way. Science cannot be politicised, nor can it spread widely unfounded information or limited findings as this could unsettle the public and create market problems. It is important to keep in mind that EFSA draws professional scientific conclusions that are not necessarily addressed to general public but to risk managers. Nevertheless, Copa appreciates EFSA’s efforts to improve general communication and thus the efficiency of EFSA’s work conducting professional and technical discussions. Of course, risk assessments need to be carried out in an environment of transparency and independence, thereby ensuring that the outcomes remain unbiased. The integrity of EFSA in delivering transparency and efficient deliverables, safeguarding food safety and consumer confidence, and supporting innovation is of the utmost importance for EU farmers. EFSA’s deliverables should be able to foster further development of innovative solutions that will help to face future challenges and to continue to build consumer confidence, which is a crucial element for the EU agri-food sector to innovate and become more competitive. We believe that harmonised EU safety assessments and trust in the food chain are important elements to foster growth and competitiveness, to protect the proper functioning of the internal market, and to support the EU’s trade agenda. Indeed, Copa will participate actively in the consultations organised as part of this initiative on transparency and sustainability of the EU risk assessment model in the food chain. We believe that it is very important to ensure enough time for proper technical consultations and a level playing field for the involvement of the relevant actors in such a complex issue. This will help to continue to build trust in the EU safety model that has proven to be a real success story. We need to learn from previous experience and to strengthen the role of EFSA by ensuring greater consistency and cooperation between the different EU risk assessment bodies, attracting good scientists, providing predictability and guaranteeing support from the different public authorities. Indeed, supporting a reliable and coherent regulatory framework, especially at times when there are uncertainties on the markets, is fundamental, so that farmers can plan ahead to ensure an innovative, competitive and sustainable agriculture
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Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström) and European agri-cooperatives

5 Dec 2017 · Mercosur negotiations, state of play

Meeting with Michel Barnier (Head of Task Force Task Force for Relations with the United Kingdom) and European agri-cooperatives

30 Nov 2017 · Meeting with the Task Force for the Preparation and Conduct of the Negotiations with the United Kingdom under Article 50 TEU

Meeting with Jyrki Katainen (Vice-President) and European agri-cooperatives

30 Nov 2017 · How the agriculture sector could benefit from EFSI.

Meeting with Vytenis Andriukaitis (Commissioner) and

23 Nov 2017 · African swine fever

Meeting with Vytenis Andriukaitis (Commissioner) and

23 Nov 2017 · Common Agricultural Policy; Trade from EU standards point of view; Glyphosate

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis) and European agri-cooperatives

31 Oct 2017 · Exchange of views on the CAP

Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström) and European agri-cooperatives

28 Sept 2017 · On-going negotiations with Mercosur

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

28 Sept 2017 · Trade in the beef sector

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

28 Sept 2017 · Topics inherent to the meat sector

Response to Evaluation of the feed additives Regulation

25 Sept 2017

Copa welcomes the evaluation of Regulation (EC) No 1831/2003 of the European Parliament and Council on additives for use in animal nutrition. EU farmers believe that this is a very important piece of legislation in the area of animal nutrition because it establishes the regulatory framework for authorising the placing on the market and use of feed additives in Europe. Indeed, feed additives represent a very important element in the nutrition of food-producing animals. After several years of implementation, we believe that it is relevant to evaluate whether this framework contributed and facilitated the development of innovative solutions for all species (including minor species) that could help meet our challenges at affordable prices for farmers in Europe. Guaranteeing a high level of protection of human and animal health, protecting consumers against misleading practices, and ensuring that decisions relating to safety are supported by a sound scientific basis are very important elements for farmers and agri-cooperatives. It is also essential to establish and safeguard a level playing field to encourage the free movement of goods, an effective functioning of the internal market and an integrated approach from farm to fork. As for animal production, it is in the interest of farmers to continue to ensure sustainable livestock production, with healthy and productive animals that can meet all the challenges ahead. Copa believes that proper animal nutrition is a prerequisite for good animal health and welfare. It also plays a very important role in improving end product quality, increasing efficiency and reducing the environmental impact. Labelling is also a very important element in this exercise, and EU farmers would be happy to contribute to the evaluation by sharing their experience during these years of implementation. To conclude, Copa would be very happy to get more involved in the evaluation by sharing the experience of EU farmers and their cooperatives with the implementation of this piece of legislation. We hope that these comments will be granted your full consideration.
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Meeting with Jean-Luc Demarty (Director-General Trade) and European agri-cooperatives

19 Sept 2017 · Mercosur

Meeting with Jean-Luc Demarty (Director-General Trade)

19 Sept 2017 · EU-Mercosur: beef

Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development) and European agri-cooperatives and

15 Sept 2017 · Exchange of views

Response to Amendment of marketing standards for free range eggs

1 Sept 2017

During the 2016/2017 outbreak, more than 80% of the EU’s free range hens are estimated to have been housed beyond 12 weeks following veterinary orders to protect them from the bird flu virus. Many egg producers suffered major income losses as continued housing meant that they were no longer able to label their eggs as “free range”. Moreover, the continuity of supply of free range eggs was interrupted, including for the processing industry. We therefore welcome the current Commission’s proposal to amend the marketing standards. This is clearly a step in the right direction and is in line with the significant increase in the market share of free range eggs in several Member States. In general, we expect an increase in free range production throughout the EU. This means that farmers with laying hens are making significant investments and therefore need reliable market conditions in time for bird flu outbreaks and housing orders resulting from veterinary restrictions. It is therefore urgent to amend the egg marketing regulation in place as soon as possible. However, the extension of the derogation would still have been insufficient for birds housed for periods beyond 16 weeks during the 2016/17 outbreak. Indeed, in some Member States the housing order lasted for a period of up to 24 weeks. Extending the derogation to at least 20 weeks in restrictions related to Avian Influenza in order to allow the maintenance of free range status is therefore crucial. This is a reasonable solution and would play a fundamental role in helping to avoid market disturbance for consumers, retailers and farmers. Furthermore, we believe that the calculation of the starting point for the derogation needs to be clarified. Using the date of placing would allow for easy control by the veterinary authorities, but this procedure ignores the associated welfare regulations as well as the principle of producing eggs free range. We propose to set the starting point for the derogation at 20 weeks of age for newly housed flocks or to align it with the Laying Hens Directive, in accordance with the definition of “laying maturity”. • The marketing standards for eggs lay down the framework for egg production and the references are therefore for hens and laying hens. In practice, the pullets are inserted into the production system before they start producing eggs due to animal welfare considerations, so that they can become familiar with the system. At that time they are pullets which not have reached laying maturity and cannot be regarded as hens. • There is no definition in the marketing standards for hens. Though it stated at the annex in marketing standards that production conditions must be at least in compliance with the Directive 1999/74/EC when it comes to laying hens in free-range production. There is a clear definition in article 2, 2.(a) Directive 1999/74/EC for the protection of laying hens; where a laying hens are hens of the species Gallus gallus which have reached laying maturity and are kept for production of eggs not intended for hatching. Further the Directive 1999/74/EC only apply for laying hens. • Further in article 20 1. (a) at the market standard it is required that producers must record information on the date for placing, age at placing and number of laying hens. At that time these birds are pullets and not laying hens. We believe that these proposals would be an effective way of preventing substantial disruption to the continuity of supply of free range eggs and are in line with consumer and retailer expectations as far as supporting free range production is concerned. Our experience in the development of free range production has shown that consumers recognise the need to house flocks according to veterinary orders, in order to protect the health of the birds. Even today, consumption levels in some Member States have not recovered to the levels seen prior to the market disruption. We therefore ask for you to support our proposals.
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Response to Initiative to improve the Food Supply Chain

22 Aug 2017

Copa and Cogeca welcome the publication by the European Commission of the Inception Impact Assessment “Initiative to improve the food supply chain” and have been calling for tangible actions to improve the functioning of the food supply chain and, in particular, to curb unfair trading practices. CONSIDERATIONS ON THE OBJECTIVES AND POLICY OPTIONS Copa and Cogeca fully support actions from the European Commission to address: i) Unfair Trading Practices; The imbalances of power in the food supply chain between price setters and price takers has led to undue pressure being put on the weaker links in the food chain (farmers and agri-cooperatives) and quite often have forced them to accept unfair and abusive prices and conditions. Under these circumstances prices often do not even cover production costs nor enable them to have an economic return on their activity. This is a known problem with a EU-wide dimension. Given these circumstances, the high level of concentration of the retail sector and the fundamental importance of defending a well-functioning Internal Market, Copa and Cogeca favour an EU framework legislation to address and curb UTPs in the food supply chain – option 3. This is the only way to address an EU wide problem. Indeed an EU framework legislation that includes the prohibition of UTPs as well as control and enforcement mechanisms combined with deterrent sanctions is the way to address this problem. UTPs put at stake the viability and sustainability of the farming sector across the EU. This should not however impact negatively on the work of agri-cooperatives to improve farmers’ position in the food chain. A significant number of Member States have already adopted legislation to curb UTPs and, with a view to safeguard a well-functioning Internal Market it is necessary to bring a EU wide solution to this problem that has clearly a EU dimension. Copa and Cogeca have worked in the past with other stakeholders in the food chain to address UTPs but relying solely on a voluntary approach (e.g. guidelines, recommendations and other non-legislative actions) hasn’t worked. The Supply Chain Initiative (SCI), to which Copa and Cogeca have not signed up to, has not delivered on a reduction of UTPs, therefore a legislative approach is the solution. Farmers’ income has dropped 20% in the past four years, therefore clear tangible and immediate action must be taken not only to reverse this situation but also to improve farmers’ share of the consumer Euro. ii) Market Transparency, and; In addition to these measures it is necessary to increase market transparency. In this respect improved information will enable all operators in the food supply chain to make better informed decisions and, in particular, farmers and agri-cooperatives, will have the possibility to improve their efficiency and have a clearer view on the distribution of added value along the food chain including to consumers. To achieve this option 2 is clearly the preferred one. However one should also explore mandatory reporting on prices in order to have robust, reliable and anonymous data along the food supply chain. iii) Producers cooperation. The items are important to improve farmers position in the food chain but one cannot fully achieve this without addressing the conditions for an improved cooperation between farmers. We therefore believe that it is necessary to provide to agri-cooperatives and other types of producer organisations with an economic activity the necessary derogations from Competition law so that they can contribute to improve farmers’ income and their share of the consumer Euro. In this context option 2 is an improvement to the current situation to enable farmers to concentrate supply, add value to their produce and improve their position in the food supply chain. However further steps to amend articles 152, 206 and 210 of Reg. (EU) n° 1308/2013 are necessary.
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Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan) and Union Européenne du Commerce du Bétail et des Métiers de la Viande

11 Jul 2017 · Future of the CAP

Response to Commission Reg. (EU) on the application of control & mitigation measures to reduce the presence of acrylamide in food

7 Jul 2017

Dear Sir or Madam, Please find enclosed a Letter to Frans Verstraete concerning the mitigation measures and benchmark level for the reduction of acrylamide in the food. Kind Regards, On behalf of Pekka Pesonen Secretary General of Copa-Cogeca Marie VAN STEEN Team assistant Copa - Cogeca Rue de Trèves 61 B-1040 Bruxelles Tél : + 32 (0)2 287 27 80 Fax : + 32(0)2 287 27 00 Visit our web page : www.copa-cogeca.eu Copa - European farmers Cogeca - European agri-cooperatives
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Meeting with Jyrki Katainen (Vice-President) and European agri-cooperatives

6 Jul 2017 · CAP, investment and trade.

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan) and European agri-cooperatives

4 Jul 2017 · Business discussion

Meeting with Günther Oettinger (Commissioner) and European agri-cooperatives

15 Jun 2017 · MFF, CAP

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan) and Danske Slagterier SA and Dutch Meat Association

13 Jun 2017 · Pig meat sector

Meeting with Xavier Prats Monné (Director-General Health and Food Safety) and European agri-cooperatives

11 May 2017 · Animal welfare; Nutrition & Health; Food safety

Meeting with Marc Lemaitre (Director-General Regional and Urban Policy)

28 Apr 2017 · Future Common Agricultural Policy and the synergies with the Cohesion Policy

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan) and European agri-cooperatives

18 Apr 2017 · Ecological farming

Meeting with Marc Lemaitre (Director-General Regional and Urban Policy) and European agri-cooperatives

13 Mar 2017 · Exchange of views on the current and future role of ESIF for rural areas

Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development) and EuroCommerce and

20 Feb 2017 · Exchange of view in relation to Avian Flu

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

14 Feb 2017 · CAP and trade, energy, animal welfare

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan) and European agri-cooperatives

25 Jan 2017 · Business discussion

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

24 Jan 2017 · Organic farming

Response to Changes to greening rules and clarifications of certain other direct payments' rules

12 Jan 2017

Continuation of the previous part (3/3) ...the weighting factors for short rotation coppice and catch crop or green cover should be harmonized with the one for NFC and therefore raise up to 0.7 to provide a balanced approach of the values of the element for biodiversity. Such an adjustment could better reflect the environmental value of EFA, as weighting factors are assigned in consideration of EFAs biodiversity objective taking into account the agronomic function of particular elements. Furthermore the weighting factors to calculate the total hectares of EFAs do not fully recognize the environmental benefits of catch crops, nitrogen fixing crops and short rotation coppice compared to the land lying fallow.
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Response to Rules for the EU scales for beef, pig and sheep carcass classification and the reporting of prices

10 Jan 2017

Copa and Cogeca represent more than 23 million farmers and their families and 22.000 agriculture, forestry and fisheries cooperatives. While we generally support the simplification objective, Copa and Cogeca would like to remind the importance played by the carcass classification system in price recording and subsequent application of public intervention and private storage which are essential in case of market imbalances in the beef and sheep sector. In view of the Meat Market Observatory recently created, we would need detailed market information which is reliable and accurate. Moreover, given that one key objective of carcass classification is to improve market transparency, prudence is needed when suggesting changes to the current system in these sectors, so that the changes do not go against this objective. Certain changes foreseen may touch key elements and principles and lead to a relaxation of the rules which today are in place. This may be detrimental to reaching the initial objectives of the system in the first place. Therefore, Copa and Cogeca would like to see the current system of classification safeguarded and where necessary, improved. It is vital to maintain a transparent system in place, within which genuinely independent carcass classification and weighting services are provided, in view of a proper measurement. It is equally essential to achieve a better harmonisation across the EU in order to avoid distortion on the internal market and contribute to strengthening of the supply chain through better commercial operations. The flexibility to be given to MS in terms of minimum requirements for on-the-spot checks in the case of beef carcass classification is problematic. The monitoring of classification by the competent authority should be provided for. Copa and Cogeca are against increasing the threshold from 75 animals to 150 animals for the application of the derogation from the obligation to have the compulsory beef classification system. Additionally, technical issues such as the reduction of tolerances and bias for mechanical classification, allowing changes to technical specifications of classification machines only where accuracy is improved from original calibration trial and the possibility to have an appeal mechanism for mechanical classified carcasses should be considered. In reference to the carcass price reporting in the sheep sector, this should be maintained and further encouraged in order to increase confidence on the prices being paid. Furthermore, working towards harmonising the dressing specifications across sheep plants at EU level would improve transparency in the deadweight marketing of sheep.
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Meeting with Juergen Mueller (Cabinet of Vice-President Karmenu Vella) and European agri-cooperatives

10 Jan 2017 · Contribution of the Common Agricultural Policy to Environmental Objectives

Meeting with Elisabetta Siracusa (Cabinet of Commissioner Phil Hogan), Peter Power (Cabinet of Commissioner Phil Hogan) and European agri-cooperatives

10 Jan 2017 · Upcoming CAP process

Meeting with Cecilia Malmström (Commissioner) and European agri-cooperatives

8 Dec 2016 · Trade and agriculture

Response to Commission Implementing Regulation amending the criteria of low risk substances

1 Dec 2016

Availability of Plant Protection Products is a key element to implement proper Integrated Pest Management (IPM). However, this is not only about active substances or products but also about preventative measures and/or suppression of harmful organisms, rotation, plant varieties, sowing dates which are often out of farmers’ control. The vast majority of pests and diseases in crops are controlled with cultural or physical measures. IPM is not a new concept for EU farmers and agri-cooperatives, as this is based on good farming practices that have evolved over time. However, we have to remind that IPM is also related to costs and economics. The whole debate on low-risk is closely related to the Directive on Sustainable Use of Pesticides and IPM principles. In this respect, since January 2014, Member States have put in place their National Action Plans (NAPs) on how to apply the general principles of IPM. These NAPs require to give wherever possible priority to non-chemical methods for pest management. Currently, there are only 7 low-risk authorised active substances (with no pending authorisations) and 11 basic substances. The average time to authorise low-risk active substances is the same as the non low-risk (more than 2.5 years since the submission of the dossier). These figures show clearly that these tools are far away from what is needed. From farmers and agri-cooperatives’ point of view, increasing availability of low-risk active substances should advance in parallel with other active substances or methods of control. Availability of a wide range of solutions is a key need in order to allow correct choices at farm level and avoid resistances. European agriculture needs to remain competitive while protecting human health and decreasing the pressure on the environment. We therefore, consider that there is a clear need for higher availability of substances and methods to fight pests and diseases, be they mechanical, biological or chemical. Copa and Cogeca have been actively involved in the work carried out by the working group on low-risk substances and that are included in the “Background document for the purpose of a possible amendment of the current low-risk criteria”. In addition, we have developed a roadmap for collaboration with the industry providing such tools. We therefore, consider, among other measures, the need for: • Approving a fast-track approval procedure for those substances that are likely to be considered as low-risk; • Increasing information provided to users through advice services and claims in the labels (this information has not to be misleading); • Unlimited periods of approval unless there are founded concerns to change it (due to unknown side effects) We want also to draw your attention to the fact that in whereas number 7, it seems to be a typo in the last sentence. In this part of the text, instead of chemicals, the text should refer to semio-chemicals. In addition, in whereas number 10, as well as the annex point 5.2.2., we propose to include the following change: “have demonstrated multiple resistance to anti-microbials with different modes of action” instead of “have demonstrated multiple resistance to anti-microbials”. Finally, as for any other active substance we claim for a level playing field in Europe. Currently, the authorisation of Plant Protection Products is done at national level, which endangers the situation for Minor Uses and Specialty Crops due to, among others, the lack of interest to invest in small markets or the inappropriate functioning of the mutual recognition system.
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Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan) and European agri-cooperatives

29 Nov 2016 · Copa and Cogeca event in the European Parliament

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

28 Nov 2016 · Concerns inherent to the farm sector

Meeting with Vytenis Andriukaitis (Commissioner) and

17 Nov 2016 · Roundtable on the future of the General Food Law Regulation

Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development) and European agri-cooperatives and European Oilseed Alliance

28 Oct 2016 · Biofuels

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan) and European agri-cooperatives

12 Oct 2016 · Cereals concerns

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan) and European agri-cooperatives

12 Oct 2016 · Agri matters

Meeting with Phil Hogan (Commissioner)

6 Oct 2016 · Address Congress

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

30 Sept 2016 · MIFID II

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan) and European agri-cooperatives

21 Sept 2016 · Nuffield project

Meeting with Cecilia Malmström (Commissioner) and European agri-cooperatives

19 Sept 2016 · Agriculture in trade negotiations

Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan)

5 Jul 2016 · Agriculture issues

Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström) and European agri-cooperatives

22 Jun 2016 · Agriculture in on-going Trade negotiations

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

22 Jun 2016 · Agri issues

Meeting with Vytenis Andriukaitis (Commissioner) and

2 Jun 2016 · Glyphosate

Meeting with Vytenis Andriukaitis (Commissioner) and

4 Apr 2016 · Endocrine disruptors

Meeting with Phil Hogan (Commissioner) and

19 Feb 2016 · AGRI issues

Meeting with Phil Hogan (Commissioner)

19 Feb 2016 · Agri Issues

Meeting with Iwona Piorko Bermig (Cabinet of High Representative / Vice-President Federica Mogherini)

28 Jan 2016 · EU-Russia relations

Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström) and European agri-cooperatives

21 Jan 2016 · Agriculture in TTIP

Meeting with Arunas Ribokas (Cabinet of Commissioner Vytenis Andriukaitis) and European agri-cooperatives

19 Jan 2016 · Russian Restrictions of pig mean exports

Meeting with Hilde Hardeman (Cabinet of Vice-President Jyrki Katainen) and European agri-cooperatives

20 Nov 2015 · New breeding techniques

Meeting with Arunas Ribokas (Cabinet of Commissioner Vytenis Andriukaitis) and European agri-cooperatives

17 Nov 2015 · Trade and investment communication

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska) and European agri-cooperatives

13 Nov 2015 · Introductory meeting

Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström) and European agri-cooperatives

12 Nov 2015 · Trade in agriculture

Meeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan) and European agri-cooperatives

26 Oct 2015 · new breeding technics regarding GMOs legislation

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen) and European agri-cooperatives

19 Oct 2015 · EU trade strategy

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and European agri-cooperatives

14 Oct 2015 · New breeding techniques, GMO

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

17 Jul 2015 · Introduction of new chairman and economic situation of the sheep sector

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan), Tom Tynan (Cabinet of Commissioner Phil Hogan)

16 Jun 2015 · Preparation of seminar on Big data, Update on logistics in grain sector

Meeting with Elisabetta Siracusa (Cabinet of Commissioner Phil Hogan) and European agri-cooperatives

20 May 2015 · Copa-Cogeca Lunch on Simplification of CAP

Meeting with Jean-Luc Demarty (Director-General Trade) and European agri-cooperatives

6 May 2015 · Trade Negotiations

Meeting with Arunas Vinciunas (Cabinet of Commissioner Vytenis Andriukaitis), Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and European agri-cooperatives

4 May 2015 · Plant protection materials

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

8 Apr 2015 · Market situation for beef, especially the suckler cow production

Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development)

19 Mar 2015 · Simplification

Meeting with Miguel Arias Cañete (Commissioner) and

17 Mar 2015 · : indirect land-use change of food-crop based biofuels & inclusion of land-use in the EU's emission reduction target for 2030

Meeting with Patrick Costello (Cabinet of Vice-President Karmenu Vella) and European agri-cooperatives

12 Mar 2015 · NEC Directive (Meeting with Policy Coordination Committee of Copa and the Cooperative Coordination Committee of Cogeca)

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová) and European agri-cooperatives

12 Mar 2015 · Infrastructure problems of European agriculture

Meeting with Karmenu Vella (Commissioner) and European agri-cooperatives

9 Mar 2015 · REFIT of Birds and Habitats

Meeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan), Elisabetta Siracusa (Cabinet of Commissioner Phil Hogan) and European agri-cooperatives

5 Mar 2015 · Present and discuss Copa-Cogeca’s preliminary ideas on CAP simplification

Meeting with Carlos Moedas (Commissioner) and European agri-cooperatives and

2 Feb 2015 · Meeting with the European Bioeconomy Alliance on the Bioeconomy Strategy

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis) and European agri-cooperatives

15 Jan 2015 · MIFID II

Meeting with Carl-Christian Buhr (Cabinet of Commissioner Phil Hogan) and European agri-cooperatives

16 Dec 2014 · General presentation, food supply chain, unfair trading practices

Meeting with Phil Hogan (Commissioner) and

4 Dec 2014 · Simplification, Farmers share of retail, TTIP, Commissioners address to COPA Presidium