European Fish Processors & Traders Association
AIPCE-CEP
Represents the EU fish processors and traders vis-à-vis the EU institutions.
ID: 01622884661-83
Lobbying Activity
Response to Revision of EU rules on food contact materials
29 Jan 2021
Please find AIPCE CEP feedback attached.
Read full responseResponse to Review of the marketing standards framework for fishery and aquaculture products
5 May 2020
AIPCE CEP represents processors and traders of fish and fishery products supplying the EU market. Our membership consists of 20 EU National Associations and 2 Associations in Third countries, comprising around 3,500 companies employing some 120,000 people, many at SME level. The overall value of the output of our industry amounts to around EUR 27 billion, or three times the turnover of the catching sector.
CONTEXT OF INITIATIVE
EU marketing standards on fishery products ensure that the EU market is supplied with sustainable products and that these products comply with the same quality requirements, thus contributing to fully exploiting the potential of the internal market of such products and warranting fair competition and improving the profitability of production. Given the significant imports of fishery and aquaculture products into the EU market, marketing standards also ensure equal treatment between EU and non-EU products.
AIPCE CEP POSITION
AIPCE-CEP supports the suggested policy option 1 – NO CHANGE - for the following:
• Council Regulation (EEC) No 1536/92 of 9 June 1992 laying down common marketing standards for preserved tuna and bonito: there is no reason to undertake its revision.
• Council Regulation (EEC) No 2136/89 of 21 June 1989 laying down common marketing standards for preserved sardines and trade descriptions for sardine-type products: there is no reason to undertake its revision.
The EU industry of preserved tuna and preserved sardines and sardine-type products, that represents more than 90% of the production of these canned products inside the EU and 2/3 of the socioeconomic impact of the complete value chain, considers these tools efficient, useful and necessary to ensure level playing field and harmonized minimum quality standards.
Moreover, they do not prevent from innovation in these categories and establish a minimum and adequate criterion for marketing fishery products such as tuna and sardines, whose supply chain is worldwide.
The existing standards and trade descriptions for preserved tuna and bonitos and sardines and sardine-type products were developed with the participation of EU stakeholders to ensure their adaptation to the real needs of the EU market and the EU processing industry.
These regulations are furthermore aligned with the corresponding CODEX standards, which have been recently updated and have been applied without any problem.
AIPCE CEP would support policy option 2 – MODERATE CHANGE – for the following:
• Council Regulation (EC) No 2406/96 of 26 November 1996 laying down common marketing standards for certain fishery products, AIPCE-CEP considers that
due to its low utility in the market and with respect to freshness. The size and weight criteria are on the other hand an important tool that serves to harmonize the market and helps to ensure a fairer and a more sustainable market for these products.
AIPCE-CEP therefore suggests to limit the process of a possible revision of the marketing standards for fishery and aquaculture products to the Council Regulation (EC) 2406/96 only, securing though that controls on the minimum conservation sizes (MCS) are maintained, in order to avoid the landing of undersized fish.
Read full responseResponse to Draft Commission Regulation establishing the “PRODCOM List” of industrial products
6 Jun 2019
AIPCE (EU Fish Processors and Traders Association) and CEP (European Federation of National Organizations of Importers and Exporters of Fish) together form AIPCE-CEP. The association represents 20 EU National Associations and 2 Associations in Third countries, for a total of nearly 3,500 companies, the majority of which with 20 employees at most, for total employment of around 120,000 persons. The overall value of the output of the industry represented by AIPCE-CEP amounts to around EUR 27 billion, or three times the turnover of the catch sector.
AIPCE-CEP thanks the Commission services for the opportunity given in providing comments on this important file. We also thank the Commission services for having accepted some of the input provided on 22nd August 2018.
On the other side, it is with some concerns that we noticed that only a very limited part of our comments has been taken into account, and only for the two smaller groups of fish products (i.e. surimi, frozen and smoked trout and other smoked fish).
For the processing industry in the EU, the amendments for a further splitting of the category NACE 10.20.25 are as important as the amendment for surimi and smoked trout.
The current product grouping for preserved and prepared fish (NACE 10.20.25) is of minor use for the industry because very different processing activities (canning, marinating and enzymatically ripening) are not divided separately. To monitor the different processing activities in a proper way, it would be necessary to have a more detailed grouping of NACE 10.20.25. The current NACE-headings are not providing a relevant picture of the large variations of the processing sector in this segment.
In view of this, AIPCE-CEP proposes the same document already presented in August 2018 (attached) and strongly asks the Commission to take our suggestions into account.
Read full responseMeeting with Joao Aguiar Machado (Director-General Maritime Affairs and Fisheries)
10 Sept 2018 · ATQ regulation
Response to Fisheries Control System
14 Aug 2018
AIPCE–CEP represents processors and traders of fish and fishery products supplying the EU market. Our membership consists of 20 EU National Associations and 2 Associations in Third countries, comprising around 3,500 companies employing some 120,000 people, many at SME level. The overall value of the output of our industry amounts to around EUR 27 billion, or three times the turnover of the catching sector.
We source raw materials from the EU fleet, from aquaculture and from wider international supply chains. But the balance of supply and demand (including for species not available in EU waters) means that imports account for a significant share of the current market.
It is however vital for consumer confidence that fish from all origins are responsibly and sustainably sourced and that capture fisheries are effectively managed in accordance with applicable legislation and conservation advice.
The CFP’s Fisheries Control System is fundamental to this and we fully support the objectives of the current proposals to ensure that it is fit for purpose and consistently and fairly applied.
In our earlier position paper responding to the stakeholder consultation exercise, we expressed a preference for improved implementation and enforcement of existing measures over the introduction of substantive new requirements. We also drew attention to the need to distinguish between measures relating to the conduct of fishing and farming activities and the existing body of food law relating to safety and consumer information and the need to ensure a level playing field between fishery products and other types of food.
As responsible business operators, we strive to be fully compliant with all relevant rules and regulations. We and our retailer customers also operate internal systems of control on a business to business level which provide additional guarantees. These systems are tried and tested and it will be important to ensure that any new provisions take necessary account of this. This is particularly relevant to the proposal to bring processed products falling under CN codes 16.04 and 16.05 within the scope of Title V, which is the subject of the majority of our comments in the attached document.
Read full responseMeeting with Joao Aguiar Machado (Director-General Maritime Affairs and Fisheries)
27 Apr 2017 · Brexit
Meeting with Joao Aguiar Machado (Director-General Maritime Affairs and Fisheries)
11 Mar 2016 · ATQ Regulation, ECO labelling, IUU, Control Regulation
Meeting with Karmenu Vella (Commissioner)
19 Jan 2015 · Autonomous Tariff Quotas, labelling, market trends, landing obligation