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European Flour Millers

Our mission is to facilitate the development of a business environment in which all milling companies can meet the needs of consumers and society, while competing effectively for sustainable growth.

Lobbying Activity

Response to Electrification Action Plan

8 Oct 2025

The European flour milling industry strongly supports the objectives of the EU Electrification Action Plan and the broader decarbonisation pathway of the European economy. As an energy-intensive sector relying on continuous operations and stable electricity supplies, our industry is committed to reducing emissions through electrification where technically & economically feasible. However, the competitiveness and viability of this transition critically depend on access to affordable and predictable electricity prices. We urge the European Commission to ensure that the Electrification Action Plan includes measures enabling primary food industrial users to access long-term electricity supply contracts at competitive rates reflecting actual production costs, rather than volatile market prices driven by fossil fuels. Such contracts - potentially underpinned by direct Power Purchase Agreements (PPAs), cooperative frameworks, or public facilitation mechanisms - are essential to provide investment certainty, maintain the competitiveness of European primary food manufacturing, and support the resilience of EU food supply chains. We therefore call on the Commission to: - Promote regulatory and market conditions that enable long-term, cost-based electricity contracts for primary food industrial users. - Encourage energy providers and Member States to develop frameworks supporting access to renewable electricity at competitive cost. - Ensure that electrification policies recognise the specific needs of continuous-process primary food industries such as flour milling. By securing reliable and affordable access to electricity, the EU can help our sector accelerate decarbonisation while preserving its economic sustainability and contribution to Europe's food security.
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Response to Technical updates of the Emissions Trading Scheme (ETS) State aid guidelines

3 Sept 2025

The European flour milling industry (NACE 1061) is not subject to ETS obligations for direct CO emissions. However, flour milling is significantly exposed to indirect ETS costs, as electricity represents a material share of production costs in milling (for grain cleaning, conditioning, drying, grinding and pneumatic transport). The pass-through of CO allowance costs into electricity grid prices increases our energy bills. At the same time, wheat flour is a commodity subject to intense international competition, both within the EU Single Market and vis-à-vis imports from neighbouring countries. While NACE 1061 is not currently listed among eligible sectors for indirect cost compensation, flour milling was included in Annex 1 of the 2022 guidelines on State aid for climate, environmental protection and energy (CEEAG) as at risk for renewable levy reductions. We believe the same approach should be maintained and clarified so that flour mills, where they can demonstrate significant electro-intensity and trade exposure, can benefit from indirect cost compensation. This would avoid distortions between sectors with comparable risk profiles and ensure a level playing field. The request is not for automatic blanket compensation. Rather, the industry proposes: 1. Explicit recognition of NACE 1061 as eligible, or at minimum, 2. A workable firm-level eligibility route allowing mills that meet the electro-intensity and trade exposure thresholds to be covered. Any compensation should remain conditional on energy audits, adoption of energy management systems, and investment plans for decarbonisation (e.g. electrification of heat, process optimisation, waste-heat recovery). In this way, support would both address carbon-leakage risks and accelerate the sectors energy transition, in line with EU climate objectives. If flour milling is excluded, EU operators will continue to bear the pass-through of ETS costs in electricity without any relief, despite being in competition with processors outside the EU who face no such burden. This creates a leakage risk, reduces investment capacity for decarbonisation, and may undermine the resilience of a strategic staple food supply chain. In conclusion, we ask that the Commission consider NACE 1061 in the updated list of eligible sectors, or ensure the Guidelines allow Member States to grant compensation to individual mills that demonstrate significant exposure to indirect ETS costs. This targeted adjustment would ensure fairness, prevent leakage, and enable flour milling to continue investing in its decarbonisation pathway while maintaining competitiveness.
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Response to Industrial Decarbonisation Accelerator Act

8 Jul 2025

As an inherently electricity-intensive sector, where mechanical milling and associated processes rely heavily on a stable and affordable supply of electrical energy, the successful decarbonisation of the European flour milling industry is inextricably linked to the availability of renewable electricity and the necessary infrastructure to support it. We believe that a successful decarbonisation strategy must be technologically neutral, allowing for diverse solutions tailored to specific industrial processes, including advanced electrification- economically viable: ensuring that decarbonisation efforts do not undermine the competitiveness of European businesses, particularly against extra-EU imports. This includes ensuring competitive electricity prices. It must be supportive of SMEs, recognising that a significant portion of our industry comprises SMEs with limited resources for large-scale investments and integrated, considering the entire value chain and the necessary energy infrastructure. The core of flour milling involves the continuous operation of powerful machinery for grinding, sifting, and conveying. These processes are highly electricity intensive. Furthermore, ancillary operations such as milling operations (the continuous running of large-scale rollers, sifters, and pneumatic conveying systems) requires substantial and consistent electrical power, while ventilation and climate control maintaining optimal temperature and humidity within mills for product quality and safety requires significant electrical energy for HVAC systems and material handling such as conveyors, elevators, and packaging machinery are all electrically powered. Transitioning to 100% renewable electricity is a priority for our industry. However, the challenges include reliable supply of renewable electricity to meet the continuous operational demands of mills, especially given the intermittency of some renewable sources - competitive pricing since the cost of renewable electricity must remain competitive to avoid increasing operational costs and impacting the affordability of staple food products and, last but not least, the existing grid infrastructure may require significant upgrades to handle increased electrification and the integration of more decentralised renewable energy sources, particularly in rural areas where many mills are located. SMEs constitute a large part of the European flour milling landscape. These businesses often lack the financial resources, technical expertise, and administrative capacity to navigate complex funding schemes, invest in cutting-edge technologies, or manage the regulatory burden associated with significant decarbonisation efforts, especially concerning large-scale electrical infrastructure upgrades. While electrification is a clear path, the necessary upgrades to electrical infrastructure within mills, the adoption of advanced energy management systems, and the integration of renewable energy sources require substantial capital investment. For thermal processes, mature and cost-effective decarbonisation technologies are still evolving. The EU flour millers operate in a highly competitive global market. Increased operational costs due to decarbonisation investments, particularly if they lead to higher electricity prices, could put European millers at a disadvantage compared to non-EU processors, who may not face similar stringent environmental regulations. This could lead to carbon leakage and undermine the very goals of the Act. To address these, the industry recommends targeted financial support for electrification, robust R&D, guaranteed access to affordable and reliable green electricity through grid investments and power purchase agreements for primary food processors to secure predictable and competitive renewable electricity prices and a dedicated capacity building for SMEs and effective measures like CBAM to prevent carbon leakage and ensure a level playing field.
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Response to Targeted amendment to the CMO and other CAP Regulations strengthening farmers position in the food supply chain

6 Mar 2025

Flour milling is the leading food industry in grain processing in Europe, with more than 3 800 mills and a large majority of SMEs using around 47 million tonnes of wheat, rye and oats each year. A resilient, competitive and sustainable flour milling sector is crucial for ensuring food security and supporting rural economies in Europe. The European Commission's proposed revision clause, allowing farmers to renegotiate contracts longer than six months, presents a significant challenge for flour millers, who rely on hedging in the derivatives market and for the following reasons: 1. Price volatility and hedging Flour millers' business model: Flour millers often enter long-term contracts with farmers to secure a stable supply of wheat at a predetermined price. This allows them to manage their raw material costs and offer predictable prices to their customers (bakeries, food manufacturers, etc.). Derivatives market hedging: To mitigate the risk of price fluctuations during the contract period, millers frequently use derivatives (futures, options) to hedge their positions. They lock in a future price for wheat, matching their purchase from farmers. Impact of revision clause: The revision clause introduces uncertainty into the contracted price. If farmers can demand renegotiation, the miller's locked-in price in the physical contract may no longer align with their hedged position in the derivatives market. 2. Mismatch and financial risk Basis risk: Even without a revision clause, there's always a degree of "basis risk" the difference between the futures price and the local cash price. The revision clause exacerbates this risk. Increased financial exposure: If the farmer successfully renegotiates a higher price, the miller is obligated to pay more for the wheat. However, their hedge may be based on the original contract price. This creates a financial mismatch, potentially leading to significant losses. Difficulty in managing risk: The unpredictable nature of renegotiations makes it extremely difficult for millers to accurately assess and manage their risk exposure. They may have to increase their hedging costs or reduce their hedging activity, both of which can negatively impact their profitability. 3. Disruption to market stability Reduced contract certainty: The revision clause undermines the certainty and predictability of long-term contracts, which are essential for efficient supply chain management. Discouraging long-term agreements: Millers may be less willing to enter into long-term contracts with farmers, opting for shorter-term agreements or spot market purchases. This could lead to increased price volatility and instability in the wheat market. Impact on customer pricing: The increased uncertainty and risk faced by flour millers will likely be passed on to their customers in the form of higher prices or less stable pricing. In summary, the revision clause, while intended to strengthen the position of farmers, introduces significant risks and uncertainties for flour millers who rely on hedging in the derivatives market. It disrupts the stability of long-term contracts, increases financial exposure, and makes it more difficult to manage risk. This could ultimately lead to higher prices for consumers and a less efficient food supply chain. We thank you in advance for your attention to this important matter.
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Meeting with Oliver Schenk (Member of the European Parliament) and AIBI aisbl - International Association of Plant Bakers

5 Dec 2024 · Food Security in the EU (Bread Initiative)

Response to Setting of nutrient profiles

29 Jan 2021

The European Flour Millers' association welcomes the opportunity to comment on the Inception Impact Assessment concerning a revision of Regulation (EU) No 1169/2011 on the provision of food information to consumers. Please find our comments attached.
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Response to Environmental claims based on environmental footprint methods

25 Aug 2020

European Flour Millers welcome this Commission's initiative, as it aims to increase trustworthiness of environmental claims. The EU pilot phase on Product Environmental Footprint (PEF) was designed as a bottom-up process where industry sectors could apply for voluntary participation. So far, only a few food & drink sectors have participated to this phase. In our view, the PEF methodology should help food companies to internally evaluate and better understand the most relevant environmental impacts of their food products. However, product-related information of foodstuffs to end consumers cannot be based on a PEF score alone to empower and enable consumer choice, as relevant aspects of concern for foodstuffs e.g. regarding health and nutrition are not included in its scope or cannot be captured adequately through LCA indicators. Moreover, when it comes to environmentally-friendly food choices, European consumers might need comparison between different food product categories to allow for decisions on effects of substituting e.g. meat through vegetal food to get the right daily amount of proteins or calories - for example in the context of a personalised diet. A recent McKinsey & Co study on agriculture and climate change (April 2020) used kilograms of carbon dioxide production per kilogram of protein, as it could have used caloric (energy) rather than protein content: both will make it more relevant in a context of a consumer environmentally-friendly food choice.
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Response to Farm to Fork Strategy

13 Mar 2020

With some 48 million tonnes of cereals processed each year, the European flour millers are the largest single food users of domestic wheat, rye and oats. The sectors employs over 45 000 people – mostly in SMEs - and an estimated 350 000 indirect labour at European farm level, due to its local sourcing of home-grown cereals and its central position in the food chain. European Flour Millers are a strong supporter of the holistic approach to making the EU food system more sustainable which is being proposed. Work is not starting from scratch. With a central role between ‘Farm’ and ‘Fork’, millers are heavily investing in improving the environmental and nutritional footprint of their products, minimising food losses which are close to zero, while ensuring safe, affordable and high-quality flours. Millers need to secure a regular access to their agricultural raw materials in both quantity and quality. The Common Agricultural Policy (CAP) sets the framework within which cereal producers operate and indirectly impacts the flour milling sector. The CAP must support EU farmers’ income & role with an appropriate budget and incentives to tackle increased environmental and climate change aspects. The area under organic farming will need to increase in Europe and the milling industry strongly supports this objective. Indeed, increasing demand for organic flour-based products and insufficient availability of domestic cereal production so far forces European millers to source part of their needs from extra-EU origins, like for organic bread-making wheat. Climate change is no longer seen as a distant threat and we see climatic conditions that are changing the distribution of pests and diseases severely affecting agricultural production. The EU needs to develop innovative ways to protect harvests from pests and diseases. At the same time, millers acknowledge growing consumer concerns about the use of plant protection products for agricultural raw materials. With many active substances expected not to be re-approved in the coming years, the challenge for food business operators will be to adapt to these developments. Where substances are not re-approved, agricultural practices and sustainable ways to fight pest during storage will have to be adjusted accordingly. This in itself represents a challenge. In this context, we have to consider the potential role of innovative techniques to protect cereal harvests from pests & diseases and improve the sustainability of the food system, while ensuring that they are safe. We believe that cereal breeding innovation have the potential to enhance plants disease resistance, thus reducing the need for pesticides. An adapted regulatory framework for modern breeding techniques should be set without delay. In the absence of clarity on plant breeding techniques, EU farmers and processors will continue to need access to existing authorised plant protection products, where sustainable alternatives do not yet exist. Flour millers produce up to 600 different types of cereal flours each year - essentially consumed as bread. Grain-based products are a major source of sustenance for the population, not only as a source of energy, but also fibre, protein and several important minerals and vitamins. Millers will definitely support the EC initiative to promote the consumption of whole-grain cereal products. Last but not least, European Flour Millers support voluntary Country of Origin Labelling for primary food products, considering the current legal framework is adequate. Blending is essential to the flour milling process: the miller buys, store, blends and mills different types of traced wheat of different qualities - irrespective of the origin. Mandatory country-of-origin labelling can significantly impact the current functioning of our supply chain, for ex. requiring the need for additional silo capacity to cater for each origin, in addition to those existing for quality.
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Response to Enhancing Market transparency in the agri-food chain

17 Jun 2019

European Flour Millers kindly requests the Commission to consider the following aspects of its Proposal on market transparency: First, the processing of agricultural bulk commodities generally requires the transformation of large volumes to reach economies of scale and be profitable. Mills have to manage stocks to supply their continuous transformation process and to optimise the milling capacity. Typically, these are small-margin SMEs. Publishing the wheat flour prices will further limit the already-limited room for manoeuvre afforded to millers in contract negotiations. Second, market price information can be easily misinterpreted and the “most representative” case varies from one Member State to a next, which makes notified prices not directly comparable. Wheat flour prices vary widely, depending on the quality characteristics of the flour, the quantity purchased, the location of the customer relative to the mill, packaging requirements, not to mention wheat costs, hedging policies etc. Furthermore, there are many variations in the style of contract (for example they may be based on the futures’ price; the volume may be fixed, but not the price, or vice-versa; it may be a formal commitment, or not; or could be a spot price agreement). Uninformed extrapolation from these figures, as to the proper functioning of the flour market, could exert downward pressure on the prices of millers and have distortive effects. In practice, a monthly notification regarding wheat flour market prices will be just as transparent, while a weekly notification is not justified and would create unnecessary administrative burden.
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Response to Establishing a legal limit for the industrial trans fats content in foods

29 Oct 2018

The current wording of the proposed trans-fat provision may cause confusion. It can be read to mean that all foods are covered, including all foods to which no trans fat has been added. Moreover, as currently drafted, the provision applies to all substances used in foods including primary foods, such as cereal flours, which may contain negligible fat content. The expectation in practice is that food manufacturers, as a result of this provision, will systematically demand quantitative analysis for suppliers of all food ingredients containing fat, regardless of total fat content. For low-fat primary foods such as presumably wheat flour, this type of analysis is simply an unnecessary cost and burden. It is also analytically complex given the low quantities of fat that might be concerned.
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