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European Poultry, Egg and Game Association

EPEGA

EPEGA ist der Europäische Verband für Geflügel, Eier und Wild.

Lobbying Activity

Response to Tariff quotas with licences

20 Aug 2019

EPEGA is the European Poultry, Egg and Game Association. We are representing the interests of the EU’s egg, poultry and game industry, in particular the wholesalers and foreign traders in these commodities. Thank you for offering the possibility of providing feedback to the Commissions proposal of a draft delegated Regulation “supplementing Regulation (EU) No 1308/2013 of the European Parliament and of the Council as regards the rules for the administration of import and export tariff quotas sub-ject to licences and supplementing Regulation (EU) No 1306/2013 of the European Parliament and of the Council as regards the lodging of securities in the administration of tariff quotas”. The consultations in Brussels on the future management of tariff quotas and the supplementing of Regulation 1308/2013 have largely been completed. For more than four years, EPEGA, which rep-resents the interests of European importers of poultry meat, has been in contact with the relevant representatives of the European Commission and has made constructive contributions at a number of meetings. In doing so, EPEGA explicitly supported the EU Commission’s objective to reduce the number of applicants in a sustainable manner, to maintain control over the quotas, and thus the im-port market, and to ensure sufficient competition within the quota. The planned changes in the management of tariff quotas will lead to massive changes for importers of poultrymeat in their applications for import licences. At this stage, the resulting consequences for economic operators are hardly foreseeable. This is particularly relevant in view of the likelihood of the UK leaving the Europen Union. A hard Brexit will have a massive impact on the EU poultry mar-ket and in particular on importers of poultry meat. In the interests of small and medium-sized im-porters in the poultry meat sector, it is therefore important to achieve legal certainty as soon as possible. EPEGA comments on the delegated act (DA), Article 9 on the reference quantity: Paragraph 1 The restriction of the reference quantity of an operator to 15 % of the quantity available for tariff quota foreseen in the third sentence is viewed positively by the majority, but only on condition that the rules on the declaration of independence laid down in Articles 11 and 12 are strictly complied with and equal treatment is ensured in all EU countries. Paragraph 8 The foreseen suspension of the reference certificate requirement for the fourth quarter where, by the end of the ninth month of a tariff quota period, the quantities applied for under a tariff quota are lower than those still available under that tariff quota is viewed critically by the majority. Due to the very short period remaining until the end of the quota year, the risk of a license forfeiture increases significantly, as the supplier countries face enormous administrative challenges in such a case. In this context, there is an urgent need to specify, who is entitled to apply. From EPEGA’s point of view, only companies that meet the application requirements and are registered in the LORI system are eligible to apply. Otherwise, this regulation would lead to the setting-up of subcontractors.¬ Paragraph 9 This paragraph introduces the possibility for the EU Commission to adopt implementing acts to sus-pend the reference quantity in the event of unforeseeable exceptional circumstances. From the point of view of business representatives, there is an urgent need for precise definition and concrete examples.
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Response to Legal act to apportion certain concessions between the EU and the United Kingdom (Brexit preparedness)

11 Jul 2018

EPEGA represents as leading organisation the interests of importers of poultry meat importers in the European Union. As regards the arrangements for the tariff quotas of poultry meat from third countries after withdrawal of the UK from the EU, EPEGA sees no need for action, to behave generously towards the United Kingdom. The United Kingdom leaves the European Union voluntarily and should be aware of the consequences of the withdrawal. EPEGA favours the option of maintaining poultry meat quotas unchanged in the EU 27 after the withdrawal of the United Kingdom and that the United Kingdom renegotiates its quotas with the third countries. A percentage allocation of the quotas between the EU and the United Kingdom constitutes a discrimination of import-ers in the member states remaining in the EU and could provide incentives for potential imitators. Furthermore, it is of vital importance that trade or import certificates (reference quantities for the quotas that were generated by other EU Member States in the United Kingdom before the Brexit ) will be mutually recognized after the Brexit.
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Response to Amendment of marketing standards for free range eggs

1 Sept 2017

EPEGA is the European Poultry, Egg and Game Association. We are representing the interests of the EU’s egg, poultry and game industry, in particular the wholesalers and foreign traders in these commodities. Traceability, food safety, animal welfare and quality controls are of major importance for the members of the association. Thank you for offering the possibility of providing feedback to the Commissions proposal of a draft delegated Regulation “amending Regulation (EC) No 589/2008 as regards marketing standards for free-range eggs where hens' access to open air runs is restricted”. In many EU-Member States egg producers invested considerable amounts in animal-friendly husbandry systems complying in this way to consumer demand for eggs produced in conditions considering animal welfare. During this year's spring, authorities in numerous regions ordered due to the outbreaks of Highly Pathogenic Avian Influenza to keep poultry indoors to protect the poultry population against a further spread of the epidemic. In many cases the order to keep poultry in-doors exceeded largely the relevant time limit of 12 weeks for the marketing of free-range eggs. As the availability of free-range eggs has been limited for a longer time period, their market share has fallen significantly and did not recover completely until now. We therefore expressly welcome the proposal of the EU-Commission to extend to 16 weeks the transitional time period for the marketing of free-range eggs during the official order of keeping poultry indoors and to apply it based on the group of hens. This will help to contain the market distortions observed during the last epidemic. However, EPEGA would have welcomed, if the EU-Commission had considered also another cri-teria for a differentiation between free-range and barn eggs , i.e. the cold scratching area. Additionally, we request the EU-Commission, to amend point 1.a) second indent in the Annex II of the text of the published proposal amending the marketing norms for eggs. In the proposal the ex-tension of the time limit for the marketing refers exclusively to official orders to keep poultry in-doors. The valid wording so far "In case of other restrictions“ is not included in the proposal. This would mean, in our opinion, that other exceptional circumstances, such as floods or exceptional weather conditions, would lead to the hens staying in the barn without a transitional period before the loss of the free-range status. Only the official order to keep poultry indoors are imposed on the basis of EU law (namely EU veterinary Law). For all other restrictions, such as extreme weather, there is no legal basis. With the present wording of the proposal the marketing norms for eggs would be changed in sub-stance and this is not intended according to the EU-Commission. EPEGA declares its interest as a stakeholder to take part in further consultations and is ready to contribute to studies undertaken. We agree to the publication of our statement.
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Response to Evaluation of marketing standards [Regulation (EU) No 1308/2013]

25 Jul 2017

EPEGA is the European Poultry, Egg and Game Association. We are representing the interests of the EU’s egg, poultry and game producers, wholesale business and foreign trade in these commodities. Traceability, food safety, animal welfare and quality controls are of major importance for the members of the association. Thank you for offering the possibility of providing feedback to the Commission “Roadmap” on the evaluation of Regulation (EU) No. 1308/2013 on common marketing standards (COM-Regulation), the Commission implementing measures taken on its basis and the so-called “breakfast directives”. On the basis of the CMO-Regulation, two Regulations were published that are of particular concern to our members. These are: • Commission Regulation (EC) No. 543/2008 of 16 June 2008 laying down detailed rules for the application of Council Regulation (EC) No 1234/2007 as regards the marketing standards for poultrymeat • Commission Regulation (EC) No. 589/2008 of 23 June 2008 laying down detailed rules for implementing Council Regulation (EC) No 1234/2007 as regards marketing standards for eggs Our sector has worked well with these Regulations. The CMO-system is a safe set of rules genuinely helpful by providing orientation and should therefore be maintained within its extant scope. We do not see any need for extending the rules of the CMO to apply on processed foods for which horizontal rules of food law are sufficient. However, we perceive the need to have the CMO-Regulations cautiously updated and optimised. Two points in particular we wish to raise: 1. Physiological water-content in poultrymeat: Significant progress has been made since the 1990s in breeding new stocks of poultry that result in a different water-/protein-ration in poultrymeat. Annex VIII of Regulation (EC) No. 543/2008 should therefore be adapted to the new reality created by new breeds. 2. Minimum requirements for the production of free range eggs. Annex II No. 1(a) of Regulation (EC) No. 589/2008, when establishing that hens must have continuous daytime access to open-air runs, at the same time allows producers to limit access to a period of time in the morning hours “in accordance with usual good farming practice, including good animal husbandry practice”. It would be helpful to have more clearly stated what constitutes good practices in this context as lack of clarity has led to misunderstandings in practice. EPEGA declares its interest as stakeholder to take part in further consultations and is happy to contribute to studies undertaken. We agree to the publication of these statements.
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