European Snacks Association
ESA
The European Snacks Association is Europe’s only trade organisation dedicated to the advancement of the savoury snacks industry on behalf of its members.
ID: 00849042167-65
Lobbying Activity
Response to Food and Feed Safety Simplification Omnibus
13 Oct 2025
The European savoury snacks sector welcomes the European Commissions commitment to streamline and modernise EU legislation to improve competitiveness and reduce unnecessary burdens for businesses. As a committed, transparent and dynamic industry, actively engaged in the transition towards more sustainable food systems, we believe that better regulation and simplification must go hand in hand with maintaining high food safety standards and fostering innovation. Savoury snacks manufacturers and their suppliers, including many SMEs, needs clearer, more proportionate rules to grow, invest and remain competitive. As outlined in recent reports, further protecting and strengthening the Single Market will be a determining factor of success. In our contribution, we outline several areas where targeted actions on food law and related legislations could reduce unnecessary administrative burdens, improve legal clarity, and introduce proportionate regulatory measures.
Read full responseMeeting with Ariane Vander Stappen (Head of Unit Health and Food Safety)
12 May 2025 · Discussion on the food and nutrition files
Meeting with Tom Vandenkendelaere (Member of the European Parliament, Shadow rapporteur)
2 May 2023 · Packaging & packaging waste
Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
6 Apr 2023
The European Snacks Association asbl (ESA) is Europes only trade organisation dedicated to advancing the savoury snacks industry on behalf of member snack manufacturers and suppliers, as well as national trade organisations. Our members support the objectives of promoting a transition to a circular economy model and are striving to manufacture products with packaging that maximise the use of resources and minimise waste, while constantly ensuring the optimum safety and quality of the food. The majority of savoury snacks are packaged using flexible laminated plastic films because they are one of the most resource-efficient options which are currently available. While manufacturers intend to continue to invest resources to offer more sustainable packaging solutions, we would like to emphasise from the outset that the ambition to achieve efficient circularity for flexible packaging cannot happen without the development of services and infrastructures to properly collect, sort and recycle, which are lacking across the European Union (EU). Current barriers to recycling processes and technologies (such as chemical recycling) are also hampering the development of innovative solutions for packaging. We believe that the European Commissions proposal for a Packaging and Packaging Waste Regulation, notably by addressing the above shortcomings, could represent a significant step towards a circular economy for packaging - including flexible plastic packaging - and hence contributing to the European Unions climate neutrality goal and the Green Deal objectives. We have prepared a document in attachment providing an overview of the elements of the proposed Regulation which should be modified or further improved to achieve the desired outcomes.
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
21 Feb 2022
The European Snacks Association asbl (ESA) is Europe's only trade organisation dedicated to advancing the savoury snacks industry. The majority of savoury snacks are packaged using flexible laminated plastic films because they are one of the most resource efficient options which are currently available.
Our members are striving to manufacture products with packaging that maximise the use of resources, minimise waste and which can be recycled to achieve greater circularity. While they intend to continue to invest resources to develop innovative packaging technology, several obstacles prevent operators to reach a fully circular model for flexible packaging.
We therefore support the objectives of the review of the Waste Framework Directive (WFD) and welcome the opportunity to provide inputs to this call for evidence as we believe some of the current barriers can be lifted with the reinforcement of existing measures and additional provisions.
- First, we would like to emphasise that achieving circularity for flexible packaging cannot happen without the development of infrastructures to properly collect, sort and recycle, which are lacking across the European Union (EU). If collection and segregation of plastic film could be introduced at scale and promoted to consumers then the recycling technologies will become financially viable and will lead to a reduction in waste disposal of these materials.
- Setting ambitious enough recycling targets at Member States level, for plastics in general and also possibly for packaging type, e.g. for flexible packaging, will help in driving further collection, sorting and recycling of plastics. This will encourage the entire waste system to take the necessary actions to meet the targets. This should be complemented as soon as possible by an effective landfill ban across the EU for waste that can be technically collected, sorted and recycled. Energy recovering (incineration) should become the very last resort and should be discouraged.
- Enforcing and mandating separate collection to make sure flexible plastic packaging is separated from mixed waste and properly and systematically collected is instrumental and should be implemented in all EU countries. Flexible packaging can be collected together with other plastics, with metal and cartons. This goes hand in hand with clear sorting instructions for consumers (e.g. local/national information campaigns, on-pack instructions - ideally harmonised at EU level) so they can play their role in the waste management system.
- Extended Producer Responsibility (EPR) fees should be specific enough to reflect the real and net cost of processing each material type. Producer Responsibility Organizations (PROs) have a pivotal role in the process and the implementation of “fee-modulation”, which takes into account the actual costs of collection, sorting and recycling of a particular type of packaging, will stimulate the recycling of flexible packaging and contribute to make it profitable. This will imply higher EPR-fees for producers. These additional contribution should be clearly earmarked to stimulate increased processing of flexible packaging.
- Investments in recycling technologies, such as chemical recycling, is instrumental to allow achieving virgin-like quality of plastics and satisfy safety issues for food contact materials. Today, it is not allowed to use mechanically recycled plastics in food contact flexible packaging. Realising the potential of chemical recycling would allow for recycled plastics to be used in food contact flexible packaging.
- Free movements of waste and recycled material should be ensured to support investments into the recycling infrastructure for flexible packaging. Not every Member States will be equipped with the proper recycling infrastructures in the short- to mid-term and the plastics waste collected and sorted in a given country should be able to travel within the EU to be recycled in another country.
Read full responseResponse to Setting of nutrient profiles
1 Feb 2021
European Snacks Association asbl (ESA) is Europe's only trade organisation dedicated to advancing the savoury snacks industry on behalf of member snack manufacturers and suppliers, as well as national trade organisations. ESA members are involved in the manufacture of potato crisps, corn chips /tortillas, pellet snacks, baked snacks, crackers, pretzels, savoury biscuits, popcorn, pork rinds, meat snacks, fruit snacks, peanuts, other snack nuts and various other savoury snacks in this category.
ESA welcomes the opportunity to provide comments on the Inception Impact Assessment (IIA) on the Proposal for a revision of Regulation (EU) No 1169/2011 on the provision of food information to consumers (enclosed) and remains at the Commission’s disposal to provide any further information.
Read full responseResponse to List of composite products exempted from official controls at border control posts
29 Jan 2021
European Snacks Association asbl (ESA) is Europe's only trade organisation dedicated to advancing the savoury snacks industry on behalf of member snack manufacturers and suppliers, as well as national trade organisations. ESA members are involved in the manufacture of potato crisps, corn chips /tortillas, pellet snacks, baked snacks, crackers, pretzels, savoury biscuits, popcorn, pork rinds, meat snacks, fruit snacks, peanuts, other snack nuts and various other savoury snacks in this category.
ESA welcomes the opportunity to provide comments on the consultation “Food safety - composite food products exempt from official checks at EU borders”(enclosed) and remains at the Commission’s disposal to provide any further information.
Read full responseResponse to Revision of EU rules on food contact materials
28 Jan 2021
European Snacks Association asbl (ESA) is Europe's only trade organisation dedicated to advancing the savoury snacks industry on behalf of member snack manufacturers and suppliers, as well as national trade organisations. ESA members are involved in the manufacture of potato crisps, corn chips /tortillas, pellet snacks, baked snacks, crackers, pretzels, savoury biscuits, popcorn, pork rinds, meat snacks, fruit snacks, peanuts, other snack nuts and various other savoury snacks in this category.
ESA welcomes the opportunity to provide comments on the Inception Impact Assessment (IIA) on the Revision of EU rules on food contact materials (enclosed) and remain at the Commission’s disposal to provide any further information.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
5 Aug 2020
The European Snacks Association asbl (ESA) is Europe's only trade organisation dedicated to advancing the savoury snacks industry on behalf of member snack manufacturers and suppliers, as well as national trade organisations.
ESA members are involved in the manufacture of potato crisps, corn chips /tortillas, pellet snacks, baked snacks, crackers, pretzels, savoury biscuits, popcorn, pork rinds, meat snacks, fruit snacks, peanuts, other snack nuts and various other savoury snacks in this category.
Our members support the objectives of promoting a transition to a circular economy model and are striving to manufacture products with packaging that maximise the use of resources and minimise waste, while constantly ensuring the optimum safety and quality of the food.
ESA welcomes the opportunity to submit its views to the inception impact assessment on the review of the requirements for packaging and other measures to prevent packaging waste.
Read full responseResponse to Temporary measures on entry into the Union of certain goods
5 Jul 2019
General comment:
• The move of safeguard to a 6-month review period – which means a more regular review period – is much appreciated.
Specific comments:
As the Commission doesn't seem to have the intention to develop a guidance document and changes to the future regulation are not anticipated; please find below comments concerning the implementation of the future regulation:
• How to define that controls are necessary? There is a need to define criteria for a “known or emerging risk” and “evidence of widespread serious non-compliance”.
• E.g. how is “wide-spread” to be defined? Is it based on the amount of countries/ports experiencing non-compliance or the percentage of imports?
• Will company-own checks be considered or will it apply only to official boarder check (local vs EU consideration)?
• Request clarity on the percentage of inspections versus consignments received and tested.
• What will be the criteria for including/delisting (not anticipated to be “definitive” or prescriptive)?
• Are ports prepared for increased controls (management of consignments/demurrage) in sufficient time?
We are happy to provide more detailed comments in case the above ones are not self-explanatory enough.
Read full response6 Jul 2017
The European Snacks Association (ESA) welcomes the opportunity to provide comments on the European Commission’s proposal for a regulation establishing mitigation measures and benchmark levels for the reduction of the presence of acrylamide in food.
ESA supports legislation in this area which would legally oblige food businesses to apply mitigation measures, as part of their existing food safety management systems, to reduce acrylamide levels in their finished products.
For potato crisps the mitigation measures include requirements on agronomy and storage, recipe design, and process design. They require businesses to regularly test products and ingredients, to trial new mitigation strategies where appropriate, and to maintain records to demonstrate use of these controls.
Application of these tools can help manufacturers mitigate acrylamide formation, and their use has resulted in significant reductions in detected levels within our members’ products (1). Mandatory application of these measures by all potato crisp manufacturers should therefore lead to reductions in mean levels across Europe.
We note and support comments submitted by our colleagues at FoodDrinkEurope, and in this response we have focused solely on the mitigation measures as they apply to our products and to the related benchmark levels. We hope these comments can be considered as improvements to help in the application of the measures.
Annex 1. I. PRODUCTS BASED ON RAW POTATOES
Selection of suitable potato varieties 1 (Annex page 2).
Suggest text is amended to read “Food business operators (hereinafter ‘FBOs’) shall identify and use the potato varieties that are suitable for the product type and where the content of acrylamide precursors, such as reducing sugars (fructose and glucose) and asparagine is the lowest for the regional conditions.”
Potato Storage and transport 2 (Annex page 2)
Suggest change to read “Potato lots shall be monitored…”
Potato Storage and transport 3 (Annex page 2)
Suggest change to read “FBOs shall define transport specifications in terms of temperature and duration, especially if outside temperatures are significantly cooler than storage. These specifications should be documented.”
Annex IV Benchmark Levels (Annex page 20)
We are very concerned that the proposed benchmark level for potato crisps made from sliced potatoes is 750 μg/kg. We believe that this level is simply too low for it to be achievable for FBOs across the full year, especially given seasonal and regional differences across Europe.
The 750 μg/kg figure appears to be based solely upon the aggregated data supplied by ESA members, where awareness of the mitigation measures is very high and data from across Europe is pooled. It does not reflect the typically higher values that have been reported by member states (85th percentile at 991 μg/kg) and within some regions as a result of local environmental conditions. Setting the benchmark at this level is likely to significantly disadvantage FBOs in countries with shorter growing seasons and a greater reliance upon stored raw materials.
Whilst we believe it is appropriate to set challenging benchmark levels, these need to be realistic and achievable across the whole of Europe and for the full year, hence we strongly urge the Commission to reconsider the proposed benchmark level for this category of products.
(1) Acrylamide concentrations in potato crisps in Europe from 2002 to 2011, Food Additives and Contaminants http://www.tandfonline.com/doi/abs/10.1080/19440049.2013.805439
Read full responseMeeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis), Paula Duarte Gaspar (Cabinet of Commissioner Vytenis Andriukaitis) and
5 Apr 2017 · Food safety, Nutrition and health, Responsible advertising to children