Federation Europeenne Des Emballeurs Et Distributeurs De Miel - European Federation of Honey Packers and Distributors
F.E.E.D.M.
F.E.E.D.M.
ID: 582140813388-26
Lobbying Activity
Response to Further reciprocal tariff liberalisation under Art. 29 of the EU-Ukraine Association Agreement
30 Sept 2024
Key message: F.E.E.D.M. supports the further liberalisation of trade in goods with Ukraine, especially the full liberalisation of honey trade resulting in a permanent duty free status for honey imports from Ukraine without further safeguard measures. About F.E.E.D.M.: F.E.E.D.M. represents the interests of the European honey packers and distributors. The members of F.E.E.D.M., being from 21 countries, commit themselves to the integrity and quality of the products, which are subject to their business. We represent about 80 % of the entire European honey import market. Current situation for honey: Ukraine is one of the most important honey suppliers for the EU, as about 40 % of the European honey demand must be imported. Before the start of Russia's war of aggression against Ukraine, honey was subject to a duty-free import quota of 6,000 tons per year into the EU based on the Deep and Comprehensive Free Trade Area of EU and Ukraine. Honey from Ukraine is of good, consistent quality and prior to 2022 the Ukrainian honey volume was sufficient to partly satisfy the demand for honey in the EU. Honey is one of the agricultural products falling under the safeguard measures mentioned in Regulation (EU) 2024/1392. As the safeguard measure has been triggered on 21st of August 2024, the standard duty-rate of 17.3 % currently applies to honey imports from Ukraine. Disadvantages of the quota system: As Ukraine is already associated with the EU in a certain way, duties should be eliminated without any quota. This would help to stabilise honey production and honey trade at the same time. The above-mentioned quota system has led to very speculative trading without any significant disadvantages for EU honey producers or benefits for Ukrainian honey producers. The quota has led to volatility in prices and unregular buying activities. Clear rules for honey imports without temporary restrictions would offer more stability for all participants in the market and would allow the market to act on behalf of offer and demand and not according to political measures. Market competition and composition: The competitiveness of honey from Ukraine and the need of the market will determine the share of honey imports from Ukraine and/or from other third countries. If honey from Ukraine was temporarily more competitive than honey from other origins, an impact on the import share might result. However, this does not mean that honey from Ukraine will generally replace or limit the use or import of honey from other origins only if it is free of duties and safeguard measures. Responsibility of the EU: Besides the economic arguments, the Commission should consider the ethical argument of supporting the Ukraine in enduring the war and rebuilding afterwards, by stimulating the production of agricultural goods and supporting trade and demand from local beekeepers, cooperations and exporters in the Ukraine. Consumer demand: Considering the recently completed revision of the labelling requirements under the European Honey Directive, it also became clear that consumers prefer more transparency and locally sourced goods. Thus, European importers should be encouraged to source honey from European countries and not for example from Asia. This could be achieved by permanently exempting Ukrainian honey from duties, quotas, and safeguard measures. Conclusion: We therefore would support the idea to liberalise honey trade between Ukraine and the EU without duties and without any safeguard measures. The EU is a net importer of honey. The honey market participants will not import an oversupply from Ukraine. The past years, with or without duties, have shown, that the imports from Ukraine are stable. The Commission informs the stakeholders regularly in the Civil Dialogue Group Meetings about the honey market via statistical data. Additionally, honey from Ukraine will not be able to satisfy all needs for different varieties of honey. Best regards, F.E.E.D.M.
Read full responseMeeting with Alexander Bernhuber (Member of the European Parliament, Rapporteur) and Fachverband der Nahrungs- und Genussmittelindustrie
15 Nov 2023 · Breakfast directives
Response to Revision of EU marketing standards for agricultural products
16 Jun 2023
F.E.E.D.M. Statement Re.: Proposal for a Directive of the European Parliament and of the Council amending amongst others Council Directive 2001/110/EC relating to honey. F.E.E.D.M. welcomes the opportunity to submit its position within the framework of the consultation process with regards to the revision of the EU Honey Directive (2001/110/EC). Please see theattached document for the detailed elaboration of our position. In summary, F.E.E.D.M. welcomes the proposal of the EC for the amending Directive and the new labelling requirements the EC defined. F.E.E.D.M. calls on the EC to offer companies the possibility of labelling their products with the ISO 3166 alpha-2 codes, extend the exemption of small portion packs to packs with up to 30 g content and provide a longer transition period for the implementation for the new labelling rules. However, F.E.E.D.M. strongly opposes any attempts of including the requirement of labelling the countries of origin in descending order or the indication of percentages in honey blends for the in the attached document mentioned reasons. Thank you for considering the position of our sector. We are at your disposal for a further exchange. Best regards, F.E.E.D.M.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
24 Apr 2023
F.E.E.D.M. Statement EU proposal for a revision of the EU legislation on Packaging and Packaging Waste F.E.E.D.M. welcomes this public consultation and the opportunity to provide comments on the Commissions proposal for a revision of the EU legislation on Packaging and Packaging Waste. F.E.E.D.M. represents the interests of the European honey packers and distributors, mainly small and medium-sized enterprises (SME). The priority of the association is to defend and promote honey as a pure and natural product. The association supports good apiculture practices and aims at improving the quality standards of the product. The members of F.E.E.D.M. commit themselves to the integrity and quality of the products, which are subject to their business. Planned ban on single-use portion packs in the HORECA sector (hotel, restaurant, catering): F.E.E.D.Ms proposal is for a continued allowance of single-use honey portion packs, especially in sensitive areas (e.g. hospital, military). Reasonable transition periods against food waste are essential.
Read full responseResponse to Cascade system for the control of residues
1 Nov 2017
This proposal of a Regulation intends to solve properly a loophole in the European legislation as regards animal welfare, helping the veterinarian Authorities to manage properly the possibility to cure food producing animals, in particular to avoid causing unacceptable suffering, as established under Article 11 of Directive 2001/82/EC. At the same time consumer protection is granted by taking the lowest possible MRL as reference point while creating legal security for operators, especially in case of minor species for which MRLs are often missing. We therefore support the proposal as it allows a harmonized handling of residues at EU level while respecting the interests of consumers.
The lack of Maximum Residue Limits (MRLs) for substances listed in table 1 of the Annex of EU Regulation 37/2010 has led in some Member States to a “zero tolerance” policy. The result is an uneven application of Community legislation within the European Union. Furthermore the rapid technical developments during the past years have led to very low detection limits for traces of substances detected in honey. These low limits are perceived as non-proportionate, when considering the MRLs set for other animal products (e.g. milk, meat). The discrepancies of analytical methods and technical standards within the EU Member States further result in a different application of Community legislation within the EU. In addition the lack of MRLs for honey at import level leads to an inconsistent handling at the border inspection.
Honey regarded as marketable in one Member State can become rejected in another member state. This unfavorable situation of legal uncertainty hinders up to day the trade and constitutes an incalculable obstacle in doing daily business. Therefore legal safety is required to the benefit of all parties involved and could finally be achieved by the proposed Regulation.
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