Federation of European Rice Millers
FERM
•To promote and defend the interests of Europe’s rice milling industry.
ID: 31958409365-30
Lobbying Activity
Response to Legislation for plants produced by certain new genomic techniques
4 Nov 2023
FERM (Federation of the European Rice Millers) appreciates the proposal for a regulation on plants obtained by certain new genomic techniques (NGTs). We welcome the progress made towards a product-based approach, which aligns with the long-standing proposal from academia and industries. While we acknowledge the distinction made between conventional-like products and others, we have concerns regarding the measures for conventional-like NGT products, referred to as category 1. Despite the recognition that NGT plants could occur naturally or be produced by conventional breeding as stated in recital 14, we believe that the proposed measures are discriminatory when compared to conventional products or those listed in Annex IB to Directive 2001/18/EC, even if verified as equivalent. Under the assumption of equivalence, we don't see a good justification for the labelling of category 1 seed material. In fact, we are concerned that seed labelling opens up the possibility of requirements for conventional-like varieties being passed on from seed to raw materials to final products. This not only risks consumer acceptance, but also creates complications for imports from third countries. The risk of non-compliance of imports is especially high for organic products. The cultivation of conventional-like NGT plants is allowed without restriction in an increasing number of countries around the world. Detection of conventional-like NGT plant material is virtually impossible, thus it remains open how controls, including contamination, should be handled. The risk of non-compliance and administrative burden do not seem in line with the acknowledged safety of conventional-like NGT plants and their products. The terms "declaration" and "verification" are being used interchangeably throughout the proposal, we believe they carry distinct meanings. The approach for the purpose of official controls towards unwanted contaminations remains unclear. If the legislation allows NGT plant production in the European Union, the current tolerance threshold for GM events may become unrealistic in cases of cross-contamination with NGTs. In contrast to notification, the verification process is foreseen as complex and burdensome and potentially opened for a level playing field distortion. Special attention should be paid to the proper enforcement of labelling rules and potential individual or national initiatives such as NGT-free, disturbing a level playing field. Regarding category 2 products, we believe the proposed measures are akin to the current GMO approach, which is not fit for purpose. In practice, it is unlikely that a significant amount of these products would enter the market due to high authorization costs and potential consumer rejection based on unjustified negative perceptions. The criteria for equivalency listed in the Annex I should be considered as a minimum for plants and potentially other organisms to be regulated in the future. Larger or more complex genomes (e.g., ploidy) should be subject to additional considerations (e.g., increased thresholds), in order to benefit from the regulation. The phrase "in any DNA sequence sharing sequence similarity with the targeted site that can be predicted by bioinformatic tools" requires clarity and refinement as it is open to interpretation. Point 3 - "insertion or substitution without interruption of an endogenous gene" - needs clarification. An insertion of a new coding section after a promoter should not be considered an interruption, as the coding section is not interrupted. A precise definition is required for the term "contiguous DNA sequence". Does it imply a single function? Could it encompass a promoter from species A combined with a coding section from species B in the same DNA sequence? Point 5, concerning the "resulting DNA sequence," requires further elaboration. We understand "possibly" as "not restricted to." Thank you for your attention.
Read full responseResponse to Sustainable use of pesticides – revision of the EU rules
19 Sept 2022
FERM – the Federation of European Rice Millers - welcomes the initiative of the Commission services to modernize legislation on the use of plant protection products (PPP). FERM is fully supporting the ambition of the commission services to protect the environment as well as to achieve the highest standard regarding the safety of the food chain and the protection of consumers.
FERM would however like to raise some specific concerns on the proposal, which are discussed in the attached position paper.
Read full responseResponse to Setting of nutrient profiles
2 Feb 2021
Origin labelling
The European rice industry is committed to providing useful and relevant information about rice products to European consumers. Around 40% of rice products on the European market today contain information relating to origin provided on a voluntary basis. This choice to include voluntary labelling of origin generally reflects the characteristics of the rice. Certain types of rice have specific qualities or are conducive to different types of cooking e.g. rice for making risotto, paella, or aromatic rice from Asian origin such as basmati or fragrant jasmine. A mandatory requirement to identify the EU/non-EU origin of rice would be acceptable, with more specific information regarding country of origin to be provided on a voluntary basis where relevant.
Date marking
Ensuring that consumers do not unnecessarily discard food due to misconceptions about its safety after a given date can make an important contribution to reducing food waste. We would generally agree with the Commission’s view that rice could be included on the list of products for which the "best before" date is not mandatory. However, there are situations where a best before date on rice is in the interest of the consumer e.g. for brown rice (due to the higher oil content in the bran (the outer shell) which has not been removed during milling). The possibility to include a "best before" date on rice must therefore be maintained.
Read full responseResponse to Establishing a legal limit for the industrial trans fats content in foods
31 Oct 2018
The Federation of European Rice Millers kindly requests the Commission to consider the following two aspects of its proposal on industrial trans fats:
1. Legal clarity
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. However, Article 8 of Regulation 1925/2006 establishes that Annex III refers to substances "added to foods or used in the manufacture of foods under conditions that would result in the ingestion of amounts of this substance greatly exceeding those reasonably expected to be ingested under normal conditions of consumption". Likewise, the title of Annex III refers to "substances whose use in foods". For consistency, the provision should read:
"The content of trans fat, other than trans fat naturally occurring in animal fat, added to or used in foods intended for the final consumer, shall not exceed 2 grams per 100 grams of fat."
If the final food has to be the reference point in this provision, another more appropriate legal basis than Regulation 1925/2006 should be sought.
2. Unnecessary burden on suppliers of low-fat food ingredients
As currently drafted, the provision applies to all substances used in foods including foods, such as rice (typically <1% total fat per 100g), which 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 food ingredients, this type of analysis is simply an unnecessary cost and burden. It is also analytically complex given the low quantities of fat concerned.
Such foods should therefore be excluded from this requirement. One option is to provide a derogation for "low fat" foods as defined by the Annex of Regulation 1924/2006 (<3g fat per 100 g for solid food and 1.5 g fat for liquid food" e.g.:
"With the exception of trans fat in low-fat foods, the content of trans fat, other than trans fat naturally occurring in animal fat, added to or used in foods intended for the final consumer, shall not exceed 2 grams per 100 grams of fat."
Read full responseMeeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan), Dermot Ryan (Cabinet of Commissioner Phil Hogan) and Confederazione Generale dell'Agricoltura Italiana
11 Oct 2016 · regulation of tricyclazole and its impact on the rice sector
Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)
21 Jan 2015 · Impact of duty-free rice import from EBA countries