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Food Fermentation Europe

FFE

Food Fermentation Europe acts as the unified voice representing the transformative fermentation food and food ingredient sector.

Lobbying Activity

Meeting with Olivér Várhelyi (Commissioner)

8 Dec 2025 · Strengthening the EU’s competitiveness and innovation through biotechnology and advanced fermentation

Meeting with Klaus Berend (Director Health and Food Safety)

8 Dec 2025 · European Biotech Act.

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)

4 Nov 2025 · Bioeconomy Strategy, and the forthcoming Biotech Act

Meeting with Anna Strolenberg (Member of the European Parliament)

4 Nov 2025 · Event Food fermentation Europe

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen)

4 Nov 2025 · attached

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen)

4 Nov 2025 · Exchange on the fermentation industry’s contribution to the EU’s competitiveness and strategic autonomy and the forthcoming Biotech Act

Meeting with Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné)

4 Nov 2025 · Food biotechnology

Response to Food and Feed Safety Simplification Omnibus

14 Oct 2025

Food Fermentation Europe (FFE) welcomes the Commissions initiative to simplify and clarify EU food and feed safety legislation. We strongly support the inclusion of a clarification on the regulatory status of fermentation products manufactured with genetically modified micro-organisms (GMMs). This issue has created significant legal uncertainty for innovators, investors, and Member State authorities. 1. Clarification on scope of Regulation (EC) No 1829/2003 The decisive regulatory criterion should remain the presence of viable production strains in the final product. Fermentation products manufactured in contained use, where no viable cells are present, should remain outside the scope of Regulation 1829/2003. This interpretation has been consistently applied for years and should be maintained to avoid fragmentation of the Single Market. 2. Treatment of recombinant DNA The mere presence of recombinant DNA does not constitute a safety risk. DNA without sequences of concern cannot replicate or transfer traits. Therefore, residual DNA should not become a regulatory criterion. Its consideration should be limited to product-specific safety assessments where full-length genes of concern (e.g. antibiotic resistance genes critical to human health) are involved. We recognise the Commissions political compromise around an analytical threshold (10 ng/g LOD), but stress that this should not be treated as a blanket regulatory trigger. 3. Biomass products Biomass products spent biomass streams or inactivated biomass containing nutritional components are essential to improve resource efficiency, competitiveness, and the circular bioeconomy. Subjecting these to the same regulatory regime as products with viable cells is disproportionate and scientifically unjustified. Where biomass contains inactivated GMM, case-by-case EFSA assessment is appropriate, but full GM food/feed procedures are neither necessary nor feasible given the frequency of production strain updates and the low-risk profile of inactivated material. 4. Need for harmonisation Divergent Member State practices, where residual DNA has been used as a criterion for enforcement, are creating confusion and market disruption. The Commission should provide a clear interpretative document to harmonise implementation across the EU. At the same time, biomass valorisation can support the growth of a sustainable circular bioeconomy by creating new opportunities for European farmers, with agricultural byproducts upcycled into high-value food ingredients. Conclusion FFE strongly supports the Commissions proposal to clarify the status of fermentation products produced with GMMs. Maintaining the criterion of viable cells only under Regulation 1829/2003, limiting DNA considerations to safety assessments, and ensuring proportionate treatment of biomass products will provide legal certainty, reduce administrative burden, and enable Europe to compete globally in biotechnology and sustainable food production.
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Response to European Innovation Act

3 Oct 2025

Food Fermentation Europe (FFE) represents companies developing precision and biomass fermentation solutions for food and feed. We welcome the European Commissions ambition to design a European Innovation Act that strengthens Europes competitiveness, closes the innovation gap with global peers, and creates an environment where start-ups and scale-ups can thrive. For our sector such an initiative is urgently needed. 1. Regulatory fragmentation and uncertainty Our members face diverging interpretations of EU legislation across Member States, particularly regarding the regulatory status of fermentation-derived products. This fragmentation undermines the functioning of the Single Market, increases compliance costs, and discourages cross-border investment. A key priority for the Act should be to harmonise definitions, provide clear legal frameworks, and ensure consistent enforcement. 2. Innovation-friendly regulatory tools An innovation stress test for legislation, paired with more systematic use of regulatory sandboxes, would enable safe piloting of new food technologies under real market conditions. Sandboxes are particularly relevant for fermentation, where scale-up requires significant infrastructure investment and regulatory predictability. 3. Access to finance and scaling infrastructure Precision and biomass fermentation are capital-intensive. SMEs and start-ups struggle to finance pilot and demonstration plants because traditional financiers perceive the sector as high risk. Unlocking the use of intellectual property as collateral, blended finance mechanisms, and EU-level de-risking tools (e.g. guarantees, IPCEI for food biotechnology) should be explicit objectives of the Act. Dedicated instruments bridging the valley of death from R&D to industrial scale-up are critical. 4. Knowledge transfer and public assets Much of the relevant research originates from publicly funded programmes. Yet commercialisation is slowed by fragmented IPR regimes and limited access to shared infrastructures. The Act should mandate streamlined access to technology infrastructures, harmonised IPR rules, and incentives for academiaindustry collaboration. 5. Public and private procurement as a driver Innovation-friendly procurement can play a decisive role in anchoring novel food technologies in Europe. Public procurement in schools, hospitals and institutions should be designed to include sustainable protein diversification options, sending strong demand signals that crowd in private investment. 6. Coordination of innovation policy Europes innovation landscape is still fragmented between EU and national levels. The Act should establish a robust mechanism to coordinate innovation strategies, funding, and regulatory practices across Member States, ensuring predictable conditions for companies scaling across borders.
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Meeting with Tilly Metz (Member of the European Parliament)

14 Jul 2025 · Food Fermentation

Meeting with Giulia Del Brenna (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

30 Jun 2025 · Opportunities and challenges in the fermentation sector

Response to Towards a Circular, Regenerative and Competitive Bioeconomy

23 Jun 2025

As the Commission advances the Bioeconomy sector to accelerate the journey of biotechnology from laboratory to market, Food Fermentation Europe (FFE) calls to explicitly include food and fermentation-enabled biomanufacturing in its scope. 1. Integrate food innovation as a core pillar of the EU's Circular, Regenerative and Competitive Bioeconomy Food biotechnology has been recognised by the European Commissions as a strategic technology under the Strategic Technologies for Europe Platform (STEP), highlighting its importance for economic resilience and innovation. To realise its potential, the Bioeconomy Strategy must explicitly include food biotech within its scope. A holistic approach should cover all relevant food biotechnologies, including precision fermentation and biomass fermentation, which enable the production of high-quality, animal-free ingredients with significantly lower environmental impacts. These technologies can play a vital role in strengthening Europes food sovereignty, reducing import dependence, and positioning the EU as a leader in sustainable food system transformation, notably through the growth of a sustainable, circular bioeconomy where agricultural byproducts are upcycled into high-value food ingredients. 2. Reform the Novel Foods regulatory pathway Despite EU leadership in food biotechnologies research & development, Europe risks losing its industry to faster-moving regions due to prolonged approval timelines, the lack of scientific pre-submission support and unclear thresholds that can reclassify fermentation products as GMOs. The EU Bioeconomy must address these gaps to retain and grow Europes domestic food biotech industry. We therefore call for the adoption of a Bioeconomy strategy that commits to making the process more transparent, predictable and innovation-friendly, without compromising safety. 3. Create dedicated funding for scaling-up food biomanufacturing The absence of scale-up financing for biotechnologies in food is a critical issue. While the European Innovation Council (EIC) and the Circular Bio-based Europe Joint Undertaking (CBE JU) fund early-stage research, and an ICPEI on Biotechnology is under discussion, no EU mechanism currently supports commercial-scale fermentation production. The Strategy should establish a dedicated scale-up support mechanism. This would fund infrastructure, de-risk investment, and enable Europe to match the global momentum in food biomanufacturing, accelerating Europes green industrial transformation. This is, at the same time, a competitiveness issue and climate and food security imperative. 4. Ensure policy coherence across EU sustainability and innovation initiatives The Strategy must be embedded within the broader EU policy ecosystem, aligning with existing and forthcoming initiatives, such as the EU Protein Strategy and the Biotech Act. Without this alignment, policy fragmentation will continue to stifle innovation. The Bioeconomy Strategy can play a critical role in ensuring that the right policy levers are put in place to boost innovation and technologies that can also play a role in protein diversification, food security, and fostering a sustainable food bioeconomy. Integrating modern fermentation techniques in the Strategy will enable more resilient, and low-impact food production systems and position Europe as a global leader in sustainable food innovation. Conclusion The Bioeconomy Strategy presents a unique opportunity to establish Europe as a global leader in food biotechnology and biomanufacturing. Fermentation is not a future prospect: it is a current, scalable solution to todays intertwined climate, food, and economic challenges. We urge the European Commission to ensure that food biotechnology, particularly modern fermentation techniques, is a central pillar of the Bioeconomy. This will unlock sustainable innovation, protect Europe's strategic autonomy, and deliver a secure and climate-aligned food system for all Europeans.
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Response to Biotech Act

5 Jun 2025

1. Integrate food innovation as a core pillar of the Biotech Act Food biotechnology has been recognised by the European Commissions as a strategic technology under the Strategic Technologies for Europe Platform (STEP), highlighting its importance for economic resilience and innovation. To realise its potential, the Biotech Act must explicitly include food biotech within its scope. A holistic approach should cover all relevant food biotechnologies, including precision fermentation and biomass fermentation, which enable the production of high-quality, animal-free ingredients with significantly lower environmental impacts. These technologies can play a vital role in strengthening Europes food sovereignty, reducing import dependence, and positioning the EU as a leader in sustainable food system transformation, notably through the growth of a sustainable, circular bioeconomy where agricultural byproducts are upcycled into high-value food ingredients. 2. Reform the Novel Foods regulatory pathway Despite EU leadership in food biotechnologies research & development, Europe risks losing its industry to faster-moving regions due to prolonged approval timelines, the lack of scientific pre-submission support and unclear thresholds that can reclassify fermentation products as GMOs. The Biotech Act must address these gaps to retain and grow Europes domestic food biotech industry. We therefore call for the adoption of a robust Biotech Act that commits to making the process more transparent, predictable and innovation-friendly, without compromising safety. 3. Create dedicated funding for scaling-up food biomanufacturing The absence of scale-up financing for biotechnologies in food is a critical issue. While the European Innovation Council (EIC) and the Circular Bio-based Europe Joint Undertaking (CBE JU) fund early-stage research, and an ICPEI on Biotechnology is under discussion, no EU mechanism currently supports commercial-scale fermentation production. The Biotech Act should establish a dedicated scale-up support mechanism. This would fund infrastructure, de-risk investment, and enable Europe to match the global momentum in food biomanufacturing, accelerating Europes green industrial transformation. This is, at the same time, a competitiveness issue and climate and food security imperative. 4. Ensure policy coherence across EU sustainability and innovation initiatives The Biotech Act must be embedded within the broader EU policy ecosystem, aligning with existing and forthcoming initiatives, such as the EU Protein Strategy and the Bioeconomy Strategy. Without this alignment, policy fragmentation will continue to stifle innovation. The Biotech Act can play a critical role in ensuring that the right policy levers are put in place to boost innovation and technologies that can also play a role in protein diversification, food security, and fostering a sustainable food bioeconomy. Integrating modern fermentation techniques in the Biotech Act will enable more resilient, and low-impact food production systems and position Europe as a global leader in sustainable food innovation. Conclusion The Biotech Act presents a unique opportunity to establish Europe as a global leader in food biotechnology and biomanufacturing. Fermentation is not a future prospect: it is a current, scalable solution to todays intertwined climate, food, and economic challenges. We urge the European Commission to ensure that food biotechnology, particularly modern fermentation techniques, is a central pillar of the Biotech Act. This will unlock sustainable innovation, protect Europe's strategic autonomy, and deliver a secure and climate-aligned food system for all Europeans.
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Meeting with Rasmus Nordqvist (Member of the European Parliament)

19 May 2025 · Plantbased food

Meeting with Christophe Hansen (Commissioner) and

30 Apr 2025 · Sustainable Protein Diversification for the Vision

Meeting with Valérie Hayer (Member of the European Parliament)

30 Apr 2025 · Food fermentation

Meeting with Gijs Schilthuis (Director Agriculture and Rural Development)

24 Mar 2025 · Exchange of views with Food Fermentation Europe on precision and biomass fermentation

Meeting with Claire Bury (Deputy Director-General Health and Food Safety)

11 Mar 2025 · Presentation of FFE and exchange on Commission biotech initiatives

Meeting with Anna Strolenberg (Member of the European Parliament)

23 Jan 2025 · Precision fermentation

Meeting with Anna Strolenberg (Member of the European Parliament)

5 Nov 2024 · Driving Synergy for a Resilient European Food System

Meeting with Marina Brakalova (Cabinet of Vice-President Maroš Šefčovič) and Acumen Public Affairs

14 May 2024 · Introduction to food fermentation technologies

Meeting with Andreea Ticheru (Cabinet of Executive Vice-President Margrethe Vestager)

16 Apr 2024 · Biotechnology and biomanufacturing Communication

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

17 Nov 2023 · food innovation and biotech sector

Meeting with Sarah Wiener (Member of the European Parliament)

18 Jul 2023 · staff only: Proteinstrategie