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FoodDrinkEurope

FoodDrinkEurope

FoodDrinkEurope represents the European food and drink manufacturing industry on commercial, technical, economic, legal and scientific matters.

Lobbying Activity

Meeting with Barry Cowen (Member of the European Parliament)

21 Jan 2026 · Meeting with FoodDrinkEurope

Meeting with Maria Walsh (Member of the European Parliament)

21 Jan 2026 · Unfair trading practices

Meeting with Cristina Maestre (Member of the European Parliament)

21 Jan 2026 · Unfair trading practices in the agri-food supply chain

Meeting with James Morrison (Director Research and Innovation)

15 Jan 2026 · Importance of food and beverage industries in the European R&I ecosystem. FoodDrinkEurope first meeting with new DG RTD Directorate B Director

Meeting with Stefan Köhler (Member of the European Parliament)

17 Dec 2025 · Politischer Austausch zu UTPs

Meeting with Wouter Beke (Member of the European Parliament) and The Kraft Heinz Company

17 Dec 2025 · Unfair Trading Practices (UTP)

Meeting with Verena Mertens (Member of the European Parliament)

17 Dec 2025 · Unfair trading practices in the agri-food supply chain

Meeting with Dario Nardella (Member of the European Parliament)

17 Dec 2025 · Priorities in the field of Agricultural sector

Meeting with Benoit Cassart (Member of the European Parliament)

17 Dec 2025 · Unfair Trade Practices Directive

Meeting with Antonella Sberna (Member of the European Parliament)

17 Dec 2025 · Pratiche commerciali sleali nel settore della filiera alimenatare in vista dell'attività legislative 2026

Meeting with Pietro Fiocchi (Member of the European Parliament)

16 Dec 2025 · tematiche ambientali

Meeting with Martine Kemp (Member of the European Parliament)

20 Nov 2025 · Field Visit

Meeting with Christian Holzleitner (Head of Unit Climate Action)

13 Nov 2025 · Catch-up on climate policy developments

Meeting with Michele Picaro (Member of the European Parliament, Shadow rapporteur)

10 Nov 2025 · Health

FoodDrinkEurope urges harmonized EPR rules and recycling infrastructure investment

6 Nov 2025
Topic — EU Circular Economy Act aims to create single market for secondary raw materials.
Message — The organization requests harmonized Extended Producer Responsibility rules applied consistently across all EU member states, earmarking of EPR fees for specific packaging types, and removal of local preference rules that restrict recyclate flows. They seek investments in recycling infrastructure to achieve 65% packaging recycling by 2035.1234
Why — This would reduce compliance costs and ensure affordable access to recycled materials for meeting packaging targets.567
Impact — State-owned waste management schemes lose flexibility to divert EPR fees to general state budgets.89
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Meeting with Jessika Roswall (Commissioner) and

29 Oct 2025 · Roundtable- closing the Loop : Addressing the Plastic Recycling Crisis in Europe

Meeting with Fabien Santini (Head of Unit Agriculture and Rural Development)

29 Oct 2025 · Retail alliances workshop

Meeting with Pascal Arimont (Member of the European Parliament) and Natural Mineral Waters Europe aisbl

17 Oct 2025 · Water resilience

FoodDrinkEurope Urges Broader Scope for Food Safety Regulatory Simplification

14 Oct 2025
Topic — This consultation seeks to simplify and reduce administrative burdens in EU food safety.
Message — They urge the Commission to expand the initiative's scope to all areas affecting food manufacturing. They also call for faster approval of health claims to support product innovation.12
Why — This would reduce administrative burdens and boost the global competitiveness of food manufacturers.3
Impact — Health advocates might worry that moving away from zero-risk goals could compromise safety.4
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Meeting with Alexandra Nikolakopoulou (Head of Unit Health and Food Safety)

10 Oct 2025 · FDE’s recommendations for the food and feed simplification omnibus

Food Industry Seeks Government Support for Electrification Transition

9 Oct 2025
Topic — EU action plan to accelerate electrification and shift energy demand from fossil fuels to electricity.
Message — The organization requests government subsidies for capital costs, stable tax incentives, grid capacity expansion, and support for research into electric solutions for medium and high-temperature heat. They emphasize that policies must enable corporate renewable energy agreements and recognize that flexibility is not always possible for certain processes.1234
Why — This would reduce their capital investment risks and bridge the green premium for replacing fossil-fuel systems.56
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Food Industry Urges Science-Based EU Nature Credit Framework

26 Sept 2025
Topic — EU framework for nature credits to mobilize private investment in biodiversity restoration.
Message — The organization requests a comprehensive framework that incentivizes nature-positive impact while ensuring competitiveness. They want nature credits combined with carbon credits, recognition of corporate contributions, and initial focus on EU markets before international alignment.123
Why — This would secure resilient agricultural supply chains and long-term productivity for their sector.456
Impact — Speculative buyers without supply chain ties could distort markets and divert land from food production.7
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Meeting with Barry Cowen (Member of the European Parliament, Committee chair)

23 Sept 2025 · Meeting with FoodDrinkEurope

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

17 Sept 2025 · EFSA’s performance evaluation

Food industry urges collaboration over regulation in EU heart health plan

16 Sept 2025
Topic — EU plan to reduce cardiovascular disease through prevention, early detection and treatment.
Message — The industry requests that cardiovascular health policies recognize all foods can be part of balanced diets, avoid discriminating against products based on composition alone, and prioritize consumer education campaigns. They emphasize recommendations must consider cultural context, affordability and convenience alongside nutrition.1234
Why — This would allow them to continue current voluntary reformulation efforts without mandatory restrictions on product composition.56
Impact — Public health advocates lose stronger mandatory measures to reduce harmful ingredients in processed foods.78
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Meeting with Eric Sargiacomo (Member of the European Parliament)

3 Sept 2025 · Pratiques commerciales déloyales

Meeting with Ciaran Nicholl (Director Joint Research Centre)

2 Sept 2025 · Present JRC’s future plans in the FDE vast range of activities and explore ways for FDE to support JRC’s work.

Meeting with Olivér Várhelyi (Commissioner) and

2 Sept 2025 · Exchange of views on food industry matters

Food Industry Backs EU Rules on Recycled Plastic Reporting

13 Aug 2025
Topic — EU rules for calculating and reporting recycled plastic in beverage bottles.
Message — The organization requests adoption of the implementing act by Q4 2025 with current mass balance allocation rules including fuel use exemption. They seek allowance for annual facility-based reporting rather than batch-wise records and permission to transfer mass balance credits between facilities.123
Why — This would reduce compliance costs while enabling chemical recycling needed for food-safe packaging.45
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Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

17 Jul 2025 · Packaging and Circular Economy Act

FoodDrinkEurope urges co-investment to attract young farmers

14 Jul 2025
Topic — The EU initiative aims to address demographic challenges within the agricultural sector.
Message — The group supports the creation of a 'generational renewal toolbox' within the CAP. They advocate for an 'earmarked share of CAP resources' for young entrants. They also suggest 'co-investment schemes between producers and processors' to manage risks.123
Why — Supporting young farmers ensures long-term food security and competitiveness for manufacturing processors.4
Impact — Established farmers might receive less funding if CAP resources are specifically earmarked.5
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Meeting with Aurel Ciobanu-Dordea (Director Environment)

8 Jul 2025 · Exchange of views on Packaging and Packaging Waste Regulation (PPWR), Circular Economy Act (CEA) and Single Use Plastics Directive (SUPD)

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

27 Jun 2025 · Sustainability Omnibus

Meeting with Valdis Dombrovskis (Commissioner) and

25 Jun 2025 · Competitiveness and simplification

Meeting with Elena Panichi (Head of Unit Agriculture and Rural Development) and spiritsEUROPE

25 Jun 2025 · State of Play of the situation between the EU and the US

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

25 Jun 2025 · Elintarvikealan tilannekatsaus

FoodDrinkEurope Urges Food Security Focus in EU Bioeconomy Strategy

19 Jun 2025
Topic — The European Commission is revising the EU Bioeconomy Strategy for a climate-neutral economy.
Message — FoodDrinkEurope requests that the strategy prioritize food security and redefine unavoidable food waste as a valuable bio-based feedstock. They advocate for national flexibility in setting biomass targets and supporting circular factory practices like anaerobic digestion.123
Why — Manufacturers would gain new revenue streams from waste and lower costs through improved resource efficiency.45
Impact — The bioenergy and biofuels industries may lose access to biomass due to food-first prioritization.6
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Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

18 Jun 2025 · Simplification

Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur)

11 Jun 2025 · Omnibus

FoodDrinkEurope urges faster market pathways for food biotech

10 Jun 2025
Topic — This consultation explores a new legislative framework to accelerate biotechnology innovation and commercialization in Europe.
Message — The group wants the food sector included in the Act to reduce regulatory complexity and speed up approvals. They also call for better risk communication and a strategic policy to boost private investment.123
Why — Simplified rules would lower compliance costs and improve the financial viability of new products.45
Impact — International competitors lose their dominance as the EU seeks to close the innovation gap.6
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Meeting with Ann-Sofie Ronnlund (Cabinet of Commissioner Ekaterina Zaharieva)

4 Jun 2025 · Life sciences

Meeting with Denis Redonnet (Deputy Director-General Trade) and

4 Jun 2025 · In his mission letter Commissioner Maroš Šefčovič is tasked to “closely monitor the full enforcement of our trade agreements on market access and rules […]”.

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur)

4 Jun 2025 · discussions on Green Claims Directive

Meeting with Gijs Schilthuis (Director Agriculture and Rural Development)

26 May 2025 · Exchange of views on simplification of legislation for farmers, the agri-food supply chain and administrations (beyond CAP)

Meeting with Aurel Ciobanu-Dordea (Director Environment) and Confederation of European Paper Industries and

22 May 2025 · Discuss with interested stakeholders the practical aspects and challenges of ensuring compliance with Art.5(5) of the PPWR (concerning PFAS limits in food-contact packaging)

FoodDrinkEurope urges broader exemptions from EU deforestation rules

13 May 2025
Topic — The Commission is updating the list of products covered by deforestation regulations.
Message — The industry requests broader exemptions for samples, marketing materials, and retail displays. They also call for flexible timelines for the destruction of quality assurance samples.12
Why — Expanded exemptions would minimize administrative burdens and simplify compliance for food manufacturers.3
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Meeting with Vytenis Povilas Andriukaitis (Member of the European Parliament)

13 May 2025 · Exchange of views

Meeting with Christophe Hansen (Commissioner) and

28 Apr 2025 · Courtesy visit and exchange of views on the Vision and on issues considered relevant by FoodDrinkEurope

Meeting with Maroš Šefčovič (Commissioner) and

28 Apr 2025 · EU’s trade relationships and its impacts on the agrifood sector

Meeting with Elena Panichi (Head of Unit Agriculture and Rural Development)

16 Apr 2025 · Info on the current and prospective trade situation between the EU and the US in the frame of Food Drink Europe Trade Working Group

Meeting with Hildegard Bentele (Member of the European Parliament)

4 Apr 2025 · Water resilience

Meeting with Valérie Hayer (Member of the European Parliament, Shadow rapporteur)

27 Mar 2025 · Unfair trading practices

Meeting with Jessika Roswall (Commissioner) and

25 Mar 2025 · Roundtable “Water, Agriculture, and the Food Supply Chain”

Meeting with Paulina Dejmek Hack (Cabinet of Commissioner Jessika Roswall)

21 Mar 2025 · Competitiveness, Water Resilience

Meeting with Antonio Malta Reis (Cabinet of Commissioner Christophe Hansen), Johannes Van Den Bossche (Cabinet of Commissioner Christophe Hansen), Pawel Wisniewski (Cabinet of Commissioner Christophe Hansen)

18 Mar 2025 · Exchange of views on FoodDrink Europe’s main trade priorities and issues, in particular as regards spirits.

Meeting with Elisabetta Siracusa (Director Agriculture and Rural Development)

11 Mar 2025 · FoodDrinkEurope’s trade priorities for the new European Commission cycle 2024-2029

FoodDrinkEurope Backs Cross-Border Enforcement to Tackle Retail Alliances

10 Mar 2025
Topic — Proposal to improve cross-border cooperation in enforcing EU unfair trading practice rules.
Message — FoodDrinkEurope supports the regulation to stop retailers from evading laws through cross-border jurisdictions. They also want a full directive revision to remove size-based thresholds and ban more practices.123
Why — It prevents unfair treatment by retail alliances and ensures consistent protection across borders.4
Impact — Large retail alliances lose the ability to shop for jurisdictions with weaker enforcement.5
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FoodDrinkEurope Warns Against One-Size-Fits-All Food Chain Rules

10 Mar 2025
Topic — Targeted amendments to EU regulations aimed at strengthening farmers' supply chain position.
Message — FoodDrinkEurope advocates for a flexible, sector-specific approach to contract rules to avoid disrupting diverse industries. They request clearer definitions for sustainability terms and a thorough assessment of administrative burdens on SMEs.12
Why — Exemptions would prevent increased administrative costs and protect established hedging mechanisms for price stability.34
Impact — Small businesses and consumers may suffer from market fragmentation and potential disruptions to food supplies.56
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FoodDrinkEurope urges flexible EU water resilience strategy

4 Mar 2025
Topic — A new European strategy to ensure sustainable water management and security.
Message — They want a flexible framework that adapts to local industrial needs. The group requests financial incentives for investing in water-saving technologies. They emphasize that water quality is crucial for food safety.1234
Why — Financial incentives and reduced administrative burdens would improve the sector's competitiveness.56
Impact — The environment may suffer if higher pollutant concentrations conflict with directives.78
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Meeting with Ariane Vander Stappen (Head of Unit Health and Food Safety) and Association of the European Self-Care Industry and

4 Mar 2025 · Discussion on the ongoing harmonisation of maximum permitted limits for vitamins and minerals in food

Meeting with Axel Hellman (Cabinet of Commissioner Jessika Roswall)

25 Feb 2025 · Water resilience

Meeting with Maria Walsh (Member of the European Parliament)

20 Feb 2025 · Agri-Food Chain

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

20 Feb 2025 · Elintarvikealan ajankohtaiset asiat

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

19 Feb 2025 · Dialogue on empowering consumers for better food and drink choices.

Meeting with Heléne Fritzon (Member of the European Parliament)

19 Feb 2025 · FoodDrinkEuropes mottagning i anslutnign till ”Food & Drink Dialogues”

Meeting with Veronika Vrecionová (Member of the European Parliament, Committee chair)

18 Feb 2025 · Vision for agriculture, UTP and CMO

Meeting with Kristoffer Storm (Member of the European Parliament)

18 Feb 2025 · Food Industry

Meeting with Valentina Schaumburger (Cabinet of Executive Vice-President Stéphane Séjourné)

6 Feb 2025 · Meeting to present FoodDrink Europe

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

5 Feb 2025 · Initiatives of relevance to the food industry, such as the Vision on Agriculture and Food (‘the Vision’), the European Board for Agriculture and Food (‘the EBAF’), the Competitiveness Compass, the Clean Industrial Deal, Unfair Trading Practices

Meeting with Rasmus Nordqvist (Member of the European Parliament)

3 Feb 2025 · Foodwaste

FoodDrinkEurope Urges EU to End Single Market Fragmentation

30 Jan 2025
Topic — The European Commission is developing a strategy to strengthen the EU Single Market.
Message — The group calls for harmonized rules to prevent national governments from creating trade barriers. They advocate for using EU Regulations instead of Directives to ensure uniform application.12
Why — Unified rules would lower compliance costs and reduce legal uncertainty for cross-border food manufacturers.34
Impact — National governments lose the power to enforce stricter local health warnings or environmental packaging bans.56
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Meeting with Giulia Del Brenna (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

20 Jan 2025 · General topics of interest, including the Vision on the future of agriculture, and political perception of the food industry

Meeting with Ingeborg Ter Laak (Member of the European Parliament)

17 Jan 2025 · Sustainability practices

Meeting with Elsi Katainen (Member of the European Parliament)

18 Dec 2024 · Ajankohtaiset elintarvikesektorin kuulumiset

Meeting with Antonella Sberna (Member of the European Parliament)

18 Dec 2024 · Innovazione e competitività nell'industria alimentare: sfide e prospettive per il settore

Meeting with Veronika Vrecionová (Member of the European Parliament, Committee chair) and Mars Incorporated

18 Dec 2024 · Presentation meeting (sustainability, packaging, labeling)

Meeting with Ondřej Krutílek (Member of the European Parliament) and Mars Incorporated

18 Dec 2024 · Presentation meeting (sustainability, packaging, labeling)

Meeting with Tomas Baert (Cabinet of President Ursula von der Leyen) and European farmers and

3 Dec 2024 · Trade tensions - strategic thinking for agri-food trade

Meeting with Oliver Schenk (Member of the European Parliament) and European Aluminium AISBL

21 Oct 2024 · Priorities for the next legislative term

Response to Commission Roadmap to phase out animal testing

14 Oct 2024

FoodDrinkEurope appreciates the opportunity to provide feedback on the European Commissions roadmap to phase out animal testing in chemical safety assessments. The food and drink industry shares the goals of reducing and ultimately eliminating unnecessary animal testing while maintaining a high level of protection for human health and the environment. The integration of New Approach Methodologies (NAMs) into safety assessments presents a scientifically advanced, human-relevant alternative to traditional animal testing. Please find our detailed comments attached. We thank you in advance for your consideration.
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Meeting with Nicola Zingaretti (Member of the European Parliament)

9 Oct 2024 · Packaging

Meeting with Stefano Cavedagna (Member of the European Parliament) and LightingEurope

9 Oct 2024 · Introductory meeting - discussion about the next legislative proposals

Meeting with Elisabetta Gualmini (Member of the European Parliament)

8 Oct 2024 · AGRI Committee

Meeting with César Luena (Member of the European Parliament)

4 Oct 2024 · Food sector priorities

Meeting with Emma Wiesner (Member of the European Parliament)

1 Oct 2024 · Utfallet av den strategiska dialogen om lantbrukets framtid.

Meeting with Herbert Dorfmann (Member of the European Parliament)

1 Oct 2024 · Food supply chain

Response to Monitoring and reporting of molecular analytical data within foodborne outbreaks

18 Sept 2024

FoodDrinkEurope appreciates the opportunity to provide feedback on the draft Commission Implementing Regulation on the collection and transmission of molecular analytical data within the frame of epidemiological investigations of food-borne outbreaks. Please find our comments attached. We thank you in advance for your consideration.
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Meeting with Pietro Fiocchi (Member of the European Parliament)

18 Sept 2024 · Exchange of views about food and drink issues

FoodDrinkEurope urges EU to tackle Canadian food trade barriers

25 Apr 2024
Topic — Evaluation of the economic and environmental impacts of the EU-Canada trade agreement.
Message — FoodDrinkEurope urges EU officials to eliminate Canadian trade barriers like discriminatory spirits rules. They also seek to resolve issues regarding dairy subsidies and wheat gluten duties.12
Why — Resolving these issues would help EU manufacturers fully exploit trade opportunities and increase exports.3
Impact — Canadian dairy processors would lose the market advantages provided by prohibited government subsidies.4
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Response to Evaluation of the European Food Safety Authority (EFSA) 2017-2024

5 Apr 2024

FoodDrinkEurope appreciates the opportunity to provide feedback on the performance of the European Food Safety Authority (EFSA). Please find our comments attached. We thank you in advance for your consideration.
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FoodDrinkEurope urges longer transition for equipment in BPA crackdown

8 Mar 2024
Topic — EU consultation on restricting bisphenol A and other bisphenols in food contact materials.
Message — They request polycarbonate exemptions and allowing industrial equipment use until its end-of-life. They seek a 36-month transition for all acidic food packaging to avoid supply disruptions. They call for clear methods to distinguish between intentionally added and incidental BPA.123
Why — This avoids premature costs of replacing machinery and prevents disruptions in food supply.45
Impact — Consumer health groups lose the benefit of a faster phase-out of BPA-containing equipment.6
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

4 Mar 2024 · future of the) Green Deal in the next institutional mandate

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

23 Feb 2024 · Sustainable Food Systems (General Exchange)

Meeting with Susanna Ceccardi (Member of the European Parliament)

21 Feb 2024 · Meeting with FoodDrinkEurope

Meeting with Franc Bogovič (Member of the European Parliament)

21 Feb 2024 · Meeting on agriculture related legislation

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

20 Feb 2024 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Katarína Roth Neveďalová (Member of the European Parliament)

24 Jan 2024 · Future of EU Agri-food sector

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

19 Jan 2024 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Response to Revision of the definition of engineered nanomaterial in food

11 Jan 2024

FoodDrinkEurope appreciates the opportunity to provide comments on the draft Commission Delegated Regulation amending Regulation (EU) 2015/2283 on novel foods as regards the definition of engineered nanomaterial (herafter referred to as ENM). We commend the Commission's efforts to take into account global technical and scientific progress in this field and its work towards preparing a more precise and comprehensive definition. You will find our contribution in pdf (attached).
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Meeting with Maroš Šefčovič (Executive Vice-President) and European Environmental Bureau and

9 Jan 2024 · Farm visit and roundtable with agri-food chain stakeholders

FoodDrinkEurope calls for unfair trading protections for all suppliers

29 Nov 2023
Topic — An evaluation assessing the effectiveness of EU rules against unfair agricultural trading practices.
Message — The organization advocates for expanding legal protections to all suppliers by removing the turnover threshold. They also want to prohibit practices like unreasonable delisting and automatic logistics penalties.12
Why — A level playing field would protect large manufacturers currently excluded from unfair trading rules.34
Impact — Supermarkets and large retailers lose the ability to automatically deduct logistics penalties from payments.5
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Meeting with Lara Comi (Member of the European Parliament) and Flexible Packaging Europe and TomatoEurope Processors Association

21 Nov 2023 · PPWR

Meeting with Salvatore De Meo (Member of the European Parliament, Rapporteur)

7 Nov 2023 · PPWR

Meeting with Maroš Šefčovič (Executive Vice-President)

6 Nov 2023 · Transition towards sustainable food systems

FoodDrinkEurope demands clear funding and uniform soil rules

3 Nov 2023
Topic — The EU is establishing a framework for monitoring and restoring soil health.
Message — The organization calls for a clarified financing framework to support farmers in transitioning to sustainable practices. They also seek stronger, harmonized guidelines for soil management to ensure a level playing field across Europe. Additionally, they request better coordination between this law and other policies like the Common Agricultural Policy.123
Why — Harmonized rules and funding reduce financial risks for the food industry's supply chain.4
Impact — National governments lose the flexibility to set specific soil requirements for their regions.5
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FoodDrinkEurope urges EU to embrace gene-edited crops for resilience

31 Oct 2023
Topic — The European Commission is proposing a new legal framework for plants developed using genomic techniques.
Message — The association wants safe gene-edited plants treated like conventional varieties. They seek to avoid unnecessary regulatory burdens. They also want to support innovation for smaller businesses.12
Why — This would lower regulatory costs and help European businesses compete with global trade partners.34
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Meeting with Tom Vandenkendelaere (Member of the European Parliament)

19 Oct 2023 · Green claims directive

Meeting with Dacian Cioloş (Member of the European Parliament, Shadow rapporteur for opinion)

18 Oct 2023 · Exchange on Agri Opinion Food Waste

Meeting with Maria Angela Danzì (Member of the European Parliament)

18 Oct 2023 · Non communicable diseases

Meeting with Laura Ballarín Cereza (Member of the European Parliament, Shadow rapporteur) and Microsoft Corporation and APPLiA (Home Appliance Europe)

18 Oct 2023 · Green Claims

Meeting with Norbert Lins (Member of the European Parliament)

18 Oct 2023 · PPWR

Meeting with Clara Aguilera (Member of the European Parliament)

17 Oct 2023 · Food Waste

Meeting with Róża Thun Und Hohenstein (Member of the European Parliament, Shadow rapporteur) and Decathlon SE

16 Oct 2023 · Waste Framework Directive revision

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and Cosmetics Europe

12 Oct 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Cyrus Engerer (Member of the European Parliament, Rapporteur) and HOTREC, Hotels, Restaurants & Cafés in Europe and World Travel and Tourism Council

28 Sept 2023 · Green Claims Directive

Meeting with Petros Kokkalis (Member of the European Parliament, Shadow rapporteur)

27 Sept 2023 · Green Claims

Meeting with César Luena (Member of the European Parliament) and EPPA SA

21 Sept 2023 · PPWR

Meeting with Clara Aguilera (Member of the European Parliament) and One Planet Business for Biodiversity

21 Sept 2023 · Sustainable Agriculture

Meeting with Maria Angela Danzì (Member of the European Parliament) and Seda International Packaging Group

12 Sept 2023 · PPWR

Response to Waste Framework review to reduce waste and the environmental impact of waste management

31 Aug 2023

Please find attached FoodDrinkEurope's views on EU food waste reduction targets set for food manufacturers under the EC revision of the Waste Framework Directive.
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FoodDrinkEurope urges streamlined verification for green product claims

20 Jul 2023
Topic — The proposal mandates standardized methods to substantiate environmental claims and prevent greenwashing.
Message — The industry calls for a 36-month transition period and simplified verification to avoid administrative delays. They suggest a life cycle perspective instead of full assessments for every claim. They propose qualitative assessments when scientific evidence for specific environmental impacts is missing.123
Why — Less rigorous assessment requirements would lower compliance costs and protect confidential business information.4
Impact — Consumers may receive less granular data if detailed impact studies are kept confidential.5
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FoodDrinkEurope urges broader phase-in for sustainability reporting

6 Jul 2023
Topic — The consultation details mandatory standards for corporate sustainability reporting within the European Union.
Message — The group requests extending phase-in periods for complex reporting topics to all companies. They also seek permission to use non-EU accounting standards and provide standalone reports.123
Why — Broadening the transition periods would lower the immediate financial and administrative costs.456
Impact — Reporting users lose immediate access to standardized data on large companies' impacts.7
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Meeting with Janusz Wojciechowski (Commissioner) and

28 Jun 2023 · Geo-political importance of food, contribution of agriculture/food to success of the European Green Deal and the EU’s global competitiveness

Meeting with Kurt Vandenberghe (Director-General Climate Action) and European farmers and

27 Jun 2023 · Fit for 55

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

26 Jun 2023 · Sustainable food systems

Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur) and WACKER CHEMIE AG

1 Jun 2023 · Forced Labour

Meeting with Christine Schneider (Member of the European Parliament)

31 May 2023 · PPWR

Meeting with Andrus Ansip (Member of the European Parliament, Rapporteur)

30 May 2023 · Green Claims

FoodDrinkEurope urges realistic timelines and flexible recycling rules

24 Apr 2023
Topic — The EU is revising rules to reduce packaging waste and improve design standards.
Message — FoodDrinkEurope requests a 2030 deadline for recyclability and a five-year transition for design rules. They propose calculating recycled content across entire product portfolios rather than per unit.123
Why — Flexibility in calculations would protect manufacturing optimization and prevent price increases for consumers.45
Impact — Environmental groups lose the stricter accountability provided by mandatory unit-level recycled content targets.6
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Meeting with Brando Benifei (Member of the European Parliament)

22 Mar 2023 · Amendments on the Proposal for a Directive on empowering consumers for the green transition (meeting held by assistant)

Meeting with César Luena (Member of the European Parliament) and McDonald’s Global Franchising Limited

22 Mar 2023 · MEP Luena's Team on Packaging and Packaging Waste Regulation

FoodDrinkEurope Urges Value Chain Focus for Carbon Removal Certificates

20 Mar 2023
Topic — New rules for a Union regulatory framework certifying sustainable carbon removals.
Message — The organization requests carbon removal certificates be used within the food value chain. They argue food production must remain the primary priority for farmers.12
Why — Food manufacturers would lower their environmental footprint by claiming removals from suppliers.3
Impact — Other industrial sectors lose out on buying agricultural carbon offsets to compensate emissions.4
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Salvatore De Meo (Member of the European Parliament, Rapporteur) and Neste Oyj and

6 Mar 2023 · PPWR

Meeting with Ivan Štefanec (Member of the European Parliament)

15 Feb 2023 · Packaging and Packaging Waste Regulation

Meeting with Tom Vandenkendelaere (Member of the European Parliament, Shadow rapporteur for opinion)

15 Feb 2023 · packaging: general introduction, recycled content, reuse

Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and Ball Beverage Packaging Europe Limited

13 Feb 2023 · Packaging waste

FoodDrinkEurope urges alignment of forced labour and due diligence laws

30 Nov 2022
Topic — A European Commission proposal to prohibit products made with forced labour from the market.
Message — FoodDrinkEurope advocates aligning this regulation with other directives to prevent overlapping requirements. They request harmonized guidance and clear definitions to ensure legal certainty for food businesses. They also call for a risk database to support smaller companies with administrative burdens.12
Why — This alignment would lower compliance costs by allowing companies to reuse existing due diligence processes.34
Impact — Non-EU suppliers may face trade bans or costly customs delays that disrupt market access.5
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Meeting with Ralf Kuhne (Cabinet of Commissioner Stella Kyriakides)

8 Nov 2022 · VTC meeting on food packaging

FoodDrinkEurope urges risk-based approach for endocrine disruptor classification

14 Oct 2022
Topic — The consultation addresses new hazard classes for endocrine disruptors under EU chemical labelling regulations.
Message — FoodDrinkEurope insists that identifying endocrine disruptors requires a causal link to an adverse effect in an intact organism. They argue against using labels for incomplete evidence like 'potential ED' and support standard risk analysis.12
Why — Industry avoids substance bans by ensuring chemicals are restricted only when exposure levels pose actual risks.34
Impact — Environmental groups lose precautionary protections if regulators must prove exposure risks before banning chemicals.56
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FoodDrinkEurope urges review of shipping rules amid soaring costs

3 Oct 2022
Topic — Evaluation of rules allowing shipping companies to cooperate on joint services.
Message — The group supports reviewing rules that allow shipping cooperation. They demand better monitoring to identify causes of transport disruptions.12
Why — Lower freight costs and improved reliability would protect the competitiveness of food exporters.34
Impact — Shipping lines would lose their regulatory exemption and face stricter competition oversight.5
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FoodDrinkEurope Urges Chemical Data Sharing With Strict IP Safeguards

16 Aug 2022
Topic — A policy initiative to improve chemical safety assessments by sharing data between agencies.
Message — FoodDrinkEurope requests standardized protocols for data access to ensure consistency and predictability. They insist that data sharing must respect confidentiality and intellectual property rights. Furthermore, EFSA should remain the lead agency for food-related chemical risk assessments.123
Why — The industry would benefit from more efficient safety assessments for innovative sustainable packaging materials.45
Impact — Companies investing in R&D could lose their competitive edge if intellectual property is disclosed.67
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Nestlé S.A. and Natural Mineral Waters Europe aisbl

29 Jun 2022 · Revision of the Packaging and Packaging Waste Directive

Food industry urges flexibility in industrial emissions revision

23 Jun 2022
Topic — The consultation seeks to update EU industrial emissions rules to improve environmental protection.
Message — FoodDrinkEurope calls for reconsideration of mandatory lower emission limits and binding performance values. They request better protection for confidential data and more time to test emerging technologies. Finally, they seek clarity on the reversal of the burden of proof for damages.123
Why — These changes would protect proprietary technology and reduce legal risks for manufacturers.45
Impact — Individuals seeking compensation for pollution would face significant challenges proving industrial liability.6
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Meeting with Andreas Schneider (Cabinet of Commissioner Janusz Wojciechowski)

31 May 2022 · Competitiveness Committee meeting. This Committee addresses topics which impact the competitiveness of the food and drink industry, such as food supply chain issues, agricultural policies, trade and sustainability.

Meeting with Janusz Wojciechowski (Commissioner) and

25 May 2022 · Current crisis in Ukraine and the impact for the food and drink supply

Food industry urges harmonized standards in due diligence rules

23 May 2022
Topic — The European Commission is proposing new rules for corporate sustainability due diligence.
Message — The industry requests an EU-wide harmonised framework aligned with international standards to ensure legal certainty. They call for clear definitions and sector-specific guidelines to be published well before enforcement begins.123
Why — Harmonisation prevents conflicting national requirements and reduces the industry's overall administrative burden.45
Impact — Regulators and civil society might find enforcement harder under the requested proportionate sanctioning system.6
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Response to Single Market Emergency Instrument (SMEI)

11 May 2022

FoodDrinkEurope welcomes the opportunity to share its views on the European Commission’s initiative for a Single Market Emergency Instrument (SMEI). We support the Commission’s ambition to create an instrument to ensure the free movement of persons, goods and services, as well as greater transparency and coordination in times of crisis. The SMEI should draw on the lessons learned from recent crises such as COVID-19, address weaknesses, barriers and the risks of fragmentation of the Single Market. It should furthermore help strengthen the resilience of the EU economy and preparedness for crisis situations. As a sector essential to providing food and drinks, Europe’s food and drink industry has a key interest in maintaining the continuity of agri-food supply chains stretching across the EU and beyond. Please see our detailed comments in the enclosed PDF file.
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FoodDrinkEurope Urges Keeping Carbon Credits Within Agri-Food Chains

2 May 2022
Topic — The EU is proposing a regulatory framework for certifying carbon removals to support climate goals.
Message — FoodDrinkEurope calls for a system that keeps carbon removals within the agricultural sector to meet targets. They also want rewards for farmers who already maintained carbon stocks before the new rules.12
Why — This allows food processors to claim emission reductions within their own supply chains at lower cost.3
Impact — Non-food industries lose access to cheaper agricultural offsets if credits are restricted to food value chains.4
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Response to Streamlining EU scientific and technical work on chemicals through the EU agencies

11 Apr 2022

FoodDrinkEurope represents the food manufacturing industry. Made up of 294,000 businesses and 4.7 million workers, the food and drink industry buys 70% of all EU agricultural produce and is Europe’s largest manufacturing industry. We support the Commission’s initiative on making best use of EU agencies to streamline scientific assessments of chemicals as part of the Implementation of the Chemicals Strategy for Sustainability. We welcome the potential benefits of streamlining the technical and scientific work of EU agencies through better coordination, new tools, and targeted amending of certain pieces of legislation. To this effect, and without reshuffling current responsibilities, we note that EFSA should continue to be responsible for the risk assessment of substances added to or present in food. Further comments are provided in the attached document.
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Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides)

6 Apr 2022 · VC Meeting: Food Security and EU Code of Conduct

Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

16 Mar 2022

FoodDrinkEurope welcomes the soil health initiative, addressing the foundation of our food system. Please find attached our feedback.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

FoodDrinkEurope welcomes the initiative to review the Waste Framework Directive to further decrease waste generation and improve waste collection. To achieve these objectives, a combination of policy options should be considered to ensure an effective implementation of specific waste stream policies under revision, specially the packaging waste directive and specific targets on food waste. Such policy options include: Reviewing the definition of waste and recycling according to available infrastructure • Setting high recycling targets for plastic and ensuring effective separation of plastic. • Ensure harmonisation in waste management practices and finalise the harmonisation of Extended Producer Responsibility • Schemes and support investments in recycling and recognise enhanced recycling as a valid technology for recycling of materials. • Assess available Food waste data and build on food and drink industry’s efforts to set future food waste targets.
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Meeting with Florika Fink-Hooijer (Director-General Environment)

10 Feb 2022 · Packaging and green claims

Meeting with Wioletta Dunin-Majewska (Cabinet of Commissioner Elisa Ferreira) and European farmers and European Liaison Committee for Agriculture and agri-food trade

28 Jan 2022 · Revision of the promotion policy.

Response to Amendment of Regulation (EU) No 282/2008 on the recycling of plastic materials to be used as food contact materials

18 Jan 2022

FoodDrinkEurope welcomes the progress made on this long-awaited text and hopes it will accelerate the long due authorization of recycling processes that have been positively evaluated by EFSA. This revision should foster innovation and ensure that the right infrastructure and technologies are in place. Moreover, climate neutrality and environmental protection objectives should be embedded in the overall objectives, while avoiding being too descriptive and restrictive. It is essential that the measures and definitions in the future recycled plastic food legislation are harmonious and compatible with other policies related to the environmental aspects of packaging. Although we are overall in agreement with the intention of the draft Regulation, we would like to make some high-level comments and more detailed remarks about this proposal. Please find these in the file attached.
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Meeting with Tom Vandenkendelaere (Member of the European Parliament)

2 Dec 2021 · Factory visit AB Inbev & waste water treatment discussion

Response to Import conditions and border controls of trade samples and certain composite products

23 Nov 2021

FoodDrinkEurope, the organisation representing the European food and drink industry, would like to thank the Commission for this opportunity to provide feedback on its initiative reviewing certain measures related to border controls for food including import conditions and border controls of trade samples and certain composite products. Food safety is of utmost importance for our organisation and our members, and we share the view that it is necessary to make sure that all foods entering into the European Union adhere to the high standards of food safety set by the EU. Please find our comments in the attachment, and our key messages summarised below. We call on the Commission to: - Ensure that Vitamin D3 can continue to be imported into the EU from critical supplying third-countries; - Extend the list of composite products exempted from official controls at border control posts to other shelf-stable products; - Handle the importation of R&D samples in a pragmatic way.
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Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and spiritsEUROPE and

15 Nov 2021 · Implementation of Decree 248 by the Chinese Customs Administration

Response to Restriction of use of green tea catechins in foods

3 Nov 2021

FoodDrinkEurope welcomes the opportunity to comment on the Commission’s proposal. The draft Commission Regulation is critical for the food industry, especially due to the far-reaching consequences that may result from this, if enacted, for the use of green tea extract containing (-) epigallocatechin-3-gallate (EGCG) as an ingredient in food and drinks. Please find in attachment our comments, as a contribution to the public consultation.
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Response to Food waste reduction targets

29 Oct 2021

Food waste is a missed opportunity to feed the growing world population, a major waste of resources and a needless source of emissions. The food and drink industry is committed to contributing to the implementation of UN Sustainable Development Goal (SDG) 12.3 which targets to halve per capita food waste at the retail and consumer level by 2030, and reduce food losses along the food production and supply chains. Our priority is to prevent food losses and waste including surpluses from occurring in the first place and to drive out resource inefficiency within our supply chains. Where surpluses cannot be avoided, we work to redirect food to feed people in line with the food waste hierarchy. Food waste features high in the Farm-to-Fork Strategy, therefore FoodDrinkEurope welcomes the European Commission’s initial consultation to provide input to the IIA on a proposal of EU-level targets for food waste reduction which are expected to be set/adopted Q2 of 2023. Bearing the above in mind, before setting food waste targets we call on policymakers: • To make sure the approach to Food Loss and Waste reduction is consistent with other food policy initiatives. Food Loss and Waste is part of the Farm to Fork Strategy and needs to be considered in other strategies as well such as those tackling climate change & revising packaging. • To further develop EU guidelines and training tools to further help implement the Delegated Act on food waste measurement adopted in 2019. These guidelines could encourage and assist the different actors in the supply chain with interpreting the data and reporting to Member States (MS). • To carefully assess with MS data collected from the two first reporting years (2020-2022) since it is the first time MS, alongside organisations in the supply chain, are engaged in such a comprehensive exercise. • To use a science-based Target, Measure and Act approach as practiced by WRAP in the UK and Champions 12.3 worldwide to ensure action is taken where it will have the most impact. • To carry out scientifically based targeted Impact Assessments on the various proposed policy measures/options. To this end, stakeholder specific consultations alongside workshops with active stakeholder engagement on the latter will need to be carried out. • The impact assessments should also focus on trade-offs (i.e packaging v food waste). • To further encourage and build upon, at EU and MS level, the efforts undertaken by the various actors of the food supply chain to reduce and prevent food waste. • To consider the important link to date marking - Education campaigns, as well as coordinated and enduring EU-wide communication initiatives are needed to improve consumer understanding of date labels (‘use by’ and ‘best before’) and to raise awareness of other ways to prevent and reduce food waste. • To support innovation which promotes circular economy such as turning discarded materials or by-products into new added-value product or re-working food back into the production process. • To incentivise food waste prevention & support donation. Where food surpluses cannot be avoided, to prioritise food redistribution to humans in line with the food waste hierarchy. FoodDrinkEurope and its members will continue to share their knowledge and expertise, as appropriate, especially within the EU Platform on Food Losses and Food Waste new mandate starting in 2022. (pdf document attached)
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Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

FoodDrinkEurope, representing the food and drink and Europe’s largest manufacturing industry., wishes to contribute to the development of the EU policy framework for biobased (BBP), biodegradable and compostable plastics (BDCP). Further background information can be found in the attachement • Harmonised definitions and clear policy framework to support innovation and investments Clear and unambiguous definitions for BBP and BDCP and provisions applied to these materials should be developed in a science-based and transparent way and must be harmonised across the EU and applied consistently across the Single Market. These definitions must be easy to operationalise for both economic operators and consumers and should clearly differentiate between bio-based and biodegradable/ compostable plastics. They should also be developed based on robust scientific evidence to guarantee credibility for consumers and a reliable legal framework for the economic operators to foster investments. A clear, reliable and practical method is also needed for the measurement of the bio-based content in plastics. As recognised in the roadmap, we wish to stress the importance of ensuring coordination and consistency with the other relevant policy initiatives in this area (Packaging and Packaging Waste and Single-Use Plastics Directives and Joint Research Centre study on the definition of recycling. • Applications for Biodegradable and compostable plastics Producers are constantly adapting to local requests and preferred formats, taking into consideration the geographical location, existing EPRs schemes, distribution channels and waste management options, as well as to meet to climate neutrality objectives and reducing other environmental impacts.Meeting these objectives can only be achieved if the capacity of producers to research and innovate on packaging design while preserving its essential functions is not hindered while ensuring competitiveness and growth of the industry We therefore believe that policy on packaging materials should set generic objectives while avoiding being too descriptive to allow for the necessary innovation to happen. Industry in this case is best placed to develop adequate solutions to reach the intended climate neutrality and environmental protection objectives. Restricting the use of some packaging materials will limit the different advantages and needs each packaging delivers for a specific context. Whilst materials and their variations used for packaging should conditions, ban of materials should be avoided as long as they fulfil certain recyclability and litter avoidance conditions. • Post-consumer management The Food and drink industry sector is ready to work collaboratively and invest accordingly, to ensure, that there is an infrastructure in place and that consumers are provided with the necessary information to enable the full circularity of packaging. The goal of the policy work should be firstly to ensure, that member states have implemented their obligations to separately collect packaging for composting, recycling and recovery to meet targets prescribed by EU legislation. In support of the single market, we recommend that compostable packaging is accepted in the biowaste bin if they meet defined requirements. • Labelling Clear rules should be set for consumer communication on compostable packaging together with adequate sorting information, to avoid consumer confusion and increase recovery and avoid contamination of established streams. The revision of the PPWD is a great opportunity to include plans to develop an EU harmonised sorting instructions for packaging. • Standardisation EN13432 standard should be reviewed with the participation of compostable packaging materials fillers, producers and waste managers. Such revision should develop harmonised definitions and differentiation of home and industrial composability.
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Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Karolina Herbout-Borczak (Cabinet of Commissioner Stella Kyriakides)

27 Oct 2021 · VTC meeting : Origin Labelling in the context of the Farm to Fork Strategy

Response to Sustainable food system – setting up an EU framework

26 Oct 2021

FoodDrinkEurope fully supports the European Commission’s objective to build more sustainable food systems and welcomes the Commission’s initial consultation on a related legislative framework initiative. This initiative should address the three pillars of sustainability to ensure food supply and food security in the long term, while maintaining the EU’s competitiveness on the global market. We are pleased to provide in attachment our recommendations for the way forward, as a contribution to the Inception Impact Assessment consultation.
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Response to Animal welfare labelling for food

5 Aug 2021

FoodDrinkEurope, the organisation of the European food and drink industry manufacturing industry, welcomes the opportunity to provide comments on the Inception Impact Assessment (IIA) on the revision of the EU legislation in animal welfare. FoodDrinkEurope agrees with the need to raise animal welfare standards, informed by the latest available evidence and science with regard to animal health and welfare. In first instance, better monitoring and control programmes of the existing rules in place are needed to ensure that these are properly implemented and better enforced, particularly against the background of the current limited veterinary and enforcement resources in the EU. Without prejudice to the other aspects of the Commission’s Inception Impact Assessment, FoodDrinkEurope would like to share the following comments on section d) on animal welfare labelling: - Achieving compliance of legislative requirements in the EU Member States is key to ensure that animal welfare standards are properly enforced. Consumer information requirements alone cannot replace effective enforcement and compliance. Only in the context of a holistic approach to animal welfare (good nutrition, good environment, good health, appropriate behaviour, positive mental experiences), labelling can bring added value. - FoodDrinkEurope supports EU-harmonised standards for the voluntary provision of animal welfare information. However, such standards need to be based on reliable data and proper science. Furthermore, future-fit solutions for such information (e.g. product information provided through digital means, such as QR codes or company websites) are needed to avoid confusion among consumers and to avoid additional burdens for food manufacturers. Therefore, it is suggested to include in the assessment policy options to provide off-pack information on animal welfare.
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Response to Amendments of Regulation (EU) 2019/2122

18 Jun 2021

Please see attached the FoodDrinkEurope comments on the consultation.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

28 May 2021

See position FoodDrinkEurope (https://www.fooddrinkeurope.eu/ ) as pdf attached.
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Meeting with Nicolas Schmit (Commissioner) and

18 Feb 2021 · Pact for Skills roundtable with the representatives of agri-food sector.

Meeting with Thierry Breton (Commissioner) and

18 Feb 2021 · Pact for Skills roundtable with the representatives of agri-food sector

Response to List of composite products exempted from official controls at border control posts

1 Feb 2021

FoodDrinkEurope, the European food and drink industry’s organisation, would like to thank the Commission for the opportunity to provide feedback on this proposal. We quote the concerns raised by the membership and we ask the Commission to consider the following points. FoodDrinkEurope members are concerned that the traffic at the Border Control Posts will increase substantially. Removing the % based exemption, the volume of goods which need to pass through Border Control Posts, will increase substantially. Considering that there are already significant delays at ports for various reasons (IT failures, Covid-related, document-related), and the timing of this change will only increase the number of loads requiring inspection. We understand that the new Regulation is intended to follow a risk-based approach. However, the process and basis which is being used to determine the risk is not clear to us. In particular, it is not clear why the new list of exempted products deemed to be low-risk was not extended to include other categories of shelf-stable composite products, not containing meat, which could also be deemed to fall into this category. Members would also welcome more clarity and guidance on the evidence that would be required to accompany an application to add a product category to the Annex of exempted products deemed to be low risk. It is noted that there is a lack of clarity about what will happen to foods already in transit before the date of application, which arrive at the border after the date of application. Furthermore, Members noted that the private attestation document is a new type of document and it may take several months to get familiar to its use. Commission guidance needs to be put in place several months in advance of these changes being implemented. Members would welcome the inclusion of decision tree flow charts in such a guidance document. Because the draft Commission proposal with the details of which products would be exempted has only made publicly available now, third countries need time to prepare for the new rules. In view of these practical issues, FoodDrinkEurope requests an extension to the application date of this measure in order to allow more time to advise businesses, agencies providing certificates, hauliers and customs agents, and for those parties to prepare for this significant change in procedures and documentation.
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Response to Revision of EU rules on food contact materials

28 Jan 2021

FoodDrinkEurope, the organisation representing Europe’s food and drink industry, welcomes the opportunity to contribute to the Inception Impact Assessment on the Revision of the EU rules on Food Contact Materials. Please find attached FoodDrinkEurope's detailed response to the Inception Impact Assessment.
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Response to Setting of nutrient profiles

27 Jan 2021

In light of the need for a more coherent and co-ordinated approach to food information in the EU, FoodDrinkEurope welcomes the opportunity that the EU Farm to Fork Strategy offers towards developing a science-based, harmonised framework for sustainable food information. The past years have seen an increasing fragmentation of food labelling rules across the EU, which can create confusion for consumers, is burdensome for business and creates unnecessary inefficiencies and waste, therefore acting as a detriment to more sustainable food systems. Given the plethora of potential additional consumer information requirements on various aspects of food (environment, nutrition, origin, animal welfare, etc.), and in light of the Farm to Fork Strategy's proposal for an EU sustainable food labelling framework envisaged in 2024, there is a need for a holistic reflection at EU level to avoid information overload, consumer confusion and negative impact on business. Such a reflection should take into account, amongst others: the actual goals which are expected to be achieved; effectiveness of current consumer information provision; consumer motivation and understanding; consistency and coherence between the various food information elements; practical feasibility for business; impact on the Single Market and international trade; and the role of digital consumer information solutions. The European food and drink industry is committed to further improve transparency and the provision of clear, factual and relevant information on the path towards more sustainable food systems. In this respect, the sector offers its technical knowledge and consumer insights to find common, harmonised solutions to further enhance food information to consumers. In the attached comments to the Inception Impact Assessment Roadmap, FoodDrinkEurope argues that the scope of the Impact Assessment could usefully be extended to include items for revision in the context of the Food Information to Consumers Regulation beyond front-of-pack nutrition labelling, nutrient profiles, origin labelling and date marking. Also, it invites the European Commission to consider - or review the need for - the implementation of outstanding provisions of the Food Information to Consumers Regulation. Finally, FoodDrinkEurope offers a comprehensive set of suggestions for elements to consider and assess in the Impact Assessment process on the food information topics referred to in the Commission's Roadmap.
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Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis) and European farmers and

20 Jan 2021 · WTO aircraft dispute

Response to Contingency plan for ensuring food supply and food security

13 Jan 2021

FoodDrinkEurope, the organisation representing Europe’s food and drink industry, welcomes the opportunity to contribute to the roadmap consultation “Contingency plan for ensuring food supply and food security”. Please find attached FoodDrinkEurope's detailed response to the consultation.
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Meeting with Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis), Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis) and

25 Nov 2020 · EU-US trade relations

Response to Amending the rules concerning the re-evaluation of approved food additives in view of the “Transparency Regulation”

2 Nov 2020

FoodDrinkEurope, the European food and drink industry’s organisation, would like to thank the Commission for the opportunity to provide feedback on this proposal. FoodDrinkEurope agrees with the comments made by EU Specialty Food Ingredients.
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Meeting with Janusz Wojciechowski (Commissioner) and

7 Oct 2020 · Future of the CAP, Farm to Fork Strategy, trade and Covid crisis.

Response to Empowering the consumer for the green transition

1 Sept 2020

The European food and drink sector supports the Green Deal ambitions to make Europe the first climate-neutral continent by 2050 and to move towards more sustainable production and consumption. Consumers play a key role in this transition. Food companies have been working to provide clear and reliable information on the environmental performance of their products, while promoting information provision and transparency along the food chain. We have been involved in the development of the PEF methodology, with today no fewer than eight sets of category rules for our sector. To prevent misleading claims, the sector has also called for the development of a harmonised framework for the voluntary use of PEF in environmental product claims. The new EC plan towards empowering consumers for the green transition aims to include measures for clearer and more reliable environmental claims for products and better-informed consumers. Its success will depend on its ability to set the right policy framework to ensure standardised, trustworthy and meaningful environmental information to consumers, while safeguarding the Single Market. 1. A harmonised and holistic approach -To enable consumers to make informed choices, harmonised rules on environmental information provision should be developed across the Single Market while creating a level playing field for sustainable products. -These rules should be sound, science based and in line with the Single Market. -They should be easy to use for companies of all types and sizes and for all types of products. -If a new standalone consumer protection instrument is developed, it should be coherent with, and build upon, existing consumer legislation such as the UCPD and the CRD. -The impact assessment should consider existing environmental provision schemes and best practices with a view to build on existing positive experience and tools. -A definition of ‘greenwashing’ should be developed and agreed upon by all stakeholders. 2.The methodology: Ensuring science-based information -A future policy framework should encourage the provision of science-based information based on the PEF methodology. -The PEF and its foundation in Life Cycle Assessment (LCA) is the most reliable and widely recognised methodology to assess products’ environmental impact and to provide reliable data. -The use of PEF should be made as simple as possible, be cost-effective and take into account the variety and complexity of products. -A new policy framework should provide tools and guidance on how to translate PEF results into information that is relevant to consumers. -It should ensure that any data is communicated in a clear, transparent, reliable and verifiable way. -Innovation to improve and stimulate the environmental performance of products should be encouraged, including by ensuring that PEF is flexible and responsive to newly available data and evidence. 3. The claim: Consumer choice and information -Environmental information should be used on a voluntary basis. Manufacturers should be able to choose which product should carry an environmental claim based on PEF. -Environmental information should be easily understandable to consumers and unequivocal from a scientific perspective. -The future framework should allow for credible 3rd party certification schemes to communicate environmental information provided they are PEF compliant. It should also allow to communicate on non LCA-related aspects (i.e. on packaging/recyclability). -The provision of environmental information to consumers should not come at the expense of providing other relevant and often mandatory information, such as on ingredients and nutritional aspects. -All information channels should be considered, including digital platforms. -Further research on consumer understanding and purchase decisions should be carried out. -Education initiatives and awareness raising campaigns, including using social marketing techniques, should also be undertaken.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

Methodology FoodDrinkEurope supports a credible and EU-harmonized environmental footprint methodology based on PEF. The harmonized PEF methodology should be the basis for identifying hotspots, promoting continuous improvement and provide product information to other businesses or consumers. You will find in the annex our papers on a proposal for a harmonized framework for the voluntary use of the PEF in environmental product claims and our views on environmental information. We welcome all efforts to establish a meaningful, credible and harmonized approach for Life Cycle Assessment-based environmental methodology across the European Union. Such efforts will support fair competition, increase consumer’s trust, empowerment and drive real change aligned with the shared aspirations by the EU and the Food and drink industry. The Life Cycle Assessment (LCA) and use of data on the Environmental performance of a product must remain as a voluntary exercise. Whenever quantitative information on environmental performance is used, the PEF should be the methodology used to calculate such information. The use of the PEF should be standardized in a policy framework which prevails over other initiatives and provides the tools on how to translate PEF results to communicable data along the chain and stakeholders. The policy framework based on the PEF should be developed with the support of interested industry stakeholders. The impact assessment of the framework should especially consider the implications and cost-effectiveness of legislation on companies specially SMEs. The framework should always take into account and promote innovation to improve the performance of products, including their environmental performance along the life-cycle. To create EU-wide PEF product group and sector-specific rules (PEFCR), the private sector should contribute directly, of course with input from other important stakeholders. The use of primary data should be favored by the future framework. The use of PEF will need to rely on a harmonized and regularly updated Emission Factor Database. Communication/Information The communication of environmental claims to consumers or other stakeholders should remain voluntary based on the PEF methodology. Communication should be flexible and represent all possible ways of communicating quantitative environmental information. Operators should be able to use the means and format of communication that they find is the most suitable and effective to support informed choices by the recipient of the information, The framework should therefore not prescribe any favored communication tool. Benchmarking a category rule for a product is not yet methodologically solid enough and risks misleading and confusing consumers. Thus, the framework should not provide indications on the comparability between of one product against another, even if they are in the same product category. Information used to communicate with consumers needs to be verifiable, credible, scientifically reliable, comprehensive, clear, not misleading, transparent, meaningful and readily to understand by consumers, be it linked to PEFCR or not. The provision of environmental information to consumers should not come at the expense of other relevant information. In this regard and in view of space limitations on pack, alternative information channels to product labelling, particularly digital platforms, need to be explored fully. The framework should allow for credible 3rd-party certification schemes to communicate environmental information as long as they are PEF compliant. It should also allow to communicate on non LCA- related aspects (i.e. on packaging attributes (recyclability) or messages requiring consumers to reduce food waste).
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Response to Amending the administrative and scientific requirements for traditional foods in view of the “Transparency Regulation”

20 Aug 2020

FoodDrinkEurope, the European food and drink industry’s organisation, would like to thank the Commission for the opportunity to provide feedback on this proposal. We do not have specific comments on the Draft Implementing Regulation. However, uncertainty still remains on how the new rules set by Regulation (EU) 2019/1381 regarding advice given to applicants, notification of studies, public consultation of third parties, confidentiality and standard data formats will be implemented in practice. We therefore look forward to continuing the dialogue with the Commission and EFSA on these matters, especially in the light of the Practical Arrangements that EFSA is preparing.
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Response to Amending the rules for applications for food additives, enzymes & flavourings in view of the “Transparency Regulation"

20 Aug 2020

FoodDrinkEurope, the European food and drink industry’s organisation, would like to thank the Commission for the opportunity to provide feedback on this proposal. We do not have specific comments on the Draft Implementing Regulation. However, uncertainty still remains on how the new rules set by Regulation (EU) 2019/1381 regarding advice given to applicants, notification of studies, public consultation of third parties, confidentiality and standard data formats will be implemented in practice. We therefore look forward to continuing the dialogue with the Commission and EFSA on these matters, especially in the light of the Practical Arrangements that EFSA is preparing.
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Response to Amending administrative & scientific requirements for applications for novel foods in view of “Transparency Regulation

20 Aug 2020

FoodDrinkEurope, the European food and drink industry’s organisation, would like to thank the Commission for the opportunity to provide feedback on this proposal. We do not have specific comments on the Draft Implementing Regulation. However, uncertainty still remains on how the new rules set by Regulation (EU) 2019/1381 regarding advice given to applicants, notification of studies, public consultation of third parties, confidentiality and standard data formats will be implemented in practice. We therefore look forward to continuing the dialogue with the Commission and EFSA on these matters, especially in the light of the Practical Arrangements that EFSA is preparing.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

6 Aug 2020

Please refer to the document in the Annex for the full FoodDrinkEurope contribution to the Packaging and Packaging Waste Directive Inception Impact Assessment. The end goals of the future PPWD and the new Circular Economy Action Plan (CEAP) should be to reduce and limit the environmental footprint of the life cycle of providing products to the end consumer and ensure that no packaging waste ends up into the environment, while fostering innovation in line with the European Green Deal ambitions. The Commission should follow an integrated approach to designing the most suitable set of measures, including in relation to recycling, reuse, packaging waste minimisation, and improvement of waste management infrastructure. Measures should be conceived as tools to achieve the end goals and their impact should be assessed through robust cost/benefit analysis and life cycle assessments that allow business to innovate at scale. The Commission should seek to provide solutions along supply chains and different packaging applications while considering other packaging elements, such as design for recycling, food waste prevention and reduction, and product safety and quality.
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Response to Hygiene rules on allergens, food redistribution and food safety culture

5 Aug 2020

FoodDrinkEurope, the European food and drink industry’s organisation, would like to thank the Commission for the opportunity to provide feedback on this draft regulation. We would welcome clarification on the scope of the following paragraph introduced in Annex I, Part A, Section II, point 5a, which is also added under Annex II, Chapter IX, point 9: 'Equipment, conveyances and/or containers used for the harvesting, transport or storage of one of the substances or products causing allergies or intolerances, referred to in Annex II to Regulation (EU) No 1169/2011, shall not be used for the harvesting, transport or storage of any food not containing that substance or product, unless the equipment, conveyances and/or containers have been cleaned and checked at least for the absence of any visible debris of that substance or product.' FoodDrinkEurope members consider that the proposal simplifies and potentially goes beyond the measures as agreed so far at Codex level as it would appear to require cleaning in all contexts whereas the Codex Code acknowledges that this should be done where necessary/as appropriate in a number of incidences. The focus on transport and storage devices only is not taking the aspects of modern allergen management into consideration. Beside transport and storage many more possibilities for inadvertent cross contaminations are possible. A visual inspection is required as risk mitigation, not taken into account cleaning steps or even the dose/response relation for different allergenic foods. A hazard analysis approach within the framework of HACCP should be promoted. We therefore believe that rather than including the requirement for a visual inspection, it is more relevant to specify that the equipment, conveyances and/or containers have been cleaned and checked according to a validated and verified cleaning process which is based on a risk assessment of usage. Hence, equipment, conveyances and/or containers used for the processing, handling, transport or storage of one of the substances or products causing allergies or intolerances, referred to in Annex II to Regulation (EU) No 1169/2011, should not be subsequently used for the processing, handling, transport or storage of any food, not indicated as containing that substance or product, until such point as suitable cleaning and/or other actions have been taken, as appropriate and feasible, to sufficiently minimise potential cross contamination. Food safety culture It appears from clause 8 in the preamble to the draft revision of 852/2004, that it is necessary to introduce general regulatory requirements for Food Safety Culture due to the ongoing work at the Codex General Principles of Food Hygiene (CXC 1-1969) (yet to be finalised) and expectations of consumers and trading partners. The work with Food Safety Culture, which originates from the industry's private standards, is still in process, as these are matters that have to do with human relations and are not a technical requirement such as e.g. HACCP. The concept is, as a defined phenomenon new, and still under development in relation to understanding, content and practice. In our opinion, there is no expectation among either third countries or consumers that companies have a defined Food Safety Culture, verified by the authorities. In addition, at present there are no objective criteria that can be used for authority verification of e.g. ‘Commitment, leadership, open and clear communication’, etc. There is currently no agreement within the private standards on how Food Safety Culture can be verified. FoodDrinkEurope members would therefore appreciate clarity on the enforcement. The provisions on Food Safety Culture look too vague to enforce in any kind of reasonable/rationale manner.
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Response to Chemicals strategy for sustainability

19 Jun 2020

The food and drink industry is Europe’s largest manufacturing sector and is conscious of the important role it needs to play in supporting the Green Deal as the growth strategy to re-boot the economic sustainability of the EU. Chemicals are essential contributors for many manufacturing industries, including the food and drink sector. Some examples are the sanitisers and disinfectants used to ensure that the foods produced are protected from microbial contamination, or the example of the chemicals used as food contact materials in packaging to protect food integrity. According to the Eurobarometer 2017 quoted in the Roadmap, 84% of Europeans are worried about the impact of chemicals in everyday products on their health and 90% about the impact of chemicals for the environment. Chemicals are often perceived unsafe while natural substances are perceived safe, which might frequently not the case. Nevertheless, the intrinsic toxic properties (hazard) of a substance is independent of its origin, natural or man-made. We believe it is paramount to invest on how the knowledge of consumers/citizens is built, and therefore urge the Commission to include an action plan aimed at improving the public perception of chemicals as part of this Strategy. For this, science-based and balanced communication is needed to prevent that existing or future safe and sustainable chemicals are not used, just because they are “chemicals’. FoodDrinkEurope welcomes that the strategy aims at encouraging innovation for the development of safe and sustainable alternatives to more hazardous chemicals. It is paramount that this shift is science-based and is harmonised at European level; unilateral actions by Member States should be prevented as they lead to a fragmentation of the internal market. We believe it important that decisions on how to manage chemicals should be based not on their intrinsic hazard alone, but on whether there are stages in their lifecycle that present an unacceptable risk to people or the environment. We believe that the most relevant aspect to consider to protect citizens and the environment, is not the hazard but the risk a specific substances poses: a hazardous chemical with very low exposure will be of lower concern than a less hazardous chemicals with a higher exposure. Thus, we would also like to stress the need for a sector-specific approach to any envisaged adaptation of the regulatory framework to address the risk posed by certain chemicals. There must be different assessments of the substances depending on their intended uses e.g. industrial chemical, packaging component and the assessments should continue to reflect exposure. A robust and comprehensive food legislation is in place to ensure a high level of protection of consumers in relation to food, while ensuring the effective functioning of the internal market. This regulatory framework is flexible enough to take into account new scientific information and methods in the assessment. An example mentioned in the Roadmap are endocrine disruptors, for which there are currently harmonised criteria for their identification under the Biocidal Products and the Plant Protection Products Regulations. Endocrine disruptors should be considered from a risk perspective rather than from a sole hazard identification, for example many naturally occurring (food) compounds might be considered to have an endocrine disrupting hazard, but do not normally present a risk to health and the same could be true for many man-made materials. Another example is the combination effects of different chemicals, on which EFSA has developed state-of-the-art methodologies such as the EFSA Guidance on harmonised methodologies for human health, animal health and ecological risk assessment of combined exposure to multiple chemicals (2019): it is therefore well equipped to address them as appropriate in its risk assessment.
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Meeting with Stella Kyriakides (Commissioner)

9 Jun 2020 · VC Meeting - Farm to Fork

Meeting with Thierry Breton (Commissioner) and

7 May 2020 · Exit and recovery strategy in the agro food sector

Meeting with Virginijus Sinkevičius (Commissioner) and

5 May 2020 · The implementation of the Circular Economy Action Plan and the European Green Deal, the impact of COVID-19 on the drink and food sector, green recovery, the forthcoming Farm to Fork and Biodiversity strategies, as well as research and innovation.

Response to Climate Law

30 Apr 2020

The food and drink industry welcomes the Commission’s proposal for a European climate law which was published on 4 March. The enshrinement of the 2050 climate neutrality goal in legislation and the holistic view taken by the Commission in the context of the European Green Deal will help engage all economic actors collectively in a common trajectory and encourage the swifter development of enabling conditions. It is also essential to provide long term guidance and predictability to businesses to invest in the transition. The European food and drink industry strongly supports the ambition to reach climate neutrality in the EU at the latest by 2050, to achieve the Paris Agreement objective . The transition towards a climate neutral economy is a business opportunity that will bring economic benefits and job creation and increase the EU’s competitiveness. The food and drink industry is committed to be faster and more far-reaching and ambitious in their actions to cut their GHG emissions in line with science-based targets and to adapt to already happening consequences of climate change. In the attached position paper, we call on policy makers to: - Ensure a clear pathway to 2050 with ambitious science-based mid-term targets - Ensure coherence and coordination between existing and future EU policy actions, including the new Circular Economy Action Plan and the future Farm to Fork Strategy, and avoid any trade-offs with food safety - Provide enabling conditions and support for the development of new business approaches, growth and jobs, leaving no one behind, based on robust impact assessments - Stimulate and support innovation and investments in low-carbon and resource efficient technologies - Engage consumers including through strengthening educational public campaigns and providing information through a multi-pronged approach - Foster actions to prevent and reduce food waste - Advocate for a global level playing field. You may also read our general position paper on climate change here: https://www.fooddrinkeurope.eu/uploads/publications_documents/FoodDrinkEurope_position_on_a_carbon_neutral_Europe_by_2050.pdf
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Meeting with Frans Timmermans (Executive Vice-President)

27 Apr 2020 · Green Deal and recovery in the food and drink sector

Response to EU rules on industrial emissions - revision

17 Apr 2020

FoodDrinkEurope feedback to European Commission Inception Impact Assessment on the Revision of the Industrial Emissions Directive FoodDrinkEurope has cooperated with the European Commission in the 2019 Evaluation of the IED. We would like to further contribute to this review with our comments to the Inception Impact Assessment Documents on the Revision of the Industrial Emissions Directive in view of certain aspects highlighted in the consultation document. Our sector supports a holistic approach to strengthen the circularity of our economic models to maximise resource efficiency and achieve carbon neutrality in the EU by 2050. - Inclusion of additional sectors: The inception impact assessment identifies potential sectors where the review of the Directive could be extended to: cattle farms, mixed farms, aquaculture and installations in current sectors just below the existing thresholds. We believe that any further extension of the scope of the directive should be properly impact assessed and consulted with the relevant stakeholders and industrial sectors. - Contribution to the circular economy: Industrial symbiosis and reusing valuable materials is a common practice in the Food and Drink industry and we therefore welcome European Legislation contributing to further it. Such approach should ensure that value of reusable materials is protected. The IED review is a very good opportunity to align related legislation around by-products. We would therefore request that terminology used in the IED is aligned with existing definition of by-products in the Waste Framework Directive . - Interaction with decarbonisation of industry: We would have the following preliminary remarks on including greenhouse gases as a relevant parameter in the IED. Form a technical perspective, CO2 can only be measured as load, i.e. resulting emissions from the combustion of a certain quantities of fuel. It can therefore not be measured as a concentration of a parameter, being this the procedure to establish measurable limits under the IED (AELs/AEPLs). CO2 load is very much dependant on the type of fuel and the energy/heat needs of the industrial processing of the raw materials/product. Such parameter can therefore only be stablished as an indicative value related to specific BATs but not as an Annual Emissions (Performance) Limit. From a legislative point of view, Green House Gases emissions are already regulated via the EU Emissions Trading Scheme (ETS). We believe further measures to reduce emission from industry should be focused in finding ways to strengthen ETS and avoiding overlapping legislation.
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Response to Farm to Fork Strategy

12 Mar 2020

The European food and drink industry strongly supports the green ambition pledged by the European Commission. Indeed, sustainable food production and consumption are indispensable conditions of making Europe the first climate-neutral continent. Food is essential for life, society, citizens and the economy; it should therefore be prioritised as a strategic sector for the European Union. Building on the high reputation and excellence of Europe’s food as safe, nutritious, culturally-diverse and of high quality, FoodDrinkEurope recognises the need – and fully supports the EU’s commitment – to strengthen our global leadership in sustainability. FoodDrinkEurope and its members are eager to play a constructive and pro-active role in driving the transition towards more sustainable food systems. This can only be achieved through supportive policy which is truly holistic, co-ordinated, harmonised, co-owned, inclusive and science-based. The policy must be continuously evaluated against its objectives and should include incentives for both consumers and businesses. For it to be successful, it must facilitate collaboration, partnership and open, forward-looking dialogue about opportunities, challenges and trade-offs, recognise Europe’s strength of diversity, ensure predictability, and enable the long-term economic viability and competitiveness of all players in the food chain. Work is not starting from scratch. With a central role between ‘Farm’ and ‘Fork’, FoodDrinkEurope members are, amongst others, heavily investing in improving the environmental and nutritional footprint of their products, improving the circularity of products and packaging, promoting more sustainable consumption behaviours, minimizing food losses, while ensuring safe, affordable, convenient and enjoyable food. Increased support for SMEs, a stronger Single Market for food and drinks, decreasing red tape and administrative burden through better regulation, research and innovation, and sustainable finance will be critical enablers for our sector to scale up, accelerate and deliver on tangible actions. The Farm to Fork Strategy presents a unique opportunity to support these efforts and minimize any barriers that food chain actors may face in contributing to the overall objective of more sustainable food systems. Attached herewith, we are pleased to provide FoodDrinkEurope's detailed preliminary contribution to the Farm to Fork Strategy. We look forward to working together with all interested parties in helping to achieve the EU's green ambition.
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Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

5 Mar 2020 · EU-US relations

Response to Minimising the risk of deforestation and forest degradation associated with products placed on the EU market

3 Mar 2020

FoodDrinkEurope welcomes the Commission's roadmap/Inception impact assessment on 'Minimising the risk of deforestation and forest degradation associated with products placed on the EU market’ as an integral part of the EU Green Deal mainstreaming biodiversity and resource efficiency with climate objectives, thus contributing to the implementation of the UN 2030 Agenda for Sustainable Development (SDGs), alongside the Paris Climate Agreement. Building on the European Commission’s communication entitled ‘Stepping up EU Action to Protect and Restore the World’s Forests’ alongside other existing EU instruments, such as Forest Law Enforcement, Governance and Trade Action Plan (FLEGT) and the EU Timber Regulation (EUTR), the food and drink industry believes it is essential to raise awareness about the importance of preventing deforestation, restoring forests and addressing the various challenges they encompass. There are several direct and indirect drivers of deforestation and forest degradation. They include activities such as the production of agricultural commodities (responsible for approximately 40% of deforestation), illegal logging, urban sprawl and mining. The recent fires in the Amazon forest in Brazil and Australia, have been a testament to the world that there is a need for urgent action to halt deforestation worldwide. Deforestation is affecting our sector and society alike. In this context, the food and drink industry has been working over the past 10 years to make its supply chains deforestation-free. While progress has been made, the industry recognises it needs to accelerate the pace of change. It is therefore committed to working collectively and with other supply chain actors and stakeholders to: -Implement the United Nations (UN) Sustainable Development Goals (SDGs); - Support the development of enabling frameworks such as Trade and Sustainable Development (TSD) chapters at EU level that promote sustainable sourcing; - Support the possible establishment of a harmonised framework on due diligence at EU level; - Strengthen the credibility and reliability of forest related certification schemes; - Participate in multi-stakeholder platforms/dialogue that will facilitate the exchange of best practices and help identify appropriate solutions and strategies to combat deforestation and foster afforestation. For more information on the above points, please see FoodDrinkEurope’s contribution paper on forest protection and restoration (attached).
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Meeting with Stella Kyriakides (Commissioner)

7 Feb 2020 · Discussion on food safety

Response to Climate Law

6 Feb 2020

Climate change has an impact on food systems, whether directly or indirectly. It can have an impact on food security, food prices, and the quality and safety of food products. In particular, extreme weather events, such as droughts and floods or rising temperatures, hamper food production, which may affect the long-term supply of safe, high-quality and affordable raw materials for the food and drink sector. In this context, most food and drink manufacturers have been integrating climate change in their business strategies and continuously work to minimise the environmental impacts of their products based on a life-cycle approach. Thanks to its efforts, it succeeded to reduce its GHG emissions by 12% between 2008 and 2017, while increasing production value by 5% in the same period. The European food and drink industry thus strongly supports the Paris Agreement objective to keep the global temperature increase below 2°C and to pursue efforts to keep it at 1.5°C. As part of the transition towards more sustainable food systems, it will take the lead in supporting Europe becoming the first climate-neutral continent in the world by 2050. FoodDrinkEurope welcomes the roadmap initiative for a European climate law aimed to achieve climate neutrality by 2050. We believe the future Law should reflect the following principles: - There is a need for a shared vision among all public and private actors and effective, coordinated actions; - Actions against climate change should be aligned in key areas, such as industrial policy, finance, trade or research, while ensuring social fairness for a just transition; - The fight against climate change needs to be included in a wider sustainability strategy to ensure sustainable and inclusive growth, environmental protection and social welfare. It should form integral part of the implementation of the Sustainable Development Goals (SDGs), while ensuring policy coherence and consistency, especially within the European Green Deal. - In this context, any initiatives directly related to the contribution of the agri-food sector to climate change mitigation and adaptation should ideally be addressed in relation with the future ‘Farm to Fork’ strategy. Moreover the Climate Law should make the following recommendations: - Further actions to reduce energy consumption and emissions from transport and logistics should be facilitated and incentivised as the most tangible actions to limit GHG emissions; - Other actions such as actions to reduce and prevent food waste and reduction of weight of transported goods should be encouraged, while avoiding any sustainability trade-offs, such as between energy efficiency and water consumption increase. - Investment in research, development and innovation needs to be accelerated, in particular to provide realistic technological solutions. We are pleased to attach a more detailed paper which outlines the way the food and drink industry is contributing to the EU climate objectives, while promoting sustainable and resilient food systems. This includes activities within our operations, such as in relation to energy efficiency, transport emissions, food waste and circular economy, as well as outside our operations, including sustainable sourcing and engaging with consumers and farmers. This paper also includes recommendations to ensure that the necessary conditions are in place for our sector to sustain its efforts and further contribute to combat and adapt to climate change.
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

FoodDrinkEurope welcomes the roadmap to a revised EU Biodiversity Strategy by 2030 as an integral part of the EU Green Deal, as well as the objective to mainstream biodiversity and resource efficiency with climate objectives, thus contributing to the implementation of the UN Sustainable Development Goals (SDGs). All Green Deal initiatives relating to the agri-food sector, including biodiversity, should be tackled together within the Farm to Fork action plan. Food and drink producers and value chain partners have a key role to play in addressing the EU and global challenges when it comes to pressures on ecosystems and services leading to biodiversity loss. We are determined to take actions, in a coordinated and holistic approach towards more sustainable food systems (see document attached), by supporting, for example, sustainable farming by scaling up regenerative agriculture practices to protect soil health, sustainable sourcing including protection of forests and eliminating deforestation, more efficient land use and the relative contribution to reduction of GHG emissions. Transition towards more sustainable food systems requires engagement and co-operation from all actors throughout the food supply chain both individually and collectively, at national, regional and global level. There is a need for a holistic, fair, and coordinated approach to create conditions for farmers to transition towards regenerative agricultural practices, preserve biodiversity and increase resilience, including working together with food manufacturers. We will encourage a shift of mindsets, business models and strategies across the whole chain, to ensure that sustainability becomes a strategic priority for all food business operators. We welcome the Commission’s intention to launch a post-2020 strategy to address the main causes of biodiversity loss in Europe and globally. International cooperation is essential and we look forward to internationally agreed biodiversity targets based on scientifically determined indicators at the UN Conference on Biodiversity in Kunming in October. Bearing the above in mind, we would like to highlight the following aspects: • Sustainable sourcing: Protecting and restoring ecosystems and services is at the center of our sustainable sourcing strategy. We will contribute to those objectives by halting deforestation throughout supply chains. We welcome the Commission Communication on protecting global forests and we intend to contribute to strengthening the existing regulatory framework on sustainable forest management and land use, following a coherent approach to existing commitments, initiatives, and best practices. • Resource efficiency: We strive to further preserve the value of resources that go into producing of food and drink products and to ensure the most efficient use of resources, in particular water, energy and raw materials. To this end, we are supporting the development of robust methodologies to measure the hotspots for biodiversity along the agri-food chain and keep natural resources in balance. • Agriculture: Agriculture has a key role to play in view of the forthcoming EU Biodiversity Strategy 2030, as it will be an essential component not only of the protection and restoration of biodiversity more broadly, but key to secure the resilience and long-term sustainability of agricultural production. We will work closely with the agricultural sector to drive the necessary change, which should be supported by adequate financial resources under the future CAP. • International trade: We support the EU’s commitment to include trade and sustainable development chapters in all EU Free Trade Agreements. It is important that these efforts are made in partnership with third countries to ensure they lead to effective improvements in the implementation of key international climate and biodiversity commitments.
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Response to A new Circular Economy Action Plan

20 Jan 2020

FoodDrinkEurope welcomes the roadmap initiative for a new Circular Economy Action Plan as part of the EU Green Deal and in line with the EU long term climate strategy and competitiveness and growth objectives. There is a need for a coherent and consistent approach to be followed throughout and any initiatives directly related to the agri-food sector should be addressed in relation with the future ‘Farm to Fork’ strategy. More specifically, the Action Plan should consider the followings: Sustainable products policy We support boosting design for reuse and recycling of packaging, including through minimum requirements for their placing on the market. These requirements should be based on harmonised design-for-recycling guidelines with evidence-based criteria and common methodologies. Packaging functionality must be taken into account in this work. Effective design of packaging is indeed key to protect and maintain food safety and quality, extend products’ shelf life and reduce transport emissions. Consumer acceptance and quality of waste management infrastructure are also key elements to consider. We support the creation of a harmonised regulatory framework on biodegradable, compostable and bio-based plastics. It will bring legal clarity and pave the way to further innovation. Existing (ISO) standards should be built upon. Engaging consumers We support enhancing consumer demand for circular products by ensuring product environmental information is reliable and credible and preventing false claims. There is a need for a coherent and harmonised product environmental footprint framework based on the PEF methodologies. National consumer information/ awareness raising actions are also needed to enable consumers to contribute to the proper disposal of waste and prevent littering. Waste generation We welcome the proposal to further reduce waste generation. To this aim, the future guidelines on the eco-modulation of EPR fees should ensure a fair and proportionate distribution of costs following a coherent and harmonised approach. The guidelines should be aligned to the future revised essential requirements of the Packaging & Packaging Waste Directive (PPWD). We also support creating an EU model for separate collection. This model should help contribute to better waste sorting and recycling based on the shared responsibility of all actors. It should be supported by innovative and high-quality recycling infrastructure that can deal with a wider range of materials. Minimum collection, sorting and recycling infrastructure requirements are needed, together with minimum quality criteria for this infrastructure. We also support increasing the amount of waste treated domestically and preventing problematic waste exports. This will help increase recycling and should go together with supporting a business case to improve recycling infrastructure in the EU. Recycled materials Our sector is working to increase the use of recycled content in plastic packaging wherever possible. To this aim, our sector needs to have access to high-quality, safe recycled materials at competitive price and in sufficient quantity. In this context, we call for the Commission to actively support the work of the Circular Plastics Alliance , update the food contact materials regulations and speed up the recycling processes autorisation. Innovation & investment We support the need for innovation and investment to support a more circular economy. Innovation and financial support are needed, alongside enabling regulatory framework, to create market conditions for more reusable and recyclable food packaging. We call to accelerate EU funding into developing collection, sorting and recycling infrastructure and the development of new recycling technologies, such as enhanced recycling.
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Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski)

8 Jan 2020 · US sanctions

Meeting with Sabine Weyand (Director-General Trade)

23 Oct 2019 · EU Trade Policy, EU Agri-Food Sector

Response to Enhancing Market transparency in the agri-food chain

17 Jun 2019

FoodDrinkEurope is the European organisation representing the EU food and drink industries. It welcomes the opportunity to comment on the draft Implementing Regulation regarding market transparency. In the context of a market-driven agriculture, market intelligence such as facts, estimates, data, is essential. FoodDrinkEurope finds that overall there is sufficient market transparency, from both public and private sources, for all stakeholders to obtain a comprehensive overview of agricultural markets. In particular, the market observatories provide data and facts that support market transparency. This draft Implementing Regulation is aimed at increasing market transparency along the chain, to the benefit of farmers in order to provide them with “accurate and timely market data”. However, FoodDrinkEurope considers that the proposal will not reach this objective and it could, if not amended, weaken some supply chains to the detriment of farmers. • Excessive price transparency can reduce operators’ negotiating capacity and thus restrict competition. Indeed, market transparency can be misinterpreted and contribute to a distorted picture of the supply chain; • Extending prices notification to the prices received by processors from retailers for some consumer products would encourage downward pressures on the processors’ selling prices and on the farmers’ income; • The legal provisions leave the definition of representative prices to Member States. The lack of harmonization will make comparison at EU level inappropriate; The complexity of the negotiation process between retailers and processors make the calculation of representative prices difficult. • Within each sectorial category, products are very diversified. Without specific product definitions for the reporting in the draft regulation, comparison of prices between Member States will not be relevant and could be misleading; Therefore, FoodDrinkEurope doubts that the draft implementing regulation will really benefit all operators in the food chain. As explained above, providing chain parties with price information can produce undesirable effects on the performance on some supply chains and hamper competition. The increased pressure on processors can be felt by farmers upstream in the chain.
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Meeting with Timo Pesonen (Acting Director-General Internal Market, Industry, Entrepreneurship and SMEs)

12 Jun 2019 · DG GROW met FoodDrinkEurope (FDE), at their request, to discuss priorities and ideas for the next five years of the Commission work in the food and drink sector.

Response to Establishment of a methodology of measurement of food waste

4 Apr 2019

FoodDrinkEurope’s answer to the EC public consultation on Food Waste measurement FoodDrinkEurope is firmly committed to supporting the implementation of the UN SDG 12.3 to halve food waste by 2030 and is an active member of the EU Platform on Food Losses and Food Waste. In this context, we warmly welcome the Commission’s draft delegated act on food waste measurement, alongside its accompanying document. We however have proposals for improvement for both documents which we believe the EC should take into account before final adoption. These proposals are detailed below as well as, for ease of reading, provided directly (as comments) on the draft documents for which can be found in an annex to this paper. Delegated act - (p.1) We believe it important to refer to – or even highlight the importance of – the Food Loss and Waste Accounting and Reporting Standard, also known as the FLW standard, developed by WRI . Although this standard is more global, it is certainly a measurement tool which has been used and embraced by many food and drink companies for quantifying food loss and waste along the supply chain. - (p.4) Sources of food waste to sewer are broader than just the beverage sector. It would be important to give further examples of what can be excluded with regards to this point so as to avoid future misinterpretation. - (p.5) Reporting templates, additional to the expected voluntary reporting template, should be developed as an Annex to the measurement methodology document. This will ensure a minimum level of consistency in the way Member States will report as well as enable adequate interpretation and comparability of reported data. This will also contribute to limiting potential administrative burden and facilitate the longer-term reporting exercise. - (p.7) Significant modifications used by Member States for measuring food waste for each stage of the food supply chain might cause a distortion with regards to the quality and comparability information received. The use of a coherent measurement methodology should be privileged in order to allow for effective analysis and comparability of the data which will in turn inform any future decisions or initiatives to tackle food wastage. Annex to the Delegated act - (p.5) The potential combination of methodologies as proposed under Annex III of the document could lead to reports not being comparable. We recommend limiting the number of methodologies and make sure similar and comparable methodologies are used in the most effective and consistent manner in all Member States. - (p.7) We strongly recommend to specify, under Annex IV, the minimum sample size which Member States should measure for each stage of the supply chain in order to ensure a balance of food manufacturing sectors covered.
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Meeting with Anne Bucher (Director-General Health and Food Safety)

28 Feb 2019 · introductory meeting

Response to Commission Regulation setting maximum residue levels for chlorate in or on certain products

14 Feb 2019

FoodDrinkEurope welcomes the opportunity to provide comments to this draft regulation. We strongly believe that Regulation (EC) 396/2005 is not the appropriate legal framework for the management of multiple source substances and especially chlorate, for which several different entry points may occur across the supply chain up to the final product intended for the consumer. The possible presence of chlorate in food has been found to come from multiple sources, such as water use, disinfection and processing aids, but not as the result of its use as a pesticide (Kettlitz et al., 2016). One example is the use of chlorinated drinking water during cultivation, harvest and processing. The use of chlorinating agents for drinking water disinfection is not a mandatory requirement in the EU; however, in several Member States chlorination is applied to ensure safe drinking water in compliance with the EU Drinking Water Directive, which is currently under review. We call for a consistent EU legislation. In addition, in its opinion on multiple use/multiple source substances (Ref. XI.10a), the REFIT Platform Stakeholder group recommends changing the definition of "pesticides residues" in Regulation (EC) 396/2005 to ensure that rules should only apply to residues from plant protection products. The Stakeholder group further asks the Commission to propose suitable Maximum levels and Maximum Residue Limits (MLs/MRLs) for multiple use substances under the relevant legislative framework. It is our understanding that these concerns will be addressed in the context of the ongoing evaluation of the plant protection products legal framework, expected to be finalised in 2019. Notwithstanding the above, FoodDrinkEurope is very concerned about the draft chlorate MRLs which are currently the subject of a public consultation, since the proposed levels are often far from what would now be realistically achievable while ensuring/maintaining microbiological safety. This would not only threaten the ability of the food industry to supply safe food for EU citizens, but would also threaten the existence of many food producers. The use of disinfectants in food manufacturing in a responsible manner is an integral part of Good Manufacturing Practices. Disinfectants for the cleaning of food contact surfaces are essential for the control of microbial, viral or parasitic pathogens, limiting their occurrence in food and water and thereby mitigating acute risks to human health. It is important to mention that significant efforts and investments have been made since 2014 by food business operators to reduce the levels of chlorate in foods, without compromising food safety. We have, however, now often reached the limits of what can practically be done using existing technologies and within the boundaries of what is economically or legally feasible. It must also be noted that the proposed MRLs cannot be achieved without the significant contribution of water suppliers, chemicals producers, third countries etc. It is for all these reasons that we believe that no feasible solution can be achieved under Regulation (EC) 396/2005. We would therefore welcome discussions on the setting of achievable Maximum Limits for chlorate, under the appropriate legal framework and having sufficiently assessed from a technical and legal standpoint the various origins of chlorates. The discussion must also be based on a solid risk assessment considering real consumers’ exposure to chlorate from all possible sources, taking into account the microbiological safety of foods and the compromises that would certainly occur should the use of chlorine-based disinfectants need to be reduced or replaced. REFERENCES Kettlitz et al. 2016. Why chlorate occurs in potable water and processed foods: a critical assessment and challenges faced by the food industry. Food Addit Contam Part A Chem Anal Control Expo Risk Assess. 2016 Jun;33(6):968-82. doi: 10.1080/19440049.2016.1184521
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Meeting with Michel Barnier (Head of Task Force Task Force for Relations with the United Kingdom) and European farmers and

4 Feb 2019 · Meeting with the Task Force for the Preparation and Conduct of the Negotiations with the United Kingdom under Article 50 TEU

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

10 Dec 2018 · Single use plastics

Meeting with Juergen Mueller (Cabinet of Vice-President Karmenu Vella), Sebastien Paquot (Cabinet of Vice-President Karmenu Vella)

10 Dec 2018 · Single Use Plastics

Response to Establishing a legal limit for the industrial trans fats content in foods

30 Oct 2018

• FoodDrinkEurope supports the European Commission’s draft Regulation amending Annex III to Regulation (EC) No 1925/2006 of the European Parliament and of the Council as regards trans fat, other than trans fat naturally occurring in animal fat, in foods intended for the final consumer. • FoodDrinkEurope supports the transition period envisaged in the draft Regulation. We would also recommend to permit food products which have been lawfully placed on the market before the date of application of the Regulation to remain on the market until the exhaustion of stocks. • FoodDrinkEurope recommends the deletion of the mandatory labelling requirement for hydrogenation as part of the next round of labelling updates to Regulation (EU) 1169/2011 on the provision of food information to consumers. • FoodDrinkEurope would welcome a commitment from the European Commission to support programmes/funding for companies, particularly Small and Medium-sized Enterprises (SMEs), to reformulate products in order to comply with the Commission’s Regulation.
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Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

17 Sept 2018 · Printing inks in food contact materials

Response to MFF: 9th Framework Programme for Research and Innovation and Rules for Participation and Dissemination

6 Aug 2018

Investing in Research and Innovation (R&I) is crucial to deliver on key societal challenges, boost job creation and growth and strengthen competitiveness in Europe. FoodDrinkEurope welcomes the Commission proposal for a regulation establishing Horizon Europe – the Framework Programme for Research and Innovation, laying down its rules for participation and dissemination for establishing Horizon Europe. This Commission proposal builds on the success of previous Framework Programmes. To strengthen this proposal, we call on the European Institutions to: • Promote the competitiveness of European industries of all sizes as one of the key objectives for Horizon Europe • Significantly increase public spending in R&I, including increased support in areas relevant to the food and drink sector. • Keep the right balance across the whole R&I chain, from the generation of new knowledge to the exploitation of the solutions available. We particularly welcome the three-pillar structure, which reflects well the whole innovation process. Thus, Horizon Europe should combine projects with low and high Technology Readiness Levels (TRL), ranging from novel ideas and breakthrough concepts to incremental solutions with rapid scale-up potential. • Consider a ‘food-themed mission’ to advance towards Food and Nutrition Security, mobilising all actors and investors, at different levels and from different disciplines, to make real progress and help consumers attain safe, affordable, healthy and sustainable diets. • Design new public-private collaborative models to attract and leverage investments and translate research more effectively into innovation and growth. Making it easier for the public and private sectors to work together in delivering innovation is fundamental to accelerate the generation of results and impact. • Engage citizens in R&I processes, re-launching and tackling societal challenges. Citizen science and societal engagement will help deliver more relevant and acceptable outcomes and spread awareness on the necessary changes, particularly those that affect lifestyles and behaviour. • Simplify further the administrative requirements of the participants of the programme, while preserving continuity in Horizon 2020 rules for participation. • Ensure a stable and coherent EU innovation policy. Removing barriers to innovation is also essential to boost the global competitiveness of European industries and will create the right conditions for innovation to flourish. • Foster a balanced approach between Open Science and Intellectual Property Policies. Please find more details about FoodDrinkEurope’s views on Horizon Europe attached. An ambitious Framework Programme is paramount to position the EU as a global industrial leader and safeguard EU growth and jobs. We truly believe that increasing EU budget in R&I and maximising its impact will enable the generation of new breakthrough concepts and allow food and drink businesses to apply new knowledge, skills and techniques.
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Response to Multiannual Financial Framework: Specific Programme implementing the 9th Framework Programme for Research and Innovation

6 Aug 2018

Investing in Research and Innovation (R&I) is crucial to deliver on key societal challenges, boost job creation and growth and strengthen competitiveness in Europe. FoodDrinkEurope welcomes the Commission proposal for a decision on establishing the specific programme implementing Horizon Europe – the 9th Framework Programme for Research and Innovation. This Commission proposal builds on the success of previous Framework Programmes. To strengthen this proposal, we call on the European Institutions to: • Promote the competitiveness of European industries of all sizes as one of the key objectives for Horizon Europe • Significantly increase public spending in R&I, including increased support in areas relevant to the food and drink sector. • Keep the right balance across the whole R&I chain, from the generation of new knowledge to the exploitation of the solutions available. We particularly welcome the three-pillar structure, which reflects well the whole innovation process. Thus, Horizon Europe should combine projects with low and high Technology Readiness Levels (TRL), ranging from novel ideas and breakthrough concepts to incremental solutions with rapid scale-up potential. • Consider a ‘food-themed mission’ to advance towards Food and Nutrition Security, mobilising all actors and investors, at different levels and from different disciplines, to make real progress and help consumers attain safe, affordable, healthy and sustainable diets. • Design new public-private collaborative models to attract and leverage investments and translate research more effectively into innovation and growth. Making it easier for the public and private sectors to work together in delivering innovation is fundamental to accelerate the generation of results and impact. • Engage citizens in R&I processes, re-launching and tackling societal challenges. Citizen science and societal engagement will help deliver more relevant and acceptable outcomes and spread awareness on the necessary changes, particularly those that affect lifestyles and behaviour. • Simplify further the administrative requirements of the participants of the programme, while preserving continuity in Horizon 2020 rules for participation. • Ensure a stable and coherent EU innovation policy. Removing barriers to innovation is also essential to boost the global competitiveness of European industries and will create the right conditions for innovation to flourish. • Foster a balanced approach between Open Science and Intellectual Property Policies. Please find more details about FoodDrinkEurope’s views on Horizon Europe attached. An ambitious Framework Programme is paramount to position the EU as a global industrial leader and safeguard EU growth and jobs. We truly believe that increasing EU budget in R&I and maximising its impact will enable the generation of new breakthrough concepts and allow food and drink businesses to apply new knowledge, skills and techniques.
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Response to Multiannual Financial Framework - CAP Strategic Plans

1 Aug 2018

FoodDrinkEurope preliminary comments on the proposal for a regulation “Multiannual Financial Framework - CAP Strategic Plans” The CAP is one of the key policies for the sustainable growth of the food and drink industry, as the EU industry is the bigger customer of EU agricultural raw materials. The industry relies on the supply of safe and competitively priced agricultural raw materials, with the quantity and quality needed to produce sufficient and varied food for European consumers and for its export market. Besides, the European food and drink industry is composed of 99% Small and Medium-sized companies, the majority of which are located in rural areas sourcing locally close to the place of farming. A truly common policy is necessary The Single Market, one of the EU’s greatest achievements, is celebrating this year its 25th anniversary. While acknowledging the wide diversity of EU agriculture and rural areas, only a truly common agricultural policy can guarantee a strong and well-functioning Single Market and prevent distortions. Since the Commission proposes to give Member States greater subsidiarity in implementing CAP interventions, including those within Pillar 1, safeguards of the common character of the CAP will be essential. For FoodDrinkEurope, these safeguards include: • A strong role of the Commission both ex-ante and ex-post, i.e. in the assessment, approval and monitoring of the national CAP Strategic Plans. • The assurance of a level-playing field within the Single Market to be a condition for the approval of the national Strategic Plans. • Adequate coordination within the Commission’s services to cross-check that national choices do not distort competition in the Single Market. • The Commission to prepare a master CAP Strategic Plan, as suggested in the European Parliament and by Member States, with dedicated boxes for CAP interventions and the respective financial allocations. This would facilitate a comparison of the national choices, among other things. In particular FoodDrinkEurope is concerned that granting Member States flexibility in the following areas could lead to distortions of competition among farmers, and hence among food processors, across the EU: • Flexibility to allocate funding to different direct payments interventions: - We support a clear budget earmarking at EU level, as part of the “checks and balances” of the policy cycle foreseen in the Impact Assessment. Hence, the EU regulation should provide for the maximum shares of national envelopes for each intervention. • Flexibility to grant coupled support to specific sectors or types of farming: - The conditions to grant coupled support should be specific and clearly defined in the EU regulation or, as a minimum, in the implementing powers of the European Commission. • Flexibility to reward farmers beyond compensation of additional costs and income foregone in the voluntary eco-schemes in Pillar 1: - High environment and climate ambition in the next CAP will be crucial to ensure a more sustainable future for our food systems but the EU should set common criteria for the incentives. The CAP should drive a competitive EU agriculture We support the CAP objective to increase competitiveness. A strong, productive and efficient European agricultural sector is key to secure the supply of agricultural raw materials. We will be particularly vigilant that the policy continues to evolve towards more market orientation. This will help advance the competitiveness of EU producers and manufacturers at home and abroad.
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Response to Towards a more comprehensive EU framework on endocrine disruptors

18 Jul 2018

FoodDrinkEurope appreciates the Commission initiative to develop a comprehensive framework on endocrine disruptors and welcomes the opportunity to provide comments on this roadmap. The roadmap states that the framework will take stock of the current situation and outline the next steps. Indeed, we think that such a framework should build on the progress already achieved, as reflected in a number of EFSA’s scientific opinions and guidance documents (e.g. European Food Safety Authority (2013), Guidance for the identification of endocrine disruptors in the context of Regulations (EU) No 528/2012 and (EC) No 1107/2009) and which should be mentioned explicitly as background information. FoodDrinkEurope supports continued use of a coherent and harmonized EU regulatory approach based on robust data and sound scientific evidence. Consistency and harmonization on the implementation at national level of the EU legislative framework are also crucial.
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Response to Reducing marine litter: action on single use plastics and fishing gear

18 Jul 2018

You will find in the annexed document fooddrinkeurope recommendations on the European Commission proposal on FoodDrinkEurope recommendations to the EP on the EC Proposal for a Directive on the reduction of the impact of certain plastic products on the environment
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Response to Transparency and sustainability of the EU risk assessment model in the food chain

22 Jun 2018

FoodDrinkEurope is representing Europe’s food and drink industry, the largest manufacturing sector and leading employer in the EU and a key contributor to its economy (289,000 companies, 99% SMEs, 4.2 million employees), welcomes the opportunity to respond to the proposal. FoodDrinkEurope supports the objective of the proposal, which is to increase the transparency and the sustainability of the EU risk assessment process. However, we are concerned with a number of aspects of the proposal which we believe will unnecessarily burden and would potentially damage Europe’s food and drink industry. Our concerns centre on the following points: • The lack of an impact assessment for this proposal is worrying. This contravenes the better regulation agenda of the European Commission, and could have a hugely negative impact on the European food and drinks industry. EFSA risk assessment is hugely important, and its integrity cannot be called into question. • The proposal as it currently stands has the potential to impede on innovation in the EU. The possibility that confidential data might be publicised can lead to companies prioritizing other regions over Europe, which will have a knock-on effect on research in the EU. • FoodDrinkEurope believes that the protection of confidential business data must be maintained. • A high level of expertise should be maintained or strengthened in EFSA, however, risk assessment should be done by the best scientists. If the talent pool is limited, it is not necessary to geographically limit the risk assessors to EU.
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Response to Initiative to improve the Food Supply Chain

14 Jun 2018

FoodDrinkEurope, representing the EU food and drink industries, believes that the proposal for a Directive on Unfair Trading Practices (UTPs) has the potential to create a minimum harmonisation across the EU level. However, to efficiently tackle UTPs in the food chain, the legislation needs to have an impact on all commercial relations among the different actors of the chain – farmers, processors, retailers and retail alliances. The extension of the scope to all players in the food chain is the key priority for the food and drink industry, in order to support the good functioning and the competitiveness of the whole agri-food supply chain. Indeed, UTPs do not discriminate by size of supplier. Unless the entire food supply chain is addressed, UTPs will continue to affect SMEs, farmers and therefore thousands of workers. The supply chain is an interdependent system – inefficiencies or challenges in one part of that system have a ‘domino effect’ on the whole chain. All manufacturers regardless of size, can be very dependent on a limited number of retailers. For a manufacturer, a contract to supply a retailer may represent a large proportion of its business, whilst conversely, one contract for a retailer will represent only a small fraction of its overall business, creating a very one-sided relationship. Moreover, the imbalance in the food chain has become stronger with the growth of retail alliances, composed of the largest European retailers. The size of these alliances gives them further bargaining power that jeopardizes the contractual freedom of the other party and its ability to refuse unfair conditions. Moreover, as indicated by the Commission in the explanatory memorandum, there is a wide-spread consensus that UTPs occur throughout the food supply chain, The Commission acknowledges that “UTPs can put operators’ profits and margins under pressure” and adds that, in 2011, “manufacturers participating in a survey reported that UTP-related costs amounted to 0.5% of turnover, which would be equivalent of €4.4 billion per year of overall food industry”. In addition, 20 EU Member States have UTP legislation (EC Impact Assessment, April 2018) – but not one existing legislative instrument treats some players in the supply chain and not others. Out of 20 Member States, none focuses on SME-only legislation. The coordination among national bodies is another important element of the proposal, in particular, regarding cooperation on specific cross-border cases. The EU Directive needs to ensure efficient cooperation between enforcement authorities. In cross-border cases, it should be clear which national enforcement authority is competent. Finally, the EU Directive needs to allow the continuation of national approaches which work efficiently, without generating additional complexity.
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Response to Towards an EU Product Policy Framework contributing to the Circular Economy

4 Jun 2018

FoodDrinkEurope represents Europe’s food and drink industry, Europe’s largest manufacturing sector in terms of turnover, employment and value added. Firstly in is relevant to highlight that Food and drink products are already covered or have been recently assessed under a large number of European Policies cited in the roadmap: • Product Environmental Footprint (PEF) and Organisation Environmental Footprint (OEF) pilots • Fitness check on the EU Ecolabel and the Eco-Management and Audit Scheme • Public Procurement for a Circular Economy – good practice and guidance • Communication on ‘A new deal for Consumers • Revision of waste legislation • European strategy for plastics in a circular economy; • Communication on options to address the interface between chemical, product and waste legislation With regards to the use of the Product Environmental Footprint methodologies in food and drink products FoodDrinkEurope would like make the following recommendations: • We would recommend a harmonised policy framework based on the PEF that is supported by industry. The policy framework should ensure that use of the PEF should be voluntary. • The policy framework should be flexible. The variety and complexity of food and drink products imply both significant initial cost and ongoing expenditure to perform environmental footprinting, particularly when products are reformulated and new products are developed. A flexible policy which would allow companies to decide what is most appropriate for their individual circumstances would be advisable. • In order to ensure consistency and comparability of results, the policy framework should apply life-cycle thinking from (even pre-) farm to fork/glass and beyond for food and drink products, with a view to enhancing environmental performance along all food chain stages, including the consumption stage. • The policy framework should support the use of PEF as a diagnostic tool for identifying hotspots and promoting continuous improvement. PEF is not yet sufficiently developed to be used to compare one food product against another as it impedes a level playing field amongst products. • Given the importance of the food and drink sector for the European economy, its strong involvement in the PEF pilots - accounting for around half of the pilots -, and the environmental specificities existing within this broad sector, any policy discussions must continue to engage the PEF food and drink pilots in a public-private partnership. • The policy framework should help enhance Europe’s international competitiveness. Food and drink production operates within global supply chains. The policy framework must also improve the operation of the Single Market and should not constitute a distortion of competition or an unjustifiable obstacle to the proper functioning of the Single Market or to international trade agreements. • The policy framework should always take into account and promote innovation to improve the performance of products, including their environmental performance along the life-cycle. • The communication of any results to consumers or other stakeholders should remain voluntary and off-pack. It is vital that the information provided is verifiable, credible, scientifically reliable, comprehensive, clear, not misleading, and transparent, particularly in the absence of a PEFCR. • In terms of communication vehicles, operators should be able to use the means and format of communication that is the most suitable and effective to support informed choice by the recipient of the information, including the use of digital technologies. The integration of Food and Drink products in other existing policies require of the availability of a robust and science-based methodology suitable to food and drink products. This is an essential precondition for the development of policy initiatives related to the environmental
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Response to Negotiation mandate for revising an agreement with the US on the import of hormone-free beef

24 Apr 2018

FoodDrinkEurope, representing the European food and drink manufacturing sector, appreciates the publication of the European Commission Roadmap “Negotiation mandate for revising an agreement with the US on the import of hormone-free beef” and opportunity to provide feedback. We strongly encourage the EU and its US counterparts to engage in a constructive dialogue on this topic and support what the Commission initiative aims to achieve, notably: - "[...] to address US concerns raised regarding the implementation of the MoU, to find a mutually satisfactory solution in line with WTO rules, and to facilitate the eventual termination of the long-standing dispute."* A situation whereby the US would withdraw from the current “Memorandum of Understanding” (MoU) and could re-impose trade sanctions on EU exports to the US must be avoided, as this would run the risk of disrupting the well-established EU-US trade relations. The US is the EU food and drink industry’s largest export market and second largest supplier of agri-food products for the EU market (raw materials, ingredients and finished products). In 2016, EU28-US trade in agri-food products reached a cumulated €32 billion** and food and drink industry activity on both sides of the Atlantic is significantly integrated. Thank you in advance for your kind consideration and efforts to maintain stable transatlantic trade relations. We look forward to being kept informed about the future developments of this file. --- *Roadmap - Ares(2018)1684779 https://ec.europa.eu/info/law/better-regulation/initiative/213924/attachment/090166e5b98f51f5 **DG AGRI – Factsheet of EU28 agri-food trade with the United States https://ec.europa.eu/agriculture/sites/agriculture/files/trade-analysis/statistics/outside-eu/countries/agrifood-usa_en.pdf
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Meeting with Marika Lautso-Mousnier (Cabinet of Vice-President Jyrki Katainen)

9 Apr 2018 · Questions related to the quality of foodstuffs

Response to Revision of the Drinking Water Directive (RECAST 2017)

29 Mar 2018

FoodDrinkEurope, representing Europe’s food and drinks industry, would like to thank the European Commission for the opportunity to comment on the proposed drinking water directive. Please find in attachment a position paper outlining the main FoodDrinkEurope concerns, which can be summarised as follows: Status of water used in food processing plants FoodDrinkEurope is concerned that the proposed changes to the definition of “water intended for human consumption” may introduce undue uncertainty for food business operators (FBOs). FoodDrinkEurope also seeks clarification in understanding the scope of the proposed changes regarding the point of compliance. FoodDrinkEurope also believes that coordination of the provisions of the proposal on water intended for human consumption and the provisions of the General Food Law and Regulation (EC) No 852/2004 on the hygiene of foodstuffs should be considered to alleviate the concerns as outlined in our position. Bottled water FoodDrinkEurope notes with concern the intention of the European Commission, as expressed in the Explanatory Memorandum of the proposed Drinking Water Directive, to introduce policies that "will help reduce bottled water consumption". We seek clarification from the Commission that the drinking water initiative will not directly work against the interests of Europe's food and drinks industry. Chlorate FoodDrinkEurope is concerned regarding the proposal of a maximum level of 250 ppb and whether this level would be an effective safeguard against microbiological contamination, as it is considerably lower than the WHO provisional guideline levels of 700 ppb. FoodDrinkEurope submits that it should be stipulated that food containing chlorate as a result of the presence of chlorate in water intended for human consumption/potable water should be deemed safe unless it is explicitly provided otherwise. The chlorate level as proposed may force FBOs to ignore this guidance, and may serve to inadvertently contradict best practice on the safety of the product. Endocrine Disruptors It is not clear how the benchmark parameters for endocrine disruptors (EDCs) have been established. To the best of our knowledge, criteria for the establishment of these are still in the process of being finalised for pesticides and biocides, and a scientific debate had not been taken place at European level for any other type substances. We therefore question the consideration of bisphenol A, beta estradiol and nonylphenol as an EDC in the proposed directive. FoodDrinkEurope also outlines some queries/concerns regarding the chemical criteria and microbiological parameters as included in the drinking water directive as proposed. FoodDrinkEurope wishes to thank you for your consideration, and looks forward to future opportunities to contribute and collaborate on this directive. Eoin Keane FoodDrinkEurope
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Response to Update of the 2012 Bioeconomy Strategy

20 Mar 2018

FoodDrinkEurope supports the European Commission in continuing to promote a circular and sustainable economy and therefore welcomes the update of the 2012 EU Bioeconomy Strategy in light of recent policy developments. Europe’s food and drink sector is committed to maximising the use of available resources and to continuously improve waste management practices at every stage along the food supply chain, always prioritising and ensuring food safety. The food sector is a main contributor to the Bioeconomy value chains. The food and drink manufacturing contributes to roughly half of the turnover for the activity sectors composing the bioeconomy in the EU. Between 2008 and 2014, the turnover of the EU bioeconomy grew by approximately EUR 140 billion, and this increase was mainly driven by the food sector. We agree that a systemic approach to future-proofing food systems in Europe is essential, expanding beyond strategic research and innovation. In this regard, the FOOD2030 initiative and its core priorities need to be closely linked with the updated Bioeconomy Strategy.
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Response to More and better mutual recognition for the single market for goods (revision Regulation (EC)764/2008) (Goods package)

19 Mar 2018

FoodDrinkEurope initial comments on the Proposal for a Regulation of the European Parliament and of the Council on the mutual recognition of goods lawfully marketed in another Member State. We welcome the Goods Package and its focus on ensuring trust in the internal market for goods. We especially appreciate the proposal for a Regulation on the Mutual Recognition of goods lawfully marketed in another member state (MS). FoodDrinkEurope is encouraged by proposals that bring clarity, coherence and stability to our industry. Uncertainty related to the absence of a negative decision • The Proposal no longer foresees a legal fiction which states that goods are considered lawfully placed on the market in absence of a negative decision of the authorities. FoodDrinkEurope would like to propose a suitable article for inclusion, which would confirm that should the competent authority fail to notify the economic operator of a decision within the allotted timeframe, the product is deemed “lawfully marketed” in the original Member State. Need for clarification regarding timing, etc. • According to Art. 5(1), should the relevant competent authority have doubts over the lawful marketability of goods, it is to contact the relevant economic operator “without delay”. We would like if a particular timeframe was set for this communication, as “without delay” is open to interpretation. • According to Art 5(3), FoodDrinkEurope notes that the authorities have 20 working days to communicate their decision on the mutual recognition declaration. However, we would appreciate if a timeframe for this decision to be made were specified. Clarification of terminology, etc. • Art. 5(5)(b) states that the MS of designation must inform the business operator, EC and the other MS of the reasoning for not allowing the goods into the market after an assessment. The grounds acceptable are “legitimate public interest grounds”, defined in art. 3(12) as meaning “any of the grounds set out in Article 36 of the Treaty or any other overriding reasons of public interest.” Since the principle of free movement of goods and the justification for the exceptions are mentioned in the Treaty, we see no reason to broaden the list of exceptions in a secondary legislation. • According to Art. 6(2)(a) the MS of designation can prohibit the marketing of the goods if the goods under normal and reasonably foreseeable conditions of use pose a serious risk. In order to ensure legal certainty, the definition of “serious risk” should be clarified. Should the risk concern food, there should be a reference to art. 14 in the General Food Law (178/2002), which contains the basic harmonized criteria for determining if a food is unsafe. Legal obligation of the business operator regarding mutual recognition declaration • A product should be deemed as lawfully marketed in an MS should it be on the market. Further administrative burden with an explicit confirmation from the relevant competent authority, the form of which could differ between MS, should not be necessary for a mutual recognition declaration. Problem-solving procedure • Article 8 suggests to strengthen an existing problem-solving tool, SOLVIT, by allowing Commission involvement should the MS not be able to reach consensus. FoodDrinkEurope would, however, suggest that the possibility to involve the Commission be granted to business operators. Furthermore, we wish to stress the importance of improving the current SOLVIT system by following up on the Action Plan on SOLVIT (COM (2017) 255 final). Product Contact Points • In the case that the Product Contact Points will not have the technical knowledge to answer the questions related to concrete national legislation. We would prefer that the 15 working days response deadline applies to the response to the question, rather than other referrals, etc. FoodDrinkEurope has also included some annotations on the proposal itself, which are in track changes in annex 1.
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Meeting with Věra Jourová (Commissioner) and

25 Jan 2018 · Dual Quality

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

19 Jan 2018 · Single Market, HLForum, Food Chain inc UTPs and Market transparency, SMEs

Response to Reducing marine litter: action on single use plastics and fishing gear

12 Jan 2018

The food and drink industry supports that actions have to be made in the field of single use plastics are taken at EU level. As highlighted in the Impact Assessment the free movement of packaged goods in the internal market is a fundamental principle of the EU and a crucial dimension for the food and drink industry and to the benefits of European consumers. With this we would like to provide recommendations on how the policy options listed in the Inception Impact Assessment could be further developed Packaging material replacement. It is worth remembering that not all plastic materials are suitable to come in contact with food, according to EU legislation. Additionally, when defining product design, packaging for food and drink products must prioritise safety and quality, as well as avoiding food waste. We trust these conditions will be taken into account when defining policy options. Packaging prevention. The assessment of the “unintended consequences“ of policy options such as prevention or substitution of packaging play an enhanced role in the case of packaging for perishable products such as food and drinks. Therefore life cycle assessment tools, on a product by product basis, must play a crucial role for to balance the benefits and externalities of packaging options. EPR fee modulation. To ensure consistency across the EU Single Market, the methodology used to modulate these fees should be EU harmonised, scientifically reliable, consistent and not misleading, and should allow flexibility for innovation. Stricter implementation of the existing and future legislation on waste. We support the need for consistent implementation and enforcement of existing provisions and essential requirements in the Waste Framework and Packaging and Packaging Waste Directives. This will help increase recovery and recycling levels without the need of reviewing the current targets. We believe that enhanced recycling can only be achieved by a strong market for recycled materials (secondary raw materials), which can only be feasible if the needed conditions apply (good quality of the recyclates, competitive price of the recycled materials). Responsiveness of the waste management sector. The waste management sector should increase its responsiveness to developments in materials design and innovation as far as sorting and recycling technologies are concerned. Funding and innovation incentives are necessary to foster recyclers’ further performance in this sense. Stimulation of deposit return schemes. The viability of reusable packaging is highly dependent of key factors: • Efficiency of existing waste management systems (e.g. Extended Producer Responsibility (EPR) systems) should be acknowledged. EPR schemes and deposit schemes for one-way packaging both working in parallel could increase the competition for the waste material being managed. • The types of packaging that can be covered by a deposit system are traditionally limited to very specific applications. EPR schemes provide the alternative to such limitation as these cover a wide array of packaging types. • Consumer behaviour and geographical characteristics of the region are a determining factor in the operability of deposit systems as these are closely linked to local infrastructure. • Reuse of packaging materials does not always deliver the best environmental outcome compared to one way packaging. In addition such systems have proven in some countries to provide lower incentives to reduce packaging weight and could lead to a decrease of efficiencies in kerbside collection systems. • Must also ensure not costly and inconvenient especially to consumers compared to kerbside systems • In many cases, options for the reuse of plastics are limited to specific applications,
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Meeting with Vytenis Andriukaitis (Commissioner)

18 Dec 2017 · Food waste, Animal Welfare, Labelling

Meeting with Jyrki Katainen (Vice-President)

15 Dec 2017 · Competitiveness of Food & Drink Industry, single market and trade issues

Response to Fitness Check of the Water Framework Directive and the Floods Directive

16 Nov 2017

FoodDrinkEurope, the umbrella organisation of the European Food and Drink Industry, welcomes the Commission Fitness Check of the Water Framework Directive and the Floods Directive. In the Roadmap it is stated, “Water is essential for many economic activities and for the environment”. FoodDrinkEurope would like to reiterate the importance of this statement for the manufacturing of foods. Chlorination of potable water used in food processing plays an essential role in the control of microbial, viral or parasitic pathogens and limits the occurrence of foodborne diseases. We particularly welcome the recognition in the Roadmap of an “integrated assessment looking, inter alia, at the interplay of water with other policies, which started in mid-2017, as this is critical to ensure the setting of appropriate food related risk management measures, related to the eventual presence of chlorate in food resulting from the use of drinking water in food production. The REFIT stakeholder platform requests proportionate risk management measures regarding the presence of chlorate in food, for details see: https://ec.europa.eu/info/sites/info/files/xi10amultiple_use_chlorate.pdf . FoodDrinkEurope fully supports the comments made by SNE (Specialised Nutrition Europe) being a member of FoodDrinkEurope We are looking forward to further discussions.
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Response to Implementing act on the Union list

2 Nov 2017

FoodDrinkEurope, the umbrella of the European Food and Drink Industry would like to offer the attached comments.
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Meeting with Věra Jourová (Commissioner) and

11 Oct 2017 · Dual quality

Response to Commission Regulation on maximum levels for glycidyl esters in certain foods

18 Sept 2017

FoodDrinkEurope, the umbrella organisation of the European food and drink industry, would like to thank the Commission for giving the opportunity to comment on the draft Regulation on maximum levels for glycidyl esters (GE) in certain foods. FoodDrinkEurope takes concerns raised about the presence of GE in food very seriously, and supports the vegetable oil and fat industry in its mitigation efforts. FoodDrinkEurope supports the proposed limits for GE on vegetable oils and fats placed on the market for the final consumer or for use as an ingredient in food, and in vegetable oils and fats destined for the production of infant formula, follow-on formula and foods for special medical purposes intended for infants and young children. However, we believe that it is necessary to say that the GE level for cereal-based food is applicable to processed cereal-based foods and baby foods for infants and young children according to Commission Directive 2006/125/EC. Recital 7 of the draft regulation recognizes the need for food business operators (FBOs) to be granted enough time to adapt their production processes. Therefore, for reasons of legal certainty and clarity and to allow for necessary delineation between different FBOs, we are asking for the inclusion of a proportionate and explicit transitional period for the implementation of these maximum limits. This would offer appropriate protection for those products already lawfully placed on the market prior to the entry into force of the Regulation to remain on the market until the date of minimum durability and/or use by date, avoiding retroactive application, and would furthermore allow FBOs to ensure that raw materials used in their production processes are compliant. FoodDrinkEurope would like to reiterate that further clarification, as requested, would be beneficial.
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Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development) and European farmers and

15 Sept 2017 · Exchange of views

Response to Initiative to improve the Food Supply Chain

22 Aug 2017

Please find attached FoodDrinkEurope feedback on the Inception Impact Assessment of the Commission Initiative to improve the Food Supply Chain.
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Response to Commission Implementing Regulation laying down administrative and scientific requirements for novel food applications

16 Aug 2017

FoodDrinkEurope would like to thank the Commission for the opportunity to comment on this Draft Commission Implementing Regulation. There is no reference in the draft to the EFSA Guidance on the preparation and presentation of an application for authorisation of a novel food in the context of Regulation (EU) 2015/2283. We think that this reference should be made to facilitate the reading and ensure consistency between the EFSA Guidance document and the draft act. Article 5 should align more closely or simply attempt to repeat the requirements specified in the EFSA Guidance. We nonetheless wonder whether the Implementing Regulation should detail the toxicology requirements or simply refer to EFSA to specify those. The latter would allow more flexibility when an update is needed since a guidance document is easier to amend than an Implementing Regulation. If the draft was adopted, Article 5(5) would require the applicant to provide the raw data, even in case of published studies. However, in some cases the applicant might not have the right to share or have access to the raw data underpinning a published study, for instance when an applicant relies on the supplier’s studies. Article 23(3) of Regulation (EU) 2015/2283 gives the applicant the right to withdraw the application whenever a disagreement occurs with the Commission over the confidentiality of information. At the same time, Article 6(2) of the draft act would allow the Commission to consult with EFSA during the same period of time. Although Article 23(7) of Regulation (EU) 2015/2283 provides that information exchanged between the Commission, Member States and EFSA is not covered by confidentiality, the protection of confidentiality would be frustrated in case the review request to EFSA was considering falling within the scope of Article 1(1) of Commission Regulation (EC) No 1304/2003 and accordingly docketed in the registry of questions. In this case, competitors could learn about the request before the applicant would be granted the right to withdraw the application. We respectfully suggest that the Commission should be allowed to consult with EFSA only after the three weeks’ time of Article 23(3) of Regulation (EU) 2015/2283 has expired. According to Article 8 the Member States shall notify to the Commission the lists of requests referred to in Article 35(1) of Regulation (EU) 2015/2283 by 1 March 2018. One of the goals of Regulation (EU) 2015/2283 is to accelerate the placing on the market of novel foods, and therefore we cannot understand the 2 months of administrative delay in the handover of the existing files. We respectfully suggest that Member States should notify to the Commission the lists of requests before January 2018 or at the very least by 1 January 2018, and that these lists should be dealt with first. Article 28 of Regulation (EU) 2015/2283 foresees that the applicant may file a parallel submission for a novel food approval and health claim review under Regulation (EC) no 1924/2006. The cover letter template of the draft Commission Implementing Regulation (Annex I), besides allowing for the request of confidentiality and data protection, should also allow for the inclusion of a parallel submission and for the staying of the novel food approval as foreseen by Article 28. Annex I lists four different types of applications in line with the wording of Article 9(2) of Regulation (EU) 2015/2283. The Annex does not allow the applicant to request the review of the post-market monitoring measures as listed in the Article, which may consist in requirements different than labelling. As an example, an applicant could be requested to periodically report sales data on a given novel food, which, with time passing and increasing history of use, could become irrelevant. An example would be an applicant asking the Commission to revisit the post-marketing monit
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Response to Implementing act on procedures for novel food status

16 Aug 2017

The draft act does not provide for any protection of confidentiality. The Implementing Regulation should ensure that the information shared with Member States is treated as confidential, in line with Article 4 of Regulation (EC) No 1049/2001. This is particularly relevant for FBOs as they must provide sensitive details (e.g. production process). Moreover, without specific rules FBOs could not claim confidentiality later in the process in case a subsequent application is requested. We therefore suggest that confidentiality provisions are included under this draft act. Article 4.2 of Regulation (EU) 2015/2283 specifies that FBOs shall consult when they are unsure whether the food is novel or not. Although, referred to in Article 1 of this draft implementing act, in several sections of the draft act and Annex II it is implied that the food is novel when the procedure is initiated. We therefore suggest that the mention to ‘novel food status’ is replaced by ‘status of the food’. In addition, Article 3.1 seems to indicate that FBOs are always required to consult. This should be clarified since Article 4.2 of Regulation (EU) 2015/2283 only applies when the FBO is unsure whether the food is novel or not. Regulation (EU) 2015/2283 and the Draft Commission Implementing Regulation could lead to the same outcome with two different legal consequences. Article 5 of Regulation (EU) 2015/2283 states that the Commission may decide that a certain food is novel with a binding implementing act. According to the draft act, a Member State could conclude that a certain food is novel and a notification will be published on the Commission’s website. One could wonder whether this notification would apply erga omnes or not given that this outcome would not be a legal act and therefore not subject to the same legal scrutiny of an implementing act. There are also no provisions included to account for a situation where other Member States would have divergent views. Moreover, other FBOs willing to place on the market the same or similar foods could not object the conclusion of a certain Member State, which could lead to the same uncertainty stemmed from Mensch und Natur AG v Freistaat Bayern case (C-327/09). The outline of the Technical Dossier seems to mirror the one of the novel food application. We wonder whether the Member State needs such in-depth information to perform the assessment. In order to ease the reading of Annex II, the 3 last paragraphs of the introduction could be rearranged as follows: ‘For all foods, Section 1 must be completed’; ‘For extracts, in addition to Section 1, Section 2 must be completed’; ‘For foods resulting from a production process not used for food production within the Union before 15 May 1997, in addition to Section 1, Section 3 must be completed’. Accordingly the titles of the sections could be renamed as follows: ‘Section 1: for all foods’; ‘Section 2: only for extracts’; Section 3: only for foods resulting from a production process not used for food production within the Union before 15 May 1997’. In Table 2 of Annex II we recommend including the terms ‘consisting of, isolated from or produced from’ in category A to be consistent with Regulation (EU) 2015/2283. The requirement of indicating which part of the organism the use for human consumption refers to (point 3.2) seems fully valid for plants and animals and sometimes algae, but its meaning for micro-organisms, fungi and micro-algae is not clear. Purity/concentration is only listed for category B, for the sake of consistency this information should also be listed for category A. Table 5 of Annex II could be simplified by grouping 5.1, 5.2 and 5.3. Table 6 of Annex II makes a legal obligation for FBOs to consult other FBOs or their federations in order to gather sufficient information, although this is not stipulated in Regulation (EU) 2015/2283. We therefore suggest deleting table 6 or replacing ‘shall’ by ‘may’.
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Response to Commission Impl. Reg. laying down administrative & scientific requirements for traditional foods from a Third Country

16 Aug 2017

FOODDRINKEUROPE COMMENTS ON THE ADMINISTRATIVE AND SCIENTIFIC REQUIREMENTS CONCERNING TRADITIONAL FOODS FROM THIRD COUNTRIES FoodDrinkEurope would like to thank the Commission for the opportunity to comment on this Draft Commission Implementing Regulation. There is no reference in the document to the EFSA Guidance on the preparation and presentation of the notification and application for authorisation of traditional foods from third countries in the context of Regulation (EU) 2015/2283. We think that this reference should be made to facilitate the reading and ensure consistency between the EFSA Guidance document and the draft act. The intention of the notification procedure for traditional foods from a third country is to enable its authorisation in the EU based on its history of safe use. Article 14 of Regulation (EU) 2015/2283 lays down the information to be included under the notification, which does not requires applicants to demonstrate the safety beyond the demonstration of safe history of use. Nevertheless, the Draft Commission Implementing Regulation extends the required information by requiring a risk assessment of the traditional food from a third country. We think that this is fundamental change that goes beyond the aim of the notification, which will then need to comply with the same rules as an application, creating administrative burden, delays and the need for additional toxicological studies and other safety studies in the light of the safe history of use of the food in the third country. Based on the aforementioned EFSA guidance, the request of raw data of individual studies (published or not) in Article 6.4 of the proposed Implementing Regulation doesn’t seem appropriate for products whose safety is assessed based on experience of continued use (see EFSA guidance part 2.6). Article 11: Timings in the transitional measures (1 Jan 2019) does not seem to be in line with the NF regulation (2 Jan 2020). Annex I lists four different types of applications in line with the wording of Article 9(2) of Regulation (EU) 2015/2283. The Annex does not allow the applicant to request the review of the post-market monitoring measures as listed in the Article, which may consist in requirements different than labelling. As an example, an applicant could be requested to periodically report sales data on a given novel food, which, with time passing and increasing history of use, could become irrelevant. An example would be an applicant asking the Commission to revisit the post-marketing monitoring requirements under Article 24 Regulation (EU) 2015/2283 and directly addressed to him/her.
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Response to Commission Regulation on the use of Listex™ P100 against Listeria in ready-to-eat food products

9 Aug 2017

FoodDrinkEurope would like to thank the Commission for the opportunity to comment on the proposed regulation which permits the use of Listex™ P100. We welcome the approval of the use of Listex™ P100 for the reduction of Listeria monocytogenes on ready-to-eat (RTE) products of animal origin. The availability of further products to combat this pathogen is also welcomed, underlining the utmost priority food business operators give to the safety of their food product. FoodDrinkEurope therefore acknowledges and appreciates the EFSA evaluation of Listex™ P100, which confirmed the safety of the product and stated that resistance to key therapeutic antimicrobials was unlikely to result from its use. The application Listex™ P100 would therefore complement existing good management and hygiene practice for the benefit of food business operator (FBO) and consumer alike. However, FoodDrinkEurope seeks clarification on some points which are as of yet not covered in the Commission’s proposal: • FoodDrinkEurope understands that bacterial genetic material may persist after successful application of Listex™ P100, and therefore assumes that non-viable listerial cells could be detected and the food product deemed unfit. Will phage-treatment technology interfere with molecular based analytics in food control measures and environment monitoring programmes? Can the accuracy of the testing/detection methods be confirmed? Can further clarification and guidance on how best to enforce good management practice in this instance be offered? • As per point (11), the regulation notes that FBOs handling meat, fishery and dairy products can use Listex™ P100 subject to certain conditions. However, there is no clarification of what these conditions are and whether FBOs handling other product types are not subject to such conditions. The draft regulation mentions as one of the conditions that FBOs need to include sampling plans for validation of Listex™ P100 treatment efficacy and monitoring for resistant L. monocytogenes strains. While validation of treatment efficacy is relevant to assure food safety, evidence of efficacy does not need to be included in the HACCP plan of the particular FBO. Such evidence would be established prior to bringing a product into production at an FBO and its HACCP plan would include measures to verify that the treatment is implemented as per the validated conditions. Notably, not all FBOs may have the capability to do the validation themselves and will resort to other expertise sources; however, they should be able to verify proper implementation conditions. Similarly, many FBOs will not have the capability to assess whether Lm strains possibly present in raw materials or the processing plant are resistant to Listex™ P100. This specific requirement seems excessive when compared to existing regulation. In using Listex™ P100, it should be sufficient when a FBO implements such measures such that validated conditions are met and meets the hygiene requirements and microbiological criteria stipulated in the Regulations quoted in point (10). FoodDrinkEurope would like to underline the food industry’s commitment to providing safe food, and reiterates its support for any product which would effectively contribute to this aim, as we believe Listex™ P100 does. Clarification in points above-mentioned would be valued to ensure best practice in future. Beate Kettlitz Director, Food Policy, Safety and R&D FoodDrinkEurope
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Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Elżbieta Bieńkowska), Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska) and AIM - European Brands Association

3 Aug 2017 · differences in compositions and in alleged quality of food

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and

25 Jul 2017 · dual quality of food

Meeting with Věra Jourová (Commissioner) and

25 Jul 2017 · dual quality of food

Response to Commission Reg. (EU) on the application of control & mitigation measures to reduce the presence of acrylamide in food

6 Jul 2017

FoodDrinkEurope welcomes this proposal as a pragmatic and effective approach to mitigate acrylamide. The application of this binding Regulation will ensure all food business operators (FBOs) take action to manage the formation of acrylamide; this will lead to a further reduction of levels in products and in consumer exposure. For the regulation to be effective it is essential that the benchmark levels (BLs) and mitigation measures are practicable and enforceable. To this end, we suggest the following improvements: 1. Some sectors are concerned that certain BLs have been set impractically low and are based on data that is not representative. In these cases we urge the Commission to take account of larger and more representative data sets, where available, in order to establish evidence-based and realistic BLs that accurately reflect the diversity of the food chain. This may necessitate adaptation of the food categorisations used. To support greater reductions in acrylamide, further agronomical research should become a priority. We welcome recognition that ‘’…there may be specific production, geographic or seasonal conditions or product characteristics for which it is not possible to achieve the benchmark levels despite the application of all mitigation measures’’ (Recital 10). However, we cannot see this reflected in the definition for BLs in Article 3 (2), or when referring to BLs in Annex III (2), (5) and (6). This should be addressed to avoid confusion in implementation. The descriptor “Products similar to the other products in this category” requires clarification. It is also unclear why the level is lower than for other products in the category. 2. We are concerned that the text gives certainty to consideration of maximum levels (MLs). The public health objective is to reduce consumer exposure as much as possible; hence we believe FBOs should be working to reduce levels of acrylamide in their products to the lowest levels reasonably achievable rather than on the basis of a static ML. Acrylamide formation is highly variable and MLs do not allow for sporadic irregularities in levels that result from natural variations in raw materials. Such outliers make it impossible to use pre-testing to monitor compliance with an ML across a production batch. Outliers could also trigger unwarranted product recalls: these are disruptive for any food business, and potentially crippling for SMEs. The problem of outliers is an issue for MLs regardless of whether they are considered as alternative to, or complementary to, the current Regulatory proposal. Similarly, the availability of suitable raw materials (dependent on varietal, geographical and seasonal aspects) will make it difficult to establish MLs that are both stringent and workable across the EU. We find it crucial for the success of this regulation to allow FBOs to demonstrate their efforts to introduce appropriate mitigation measures and meet BLs before MLs are considered. 3. Further clarification is necessary regarding the definition of different operators (Recital 12, Art 2 (2) and (3)). It is not immediately clear which companies fall under these definitions. Specification is needed to ensure the regulation can be successfully implemented. We find it encouraging that the annex builds on existing best practices to reduce levels of acrylamide in food. The legal obligation for businesses to implement specific measures to keep acrylamide as low as is reasonably achievable is an effective and practical approach. Furthermore, the mandatory nature of the Regulation means compliance will be strictly assessed and enforced as part of official controls. The safety of the food chain, including mitigation of acrylamide, is of utmost importance to the food industry; we will continue to build on our work of the last decade to research and develop new and better solutions for reducing levels in foods under the framework of this proposal.
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Meeting with Věra Jourová (Commissioner) and AIM - European Brands Association

11 May 2017 · Dual food quality

Meeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan) and Weber Shandwick

8 May 2017 · FoodDrinkEurope Reputation Audit

Meeting with Jyrki Katainen (Vice-President) and Plastics Europe and

28 Mar 2017 · Plastics Value Chain

Response to Flavourings - as regards certain flavouring substances

24 Nov 2016

As informed by the European association representing the flavour industry (EFFA), the number of flavouring formulations impacted by the draft Regulation is estimated at more than 7000. These flavourings are used at different dosages in different food/beverage applications, alone or mixed with other flavourings. Some flavourings might also contain several of the substances covered by the draft Regulation. Given the number of different foods and beverages that is likely to be impacted, it is impossible to double check if all the applications are reflected on the draft Regulation within the short period of 4 weeks of the public consultation. Hence, as FoodDrinkEurope, we are not in the position of providing feedback on that aspect. The draft Regulation has a transition period of 20 days after publication in the Official Journal. It is not realistic to expect that the whole food industry, and especially SMEs, can review and, if required, reformulate products containing these substances within the 20-day transition period. We take note of the comments provided by EFFA, the specialised industry association and we trust they have expressed the appropriate concerns of this industry which would affect our business operations.
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Meeting with Phil Hogan (Commissioner)

24 Nov 2016 · Agriculture Issues

Meeting with Vytenis Andriukaitis (Commissioner) and

17 Nov 2016 · Roundtable on the future of the General Food Law Regulation

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

19 May 2016 · High Level Forum for a better functioning food supply chain

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

15 Dec 2015 · Joint mtg European agri-food chain organisations/Markets in Financial Instruments Directive

Meeting with Antonio Lowndes Marques De Araujo Vicente (Cabinet of Commissioner Carlos Moedas) and Fédération Européenne des Fabricants d'Aliments Composés and

24 Nov 2015 · H2020, new Scientific Committee

Meeting with Daniel Calleja Crespo (Director-General Environment)

18 Nov 2015 · Circular Economy

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis), Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

28 Sept 2015 · Nutrition and Health, Food Safety

Meeting with Robert Madelin (Director-General Communications Networks, Content and Technology) and American Chamber of Commerce to the European Union and

3 Jun 2015 · New College and Better Regulation

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

21 May 2015 · High Level Forum for a Better Functioning Food Supply Chain

Meeting with Ladislav Miko (acting Director-General Health and Food Safety) and Union Européenne du Commerce du Bétail et des Métiers de la Viande and

26 Feb 2015 · GM import authorizations

Meeting with Vytenis Andriukaitis (Commissioner) and

23 Feb 2015 · Implementation of the Regulation (EU) 1169/2011 (Food Information to Consumers).- Labelling & Food Safety and Fraud

Meeting with Carl-Christian Buhr (Cabinet of Commissioner Phil Hogan)

10 Dec 2014 · General presentation of the organisation, topics of current interest, http://www.supplychaininitiative.eu/