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Freshfel Europe - the forum for the European fresh fruits and vegetables chain

Freshfel

Freshfel Europe represents the European fresh produce sector, promotes fruit and vegetable consumption, and advocates for improved market access and sustainability.

Lobbying Activity

Meeting with Johannes Van Den Bossche (Cabinet of Commissioner Christophe Hansen) and GroentenFruit Huis

5 Nov 2025 · Exchange of views on sustainability, simplification, and competitiveness in the fruit and vegetable sector

Meeting with Pierre Bascou (Deputy Director-General Agriculture and Rural Development)

16 Oct 2025 · The role of interbranch in the supply chain

Fruit sector urges overhaul of EU pesticide authorization rules

14 Oct 2025
Topic — Consultation on simplifying food safety and marketing authorizations for agricultural products.
Message — Freshfel calls for a reverse approach where pesticides are permitted unless explicitly restricted. They also request a fast track for low-risk substances and removing zonal divisions.123
Why — Streamlined rules would provide growers with a wider, more reliable toolbox of solutions.4
Impact — Environmental groups lose protections if the precautionary approach is sidelined to favor faster approvals.5
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Meeting with Elena Panichi (Head of Unit Agriculture and Rural Development)

4 Sept 2025 · Exchange of views on the European fresh fruit and vegetable trade with the Americas.

Response to Import into the Union of high-risk organic and in-conversion products

11 Jul 2025

Freshfel Europe is the European Association representing the fresh fruit and vegetables sector. We take note of the Commission proposal amending Delegated Regulation (EU) 2021/1698 as regards certain criteria for the establishment of the list of high-risk third countries and high-risk products. Confidence in fresh produce and its characteristic are of the utmost relevance for the sector for the confidence of consumers. While understanding the rational of strict controls for the compliance with the EU organic regulation, we have reservation that that suspicion could be leading to reclassification of a products or a specific origin. When considering suspected cases to take concrete decision, it might be discriminatory for some products being included on a high risk list even though there are no proven cases of non-compliances. The measures will lack proportionality and sanction unfairly producers and EU importers with a high-impact measure even in practice in full compliance with the organic legislation. Placing products/origins on an high risk list has far reaching implications and should therefore be only based on concrete and repeated cases and not on the basis of mere suspicions. Furthermore, making checks stricter could also lead to longer custom procedures, which in the case of a perishable product like fresh fruit and vegetables could have important consequences on the quality of the product as well as raising the amount of food waste.
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Response to Fruit and vegetables – review of sectorial rules and modernising certain market monitoring provisions and mechanisms

10 Jun 2025

The Commission proposal suggests that for simplification purposes, SIV should be calculated on a weekly basis. This new approach might lead to several undesired consequences that are explained in the attached position including: Disconnection of a weekly calculated value with the daily fluctuating market reality Risks of market disturbances resulting form possible "stop and go" Uncertainty of the representativeness of the new value if not any more based on daily reporting Administrative v. business simplification
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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 Elena Panichi (Head of Unit Agriculture and Rural Development)

16 May 2025 · Exchange of views on the European fresh fruit and vegetable trade with the Americas

Meeting with Frank Bollen (Head of Unit Agriculture and Rural Development)

24 Apr 2025 · Exchange of views on some issues concerning exports of fruits & vegetables to some neighbourhood countries

Meeting with Vytenis Povilas Andriukaitis (Member of the European Parliament)

9 Apr 2025 · EU Health

Freshfel Europe demands exemption from mandatory written contracts

10 Mar 2025
Topic — The EU is proposing amendments to agricultural regulations to strengthen farmers' supply chain positions.
Message — The organization requests an exemption from mandatory written contracts for every delivery to avoid administrative burdens. They also oppose new limits on the representativeness and membership rules for producer organizations.12
Why — Exemptions would prevent significant administrative and financial costs while maintaining the speed of business operations.34
Impact — Growers and consumers lose as mandatory paperwork creates unrealistic burdens and increases food waste.56
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Meeting with Ricard Ramon I Sumoy (Acting Head of Unit Agriculture and Rural Development)

24 Jan 2025 · Exchange of views on the future Vision of agriculture and food

Meeting with Tom Vandenkendelaere (Member of the European Parliament)

4 Oct 2023 · Farm to Fork strategy, pesticides, new genomic techniques

Freshfel Europe demands green claim rights for loose produce

20 Jul 2023
Topic — This proposal requires companies to use standardized methods to substantiate their environmental claims.
Message — The association supports using Product Environmental Footprint methods to build consumer trust. They demand that fresh produce sold in bulk has equal access to green claims. They also propose extending the compliance correction period to three months for operators.123
Why — This approach would protect industry competitiveness by reducing costs and avoiding excessive penalties.45
Impact — Pre-packaged food producers may lose their marketing advantage if loose products display similar claims.6
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Meeting with Clara Aguilera (Member of the European Parliament, Rapporteur for opinion) and CropLife Europe and

4 Jul 2023 · Sustainable Use of Pesticides Regulation

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

27 Jun 2023 · Fit for 55

Response to Revised marketing standards for fresh fruit and vegetables, bananas, nuts, dried fruit and pulses

17 May 2023

In view of the ongoing revision process of the existing rules of marketing standards of fresh fruit and vegetables, which are listed under Commission Implementing Regulation (EU) No 543/2011, the fresh produce sector would like to express its apprehensions about the ongoing public stakeholder consultation. The draft legal act as it stands today will result in: Extensive increase of food waste. Lack of diversification of sourcing of raw materials. Increased price for the European consumers. Decrease in consumption of healthy produce due to increase of price. Lower income for European growers that were used to supply ugly and misshaped fruit and vegetables to facilities that prepare IV gamma products. Misinterpretation and/or lack of coherent interpretation of rules across the EU and consequently in barriers to trade within the EU. Extensive impact on daily operations of food business operators while not providing adequate return to the European consumers. Restriction of growth of IV gamma products industry which highly contributes to consumption levels of fresh produce in many European countries. Discrimination of food industry involved production of IV gamma products (e.g versus frozen or canned industry). Potential inability to comply with requirements, provided it is difficult or impossible to apply them in practice. Blockage of opportunities for the fresh produce sector to serve the European consumers healthy foods in innovative and convenient manner. Please find the position of the fresh produce industry enclosed.
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Freshfel Europe opposes discriminatory packaging ban for fresh produce

21 Apr 2023
Topic — EU consultation on revising rules to reduce packaging waste and improve recyclability.
Message — Freshfel urges policymakers to reconsider the ban on single-use packaging for fresh fruits and vegetables. They advocate for sector-led commitments and innovation instead of mandatory restrictions.12
Why — This would prevent operational disruptions and maintain the shelf-life and safety of perishable produce.34
Impact — Consumers face higher health risks and reduced food quality, while environmental efforts suffer from increased waste.56
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Fresh Produce Industry Warns Pesticide Cuts Threaten Food Security

19 Sept 2022
Topic — EU regulation proposing 50% reduction in chemical pesticides by 2030.
Message — The organization requests that pesticide reduction targets account for climate change impacts, availability of effective alternatives, and food security concerns. They argue the 50% reduction by 2030 is unrealistic without more low-risk substances and proper IPM implementation support across all member states.123
Why — This would allow growers to maintain production levels and avoid increased costs from less effective alternatives.45
Impact — European consumers face higher food prices and reduced supply of diverse fresh produce.67
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Meeting with Mazaly Aguilar (Member of the European Parliament)

17 May 2022 · Freshfel Europe, the European Fresh Produce Association.

Response to Application of EU health and environmental standards to imported agricultural and agri-food products

16 Mar 2022

PLEASE FIND ENCLOSED OUR CONTRIBUTION TO THE CONSULTATION
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Meeting with Janusz Wojciechowski (Commissioner) and

27 Jan 2022 · 2022 Annual Work Programme of the EU Promotion Policy

Meeting with Christiane Kirketerp De Viron (Cabinet of Commissioner Johannes Hahn) and European agri-cooperatives and

14 Dec 2021 · Agricultural Promotion Policy

Response to EU school scheme: amendments to the rules on the educational measures and the selection and approval of aid applicants

19 Nov 2021

Freshfel Europe fully supports the European Commission’s objective of increasing the consumption of fruit and vegetables among schoolchildren by implementing educational activities to reconnect them with agriculture and teach about healthy eating habits. Freshfel Europe welcomes the proposed amendments to Implementing Regulation (EU) 2017/40 as regards the educational measures and the selection approval of aid applicants. Most importantly, Freshfel Europe agrees that Member States should ensure that accompanying educational measures are taken for all participating children, to maximize the outreach of the EU school fruit, vegetables and milk scheme. Freshfel Europe's full response is hereby attached.
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Response to EU school fruit, vegetables and milk scheme: amendments to the rules on aid applications, payment of aid and checks

19 Nov 2021

Freshfel Europe fully supports the European Commission’s objective of increasing the consumption of fruit and vegetables among schoolchildren by implementing educational activities to reconnect them with agriculture and teach about healthy eating habits. In that regard, Freshfel Europe welcomes the proposed amendments to Implementing Regulation (EU) 2017/39 with regard to the aid applications, payment of the aid and on-the-spot checks. Freshfel Europe agrees with the European Commission’s commitment to ensuring the EU school fruit, vegetables and milk scheme is implemented efficiently and correctly among the Member States by supplementing the non-exhaustive list of verifications that are part of the checks on aid for the supply of products and for educational measures. Freshfel Europe's full response is hereby attached.
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Response to Towards the future Generalised Scheme of Preferences legal framework granting trade advantages to developing countries

16 Nov 2021

Freshfel Europe, the European Fresh Fruits & Vegetables Association, would like the welcome the proposal adopted by the Commission for a new EU Generalised Scheme of Preferences, particularly in regards to the inclusion of environmental sustainability considerations and the need to keep safeguards to protect European production. Concretely, in the area of environmental sustainability and to ensure positive steps by GSP beneficiaries in sustainable development, the sector would like to stress the need for the EU to step-up efforts of technical and financial assistance to these partners to attain global climate goals. This is essential for the future of market access of fruits and vegetables of GSP beneficiaries in the EU, given the increasingly strict EU requirements related to the Green Deal and Farm to Fork Objectives (e.g. on food quality & safety, sanitary and phytosanitary issues). GSP countries should therefore be priority beneficiaries of EU programmes such as the Better Training for Safer Food and other related initiatives, to ensure their compliance with environmental conventions and sustained access to the EU market. Please find our detailed remarks in this regard and our assessment of the positive impact of the previous GSP scheme in the position paper enclosed.
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Response to Carbon Border Adjustment Mechanism

3 Nov 2021

Freshfel Europe, the European Fresh Produce Association, would like the welcome Commission’s proposal for a Carbon Border Adjustment Mechanism (CBAM) and the exclusion under its scope of the fresh fruit and vegetables sector. Fresh fruit and vegetables have one of the highest consumption recommendations by the World Health Organisation (at least 400g per capita per day) and have the lowest environmental impact in their production compared to other agri-food sectors. As a reminder of our previous position paper, please find below some key considerations why this instrument would not be appropriate for the sector. Further details of each consideration are provided in the position paper enclosed. 1. Absence of carbon leakage risk 2. Need for coherence with Farm to Fork Strategy 3. Diversity of agricultural practices and climates and complexity of assessments still in progress 4. Negative impact on producers and developing countries 5. Risk of retaliation On the other hand, Freshfel has evaluated with its members the impact of the inclusion of fertilisers under the scope of the CBAM proposal. Whilst F&V remain marginal consumers of fertilisers overall, these are still important inputs for production in Europe, although the sector lacks sufficient data to evaluate fully the share of imported fertilisers used in EU production. In addition, the sector considers, that the introduction of the CBAM could be a good opportunity for the sector to move towards a reduction of EU F&V growers’ dependence of fertilisers, since currently there is often an abusive use with negative environmental consequences , as well as damages for the quality of the fruit, limiting shelf-life. In light of these considerations, we would like to request the EU to consider in parallel the following suggestions: • First, to closely analyse and monitor the impact of the CBAM’s implementation in the prices of inputs for EU F&V production, in order to trigger potential safeguard actions should an increase in fertilisers’ costs damage growers’ incomes, which are particularly sensitive in the current context, where the sector is working on tight margins. • Second, to support the sector in its objective to reduce overall the use of fertilisers, among other prioritising education and dissemination of good agricultural practices among growers to reduce potential unnecessary uses of fertilisers. Freshfel Europe looks forward to continuing to collaborate with EU institutions on this dossier, and remains available to provide additional information and insight from the sector.
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Response to Food waste reduction targets

29 Oct 2021

Freshfel Europe, the European Fresh Produce Association, welcomes the European Commission’s proposal for a ‘revision of Directive 2008/98/EC on waste – part on food waste reduction target’. This initiative under the Farm to Fork Strategy will further stimulate Europe’s food waste reduction efforts throughout the agri- food supply chain for a more sustainable food system in line with the European Green Deal’s ambitions. Freshfel Europe additionally strongly supports continued work throughout the Union towards meeting Sustainable Development Goal (SDG) 12.3 to halve per capita food waste at retail and consumer level by 2030 and reduce food losses along the food supply chain, which will be facilitated by this initiative. Please find attached Freshfel Europe’s detailed remarks regarding the Inception Impact Assessment.
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Response to Sustainable food system – setting up an EU framework

26 Oct 2021

Freshfel Europe, the European Fresh Produce Association, welcomes the European Commission’s proposal for a Regulation on ‘Sustainable food system framework initiative’. This initiative will facilitate a higher level of policy coherence within and between EU-level agri-food policy, which aim, either directly or indirectly, to enhance sustainable across the Union. Freshfel Europe welcomes the development of both Farm to Fork Strategy proposals under the current initiative, namely the ‘proposal for a legislative framework for sustainable food systems’ and ‘proposal for a sustainable food labelling framework to empower consumers to make sustainable food choices’. Please find in the attachment Freshfel Europe’s detailed remarks regarding the Inception Impact Assessment.
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Response to Fruit and vegetable production - more flexibility in the calculation of the value of damage caused by natural disaster

27 Sept 2021

Freshfel Europe, the European Fresh Produce Association, represents the interest of the whole supply chain of fresh fruit and vegetables in Europe. Freshfel Europe is registered in the EU transparency register of interest representatives under reference n° 1637225479-02. Freshfel Europe welcomes the public consultation on the draft delegate regulation on the calculation of the value of the marketed production of fruit and vegetables producer’s organisations in case of natural disaster. Freshfel Europe supports this initiative which aims to give to producer organisations more flexibility and clarity when calculating the market value of produce damaged and made unusable for consumption and processing due to natural disasters, extreme weather events and diseases or pest infestations. However, a number of points need to be clarified to secure a good implementation of the new provision on the scope of the measures and proves needed for controls. Freshfel Europe detailled position is provided in the attached document.
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Response to Amendment of protective measures against pests of plants

23 Aug 2021

Freshfel Europe, the European Fresh Fruits and Vegetables Association, closely monitors the EU’s Plant Health regime, of crucial importance for a sector which is dependent on movements of plants and the maintenance of biosecurity. As such, Freshfel has closely reviewed the changes proposed under the present Implementing Regulation and would like to ask for the elements included in the document enclosed below to be taken into consideration. This includes the need for a clear timeline of implementation and sufficient transition time for the sector to adjust to the new requirements, as well as the need for sufficient communication about the measures’ implication to trade partners and the sector. On behalf of the fresh fruit and vegetables sector, we would also like to welcome the Commission’s communication efforts and hope these can be continued and reinforced in the run-up to the adoption of this Implementing Regulation, in order to ensure that the measure does not negatively impact trade, particularly with developing countries. Freshfel Europe remains committed to continue disseminating relevant information among its members and network of contacts to support preparedness of the sector and compliance with the new measures.
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Response to The certificate of inspection and the official controls at the entry into the Union of organic products

12 Jul 2021

Please find attached Freshfel Europe's response on the EC consultation on organic products from non-EU countries. We remain available for further discussion. Best regards, Nelli Hajdu
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Response to Agriculture - List of products and substances authorised in organic production

23 Apr 2021

Please find Freshfel Europe's Feedback attached. We remain available for further exchange. Best regards, Nelli Hajdu Director Trade Policy Freshfel Europe - The European Fruit and Vegetable Association
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Response to Information and promotion measures for agricultural and food products in the internal market and in non-EU countries

9 Mar 2021

Freshfel Europe is the European fresh fruit and vegetables Association with a membership across the supply chain. Freshfel Europe welcomes the opportunity to comment on the Inception Impact Assessment relating to EU promotion policy for agricultural products on the EU internal market and third country markets.The detailled position paper is to be found enclosed and covers the different aspects raised in the Inception Impact Assessment.
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Response to Revision of EU marketing standards for agricultural products

16 Feb 2021

Freshfel Europe welcomes the opportunity to comment on the five options presented in the Inception Impact Assessment for a revision of EU marketing standards for agricultural products. In view of the current use and potential future use of marketing standards in the fresh produce sector, Freshfel Europe believes Option 3 “Revise the current marketing standards to modernise them (e.g. to take into account technological change and new production methods), increase their contribution to the sustainability of the food system, align the rules with the requirements of the Lisbon Treaty, and simplify existing legislation by consolidating rules on marketing standards in fewer regulations” is the most appropriate Option for this revision. Please find our comments enclosed in the attachments.
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Response to Setting of nutrient profiles

3 Feb 2021

Freshfel Europe strongly supports the European Commission’s ambitions in the European Green and the Farm to Fork Strategy to foster a more sustainable food system in Europe. Accordingly, Freshfel Europe believes that the EU food system’s impact on the environment must be evaluated and minimized. At the same time a shift towards healthy and sustainable diets must be pursued in all areas. This is vital for long-term food system change. Freshfel Europe therefore welcomes the European Commission’s proposal for a revision of Regulation (EU) 1169/2011 on the provision of information to consumers. The revision of Regulation (EU) 1169/2011 will be fundamental in driving change in the food environment to better European consumers’ diets. Freshfel Europe welcomes the opportunity to comment on the four main actions outlined in Inception Impact Assessment for the revision of Regulation (EU) 1169/2011, namely a proposal for a harmonised mandatory front-of-pack nutrition labelling, the setting of nutrient profiles, the extension of mandatory origin or provenance indications to certain products, and EU rules on date marking (‘use by’ and ‘best before’). Please see the attached document for Freshfel Europe's full response.
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Response to Amendment of the IMSOC Regulation as regards the functioning of ADIS, EUROPHYT and TRACES

19 Jan 2021

Dear Madam/Sir, please find our response in the file attached. We remain available for further exchange. Best regards, Nelli Hajdu Director Trade Policy and Business Development
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Response to Contingency plan for ensuring food supply and food security

13 Jan 2021

A sustainable European food system must be able to providing citizens with a sufficient and varied supply of safe, healthy and nutritious and affordable food products in times of crises. Freshfel Europe and the European Sprouted Seeds Association (ESSA) wholly supports the European Commission’s ambition outlined in the European Green Deal and the Farm to Fork Strategy to conceive a contingency plan to be activated in times of crises that affect a part or the entire European food system endangering European food security. As part of the development of the contingency plan, Freshfel Europe and ESSA strongly supports the creation of a coordinated crisis preparedness and response mechanism, among other initiatives to prevent, manage and evaluate crises affecting the food supply chain. For a full response, please see attached.
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Response to Environmental claims based on environmental footprint methods

28 Aug 2020

Consumers are key to a successful and effective green transition. The fresh fruit and vegetable sector endeavours to supply consumers with safe, high quality and fresh products that also meet their environmental, social and sustainability product expectations. The fresh fruit and vegetable sector is fundamental for a greener European economy, whose impact filters to global markets. Fresh fruit and vegetables have one of the highest consumption recommendations by the World Health Organisation (at least 400g per capita per day) and have low environmental impact production. Consequently fruit and vegetables play a fundamental role in a greener economy. Freshfel Europe therefore supports the European Green Deal’s identification that companies making green claims assess their impacts on the environment using a standard methodology. This will foster sustainable goods and consumption patterns. In doing so Freshfel Europe also supports the new Circular Economy Action Plan and the Farm to Fork Strategy’s actions to empower consumers to make informed healthy and sustainable food choices, including examining ways to harmonise voluntary green claims for food. Over time these endeavours will minimize the environmental footprint of products consumed by European citizens and work towards the overall policy objective of the EU of climate neutrality by 2050. In the food sector consumers drive demand. Along with availability and accessibility, this includes product characteristics such as colour, taste, convenience, shelf life and packaging and importantly sustainability. To facilitate consumer purchase, Freshfel Europe supports the provision of accurate, reliable, comprehensible and consumer-friendly information regarding product sustainability including green claims. To signal to consumers, but also to improve food product environmental, economic and social performance, sustainability logos, labels, trust and quality marks and claims have been historically used by the fresh produce sector. This is now developing to available online information to consumers through label codes, for example QR codes, which can provide more extensive and detailed information regarding green claims. While extremely useful in product distinction for consumers, the sector has taken note of the proliferation of these demarcations. Freshfel Europe recognizes that the discontinuation of the proliferation of green claims and a simultaneous facilitation of comparability between claims will aid consumer choice. Although unable to participate in the European Commission’s pilot phases, Freshfel Europe has supported the delineation of environmental footprint methods through Product Environment Footprint Category Rules (PEFCRs) or Organisation Environmental Footprint Sector Rules (OEFSRs). With the increase of interest in and use of green claims in the fresh produce sector, a more harmonised approach to substantiating claims to provide environmental information is necessary. Please see the attached file for Freshfel Europe's full response.
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Freshfel Europe urges effective alternatives before pesticide cuts

6 Aug 2020
Topic — The European Commission is revising rules to reduce chemical pesticide use and risks.
Message — Freshfel demands that removed chemical substances are replaced with effective, affordable solutions. They request harmonised EU guidance on integrated pest management to ensure fair competition. They also call for legal revisions to allow new breeding techniques like CRISPR-Cas.123
Why — This prevents economic loss and maintains the competitiveness of the fresh produce sector.45
Impact — Environmental groups would see delayed progress toward reducing the use of chemical pesticides.67
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

5 Aug 2020

Packaging is an essential element of the European fresh fruit and vegetable supply chain. The fresh produce sector uses packaging throughout the supply chain from production, wholesale, logistics, trade and at retail level to provide safe, high quality and fresh products to consumers. Freshfel Europe supports the European Green Deal’s ambitions to increase the sustainability of packaging use through enhanced reusability and recyclability of packaging as well as the commitment to tackle over-packaging and waste generation, which is also reflected in the new Circular Economy Action Plan (CEAP 2.0). While much effort has been made by the EU fresh fruit and vegetable sector to address packaging use through innovations in packaging materials and design as well as reductions in over-packaging, there remains scope for change to further boost the sustainability of the sector. Freshfel Europe therefore supports the European Commission’s initiative to review Directive 94/62/EC on Packaging and Packaging Waste and the requirements of packaging and other measures to prevent packaging waste. Please see the attached document for Freshfel Europe's full response.
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Response to Trade policy review, including WTO reform initiative

10 Jul 2020

Freshfel Europe supports the EU plans to revise its Trade Policy. Taking into consideration the ongoing challenges the F&V sector is facing, the new EU Trade Strategy shall seek to be more assertive, looking into fully exploiting the potential of existent multilateral and bilateral agreements with trade partners and, if needed, making use of ‘hard’ tools on top of ‘soft’ engagement to ensure reciprocity in trade relations. Moreover, work shall be continued with trade partners to seek further SPS facilitation to ensure faster, less burdensome fruit and vegetables access to third country markets, either via multilateral WTO and IPPC commitments, SPS Chapters in FTAs or with other bilateral agreements, formal or informal. An enhanced internal coordination among EU services, Member States and the EU private sector shall also help securing faster opening of third country markets for all Member States and fruit and vegetables categories. The EU Trade Policy shall also ensure the support of trade partners to achieve environmental goals through so-called Green Alliances. In order to secure this, technical support should be targeted to developing partners, particularly in Africa and America, as these are key suppliers to the EU Market. Last but not least, the EU shall translate its ambitions to become ‘fit for the digital age’ into concrete solutions that facilitate trade operations, allowing, for instance, electronic transmission of import and export certification, enhanced information sharing, and modernisation of compliance monitoring tools.
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Response to FuelEU Maritime

24 Apr 2020

Freshfel Europe is the European Fruit and Vegetable Association and represents the entire supply chain from production to trade to retail. Freshfel has compiled a comprehensive response of the sector on the roadmap for "CO2 Emissions for shipping - encouraging the use of low-carbon fuels, attached here. We remain available for further discussion. Best regards, Nelli Hajdu Director Trade Policy and Business Development
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

Life on our planet is supported by the world’s biodiversity. Interlinking ecosystems around the world, biodiversity is crucial to regulating the climate and providing an abundance in species and gene variety. Biodiversity also provides our natural capital such as clean air, water, flora, fauna and materials, which deliver ecosystem services that underpin our economies. Biodiversity loss due to human-induced climate change is one of the most critical global environmental threats being faced by our planet. Irreversible biodiversity loss will result in ecosystem collapse and it will threaten society’s ability to develop and confront new environmental challenges. Biodiversity preservation and restoration is key to a sustainable future for Europe. Freshfel Europe supports the European Commission’s objective of a new EU Biodiversity Strategy to 2030 as outlined in the European Commission’s European Green Deal. Commitments and measures in this new strategy will continue the EU’s efforts over the last ten years to halt the loss of and restore biodiversity and ecosystem services as well as to contribute to averting global biodiversity loss. Please see the attached file for Freshfel Europe's feedback in full.
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Response to A new Circular Economy Action Plan

20 Jan 2020

Circularity of the European economy is key to achieving long term sustainability while at the same time ensuring competitiveness. The 2015 EU Action Plan for the Circular Economy has been instrumental in protecting the environment and generating sustainable growth across the EU, while at the same time boosting and modernising Europe’s industry and economy. Guiding the EU towards a long-term vision for a circular economy, the Action Plan has also contributed to achieving the Sustainable Development Goals. Freshfel Europe supports the European Commission’s continued commitment to more circular objectives. As such Freshfel Europe welcomes the European Commission’s commitment to the adoption of a new Circular Economy Action Plan as presented in the European Commission’s Communication on the European Green Deal. This new Action Plan will not only enable the continuation of European-wide efforts since 2015 to increase circularity, but will provide a new opportunity to develop more circular activities in new areas to further foster environmental protection and sustainable growth across the EU. Please see the attached file for Freshfel Europe's feedback in full.
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Response to Tariff quotas with licences

19 Aug 2019

Freshfel Europe, the European Fresh Produce Association, represents the fresh fruit and vegetables supply chain in Europe. Our membership comprises associations and companies that have an interest in the European fresh fruit and vegetable sector at different levels of the European supply chain, from production trade and logistics down to retail. Freshfel is a non-profit association established under the Belgian legislation of 1919. Freshfel Europe is registered in the EU transparency register under n° 1637225479-02. Throughout the past two years, Freshfel Europe has closely followed the ongoing reform of European legislation on TRQ management. Please find our feedback to the consultation below.
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Response to Tariff quotas with licences

19 Aug 2019

Freshfel Europe, the European Fresh Produce Association, represents the fresh fruit and vegetables supply chain in Europe. Our membership comprises associations and companies that have an interest in the European fresh fruit and vegetable sector at different levels of the European supply chain, from production trade and logistics down to retail. Freshfel is a non-profit association established under the Belgian legislation of 1919. Freshfel Europe is registered in the EU transparency register under n° 1637225479-02. Throughout the past two years, Freshfel Europe has closely followed the ongoing reform of European legislation on TRQ management. Please find our feedback to the consultation below.
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Response to Amendment of products and substances allowed in organic production

15 Aug 2019

Freshfel, the European Fresh Produce Association welcomes the opportunity to comment on the draft Commission Implementing Regulation (EU) …/… amending Regulation (EC) No 889/2008 laying down detailed rules for the implementation of Council Regulation (EC) No 834/2007 on organic production and labelling of organic products with regard to organic production, labelling and control. Freshfel’s comments can be found enclosed in the attachments.
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Response to Temporary measures on entry into the Union of certain goods

15 Jul 2019

Freshfel Europe is the European umbrella organization for the European fruit and vegetable sector and represents 150 companies and national associations along the whole supply chain. Fruit and vegetable imports, with a market volume of 16 mio. T and € 16.8 billion, are an important corner stone for the economic development of the EU and its member states. The growth trend has continued for more than 20 years as has demand for fresh and good quality product in time. A good functioning of the European legislation on temporary measures on entry into the Union is very important and the merge of different pieces of legislation makes the legislation on this matter more complete and better readable. The fresh produce sector would like to raise a number of issues with regards to the Draft Commission Implementing Regulation (EU) on the temporary increase of official controls and emergency measures, which concern the listing and de-listing criteria for products, the need for a guidance document to increase the transparency of the processes, and the overall transparency of the regular reviews of annexes I and II of the draft regulation. Please find below our position paper outlining these issues in detail. Freshfel Europe remains at the disposal of the Commission services to discuss these and other issues.
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Response to The Information Management System for Official Controls regulation (IMSOC)

17 Jun 2019

Please find Freshfel Europe's response to the public consultation on the Information management system for official controls regulation (IMSOC) attached in the PDF file below.
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Response to Enhancing Market transparency in the agri-food chain

17 Jun 2019

Freshfel Europe is the vertical organisation representing the various segments of the fresh fruit and vegetable sector – from production down to retail, with a membership across the EU. Freshfel welcomes the Commission’s overall objective to strengthen the supply chain and to ameliorate the position of the weaker links. However, there are some concerns regarding the means to achieve this as proposed in the draft Implementing Regulation (see file attached).
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Response to Rules related to the Common Health Entry Document (CHED)

11 Mar 2019

Freshfel Europe is the European fruit and vegetable association, representing round about 150 members (companies and associations) along the supply chain. With more than 15 mio. T. of imports, 5 mio. T of exports and 32 mio. T. of intra-EU trade, the fruit and vegetable sector contributes significantly to jobs and growth within the EU. Swift and simple custom and certification procedures are of great concern for the sector, as time matteres essentially for the trade with perishable goods. Please find attached the full response to the European Commission's public consultation on the Draft Delegated Act regarding the rules to the Common Health Entry Document. Freshfel remains available for further exchange.
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Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development)

29 Nov 2018 · exchange of views on fruit market

Response to Amendment of the import and internal movement requirements of harmful organisms of plants

26 Nov 2018

Freshfel Europe, the European Fresh Produce Association, represents the fresh fruit and vegetables supply chain in Europe. Our membership comprises associations and companies that have an interest in the European fresh fruit and vegetable sector at different levels of the European supply chain, from production trade and logistics down to retail. Freshfel is a non-profit association established under the Belgian legislation of 1919. Freshfel Europe is registered in the EU transparency register under n° 1637225479-02. Freshfel Europe welcomes the overall objectives of the Plant Health Reform and the Commission’s efforts to take the necessary technical measures to protect European production from the threat of pests and diseases while respecting the freedom to trade without unnecessary burdens. In order to achieve this goal, we believe the following remarks on the Draft Commission Implementing Directive amending Annexes I to V to Council Directive 2000/29/EC should be taken into account (see file enclosed).
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Response to Initiative to improve the Food Supply Chain

13 Jun 2018

Freshfel Europe, the European Fresh Produce Association, represents the fresh fruit and vegetable supply chain in the European Union and is registered in the transparency register under the reference: 1637225479-02. We incorporate more than 150 direct members and associated members, including companies and national associations of producers, shippers, exporters, importers, distributors, retailers, and their service providers. Through the membership of national associations, we have a wide, representative outreach of the EU fruit and vegetable production and trade. The fruit and vegetable supply chain is defined by specific characteristics: there is (sometimes high) perishability and seasonality, a very short commercial cycle; a myriad of distribution channels, huge diversity across categories and within single product lines; a fragmented production base, and a consolidated retail sector and regular fluctuations across supply and demand, which can lead to price volatility. Given this fluctuation and market requirements, daily adjustments and flexibility in commercial practices are often required, alongside the overall programming of seasons which typically guides the well-established and long-term relationships between different operators across the chain. From this integrated supply chain perspective, we would like to offer a few comments and ask for some clarifications regarding the proposed Directive (See Annex).
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Response to EU Single Window environment for customs

31 May 2018

Freshfel Europe has been involved in various meetings since 2014, when the Single Window project was launched. As a follow-up to this engagement, Freshfel would like to warmly welcome the spirit and objectives outlined in the Commission Inception Impact Assessment for an EU Single Window environment for customs, and to maintain its engagement with the Commission as the initiative unfolds. The roadmap succeeds in pointing at the main challenges the industry is currently facing in the area of customs, which are intensified by the inherent complexity of the Customs Union arrangements. Against this backdrop, the urgent development of a smart Single Windows is key for the EU to maintain its economic position, keeping its attractiveness as a destination of imports and facilitating EU exports.
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Response to Alignment of fruit and vegetables marketing standards to the international UNECE standards

29 Mar 2018

Freshfel Europe, the European Fresh Produce Association, welcomes the alignment of fruit and vegetables marketing standards to the international UNECE standards and the opportunity to comment on the draft Commission Delegated Regulation (EU) …/... amending Implementing Regulation (EU) No 543/2011 as regards marketing standards in the fruit and vegetables sector. Freshfel would like to address a point regarding the provisions concerning marking of fresh fruit and vegetables. Products are often packed at the point of the harvest in pre-packages or even during harvest (e.g. mushrooms and strawberries). The transport package holding the individual prepackages should be fully labelled according to the requirement of Regulation 543/2011. Due to the last minute demands and specific requirement of retailers/buyers on labeling (e.g. language, barcoding, pricing) and due to extra quality controls and checks to avoid food waste (possible removal of a product that no longer corresponds to the marketing requirements), the process of the final labeling of prepackages is mostly done at a later stage of the supply chain, right before the distribution of the product to the final point of sale. In the proposed text by the European Commission the industry misses the provision set in the UNECE standards which would clarify the common practice applicable in the supply chain: “These marketing provisions do not apply to sales packages presented in packages”. According to the Regulation 543/2011 (art. 6) and the requirements listed in Regulation 1169/2011, prepackages have to be fully labelled at the point of sale. The fresh produce sector would like to request the European Commission to align this UNECE labeling norm with the Implementing Regulation (EU) No 543/2011 as regards marketing standards in the fruit and vegetables sector by inserting the footnotes to the European general and specific marketing standards. In regard to marketing standards at the EU level, Freshfel reiterates the need to continue evaluating implications for marketing standards with an evolving supply chain (including distribution through food services customers) and with the growing demand for convenient and ready-to-eat products.
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Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development) and European Public Health Alliance and European Heart Network

27 Mar 2018 · exchange of view on the Communication on Food and Farming

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

20 Apr 2017 · Presentation of their latest brochure

Meeting with Arunas Vinciunas (Cabinet of Commissioner Vytenis Andriukaitis), Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and

14 Dec 2016 · Dimethoate

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

14 Jun 2016 · Priorities of the CE on the fruit and vegetables dossier

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

14 Jun 2016 · Fruit & vegetable

Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development)

8 Jun 2016 · exchange on the outlook for appels and pears sectors

Meeting with Vytenis Andriukaitis (Commissioner) and

4 Apr 2016 · Endocrine disruptors

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

26 Mar 2015 · SPS barriers in Third Countries for fruit and vegetables