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FRUCOM - European Federation of the Trade in Dried Fruit, Edible Nuts, Processed Fruit & Vegetables, Processed Fishery Products, Spices and Honey

FRUCOM

FRUCOM pursues the following objectives: - To bring together importers, agents, brokers and other traders in Dried Fruit, Edible Nuts, Processed Fruit & Vegetables, Processed Fishery Products, Spices, Honey and Similar Foodstuffs within a common organisation in order to facilitate and promote the activities of and cooperation among operators at European level; - To represent, defend and promote at EU level the general interests of the sector and the common interests of FRUCOM members (national associations of traders in Dried Fruit, Edible Nuts, Processed Fruit & Vegetables, Processed Fishery Products, Spices or Honey). To attain these objectives, FRUCOM undertakes the following activities: - Monitor and circulation of information to FRUCOM members on the EU legislation and policy developments in the fields of: international trade, agriculture, food safety, fisheries and customs. - Permanent link with the institutions of the European Union, the key decision-mak (...)

Lobbying Activity

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

1 Jul 2025 · US tariffs and EU countermeasures

Meeting with Péter Bokor (Head of Unit Health and Food Safety)

10 Jun 2025 · (Re-)introduction FRUCOM

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

2 Apr 2025 · Exchange of views on the current and prospective trade situation between the EU and the US

Meeting with Ariane Vander Stappen (Head of Unit Health and Food Safety)

7 Feb 2025 · Exchange of views on promoting healthy diets and sustainable nutrition

Response to Autonomous Tariff Quotas Regulation

4 Nov 2024

FRUCOM represents European Union importers of processed food products, including processed seafood. FRUCOM welcomes the opportunity to provide feedback on the Sustainable imports of fishery products under the EU Autonomous Tariff Quota Regulation, and considers it timely that that the European Commission is undertaking a review of the ATQ regime for after 2026, including in relation to the sustainability of imported fishery products. The feedback by FRUCOM emphasises that the European Commission should: - Guarantee a Level Playing Field on sustainability for all fisheries products placed on the EU market - Avoid Duplication of Sustainability Obligations. The full feedback can be found in the associated file. FRUCOM remains at the disposal of the European Commission on any matters related to this important initiative and looks forward to participating in further consultations on the matter
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Response to Environmental claims based on environmental footprint methods

20 Jul 2023

Please find attached FRUCOM's full position on the Green Claims Directive proposal. FRUCOM represents European Union importers, and growers, processors, and traders, of edible nuts, dried and processed fruit and vegetables, and processed fish and seafood products. - FRUCOM welcomes the publication of the Proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive), on 22 March 2023. - FRUCOM supports the goals of the Directive, to ensure that environmental claims communicated to European consumers are substantiated and that the process for substantiating these claims is science based, that it eliminates or at least reduces greenwashing and misinformation, and that it ensures a level playing field within the EU and between EU and non-EU products. - FRUCOM strongly encourages the European Commission to focus on, and support, the substantiation of existing voluntary private environmental labelling schemes. Many operators have made significant investments to achieve certification under these private environmental labelling schemes, which often have a wider geographic scope than just the EU. This is relevant as the EU is one of the most important destinations for environmentally certified goods produced in third countries. - FRUCOM believes that the Green Claims Directive should encourage continuous improvement under existing private sustainability initiatives whilst also establishing a clear, harmonised, certain, and flexible framework for the minimum requirements for the substantiation of environmental claims.
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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

Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

24 Apr 2023

FRUCOM represents European Union importers, and growers, processors, and traders, of edible nuts, dried and processed fruit and vegetables, and processed fish and seafood products. FRUCOM welcomes the publication of the Proposed Regulation on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC, on 30 November 2022. - FRUCOM supports the goals of the Regulation, to reduce packaging and packaging waste, and encourage recycling, reuse / refill, composting, and packaging minimisation. - FRUCOM strongly encourages the European Commission to focus on, and promote, proven voluntary approaches and incentives for compliance with targets for minimising packaging and packaging waste, which will encourage the private sector to take up packaging solutions or alternatives to meet EU goals. - FRUCOM believes that the Proposed Regulation on packaging and packaging waste presents a number of important drawbacks that the Commission can easily address: > Firstly, in relation to the blanket ban under point 1 of Annex V of plastic packaging used at retail level to group goods sold in cans, tins, pots, tubs, and packets; a level of flexibility should be maintained as grouping using cardboard or paper solutions is not always possible where the product quality, safety and utility would be compromised. In this regard, including the option to use recycled plastics for grouping would be more sustainable and practical. > Secondly, in relation to the blanket ban under point 4 of Annex V for single-use, portion packaging of any sort for preserves, sauces, etc. in a HORECA environment; this presents hygiene, food waste, and logistical costs for many products. As such, a mix of alternative packaging solutions could be permitted to provide flexibility to the HORECA sector and food manufacturers whilst meeting the goals of the Regulation. > Thirdly, the proposed Regulation fails to provide a clear transition period for the application of the new obligations for importers, distributors, manufacturers, and other operators, meaning that there will be a significant cost burden, especially for SMEs, to comply with any new rules. This can be remedied through the Commission staggering and defining the deadlines for compliance based on operator size, incentivising and investing in the use of sustainable packaging, and harmonisation and standardisation of Member States rules on reuse/ refill recycling, and composting. FRUCOM avails itself of this opportunity to thank the European Commission for its consideration of the arguments made in this paper and assure the Commission of our availability and interest in supporting the European Commission to address packaging and packaging waste where dried fruit and nuts, and processed fruit, vegetables and fisheries products are concerned. FRUCOM's full feedback can be found in the attached file.
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Response to Effectively banning products produced, extracted or harvested with forced labour

20 Jun 2022

FRUCOM represents European Union importers, and growers, processors, and traders, of edible nuts, dried and processed fruit and vegetables, and processed fish and seafood. Many of these products are either not produced in the EU or the production volume is not sufficient to meet the market demand, hence the need for imports. Sourcing is global, from both developed and developing countries. FRUCOM welcomes the efforts of the European Commission to put in place a framework to address forced labour in the production, extraction, or harvesting of goods that will be placed on the European Union’s single market. Because FRUCOM supports and recognises the importance of ending forced labour worldwide, FRUCOM wishes to highlight some critical considerations for the industries it represents. These concern: (1) The scope and approach of the instrument (2) The impact on SMEs (3) Ensuring respect of the Level Playing Field (4) Support functional tools and existing approaches that counter forced labour (5) Legal certainty and Remedies FRUCOM remains available to provide further information on best practices to prevent forced labour in supply chains and is interested in being included in future discussions on this topic. Further information can be found in the file attached.
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Response to Sustainable corporate governance

23 May 2022

FRUCOM appreciates this opportunity to provide feedback on the Proposal for a Directive of the European Parliament and of the Council on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937, published on 23 February 2022. Whereas FRUCOM supports the principle of introducing an EU due diligence legal framework and believes it important for companies to consider their impact on issues like human rights and the environment in their long-term decision making, FRUCOM considers that the proposed Directive on Corporate Sustainability Due Diligence presents some important drawbacks. FRUCOM strongly recommends that the European Commission, Parliament, and Council, consider remedial actions to ensure that the proposed Directive does not encourage the withdrawal of micro, small and medium sized companies from operating in global supply chains that are unavoidably and invariably complex, and does not place European companies at a disadvantage relative to international companies. Please find attached FRUCOM's feedback.
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Response to Application of EU health and environmental standards to imported agricultural and agri-food products

16 Mar 2022

FRUCOM represents European importers and growers, processors, and traders in origin countries of edible nuts, dried and processed fruit and vegetables and processed fish and seafood. FRUCOM recognises that the European Union is already undertaking an unprecedented and highly consequential drive towards European and global sustainability through the various objectives and policies agreed under the Green Deal and Farm to Fork Strategy. Many of these policies already foresee operators placing imported products on the EU market having to ensure that standards are met which concern the environment. It is already the case that significant political, financial, and other resources are being used to work with third country partners in relation to existing and ongoing policies and agreements that have implications for the placing of imported agri-food products from third countries on the EU market. FRUCOM therefore strongly encourages the European Commission to focus in this report on how greater support and efforts can be invested in ensuring existing systems are robust, continue to be effective and efficient, and are scaled up where relevant. Please find the full feedback in the document attached.
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Response to Revision of EU marketing standards for agricultural products

16 Feb 2021

FRUCOM, representing the EU importers of dried fruit and nuts, thanks the Commission for the consultation on the EU marketing standards for agricultural products– inception impact assessment. As stated by the Commission, this initiative aims to update these standards to encourage the supply of more sustainable products to consumers and simplify current legislation. The objective of the initiative is also to explore the need for introducing new marketing standards, to take into account sustainability considerations, including environmental impact. According to FRUCOM analysis, the dried fruit and nuts are largely excluded from the current EU marketing standards, except dried grapes of the sultana and Muscatel varieties and currants and nuts in shell. FRUCOM is in favor of option 2: do not revise the substance of the current marketing standards but align the existing legislation with the procedural requirements of the Lisbon Treaty. Our arguments: 1. The dried fruit and nuts are largely excluded from the current EU marketing standards, except dried grapes of the sultana and Muscatel varieties and currants and nuts in shell, 2. During the study of the current standards for fresh and processed fruit and vegetables to which dried fruit and nuts belong, limited potential for simplification and no significant issues were identified; 3. FRUCOM already gave a response to the consultation on product environmental footprint – the expected EU calculation method - in favour of a voluntary approach. Comments in more detail: Dried grapes There are special EU marketing standards for dried grapes (Commission Regulation 1666/1999). This standard is now devoid of any technical basis. The norm is so minimal that even dried grapes only suitable as animal feed would be considered compliant. The product-specific UNECE standards would be our preferred option and the standard 1666/99 should be dropped. Nuts in shell The general marketing standards for fresh fruit and vegetables also apply to nuts in shell. But the EU law also says that if all parameters of the product-specific UNECE standard are met, this is recognized as compliant with the EU marketing standards. This is regulated in Article 3 of regulation 543/2011 and should be kept like this or nuts in shell should be dropped from the list of fresh fruit. Commission Implementing Regulation (EU) No 543/2011, Article 3, Marketing standards; holders 1. “where the holder is able to show that the products are in conformity with any applicable standards adopted by the United Nations Economic Commission for Europe (UNECE), they shall be considered as conforming to the general marketing standard”. Origin: the indication of origin for these products should be voluntary, as the value added must be proportionate to the effort for the business operators and the control authorities. Any supplier is free to provide voluntary information. Sustainability standards The EU method for assessing environmental sustainability would be product environmental footprint methodology developed by DG ENVI. In response to the public consultations on this methodology, FRUCOM stated it favors a voluntary approach. We made detailed comments on the complexity of the methodology. Its use on product labelling is not always appropriate given changing supply chains. Integration or recognition of existing standards is desirable. More pilot studies must be developed, in addition to beer, wine and pasta, the only three food and drink products so far. The difficulty of implementation of EU methodology in non-EU countries must be considered. We also commented on likely economic impacts, costs and competitiveness, including for SMEs; timeline for implementation and technical assistance. To see FRUCOM comments: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12511-Environmental-claims-based-on-environmental-footprint-methods/F547338
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Response to Setting of nutrient profiles

2 Feb 2021

FRUCOM welcomes this public consultation and the opportunity to provide comments on the inception impact assessment on “Food labelling – revision of rules on the information provided to the consumer”. FRUCOM represents the interests of European traders in dried fruits, edible nuts, honey, processed fruits & vegetables, and processed fishery products. We embrace Commission’s proposal to revise the rules on the information provided to the consumers. We agree that the variety of front-of-pack (FOP) schemes present on the EU market results in inequity in consumers’ access to information and could result in fragmentation of the internal market, costs for businesses having cross-border activities as well as consumer confusion and lack of trust. We support that any initiative that will be implemented should be at the EU level and therefore is harmonized throughout all EU markets. FRUCOM is in favour of the use of a harmonized FOP and our preferred option is the use of a “summary labels with graded indicators” scheme (option 4). Nutri-Score is currently the most widely used FOP scheme in the EU. However, its algorithm should be adopted to the type of the food as it is important that the final score of the food is not misleading. For example, as stated in the Market Advisory Council (MAC) Advice “Nutri-Score Labelling on Fish Products”, Nutri-Score provides a negative rating for fish products that have high fat content and are high in natural omega-3 of marine origin (EPA – DHA), despite their recognised high health benefits. There should not be contradictions with the European or even national dietary recommendations. Regardless of which FOP scheme is implemented, emphasis should be given on the consumer education on the scheme used in order for it to be most impactful. We see the need for an action regarding date marking. We support any changes to help consumers understand which foods do not have food safety concerns even after the date indicating a potential degradation in quality.
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Response to Action plan for the development of EU organic production

23 Oct 2020

FRUCOM welcomes the opportunity to provide our comments on the roadmap for the “Action Plan for the development of EU organic production”. FRUCOM represents the interests of European traders in dried fruits, edible nuts, honey, processed fruits & vegetables, and processed fishery products. Through its membership, mainly based on 9 national trade organisations in 7 EU Member States, FRUCOM represents over 300 companies across the EU and beyond. We embrace Commission’s commitment to reach at least 25% of EU agricultural land farmed under organic farming by 2030 and a significant increase in the organic aquaculture which will contribute to improving the sustainability of the food system and to reverting biodiversity loss. As stated in the roadmap, the action plan aims to help Member States stimulate supply and demand of organic products. An important parameter in stimulating the growth of organic market is the financial support. Certification costs can be very high in some cases and we believe they should be covered by the Member State to support organic operators. Such cases already exist, for example Denmark. FRUCOM is part of the Civil Dialogue Group of Organic and we are committed to cooperate with the Commission on different aspects of the organic policy.
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Response to Farm to Fork Strategy

16 Mar 2020

FRUCOM represents importers of dried fruit, nuts, processed fruit, vegetables and seafood. These foodstuffs and ingredients are important in order to guarantee both healthy and sustainable diets. ·It is well established from high quality human studies that eating 1-2 portions nuts daily reduces the risk of cardiovascular disease and lowers and triglycerides. ·All tree nuts and peanuts provide a source of healthy monounsaturated and polyunsaturated fatty acids and fibre and likewise all dried fruits are a source of carbohydrate and fibre and are low in fat and salt. ·The nutrients in traditional dried fruits are similar to the equivalent fresh fruit (eg comparing one grape or plum to one raisin or prune), so they provide good sources of several micronutrients, except vitamin C. ·As regards micronutrients, each type of nut and dried fruit have individual strengths due to their unique mixes of different of vitamins, minerals and health protective bioactive compounds. ·Seafood is a nutritious source of protein; some species are source of omega 3 and 6. Imports contribute as well to sustainability of the EU food manufacturing and retail sectors. The EU supply chains have a high degree of specialization and interdependence, so that both EU and non-EU ingredients are essential. In our view, labelling of origin does not provide sufficient information on sustainability, which is not determined by origin alone. Sustainable farming and processing practices must be considered, and these are often sector and/or product specific. Any future policies should involve impact assessment and be based on science.
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Response to Commission Regulation setting maximum residue levels for chlorate in or on certain products

18 Feb 2019

FRUCOM represents and defends the interests of traders in dried fruit, edible nuts, processed fish and processed fruit and vegetables in Europe and beyond. FRUCOM welcomes the opportunity to provide comments on this draft Regulation. Chlorate is used in water treatment to control microbial, viral and parasitic pathogens in limiting their occurrence in water. This water is used in nearly all steps of the production process, including: irrigation, washing, cooling, rinsing, glazing, transporting and blanching. Chlorate is also used for sanitising and disinfecting equipment and other surfaces which come into direct contact with food products. These are considered major sources of chlorate residues in food products. Chlorate is no longer permitted to be used as a pesticide under EU legislation. Therefore, FRUCOM believes that EU Regulation 396/2005 is not the appropriate legal framework to regulate the presence of chlorate in food. FRUCOM calls on the European Commission to put on hold discussions on MRL changes until the ongoing review of the Drinking Water Directive is finalised and appropriate limits for chlorate in drinking water can be established. FRUCOM invites the Commission to have a broader discussion on the setting of realistic maximum levels under the appropriate legal framework, taking into account all potential sources of chlorate and ensuring high microbiological safety and hygiene standards to ensure public health.
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Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

10 Sept 2018 · trade in dried fruit

Meeting with Jyrki Katainen (Vice-President) and FoodDrinkEurope and

28 Mar 2017 · Plastics Value Chain

Response to Import conditions for foodstuffs from non-EU countries due to microbiological contamination

16 Nov 2016

Since microbiological contamination can be eradicated as a result of heat treatment at certain temperatures and period of time, we believe that imported food of non-animal origin that are intended for further processing by a validated heat treatment process should be exempted from the scope of this Regulation.
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