Lobbying by GroentenFruit Huis

GroentenFruit Huis

GFH

GroentenFruit Huis is de brancheorganisatie voor producentenorganisaties en bedrijven, actief in de handel, bewerking en afzet van verse groenten en fruit.

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Website Transparency Register Profile

ID: 824033130961-66

Lobbying Activity

Meeting with Gijs Schilthuis (Director Agriculture and Rural Development)

14 Jan 2026 · Food and Feed Omnibus, PPWR

Meeting with Johannes Van Den Bossche (Cabinet of Commissioner Christophe Hansen) and Freshfel Europe - the forum for the European fresh fruits and vegetables chain

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

Response to Food and Feed Safety Simplification Omnibus

14 Oct 2025

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Response to Updating the methods for sampling and analysis for pesticide residues and repealing Directive 2002/63/EC

29 Jul 2025

We welcome the introduction of measurement uncertainty in the assessment of compliance with Maximum Residue Limits (MRLs). The previous Commission Directive 2002/63/EC did refer to the "accuracy and precision of analysis" when determining compliance, but the proposed new regulation introduces a clear and concrete method for addressing this uncertainty. By incorporating measurement uncertainty in a structured manner, the new regulation makes the assessment of MRL compliance more scientific, robust, and fair. However, we note with concern the provision in Annex, Part C, point C.3.2, which states that when the residue level found in a sample results in an international estimated short-term intake (IESTI) exceeding the acute reference dose (ARfD), a measurement uncertainty with a lower confidence level may be applied. In our view, the current wording leaves room for diverging interpretations among Member States. This could result in inconsistent enforcement and unequal treatment of operators across the single market. To ensure legal certainty and harmonised implementation, this provision should either be reconsidered or significantly clarified. The regulation also offers increased clarity and specificity for sampling very large products, such as melons, and fruits presented in bunches, such as bananas. This is achieved through the introduction of explicit classifications and definitions of "units" that are better tailored to the characteristics of these products. Sampling of highly valuable products: Although the possibility already existed under the old directive, the proposed new regulation places greater emphasis on the option to take a smaller sample size for products of exceptionally high value (e.g., saffron, rose petals), provided that the reason is clearly stated in the sampling report. This is a pragmatic and proportionate approach that we strongly support. This reaction is given by Fresh Produce Centre / GroentenFruit Huis is an industry body from the Netherlands that represents the interests of vegetables and fruit producers/ growers, their Producer Organisations, traders and wholesalers export companies etc. The members of Fresh Produce Centre account for over 80% of total sales of vegetables and fruit in the Netherlands. Our number in EU- transparency register is 824033130961-66

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Response to Fruit and vegetables – review of sectorial rules and modernising certain market monitoring provisions and mechanisms

11 Jun 2025

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Response to Fruit and vegetables – review of sectorial rules and modernising certain market monitoring provisions and mechanisms

6 Jun 2025

Regarding the proposed change of article 74.1 of Delegated Regulation (EU) 2017/891 and the consideration point 2 and the proposed change of article 38 of Implementing Regulation amending (EU) 2017/892: Still a significant volume in the trade of Fruit and Vegetables is done at a daily basis, prices in the market are volatile due to changes in supply and demand. SIV's are now compiled on a daily basis, so reflects and give the actual value of the fruit and vegetables on that specific day. When SIV are set on a weekly basis, as given in the proposal, the actual import goods are tariffed on a historical (partly) price that goes back for 16 days the maximum. For a well-functioning EU market (mechanism) we are strongly in favour of keeping the system of a daily SIV that has existed for so many years. We need a system in which import duties are paid on the actual market value. The actual (and daily based) realistic value of the good has to be taken into account for the system of entry prices as well. A further reduction of administrative burden can easily be established by improving ICT systems of MS and EC, whilst not harming the internal market, as MS still has to obtain prices on a daily basis from the Fruit and Vegetable markets.

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Meeting with Tom Berendsen (Member of the European Parliament) and evofenedex the Dutch Shippers' Council

12 May 2025 · Fresh food logistics

Meeting with Ricard Ramon I Sumoy (Acting Head of Unit Agriculture and Rural Development)

10 Apr 2025 · On-farm Sustainability Compass

Response to Targeted amendment to the CMO and other CAP Regulations strengthening farmers position in the food supply chain

7 Mar 2025

About Fresh Produce Centre: Fresh Produce Centre / GroentenFruit Huis is an industry body from the Netherlands that represents the interests of vegetable and fruit producers / growers, their Producer Organisations, traders and wholesalers, export companies, etc. The members of Fresh Produce Centre account for over 80% of total sales of vegetables and fruit within the Netherlands. Our number in EU- transparency register is 824033130961-66. The Fresh Produce Centre welcomes the opportunity to react on the REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) No 1308/2013, (EU) 2021/2115 and (EU) 2021/2116 which regards the strengthening of the position of farmers in the food supply chain. 1. In article 168 proposals are given on contractual relations. The fruit and vegetable supply chain is highly volatile and changes daily. Harvest times are dependent on weather conditions, produce is highly perishable, and the supply chain depends on the ripening process / maturity of the fruit and or vegetable (including seasonal supply). In this case we plead to exempt the fruit and vegetable sector completely - and more specifically EU 27 - from the proposed obligation of written contracts or offers (art. 168.6.b). Writing contracts for highly volatile daily trade, then uploading them in a MS system etc. will cost valuable time, perishables will lose quality and value, and the proposed increase of time will cause food loss in the supply chain. As the trade between producer and first buyer is inter EU MS, we do not think it wise to have a difference between MS regarding perishables under art. 168.9. In summary: we propose to move art. 168.b (for perishables such as Fruit and Vegetables) under a new article 168.5.e. 2. Article 88a. Optional terms for commercial modalities In article 88a proposals are made to define terms as "fair", "equitable" and "short supply chain". Currently these terms are used as marketing tools in wholesale/retail markets for promotional purposes. Besides the large and intensive EU-wide discussion of defining these terms, we foresee a large administrative burden and an intensive process of audits and inspections if this is to be regulated by authorities. The highly appreciated labels "organic" and/or "GI" are already in the markets. Creating these new labels ("fair", "equitable" and "short supply chain") and defining and controlling them by EU legislation will lead to more confusion for consumers , and an increase in prices. We are in favour of NOT regulating "optional terms of commercial modalities". This draft regulation is in direct conflict with the Green Claim Directive, which aims to empower consumers towards the green transition by regulating sustainability claims and tackling misleading claims with clear and reliable information. Products using terms like "fair" must have a label based on an independent certification system, audited by a third party in accordance with European rules, and apply to both EU and imported products. Since the Commission adopted Recommendation 2013/179/EU in 2013, the Product Environmental Footprint (PEF) method has been developed. This method helps companies make substantiated claims, reduce assessment costs and improve product comparisons. The fresh fruit and vegetable sector is and has been investing in developing Product Environmental Footprint Category Rules (PEFCR). Setting any other definitions as proposed in Article 88a will therefore undermine the objectives of Directive 2024/825.

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Meeting with Anna Strolenberg (Member of the European Parliament, Shadow rapporteur)

20 Feb 2025 · Mercosur, common agricultural policy, Common market organisation

Meeting with Jessika Van Leeuwen (Member of the European Parliament)

20 Nov 2024 · Exchange of views

Meeting with Ton Diepeveen (Member of the European Parliament)

13 Nov 2024 · Kennismakingsgesprek

Meeting with Bert-Jan Ruissen (Member of the European Parliament) and European Food Forum

16 Oct 2024 · Agriculture

Response to Approvals of unilateral extensions of ETS2 scope and corresponding additional allowances

16 Aug 2024

Fresh Produce Centre / GroentenFruit Huis is an industry body from the Netherlands that represents the interests of vegetable and fruit growers, their Producer Organisations, traders and wholesale export companies etc. Our number in EU- transparency register is 824033130961-66 As representatives of the Dutch fresh fruit and vegetable trade we are concerned about the additional sector expansion under ETS 2 in the Netherlands. There is a well-founded concern among many of the affected business operators that the proposed extension could adversely impact the level playing field, lead to negative external effects with respect to European trade integration and jeopardize the broader sector ambitions of transitioning to multi-modal transport chains. Our economy and many surrounding member states are reliant on our position as the European entry hub, as a significant portion of the fresh-produce that enters the internal market is funnelled through one of our main ports or produced in The Netherlands. We have reservations about the effect that introducing additional administrative and financial burdens on transport could have on this essential function. Especially considering that this expansion only applies to the Netherlands and is supplementary to the standard ETS obligations in the rest of the Union. This in turn threatens the level playing field for member states and in turn could potentially harm the internal market. Furthermore, the rail sector being included hampers the viability of many multi-modal transport initiatives that are currently underway, as many of them include rail freight as a more sustainable alternative to road haulage. Additional costs being levied on such sustainable alternatives could further inhibit this necessary transition. We suggest that serious consideration is given to amelioratory measures for those designated sectors which are capable of substituting more polluting ones. Additionally, attention needs to be paid to implementing reasonable 'price corridors' to ensure efficacy and prevent disproportionately high costs for business-operators and in the end, the EU consumers..

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Meeting with Tom Berendsen (Member of the European Parliament)

11 Jan 2024 · Introduction

Response to Legislation for plants produced by certain new genomic techniques

4 Nov 2023

About Fresh Produce Centre: Fresh Produce Centre / GroentenFruit Huis is an industry body from the Netherlands that represents the interests of vegetables and fruit producers/ growers, their Producer Organisations, traders and wholesalers export companies etc. The members of Fresh Produce Centre account for over 80% of total sales of vegetables and fruit within the Netherlands. Our number in EU- transparency register is 824033130961-66 The Fresh Produce Centre welcomes the opportunity to react on the draft Regulation on plants obtained by certain new genomic techniques and their food and feed. Having resistant and resilient crop varieties is one of the foundation of a solid and well-functioning IPM and linked to meeting the goals set in the Green Deal. To enable the advantage of new breeding techniques in the EU) adjustment of the GMO legislation is key. We welcome the proposal of the Commission very much as this enables innovation and increases the toolbox of breeders also the SMEs. An important pillar in the draft Regulation is to exempt NGT and category 1 NGTs from the GMO. Furthermore, it is key that this draft Regulation is set at the EU level in order to guaranty free movement of goods (seeds, plants for planting and food/feed produce) within the Union and also clarifies rules for imported products. As there is competitive disadvantage for the EU operators and the risk of trade disruptions, the adaptation of the EU regulatory frame work for NGT is both crucial and urgent. No additional labelling on final food products As there is no difference in the characteristics of the food and, in particular, as to its nature, identity, properties, composition, quantity, method of manufacture or production of food product obtained from cat.1 NGT labelling or from conventional breeding, we support that labelling of the end-product is not needed. Both at the genomic level of the plants and the product levels these cannot be distinguished. Labelling would be discriminatory and misleading of consumers, being not in line with art 1 of Regulation 1169/2011 of Food Information. Looking from comparative claims perspective on fair information practises throughout the supply chain, the discriminatory negative labelling of NGTs would not only significantly increase the cost within the food supply chain but also the willingness to use NGT crops. The traceability of food is already required in general food law and no additional requirement needs to be set in this legislation. Annex I equivalence criteria for NGT The set cut-off of a maximum number of 20 modifications is not based on sound scientific data. This maximum number is exceeded with conventional breeding techniques and thereby is not in line with aim of defining the equivalent NGT plant. This maximum number seriously hampers the application of NGT techniques in improvement which are relevant for sustainable agriculture. Complex traits like drought resistance or more efficient nutrient conversion involves multiple loci and will vary for the different plant species. Furthermore since many plant species are polyploid, the maximum number of modification should be fixed at the haploid genome. Organic Production The draft regulation clarifies that as with the Regulation (EU) 2018/848 on organic production and labelling prohibits the use of GMO seeds and products also the NGT will be prohibited. END

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

18 May 2023

GroentenFruit Huis maakt bezwaren tegen de voorliggende Consultatie Wijziging van Verordening (EU) 1308/2013 met kenmerk (2023) 2826215 waarmee zowel snijderijen, handelaren, telers, producentenorganisaties actief in de productieketen van versneden groenten en fruit (IV-gamma) als de consumenten in negatieve zin (en) buitenproportioneel worden geraakt. Dit wordt enerzijds veroorzaakt door: A. Het inperken van de definitie "industriële verwerking" in het voorstel tot enkel verduurzaamde groenten en fruit (conserven, diepvries, jams) producten en daarmee de bepalingen de uitzondering en vrijstelling voor de handelsnormen voor zowel de levering van de grondstoffen als het eindproducten van snijderijen ingrijpend zijn gewijzigd. Anderzijds door B. Het opnemen in het voorstel van bepalingen tot een verplichte vermelding van land van oorsprong op verpakkingen met versneden groenten en fruit (IV Gamma product) want verandert het volledige productieproces en bedrijfsvoering van snijderijen wat tot leidt tot enorme investeringen en zeer grote kostentoename in het proces van versnijden, verpakken en labelen van verse groenten en fruit. Het aandeel van versneden verse groenten is 25% van het totale verkoopvolume groenten in de Nederlandse supermarkt. Ook in andere lidstaten zien we een toenemende vraag naar deze producten. De door de EC beoogde wijziging van de huidige Verordening leidt echter tot een averechts effect op de diverse gestelde doelen gesteld in zowel de Farm to Fork als de Green Deal. Het voorstel zal leiden tot een toename van voedselverspilling, verhoging van de CO2 uitstoot in de gehele productieketen en grote disproportionele prijsstijgingen voor de consument waardoor het stimuleren van meer consumptie van groenten en fruit in Europa niet wordt bereikt. In onderhavig en bijgevoegde document zetten we onze bezwaren uiteen. Wij vragen de EC klemmend haar voorstel aan te passen en terug te keren naar de oorspronkelijke teksten uit de Vo 543/2011 de welke in praktische zin werkbaar waren en niet leiden tot de hierboven genoemde negatieve impact op de totale keten van telers, productenorganisaties, handelaren, snijderij bedrijven, retailers en Europese consumenten van vers gesneden groenten en fruit. About Fresh Produce Centre: Fresh Produce Centre / GroentenFruit Huis is an industry body from the Netherlands that represents the interests of vegetables and fruit producers/ growers, their Producer Organisations, traders and wholesalers export companies etc. The members of Fresh Produce Centre account for over 80% of total sales of vegetables and fruit in the Netherlands. Our number in EU- transparency register is 824033130961-66

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

21 Apr 2023

Fresh Produce Centre is an industry body with members who are important players in the production, producer organisations trade, export of fruit and vegetables. They supply a complete assortment to the European retailers and food service, EU consumers. We represent 80% of the Dutch business, we react on behalf of them. Although we endorse the need for packaging to be more sustainable, the proposed legislation will have a significant negative impact on the sector. The sector benefits from unambiguous policy across the various EU MS to enable the free movement of goods. The proposed legislation offers a good basis for this, however in our opinion it also has several bottlenecks. Moreover it gives MS a possibility to deviate implementation from European legislation if the requirements are stricter than described in EU law. This in turn can lead to a range of different measures per MS and does not contribute to a 'one single market'. Fruit and vegetables are fresh, living products that are still undergoing development from the time of harvesting to consumption. Packaging has an important function when it comes to maintaining quality, product protection, food safety, traceability and preventing food waste. It is quite possible that existing legal regulations for fruit and vegetable packaging and labelling conflict with a potential ban on fruit and vegetable packaging > 1.5 kg. Failure to pack fruit and vegetables will further lead to moisture loss, resulting in lower quality, but also loss of economic value. In the Netherlands, about 70% of all fruit and vegetables are currently packaged in supermarkets. Banning packaging under 1.5 kg will much more often lead to food waste and is therefore in conflict with the objective of the Green Deal to halve food waste by 2030. Banning packaging under 1.5 kg therefore has a substantial negative environmental impact as a result and a negative effect on the availability of fruit and vegetables. The limit of 1.5 kg is also insufficiently substantiated and seems arbitrarily chosen. In many cases, packaging makes an important contribution to another objective of Europe, namely to stimulate the consumption of fruit and vegetables, which in turn contributes to the health of citizens, and it also concerns a diet with a low environmental impact. With packaged products for different eating moments, such as snack vegetables for snacks, consumers are helped to make a healthier and environmentally conscious choice. The share of packaged fruit and vegetables in the total volume of packaging waste is relatively small at approximately 1.6% of the total packaging amount in the Netherlands (source: KIDV.nl). The proposed legislation specifically for fruit and vegetables is therefore disproportionate given this low share of packaging and its positive contribution in terms of shelf life, quality and traceability. In addition, the ban on packaging up to 1.5 kg does not do justice to the companies that have switched from plastic to cardboard packaging for fruit and vegetables in recent years. Scientific research has to point out which product can be produced and traded without or with sustainable packaging. The use of circular raw materials in the European Union is appropriate if the waste system in the 27 member states can provide enough reusable and circular (bio)plastics and recyclable cardboard for safe, good and clean fruit and vegetables without food waste. We therefore ask you to reconsider the proposal to ban packaging under 1.5 kg for fruit and vegetables. More research is needed into the environmental impact of packaging fruit and vegetables under 1.5 kg. The availability of recycled plastic as a raw material for plastic packaging should also be taken into account. The availability of sufficient food grade recyclate is currently a problem in making plastic packaging more sustainable. See our letter attached.

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

15 Mar 2022

Fresh Produce Centre represents the interests of businesses involved in the sale and marketing of fruit and vegetables and is a source of knowledge and inspiration. Its members account for over 80% of total sales of fruit and vegetables in the Netherlands, which are worth around €15 billion (including growers’ associations). Our organisation has around 350 members. The members are trading companies and growers’ associations involved in the sale and marketing of fruit and vegetables. They are specialised in the domestic wholesale, import, export, treatment, processing, packaging, storage and transhipment of fruit and vegetables. We have the following comments with regard to the document on the 'Application of EU health and environmental standards to imported agricultural and agri-food products': • It is positive that the EU wants to play a prominent role, but it must be emphasized that there are several ways to achieve the environmental/sustainability goals as described in the Farm-to-Fork Strategy. By applying different production standards/systems, the same objectives can be achieved. • If the EU will install higher trade barriers for agricultural products from third countries, we will most probably be confronted with retaliation measures (third countries will demand compliance with their own specific environmental/sustainability requirements) which will make it much more difficult for EU producers to export their products in the near future to export their products to countries outside the EU. This is a major problem for those EU member states which are dependent on international trade. • A European environmental footprint initiative should be considered as an important science based tool to ensure that European producers comply with the European standards. At the same time we should prevent that those standards become too stringent and are fit-for-purpose. It requires an holistic approach as in which elements such as type or crop, climatic conditions, production methods, type of pest and diseases and the availability of water are also within the EU highly variable. • Empowerment of food producers worldwide and sharing best practises to improve sustainable food production is needed. • Consumers are not willing to pay for sustainability as such. This needs to be taken into account when new policies are being developed. However, it is important in this transition that consumers are willing to pay a better price for agricultural products. Therefore consumers should be motivated to pay a higher price for sustainable food. Profitability is an important pillar of sustainability. • European policy makers and producers should rely more on the strength of their own products instead of relying on protectionist measures to sell their products within and outside of the EU. European food is worldwide highly being appreciated. • Sustainability targets, such as the ones mentioned in the Farm-to-Fork Strategy, should always be science based. This is currently not the case since the policy which is being developed at the moment is mainly the outcome of political discussions. • It is important to realise that we do not have a level playing field within the EU when it concerns the application of plant protection products (PPP). PPP's which are not allowed in The Netherlands are allowed in other EU member states, and the other way around. IPM should be the main driver of plant protection both with the EU and third countries. • It is not realistic to prohibit all import MRL's as is being proposed by some member states. Low risk and biological active substances are also widely used in third countries. The time to market new innovations including low-risk PPP (synthetic and biological) might be shorter in specific third countries.

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

20 Nov 2021

Fresh Produce Centre appreciates the possibility to comment on the draft act for the school fruit, vegetables and milk scheme - educational measures and the selection/approval of aid applicants. Fresh Produce Centre represents the interests of businesses involved in the sale and marketing of fruit and vegetables and is a source of knowledge and inspiration. Its members account for over 80% of total sales of fruit and vegetables in the Netherlands, which are worth around €15 billion (including growers’ associations). Our organisation has around 350 members. The members are trading companies and growers’ associations involved in the sale and marketing of fruit and vegetables. They are specialised in the domestic wholesale, import, export, treatment, processing, packaging, storage and transhipment of fruit and vegetables. We are convinced that the European school fruit, vegetables and milk scheme is of great importance to the distribution of fresh, healthy and sustainable products amongst school children in the EU. We therefore greatly appreciate the work which has been put into the school scheme in order to increase the consumption of fruit and vegetables at schools. Although a large number of proposals have been made to improve the EU school scheme, further adjustments might be needed to improve the effectiveness of the scheme: Broaden the scope - We think that it is important to give every child the opportunity to provide fresh fruit and vegetables. Nevertheless it should become possible for member states to reserve a part or percentage of the available amount of the available budget for certain target groups who might need it more. Include sustainability in the educational measures - The Delegated Regulation points out several examples of educational activities which should be rolled out to reconnect children with agriculture. This is an important element but in this regard it should not be forgotten that a certain number of fruits and vegetables are not available year round. There should be more attention for this aspect which is extremely important for the level of sustainability. Children should get informed better about the sustainability aspect of the products they consume. That is why every member state should be able to appoint a fixed percentage of its budget for accompanying measures. This should be realised through public procurement and not through a system of flat rates in which the supplier is being held responsible for proving that the educational measures have truly been realised. Fresh Produce Centre would like to thank the European Commission for the adjustments of the school fruit, vegetables and milk scheme - educational measures and the selection/approval of aid applicants and for taking the comments of stakeholders into account. We appreciate all the efforts which are currently being undertaken to stimulate the intake of fresh products by promoting fruits and vegetables as healthy and sustainable products which fit in a healthy diet.

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Response to Farm to Fork Strategy

16 Mar 2020

Fresh Produce centre promotes the interests of companies that are active in the sale of fruit and vegetables and is also a source of knowledge and inspiration. Its members account for over 80% of total sales of fruit and vegetables in the Netherlands, which are worth around €15 billion (including growers’ associations). Fresh Produce Centre has around 350 members. The members are trading companies and growers’ associations involved in the sale and marketing of fruit and vegetables. They specialise in the domestic wholesale, import, export, treatment, processing, packaging, storage and transhipment of fruit and vegetables. All Fresh Produce Centre underlines the challenges which are described in the Farm to Fork Strategy as well as the urgency of creating a more sustainable food system. It is a positive development that Europe is realising this goal through the Green Deal and the Farm to Fork Strategy but it is also important to realise that we have to commit ourselves to the Sustainable Development Goals (SDG's) since we are dealing with global challenges. Process consultation Fresh Produce Centre welcomes the possibility which is offered by the European Commission to comment on the Roadmap of the Farm to Fork Strategy. We can support the overall objective of the strategy. Especially when it concerns making healthy diets, in which fruit and vegetables should play a prominent role, the easy choice for European citizens. However, we also would like to share some comments with regard to the process of the consultation of citizens and stakeholders: • The fact that the consultation on the 'Farm to Fork Strategy' is taking place before the document itself has been published is something we are worried about. If there will be no second online consultation on the 'Farm to Fork Strategy' we fear that there will not be enough ways to respond on the content of the strategy in a written way. • The installation of a Dedicated Advisory Group of the Food Chain and the possibility for stakeholders to take part in a workshop, besides the already existing CDG on the CAP, might not be sufficient for all stakeholders in the food supply chain to respond to the Farm to Fork Strategy in an efficient way. There is also the risk that some of the relevant stakeholders will be excluded in this way from the consultation process due constraints which make it impossible to attend the meeting which still need to be scheduled. • Although the strategy sets out four relevant goals, it does not entail which ones will have the most priority. Because of this, it remains unclear what the focus of the Commission will be. • The strategy is in some cases too general. For example when one is talking about 'for food producers to thrive in a sustainable food system'. In other cases it is too detailed. For example, when it concerns proposed actions to promote sustainable food consumption. In this paragraph it is assumed that, when consumers are informed better about where there food is coming from and what the nutritional value is, this will automatically result in to more sustainable and healthy choices. However, this will not necessarily be the case. • While the CAP is still being discussed by the European Parliament, and an agreement on the Multi annual Financial Framework still needs to be finalised, one is already stating that the CAP should reflect the goals of the Strategy. This is surprising since the CAP is not integrated in the Green Deal and is still intensively being discussed by the members of the European Parliament. Even though, the CAP will be instrumental in implementing the Farm to Fork Strategy. • There is no clear timeline on the 'Farm to Fork Strategy' yet which makes it difficult for member organisations in the food supply chain to consult/inform their members on time about relevant upcoming stakeholder events and to draft a clear strategy on how to take part in the consultation process in an efficient way.

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Response to Identity and physical checks on certain goods performed at control points and documentary checks performed at distance

20 Sept 2019

Dear Sir / Madam, Fresh Produce Centre represents both production and trading companies (import, export, domestic) in fresh fruits and vegetables in the Netherlands, with a combined turnover of about 15,1 billion euro’s. The members of Fresh Produce Centre play an important role in the import of plant products in the European Union. With regard to the Commission draft Implementing regulation regarding the "Information Management System for Official Controls (IMSOC)" / CHED we would like to emphasize our following concerns: Commission Delegated Regulation supplementing Regulation (EU) 2017/625 (Brussels SANTE/2019/7128) Chapter 1 Identity checks and physical checks performed at a distance from a border control post. Article 2 item (d) Before the consignment leaves the border control post, the operator has notified the competent authorities of the control point where identity and physical checks are to be performed of the expected time of the arrival of the consignment and of the means of transport by completing and submitting a separate CHED into the information management system for official controls ('IMSOC') Our serious concern regarding the second CHED (CHED II): A second CHED (CHED II) used for a shipment that already got a CHED (CHED I) will cause confusing during the import process. Our members and their suppliers will mix these documents while both are related to the same shipment. When more details become available this can preferably be entered in the commonly used import system (Client Import). When these details have to be part of the CHED document (CHED I) it will be much more understandable to update the already existing CHED by the system. This to make sure there is only one CHED in use for the specific shipment (with a unique document number). This will also help to keep computer systems (Authorities- and Company systems) straight forward without complex checks to prevent for mistakes. These new data requirements impose a high administrative burden for all member states. In the case of the Netherlands, it will cost the government an extra € 6.5 million per year (5 times as much as currently) and Dutch operators € 11.8 million per year (4.5 times as much as currently). Yours faithfully, Daco Sol Fresh Produce Centre The Netherlands

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Response to Temporary measures on entry into the Union of certain goods

16 Jul 2019

Fresh Produce Centre is the Dutch industry association that comprises both the production and trading companies (import, export, domestic) in fresh fruits and vegetables in the Netherlands, with a combined turnover of about 16 billion euro’s. The members of Fresh Produce Centre play an important role in the import of fruit and vegetables in the European Union and aim to do so in a responsible way. With regard to the Draft Commission Implementing Regulation (EU) on the temporary increase of official controls and emergency measures governing the entry into the Union of certain goods from certain third countries we would therefore like to emphasize the following points: • Emergency measures should only be activated in the case of a real emergency situation. Currently, emergency measures seem to be used for protectionist purposes. This should not be allowed. Clear scientific evidence needs to be presented to justify the implementation of emergency measures. • MRL's should not be considered as food safety thresholds. MRL's are based on Good Agricultural Practices (GAP) and represent a trading limit. However, stricter import controls are often justified by the European Commission by referring to MRL exceedances. At the same time it is unclear which type of data/dossier, collected by the Commission through the member states, is being used by the Commission to impose measures. It would be better if the Commission receives also the data from the sector itself in order to develop tailor-made solutions. • An increase in transparency is needed to get to know more about the way in which commodities are classified as high risk. For business operators it is important to know why commodities are considered as high risk and how those products can lose this label again. Therefore the criteria which are used by the Commission should become clear and should be communicated in a transparent way. Besides this, it also relevant to have more clarity about the duration of a temporary measure and about the length of the procedure to get commodities removed from the high risk list. Business operators need incentives. Therefore the Commission should reward those operators who help to minimize the risks while operators who intentionally take insufficient account of the risks should be penalized. • As a result of the use of systems like TRACES, more detailed information on consignments and trade volumes can be gathered in the near future. This makes it possible to have a closer look at trade flows. Digital innovation in the sector should be used to see how the sector can help to gather more useful information on the import of commodities to minimize food safety risks. • More responsibility can and should be given to the private sector. Most food safety checks in third countries are already being executed by the private sector. This has everything to do with the fact that exporters outside the EU must comply with European retailer standards which are in general more strict, for example when it comes to MRLs, than those which are set in the EU legislation. A general measure on origin and commodity is not making any difference when it comes to food safety while it does create an unnecessary increase of the costs and delay in logistics. This makes it difficult to maintain the quality of the perishable commodities. It is therefore important to speed up the procedures. • Proportionality should be taken into account when implementing new measures. That is why it is relevant to look at the figures of the overall number and volume of imports. This is important in order to put the data in the right perspective. It would be highly appreciated if the European Commission takes the above mentioned comments into account. In the case of questions Fresh Produce Centre is always prepared to answer them.

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

18 Feb 2019

The Fresh Produce Centre (GroentenFruit Huis) would like to thank the European Commission for the opportunity to comment on the Commission proposal SANTE/10684/2015 Rev. 3 to amend Annex III to Regulation (EC) No 396/2005 as regards MRL for chlorate. For more information, see attachment.

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