Hotelverband Deutschland (IHA) e.V.
IHA
Der Hotelverband Deutschland (IHA) ist der Branchenverband der Hotellerie in Deutschland.
ID: 69817563153-14
Lobbying Activity
Response to Fairness in platform-to-business relations
21 Nov 2017
See file attached.
Read full response6 Jul 2017
German Hotel Association (IHA) opposes a Commission Regulation (EU) on the application of control & mitigation measures to reduce the presence of acrylamide in food for the following reasons:
1. -Legislative regulation is not necessary as voluntary measures are adequate-
Disproportionate burdens like documentation obligations or sampling and analysis obligations would harm a lot of businesses in the hospitality sector without being necessary for consumer protection. A legislative regulation is also inappropriate considering the ambiguous data regarding the relation between health effects and acrylamide exposure through food. The German hospitality industry, which mostly consists of small and medium-sized enterprises, has to deal with excessive bureaucracy anyway. Therefore, DEHOGA opposes another burdensome und unfounded legal initiative and supports an information campaign instead.
Apart from that, another reason to stop this draft regulation is the general emotional rejection of unnecessary EU-bureaucracy. The obligation to hang out a “French fries traffic light” brings back memories of the “cucumber regulation” or the “olive oil jug ban” in restaurants.
2. -Information campaign instead of regimentation-
Consumer health is a top priority for us. Even though there is no clear evidence of a causal relation between the amount of acrylamide in foodstuffs and consumer health (according to EFSA), we understand that consumers might be confused and aware regarding the presence of acrylamide in foodstuffs. Therefore DEHOGA assumes its responsibility and is willing to take part in an information campaign to raise awareness of the acrylamide subject. To ensure an effective campaign we want to help to develop guidelines and brochures together with similar business associations. While disproportionate measures, as demanded by the European Commission, will evoke incomprehension amongst businesses and the general public, voluntary measures would be more motivating and therefore effective concerning consumer protection.
3. -Producers are primary responsible-
Instead of burdening the SME sized hospitality industry with even more red tape, producers of foodstuffs that are mentioned in article 1 No. 2 of the draft regulation should make sure to provide the hospitality sector with information about risks and recommended preparation methods. Thus, the hospitality industry is put in a position to keep the presence of acrylamide low.
4. -Draft regulation wording is not unambiguous-
Besides these basic objections against the regulation draft, it also lacks clear and precise enough wording and therefore infringes the principle of legal certainty. The wording in article 2 No. 3 of the draft regulation is not precise enough and creates delimitation problems. This would lead to major execution problems and legal disputes regarding the question whether a business falls under the category of article 2 No. 2 or 2 No. 3 of the draft regulation.
The requirement regarding the use of a “colour guide” (Annex II Part A) raises questions: Who supplies the businesses with the colour guides? Will it cost anything? How can a consistent printing and colour quality of various colour guides be ensured? Even if a consistent quality of the colour guides can somehow be ensured, the illumination at workplaces differs from workplace to workplace, so that this aspect alone leads to different coloured representations. This results in unavoidable problems regarding execution and practical implementation.
German Hotel Association (IHA)
Am Weidendamm 1A
10117 Berlin
Germany
www.hotellerie.de
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