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Landbrug Fødevarer - Danish Agriculture and Food Council

DAFC

The Danish Agriculture and Food Council represents Danish farmers, producers and cooperatives, working to promote their interests and strengthen competitiveness nationally and internationally.

Lobbying Activity

Meeting with Per Clausen (Member of the European Parliament)

26 Jan 2026 · NGT

Meeting with Dan Jørgensen (Commissioner) and Nykredit Realkredit A/S and PFA Pension, Forsikringsaktieselskab

12 Dec 2025 · Energy policy and European Competitiveness

Meeting with Christel Schaldemose (Member of the European Parliament)

2 Dec 2025 · transport of animals

Meeting with Rasmus Nordqvist (Member of the European Parliament)

19 Nov 2025 · Agricultural policy

Danish Agriculture Group Backs Flexible Emergency Slaughter Rules

16 Oct 2025
Topic — EU regulation amendment on emergency slaughter of domestic ungulates outside slaughterhouses.
Message — The organization supports the proposed changes to allow more flexible emergency slaughter conditions. They request guidance text clarifying when animals should not be emergency slaughtered and suggest allowing video consultation for ante-mortem inspections.123
Why — This would reduce economic losses from injured animals and minimize food waste.4
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Danish Agriculture Council urges delay in bluetongue reclassification

13 Oct 2025
Topic — EU proposal to recategorize bluetongue virus as a category D disease.
Message — The organization requests delaying the reclassification until the disease's progression is better understood. They argue current uncertainty makes the change premature and could increase risks of new serotypes spreading. Member states should retain authority to prevent imports of animals carrying new serotypes.123
Why — This would maintain stricter import controls protecting Danish herds from new bluetongue serotypes.45
Impact — Other member states lose flexibility in disease management as national control replaces coordinated EU measures.6
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Meeting with Alexandre Paquot (Director Climate Action)

25 Sept 2025 · Implementation of the Danish Tripartite Agreement

Meeting with Per Clausen (Member of the European Parliament)

25 Sept 2025 · Ændringer af landbrugsstøtten

Meeting with Gijs Schilthuis (Director Agriculture and Rural Development)

25 Sept 2025 · Implementation of the Danish Tripartite Agreement

Meeting with Brigitte Misonne (Acting Director Agriculture and Rural Development)

11 Sept 2025 · Trade and policy challenges for the Danish pigmeat sector

Danish food industry urges simplified plastic recycling reporting rules

12 Aug 2025
Topic — EU initiative setting rules for calculating and reporting recycled plastic in bottles.
Message — The group proposes annual facility-level reporting instead of burdensome batch-wise records. They also advocate for transferring credits between facilities to improve operational flexibility.12
Why — Reducing record-keeping requirements would lower administrative burdens and overall compliance costs.3
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Danish Agriculture Council urges EU to relax state aid rules

10 Jul 2025
Topic — EU consultation on a strategy to attract young and entrepreneurial farmers.
Message — DAFC requests revised state aid rules to increase financial support for young farmers. They propose mandatory uniform investment rates and tax exemptions for start-up aid. They also advocate for aid eligibility for alternative co-ownership models.123
Why — This would lower financial barriers for young people entering the expensive Danish farming sector.4
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Danish Agriculture Council urges transition periods for welfare rules

4 Jul 2025
Topic — EU legislative revision to improve on-farm animal welfare and phase out cage use.
Message — DAFC supports phasing out cages but demands sufficient transition periods and financial support for farmers. They recommend allowing temporary confinement for sows around farrowing to balance animal welfare and worker safety. The organization also calls for import requirements that align with EU production standards.123
Why — This would protect farm financial viability and prevent market loss to cheaper foreign imports.45
Impact — Animal welfare groups lose as cage-free transitions are slowed and temporary confinement continues.6
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Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

1 Jul 2025 · Issues linked to the pursuit of EU Green Policies in the perspective of the challenges facing Danish farmers (with a focus on the initiatives taken under the tripartite agreement between DK gov't, farmers and environmental NGOs)

Meeting with Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall)

19 Jun 2025 · Water Resilience Strategy WFD Environment and agriculture in general

Meeting with Christophe Hansen (Commissioner) and

19 Jun 2025 · Mutual introduction and exchange of views on the MFF, the CAP post-2027, the Vision for Agriculture and Food, the simplification package, exports and global trade.

Meeting with Asger Christensen (Member of the European Parliament)

13 Jun 2025 · Agriculture

Meeting with Alexandre Paquot (Director Climate Action)

24 Apr 2025 · The overall state of affairs in EU climate policy

Meeting with Stine Bosse (Member of the European Parliament)

10 Apr 2025 · European agriculture policy

Meeting with Dan Jørgensen (Commissioner) and Meta Platforms Ireland Limited and its various subsidiaries and

10 Apr 2025 · European competitiveness and Affordable Energy Action Plan

Meeting with Asger Christensen (Member of the European Parliament)

1 Apr 2025 · Agriculture

Meeting with Stine Bosse (Member of the European Parliament)

17 Mar 2025 · European agriculture policy

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

11 Mar 2025 · Exchange on biopesticides, bio-stimulants and new proteins

Danish Agriculture and Food Council urges veterinary medicine focus

26 Feb 2025
Topic — This consultation addresses supply chain vulnerabilities and dependencies of critical medicines in Europe.
Message — The council highlights that penicillin supply for production animals is limited due to few production sites. They call for new medicines to treat prevalent animal diseases.12
Why — Securing medicine supplies would help Danish farmers maintain healthy livestock and production levels.3
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Meeting with Herbert Dorfmann (Member of the European Parliament)

20 Feb 2025 · Disucssion of the upcoming CAP reform.

Response to Authorisation of lumiVAST Trichinella for Trichinella testing

20 Dec 2024

Please find attached feedback from DAFC on this concultation
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Meeting with Asger Christensen (Member of the European Parliament)

27 Nov 2024 · Poultry Processing and Trade

Meeting with Asger Christensen (Member of the European Parliament)

12 Nov 2024 · Agriculture

Meeting with Asger Christensen (Member of the European Parliament) and Nordic Logistics Association and

4 Nov 2024 · Animal Transport

Meeting with Asger Christensen (Member of the European Parliament)

10 Oct 2024 · AGRI priorities/CAP

Meeting with Asger Christensen (Member of the European Parliament)

25 Sept 2024 · Danish Agriculture

Meeting with Sigrid Friis (Member of the European Parliament) and Fagligt Fælles Forbund

24 Sept 2024 · Sustainability in the EU, EU Enlargement and Enforcement of EU Rules

Meeting with Per Clausen (Member of the European Parliament) and Fagligt Fælles Forbund

24 Sept 2024 · Bæredygtighed i EU, bæredygtig håndhævelse af EU’s regler på et velfungerende og fair indre marked. MEP middag

Meeting with Christel Schaldemose (Member of the European Parliament)

24 Sept 2024 · bæredygtigheden i EU

Meeting with Villy Søvndal (Member of the European Parliament)

24 Sept 2024 · Discussion on agricultural and workers' affairs

Meeting with Asger Christensen (Member of the European Parliament) and Fagligt Fælles Forbund

24 Sept 2024 · Agriculture and Sustainability

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

13 Sept 2024

Danish Agriculture & Food Council would like put forward below comments to the draft: We find it is very important that uniform practices are established across Member States to ensure a harmonised approach to the implementation of the delegated act. Therefore, we urge that a standardized nomenclature for WGS types is established in all Member States, and further recommend the implementation of clear guidelines on how authorities should respond to the data collected. Additionally, we believe that equal conditions should be ensured for all businesses, so that businesses that according to article 1, point 3 deliver additional data to the competent authorities are not punished compared to businesses that do not provide addtional data. We also believe that it is necessary to establish an expiry date for isolates in the database, as the absence of an expiry date could result in businesses being implicated based on isolates that are several years old. Furthermore, it is important to clarify the ownership of the information in the authority database and who the WGS results are shared with. We believe there is a need for clarification regarding the ownership of the WGS types and other information, both in cases where the company provides the isolate, data, and WGS result, and in cases where the authorities have conducted the WGS analysis. It should also be clarified whether the information in the databases can be used for reporting, research, and development, whether the data in such cases will be anonymized, and whether businesses will need to provide consent for its use. With regard to data sharing, it is concerning if sharing WGS results with authorities could result in public access to the results, potentially leading to negative publicity for the companies involved. Sincerely Trine Vig Tamstorf Head of Food and Animal Health Policy Unit Danish Agriculture & Food Council M +45 3017 8872 E tvt@lf.dk
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Meeting with Stine Bosse (Member of the European Parliament)

17 Jul 2024 · EU Agricultural policy

Meeting with Villy Søvndal (Member of the European Parliament)

16 Jul 2024 · Welcome dinner

Danish Agriculture Council Urges Technology Neutrality for Recovered Nitrogen

17 May 2024
Topic — The consultation concerns amending the Nitrates Directive to facilitate recovered nitrogen use.
Message — The council supports the proposal but opposes listing specific processing techniques. They request that the Commission set requirements for products rather than processes. This avoids hindering technological innovation and future development.12
Why — Removing specific process lists allows the food cluster to pursue technological improvements.3
Impact — Firms developing alternative processing technologies would lose out under a restrictive list.4
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Danish Agriculture and Food Council urges rethink of transport rules

12 Apr 2024
Topic — The EU is revising rules on animal welfare during transport and exports.
Message — DAFC urges maintaining current 24-hour transport cycles and excluding loading times from travel duration. They also request deleting requirements for mandatory veterinary supervision during loading.123
Why — Preserving current standards avoids high investment costs and maintains existing agricultural logistics.45
Impact — Environmental goals are undermined by a predicted forty percent increase in truck traffic.6
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Meeting with Christel Schaldemose (Member of the European Parliament)

9 Apr 2024 · Aktuel politik særligt fødevarer og landbrug

Danish Agriculture Council seeks Animal Health Law technical updates

3 Apr 2024
Topic — Evaluation of EU regulations on animal health, disease prevention, and food safety.
Message — The council proposes a second testing phase to prevent killing healthy animals due to false positives. They also request that horse owners be permitted to voluntarily exclude animals from human consumption.12
Why — These adjustments would reduce the economic impact of food waste and lower compliance costs.3
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Response to Evaluation of the National Emission reduction Commitments Directive

14 Mar 2024

As an organization representing agriculture and the food industry in Denmark, our focus is on ammonia. Agriculture accounts for 94 percent of ammonia emissions in the EU (2020). The current directive on reduction of national emissions of certain pollutants replaced the directive on national emission ceilings in 2016. These two directives have significantly contributed to a 32 percent reduction in ammonia emissions in the EU from 1990 to 2021 (EEA 2023). There is a significant difference in how much individual member states have reduced and been obligated to reduce ammonia emissions. Several countries, including Denmark, have reduced by 50 percent or more from 1990 to 2021. This shows that there is still potential for reductions in ammonia, even with known technologies that are both economically and technically available. The Danish Agriculture and Food Council do not support the inclusion of methane in the scope for the directive on reducing national emissions, as methane as a greenhouse gas will be regulated to meet EU climate goals. A revised directive on reducing national emissions should therefore focus on opportunities for further reductions by: - Ensuring consistent implementation of already adopted legislation on reducing ammonia emissions. - Promoting awareness of known and tested technology for reducing ammonia from livestock production, manure storage, and fertilizer use. - Supporting the development, testing, and market introduction of ammonia-reducing technology by creating consistent frameworks in the EU for testing and verifying technologies for emission reduction and providing financial support for testing and implementing new technology. - Addressing scientific, administrative, and economic barriers to the introduction of emission reduction technology in general. - Ensuring coherence with other EU legislation that directly or indirectly regulates the use of emission-reducing technology, particularly the nitrate directive and the industrial emissions directive. In the recently adopted revised directive on industrial emissions, one of the initiatives is the establishment of an innovation center for industrial transformation and emissions. Knowledge from this center should be incorporated into a revised directive on reducing national emissions and its subsequent implementation.
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Response to Technical specifications for the preparation of risk management plans to ensure the safe reuse of treated waste water in

8 Feb 2024

The EU Industrial Emissions Directive require that companies must use Best Available Technipues (BAT). With reference to the EU BREF for food, drink and milk industries (COMMISSION IMPLEMENTING DECISION (EU) 2019/2031) the EU defined BAT for land spreading for these industries is BAT (BAT 10 on Resource efficiency). The use of this BAT techniques ensures that e.g. potato starch producers and dairies use land spreading of their waste water to increase their resource efficiency. It is important that the technical specification does not prevent or complicate this application. Example of technical specification that will have negative impact on the use of land spreading as a BAT: in the specification in page 5 root crops are defined as food crops consumed raw or unprocessed. Potatoes are root crops but are not consumed raw or unprocessed. They always undergo additional processing, including cooking or industrial processing and will not be eaten raw. The specification in page 5 should be changed in order to ensure, that potatoes does not belong to the category root crops. It belongs to the category processed food crops.
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Meeting with Marianne Vind (Member of the European Parliament)

24 Jan 2024 · AGRI

Meeting with Erik Poulsen (Member of the European Parliament)

22 Jan 2024 · Green Claims Directive

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

12 Jan 2024 · EU agricultural policy and food production

Meeting with Janusz Wojciechowski (Commissioner) and European farmers and

10 Jan 2024 · Meeting with EU associations representing different sectors and actors presenting a proposal for a mechanism to protect sugar, cereals/oilseeds, poultry meat and eggs farmers/producers from severe market disturbance linked to imports from Ukraine.

Meeting with Morten Løkkegaard (Member of the European Parliament)

5 Jan 2024 · Sustainable food production

Meeting with Asger Christensen (Member of the European Parliament) and Danish Shipping and

8 Dec 2023 · Agriculture/Transport

Meeting with Asger Christensen (Member of the European Parliament)

15 Nov 2023 · Agriculture

Meeting with Asger Christensen (Member of the European Parliament)

8 Nov 2023 · Delegeret L&F

Meeting with Asger Christensen (Member of the European Parliament, Shadow rapporteur for opinion)

3 Nov 2023 · New Genomic Techniques

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

1 Nov 2023

The Danish Agriculture & Food Council (DAFC) supports the Commission's focus on food waste and aims for a reduction in quantities at the EU level. This is necessary to meet the ambitions of the UN Sustainable Development Goal 12.3, which aims for a 50% reduction in food waste in households, retail, and food service sectors, as well as reduction throughout the rest of the chain. Increasing efforts to reduce food waste are important to ensure responsible resource utilization and mitigate climate impact. Therefore, DAFC has been focused on reducing food waste since 2006 and has initiated numerous activities to reduce food waste within food companies and other actors in the food chain, including consumers. Previous initiatives have demonstrated that reducing food waste takes a considerable amount of time due to the challenge of changing consumer behavior and habits. Furthermore, clear, and unambiguous definitions of food waste and consistent measurement methods are needed across the EU. Therefore, it is positive that, according to the proposal, the Commission will have the opportunity to adopt rules for more standardized methods of measuring food waste. Member States reported the first data on food waste in 2022 for the data year 2020. However, these data are highly deficient and are based on widely different methods in different countries and sectors. It has been particularly difficult to obtain data from food processing and manufacturing. Similarly, there are significant challenges in defining when something should be categorized as food waste, byproduct, or animal byproduct. Therefore, the DAFC is concerned about setting legally binding reduction targets for food waste. Our perspective is rooted in the belief that crafting legally mandated objectives for specific sectors, based on notably limited and uncertain data, is premature. In the current proposal, we would have favored the inclusion of indicative targets. Over the past two to three years, DAFC has been actively engaged with the complexities of collecting data and defining food waste within the processing sector. Obtaining data poses significant challenges for our members, involving substantial time and cost. Our slaughterhouse companies grapple with practical difficulties in quantifying food waste. The complexities are particularly pronounced when dealing with definitions and categorizations of food waste, byproducts, and animal byproducts. The question of whether food should be defined based on its consumption within a specific country or on a global scale introduces a significant discrepancy in determining what qualifies as food waste within a processing plant. Moreover, the determination of whether a residue from food processing qualifies as waste or as a byproduct (according to the Waste Framework Directive) often falls under the jurisdiction of local authorities. In Denmark, for instance, this responsibility lies with municipalities. Consequently, a residue deemed food waste in one municipality might be regarded as a byproduct in another. In addition, slaughterhouses are strictly operated according to the animal by-products regulation, and residues are classified as category I, II, or III after this regulation. This conflicts with the definition of food waste and makes it very difficult to obtain valid food waste data. DAFC is keen to engage in dialogue regarding obtaining better and more reliable data on food waste from food processing and manufacturing, as well as improving definitions and delineations of food waste, byproducts, and animal byproducts in practice. We would like the EU Platform on Food Losses and Food Waste to focus on these matters.
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Meeting with Asger Christensen (Member of the European Parliament)

26 Oct 2023 · Agriculture

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and Association Française des Entreprises Privées / French Association of Large Companies

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

Meeting with Niels Fuglsang (Member of the European Parliament)

10 Oct 2023 · Grøn omstilling

Meeting with Lukas Visek (Cabinet of Vice-President Maroš Šefčovič)

5 Oct 2023 · Sustainable food systems

Danish agriculture group demands harmonized standards for green labels

30 Jun 2023
Topic — EU initiative to standardize how companies substantiate environmental claims and labels.
Message — The group wants a single calculation method used across Europe for all environmental claims. They also argue that animal welfare should be excluded and all farming methods treated equally.123
Why — A common methodology would lower the administrative burden and costs for food exporters.4
Impact — Local national labeling schemes would lose their advantage in promoting domestic goods over imports.5
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Danish Agriculture Council urges coherence in sustainability reporting standards

30 Jun 2023
Topic — New European standards defining how companies must report environmental and social impacts.
Message — The council requests better coherence with environmental laws and specific amendments to definitions. They propose making certain disclosures optional to avoid significant extra burdens.12
Why — Alignment with existing laws would reduce complexity and cut administrative compliance costs.3
Impact — Environmental groups lose standardized data on waste recovery and circular material use.4
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Meeting with Erik Poulsen (Member of the European Parliament, Shadow rapporteur for opinion)

7 Jun 2023 · NZIA

Meeting with Asger Christensen (Member of the European Parliament)

1 Jun 2023 · Delegeret L&F

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

31 May 2023 · Resolution on EU action to combat antimicrobial resistance

Danish Agriculture Council Urges Reduced Plastic Reporting Frequency

30 May 2023
Topic — Common EU rules for calculating and reporting recycled content in plastic bottles.
Message — The council requests replacing annual reporting with single reports in 2025 and 2030. They also advocate for mass-balance principles and seek clarification on compliance for bottle components.123
Why — These changes would lower compliance costs and simplify cross-border transport of bottles.45
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Response to Updating the legislation related to the hygiene rules for products of animal origin

22 May 2023

Please find attached feedback from danish Agriculture and Food Council on this proposal.
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Danish Agriculture Council urges flexible biogas and biodiversity rules

3 May 2023
Topic — This initiative defines which economic activities qualify as environmentally sustainable for investment.
Message — The council requests a specific category for biogas production regardless of how the fuel is used. They also advocate for less complex rules for biodiversity projects to prevent smaller efforts from being excluded.123
Why — These changes would reduce administrative burdens and increase funding opportunities for farmers.4
Impact — Environmentalists lose the rigorous scientific oversight and auditing required for conservation activities.56
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Meeting with Christel Schaldemose (Member of the European Parliament)

26 Apr 2023 · Green claims, emballage, NGT, Nature Restauration Targets, Sustainable Use of Pesticides, soil, framework for sustainable food systems.

Danish food producers urge stronger EU-wide packaging harmonization

20 Apr 2023
Topic — The European Commission is revising rules on packaging design, recycling, and waste reduction.
Message — The group demands uniform EU rules to stop national labeling requirements from blocking exports. They also urge removing mandatory reuse targets for food packaging to prevent hygiene risks and food waste. Finally, they propose stopping high-quality food plastic from being used in non-food items.123
Why — Harmonized rules would reduce export barriers and protect the quality of food products.45
Impact — Environmental groups lose if the reduction of plastic waste through reuse targets is abandoned.6
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Meeting with Erik Poulsen (Member of the European Parliament)

29 Mar 2023 · PPWR

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

20 Mar 2023 · Sustainable finance, Taxonomy

Meeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski), Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski) and

14 Dec 2022 · GMOs and NGTs

Response to European Critical Raw Materials Act

25 Nov 2022

The Danish Agriculture and Food Council welcomes this initiative from the Commission. It is important to point out that much more should be done to secure and reuse the valuable resource in organic waste and in biomass in general. We support the ECN's considerations and proposals for this consultation, which were submitted on 10 October. With regard to CRM and organic waste, the focus will be on the recycling of phosphorus. The main source of phosphorus in fertilizers is phosphate rock, which has been on the CRM list since 2014. The EU's need to import phosphate rock and derived products could be significantly reduced if resources, including phosphorus, in organic waste and biomass were more available for recycling. One of the central conditions that determines the availability of organic waste and biomass for recycling is that the recycling to the soil-plant system must not pose a threat to human and animal health or the environment. It is therefore of crucial importance that waste water and other biowaste and biomasses are "clean", e.g. is kept free of harmful substances in quantities that can be harmful to human and animal health or to the environment. The focus should be on the input side to avoid the need to implement expensive and complicated end-of-pipe solutions. But at the same time, it is important to be aware of possible legislative obstacles, which can inadvertently lead to excessively restrictive regulation of biomass recycling and lead to less efficient recycling. It is therefore very important that a regulation on CRM is in accordance with existing legislation, where the directive on the treatment of urban waste water, the sewage sludge directive, the by-product regulation and the fertilizer regulation are central parts of the regulatory framework. (This answer has been submitted in collaboration with Genanvend Biomasse,TR number 160724647389-94)
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Meeting with Janusz Wojciechowski (Commissioner)

9 Nov 2022 · To discuss and hear about the implementation of Complementary Redistributive income Support for Sustainability in Denmark.

Danish Agriculture Council urges removal of fertilizer packaging limits

21 Oct 2022
Topic — Rules for placing certain fertilizers containing animal by-products on the market without official controls.
Message — DAFC supports recycling nutrients but opposes the 50kg package size and 50% volume limits. They argue these rules create unnecessary regulatory obstacles for professional farming operations.12
Why — This would lower transport costs and reduce the environmental impact of plastic packaging.34
Impact — Regulators might struggle to prevent animal by-products from being illegally reused as animal feed.5
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

22 Sept 2022 · Discussion on carbon removals

Response to Use of veterinary medicinal products for diseases in terrestrial animals

1 Sept 2022

DAFC are concerned to see that the regulation and annex (concerning FMD en CSF) aren't clear about the possibilities for the movements of vaccinated and unvaccinated pigs to other destinations than the slaughterhouse, especially in the first 30 days after completion of the protective vaccination (until the completion of the surveillance). This is highly important for for example weaned piglets and weaners from ca. 10 weeks of age that will be housed at a different location than the sow farm (they will move to a finisher farm). If they can't be moved within or outside the vaccination zone, this could have a huge impact on animal welfare if there is not enough housing capacity at the sow farm. We call for the Commission to specify how piglets and weaners can be moved to avoid animal welfare situations where housing capasity is limited. According to Annex VII (FMD), Part 3, Article 3.3 c, a derogation for the movement of non-vaccinated calves, offspring to vaccinated cows is possible, so it seems reasonable to think that a derogation for pigs should be possible as well. It is also unclear to us how eggs , day-old chicken, hatching eggs and hens for slaughter can be handled in the case of emergency protective vaccine against HPAI. It is important that they can be moved before the 21 days and we also fin the testing regime very restrictive and comprehensive, and encorourage the Commission to look into opportunities for a lighter version of the test regime.
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Danish Farmers Warn Nature Rules Threaten Food Security

18 Aug 2022
Topic — The consultation concerns a proposed regulation for legally binding nature restoration targets in Europe.
Message — The DAFC requests a thorough analysis of economic impacts before adopting the regulation. They advocate for voluntary participation and full financial compensation for private landowners.12
Why — Full compensation and voluntary measures would protect farmers from the financial costs of restoration.3
Impact — Biodiversity recovery may be hindered if restoration relies entirely on voluntary landowner participation.4
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Meeting with Janusz Wojciechowski (Commissioner) and

23 Jun 2022 · Lifting of all tariffs and quotas for poultry meat imports from Ukraine

Danish Agriculture Council backs EU human-only antimicrobial list

12 May 2022
Topic — EU regulation designating certain antimicrobials reserved exclusively for human medical treatment.
Message — The organization supports the list of antimicrobials reserved for humans but requests clearer definitions of which substances are included. They want explicit clarification that macrocytes does not include macrolides to avoid misunderstanding.12
Why — Clearer definitions would help them understand which veterinary medicines remain available for livestock.3
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Meeting with Margrete Auken (Member of the European Parliament)

10 May 2022 · EU climate policy

Response to Carbon Removal Certification

6 Apr 2022

Feedback to EU-Commission regarding certification of carbon removals The Danish Agriculture and Food Council (DAFC) welcomes the possibility to contribute to the hearing on certification of carbon removals. The DAFC acknowledges that carbon removals cannot replace emission reductions but is an additional tool that can be used to reduce (biological) emissions in the agricultural sector. A common certification of carbon removals is necessary to enable this potential. 1. Carbon market for carbon crediting schemes The DAFC supports the Commission’s pledge to develop a market-based system for carbon crediting schemes, and focus must be on a harmonized common EU-system. It is necessary to develop and monitor, how different carbon-schemes can be applied in the agricultural sector, and the DAFC supports the development of measurement, monitoring, reporting and verification tools at EU-level. 2. Common certification on carbon removals The DAFC supports the Commission’s proposal, in terms of applying both natural ecosystems and industrial solutions to help remove carbon from the atmosphere. In order to develop an EU-market for carbon removals, there must be a common EU-regulation in place. Currently, there is no international regulated market for carbon removals, instead there are voluntary carbon schemes, that all apply a wide variety of approaches to quantify climate-benefits. A common certification of carbon removals must be able to function both on a regulated market, as well as on the voluntary market. The DAFC focuses on developing carbon certification schemes, that are scientific reliable and trustworthy both for carbon removals from nature-based solutions as well as from technological solutions. This will also provide financial incentives that will lead to additional removals in the EU – both on the voluntary market and a new regulated European market. 3. Develop existing technologies The DAFC furthermore recommends that existing carbon-removals measures must be tested on a large scale. Existing technology such as BECCS (bioenergy carbon capture, utilization, and storage) contains unique climate potential but needs to be upscaled and commercialized, and focus must be on creating financial incentives to upscale existing technologies within the area of carbon crediting. Existing technologies such as the creation of biochar through pyrolysis has the possibility of reducing emissions in the agricultural sector with nearly 50 %. Technology neutrality must be a focus area, and the financial support should go towards various technologies, whilst also facilitating the establishment of exchange of experience within this area among the different member states. 4. Climate neutrality goal for 2035 in a combined LULUCF-sector The DAFC takes note of the Commission’s goal of achieving climate-neutrality in the combined LULUCF and agricultural sector by 2035 and generate negative emissions in the years thereafter. It is an ambitious goal that requires that the interpretation and understanding of the goal needs to be clarified in relation to carbon crediting schemes, specifically the carbon farming initiatives are of importance to the DAFC. The DAFC calls on the Commissions to ensure that there is reliable data for measuring and accounting uptake and emissions in the LULUCF-sector. Currently, it is difficult to be certain about the extent of emissions in the sector, but to ensure stability in the sector the way of measuring the uptakes/emissions must not change drastically over the coming period. Currently, the agricultural sector does not have the tools at their disposal to reach the ambitious goal in the relative short time frame, and the DAFC calls on the Commission to ensure that the transition in the sector to be as cost-minimizing and as fair as possible among the European-member states.
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Danish Agriculture urges science-based AMR strategy over consumption targets

17 Mar 2022
Topic — EU proposal for strengthened coordinated action against antimicrobial resistance across member states.
Message — The organization requests replacing reduction targets based on consumption with AMR action plans focused on high-impact interventions. They advocate for knowledge transfer from low-use countries and increased research on disease prevention and antibiotic alternatives.123
Why — This would let them avoid uniform reduction targets despite already having low antimicrobial usage.45
Impact — Public health advocates lose clearer accountability through measurable consumption-based reduction targets.6
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Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager), Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager)

17 Mar 2022 · Pillar Two Directive / taxation of cooperatives.

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

9 Mar 2022

Danish Agriculture & Food Council on Call for Evidence – “Soil health – protecting, sustainably managing and restoring EU soils” The present initiative includes ambitious targets and initiatives to preserve and improve soil health. It concerns soils in poor health due to • Physical conditions • Chemical conditions • Biological conditions However, there is a number of shortcomings in terms of definitions and argumentation for a need for specific soil regulation, as most of the initiatives are already covered by other EU regulation. For these reasons, the DAFC finds the new soil initiative, overall, superfluous. A. Political context, problem definition and subsidiarity check The subsidiarity principle must be fulfilled It is stated that an EU intervention is justified due to “the significant transboundary drivers and impacts of soil degradation”. However, soil degradation for a large part is not transboundary. Pollution may move via air and water, but this is addressed in other EU regulation. Food safety Food safety is mentioned as a major EU problem. This is not argued for, and food safety matters are addressed in other EU regulation. Migration There is absolutely reason to believe that land degradation and climate change will lead to migrant pressure on EU borders, as mentioned. However, EU soil regulation will not change this, as the soil changes causing migration are happening outside of the EU. B. Objectives and Policy Options Lack of definitions It cannot be stressed enough, that definitions are essential – and completely lacking in this document. “Soil health” may refer to a large array of characteristics, including fertility, content of pollutants and soil structure. Depending on the use of the soil, each characteristic may be more or less important, and what is optimal will vary widely. Nutrient loss It is suggested to reduce nutrient losses “by at least 50%”, “resulting in the reduction of fertiliser use by at least 20%”. Without a baseline, the numbers have, however, no meaning. In Denmark, a vast array of measures to reduce nutrient loss are being implemented, and have been for decades, under the Water Framework and Nitrate Directives. Reducing fertilizer use by 20 pct. compared to today would cause severe malnutrition in crops. Setting fixed goals for all countries without taking into account the current situation and previous actions taken is meaningless. Overlap with existing regulation Generally, there is a huge overlap between the issue of soil health and other types of existing EU-regulation, including the Common Agricultural Policy, which includes a lot of measures and requirements directed towards soil health both in the new enhanced conditionality and in specific schemes in the member states. It is extremely important that a new parallel regulation is not developed as this will both increase complexity and decrease the opportunities to give farmers positive incentives to improve soil health in the CAP. Generally the principle should be to reward farmers for initiatives towards soil health rather than introducing new regulation. This can be done both via EU-funding and with national funds. Private landowners The initiative lacks a position on matters concerning private landowners. If new regulation is to be implemented, a number of basic principles must be followed: • Caring for or restoring soil health should not penalize private landowners • Scientific knowledge must be attained regarding the effects of initiatives and the need for actual management • Actions for soil health must be voluntary, and relevant stakeholders, including landowners, must be involved from early stages • Objectives and implementation instruments must be proportionate, and sufficient funds must be allocated for the management • Positive incentives, such as adequate compensation, must be provided to private landowners.
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Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius)

25 Feb 2022 · To exchange views on the planned Nature Restoration Law (NRL)

Meeting with Asger Christensen (Member of the European Parliament)

31 Jan 2022 · Større Jordbrugs Vinterseminar

Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager)

2 Dec 2021 · Carbon farming and carbon removal certification

Response to Revision of the Energy Tax Directive

18 Nov 2021

Generelle bemærkninger Landbrug & Fødevarer (Danish Agriculture & Food Council) er enige i behovet for at opdatere energibeskatningsdirektivet. De nuværende satser i direktivet er ikke balanceret efter energi- eller CO2-indhold, ligesom direktivet i nogle tilfælde rammer VE hårdere end fossile brændsler. Det bidrager ikke til den grønne omstilling. Landbrug & Fødevarer håber, at et justeret direktiv kan sikre en mere ensartet beskatning mellem Danmark og de øvrige EU-medlemslande. Det er ikke hensigtsmæssigt for det indre marked, hvis et eller flere medlemslande vælger et markant højere afgiftsniveau end de øvrige medlemslande. Landbrug & Fødevarer er derfor bekymret for dansk erhvervslivs konkurrenceevne i forhold til 3. lande, men også i forhold til øvrige EU-lande, hvis Danmark vælger et væsentligt højere afgiftsniveau end de øvrige EU-lande. Afgift på motorbrændstof, der anvendes til landbrug mv. Det er vigtigt for Landbrug & Fødevarer, at muligheden for en lavere sats til motorbrændstof, der anvendes til landbrug mv., fastholdes. Landbruget og fødevareerhvervet er et konkurrenceudsat erhverv, og en høj afgift kan betyde, at produktionen flytter til udlandet til skade for vækst og arbejdspladser i Danmark og klimaet. Blandinger af produkter med forskellige afgiftssatser Det er væsentligt, at blandinger af produkter, hvor afgiftssatserne varierer, beskattes forholdsmæssigt. Det gælder fx blandinger af fossile og VE-brændsler. Landbrug & Fødevarer finder det derfor positivt, at direktivet lægger op til, at blandinger beskattes forholdsmæssigt. Det vil give et incitament til at anvende flere VE-brændsler. Afgift på visse former for biomasse Det fremgår af forslaget, at træflis og trækul mv. er omfattet af afgift, hvis det anvendes i anlæg med en samlet nominel indfyret termisk effekt på 5 MW eller derover. Der er administrative udfordringer med at opgøre afgiftsgrundlaget for biomasse. Det vil være særlig problematisk, hvis mindre anlæg også blev omfattet af direktivet. Der er en del mindre anlæg i landdistrikterne, hvor mulighederne for at anvende andre former for varme, som fjernvarme, er begrænset. Kommissionens forslag om at omfatte visse former for biomasse bør derfor også tage højde for de administrative udfordringer og balancen mellem land og by. Ikrafttrædelse Landbrug & Fødevarer finder, at ikrafttrædelsestidspunktet bør udskydes fra 2023 til 2025 for at give virksomhederne god tid til at omstille sig. Selvom Kommissionen foreslår en indfasningsperiode på 10 år for nogle brændsler, så vil dele af Kommissionens forslag få betydelige konsekvenser for erhvervslivet allerede i 2023. Erhvervslivet bør have mulighed for at tilpasse sig, og det kan være vanskeligt, hvis der er kort tid fra vedtagelse til ikrafttrædelse.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

7 Nov 2021

The Danish Agriculture and Food council (DAFC) appreciate the opportunity to provide feedback to the proposal for a Revision of the Burden Sharing Regulation. The DAFC have the following comments to the proposal. The DAFC note that with the Commission’s proposed revision of the Effort Sharing Regulation, agriculture will be the only remaining non-ETS sector left in 2030. The current architecture of the ESR remains unaltered with the new proposal, and the Commission maintains that the GDP per capita approach is a valid approach to distribute efforts in a fair way reflecting different economic capacities of EU Member States. The DAFC believes that it must be of high priority to ensure a fair distribution of efforts across the EU. The effort sharing should take into consideration the countries that have already ensured a high level of reductions and are left with relatively higher reduction costs. Currently, Denmark’s ESR 2030-reduction target is 39 pct. whereas other countries must reduce by 0 percent. With the new fit for 55 proposal the current architecture of the EU effort sharing policy - however - remains unaltered. For that reason, the DAFC is concerned that part of the Danish agricultural production will relocate to other countries within or outside the EU, with lower reduction targets. In such case, the EU’s total costs of climate action would increase due to the absence of a common EU reduction target for agriculture. The DAFC believes that the effort sharing should instead focus on cost-effective reductions instead of being based on GDP per capita. An effort sharing based on cost-effective reductions will ensure more reductions for less money. The Member State specific reduction target should therefore reflect each country’s potential for achieving cost-effective reductions, and the current 40 percentage point difference in the new proposal between the countries with the highest and lowest domestic ESR target must be significantly reduced to avoid intra-EU carbon leakage. The DAFC furthermore notes that the member state specific reduction targets are increased, and therefore, the flexibility options should be increased simultaneously. The DAFC supports the proposal in the impact assessment to increase the flexibility of LULUCF credits towards both the ETS and ESR. Furthermore, the DAFC recommends that the Member States should be given the flexibility to buy and sell credits generated in the LULUCF-sector towards 2030, and thereby increasing the cost efficiency of reaching the overall EU emission target and preparing for an EU market-driven certification system for carbon uptake in the new extended LULUCF sector after 2030. Finally, the DAFC stresses that the agricultural sector is a major contributor to the national economy in some member states. In Denmark, a disproportionate high reduction target (in relation to other EU member states) will have an enormous impact on the agricultural sector and thus on the Danish national economy. In other EU Member States, the role of the agricultural sector is less dominant. Therefore, the member state specific reduction targets should also reflect the role of the agricultural sector in each country with a specific focus on consequences for the national economy.
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Response to Land use, land use change and forestry – review of EU rules

26 Oct 2021

The DAFC support the strong focus on carbon removals as part of the EU’s enhanced climate ambition since it constitutes an important step towards the climate target for 2030 and 2050. With the revision of the LULUCF regulation the Commission proposes to incentivize carbon removals through certification of carbon removals in the period until 2030. DAFC, however, notes that the system should be market based in accordance with the call in the European Climate Law. In the draft proposal from the Commission, the emphasis is on direct incentives. This is, according to the DAFC, an unsuitable approach, and therefore, market-based models should be prioritized. In this context the DAFC would encourage the Commission to swiftly examine and put forward market-based proposals for certification of carbon removals. Furthermore, DAFC recommend mobilizing private funding to accelerate the market for carbon removals. Common climate pillar: In general, DAFC supports the examination of a combined agricultural sector and LULUCF sector. A common climate policy pillar with a joint reduction target across EU will enhance competitiveness and growth opportunities within the EU agricultural sector. Additionally, merging the agricultural sector with the LULUCF sector will strengthen incentives to complying with reduction targets using carbon farming and CO2 removals. Climate neutrality objective: DAFC takes note of the Commission objective to achieve climate neutrality in the Union-wide greenhouse gas emissions and removals in the combined sectors in 2035 at the latest and reducing emissions to net zero by that date and generating negative emissions thereafter. It should be clarified in the text, that the agricultural sector should, according to the impact assessment option 3, contribute with a 20% reduction by 2035. Consequently, the climate neutrality goal should mainly be fulfilled through removals in the other LULUCF sectors. Flexibility mechanisms: The DAFC recommends that a common EU market-driven certification system for carbon uptake should be established to secure cost-efficient carbon sequestration within the combined LULUCF-sector after 2030. The certification system should be based on the principles of transparency and a common mandatory reporting system based on a tier 3 reporting or similar systems. To this end the Commission should issue guidelines on reporting systems which will enable a more harmonized and comprehensive reporting across EU Member States.
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Response to Restoring sustainable carbon cycles

6 Oct 2021

The DAFC finds that carbon farming must be recognized as an important tool to reduce agricultural GHG emissions through land use and farm practices that can sequester carbon in natural sinks. Carbon farming is an important part of the effort towards reaching the climate target for 2030 and the net zero target for 2050. The Commission is pointing out that reaching the net-zero greenhouse gasses emissions by 2050 and generating negative emissions thereafter requires drastic emissions reductions in the EU economy. Capturing CO2 from the atmosphere and storing it in terrestrial and marine eco-systems, geological reservoirs or products will be of great importance. To close the gap to climate neutrality both nature-based, and technological solutions should contribute to remove several hundred million tonnes of CO2 per year from the atmosphere. The proposal for a revised LULUCF regulation sets out an objective of a climate-neutral land sector by 2035, and it is stressed that it will be necessary to create a system of incentives to realise the potential of carbon farming. The DAFC support the Commission’s intention to create a system of incentives to realise the potential of carbon farming. The DAFC reiterates the call in the EU Climate Law, where it was reflected that carbon sinks play an essential role in the transition to climate neutrality in the Union, and in particular the agriculture, forestry and land use sectors. The Commission should explore options for the development of a carbon market for market-based carbon crediting schemes and should establish market-based financial incentives for farmers and foresters. These incentives must be established outside the umbrella CAP. Furthermore, the Commission should consider mobilizing private funding to accelerate the market for carbon removals. To develop a market-based system for carbon crediting schemes, a strong, common, and harmonized EU-system for measurement and verification of the carbon absorption and storage potential of agricultural soils and biomass must be established. Therefore, the DAFC welcome the Commission’s intention to launch the EU carbon farming initiative which will provide a conceptual framework for different types of carbon farming and an additional proposal for a regulatory framework for the certification of carbon removals. There is a need for better data on techniques for storing and removing carbon and consequently, the Commission should prioritize technology development within this field. The DAFC recommends that existing technologies must be tested in large scale. An existing technology like BECCS contains a unique climate potential but needs to be upscaled and commercialized. In Denmark, the creation of biochar through pyrolysis can nearly half the emissions from the Danish agricultural sector. Biochar can also improve the quality of the soils and can serve as fuel for the aviation industry. Politically, it must be a priority to support various technologies with a focus on technology neutrality. A coherent approach must be established to share experiences among EU member states within the field of a technology neutral effort to support technological solutions. The LULUCF sectors cannot compensate entirely for fossil carbon emissions from other sectors. Therefore, the technology for CCS should be developed alongside a regulatory framework for carbon farming. The DAFC take note of the Commission’s objective to achieve climate neutrality in the Union-wide greenhouse gas emissions and removals in the combined sectors by 2035 at the latest and to reduce emissions to net zero by that date and generate negative emissions thereafter. The DAFC finds this goal very ambitious and the interpretation and understanding of this goal must be clarified. The agricultural sector does not have the tools at their disposal to reach such an ambitious goal within a relatively short time frame. Therefore, this target needs to be discussed further.
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Meeting with Asger Christensen (Member of the European Parliament)

23 Sept 2021 · Agriculture policies

Response to Animal welfare labelling for food

24 Aug 2021

Please find attached the feedback from Danish Agriculture and Food Council
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Meeting with Asger Christensen (Member of the European Parliament)

3 May 2021 · Ecology

Response to Agriculture - List of products and substances authorised in organic production

23 Apr 2021

Thank you for the opportunity to comment on these proposals. We see important obstacles in annex II and annex V. Annex II: Authorised fertilisers, soil conditioners and nutrients Nutrient supply is the biggest challenge for organic plant producers in Denmark, since the availability of manure from organic animals is unevenly distributed. The organic regulation and existing interpretations exclude many recycled nutrients which makes it difficult to prioritize true recycled nutrients above conventional manure. Annex II should offer more flexibility to ensure better nutrients supply. We recommends that: Annex II should offer: a. more flexibility to member states to prioritize among different sources of non-organic nutrients. b. flexibility for member states to approve more recycled nutrient. Please find further explanations in the attached document. Annex V: Authorized products and substances for use in the production of processed organic food and yeast used as food or feed We find inconsistencies in this annex regarding the use of calcium chloride. Calcium chloride used as a coagulant in the production of sausages based on meat and products of plant origin is apparently considered to be a technical auxiliary function (processing aid), while the same use in the production of cheese is considered to be an additive and should be labelled as an additive. This is inconsistent and discriminatory against producers of organic cheese. Likewise, it seems inconsistent that the use of calcium chloride in the production of conventional and organic cheese (er lidt I tvivl om flertal her) has different status, even though the function and purpose are exactly the same in the two production methods. Regarding the use of hydrochloric acid for cheeses salted in brine bath, this should not be limited to the production of selected Dutch types of cheese. There is a similar need for adjusting the pH of the brine bath in other types of cheese, and we believe that hydrochloric acid should be allowed for all cheese production where brine is used. Alternatively, it should not be allowed for any types of cheese at all. Best regards Lars Holdensen Chief Policy Advisor Danish Agriculture and Food Council
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Danish Agriculture Council urges EU to avoid trade barriers in antimicrobial rules

19 Apr 2021
Topic — EU regulation designating certain antimicrobials for human use only.
Message — The organization supports the proposed criteria for reserving antimicrobials for human treatment. However, they urge the Commission to ensure the rules do not create unnecessarily restrictive trade measures against imports from third countries.12
Why — This would protect their ability to import food products and animals without facing technical trade barriers.34
Impact — Public health advocates lose stronger controls on antibiotic use in imported animal products.5
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Danish Agriculture urges EU to avoid illegal trade barriers on antibiotic imports

19 Apr 2021
Topic — EU controls on imports to enforce prohibition of certain antimicrobial uses.
Message — The organization requests the European Commission ensure the proposal does not include unnecessarily restrictive trade measures against imports from third countries. They believe the restrictions may conflict with WTO rules and undermine third countries' confidence in the EU.12
Why — This would help them maintain access to imported products and avoid stricter controls.3
Impact — Public health efforts lose stronger controls against antibiotic-resistant products entering the EU.4
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Response to Information and promotion measures for agricultural and food products in the internal market and in non-EU countries

5 Mar 2021

The Danish food industry has a vision to be climate neutral by 2050. In close partnership with our members, we will show, an economic sustainable way to a climate neutral food production. With 189.000 jobs created Denmark and an annual export amounting to around 23 billion euro, we represent a strong Danish food cluster committed to finding solutions to the world's climate challenges. Danish Agriculture & Food Council believe that the Promotion Policy can actively contribute to increasing the sustainability of the food system. However, the following elements need to be taken into account: As stated by the evaluation of the Promotion Policy that has been commissioned by the Commission (SWD(2020) 401 final of 22 December 2020), “Overall, the objectives of the policy and its related activities remain relevant, have clear EU added value and there is no major inconsistency between the EU agricultural promotion policy and other EU policies, including the EU health, climate and environmental and development policies.” We believe that this should be kept in mind when reviewing the policy. Indeed, the contribution of the Promotion Policy can certainly be enhanced, but we need to underline that thanks to the already high sustainability standards of EU products, the Promotion Policy is already contributing to increase sustainability of food production. Furthermore, we would like to insist on the fact that this sustainability objective should never compromise the first and main objective of this policy, which is the competitiveness of EU agricultural products. Regarding the objective to nudge consumption to sustainable choices and healthy diets, we emphasize the fact that no product in it self is neither unsustainable nor unhealthy by definition. The sustainability of a product depends on its production method that can be more or less sustainable, while the healthiness of a food product depends on the way it is consumed and incorporated in an overall diet. Therefore, we strongly underline the fact that no agricultural good should be excluded from the Promotion Policy or benefit from a reduced support. We thus strongly oppose any reduction of support or exclusion of meat and wine. Furthermore, we would like to stress that EU products obtain some of the highest standards when it comes to environmental sustainability and animal welfare. Therefore, if we were to stop the promotion of EU products like wine or meat, consumers would turn to similar non-EU products with considerably lower standards. We would thus indirectly promote less sustainable production. The singling out meat in the Europe Beating the cancer plan is highly unacceptable to us, quote; “with less red and processed meat and other foods linked to cancer risks and more fruit and vegetables”. The evidence of the direct link between cancer and meat is very weak and inconclusive. From a nutritional point of view, meat provides bioavailable proteins and a vast amount of vitamins and minerals, of which some is not obtainable from vegetables or fruit, and is an important nutritional factor for infants and frail people. The WHO also concludes the following (quote); “WHO has underlined that red meat has nutritional value and that it is important to balance the risks and benefits of eating red meat and processed meat. Cancer is a complex disease. There are a multitude of factors that contribute to one’s risk of chronic diseases, including cancer. We believe there is no compelling evidence to suggest that red and processed meat, consumed as part of a balanced diet, increases the risk of cancer. No single food has been proven to cause or cure any type of cancer.” The only valid and everlasting dietary guideline to promote health in any population, is to eat a varied and balanced diet, and no more calories than the body can use, as ALL foods both challenges our health with potential toxins and provide us important nutrients to maintain healthy lives.
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Response to Commission Decision determining the benchmarks values for free allocation in the period 2021-2025

22 Dec 2020

Please find attached the opinion of the Danish Agriculture & Food Council
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

The Danish Agriculture and Food Council (DAFC) are grateful for the opportunity to comment on the delegated act on EU taxonomy. This is a very important topic and the future agricultural production will be highly influenced by financial regulation, including sustainable finance. The DAFC welcomes the overall purpose of sustainable finance, however the proposed regulation does not meet this purpose. The DAFC finds that sustainable finance could be an important tool in ensuring the implementation of, simple methods to minimize the impact of agricultural production, not only on climate but also on nature and the environment. The essence of sustainable finance regulation should be on reducing GHG emission and not on using management practices that are inflexible and carved in stone. It is important to realize that lists of initiatives, such as the lists in the appendixes, will never be fully complete. New techniques are developed continuously, and it is pivotal that the list can be amended, and new techniques / initiatives can be added. The focus of sustainable finance should be on developing a valid method to measure/estimate GHG emissions per output unit and not applying management practices that are, at best, questionable. It is also important to note that this list is not a one-size-fits-all. Which initiatives are the optimal choice depends on geographical and climatic conditions, cultivation practice, etc. It is therefore essential that all initiatives on agricultural land are voluntary and based on choice to ensure that the individual farmer can decide what is optimal on his/her land and in his/her business. Thus, good management practice should be ensured through highly qualified consultancy services and intelligent legislation, providing flexibility for the farmer, rather than rigid schedules and control. This is essential for the optimal implementation of the various measures. The DAFC finds that the recommendations that are included into the delegated act derive from the work of the TEG which lacked technical and legislative knowledge of the agriculture and forestry sector. We also regret the same level of lack of representatives is in the newly created advisory board, the Platform for Sustainable Finance. The Regulation 2020/852 clearly states that when developing the technical screening criteria, it is of particular importance that the Commission carry out appropriate consultations in line with the Better Regulation Agenda and that the process for the establishment and update of the technical screening criteria should involve “relevant stakeholders” and should build on the advice of experts who have proven knowledge and experience in the “relevant areas”. The four weeks period for consultation on such complex file is unacceptable. Sustainable economic activities are already defined in sectorial regulations and must not be redefined for sustainable investment purposes. The technical screening criteria must be in line and compatible with existing measures in the CAP. The DAFC has some specific concerns regarding the use of management practices, especially concerning the use of conservation agriculture, the use of baselines and green washing effects in the regulation, this is further specified in the attaced file. An example is that the use of conservation agriculture in organic farming cannot be performed in a large scale in Denmark. The overall target for this regulation should be to develop a method for measuring GHG emissions per produced output unit and not on determining rigid and in some cases non-operational management practices. Regarding manufacturing and energy the proposed regulation have a negative impact on the green transition. Regarding construction and real estate activities the proposed regulation will punish the frontrunners and have a negative impact on the market based development of sustainable finance. The DAFC is, of course, available for further dialogue in this matter.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

The Danish Agriculture & Food council (DAFC) welcomes the Commission’s effort on climate action and supports the joint work on the 2030-climate target as well as the objective of climate neutrality in 2050. DAFC urges the Commission to pursue cost-effective CO2-reductions such as reductions within the ETS. Furthermore, the Commission should enhance the work on carbon farming since CO2-removals constitute an important step towards the climate target for 2030 and 2050. DAFC recommends mobilizing private funding to accelerate the market for carbon removals. Scope of the ETS When revising the scope of the ETS, DAFC recommends conducting thorough analyses of consequences for each member state. Also, consequences for the remaining ESR-sector, agriculture, must be known if transportation and the building sector are included in the ETS. If transportation and the building sector are included in the ETS leaving the agricultural sector as the only sector within the ESR, the ESR-reduction target must be lowered relatively. In this case, the flexibility mechanisms must be increased between the ETS, ESR and LULUCF since the agricultural sector faces unique challenges in reducing emissions from biological processes. In general, DAFC supports the examination of a combined agricultural sector and LULUCF sector (LULUCF sub option 2.3 in the Impact Assessment). A common climate policy pillar with a joint reduction target across the EU will enhance competitiveness and growth opportunities within the EU agricultural sector. Additionally, merging the agricultural sector with the LULUCF sector will strengthen incentives to complying with reduction targets using carbon farming and CO2 removals. However, it must be of high priority, if a new climate policy pillar is established, to conduct a separate public consultation on the regulation of this new pillar. Particularly it must be thoroughly discussed whether the climate policy pillar should contain the total LULUCF sector or exclusively parts of the LULUCF sector relevant to agriculture. Regardless the scope of the ETS, the flexibility mechanisms should be increased. Especially considering the current COVID-19-crisis. If a new common climate policy pillar is established, it should be elaborated how flexibility mechanisms can work between the ETS and the climate policy pillar. Effort sharing across EU In general, it must be of high priority to ensure a fair share of efforts across the EU. The effort sharing should take into consideration the countries that have already ensured a high level of reductions and are left with relatively higher reduction costs. Currently, Denmark’s ESR 2030-reduction target is 39 percent whereas other countries must reduce by 0 percent. If the current architecture of the EU climate policy remains unaltered, the DAFC is concerned that part of our agricultural production will move to other member states, or even outside the EU, with lower or non-reduction targets. In such case, the EU’s total costs of climate action would increase due to the absence of a common EU reduction target for agriculture. A common climate policy pillar for all member state countries with a joint reduction target will accommodate this issue ensuring a fair share of contributions and most importantly a joint effort on climate action. Instead of basing the effort sharing on GDP per capita, the effort sharing should focus on cost-effective reductions. An effort sharing based on cost-effective reductions will ensure more reductions for less money. If maintaining the ESR, the member state specific reduction target should reflect each country’s potential for achieving cost-effective reductions. If the member state specific reduction targets are increased, the flexibility options should be increased simultaneously. In particular, DAFC supports the proposal in the Impact Assessment to increase the flexibility of LULUCF credits towards both the ETS and ESR. In the revision of the ESR, it must be cons
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

The Danish Agriculture & Food council (DAFC) welcomes the Commission’s effort on climate action and supports the joint work on the 2030-climate target as well as the objective of climate neutrality in 2050. DAFC urges the Commission to pursue cost-effective CO2-reductions such as reductions within the emission trading system. Furthermore, the Commission should enhance the work on carbon farming since CO2-removals constitute an important step towards the climate target for 2030 and 2050. DAFC recommends mobilizing private funding to accelerate the market for carbon removals. As an example, In Denmark, a newly established “Climate-forrest foundation” aims at attracting private funding for increasing emission storage in soils and forests. Common climate policy pillar In general, DAFC supports the examination of a combined agricultural sector and LULUCF sector (LULUCF sub option 2.3 in the Impact Assessment). A common climate policy pillar with a joint reduction target across EU will enhance competitiveness and growth opportunities within the EU agricultural sector. Additionally, merging the agricultural sector with the LULUCF sector will strengthen incentives to complying with reduction targets using carbon farming and CO2 removals. However, it must be of high priority, if a new climate policy pillar is established, to conduct a separate public consultation on the regulation of this new pillar. Particularly it must be thoroughly discussed whether the climate policy pillar should contain the total LULUCF sector or exclusively parts of the LULUCF sector relevant to agriculture. If a new common climate policy pillar is established, it should be elaborated how flexibility mechanisms can work between the ETS and the climate policy pillar. Finally, DAFC recommends ensuring synergies and coordination between various climate related legislation in the EU. For example, the Common Agricultural Policy (CAP) and the Farm to Fork strategy contain elements on climate action as well which is why the interaction between the LULUCF regulation, the CAP, and the Farm to Form strategy must be considered.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Updating the Emission Trading System Opinion of the Danish Agriculture & Food Council The Danish Agriculture & Food council (DAFC) welcomes the Commission’s effort on climate action and supports the joint work on the 2030-climate target as well as the objective of climate neutrality in 2050. DAFC urges the Commission to pursue cost-effective CO2-reductions such as reductions within the ETS. Furthermore, the Commission should enhance the work on carbon farming since CO2-removals constitute an important step towards the climate target for 2030 and 2050. DAFC recommends mobilizing private funding to accelerate the market for carbon removals. Scope of the ETS When revising the scope of the ETS, DAFC recommends conducting thorough analyses of consequences for each member state. Also, consequences for the remaining ESR-sector, agriculture, must be known if transportation and the building sector are included in the ETS. If transportation and the building sector are included in the ETS leaving the agricultural sector as the only sector within the ESR, the ESR-reduction target must be lowered relatively. In this case, the flexibility mechanisms must be increased between the ETS, ESR and LULUCF since the agricultural sector faces unique challenges in reducing emissions from biological processes. In general, DAFC supports the examination of a combined agricultural sector and LULUCF sector (LULUCF sub option 2.3 in the Impact Assessment). A common climate policy pillar with a joint reduction target across the EU will enhance competitiveness and growth opportunities within the EU agricultural sector. Additionally, merging the agricultural sector with the LULUCF sector will strengthen incentives to complying with reduction targets using carbon farming and CO2 removals. However, it must be of high priority, if a new climate policy pillar is established, to conduct a separate public consultation on the regulation of this new pillar. Particularly it must be thoroughly discussed whether the climate policy pillar should contain the total LULUCF sector or exclusively parts of the LULUCF sector relevant to agriculture. Regardless of the ETS scope, the flexibility mechanisms should be increased. Especially considering the current COVID-19-crisis. If a new common climate policy pillar is established, it should be elaborated how flexibility mechanisms can work between the ETS and the climate policy pillar. Free allowances If including transportation and the building sector in the ETS, it is crucial to raise the amount of free allowances simultaneously. The carbon leakage list, including the free allowances, were revised in 2018, where several companies were removed from the carbon leakage list. It is important to consolidate the carbon leakage list as it is with the companies currently appearing on the list. Also, the sectors eligible for 30 percent free allowances until 2026 must keep this right. The Impact Assessment touches upon the option of lowering the linear reduction factor (LRF) or increasing the market stability reserve (MSR) in order to comply with the climate targets. DACF strongly urges the Commission to maintain the share of free allowances at the current level of 43 percent with a buffer of 3 percent regardless future changes to the LRF or MSR. It is important to maintain the possibility of a qualitative assessment of the risk of carbon leakage for the specific sectors. Following the revision of the carbon leakage list in 2018, several companies still struggle with open cases concerning allocation of free allowances. DAFC recommends that the Commission appeals to the member states to finish open cases before adopting new legislation regarding the ETS. Administrating the ETS From the companies’ perspective, the administration of the ETS is extremely bureaucratic. It is an enormous challenge for the companies to meet ETS requirements in terms of data on energy consumption for instance. Especially small companies face th
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Response to Model official certificates for certain categories of terrestrial animals and germinal products thereof

2 Nov 2020

DAFC have following comments regarding CHAPTER 1: MODEL OFFICIAL CERTIFICATE FOR THE MOVEMENT BETWEEN MEMBER STATES OF BOVINE ANIMALS NOT INTENDED FOR SLAUGHTER (MODEL ‘BOV-INTRA-X’) Regarding point I.20 Certified as or for (present point. I.25) a. Today the option Breeding is used for breeding animals. Can the Commission confirm whether breeding animals in the new model should be changed to Further keeping? and if the breeding animals are to be in Quarantine is that changed to Quarantine or similar establishment in the new model? As many different set-up of Quarantines are used it is important that it is clarified in which cased the option "Quarantine or similar establishment" are to be used, to prevent any mistakes in the filling out of TRACES data. Regardint point I.22 For transit through Member State(s). This is an option not currently existing in TRACES today. Will that be incoporated in TRACES in the future or how to deal with this? If we are to add transfer countries, what will then happen if the route is changed due to unforseen trafic problems. Should the informations in TRACES then be changed upon arrival? Regarding Point I.30 Description of consignment (present. I.31) a. Is this point only meant for boars to Insemination stations as is the situation today or does the point cover other cases? we have not been able to find an answer in Article 52 or 54(2) of Delegated Regulation (EU) 2019/2035. I hope the Commission can find the time to answer our questions regarding the new model.
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Response to Industrial pollution - revision of the European Pollutant Release and Transfer Register

26 Oct 2020

I dag indberettes der data på en lang række områder, både nationalt og på EU-plan, fx ifm. NEC, EUROSTAT, klimadata mv. Et væsentligt element i evalueringen bør derfor tage højde for, at en lang række af de efterspurgte data kan finde i mere eller mindre detaljeret grad i andre registre. For at undgå dobbeltrapportering bør det undersøges, hvordan disse data kan supplere og erstatte indberetningskrav til E-PRTR. Der bør være fokus på at sikre, at indberetninger så vidt muligt sker via indberetninger fra de enkelte medlemsstater, og at man i så begrænset omfang som muligt begynder at stille krav om individuelle indberetninger. Det bør således undersøges, om der kan indføres en mulighed for at lade myndighederne i de enkelte medlemslande indberette på vegne af de enkelte virksomheder, for at undgå unødige administrative byrder. Det bør i evalueringen være langt større fokus på at vurdere, hvilke data der er nice-to-have og hvilke data der er need-to-have. Indberetningskrav bør således være ledsaget af en konkret vurdering af, hvorfor disse data er nødvendige, og også, om nødvendigheden af detaljeringsgraden af disse oplysninger. Diffuse kilder bør i langt højere grad rapporteres samlet fra staten fremfor på individuelt niveau. Der savnes en langt højere fokus på at sikre og minimere administrative byrder i forbindelse med E-PRTR systemet og indberetningskravene. Evalueringen bør således udvides med en konkret vurdering af de administrative byrder, herunder hvordan de kan reduceres, fx via en mere aggregeret indberetning fra myndighedsniveau.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

Kommentarer til public consultation om Legislative proposal on substantiating green claims: Landbrug & Fødevarer (Danish Agriculture and Food Council) takker Kommissionen for at inddrage offentligheden og relevante stakeholderes i udviklingen af et framework for green claims. Vi repræsenterer hele den danske fødevareklynge fra jord til bord og arbejder aktivt med at udvikle sektoren i en mere bæredygtig retning. Det danske fødevareerhverv har bl.a. en vision om at være klimaneutralt i 2050. Vi har gennem flere år fulgt PEF-arbejdet tæt og vores videncenter SEGES har flere projekter, der fagligt skal understøtte arbejdet med PEF, herunder hvordan man kan fremskaffe valide data i hele værdikæden. En vigtig forudsætning er at arbejdet står på et fagligt fælles fundament og at forbrugeren får valideret og anerkendt information. Hvis PEF skal lykkes, er der et stort behov for hurtig, at få mange flere produkter med Helt overordnet mener vi endvidere: • Forbrugeren skal kunne træffe bæredygtige valg på et videnskabelig, men tilgængelig og forståeligt grundlag. • Green claims bør derfor være videnskabeligt funderet og evt. mærkning bør baseres på livcyklusanalyse. Nationale og private ordninger er problematiske og udgangspunktet bør være internationale eller som minimum EU-standarder. EU’s PEF er et godt fundament. • Et evt. mærke skal som minimum være i overensstemmelse med reglerne for det indre marked, ligesom en mærkningsordning ikke må medføre skævvridninger i konkurrencevilkår på tværs af EU. • Der bør indtænkes, hvordan der kan findes en global harmoniseret løsning i forbindelse med green claims. For fødevarer arbejder FAO bl.a. med FAO-LEAP, som der bør koordineres med. • For fødevarer er det vigtigt, at sundheds- og ernæringsparametre indtænkes i arbejdet, ligesom FN’s kriterier for bæredygtig kost bør iagtages. • Det er vigtigt at arbejdet med at lave et EU-fundament for green claims bliver en fælles ramme, der favner alle de underliggende strategier i green deal på tværs af relevante generaldirektorater, så EU ikke udvikler forskellige strategier for forskellige produktgrupper. • Det er meget vigtigt at skabe en incitamentsstruktur, der kan understøtte innovation og udvikling af mere bæredygtige produkter og produktion. Det skal tilgodese first movers. Virksomheder, der målrettet arbejder med at forbedre sine produkter og produktion i en mere bæredygtig retning skal også kunne vise forbrugeren det og få markedsfordele ved det.. • Målet skal være at sammenligne indenfor samme produktgruppe eller hvor der er defineret en PEFCR. • Der er stadig en række udfordringer, som skal løses i forbindelse med den videre udvikling af PEF og særligt hvis PEF skal bruges i forbindelse med forbruger og B2B-kommunikation. Her kan nævnes: • Allokering • Datakvalitet, brug af primære data og kvalitetssikring • Administrative byrder. Det er en meget stor opgave at dokumentere data, og der skal findes en løsning for alle typer virksomheder • Definition af den funktionelle enhed for fødevaregrupper • Hvordan håndteres sammensatte produkter eksempelvis pølser • Emballage • Datakvalitet importerede varer Endelig skal vi takke Kommissionen for at nedsætte en særlig ”agricultural working group”, der kan hjælpe med faglig afklaring for det videre arbejde med PEF indenfor fødevaresektoren. I den forbindelse er det vigtigt, at inkludere de mange måder, hvorpå landbrugs og fødevareproduktionen bidrager til den cirkulære økonomi.
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Response to Sustainable use of pesticides – revision of the EU rules

7 Aug 2020

The Danish Agriculture & Food Council (DAFC) welcomes the roadmap for a revision of the Sustainable Use Directive since the implementation of SUD across EU have been fragmented. We also agree on the overall goal of the directive, namely, to reduce the risks when using pesticides. Farmers has no intention to destroy the very nature he is depending on. On the other hand, pesticides are important tools to combat various pests and will remain so in the next + 20 years. DAFC have some comments on the process and the foreseen outcome as described. In Denmark the SUD has been implemented quite stringent with focus on IPM and reducing the overall risk when using of pesticides e.g. with a high pesticide tax. This have resulted in a low use of pesticides compared to the rather complex plant production that still exists. Also, we have managed to keep a high crop production. When it comes to the evaluation of the effect of SUD, we think that the HRI1 gives some indication of the risk of using pesticides. HRI2 is not relevant, since the number of derogations says nothing about anything. The HRI2 should be ignored. The HRI1 is follows the same pattern as the Danish risk indicator (PBI), which is much more complex to calculate. This indicate that HRI1 might be relevant as a point of departure. But it is pivotal that front runner nations, like Denmark, that has done a lot on reducing the risk of pesticides, does not get punished in using a non-descriptive reference year or other measures. DAFC therefore think that the reference period should be multiple years and go back in time, so front runners are not punished with reduction targets based on single years after reductions already have been made. If the latter becomes the reality, EU will remove all incentives to implement regulations swift in the future. Additionally, the pesticide regulation (1109/2009) will remove some of the most problematic pesticides with time. This will also reduce the HR1, although it can be difficult to separate from lower use. The effect of 1109/2009 on the HR1 should be described scientifically. Secondly, if uniform implementation is the major problem, more focus should be made into enforcement of the regulation. It is mentioned in one sentence, but it remains unclear how and what the EU Commission is thinking about how to increase the enforcement. Directives has by nature a very non-uniform implementation across EU member states. What is the plan? Is it to fasten up implementation and thereby obtaining results? Or is it EU going to tell national states how to implement? DAFC think that education of farmers is one of the most important IPM tools. Modern equipment, like precision farming, will also add on to this, but only if the farmer makes solid informed decisions based on scientific principles. The SUD in its current form will not succeed in producing given specific reduction goals across EU. The text is simply too wake. IPM is also about reducing the need for pesticides. Preventing a problem before it is becoming a pest is more cost effective than various technically solutions. This sounds simple, but it is much more difficult than that. Promoting bio-pesticides is still a strong focus on treatment / cure rather than preventing a pest from arising. In the roadmap should be a solid scientific analysis of the legislative and scientific problems facing if we are to increase the focus on the prevention track, (crop rotation, breeding with modern methods, new crops, non-chemical / biological treatments etc.). Finally, DAFC is of the opinion that all coming analysis and regulations regarding Farm 2 Fork should also include economic business analysis, so the costs are clear to all decision makers. We are looking forward to being part of this very important work.
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Response to EU Methane Strategy

20 Jul 2020

The Danish Agriculture & Food Council has a vision on a climate neutral Danish food industry by 2050. As a consequence, the sector must reduce methane emissions. EU must reduce its methane emissions as well; however, we do agree with the Commission, that it is not possible to eliminate the methane emissions in total. In food production we work with live organisms, which is not possible without emissions. EU should commit themselves on reducing methane emissions, and support measures and innovation that can make it happen. We do not believe that the road to methane emissions should be targeted in the directives on air pollution, e.g. the NEC directive. Instead the methane emissions should be targeted under the climate ambitions of the EU. The methane strategy must consider the differences between the methane emissions in the Member States. In Denmark there are few methane emissions in the waste- and energy sector. This should not lead to a disproportionally large burden in the Danish agricultural sector. It is important to remember, that agricultural emissions of methane are the result of natural microbial processes in anaerobic (oxygen free) environments. They are difficult to both measure and mitigate. Research on agricultural methane emissions is receiving a lot of attention and efforts these years, but progress takes time, and there are still many uncertainties about quantitative effects of mitigation measures and possible side-effects. With regards to enteric methane emissions, it is important to relate emissions to the output of the production – both direct output as meat and milk, but also indirect output as the contribution of livestock to conservation of nature or social stability in rural areas. A sustainable intensive production with high feed efficiency and high production rate, will give low emissions per kg of product, and thereby secure food production with less methane emissions. However, extensive production methods generally have higher emissions per kg of meat or milk, but lower when related to other societal services like biodiversity-level. The sustainable transition should go hand in hand with growth and employment, and consider food security. Sustainability and climate goals should lead to a competition advantage – not reduce production. It is important that the reduction of methane emissions don’t lead to disproportionally large burdens for the agricultural sector. It is a challenge to monitor and verify the greenhouse gasses in the agricultural sector, which can lead to a lack of data, and the data we have, often comes with a high level of uncertainty. We support that the EU and the Member States prioritize collecting data within the sector, as we also support the current project in Denmark on developing climate accounting on a farm level. However, the data collection does not lead to unnecessary bureaucracy or financial burdens for the farmer. With regards to biogasproduction it is extremely important, that all use of biomass respects the waste hierarchy. Feed products should be utilized for food production by livestock and subsequently the manure can be used for biogas. Particularly ruminants have a unique ability to optimize resource use in the circular bioeconomy. It is important, that the evaluation of various mitigation techniques does not focus single-mindedly on methane emissions but takes into account the full impact of side effects, eg. how shifts in feed composition will affect GHG-emissions from the cultivation of the feed. We want to emphasize the need for better uniform and standardized data of all factors related to methane emissions across member states. Particularly the lack of comparable data from livestock production makes it difficult to estimate emissions and thereby also to track efficiency of mitigation measures. A more uniform registration is an essential basis for a strategy, which considers the differences between Member States.
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Response to Fitness Check of the EU legislation on animal welfare

10 Jul 2020

To DG Sante Please find enclosed the comments from Danish Agriculture and Food Council to the evaluation of EU rules
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Response to Climate Law

1 May 2020

Please see the attached file.
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Response to EU rules on industrial emissions - revision

21 Apr 2020

Overall, the roadmap addresses the most important overall issues like circular economy, better BREF process and implementation issues. Below we have listed elements that we think needs to be taken into consideration in the assessment. BREF process In the work on the BREF process we would like to have more focus in innovation. The current approach is too focused on end-of-pipe solutions. More attention ought to be given to prevention and circular economy and a more holistic approach where cross media effects are properly assessed. The previous IPPC directive had more focus on prevention. BAT conclusions In regards to implementation issues it is mentioned that the initiative aims to tackle comparability of Member States’ implementation of EU requirements, including BAT conclusions, into permits and verification. In this regard, it is of upmost importance that this assessment specifically compares the implementation of BAT- AEL limits in permits. In our understanding implementation of the BREF’s is very different between the different member states, and much more focus should be placed on a uniform implementation. In particular, a more uniform implementation with special emphasis on BAT-AEL limit settings is needed. For instance, the data gathering on the FDM BREF showed that waste water emissions in Denmark were lower compared to other countries. Also, the BAT-AEL on dust for feed is much lower than for other sectors with more harmful dust. This will consequentially lead to high investments for some food manufacturers and may therefore lead to competitive disadvantages with other regions. Cost-efficiency and proportionality When looking at implementation issues there is a need to address cost-efficiency and proportionality to ensure that the regulation ensures the highest level of environmental benefits compared to the administrative and economic costs. For instance, the stringent focus on monitoring and reporting is to extensive and does not give proportionate environmental benefits. The directive ought to address environmental issues more holistically, i.e. by focusing more on the production sites and by focusing solely on the most significant emissions, thereby ensuring a better targeting of the resources. In this regard, the trend towards regulation of odor is very problematic as a significant environmental parameter considering that odor does not pose a risk to either the environment or human health. Furthermore, local regulation of odor is more relevant since odor problems also depend on the location of the production site. Too much focus on less important environmental emissions leads to far too many resources spent on unnecessary regulatory issues and documentation work. Focusing more on the most significant emissions will ensure a more significant positive environmental impact. Coherence with other EU-regulation In regards to farms it is very important to avoid double regulation, for instance in regards to farm land regulation (manure fertilizer regulation) and the regulation in the habitat and nitrates directives.
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Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

The Danish Agriculture & Food Council Association (DAFC) is very grateful for the opportunity to comment on the TEG report before the Commission draws the delegated act. Overall the DAFC finds that the TEG report has improved on several parameters compared to the report presented in June 2019. When establishing thresholds, it is very important that national models can be implemented in the sustainable finance framework. An audit every third year seems very cost-inefficient and under Danish conditions not desirable given that Danish mortgages are specified for typically 30 years. When a farm is granted a mortgage of 30 years, it is not desirable to refinance 3 years after an audit, due to the costs of refinancing. We therefore suggest that the audit is adjusted to the length of the mortgage. In the proposed farm sustainability tool it is very important that this is integrated and complies with the CAP measures in order to reduce the workload for the individual farm. The costs of compliance with taxonomy must never exceed the benefits from sustainable finance. This should be market driven, however the risk of carbon leakage to third countries in short and midterm is obvious, if investment costs rises further than the benefits from sustainable finance. It is important to realize that lists of initiatives, such as the lists in the TEG report, will never be fully complete. New techniques are developed continuously, and it is pivotal that the list can be amended and new techniques / initiatives can be added. It is also important to note that this list is not a one-size-fits-all. Which initiatives are the optimal choice depends on geographical and climatic conditions, cultivation practice, etc. It is therefore essential that all initiatives on agricultural land are voluntary and based on choice to ensure that the individual farmer can decide what is optimal on his/her land and in his/her business. Thus, good management practice should be ensured through highly qualified consultancy services and intelligent legislation, providing flexibility for the farmer, rather than rigid schedules and control. This is essential for the optimal implementation of the various measures. An intelligent GHG threshold is pivotal. Farmers that have already reduced emissions from production will find it harder to reduce further, than farmers who have not yet taken any steps to reduce emissions. It is therefore necessary to develop a system that assesses GHG emissions according to a common goal and not to present emissions or to emissions in a recent year. In this way, it can be ensured that first movers are rewarded, not punished. This is also the case for the taxonomy on buildings. On buildings in countries with very strict definitions of the NZEB, it might be near impossible to find a requirement of 20 pct. lower energy demand than in countries with a different implementation of NZEB (EC, 2010). Buildings in Denmark are typically financed with at 30-year mortgage loan on the entire property. In the case of renovation of buildings, the taxonomy implies that only the renovation amount is taxonomy eligible. This is not desirable given the Danish mortgage model. The parting of energy renovation from the rest of the building is not desirable and will increase the cost of the loans and hence making it unfavorable to make energy renovations. A solution to this problem could be to include the entire property after major energy renovations e.g. larger than 30 pct. as taxonomy eligible. Loans granted on farm level must be categorized as farm eligible. Loans granted to non-eligible farms should not be characterized as “brown” or undesirable but should be considered as neutral. This gives the farms an incentive to push on to become greener and taxonomy eligible. Sustainability should be fulfilled per unit produced, hence high productivity is encouraged, and a minimal carbon footprint per unit produced can be obtained.
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Response to Farm to Fork Strategy

16 Mar 2020

Please find attached a position paper from Danish Agriculture & Food Council about the upcoming EU Farm to Fork Strategy (roadmap)
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and Fødevareforbundet NNF

17 Feb 2020 · Sustainable food systems

Response to A new Circular Economy Action Plan

17 Jan 2020

The Danish Agriculture & Food Council welcomes the roadmap for a new circular economy action plan. In our opinion there is a huge potential for circular bio-economy in the EU. Therefore, we are surprised that the roadmap does not include circular bio-economy. The Danish Agriculture & Food Council considers circular bio-economy essential to the agricultural sector’s and the food industry’s contribution to help accelerate the green transition and replace fossil resources. Circular bio-economy is about high resource efficiency, recycling of biological materials as well as the development of bio-based materials and high value products such as medicines and ingredients. This is very much in line with the European Commission's ambition to secure a sustainable production and manufacturing industry in the future. Therefore, the Danish Agriculture & Food Council would like the planned revision of the IE directive to include circular economy policy in practice. The directive must encourage circular economy solutions such as water reuse and resource efficiency and not be a hindrance to circular economy which is sometimes the case today. Furthermore, the Danish Agriculture & Food Council notes that the Commission will provide citizens with reliable, verifiable and comparable information on products' sustainability features and tackle false green claims. We appreciate the European Commission’s intention to strengthen its communication on the sustainability of products. The Danish Agriculture & Food Council supports a common EU methodology such as the EU's Product Environmental Footprint (PEF) method, which demonstrates products’ impacts on the environment through life cycle analyzes.
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Response to Organics production rules

28 Nov 2019

Verandas should be part of the usable area for poultry Verandas support good animal welfare in the organic poultry production and should be considered as usable area if the birds have access to the area during their active hours. The poultry house is defined in Regulation 2018/848 as: "“poultry house” means a fixed or mobile building for accommodating flocks of poultry, which includes all surfaces covered by roofs, including a veranda; the house may be subdivided into separate compartments, each accommodating a single flock;" In Annex II, part II, point 1.6.1 of Regulation 2018/848, we find these requirements for buildings: "“Insulation, heating and ventilation of the building shall ensure that air circulation, dust level, temperature, relative air humidity and gas concentration are kept within limits which ensure the well-being of the animals”." It should be specified that verandas are considered as usable area if they fulfill the requirements for a building in point 1.6.1. Otherwise it seems that the Commission has interpreted/introduced a new definition of a veranda in the production rules that is in conflicting with the definition of a “poultry house” in the Basic Act (2018/848). Length of outdoor areas for poultry It is important to maintain the possibility to increase the length of outdoor areas of up to 350 m. It is our experience that laying hens will explore long distances if the outdoor area is covered with vegetation including trees, shrubs and alike, and in particular if they are trained to use the outdoor areas from early age. Pullet production The requirements for pullet production, in relation to stocking density on indoor and outdoor areas, are suitable and in line with our practice. The management of light is crucial to control the development of these birds, in particular in the first 8 weeks. For this reason, we suggest allowing artificial light programs to substitute natural light in the first 8 weeks, until the birds get access to outdoor areas. Outdoor areas to parent birds is challenging We suggest that outdoor areas for parent birds could be substituted by a reduced roofed outdoor area due to the risk of diseases and the potential risk for the broiler production relying on the parent production. With the requirement of access to outdoor areas we expect the organic parent production to be nominal, so organic broilers will be based on non-organic chickens with a 10-week conversion period. Outdoor areas for broilers We find the requirements of 4 m2 outdoor area per broiler to be exaggerated, since the birds use the outdoor area in a more limited period and to a lesser extent than laying hens. In our opinion 2 m2 of outdoor area/bird is more than enough to provide the broilers with an attractive outdoor area and to incorporate the nutrients delivered by the birds.
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Response to Animal disease notification, reporting, surveillance, eradication and disease-free status

3 Jul 2019

Please find attached comments from Danish Agriculture and Food Council
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Response to Enhancing Market transparency in the agri-food chain

4 Jun 2019

The Danish Agriculture & Food Council appreciate the opportunity to comment on the Commission’s proposal on increased market transparency. Implications relating to representativity The Danish food sector is characterized by a large share of co-operatives and private companies who in decades have been consolidating on the Danish market and abroad. This entails that many of the individual reports that should be submitted will not include at least three companies producing the product in question. The individual reports can thereby not live up to the principles of representativity, why the Danish Agriculture & Food Council finds the collection of such information unsuitable for further data processing. Missing details in the proposal A prerequisite for providing qualified information on prices that are comparable across the EU is, that it is clearly defined what product specifications that are covered by the proposal. For example, for whole chickens it must be specified within which weight limits the prices must be stated. Chickens are produced with a weight of 1 to 2 kilos, and the prices per kilo not necessarily correspond (small chickens are more expensive per kilo). For chicken breast and thigh meat it must be specified whether the price should be calculated with or without brine. For thigh meat it is further necessary to define the type of cuttings that are subject to the price reporting since there is a great price difference on over and under chicken legs and chine. Additionally, it must be clearly defined whether the reporting’s should be based on fresh/chilled meat and/or if frozen meat should be included as a weighted price (chilled meat is more expensive than frozen meat). It should also be noted that the Commission has informed the Danish Agriculture & Food Council that there are no reliable figures for the total European production of organic chicken. Currently it is therefore impossible to clarify whether the Danish production is above or below the 2 % threshold specified in Appendix 2 of the proposal. The Danish Agriculture & Food Council lacks a clarification on the detailed implementation of the proposal, e.g. product definitions laying the foundations for the reporting requirements. Among others: “fat filled powder”, defined as a dairy product but not further specified, and “minced meat” for pork and beef, where there currently exists no definition of the fat percentage which is central to the price of the product. Practical issues with timing In general it would be positive if data was new and updated. But when it comes to milk deliveries the reporting today on the 25th is already a challenge and the data might be adjusted later when delivered to Eurostat (soon we will get additional time to report to Statistics Denmark/Eurostat because several MS has problems delivering data on time). Competitive lop-sidedness The Danish Agriculture & Council is concerned that the proposal will have a negative influence on open competition in the price setting between producers and retail channels. For example, within the dairy sector there is a great difference on the price of branded milk and private-labelled milk. When the reported prices must represent the total sales of liquid milk, as suggested in the proposal, it will in principle undermine the innovations and investments made in these brands. This will put the price under pressure since retailers can consider the reported price as a reference price of which they will not pay more than. Hence the proposal will result in lower prices and ultimately low transfer prices for the milk producers. The Danish Agriculture and Food Council would also like to state that we fully support the comments put forward by both the European Dairy Association (EDA) and the European Livestock and Meat Trades Union (UECBV), regarding the Commission’s proposal on increased market transparency. Thank you
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Response to Rules for establishments keeping terrestrial animals and hatcheries and their traceability

22 May 2019

The Danish Agriculture & Food Council (DAFC) will thank you for the opportunity to provide comments to the new rules regarding establishments and traceability. We have noticed the following issue regarding record-keeping obligations of establishment keeping bovine, ovine, caprine, and porcine animals. Article 23 states that operators shall record the date of birth of each animal kept on the establishment and the date and of death. We want to raise the Commissions attention to the derogation that was stated in directive 92/101/CEE (article 4, point 1(a)), that for porcine animals recording of birth and death was not mandatory. The directive was repealed by Council Directive 2008/71/EC of 15 July 2008 on the identification and registration of pigs, where article 4 point 1 specifies that the register should shall include an up-to-date record of movements (numbers of animals concerned by each entering and leaving operation) at least on the basis of aggregate movements, stating as appropriate their origin or destination, and the date of such movements. Birth and death are not mentioned. The Animal Health Law neither mentions the recording of birth for porcine. Therefor DAFC suggest introducing a derogation for the recording information referred to in paragraph 1 (a) for porcine: X. Operators of establishments keeping porcine animals shall be exempted from recording the information referred to in paragraph 1 (a) DAFC hope for these concerns to be taken into consideration.
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Response to Rules on border control posts and measures to be taken in cases of non-compliant consignments of animals and goods

26 Mar 2019

Please find attached comments from Danish Agriculture and Food Council (DAFC)regarding draft implementing regulation for border controls for animals and goods. Kind regards Trine Vig Danish Agriculture and Food Council
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Response to Evaluation of the Industrial Emissions Directive

4 Dec 2018

Landbrug & Fødevarer repræsenterer mere end 1.500 husdyrbrug, som er omfattet af IE direktivet samt 100 virksomheder indenfor fødevareproduktion, kartoffelmel, slagterier, bryggerier, mælk, foder, garveri og biogas med produktion i Danmark. Mange af virksomhederne har hovedkontor i Danmark og produktion i andre EU-lande, blandt andet Sverige, Finland, Tyskland og England, og hvor miljøarbejdet koordineres fra Danmark. Landbrug & Fødevarer er tæt involveret i BREF-processen og repræsenterer i den sammenhæng flere forskellige Europæiske organisationer i Sevilla processen og Artikel 13 Forum. Vi deltager direkte i den tekniske arbejdsgruppe ift. IRPP, FDM og SA BREF’erne. Landbrug & Fødevarer skal positivt bemærke, at der lægges op til en tæt inddragelse af interessenter, herunder via interviews. Landbrug & Fødevarer vil i den forbindelse gerne stille sig selv til rådighed i forbindelse med de målrettede interviews. Landbrug & Fødevarer har samtidig modtaget tilkendegivelser fra flere medlemsvirksomheder, som også stiller sig til rådighed for interviews. BREF er et meget vigtigt element i IE direktivet, og det er således positivt, at denne proces får særlig opmærksomhed i evalueringen. Landbrug & Fødevarer skal i den forbindelse bemærke, at der i denne proces er en stor udfordring med lukkethed i processen, idet en lang række af de data som indsamles er fortrolige. Det betyder, at det blandt andet ikke er muligt at vurdere datagrundlagets validitet og relevans i forskellige sammenhænge. I forhold til den tekniske arbejdsgruppe, skal Landbrug & Fødevarer bemærke, at sammensætningen af denne gruppe fungerer meget tilfredsstillede. Der bør i BREF processen samtidig være fokus på at sikre, at BREF’erne spiller bedre sammen. I dag har vi eksempler på, at virksomheder – omfattet af flere BREF’er – kan få modstridende krav. Landbrug & Fødevarer kan på baggrund af ovenstående støtte op om en grundig evaluering af selve BREF processen. Landbrug & Fødevarer skal – som supplement til ovenstående bemærkninger til BREF processen – anmode om, at evalueringen også tager fat i en proportionalitetsvurdering i forhold til fastsættelse af BAT-konklusionerne. Det bør i den forbindelse vurderes, om BAT altid medfører en miljøgevinst, ligesom principperne for vurdering af cross-media effekter bør genbesøges. Såfremt der er tilfælde, hvor en yderligere reduktion i emissionerne ikke giver en miljøgevinst, bør ressourcerne i stedet anvendes på andre områder, hvor der er reelle miljøgevinster. Landbrug & Fødevarer skal samtidig anmode om, at der i evalueringen lægges vægt på mulighederne for at indarbejde den cirkulære økonomi i direktivet, så der kommer et endnu større fokus på ressourceeffektivitet og bæredygtig produktion, ligesom der bør foretages en tilbundsgående evaluering af implementeringen af direktivet i de enkelte EU-lande, herunder ift. kravene i virksomhedernes miljøgodkendelser (fx fastsættelse af BAT-AEL).
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Response to Proposal for a Regulation of the European Parliament and of the Council on minium requirements for water reuse

5 Jul 2018

Landbrug & Fødevarer er positive overfor kommissionens forslag til forordning vedrørende genanvendelse af renset spildevand til markvanding. Forslaget understøtter dagsordenen om cirkulær økonomi og øget ressourceeffektivitet, som vi bakker op om. Vi finder det ligeledes hensigtsmæssigt, at der fastsættes fælles standarder i en forordning, med henblik på at sikre ens retningslinjer og dermed lige vilkår på tværs af medlemsstaterne. Det er helt afgørende for os, at kriterierne sikrer et højt niveau af fødevaresikkerhed. I den sammenhæng har vi et konkret spørgsmål til tabel 1, side 7 i bilaget til forordningen, hvor det fremgår, at ”pigs must not be exposed to fodder irrigated…” Hvad er baggrunden for dette? Det primære markvandingsbehov i Danmark dækkes af grundvand. I Danmark anvendes desuden vand fra fødevareproduktionen til vanding. Der anvendes blandt andet kartoffelvaskevand og vand fra mejeriproduktion til vanding af marker. Vanding med kartoffelvaskevand er desuden defineret som værende Bedste Tilgængelige Teknik (BAT) i EU’s kommende BREF standarder for Food, Drink and Milk. Det er vigtigt for fødevareerhvervet, at disse anvendelser kan fortsætte uhindret, og at der ikke stilles yderligere krav til godkendelse, måling og dokumentation. Vi er således bekymrede over definitionen af urban waste water, som omfatter vand defineret i Direktiv 91/271/EEC. Her er blandt andet forarbejdning af mælk og kartofler defineret som industrisektorer i direktivets bilag III. Som vi læser direktivteksten og den kommende forordning, så vil eksempelvis kartoffelvaskevand og vand fra mejeriproduktion kunne være omfattet af de kommende krav. Såfremt ovenstående vandtyper er omfattet af kravene, ser vi det nødvendigt, at der indføres en undtagelsesmulighed i forordningen, så vanding med vand fra blandt andet mejerier og kartoffelproduktion ikke skal igennem øgede administrative byrder, herunder godkendelser og tests. Det er for eksempel ikke relevant at teste for E. coli i disse vandtyper. Det er Landbrug & Fødevarers opfattelse, at øgede administrative byrder vil begrænse brugen af ovenstående vandtyper væsentligt, ligesom det vil medføre unødige økonomiske byrder for erhvervet. Endelig finder vi det vigtigt, at det sikres, at de foreslåede bestemmelser ikke får betydning for den fortsatte anvendelse af slam på markerne.
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Meeting with Peter Wehrheim (Cabinet of Commissioner Phil Hogan), Peter Wehrheim (Cabinet of Commissioner Phil Hogan)

27 Apr 2018 · Climate policy

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

23 Mar 2018

Det er positivt, at drikkevandsdirektivet opdateres og tilpasses med henblik på at sikre kvaliteten af drikkevandet. Det er vigtigt, at fødevareproducerende virksomheder kan være trygge ved kvaliteten af det vand, der benyttes i produktionen og dermed med kontrollen af drikkevandskvaliteten. Vi ser derfor positivt på, at kontrollen med kvaliteten af drikkevand foreslås gennemført mere risikobaseret med udgangspunkt i en konkret risikovurdering. Vi bemærker i den forbindelse, at medlemslandene skal sørge for, at der er mulighed for at tilpasse kontrolhyppigheden og kontrolparametrene, hvilket netop er vigtigt i den konkrete kontrolvaretagelse. Det er afgørende at få vurderet, om fjernelsen af dispensationen i den tidligere artikel 9 kan give udfordringer for fødevarevirksomheder med egen boring, og om der vil være mulighed for at dispensere fra parameterværdier, som ikke overholder kravene i drikkevandsdirektivet (men som ikke har betydning for sundheden eller fødevaresikkerheden). Genbrug af vand/mælkevand bør ikke adressers i dette direktiv, men bør høre under forordning 852. Dog er der et punkt - Artikel 2 – Definitions, der kan hindre en løsning i forordning 852. Her bør ordet ”all” fjernes for at give plads til genbrugsvand og vand udledt af fødevarer (fx mælkevand). Som definitionen nu lyder, skal al vand, der anvendes i fødevareproduktion være af drikkevandskvalitet. “Water intended for human consumption’ shall mean: (a) all water either in its original state or after treatment, intended for drinking, cooking, food preparation 􀃖 or production,  or other domestic purposes 􀃖 in both public and private premises  , regardless of its origin and whether it is supplied from a distribution network, ⌦ supplied ⌫ from a tanker or, 􀃖 for spring waters, put  in bottles”. Økonomiske konsekvenser Det er positivt med mere og bedre information om drikkevandet kvalitet samt bedre uddannelse af blikkenslagere. Landbrug & Fødevarer skal dog kraftigt opfordre til, at det præciseres omkostningerne for disse tiltag ikke skal afholdes af vandforbrugerne. Det er Landbrug & Fødevarers opfattelse, at hverken informationskampagner og generel uddannelse af blikkenslagere bør være en del af kerneydelsen i vandforsyningerne. Artikel 10 – Risikovurdering af forbrugernes fordelingsnet Det bør præciseres, at der her kun menes forsyninger, som leverer til vandforbrugere gennem et ledningsnet, og ikke fx fødevarevirksomheder med egen boring. I den danske implementering bør det som minimum sikres, at uddannelse af blikkenslagere, oplysning samt rådgivning ikke finansieres af vandforbrugerne via taksterne. Artikel 14 – Oplysninger til offentligheden Det bør præciseres, at der her kun menes forsyninger, som leverer til vandforbrugere gennem et ledningsnet, og ikke fx fødevarevirksomheder med egen boring. Bilag 1, del A Det anføres, at der skal analyseres for Clostridium perfringens sporer. I det nuværende direktiv er der indført en note, hvor det fremgår, at kravet kun gælder for overfladevand. Årsagen til noten er, at analyseparameteren ikke er relevant for fx vandboringer, hvor denne parasit ikke findes. Man bør derfor fra dansk side arbejde for, at den eksisterende note bliver fastholdt, så erhvervet undgår unødvendige øgede omkostninger. Bilag IV Det bør præciseres, at bilaget ikke omfatter fødevarevirksomheder med egen boring.
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Meeting with Margrethe Vestager (Commissioner)

22 Feb 2018 · EU Current Affairs

Meeting with Phil Hogan (Commissioner) and

30 Jan 2018 · Business discussion

Meeting with Soren Schonberg (Cabinet of Commissioner Margrethe Vestager)

5 Dec 2017 · The EU seen from Denmark and from Brussels

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

30 Nov 2017 · Business discussion

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

17 Nov 2017

Landbrug & Fødevarer (Danish Agriculture & Food Council), som er en erhvervsorganisation for landbruget, fødevare- og agroindustrien i Danmark, hilser WFD Fitness Check velkommen. Med reference til COPA-COGECAs bemærkninger, vil vi gerne benytte lejligheden til at supplere med følgende bemærkninger til den igangværende høring af Roadmap for the fitness check: 1. Vi efterspørger og efterlyser særskilt fokus på proportionalitet og balance mellem vandrammedirektivets miljømålsætninger og andre hensyn, fx til bæredygtig erhvervsudvikling og bosætning i landdistrikterne. Efter vandrammedirektivets vedtagelse er det blevet et krav, at ny EU-lovgivning skal underkastes en konsekvensvurdering. I forbindelse med det forestående fitness check bør en konsekvensvurdering indgå, med henblik på at sikre realistiske målsætninger. 2. I forbindelse med fitness check bør effekten af klimaforandringerne på vandrammedirektivets dækningsområde tages med. Klimaforandringer har allerede og vil også fremover få stor betydning på vandforvaltningen, herunder hvilke klimatilpasninger, der er nødvendige at gennemføre - og som i nogle tilfælde vil virke i modstrid med elementer i vandrammedirektivet i sin nuværende form - og miljømålsætningerne vil i en række tilfælde skulle ændres til en anden virkelighed end den, der er udgangspunktet for bestemmelsen af høj, god, moderat etc. tilstand i vandområderne. Højere temperaturer og ændringer i nedbøren vil helt naturligt medføre, at den gode økologiske tilstand er anderledes nu og fremover end for årtier siden (shifting baselines). Og det har enorm betydning for den nødvendige indsats for at nå i mål. 3. Der bør i forbindelse med fitness check ses nærmere på byrdefordelingen mellem lande. Erfaringen viser, at medlemsstaterne opgør deres indsatser på forskellige vis - og derved er det svært at sammenligne indsatsen på tværs af fællesskabet.
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Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

6 Sept 2017 · Business discussion

Response to Initiative to improve the Food Supply Chain

21 Aug 2017

Initiative to improve the food supply chain in the EU Danish Agriculture & Food Council welcomes the opportunity to provide our reaction to the European Commission’s inception impact assessment “Initiative to improve the food supply chain”. Danish Agriculture & Food Council has been representing Danish farmers and agricultural cooperatives for more than 100 years, and has throughout that time been working to maximise the farmers’ share of the value in the food chain. Some of the most important tools have been market information and transparency; farmers’ cooperation mainly through agricultural cooperatives and ensuring fair trading principles. Danish Agriculture & Food Council therefore fully supports the Commission’s engagement in the issue. It is our experience that farmers through the promotion and creation of cooperatives and other efficiency enhancing forms of cooperation can become more competitive by reducing their costs and reinforcing their bargaining position in the food chain through larger scales and better marketing of their products (innovation of new products, brands etc.). This is a fact that we also see reflected in the report from the Agricultural Markets Task Force. In relation to the objectives and the policy options, Danish Agriculture & Food Council has the following comments: i. Unfair trading practices Danish Agriculture & Food Council finds it extremely important to combat unfair trading practices. However, the answer should not be found in more EU legislation, since a “one size fits all” approach cannot be adapted to the various and multiple food chains in the individual member states. The fact that more than 20 member states have already adopted very different legislation to curb UTPs which is tailor-made to address the specific challenges on the individual markets is an illustration that common EU rules (option (3)) will not be able to solve the problems met by farmers in many member states. Complex mandatory regulation will lead to increased administrative burdens and slow down the market-orientation of the sector, which is facing increasing competition from emerging countries with low production costs. We are deeply concerned that a uniform EU legislation will increase the number of bureaucratic rules – and thereby costs – to the farmers without increasing the farmers’ income. Danish Agriculture & Food Council therefore supports option (1) or as an alternative option (2). Should the Commission, however, in the end decide to proceed with option (3) or (4), Danish Agriculture & Food Council finds it extremely important that agri-cooperatives are exempted from mandatory regulation. This should reflect the fact that agri-cooperatives in a number of member states have been able to improve the economic position of the farmers in the food chain. It will therefore be in conflict with the policy objective if new mandatory regulation adds more regulation and costs to the agri-cooperatives. ii. Producer cooperation Danish Agriculture & Food Council fully supports the opportunity for farmers to cooperate. However, already existing producer cooperatives must not be obstructed by new regulation or initiatives. It is therefore of paramount importance that there must not be any mandatory requirements that alter the statutes of existing cooperatives. iii. Market transparency Danish Agriculture & Food Council finds that the Commission at present should focus on making sure that the market information which is already supposed to be collected is in fact up-to-date from all member states. The proposal to collect data on key products further downstream is very ambitious, and Danish Agriculture & Food Council has reservations about the relevance and the possibility to ensure compatibility of data.
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Meeting with Claes Bengtsson (Cabinet of Commissioner Margrethe Vestager)

21 Jun 2017 · Plant Patents

Response to Changes to greening rules and clarifications of certain other direct payments' rules

12 Jan 2017

Danish Agriculture & Food Council has discovered that there has been added a point 10c to article 45 which is formulated as follows: “On areas referred to in paragraph 9 established by under-sowing grass or leguminous crops in the main crop, this prohibition shall apply from the moment of the harvesting of the main crop until the sowing of the next main crop.” In the previous feedback to this delegated act from Danish Agriculture & Food Council we have raised some of the problems it would cause if the ban on plant protection products should also apply to the main crop of under-sown grass. Therefore it is very positive that point 10c has been added. The current formulation of point 10c will however not solve the problem that we have addressed. The challenge is that the prohibition shall last ...”until the sowing of the next main crop”. Danish Agriculture & Food Council therefore suggests that the sentence is reformulated to one of the following options: 1. ...”until the period set by the member state for the presence of under-sown grass ends” 2. ...”this prohibition shall apply in an 4/8 week period set by the member state –ending at the latest when the period set by the member state for the presence of under-sown grass ends” Danish Agriculture & Food Council mainly suggests these changes because the formulation proposed by the Commission is not compatible with the following rules and practices of establishing EFA-areas as under-sown grass in Denmark: • In many cases under-sown grass will turn into next year’s main crop. • If the under-sown grass does not turn into next year’s main crop, next year’s main crop will not be established until next spring. • The ban on plant protection products will therefore be in effect in a long period of time after the deadline beyond which it is allowed to put down the under-sown grass and catch crops. In Denmark this deadline is currently 27th of October. Generally it will not make sense to continue the ban on plant protection products beyond the end of the period where under-sown grass used for EFA is required to be in the field. If the ban on using plant protection products follows the described model, it will therefore give the following problems: Farmers will not get their greening payment until a much later stage – after finishing the control of the ban – and the control cannot be finished until farmers start to establish the next main crop. This will be at least until the following spring. In cases where the under-sown grass turns into the next main crop – it might even be a period of one or several years – where the farmer will not be allowed to grow the crop after normal agricultural practices. It is important that the farmer is given the opportunity to combat weeds after the deadline beyond which it is allowed to put down the under-sown grass. If this is not possible the farmer will in many cases have to combat these weeds (such as couch grass) at another time of year using a higher doze of plant protection products and with a less efficient result. In most cases the formulation suggested by the Commission will make it impossible for member states and for farmers to use under-sown grass as EFA, because the farmer will have to refrain from sound environmental farming practices, and the control and payment of support to farmers will be significantly delayed.
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Meeting with Soren Schonberg (Cabinet of Commissioner Margrethe Vestager)

12 Jan 2017 · EU policy developments in the area of agriculture

Response to Calculation of reductions related to the greening payments in agriculture

6 Jan 2017

Danish Agriculture & Food Council is disappointed of the level of ambition in simplifying and improving the proportionality of the rules for calculation of reductions in the greening payments. The current proposal contains mainly rephrasing of words and only minor changes to the proportionality of the calculation of corrections. There is an ugent need to increase proportionality in the calculation further. As an example multiplying the missing area for EFA with a factor 10 is way too high.
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Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

15 Sept 2016 · Agri matters

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

1 Jun 2016 · To share insights on the implementation of more targeted environmental legislation in Denmark

Meeting with Margrethe Vestager (Commissioner)

1 Jun 2016 · Climate action & current situation in agriculture and trade negotiations

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

1 Jun 2016 · AGRI matters

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

24 Jun 2015 · Simplification of the CAP

Meeting with Margrethe Vestager (Commissioner)

27 Apr 2015 · Commission priorities and work programme

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

12 Mar 2015 · Organic farming, the Commission's proposal in particular conversion, residue levels and controls

Meeting with Phil Hogan (Commissioner) and

5 Feb 2015 · Simplification, Greening, Fat tax, Pig price crisis, ammonia emissions

Meeting with Claes Bengtsson (Cabinet of Commissioner Margrethe Vestager), Ditte Juul Jørgensen (Cabinet of Commissioner Margrethe Vestager), Soren Schonberg (Cabinet of Commissioner Margrethe Vestager)

5 Feb 2015 · Introduction to the Agriculture & Food Sector

Meeting with Juergen Mueller (Cabinet of Vice-President Karmenu Vella), Patrick Costello (Cabinet of Vice-President Karmenu Vella)

5 Feb 2015 · Air quality package

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen) and Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners

21 Jan 2015 · Competitiveness of agriculture sector