Li Service
Vi är en arbetsgivar- och branschorganisation för den svenska livsmedelsbranschen.
ID: 849925514506-35
Lobbying Activity
Meeting with Pär Holmgren (Member of the European Parliament)
13 Nov 2025 · Unfair trading practices directive
Meeting with Pär Holmgren (Member of the European Parliament)
17 Jul 2025 · Climate, Environmental and Agricultural policy
9 Apr 2024
See attached file
Read full responseResponse to Restrictions on bisphenol A (BPA) and other bisphenols in food contact materials
8 Mar 2024
Swedish Food federation comments on the Draft Regulation for BPA and other bisphenols and their derivatives with harmonized classification for specific haz-ardous properties in certain materials and articles intended to come into contact with food Overall, the increased attention given to the harmful effects of chemicals covered by the draft regulation, as well as the ambition to prohibit the use of Bisphenol A in food contact materials, is seen as a positive development. Further we pursue clarification on: Paragraph 2,a, article 2; A Final food contact article can be composed of multiple articles, not all of which come into direct contact with food. These articles may also be easily separable. Therefore, it is important to clarify whether all the articles are within the scope or if only the articles with direct contact with the food are included. Given the significant development in combi primary packaging solutions that com-bine fiber and plastic, there is a growing ambition to separate these articles to achieve future recyclability goals. The clarification will not only assist in ensuring compliance during the manufacturing stages of the supply chain, but also contribute to cleaner paper waste streams for food packaging. Paragraph 1, article 7; For all materials and articles covered by the draft regulation, a written declaration is required throughout all marketing stages to ensure compliance with regulatory re-quirements stated in the draft regulation. It is important to clarify whether the retail stage is included within the definition of "all stages of marketing". However, the ben-efit of this formal document for retailers is minimal. The responsibility lies with the Food Business Operator to ensure the proper use of food contact materials as de-fined for plastics in EU Reg. 10/2011. Introducing additional documentation for the retail stage will only result in additional administrative tasks.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
10 Mar 2023
Our comments and proposals are in the attached document
Read full responseResponse to New requirements for transport and storing of fishery products.
31 May 2022
Livsmedelsföretagen / the Swedish food federation, representing the Swedish food and drink industry, thanks the European Commission for the opportunity to comment on this draft act.
As regards the proposal to increase the maximum time limit for delivering eggs to the consumer, we strongly believe this is an essential issue to address in order to reduce unnecessary food waste. However, this proposed move would certainly not be enough. Rather than maintaining rules of this nature, we are of the opinion that the food business operators must be given the responsibility to determine the shelf-life of eggs in the same way as for any other food, i.e. with a risk-based approach and assuming their responsibilities in relation to food safety and vis-à-vis consumers. We know that Swedish eggs are safe to consume well beyond 28 days, both due to the negligible prevalence of salmonella and the fact that consumers in Sweden generally stores eggs in the fridge. Thus, even a prolongation of the maximum time limit will not properly address the current regulation-driven food waste that we find highly unfortunate and that would be both easy and important to address.
In case this point will still be maintained in the EU Regulation, at the very least we urge the Commission to introduce a measure of flexibility, e.g. to allow Member States with a documented low or negligible prevalence of salmonella to set a longer time limit than 28 days at national level.
If Europe wants to be serious about reducing food waste, this point is a low-hanging fruit to address, without increased food safety risks for the consumers.
Read full responseResponse to Setting of nutrient profiles
3 Feb 2021
Livsmedelsföretagen är en arbetsgivar- och branschorganisation för den svenska livsmedelsindustrin. Våra cirka 800 medlemsföretag sysselsätter 48 000 personer och utgör tillsammans Sveriges tredje största industrigren. Livsmedelsföretagen välkomnar möjligheten till synpunkter inför revideringen av förordning 1169/2011 om livsmedelsinformation. Det är positivt att en diskussion om märkningslagstiftningen nu sker på EU-nivå och det är Livsmedelsföretagens förhoppning att processen leder till förbättrad harmonisering inom EU och färre nationella särregleringar.
För att ge konsumenterna ännu bättre möjligheter till medvetna och hållbara val, har livsmedelsmärkning identifierats som ett nyckelområde inom Farm to fork-strategin. Här behöver man beakta att EU genom åren redan har utvidgat kraven på märkning av livsmedelsprodukter till att omfatta en lång rad obligatoriska uppgifter. Ytterligare märkning kan i vissa fall vara ett bra sätt att underlätta hållbar konsumtion men med tanke på de redan omfattande lagkraven på märkning, bör man ha som utgångspunkt att mer information på produkterna kan tillhandahållas genom frivilliga märkningar. I Sverige är t ex två vanliga frivilliga märkningar, som var och en fyller viktiga funktioner, hälsomärkningen Nyckelhålet och ursprungsmärkningen Från Sverige. Det är därför viktigt att kommissionen inte bara fokuserar på nya lagkrav i konsekvensutredningen utan även utreder alternativ med frivilliga, marknadsdrivna märkningar, liksom konsumentupplysning på andra sätt än genom märkning av produkter.
Ifall lagändringar ändå föreslås så småningom, är det viktigt att tillräckligt lång övergångstid ges till företagen för att undvika onödiga kostnader och kasseringar av förpackningsmaterial.
Konsekvensutredningen behöver noggrant analysera vilka effekterna av olika handlingsalternativ kan bli för såväl konsumenter, producenter som den totala hållbarhetseffekten. Exempelvis behöver man ta hänsyn till att utrymmet på livsmedelsförpackningarna är begränsat och att konsumenter redan idag upplever svårigheter att hitta den information man söker (se t ex Livsmedelsverkets rapport (An)märkningsvärt - en undersökning om konsumenters förståelse av livsmedelsinformation, s 15-16), då ytterligare märkningskrav riskerar att öka den komplexiteten. Det är också viktigt att inte befintliga och välfungerande frivilliga märkningar som de ovan nämnda undermineras av nya EU-krav. Man behöver också noga analysera konsekvenserna för EU:s inre marknad, kostnader för såväl producenter som konsumenter, samt industrins konkurrenskraft.
Livsmedelsföretagen ansluter sig till de synpunkter som lämnats av FoodDrinkEurope och vill därutöver framhålla några synpunkter på näringsmärkning ”front of pack”, näringsprofiler, ursprungsmärkning och datummärkning, se det bifogade dokumentet.
Livsmedelsföretagen ser fram emot en fortsatt diskussion och vill gärna bidra med branschens erfarenheter och kunskap under det fortsatta arbetet med att se över förordningen om livsmedelsinformation.
Read full responseResponse to Farm to Fork Strategy
16 Mar 2020
Livsmedelsföretagen (the Swedish Food Federation) is a trade association for the Swedish food industry, representing around 800 companies of which the vast majority are SMEs. The food industry is the third largest among Sweden's manufacturing industries. The Swedish Food Federation is pleased to present its views on the European Commission's Roadmap on its forthcoming Farm to Fork Strategy.
The Swedish food industry welcomes the intention of the European Commission to make sustainable food systems a core priority under its current mandate. For many years, our industry has worked towards sustainability of food systems in all relevant aspects - environment protection and fighting climate change, economic viability of companies and competitiveness of the industry on EU and international markets, as well as social responsibility towards both consumers and employees.
The Commission's ambition on sustainable food systems is therefore welcomed by the Swedish food industry. In order for it to be successful, we believe there are a number of fundamental principles that need to be underpinning the Farm to Fark Strategy:
- A holistic approach to food systems, where all aspects of sustainability are carefully considered, is crucial and will be demanding for policy-makers and all stakeholders at EU, Member State as well as regional and local levels. We expect a new strategy for sustainable food systems at EU level to pilot a cross-cutting and coordinated approach that is capable of managing the trade-offs between different policy objectives that will inevitably have to be made. Here it is also essential to keep in mind that food safety is a cornerstone of European food policy thus far and must remain the overarching objective also for the future.
- EU policy needs to be based on sound science and evidence. This is already a challenging task in many ways but will be increasingly so for a truly holistic food policy. Supporting science and evidence will have to be produced not only for the individual measures in themselves but also for the policy as a whole, as well as on how different measures and sub-policies affect each other. In general, impact assessments and evaluation will be key tools to make sure that we get it right and avoid policy-making for window-dressing rather than for real progress. The European Commission therefore needs to continue upholding and to further enhance its Better Regulation agenda.
- We see a great opportunity for strengthening European food production under the Farm to Fork Strategy, and to ensure that it stays competitive vis-à-vis the rest of the world. For this to happen, we are convinced that all policy work will have to be done in an open, inclusive and transparent way where all stakeholders, including the processing industry with its crucial role between farmers and retailers in the food chain, has a seat around the table.
- The EU Single Market and harmonised law on food needs to be protected and developed, whereas fragmentation by way of national regulations, which has increased in recent years, must be pushed back.
- In order for Europe to lead the way towards sustainable food systems worldwide, we need a positive environment for European food businesses to thrive, with fair conditions for all companies - including the many SMEs in the sector.
- To support a transition of the food systems, the industry and society as a whole need to invest in research and innovation. This will require financial support but also a critical revision of the regulatory framework, to make sure that it provides incentives rather than barriers to R&I.
- Any EU food policy must respect cultural differences in diets. Consumer preferences, food traditions, product offer and diets diverge between Member States. In particular in the context of promoting healthy diets, this needs to be taken into account.
Finally, we strongly support the views that have been expressed by FoodDrinkEurope in its comprehensive contribution.
Read full response30 Jan 2018
The date of application in Article 4 should be 1 April 2020
There is need for a longer transition period, 18-24 months, due to both the need for companies to adapt and the need for an EU guidance document to be developed. The Implementing Regulation is rather simple and leaves room for interpretation, so there is a clear need for a guidance at EU level in order to ensure a common application of the rules across the Member States. Moreover, the guidance need to be ready well in advance of the date of application, in order for companies to adapt as necessary without legal uncertainty, unnecessary costs and/or waste of packaging material.
Clarification on the scope of application (Article 1)
It is common to indicate the place of production on the label of many products, with the wording “made in” or similar. In certain cases, this is due to national legal requirements in certain countries. However it is also a long-standing practice to provide this information on a voluntary basis, without any intention to inform about origin/provenance of the ingredients, but simply to clarify where it is produced which is believed to be of a certain interest to the consumer. There is no reason to believe that such indication would mislead any consumer to believe that the ingredients of the product are originating from the place of production. It should be made clear that this kind of labelling is not within the scope of the Implementing Regulation. Otherwise, uncertainty on this point risks leading to these indications being removed from products; resulting in less, rather than more information given to the consumer – clearly against the purpose and the spirit of the legislation.
Also, any use of acronyms, pictorials, statements or terms on the label with the only purpose to clarify to the consumers where their language of information is to be found on a multi-language label, should not be considered to be indications of origin.
Both these concerns and others related to the scope of the Implementing Regulation, could be addressed by additional wording either in a recital or, preferably, in Article 1, that the Regulation only applies where the presentation of the food as a whole is to be considered as explicitly intended to provide information on the country of origin or place of provenance to the purchaser and is likely to have such effect on the normally informed and reasonably circumspect consumer.
More flexible wording (Article 2b)
The draft Regulation would make it difficult to handle products where the sourcing of the primary ingredient varies frequently over time and where the origin sometimes is the same as the product as a whole. For example, this is often the case for products where the primary ingredient is vegetables and where it is impossible to ensure constant and sufficient supply/quality all year around of Swedish-origin ingredients. In order to cover all production circumstances, as referred to in recital 13, the wording in Article 2 b) must be possible to use also in these cases, where the origin of the primary ingredient is sometimes the same as, and sometimes different from, the origin of the whole product. One way of ensuring this would be to add the word “may” in the standard statement laid down in Article 2 b): “(name of the primary ingredient) do/does/may not originate from (the country of origin or the place of provenance of the food)", or any similar wording likely to have the same meaning for the consumer.
Some points where we see particular need for clarifications, either in the guidance or in the recitals:
• The definition of primary ingredient in the Regulation 1169/2011 leaves room for interpretation. Further guidance and examples are needed here.
• More guidance is needed as regards what should be considered as customary or generic names (cf recital 8).
• It is also necessary to provide further clarity as regards names which contains phrases such as 'inspired by', 'kind', 'type', 'style' etc.
Read full response6 Jul 2017
Swedish food producers take the issue of acrylamide seriously and the Swedish Food Federation welcomes the opportunity to comment on the draft Regulation.
Overall, we welcome the regulatory approach taken by the Commission. By introducing, for the first time, a legal obligation for all concerned manufacturers to apply relevant mitigation measures, this legislation will help to further reducing consumer exposure to acrylamide. At the same time, the draft Regulation reflects the complex nature of acrylamide formation in food. In particular, we appreciate that obligations are clearly related to factors that are under the control of manufacturers. We also believe that the draft Regulation provides a clear legal framework for official controls by enforcement authorities.
We do note with some concern that there is reference to the introduction of maximum limits in recital 15. In our view, it would not be logical and not in line with the principles of better regulation to introduce an additional layer of regulation in the immediate term. Before any such double regulation is considered, the effects of the draft Regulation must first be evaluated.
In this context, we wish to recall that it would be practically impossible to control the acrylamide content in each individual package of food, given the variability of acrylamide levels that will always occur as a result of factors out of the direct control of the manufacturer, e.g. seasonal and geographical variation in raw materials. The latter is particularly relevant for Swedish food companies, given that the climate conditions for certain raw materials grown in Sweden, notably potatoes, can lead to somewhat higher levels of acrylamide in the end product (e.g. shorter growing season and longer storage times). At the same time, both consumers and producers have an interest in using Swedish raw material for many reasons, e.g. to keep supply chains as short as possible.
We welcome that the concept of benchmark levels has been clearly defined in the draft Regulation, which we hope will reduce the risk of misunderstandings when implementing the legislation.
As to the benchmark levels as such, in some cases the figures seem too low, if the intention is to set the benchmark level at the 85th percentile. For such cases, we believe there is need for a more representative sets of data in order to achieve a sound evidence-based approach. In the case of breakfast cereals it also seems odd that the benchmark level for bran products and whole grain cereals is the same as for wheat and rye based products, whilst it is well known that bran and whole grain products has a higher risk of acrylamide formation due to higher asparagine levels. Furthermore, the category “products similar to the other products in this category“ is too vague and needs to be more clearly defined.
We appreciate that the mitigation measures listed in Annex I are based on the industry codes of practice and largely agree with the contents. There are some cases where we feel that the text risks being overly rigid, e.g. in point X.7 which says that FBOs shall use asparaginase insofar possible. Many manufacturers are not making use of GMO products due to consumer acceptance and there are also other methods that gives the same effect, e.g. yeasts. Therefore, a more appropriate wording would be: ”…shall consider the use of asparaginase or other methods to reduce asparagine, insofar possible and taking into account…”etc.
There should also be a recognition that measures must be proportionate to the resources and capacity of the many small and micro enterprises, e.g. in the bakery sector.
Finally, we recommend including a statement, perhaps in a recital, that the Regulation, notably Annex I, will be revised to take into account the development of new mitigation measures. Actions to enhance food safety is at the heart of the Swedish food industry and we will continue our efforts to reduce acrylamide presence in food.
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