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Milchindustrie-Verband e.V.

MIV

Der Milchindustrie-Verband ist der Spitzenverband der deutschen Milchindustrie.

Lobbying Activity

Meeting with Christine Schneider (Member of the European Parliament, Rapporteur) and Zentralverband des Deutschen Handwerks e.V. and

26 Nov 2025 · EUDR (Stakeholder Exchange)

Meeting with Fabien Santini (Head of Unit Agriculture and Rural Development)

8 Oct 2025 · Courtesy visit and CMO targeted amendment

Meeting with Norbert Lins (Member of the European Parliament)

1 Oct 2025 · GMO / UTP

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

19 Mar 2025 · Discussion on the Commission proposal for a targeted amendment of the CMO Regulation and other EU policy topics relevant for the German dairy industry.

Meeting with Christophe Hansen (Commissioner) and

19 Mar 2025 · Discussion on the Commission proposal for a targeted amendment of the CMO Regulation and other EU policy topics relevant for the German dairy industry

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

10 Mar 2025

MIV, the association of the German dairy industry, would like to make the following comments on art. 148 CMO: The proposed measures to reinforce contractual relations in the milk sector (art. 148 CMO) will not strengthen the position of farmers in the food supply chain. On the contrary, the current price transmission mechanisms will be weakened. The Commission proposal interferes with the fundamental right of entrepreneurial freedom and disregards contractual relations that are functioning well. Furthermore, it adds bureaucracy and leads to overregulation. In a free market economy, contractual content should be determined by the individual parties through negotiation. Therefore, the current subsidiarity approach in art. 148 CMO should be maintained, whereby Member States can decide for themselves whether to regulate written contracts depending on their own national environment. A uniform approach does not consider the specificity of the dairy sector compared to other sectors, nor does it account for the different environments and interests that exist among Member States. In Germany, there is a broad variety of contractual arrangements in place, depending on the product, the client, the market environment, the producers, and the dairy company. To be able to cope with a very dynamic milk market, milk buyers require flexibility when setting prices in order to quickly adapt to changing market developments and effectively transmit price signals. Due to the inherent volatility of the milk market, pre-fixed prices will lead buyers to incorporate risk discounts, which in turn negatively affect farm-gate prices and weaken producers' liquidity. Price formulae are seen as too rigid, too, as they may not always reflect real market returns. Under no circumstances should they be linked to production costs as it does not reflect the principle of a free market economy. The voluntary nature of market-driven contractual practices and existing hedging models have been successful and should be supported. Avoiding state intervention is essential to maintain the competitiveness of the German dairy industry. MIV members insist on operating within a free market economy, where contractual terms remain subject to free negotiation and mutual agreement. Please find more details in the attached document.
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Meeting with Norbert Lins (Member of the European Parliament)

5 Feb 2025 · Art. 148 GMO

Response to Unfair trading practices in the agricultural and food supply chain

28 Nov 2023

The Directive on Unfair Trading Practices and its implementation in Germany has proven effective in reducing several unfair trading practices used by companies buying dairy products. Many contracts have been adjusted. The contact and exchange with the implementing agency works well, but it lacks personnel capacity. Although it is possible to introduce anonymous complaints, the fear factor is still high. In general, payment behavior has improved, but nevertheless many payments are still overdue. The turnover ranges are complicated in their application and lead to a lot of bureaucracy and mistakes. Instead of ranges, the decisive factor should be the market power in the chain. We would therefore suggest to delete the turnover ranges and limitation. Arbitrary and disproportionate contractual penalties are currently not covered by the Directive (eg disproportionate penalties although 98-99% has been delivered). Such practices should be forbidden in the future. Another issue is that buyers place orders at very short notice and thus saves storage costs, which should also be tackled. Some buyers try to pass on costs that stem from legal obligations (eg audit costs related to deforestation-free requiremens) which lie in their area of responsibility. This should also be expressly forbidden. The current prohibition to return goods under certain conditions needs some refinement in the wording, as return does not include certain practices that have the same effect.
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