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Nederlandse Zuivel Organisatie

NZO

The Dutch Dairy Association (Nederlandse Zuivel Organisatie, NZO) is an association of the Dutch dairy industry, representing the interests of thirteen dairy companies.

Lobbying Activity

Response to Electrification Action Plan

8 Oct 2025

The Dutch dairy industry places a high priority on making its production processes more sustainable and is actively implementing projects to reduce CO emissions in its factories. Electrification of dairy industrial processes plays a key role in this transition. However, this shift will lead to a sharp increase in electricity demand from dairy factories, requiring timely coordination with grid operators and policymakers. To accelerate electrification of the processes, the following elements are key for the Dutch dairy sector: 1. Attention to the network infrastructure for providing sufficient electricity. Electricity must be available now and in the future, including for the large energy consumers operating in peripheral/rural areas. Currently, Dutch dairy companies face technical, financial, and infrastructural barriers. 2. Electricity must be generated from green energy sources and not from fossil fuels. Energy generation from wind turbines and solar panels does not provide enough power to supply the factories. If additional electricity is needed, it must be generated from green energy sources and not from fossil fuel-powered energy carriers. 3. Sufficient (365 days a year) and 24/7 renewable electricity must be available to the factory. Good connections between the electricity grid and the factory are essential. This is because dairies continue to process a rapid flow of raw milk and fresh products 24/7. 4. Support (including subsidies) for adapting internal energy infrastructure and installations in the factory. This is because the factory needs to switch to equipment that runs on electricity instead of gas. 5. Simplifying the permitting process to enable adaptations. Obtaining permits is currently a lengthy and difficult process, which delays the transition to electrification.
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Meeting with Jessika Van Leeuwen (Member of the European Parliament)

24 Sept 2025 · Europese Landbouwbeleid en milieu- en klimaat beleid

Meeting with Johannes Ten Broeke (Cabinet of Commissioner Wopke Hoekstra)

26 Mar 2025 · Exchange views on future of dairy farms and challenges faced by sector.

Response to Commission Directive amending Annex III of the Nitrates Directive

17 May 2024

The dairy sector wishes to contribute to the challenges related to nutrient loss and nitrogen pollution in water courses and soil. The Dutch Dairy Association (NZO) therefor welcomes the proposal on updated rules on the use of certain fertilising materials from livestock manure (RENURE). The current directive is no longer up to date with technological advances made in the last three decades turning raw manure into sophisticated fertilisers. The proposed amendment is needed to increase nutrients circularity on farm. We want to stress that if this amendment is implemented, dairy operators can improve the utilization of nutrients from manure, protect water quality and reduce greenhouse gas emissions from manure. With reference to the text we have 4 suggestions to improve the effectiveness of this proposal: 1. We recommend having only a cap on the amount of N from manure being produced, but not on the amount of manure or animal numbers. 2. We think that to maintain the proposal up to date with the best available techniques in the future, it is essential to create a procedure to add new manure processing methods to this amendment. 3. It should be clarified what is meant by equivalent measures 4. It should be clarified at the EU level what particular precautions concretely means. Last, we endorse the contribution of the European Dairy Association regarding the proposal on the use of renure and refer to their uploaded comment and document.
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Meeting with Annie Schreijer-Pierik (Member of the European Parliament)

27 Mar 2023 · Trade agreements

Response to Carbon Removal Certification

23 Mar 2023

The Dutch Dairy Association (NZO), representing the Dutch Dairy Industry, supports the contribution of the European Dairy Association on the consultation of the proposal EU-rules for the certification of carbon removals. Additional to the key points in the EDA-document, the NZO would like to draw the attention of the EU institutions to the negative feedback effects from carbon farming if certificates of carbon removals will be traded outside of the food value chains. This might result in offsetting of non dairy related GHGs and avoids incentives to reduce the offset emissions. In line with that, we also do not favor double counting as a concept. Double counting is the act of using the emission reduction by carbon removal twice and in our opinion, this is a potential harm for the progress of sustainability.
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Meeting with Annie Schreijer-Pierik (Member of the European Parliament)

8 Mar 2023 · Dutch dairy sector

Response to Updating the EU Emissions Trading System

8 Nov 2021

The Dutch dairy Association welcomes the opportunity to comment on the Commission proposal of the review of the ETS and would like to draw the attention to the following points of interest: • Strengthening of the scheme means a cost increase for the participants of the ETS. The European Commission should be aware that stacking of rules and measures (European, national and international level) might lead to disproportional increase of costs. Increase of costs leads to a worsening of the economic position. It also means that less money is available for investments on projects to reduce the emission of CO2. We suggest the Commission to perform an impact assessment on the stacking of rules and measures for reduction of CO2-emission for the industry. • The ETS review proposes that free allocations, given to the installations of the carbon leakage list, will be made conditional on investments in techniques to increase energy efficiency. Is the Commission aware that an investment to reduce carbon emission sometimes will lead to a bigger energy demand? (changing the source for energy e.g. stop using gas and change to use of green electricity might imply reduction of CO2, but a rise in the demand for energy). • Manufacturing industries receive a share of their emission allowances for free. This allocation of free allowances to emit CO2 is based on benchmarks of the average greenhouse gas emissions of the best 10% performing installations. The dairy industry has no product benchmark and depends on the heat benchmark. Due to extern factors and regulation in the Netherlands the dairy industry cannot implement the techniques of best performing installations of the heat benchmark. It is therefore impossible to meet the heat benchmark. • Access to sustainable energy is key and a lot of dairy installations cannot make the transition due to the lack of a good energy infrastructure (e.g. demand for green electricity exceeds the supply of it, but also the electricity cannot be delivered to the location due to a lack of access to the electricity network). The dairy factories cannot take measures for electrification as long as the electricity cannot be delivered. • We are pleased to see that the review of ETS contributes to a level playing field in the European Union, nevertheless we would like to hear the view of the Commission with regards of national initiatives that raise the price of CO2-emission. • We also would like to hear the views of the conditionalities for the new funds? With reference to the proposals and reviews of current policy following the FF55% the Commission should always keep in mind the features of the food sector such as the dairy sector: • The proposals should take into account the extra ordinary position of the dairy industry: food (and drink) is a primary basic need, and also takes care of the food and nutrition security for EU citizens, and beyond. • The proposals in the FF55% should take into account the commitments for environment but also the commitments done in SDG’s (holistic approach).
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Response to Animal welfare labelling for food

23 Aug 2021

The Dutch Dairy Association (Nederlandse Zuivel Organisatie, NZO) is an association of the Dutch dairy industry, representing the interests of thirteen dairy companies. They process milk into a wide range of dairy products: from beverages, infant formula and children’s food, cheese and desserts, to ingredients for the broader food industry and the pharmaceutical sector. The NZO aims to reinforce its members’ abilities to produce and market their products. To reach this goal, NZO can be found in The Hague and in Brussels, and it also participates in public dialogue. It is important for farmers to have an integral embedding of various ambitions in their business operations. It ensures efficient and effective working and it prevents trade-offs. It is therefore important to have an integral view of animal welfare in combination with other sustainabililty objectives and foodsafety. Keeping regulations fit for the future contributes e to a large extent to well-being being translated into clear prescriptions rather then end regulations. For further information see annex
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Response to Review of the EU school fruit, vegetables and milk scheme - EU aid

27 Jul 2021

The Dutch Dairy Association (NZO) welcomes the opportunity to respond to the review of the EU school fruit, vegetables and milk scheme. Please find our feedback attached.
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Response to Commission Regulation setting maximum residue levels for chlorate in or on certain products

18 Feb 2019

The Dutch dairy industry, united in the Dutch Dairy Association (NZO), has made great efforts in recent years to reduce chlorate levels in milk and dairy products. The NZO has taken note of the proposed standards regarding chlorate within the pesticides legislation (Regulation (EC) No. 396/2005). The NZO contradicts the proposed standard of 0.02 mg / kg on raw milk, as did the other national industry associations for the dairy industry united in the European Dairy Association. The following considerations form the basis of the position of the NZO: - Regulation (EC) Nr. 396/2005 is not the right legislative framework to establish standards for chlorate. Chlorinated drinking water and insurmountable impurities in processing aids are important sources of chlorate in milk and dairy products. The presence of chlorate in food is therefore not the result of the use as pesticide. - The proposed standards for milk and dairy products are in no way in relation to the drinking water standard of 0.70 mg / kg as proposed by the World Health Organization, and the European proposal to tighten this to 0.25 mg / kg in the current revision of the European Drinking Water Directive. - The dairy industry has to deal with strict microbial safety requirements. In addition, restrictions apply to the quantities of process water from sustainability considerations. Both aspects are at stake when implementing the proposed chlorate standards. - Product standards must apply at product level 'as consumed'. - Research results from the NZO show that the proposed standard of 0.02 mg / kg for raw milk at farm level is currently not generally feasible. Commonly found chlorate concentrations in raw milk are in the same order of magnitude as the proposed standard of 0.02 mg / kg. Dairy farmers are closely monitored for compliance with the quality manuals, which allow good practices to be adopted at the levels found. Standard overrun within the pesticides legislation has far-reaching consequences for dairy farmers, such as refusal of milk. This is absolutely an undesirable situation, which cannot be explained either with regard to the standard for drinking water. Above all aspects, the NZO calls for the harmonisation of the chlorate standards in raw milk, milk and dairy products as consumed, and drinking water. A generally applicable chlorate standard of 0.1 mg / kg is considered appropriate. The NZO trusts that the rational considerations are appropriately included in the decision-making process. In addition to the above, the NZO is in line with the position of the European Dairy Association (EDA) and European Whey Products Association (EWPA).
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