Primary Food Processors

PFP

The Primary Food Processors (PFP) association represents the interests of the European primary food processing industry.

Lobbying Activity

Primary Food Processors urge broader EU food safety simplification

14 Oct 2025
Message — PFP requests extending simplification to more regulations and streamlining contaminant rules. They also seek faster approvals for pesticides and emergency mechanisms for supply chains.123
Why — Streamlined regulations would reduce compliance costs and improve the sector's competitiveness.45
Impact — Consumer and environmental groups may face risks from relaxed pesticide residue limits.6

Primary Food Processors Demand Lower Energy Prices and Funding

9 Oct 2025
Message — The industry calls for competitive electricity prices and public funding for mature technologies. They also request faster grid connections and tax reductions for industrial residues used as fuel.123
Why — These changes would reduce operational costs and de-risk investments in climate-neutral technologies.45
Impact — Producers of forest-sourced biomass may lose market share to industrial processing residues.6

Primary Food Processors demand lower electricity prices and grid exemptions

9 Oct 2025
Message — Access to long term contracts with competitive electricity prices based on production costs is requested. They call for faster grid connections and exemptions from grid tariffs for energy-intensive industries. Public funding should support mature and proven technologies rather than just breakthrough innovations.1234
Why — Lowering taxes and providing operational support would reduce the high cost of electrification.56

Primary Food Processors urge clarity on pesticide sampling scope

30 Jul 2025
Message — PFP requests clarifying that the regulation applies only to official controls rather than food businesses. They also advocate for harmonizing sampling methods and extending flexibility to food products.123
Why — This ensures businesses avoid economically unsustainable and destructive testing requirements for every product lot.4

Primary Food Processors support streamlined rules for genomic plants

23 Oct 2023
Message — They support exempting certain genomic plants from mandatory GMO labeling and traceability rules. The group requests a harmonized verification process that remains simple and not overburdened. They also express concern regarding the potential rise of negative NGT-free labels.123
Why — This would lower operational costs by removing strict labeling and tracking obligations.4
Impact — Producers of NGT-free products lose their ability to differentiate via negative labels.5

Food industry group urges clarity on environmental footprint rules

29 Jun 2023
Message — The group urges the Commission to confirm which food products require specific environmental footprint rules. They question prioritizing food claims now to avoid risks of switching between different regulations. Finally, they advocate for harmonized recognition of labeling schemes across the EU.123
Why — Harmonized rules would reduce administrative burdens and prevent companies from adapting to multiple regulations.45
Impact — The broader green transition suffers because the directive primarily benefits a niche of leading companies.6

Primary Food Processors demand representation and lower recycling targets

3 May 2023
Message — PFP demands seats on the Sustainable Finance Platform to influence technical criteria. They also request lower plastic recycling thresholds and broader recognition of bio-based feedstocks.123
Why — Representation would ensure industry members maintain access to finance and agricultural supplies.4
Impact — Environmental groups lose out if plastic recycling targets are weakened for the food industry.56

Primary Food Processors warn pesticide cuts threaten food security

19 Sept 2022
Message — Maintain current pest management definitions to prevent crop damage before treatment is permitted. The group also seeks a legal framework for new genomic breeding techniques.12
Why — This protects agricultural yields and ensures the continued competitiveness of food processors.34
Impact — European citizens risk lower food security and higher reliance on foreign imports.56

Primary Food Processors warn against publishing business-sensitive data

23 Jun 2022
Message — PFP warns that the obligatory publication of business sensitive data may damage companies. They oppose rules requiring disclosure of production volumes, energy, and water consumption.1
Why — Restricting these disclosures would protect companies from financial damage and competitive disadvantage.2

Food industry warns strict emission limits threaten economic competitiveness

23 Jun 2022
Message — The organization recommends allowing authorities to set emission values above the lowest levels. They argue against binding performance limits for resources and request longer timelines for testing new technologies.123
Why — Companies would avoid strict compliance costs and the technical burden of mandatory benchmarks.45
Impact — Nearby residents would struggle to prove environmental damages or access sensitive operational information.67

Meeting with Pascal Arimont (Member of the European Parliament)

21 Apr 2022 · Energetic self-use of biomass residues for decarbonisation

Response to Evaluation and revision of the Weights and Dimensions Directive

18 Feb 2022

PFP, the association for the European primary food processing industry, would like to take the opportunity of this call for evidence to comment on Directive 96/53/EC. In particular, we would like to highlight an issue regarding cross-border transport. According to Directive 96/53/EC, in the cases of articulated vehicles with five or more axles with maximum authorised vehicle weight limited to 40 or 42 tonnes in the Directive, Member States can opt to increase the maximum weight above 40 or 42 tonnes for national traffic. This option has been used by several Member States. However, there are instances of 2 neighboring Member States having opted to increase this maximum weight to 44 tonnes for national transport (thereby presumably having assessed the safety of bridges, tunnels and other infrastructure with the higher load), while the maximum weight for international transport between these two neighboring Member States remains limited to 40 or 42 tonnes by the Directive. Such a limitation has a negative impact on traffic volume and also on the environment (fuel use, CO2 emissions), given that (international) transport with 40 or 42 tonnes requires the use of more trucks than what would be the case with 44 tonnes. The Directive should be amended to increase the maximum weight of all specified road vehicles engaged in cross-border traffic to 44 tonnes. This is essential to safeguard the free movement of goods between Member States and hence the EU Single Market. It should be noted that in intermodal transport operations, weights up to 44 tonnes have already been already allowed for several years. Increasing the maximum weight limit to 44 tonnes would not in our view cause any significant technical challenges. Finally, we believe that the current 40 or 42 tonnes limitation could pose a competitive disadvantage for hauliers that need to cross borders and subsequently for all those who use their service.
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Response to Maximum dimensions and weights in national and international traffic for certain road vehicles circulating within Union

2 Feb 2022

PFP, the association for the European primary food processing industry, would like to take the opportunity of this consultation to comment on Directive 96/53/EC. While we understand that this consultation deals with the codification of this directive, we would like to highlight an issue regarding cross-border transport. According to Directive 96/53/EC, in the cases of articulated vehicles with five or more axles with maximum authorised vehicle weight limited to 40 or 42 tonnes in the Directive, Member States can opt to increase the maximum weight above 40 or 42 tonnes for national traffic. This option has been used by several Member States. However, there are instances of 2 neighbouring Member States having opted to increase this maximum weight to 44 tonnes for national transport (thereby presumably having assessed the safety of bridges, tunnels and other infrastructure with the higher load), while the maximum weight for international transport between these two neighbouring Member States remains limited to 40 or 42 tonnes by the Directive. Such a limitation has a negative impact on traffic volume and also on the environment (fuel use, CO2 emissions), given that (international) transport with 40 or 42 tonnes requires the use of more trucks than what would be the case with 44 tonnes. The proposal which is the object of this consultation does not seem to address the issue. It should be noted that in intermodal transport operations, weights up to 44 tonnes are already allowed since several years and would not in our view cause any significant technical challenges. Finally, we believe that the current 40 or 42 tonnes limitation could pose a competitive disadvantage for hauliers that need to cross borders and subsequently for all those who use their service.
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Primary food processors urge EED exemptions and data confidentiality

19 Nov 2021
Message — Campaign plants operational for fewer than 180 days should be exempt from heating network requirements. The directive should recognize combined heat and power as a sustainable energy solution for industry. Audit recommendations must remain confidential to protect secret operational data.123
Why — This would prevent high investment costs for seasonal plants and protect secret operational data.45
Impact — Local heating networks lose potential energy inputs that could have improved municipal heating efficiency.6

Primary food processors seek energy tax exemptions for competitiveness

18 Nov 2021
Message — The organization says energy products used by power plants should be exempt from taxation. They also ask for lower tax rates for biofuels from food and feed crops.123
Why — This would support sector competitiveness and reduce the existing risk of carbon leakage.45
Impact — Environmentalists lose as incentives for biofuels from food crops may damage the environment.6

Primary Food Processors Urge Protections for Rural Industrial Decarbonisation

5 Nov 2021
Message — PFP requests removing energy audit conditionality and maintaining free allowances for biomass-using plants. They also demand grid reinforcements and competitive electricity prices to facilitate rural industrial electrification.12
Why — This would protect the industry from financial penalties while reducing electrification costs.3
Impact — Environmental goals are undermined if firms ignore energy efficiency recommendations without penalty.4

Primary Food Processors urge exemptions from EU waste targets

28 Oct 2021
Message — The association wants certain processing sectors excluded from waste measurement and reduction targets. They argue that non-edible agricultural materials should not be classified as food waste.12
Why — The industry would avoid new reporting burdens and reduction targets for materials they classify as valuable by-products.34

Primary Food Processors oppose mandatory country-of-origin labeling requirements

1 Feb 2021
Message — The organization requests maintaining the current voluntary legal framework for origin labeling. They argue that existing rules are adequate and do not support new mandatory requirements for their products.1
Why — Maintaining voluntary labeling helps these industries avoid the costs of tracking ingredient origins.2
Impact — Consumers lose access to standardized information about the origin of certain food categories.3

Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

The Primary Food Processors would like to express their deepest concerns following the Commission’s publication of the first draft delegated act and its annexes supplementing Regulation 2020/852 establishing a framework to facilitate sustainable investments, which pose a serious threat to the competitiveness of their sectors and to their ability to contribute towards climate change mitigation and adaptation. In the attached letter, we put forward the reasoning why we respectfully ask you to remove the references made to the uses of agricultural raw materials for industrial and energy applications such as plastics, biofuels for transport, biowaste and organic chemicals, stating that a key criterion is that “Food or feed crops are not used as bio-based feedstock for the manufacture” of these biobased products and ingredients, a key economic activity of the Primary Food Processors. Hence, PFP asks the Commission to delete the following sentences in Annex I of the draft delegated act: - Page 89: “Food or feed crops are not used as bio-based feedstock for the manufacture of organic base chemicals” - Page 95: “Food or feed crops not used as bio-based feedstock for the manufacture of plastic in primary form” - Page 126: “Food and feed crops are not used in the activity for the manufacture of biofuels used in transport” - Page 164: “such other input material may not include food or feed crops”. Primary Food Processors (PFP) is an alliance composed of six trade associations, representing manufacturers of sugar, starch, wheat flour, vegetable proteins, cocoa, and vegetable oil and protein meal products, respectively, processing agricultural raw materials into a range of commodities and ingredients that are purchased by secondary processors for food, feed, and industrial and energy uses. The primary food processing industry uses around 220 million tonnes of agricultural raw commodities annually, directly employs over 120,000 people in the EU and provides one million indirect jobs. Biorefineries are the cornerstone of the EU bioeconomy valorising biomass, by- and co- products and waste feedstocks into added-value bio-based products that substitute fossil resources. In the bioeconomy, land use and food security are optimised through a sustainable, resource-efficient and almost zero-waste utilisation of Europe’s renewable raw materials, therefore contributing significantly to a circular economy. Our assessment of the impact is that large parts of the EU bioeconomy risk being considered as unsustainable for taxonomy purposes, even though their primary purpose is to process and add value to renewable resources as feedstock for making innovative, value-added everyday products and materials. The bioeconomy does not fall under one particular NACE code; instead, its sectors fall either wholly or partly under various NACE codes. The reference “Food or feed crops are not used as bio-based feedstock for the manufacture” of these biobased products and ingredients is of great concern to PFP because of its repercussions on investments and forthcoming policies. Indeed, we see taxonomy being referred to as a tool by many, either on a voluntary or mandatory basis. While this could be considered initially as a positive development, as we believe the bioeconomy to be instrumental in achieving the European Green Deal objectives, the eradication of those bioeconomy outlets from the positive taxonomy is problematic. We note many inconsistencies and contradictions between the consequences of this draft delegated if no changes are made, and EU policies & regulations detailed in the attached letter. All the outlets of the bioeconomy are instrumental in preserving the competitiveness of its industries and their suppliers; blocking the use of renewable raw materials in some of them, puts the entire value chain at stake.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

PFP, the association representing European primary food processors welcomes the intention of the European Commission to improve the regulatory framework for the use of green claims. In this regard, we would like to highlight the following points: 1) Product Environmental Footprint Category Rules are available for six food and drink sectors only. This means that for the many remaining food and drink sectors no category rules have been developed yet; there is hence a large gap which still needs to be bridged. For those sectors for which a PEFCR is available, performing PEFCR has become relatively cheap due to the methodology and the necessary data being freely available. However, the desired independent verification of the PEFCR results still is expensive. 2) We believe that PEF can help identify environmental hot spots in products' life cycles and harmonizing environmental life cycle assessment. At the same time, we believe that voluntary green claims should be substantiated by PEF, but we invite the Commission, in particular for food and drink production, to explain how the use of PEF will lead to reduction of environmental impact and will avoid to just trigger, for instance, a re-allocation of product flows. 3) More clarity on the definition and scope of “green claims” is needed. 4) Finally, we invite the Commission, in a policy document, to identify the data and methodology gaps that still hinder full scale use of PEF substantiated green claims for food. PFP will provide further input in the upcoming public consultations. PFP members (starch manufacturers, cocoa bean processors, the vegetable oil and protein meal industry, vegetable proteins manufacturers, flour millers, and sugar manufacturers) form a vital link in the food chain, delivering efficiently produced, high quality safe food for our customers and the consumer. The quality and safety of both agricultural raw materials and end products is paramount to our industries.
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Primary food processors urge inclusion in ETS state aid revision

16 Jan 2019
Message — The organization requests the Commission include the vegetable oil industry in targeted sector assessments. They highlight that manufacture of oils and fats faces a significant carbon leakage risk.12
Why — Inclusion would allow these companies to receive state aid to offset electricity costs.3

Primary Food Processors urge context for food risk data

12 Jun 2018
Message — Sensitive data should only be published together with the final EFSA opinion. PFP calls for releasing exclusively data actually used in risk assessments. This avoids damaging industry competitiveness and creating unfounded fears.123
Why — Restricting data access prevents competitors from identifying company methods and protects brand reputation.45
Impact — Transparency advocates and researchers lose immediate access to raw data before official conclusions.6

Primary Food Processors urge clarity on origin labeling rules

30 Jan 2018
Message — PFP requests a guidance document to address lingering interpretative uncertainties. They emphasize that complex processing makes high precision reporting difficult for some.12
Why — Clearer guidelines would reduce legal uncertainty and facilitate smoother business-to-business transactions.34
Impact — Consumers may receive less precise information regarding the specific origin of ingredients.5

Primary Food Processors Urge Science-Based Food Safety Transparency

16 Jan 2018
Message — The association supports risk assessments based on sound science regardless of the funding source. They advocate for educational campaigns to improve public perception and avoid false messages about food. New transparency measures should follow existing laws and build upon current agency initiatives.12
Why — This would protect the validity of industry-funded research and reduce public opposition to their products.3
Impact — Groups seeking to restrict private funding from safety evaluations would find their objectives blocked.4

Primary food processors urge EU to reject mandatory value-sharing

21 Aug 2017
Message — The group requests maintaining the status quo on value-sharing because they lack the flexibility to implement such systems. They reject mandatory unfair trading rules, arguing that legislative action creates unnecessary administrative complexities and burden.123
Why — The organization avoids increased compliance costs while protecting its narrow profit margins from regulatory interference.45
Impact — Small-scale farmers lose potential protections and profit-sharing mechanisms that would buffer them against price volatility.67