SEA SALT EUROPE
SEA SALT EUROPE
SEASALT Europe is the European organisation of Sea Saltworks.
ID: 141305050811-77
Lobbying Activity
Response to Modification of rules on organic trade and simplification
18 Nov 2025
SEASALT Europe appreciates the opportunity to contribute to this Call for Evidence regarding the targeted amendment of the Organic Production Regulation (EU) 2018/848. We highlight that a significant share of our members holds certification under Regulation (EU) 2018/848. Since the inclusion of "sea salt and other salts for food and feed," approximately 100 operators can be consulted on the TRACES system. This reflects strong consumer demand for natural, environmentally supportive organic salt. We share the Commission's strategic objective of simplifying the regulatory framework and expressly support the initiative's approach of seeking a targeted and limited adjustment to remove unnecessary complexities. We stress that any simplification efforts must never lead to a reduction in the required standards for environmentally sustainable production. Furthermore, we strongly urge the Commission to keep the amendment process exclusively focused on solving the problems already identified and the specific complexities outlined in the Commission's documentation. Maintaining this specific, targeted focus is crucial to ensure the essential stability of the rules and reinforce trust in the organic system. Our detailed position is outlined in the attached document.
Read full responseResponse to Food and Feed Safety Simplification Omnibus
8 Oct 2025
SEASALT Europe supports the objectives of the European Commission's Omnibus Initiative regarding simplification and competitiveness. However, we consider that these goals are severely compromised by the current application of the Biocidal Products Regulation (BPR), which imposes disproportionate requirements on our sector's predominantly SMEs. Our contribution respectively urges the Commission to consider our proposals as part of this crucial streamlining effort, noting that the urgency of the issues is underscored by the anomalies already detected by the European Commission itself. In this document, we identify three critical regulatory anomalies for which we propose specific solutions. First, the Regulatory Incongruity arising from erroneously equating sea salt (a foodstuff/feed and natural precursor) with a conventional biocidal product, creating a legal collision. To avoid this, we consider necessary to define a Specific Approach for Natural Precursors. Second, we consider there is an incongruity in Responsibility Assignment and Costs due to the responsibility for Biocidal Product Authorisation being unjustly transferred to precursor producers (SMEs), which results in a prohibitive cost structure that distorts the Internal Market. A Clarification of Responsibility (to the manufacturer of the electrolysis device) and a Proportional Adjustment of the Cost Structure tailored to the entity's size is proposed in this regard. Finally, Non-Compliance with Deadlines in the initial validation phase is highlighted since it paralyses SME commercial expansion. This could require the Extension of the Legal Safeguard (analogous to BPR Art. 31(5)) to the initial authorisation phase. Rectifying these dysfunctions would promote SME competitiveness and align with EU legislation overall "One Health" vision. Please, find attached the document containing the detailed arguments and proposals.
Read full responseResponse to Import into the Union of high-risk organic and in-conversion products
7 Jul 2025
Please find attached SEASALT Europe's official contribution to the draft Commission Delegated Regulation (EU)/ amending Delegated Regulation (EU) 2021/1698. As SEASALT Europe, representing predominantly small, family-owned businesses, we are dedicated to advocating for the quality and sustainable production of European sea salt. We welcome the Commission's proposed amendment concerning import controls, recognizing its significance. However, our key focus in this contribution underscores the critical need for equally robust organic controls within the European Union itself. Our detailed contribution, thoroughly outlined in the attached document, highlights several crucial areas: Improved Internal EU Organic Controls: We urge the Commission to establish more direct and effective complaint mechanisms for consumers, specifically addressing internal EU organic non-compliance. Harmonized Organic Rules: The current lack of consistent organic production rules for products such as sea salt regrettably leads to varied interpretations and, potentially, the issuance of non-compliant certifications. Mandatory Certificate Validation: To safeguard the integrity of the EU organic label, we propose the implementation of a mandatory prior validation for all organic certificates by an independent authority before their upload to TRACES. We firmly believe that these measures will significantly strengthen the overall integrity and effectiveness of the EU organic system.
Read full responseResponse to Adaptation of ECHA fees to inflation
17 Mar 2025
SEASALT Europe, representing European sea salt producers, expresses its opinion on the proposed amendment to Regulation (EU) No 564/2013 regarding biocidal product fees. While we acknowledge the importance of adjusting fee structures, particularly to ensure equitable treatment for Small and Medium-sized Enterprises (SMEs), we wish to draw attention to critical concerns regarding adherence to regulatory timelines, the significant impact of administrative delays on small businesses, and the classification of sea salt within the Biocidal Products Regulation (BPR). We respectfully emphasize the following key areas for consideration: Fee Structure: Ensuring fairness and proportionality in relation to enterprise size. Regulatory Timelines: Upholding the integrity and predictability of evaluation processes. Sector Challenges: Addressing the unique circumstances faced by the sea salt sector. Compensatory Measures: Implementing equitable solutions to mitigate the effects of delays. Ad Hoc Working Groups: Facilitating efficient resolution of complex evaluation issues. We propose specific compensatory measures and respectfully urge the Commission to prioritize the enhancement of evaluation processes. For a detailed exposition of our position, please refer to the document. We thank you for your attention to these important matters and remain at your disposal for any further clarification or discussion.
Read full response14 Oct 2024
SEASALT Europe appreciates the opportunity to provide feedback on this Draft Implementing Regulation and Annex. We understand that specific rules in Annex II of Reg. (UE) 848/2018 facilitate controls for imported products, but we are concerned about the broader category g) of 'Other products listed in Annex I.' The lack of specific rules for certain products, such as "sea salt and other salts for food and feed", could lead to inconsistent interpretation and enforcement. This could create unfair competition and undermine consumer trust in organic products. We urge the Commission to develop clear and enforceable guidelines for these products to ensure the overall coherence of organic production."
Read full responseResponse to Modifying provisions relating to the promotion of agricultural products
17 Sept 2024
SEASALT Europe is the European Sea Salt Works Association that represents the interests of the sea salt producers before European institutions. Our mission is to promote recognition, quality, and sustainability of European sea salt, sourced from the sea through evaporation exclusively driven by wind and sun. Regarding the draft COMMISSION DELEGATED REGULATION (EU) /...of XXX amending Delegated Regulation (EU) 2015/1829 supplementing Regulation (EU) No 1144/2014 of the European Parliament and of the Council on information provision and promotion measures concerning agricultural products, SEASALT Europe would like to advocate for the inclusion of sea salt within the scope of Article 157 of Regulation (EU) No 1308/2013. This would enable the entities listed in Article 7 of Regulation (EU) No 1144/2014 to submit proposals for EU co-funded information and promotion programs for sea salt. Sea salt, a natural and essential food produced sustainably, is often overlooked due to its unique mineral origin (neither vegetable nor animal). Despite its importance and cultural heritage, sea salt production faces challenges due to a lack of specific recognition within EU policies. Sea salt production shares strong ties with agriculture, unlike other type of salts, with processes dependent on natural resources and local ecosystems. The inclusion of sea salt in the regulation would recognize its value, protect associated ecosystems, support European sea salt producers, and ensure the future of this sustainable practice. Detailed arguments supporting this position are provided in the accompanying document. We remain at your disposal to provide any further clarification or information you may require.
Read full responseResponse to Import into the Union of high-risk organic and in-conversion products
21 Jun 2024
SEASALT Europe welcomes the opportunity to provide comments on the proposed Commission Delegated Regulation amending Delegated Regulations (EU) 2021/1698 and 2021/2306 regarding the controls of high-risk product consignments intended for import into the Union as organic or in-conversion products. SEASALT Europe expresses its confidence that the European Commission's proposal is based on a thorough assessment and does not jeopardize the integrity of the EU's organic product control system. Streamlining physical checks and sampling for certain high-risk products, when implemented responsibly and strategically, can offer efficiency and cost benefits without compromising product quality and safety. However, it is paramount to ensure that the reduction in controls does not translate into diminished vigilance and compliance with the stringent EU organic standards. Robust control measures must be maintained to guarantee that only products meeting EU requirements enter the market. SEASALT Europe appreciates the inclusion of a list of high-risk products, countries of origin, and specific control percentages for each product. This transparent information is essential for ensuring consistency and effectiveness of controls across the EU. While supporting the reduction of physical checks and sampling for some products, SEASALT Europe suggests redirecting the freed-up resources towards more comprehensive controls on products and countries that have exhibited a higher non-compliance rate in the past. This targeted approach would strengthen controls where most needed without neglecting overall market protection. In summary, SEASALT Europe endorses the European Commission's proposed approach, provided it is implemented with appropriate safeguards to ensure that the integrity of the EU's organic product control system remains uncompromised. The combination of a high-risk product list, specific controls, and strategic resource reallocation can lead to a more efficient and effective system without sacrificing the quality and safety of organic products.
Read full response14 Jun 2024
Thank you for the opportunity to provide our comments on imports of organic products certification and checks of certain operators in non-EU countries. We support the extension, as we believe it is preferable to allow more time to ensure that all control authorities are fully aware of the new requirements. However, we would like to draw attention to the significant changes introduced by Regulation 848/2018 compared to the previous Regulation 834/2007, particularly with regard to the scope of products covered, such as "sea salt and other salts intended for human and animal consumption." Our sector is concerned that imports of this product may not comply with the requirements of Regulation 848/2018, especially in the absence of detailed production rules in a delegated act. The potential for varying interpretations among European control bodies, and even more so among control bodies certifying products from non-EU countries, raises concerns about the transparency and credibility of these certificates. To address these concerns, we propose the following: Strengthen cooperation and information exchange among control bodies. This would facilitate the sharing of best practices and ensure that all control bodies are applying the Regulation in a consistent manner. Conduct targeted training for control bodies on the new requirements of Regulation 848/2018. This would ensure that control bodies have the necessary expertise to effectively enforce the Regulation. We believe that these measures would help to ensure the implementation of Regulation 848/2018 and maintain the high standards of organic production in the EU. Thank you for your consideration.
Read full response