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STARCH EUROPE

Starch Europe represents the European starch industry, aiming to ensure a safe, sustainable supply of starch-based ingredients, plant-based proteins and fibers.

Lobbying Activity

Starch industry seeks lower energy costs and faster grid connection

9 Oct 2025
Topic — The EU strategy aims to accelerate renewable energy use in industrial heating and cooling.
Message — Starch producers request stable, low-cost power contracts and faster permits for electricity grid connections. They want EU funding to cover both new innovations and existing, scalable green technologies. The industry also asks for financial help to switch from gas to electricity.123
Why — These changes would lower production costs and prevent businesses from moving outside Europe.4
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Starch Europe urges lower power prices and faster grid access

9 Oct 2025
Topic — The EU consultation addresses barriers to electrification and decarbonizing energy demand.
Message — The association requests competitive electricity prices and faster grid connections for rural sites. They want funding for proven technologies and simpler, digitalized permitting processes for decarbonization.12345
Why — Lower energy costs and streamlined permitting would protect the sector's global competitiveness.6
Impact — Global competitors in China and the U.S. would lose their energy cost advantage.7
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Starch Europe Urges Compensation for Indirect Electricity Emission Costs

5 Sept 2025
Topic — The consultation reviews state aid rules for compensating industries for indirect carbon costs.
Message — Starch Europe requests that the EU update its eligibility list for state aid to include sectors facing high indirect carbon costs. They argue that current carbon price realities require a new assessment to prevent production from moving outside the EU. They also seek better consultation for industries near the eligibility threshold.12
Why — This would lower electricity expenses and provide the financial security needed for low-carbon investments.3
Impact — Other industrial sectors might suffer if these subsidies create unfair competition within the EU internal market.4
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Meeting with Koen Dillen (Head of Unit Agriculture and Rural Development)

4 Sept 2025 · Discussion on current market developments, priorities related to arable crops and CMO reform

Starch Europe Demands Simplified Reporting and Carbon Protections

8 Jul 2025
Topic — Legislative review of the EU Emissions Trading System and Market Stability Reserve.
Message — The industry requests simplified reporting methodology and a gradual phase-out of the Market Stability Reserve. They seek continued free allowances beyond 2030 and export compensation under the new carbon border tax.1234
Why — These measures would lower compliance costs and maintain the sector's global export competitiveness.56
Impact — General climate budgets lose funding if revenues are strictly ring-fenced for industrial sectors.7
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Starch Europe urges inclusion in future Innovation Fund calls

8 Jul 2025
Topic — A review evaluating the effectiveness of the European Union’s Innovation Fund operations.
Message — They request targeted inclusion in calls for underrepresented sectors like starch. They propose expanding the definition of innovation to include more mature technologies.12
Why — This would help the sector fund electrification and reduce its high carbon footprint.3
Impact — High-risk clean-tech projects may lose funding if the budget shifts toward mature industries.4
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Starch Europe urges EU to prioritize bio-based industrial investment

23 Jun 2025
Topic — The consultation seeks input on updating the European Union's bioeconomy strategy.
Message — The organization calls for the bioeconomy to be integrated into energy and climate policies to ensure affordable power for biorefineries. They recommend removing restrictions on using food crops for industrial purposes and setting binding targets for bio-based content in products. They also suggest using new breeding techniques and financial tools to enhance agricultural resilience and de-risk investments.123
Why — This approach would lower operational costs while creating guaranteed market demand for starch products.45
Impact — Fossil-based material producers would lose market share to renewable starch-based alternatives.67
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Meeting with Elena Panichi (Head of Unit Agriculture and Rural Development)

22 Apr 2025 · Info on the current and prospective trade situation between the EU and the US in the frame of Starch Europe’s Trade Working Group Meeting

Starch Europe warns mandatory contract revisions threaten industry stability

10 Mar 2025
Topic — Targeted amendments to EU regulations aimed at strengthening farmers' positions in food supply chains.
Message — Starch Europe opposes mandatory revision clauses for contracts longer than six months. They propose excluding wheat, maize, peas, and starch potatoes from this requirement. They also request a thorough impact assessment before these clauses are adopted.123
Why — Avoiding these rules protects producers from net losses and maintains long-term supply stability.4
Impact — Farmers lose the new legal right to renegotiate their prices when markets shift.5
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Starch Europe calls for simplified ETS activity level rules

9 Jan 2025
Topic — The consultation updates rules for adjusting free emission allowance allocations due to activity level changes.
Message — Starch Europe requests simplified procedures for heat benchmark sectors to avoid reporting complexity. They urge the Commission not to impose disproportionate administrative burdens on manufacturers.12
Why — This exemption would prevent expensive investments in measurement systems and reduce administrative compliance costs.34
Impact — The European Commission loses the granular data needed to accurately calculate industry carbon leakage risks.5
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Starch Europe warns Canadian duties undermine CETA trade objectives

25 Apr 2024
Topic — Evaluation of the economic, social, and environmental impacts of the EU-Canada trade agreement.
Message — The association wants the evaluation to account for Canadian duties on wheat gluten. They argue these measures harm trade relations and damage the agreement's objectives.12
Why — Mentioning these duties in the report could help restore lost market access for exporters.3
Impact — European starch producers suffer from reduced revenue due to the sudden collapse of Canadian exports.4
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Starch Europe urges flexibility in carbon permit allocation rules

2 Jan 2024
Topic — The European Commission is updating rules for distributing free greenhouse gas emission permits.
Message — The group wants investment payback calculations to be based on completed studies. They also request that emission-saving measures apply across different installations belonging to the same company.123
Why — This would help firms retain free permits while managing their technical and financial capacity.4
Impact — The environment loses if efficiency requirements are shifted away from specific polluting installations.5
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Starch Europe seeks priority access to carbon removal certificates

20 Mar 2023
Topic — This proposal creates a regulatory framework for certifying, monitoring, and verifying carbon removals.
Message — Starch Europe wants certificates from carbon farming used for scope 3 accounting. They request preferential access or first refusal for certificates generated in their chain.12
Why — This allows companies to claim removals within their supply chain and reduce emissions.34
Impact — Other sectors face reduced availability of carbon credits if agri-food firms get priority.5
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

20 Dec 2022 · ETS

Starch Europe urges flexibility in new industrial emissions rules

23 Jun 2022
Topic — The European Commission is revising rules to reduce industrial pollution and improve environmental health.
Message — The organisation recommends that environmental performance limit values remain non-binding to manage trade-offs between energy efficiency and waste levels. They also ask authorities to reconsider enforcing the lowest possible emission levels which may be unrepresentative. Furthermore, they call for clarifying the reversal of burden of proof regarding damage claims.123
Why — This would provide greater operational flexibility and reduce the risk of successful liability lawsuits.45
Impact — Local residents and environmental groups will find it harder to win compensation for pollution damages.6
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Response to Evaluation and revision of the Weights and Dimensions Directive

18 Feb 2022

Starch Europe, The European Starch Industry Association, would like to take the opportunity of this call for evidence to comment on Directive 96/53/EC. As an active member of the Primary Food Processors (PFP), Starch Europe fully supports the PFP position provided in reply to this call for evidence. 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

Starch Europe, The European Starch Industry Association, 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 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 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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Response to Carbon Border Adjustment Mechanism

18 Nov 2021

Please find attached Starch Europe contribution.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

As PFP member, Starch Europe fully supports the PFP position. In particular, we welcome the ETS proposal and remain committed to further reducing our emissions, but note several critical points in the proposal that could cause serious difficulties in our sector - The new ambitious linear reduction factor will likely lead, despite the higher maximum benchmark update rate, to the implementation of the CSCF, which requires all sectors to achieve the same reductions whatever the effort requested; - Increasing the maximum benchmark update rate would also seriously impact our industry, which considering past efforts is already stretched in terms of energy efficiency gains, making further emission decreases via measures such as replacing installations or sourcing renewable energy challenging; - We consider that the absence of free allocation for heat production from electricity might hinder efforts to electrify heat production in the industry e.g. electric boilers to replace gas-fired boilers; - The 25% reduction of free allocation foreseen in case of non-compliance with the energy audit recommendations is not aligned with the design of the ETS. One of the advantages of a cap and trade system is it incentivises the most impactful decarbonisation solutions. At EU or company level some sites have more emission reduction potential than others, meaning it may not always be efficient to force everybody to act at the same time. While understanding that the aim of this provision is to incentivise the uptake of low-carbon technologies, we therefore request to remove this conditional approach from the proposal; - We are concerned by the exemption from the scope of the Directive of installations where emissions from the combustion of sustainable biomass contribute to more than 95% of the total GHG emissions. Such installations would lose their free allowances when passing from an e.g. 85% to 95% biomass-emissions share, which is a disincentive to decarbonise. To reduce the impact of the above critical points and of current very high energy and carbon prices and to support our decarbonisation efforts, we ask the Commission to urgently - Support the decarbonisation of our processes via the use of low carbon electricity by -- supporting the upgrade and reinforcement of electricity grids to enable them to withstand the increased demand linked to electrification, in particular in rural areas where our industries are typically located; -- guaranteeing a viable and competitive price for electricity; -- reinforcing support measures for industries improving energy efficiency. - Ensure that the use of scarce solid biomass fuel is avoided where alternatives are available e.g. standalone power generation/district heating systems; - Ensure no overlap with the ETS system results from the application of the new ETS for buildings and transport. In the medium term, our members also believe that it will be essential to - Ensure higher availability, also in rural locations, of low carbon energy and carbon-neutral electricity and energy carriers such as sustainable and advanced biogenic fuels and renewable hydrogen, e.g. enabling the self-use of own-produced biogas/biomass without the obligation to comply with new sustainability requirements. We feel that envisaging a phase-out of solid fossil fuels by 2030 to support the ambitious targets of this proposal could be realistic; - Consider the critical role of the food sector and of primary processing especially as a vital link in the food chain and key bioeconomy actor. In view of preserving this sector, to consider specific measures to avoid it is affected by carbon leakage and delocalisation, e.g. as the availability of free allowances will decrease. In the longer term, the development of infrastructure for CO2 storage adapted to rural locations e.g. rail wagons, should also be supported. Finally, we support any action by the Commission to counter carbon leakage and safeguard our industry's competitiveness.
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Response to Policy framework on biobased, biodegradable and compostable plastics

26 Oct 2021

Starch Europe represents the EU starch industry both at European and international level. A crucial link between EU farmers and bioeconomy outlets, the European starch industry produces more than 15 million tonnes of high-quality ingredients, including starches and starch-derivatives, plant-based proteins and fibres, from its 75 starch production facilities in 19 EU Member States. This is extracted from over 24 million tonnes of primarily EU grown wheat, maize and starch potatoes, and serves a wide customer-base in both food, feed and industrial sectors. Through decades of constant innovation, and the incredible versatility of starch, the European starch industry is today seen as a pioneer in the European Bioeconomy, and as a zero-waste industry making full use of every part of the agricultural raw materials used, is an essential actor driving sustainability across the agri-food value chain. As an ingredient provider to the manufacturing of biobased plastics, we would like to share our views about this roadmap’s connection EU starch industry’s circular business models and the many outlets of Bioeconomy. Always a strong supporter of the EU Bioeconomy strategy and its action plan on all four bioeconomy outlets (food, feed, industrial and fuel), we welcome the Commission acknowledgement of the importance of the EU Bioeconomy in the delivery of both the Farm to Fork strategy and Circular Economy Action Plan objectives. Biorefineries are the cornerstone of the EU starch industry, valorising biomass, by- and co- products and waste feedstocks into added-value plant-based ingredients. 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. In this spirit, Starch Europe contributed to the CEN Technical Committee 411 as a liaison organisation in the definition of biobased products standards and their accounting supporting the elemental analysis which leads to determining the amount of carbon, oxygen, hydrogen, nitrogen and sulphur present in the product. Also important are references to credible ‘bio-based content’ certificates and labels based on the standard EN 16785‐1:2015, and the NEN certificate and label for bio‐based content certification scheme: http://www.biobasedcontent.eu/. Substituting fossil-based consumer products with bio-based ones is key to developing a sustainable economy based on renewable materials in Europe. Acknowledging that fossile must remain in the ground, substitution of fossil carbon is a positive feature in itself, as recognized by Ellen MacArthur Foundation as well as the World Business Council for Sustainable Development 2020 report “Circular Bioeconomy: The business opportunity contributing to a sustainable world”. Alternatives to fossil-based energies are not required to prove that the benefit of their substitution effect « goes beyond reducing fossil carbon use ». In view of the aforementioned reports, we would like to ask the Commission why this is required exclusively for alternatives to fossil-based plastics. The case studies annexed to JRC’s LCA study on alternative feedstock for plastic production use data of growing renewable raw materials outside the EU, e.g. corn in the USA or sugar cane in Brazil. To give the full picture, LCA studies must include a figure for the biogenic carbon that remains in the biobased products. Our view is that these shortcomings hamper their use for comparative purposes to base future policies. We would welcome further reflection and exchanges of views on this forthcoming framework.
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Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

14 Apr 2021 · To discuss the delegated act to be adopted under the Taxonomy Regulation

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

15 Mar 2021 · Delegated Act, Taxonomy

Response to Information and promotion measures for agricultural and food products in the internal market and in non-EU countries

9 Mar 2021

Together with their customers, Starch Europe members strive to offer convenience & diversity in plant-based food and drink products. Every year, the EU starch industry invests about 80 million € in research and development across the board. Through targeted innovation, the EU starch industry has developed a broad portfolio of valuable plant-based protein ingredients with high-protein content. These plant-based protein ingredients provide both functionality and nutritional qualities in a wide array of food and specialised feed applications. For a wide portfolio of plant-based protein products supplied by the EU starch industry, please see pages 2-4 of the EU starch industry’s position paper on plant-based protein products (https://starch.eu/priority/the-key-contribution-of-the-eu-starch-industrys-plant-based-protein-products/) page 7 is dedicated to Starch Europe’s recommendations in the EU’s promotion policy. The EU Plant Protein Plan and Member States’ plans focus on the growing of the protein crops themselves and overlook the processing steps and circular economy principles of starch biorefineries which convey not only convenience but also ensure all consumers the access to affordable, nutritious ingredients and foods. We call on the Commission to take a farm-to-fork approach and integrate the value of the first processing of cereals and plant protein crops, helping address the consumers’ request for sustainable, convenience & diversified plant-based protein products. Today, we understand that plant-based food and drink products are not eligible to promotion measures under Regulation 1144/2014. They are neither included in Annex I TFEU, nor in the Annex 1 to Regulation, pending clarification of the definition of Annex I point (d) “beverages made from plant extracts”. In line with the objectives of Regulation 1144/2014, of the “Beating Cancer” plan and of the Farm-to-Fork strategy debated during today’s Commission Civil Dialogue Group meeting, we believe that all plant-based food and drink products made from cereals and plant protein crops should be eligible under the EU information provision and promotion measures. In the context of agronomical, climate, environment and food security challenges, we believe that plant-based food and drink products have a key role to play. We understand the initial focus of promotional measures on agricultural products. However, to bring more European consumers towards plant-protein nutrition, these consumers need to be made aware of the ready-to-use, convenient food products that are available on the market. Raising awareness about these products would make it easy for consumers to incorporate more high-quality EU-grown plant-protein in their diet. Plant-protein food products can indeed be an entry point for ‘new’ flexitarians who are just starting to discover the variety of plant protein agricultural and food products. As the Agrosynergie study demonstrated, the demand for plant-based proteins is driven by the increasing numbers of vegan, vegetarian & flexitarian consumers in Europe. This demand is also driven by a need for these consumers to have access to more convenient plant-protein based food products that are easier and quicker for them to prepare at home. That is precisely why processed agricultural plant-protein products must be an integral part of the future promotion policy. To conclude, Starch Europe favours option 2 and calls on the Commission to adapt the list of eligible products “in line with the Farm to Fork Strategy and Europe’s Beating Cancer plan”. To that end, the forthcoming legislative proposal should extend the list of eligible products contained in Annex I of Regulation 1144/2014 to include: - Plant-based protein food products - Plant-based drinks with a minimum protein content of 2.8 mg / litre. For more information, please see the letter sent by ENSA, EUVEPRO and Starch Europe to the Commission on 17 May 2019.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Starch Europe would like to express its 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 the sector and to its ability to contribute towards climate change mitigation and adaptation. In the attached position, we lay out our reasoning why we believe it is essential 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, that constitute key outlets to the EU starch industry. More generally, the references and criteria for agricultural raw materials will have to be consistent with other EU regulations. The starch industry does not only produce starch. The over-riding objective of starch producers is to valorise all the components of the agricultural raw materials it extracts and processes and produce minimal waste; less than 1% is not valorised. During the starch production process, the European starch industry also produces 5 million tonnes of valuable oil, fibres and proteins which are used for both animal and human nutrition. The more starch the industry produces, the more protein and fibre-rich co-products it produces, thus providing high quality feed and helping to compensate for the EU’s structural deficit in plant proteins. Ever since the starch industry began, starch has been associated as much with its non food uses as with food ones. The first historic references to starch, which date back to 4000 BC, describe its use by the Egyptians in strengthening papyrus. Its use as an adhesive in paper persists to this day, with the starch content of some modern day paper being up to 10%. Starch is renewable and biodegradable. As such it is a well-suited raw material for the sustainable use of agricultural products in the bio-based industry, replacing fossil-fuel-based ingredients, in the fermentation, construction, chemical, cosmetics, plastics and detergent industries. Innovation in a broad portfolio of valuable plant-based protein ingredients with high-protein content, provide both functionality and nutritional qualities in a wide array of food and specialised feed applications. EU Regulation 2020/852 provides that the Commission should take into account “relevant Union law”, but we note many inconsistencies and contradictions between the consequences of this draft delegated act if no changes are made, and EU statements and policies as detailed in the position paper The criterion that “Food or feed crops are not used as bio-based feedstock for the manufacture” of these biobased ingredients, is of great concern to Starch Europe because of the repercussions such wording would have in terms of investments, access to finance and forthcoming policies. 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. It is precisely because the starch industry is not dependent on any one final product or any one final outlet for its products (see process flow chart enclosed), that it has successfully developed over many centuries. Reaching a nearly zero-waste threshold also requires all the outlets of the bioeconomy. This has not only benefitted the starch industry itself, but also its customers and the many farmers who depend on it both as a consistent and reliable user of their produce in times of fluctuating food prices, and as such, as an essential contributor to the balance of crop rotation in the field.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

With cogeneration (simultaneous generation in one process of thermal and electrical or mechanical energy), starch plants replace a separate heat-only boiler and full grid power purchase with a solution reducing in many cases CO2 emissions by up to 30%. Although cogeneration (CHP) is currently not considered to be subject to carbon leakage due to its local/regional nature, it is in competition with less sustainable technologies not covered by the EU ETS, creating the possibility of 'internal carbon leakage'. We believe the EU ETS Phase IV framework still fails to correct this distortion, making it more expensive for the starch industry to reduce GHG emissions and undermining efforts to deliver on the EU GHG emissions reduction target for 2030. We suggest that the EU ETS revision considers: 1.Removing CHP systems from the definition of 'electricity generator' (similarly to what is done for installations which carry out activities listed in Annex I). Industrial CHP is usually installed to cover on-site heat and electricity demand. While most of the electricity is self-consumed, some residual electricity (usually small amounts) is being injected to the grids. Therefore, the industrial site is not specialized in power production and sale to the market. Yet, if not covered by Annex I, such a site would be considered as an 'electricity generator', which may entail a loss in free allocations. This penalizes energy intensive industries that choose CHP to improve their carbon efficiency. An extra definition could be added in Directive 2003/87/EC to cover ‘CHP generators’ whereby the electricity generated on site needs to be in part self-consumed and the balance if any is then allowed to be sold to third parties. Importantly, industries producing electricity by CHP may only include the lack of free allocation for electricity production costs in the price of electricity sold, if any, but it is not possible for them to recover costs related to the absence of free allocation to heat production emissions as well as fuel benchmark emissions. 2.Ensuring that free allocation to high efficiency CHP is delivered through an adequate heat benchmark so that the full potential of this carbon reducing technology is recognised. The heat benchmark update between EU ETS Phases III and IV could lead to a significant reduction of free allocation to CHP. We believe that in case the phase IV heat benchmark takes biomass into account in the 10% highest performing heat supply solutions, it will not provide the best incentives for GHG reductions nor reflect real technological progress. Indeed, accounting for biomass encourages a massive switch to biomass, a fuel not readily and widely available. Furthermore, in case there is a change in the underlying methodology for accounting CHP heat emissions between Phases III and IV, with more emissions being allocated to electricity and fewer to heat, a correction factor should be introduced to ensure consistency between the two phases. Failing this, improvements in the CHP carbon efficiency would be overestimated. The result would be a lower heat benchmark despite no real improvement in carbon efficiency or higher uptake of CHP, which would reverse any competitive advantage of CHP over less efficient heat generators. 3.Minimising the risk of distortion of competition in the internal market between ETS and non-ETS sectors by applying equal treatment to heat from a boiler with capacity below 20MW, not covered by EU ETS, and from equivalent CHP installations of approximately 20-35MW, covered by stricter conditions under the ETS. In addition to the comments above, we strongly suggest to review the ‘electricity generator’ definition in Directive 2003/87/EC to avoid that it covers installations which in our view should no longer be considered electricity generators e.g. installations at which it is no longer physically possible to generate electricity or which do not produce electricity for sale since extended periods.
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Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

28 Oct 2020 · Starch Europe, "How can the starch industry contribute to a more sustainable food system?", virtual event bringing together high-level panelists to discuss opportunities and challenges of starch industry.

Response to Carbon Border Adjustment Mechanism

1 Apr 2020

Starch Europe raised at several occurrences that the stricter environmental policies implemented in the EU weigh on the competitiveness of the EU starch industry globally, and regrets the lack of a global playing field with other trade partners. The EU starch industry is covered by the Emission Trading Scheme Directive (ETS), and part of the Carbon Leakage List that identifies sectors at risk of relocation outside the EU, as a result of their high energy intensity and trade exposure. Starch Europe supports the continuation of the ETS and of the Carbon Leakage List until a relevant and at least equivalent Carbon Border Adjustment Mechanism (CBAM) is implemented. As for all trade-related issues, Starch Europe is a strong supporter of a WTO-compatible multilateral approach to secure a fair trading environment, that benefits all trade partners. Until an international carbon market is agreed upon and implemented, proper carbon leakage measures must remain in place to protect the EU industry. The carbon content of starch products falling under the same (8 digit) CN code can significantly differ. Benchmarks will need to be adjusted to assess the carbon content of starch products at a more precise level that 8-digit CN codes. Finally, Starch Europe supports a mechanism that would correct the increasing competitiveness gap that currently results from the lower carbon emission allowances granted to sectors falling under the ETS. The mechanism should compensate for the cost of carbon emissions and take into account the energy efficiency and the sensitivity of sectors.
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Response to Farm to Fork Strategy

16 Mar 2020

Starch Europe welcomes the opportunity to input into the Farm to Fork consultation and is a strong supporter of the holistic approach being proposed. EU starch producers will be key enablers in the move towards a more sustainable food system. EU policies need to reflect the sector's potential and challenges. With that policy support the EU starch sector can play an even larger role in, inter alia, increasing transparency, meeting changing consumers needs, developing a more efficient and sustainable food system and supporting EU farmers, whilst maintaining food security and food safety. We look forward to working with the European Commission and other stakeholders on detailed proposals to help improve the sector's contribution further. Starch Europe's detailed preliminary comments are attached.
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Response to European Partnership for a Circular bio-based Europe

27 Aug 2019

The EU starch industry processes about 23 million tonnes of EU-grown agriculture raw materials (mainly wheat, maize and starch potatoes) serving the four outlets of the bioeconomy, food, feed, industrial and energy with sustainable and added value ingredients (www.starch.eu). Starch Europe welcomes the increase in research and innovation funding and supports the Commission’s proposal on Horizon Europe, the most ambitious research programme ever, to dedicate 10 billion euros to food, agriculture, rural development and the bioeconomy. With the objective of scaling up and strengthening the existing value chains, and unlocking investments and markets for bio-based products, Starch Europe fully supports the continuation of the public private partnership over the next 2019-2024 period. As this form of partnership would provide stakeholders with a stable, long-term and predictable investment and legal framework in the EU, Starch Europe advocates for the continuation of the same type of partnership as the current BBI JU, i.e. “An institutionalised European Partnership (option 2) based on Article 187 TFEU, in the form of a Joint Undertaking, would create a long-term dedicated implementing structure representing the deepest level of integration, engagement and up-front commitment, including a financial commitment, from partners”. In the spirit of FOOD2030, this future partnership must instigate a greater number of food-oriented projects including plant protein products. It is essential to integrate proteins as food ingredients into the future Horizon Europe, thereby contributing to the first of the FOOD2030’s four priorities: nutrition. An increase in availability of plant protein can also help reduce the non-communicable diseases and environmental impact of food production and consumption. Consumers trends are driving the demand for plant protein products in their transition towards a more plant-protein based diet. The EU plant protein plan identified as particularly promising the “market for meat and dairy alternatives, with annual growth rates of 14% and 11% respectively”. This demand is also driven by a need for these consumers to have access to more convenient plant-protein based food products that are easier and quicker for them to prepare at home. Starch Europe calls onto the Commission to resolve the legal vacuum of plant protein products in the EU promotion policy Regulation 1144/2014. The EU starch industry contributes to EU’s supply of varied sources of protein-rich products (about 5 million tonnes every year) with: - Medium proteins (15%-30%) to feed outlet - Super proteins (60%-90%) to food and feed outlets On top of animal feed, our industry's plant protein products go to innovative applications such as - Food: Bakery - Specialised nutrition: sports, elderly, meat alternatives, hospital special diets - Specialised feed: aquaculture, poultry, pet food The circular bio-based Europe Joint Undertaking could support the innovation at each level of the plant based-value chain, from farm to fork, through research and innovation funding in e.g. : o seeds to achieve better and more stable yields and greater disease resistance in protein crops o the know-how on the functionality, quality and consistency of starch-protein-products in food applications o the process to extract proteins and to convert plant proteins to, for example, animal protein alternatives. To conclude, the Circular Bio-based Europe public private partnership would help support the industrial development in the EU of a sustainable and competitive supply chain for all existing plant-based proteins and potential new sources of proteins produced on the European territory and engage with the farmers growing the EU starch industry’s key protein crops in a true value chain approach.
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Response to Amendment of products and substances allowed in organic production

1 Aug 2019

With this feedback we would like to request an addition under Annex IV ('Annex VIII) of the proposed draft, section Section B — processing aids and other products, which may be used for processing of ingredients of agricultural origin from organic production. For the entry "sodium hydroxide", we suggest to add in the column "Specific conditions and restrictions in addition to Regulation (EU) No 1333/2008" the following possibility: "for starch(es) production". The text would then read "Sodium hydroxide X With regard to foodstuffs of plant origin: for sugar(s) production;for oil production excluding olive oil production;for the preparation of plant protein extratcs; for starch(es) production"
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Response to Commission Regulation setting maximum residue levels for chlorate in or on certain products

18 Feb 2019

Starch Europe members welcome the opportunity to provide feedback on the Commission proposal for a Commission Regulation amending Annex III to Regulation (EC) No 396/2005 of the European Parliament and of the Council as regards maximum residue levels for chlorate in or on certain products. Please find in the attached document our comments on this proposal.
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Response to Revision of the ETS State aid Guidelines

17 Jan 2019

Starch Europe members welcome the proposal from the Commission to revise the Commission guidelines on certain State aid measures in the context of the greenhouse gas emission allowance trading system post-2020. The EU ETS impacts starch production installations in the EU, and the starch industry deeply regretted the lack of possibilities for compensation of indirect ETS costs during phase III of the EU ETS. Starch Europe members therefore welcome the foreseen possibility to better protect sectors recognised as being at a significant risk of carbon leakage. This possibility will be highly relevant for the starch industry for the period 2021-2030; the revised EU ETS Directive (Directive 2018/410/EU) confirmed that the manufacture of starches and starch products is facing and will face for the decade to come a significant risk of carbon leakage. Additional threats will be faced for the period 2021-2030 such as the impact for the sector of the revision of the fall-back benchmarks, which as currently discussed will lead to under-allocation. Possibility to be compensated for indirect ETS costs will therefore be key to properly protect the industry from cumulative ETS impacts. In the spirit of the above, Starch Europe welcomes the option, mentioned in the roadmap to assess eligibility to compensation, to use the so-called Carbon Leakage list that already identifies sectors deemed at risk of carbon leakage. All measures foreseen to avoid Carbon Leakage should indeed be available to sectors that are deemed at risk of Carbon leakage. Starch Europe considers an utmost necessity to review the list of sectors exposed to a significant risk of carbon leakage due to indirect emission costs, taking into consideration, at the very least : • An eligibility based on the combination of trade intensity and (multiplied by) indirect emission intensity factors and not separate criteria’s, in order to limit threshold effects; • Incorporating into indirect emission intensity factor the carbon cost linked to auto-consumed electricity. This because emissions from self-produced, self-consumed electricity are not eligible for compensation by free allowances and hence have effects on the carbon leakage risk in all aspects identical to indirect emissions cost passed on by electricity providers (for electricity purchased on the grid). This would avoid particularly penalising installations/sectors that invested in energy-efficient, less carbon intensive technologies such as Combined Heat and Power generation. A number of consultation steps are described in this Commission roadmap. Starch Europe intends to contribute to these consultation processes and asks the Commission to already consider Starch Europe as a key actor when planning targeted/sector specific assessments for the revision of the guidelines on EU ETS indirect costs related State aid.
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Response to Free allocation of emission allowances

23 Nov 2018

We note that the Commission proposal for FAR outlines the methodology for the update of the fall-back (heat and fuel) benchmarks based on the data collection to take place in 2019, collecting data for years 2016-2017. Starch Europe is concerned that the results of the data collection will be compared to a proxy approach used in 2008 (use of the Energy Efficiency Directive Harmonised Reference Value for heat production). This is expected to lead to maximum reduction of the heat benchmark that would not reflect the real technological progress that occurred between 2008 and 2017, which the benchmarks update is supposed to reflect. In addition, Starch Europe is concerned about the equation (11) proposed in Annex VII part 8 of the proposal for FAR. This equation was developed to calculate energy savings from a cogeneration installation – CHP – compared to a separate production of heat and electricity. It is not adequate to allocate the right amount of CO2 emissions to the heat production of a CHP, over-allocating emissions to the electricity production and under-allocating emissions to the heat production. This will lead, when used for the heat benchmark update, to an unrealistically decreased heat benchmark. Most importantly it also sets an unfortunate precedent as it overestimates the CO2 emissions savings of CHP installations, de facto overestimating the CO2 costs savings of CHP installations. This leads to a reduced incentive to invest in CHP installations, despite both the ETS Directive and the Energy Efficiency Directive mentioning CHP as a solution to increase energy efficiency and decrease carbon intensity. This is counterproductive, as it might lead to an overall decrease in energy efficiency, while the EU also sets targets to increase energy efficiency. More coherence should therefore be sought in the development of the EU climate and energy policies, and the Commission should take this into account when finalising the FAR.
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Response to Legal act to apportion certain concessions between the EU and the United Kingdom (Brexit preparedness)

16 Jul 2018

Generally speaking, there are two Tariff Rate Quotas of relevance to the European starch industry in the Brexit preparedness exercise: 1. The tariff rate quota of Manioc Starch (10 000 tonnes) opened to all third countries (Erga Omnes) for exporting Manioc Starch at a reduced duty (66€/tonne) to the EU. 2. The tariff rate quota of Manioc Starch (10 500 tonnes) devoted to Thailand for exporting Manioc Starch at a reduced duty (66€/tonne) to the EU. While the draft COM 2018 (312) proposal reports on the first quota of manioc starch (Erga Omnes) in the Annex to the Commission’s proposal, it does not include the second quota devoted to Thailand. Starch Europe therefore calls on the Commission to include, in the Brexit preparedness exercise, the existence of this tariff rate quota of Manioc Starch (10 500 tonnes) devoted to Thailand for exporting Manioc Starch at a reduced duty (66€/tonne) to the EU, order number 090125. We would be grateful if you could take our suggestion on board, and remain available for any question you may have.
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Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

7 May 2018 · Challenges of the EU starch industry

Response to Revision of the Drinking Water Directive (RECAST 2017)

30 Mar 2018

Starch Europe members took note of the Commission proposal for a revision (RECAST) of the Directive on the quality of water intended for human consumption (so called Drinking Water Directive), and would first like to thank the Commission for the opportunity to share their feedback on this proposal. Changes to the current directive were identified, that would have consequences that are not yet fully understood. Starch Europe members felt, when reading the draft proposal, that some ambiguity could arise from the proposed changes on the scope of the Drinking Water Directive (article 2 on definitions and article 6 on the points of compliance). In particular, the status of water used in in the production of food seems unclear. On the one hand we note that in the definition of water for human consumption, point b (water use in food production undertakings) is proposed for repeal. On the other hand the remaining part of that definition covers water “intended for drinking, cooking, food preparation or production, or other domestic purposes “in both public and private premises” (changes emphasised in bold). The addition of the word “production” may be read as covering the food industry, while the fact that this word is followed by “or other domestic purposes” suggest the contrary. Starch Europe members also wonder what will be the impact of the changes proposed on article 6 on the point of compliance. Clarification on the scope of the proposal would therefore be welcome. Starch Europe members would like to remind the Commission of the importance of water in the processes of the food industry, and in particular of the starch industry. It must be considered that starch plants not only use important volumes of water, but also source a significant part of their process water themselves. Water used in starch processes, that are not coming from distribution networks, can come from wells or surface waters. Independently of its origin, process water in the starch industry can also be additionally treated within the starch plants. Water can also be recycled to be used again in the processes. We fully understand that water used in food processing is covered by Regulation 852/2004 (on the hygiene of foodstuffs) but avoiding conflicts with the Drinking Water Directive is of special importance to us. It is therefore of paramount importance that food business operators, including Starch Europe members, are informed and consulted during the Drinking Water Directive revision process, as it is a piece of legislation that, to some extents, covers water used for food production.
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Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

24 Jan 2017 · Bioeconomy

Meeting with Elżbieta Bieńkowska (Commissioner) and

1 Mar 2016 · Circular economy

Meeting with Elżbieta Bieńkowska (Commissioner) and

1 Mar 2016 · world-leading, smart, sustainable & competitive bioeconomy

Meeting with Jean-Luc Demarty (Director-General Trade)

20 Nov 2015 · On-going trade negotiations

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu) and European agri-cooperatives

18 May 2015 · EU bioeconomy policy

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan), Tom Tynan (Cabinet of Commissioner Phil Hogan)

12 Mar 2015 · Market developments in potato starch, isoglucose quota, tapioca starch

Meeting with Christian Burgsmueller (Cabinet of Vice-President Cecilia Malmström), Maria Asenius (Cabinet of Vice-President Cecilia Malmström)

17 Feb 2015 · Various ongoing trade negotiations

Meeting with Carlos Moedas (Commissioner) and European farmers and

2 Feb 2015 · Meeting with the European Bioeconomy Alliance on the Bioeconomy Strategy