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SYNDICAT NATIONAL DES INGREDIENTS AROMATIQUES ALIMENTAIRES

SNIAA

Les Fabricants, les Négociants, les Transformateurs et Mélangeurs de matières aromatiques, et produits assimilés à destination des industries de l'alimentation et des autres industries constituent un Syndicat professionnel régi par le Code du Travail (Livre Ier – Art.

Lobbying Activity

Response to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)

13 May 2025

SNIAA (French Flavour Association) represents flavour houses in France, small, medium size and large companies producing food flavourings. SNIAA is member of the European Flavour Association (EFFA). Flavourings are essential food ingredients that contribute to safe, sustainable and enjoyable food choices for consumers. By fostering innovation and regulatory excellence, flavourings support a competitive and diverse European food industry. We welcome the opportunity to provide input on the draft Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 on deforestation-free supply chains (EUDR). Our members remain committed to supporting responsible sourcing practices and sustainability objectives. We also welcome proportionate and pragmatic regulations allowing for a workable implementation for market players operating throughout complex international value chains. We welcome several clarifications introduced in the draft Delegated Regulation, which we believe address important technical and interpretative issues previously identified by multiple industry stakeholders. 1. Clarification on product samples (Recital 5): The explicit exclusion of product samples used for testing, analysis, or the solicitation of commercial orders is a welcome clarification. These types of samples are essential to the daily work of the flavour industry and play a key role in innovation, product development, regulatory validation, and quality assurance processes. They are generally not placed on the market as independent commercial products, and they often have no marketable value on their own. Requiring full due diligence documentation for such items would impose a disproportionate administrative burden and potentially hinder innovation. Moreover, we would recommend that relevant Commission guidance (i.e. the FAQ document) be updated accordingly to reflect the exemption more fully and consistently across all relevant sections. 2. Packaging and accessory materials (Recital 6 and related Annex changes): We acknowledge the clarification that packaging materials and containers used exclusively to support, protect, or carry another product placed on the market are not considered in scope. Similarly, the exclusion of accessory items such as user manuals, leaflets, catalogues, and marketing materials when accompanying a product is helpful. These components are typically integrated with the main product and not placed on the market independently. Their exemption reflects commercial reality and avoids unnecessary due diligence obligations for items that pose minimal risk in terms of deforestation-linked commodities. 3. Second-hand and reusable materials: The explicit exclusion on used and second-hand products, including packaging and transport materials such as pallets that are clearly suitable for repeated use, is a pragmatic and proportionate step. Many companies in the flavour sector use pooled or returnable pallet systems as part of a broader circular economy approach. Ensuring that such materials are excluded from scope where they are reused in closed loops or presented alongside the primary product is both practical and environmentally coherent. We thank the Commission for its consideration of stakeholder input during the preparation of the draft Delegated Regulation and remain available for further dialogue as implementation continues.
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Response to Introducing new hazard classes–CLP revision

18 Oct 2022

Please see the contribution attached.
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Response to Setting of nutrient profiles

3 Feb 2021

Please find attached the contribution from SNIAA (French Flavour Association).
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Response to Flavourings - as regards certain flavouring substances

24 Nov 2016

SNIAA is the association representing the companies producing food flavourings in France. A large majority of these companies are small and medium size companies. As a member of EFFA, the European Flavour Association, SNIAA supports EFFA comments on the Commission Draft Regulation aiming at defining numerical restrictions for the use of the flavouring substances of the FGE.203rev1 in food categories. SNIAA considers that the adoption of these draft measures will not lead to the expected target of improvement of the consumers’ health. On the contrary, it will create an important unjustified additional burden for economic operators. Furthermore, this draft is adopted following a procedure in contradiction with the existing legal rules. As a matter of fact, SNIAA considers that the draft regulation in reference: • Will not lead to any improvement of the consumers’ health. The attention of the reader should be drawn on the fact that these substances have a long history of safe use and that they have been approved by different safety evaluation authorities such as JECFA, the FEMA experts panel and the US FDA. In the frame of the EU substances evaluation program and as a follow up of the EFSA opinion published in April 2014, EFFA has sent to the Commission adequate complementary data resulting from new toxicological studies. SNIAA and EFFA are confident that these complements will make it possible for EFSA experts to finalise the risk assessment of these substances as laid down in the EU official procedure. In concrete terms, SNIAA expects that the safety of these substances will be reconfirmed in 2017. • Does not comply with the regulatory procedural frame of elaboration and modification of the list of flavouring substances. According to the Regulation (EU) No 872/2012, the Union List includes already assessed substances as well as substances still under assessment. These latter substances are authorised and may continue to circulate during the time of their assessment. This principle is concretely implemented by the “footnote” approach in the Union List. These provisions provide all necessary transparency and legal certainty regarding the situation of flavouring substances. • Will create important and unnecessary administrative and financial burden for flavour companies. As the limitation are numerical, companies will be compelled to change labels and technical documentation so as to provide their customers with adequate information (use and levels of 20 substances of the FGE.203rev1). A large number of flavourings are concerned even in smaller companies. For those companies the burden will be especially heavy. In addition, the flavour producers have unhappily experienced in the recent years that any restrictive legal measure on a given ingredient leads in practice to a quick and definitive elimination of this ingredient by some customers and retailers.
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