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The EU Vegetable Oil and Proteinmeal Industry

FEDIOL

FEDIOL represents the European vegetable oil and proteinmeal industry to influence EU regulatory frameworks for processing.

Lobbying Activity

Meeting with Jens Geier (Member of the European Parliament)

13 Jan 2026 · Exchange on Industrial Accelerator Act and Energy Oils

Meeting with Aurelijus Veryga (Member of the European Parliament)

13 Jan 2026 · What are Ultra-Processed Foods and why their definition matters

Meeting with Michalis Hadjipantela (Member of the European Parliament)

11 Dec 2025 · Introductory Meeting

Meeting with Ricard Ramon I Sumoy (Head of Unit Agriculture and Rural Development)

26 Nov 2025 · Discussion on policies or initiative affecting the sectors’ competitiveness.

EU Vegetable Oil Industry Urges Impact Assessments for Pesticide Changes

14 Oct 2025
Topic — The EU proposal aims to simplify food safety regulations and marketing authorisations.
Message — FEDIOL argues major pesticide limit changes must undergo impact assessments to protect supply chains. They also request support for contaminant testing and harmonized enforcement across Member States.123
Why — Harmonized rules and scientific assessments would reduce trade disruptions and simplify business operations.45
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FEDIOL demands lower electricity prices and faster grid connections

9 Oct 2025
Topic — This consultation aims to accelerate the decarbonisation of industrial heating and cooling systems.
Message — FEDIOL requests long-term contracts for electricity and exemptions from grid tariffs for energy-intensive industries. They also want public funding for mature technologies instead of only breakthrough innovations.123
Why — These measures would reduce operational costs and make high-investment electrification projects economically feasible.4
Impact — Household consumers might face higher energy bills if grid costs are shifted away from industrial users.5
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Vegetable oil industry demands lower power prices for electrification

9 Oct 2025
Topic — The EU Electrification Action Plan aims to shift energy demand from fossil fuels to electricity.
Message — FEDIOL calls for long-term contracts with competitive prices and subsidies for electrical infrastructure. They request exemptions from grid tariffs and faster permitting for energy-intensive industries. Additionally, they seek funding for mature, proven technologies rather than just breakthrough innovations.123
Why — These measures would make large-scale electrification investments economically viable for primary food processors.4
Impact — Residential electricity consumers may face higher costs if industries receive exemptions from grid tariffs.5
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Meeting with Iuliu Winkler (Member of the European Parliament)

7 Oct 2025 · Challenges of agriculture

Meeting with Giorgio Gori (Member of the European Parliament)

7 Oct 2025 · Energy prices, decarbonization of energy-intensive industries and upcoming bioeconomy strategy

Meeting with Andrea Wechsler (Member of the European Parliament) and TotalEnergies SE and European Ceramic Industry Association

7 Oct 2025 · EU Energy and industry policy

Meeting with Fabien Gehl (Head of Unit Trade)

5 Oct 2025 · Meeting with FEDIOL

Meeting with Olivér Várhelyi (Commissioner) and

15 Sept 2025 · Challenges in the fields of plant protection products, contaminants, labelling policies

Meeting with Johannes Van Den Bossche (Cabinet of Commissioner Christophe Hansen) and Fédération Européenne des Fabricants d'Aliments Composés and

15 Jul 2025 · Risk of supply shortages for critical EU Agrifood- & feed-imports linked to geopolitical turbulence and EUDR implementation

Vegetable oil industry urges clearer scope for deforestation rules

13 May 2025
Topic — Consultation on amending the list of products covered by the EU Deforestation Regulation.
Message — The industry requests specific labels to exclude products derived from non-regulated commodities. They also want samples and waste materials for oil palm and soya exempt.12
Why — These changes would reduce compliance costs and avoid unnecessary regulatory burdens.3
Impact — Enforcement agencies may face increased complexity in distinguishing regulated products from exemptions.4
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Meeting with Irene Sacristan Sanchez (Head of Unit Health and Food Safety) and Fédération Européenne des Fabricants d'Aliments Composés and Comité du commerce des céréales, aliments du bétail, oléagineux, huile d'olive, huiles et graisses et agrofournitures de l'U.E.

28 Apr 2025 · Commission proposal on plants obtained by certain new genomic techniques (NGT proposal)

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

10 Apr 2025 · EU Deforestation Regulation

Response to Towards a Circular, Regenerative and Competitive Bioeconomy

7 Apr 2025

FEDIOL members are oilseed crushers and vegetable oil refiners, operating in the EU, which produce vegetable oils and protein meals for food, feed, biofuels, bioenergy and non-energy technical uses. An important part of our products directly replaces fossil-based products. The oilseeds crushing and vegetable oil refining plants are bio-refineries which are a living existing example of the bioeconomy. Since much of our feedstock comes from European farmers, our operations also foster rural development across Europe, while respecting environmental legislation and fulfilling sustainability criteria. FEDIOL welcomes the EUs Competitiveness Compacts assertion that The EU Bioeconomy Strategy will position the EU in the rapidly expanding bioeconomy market with a significant growth potential in bio-based materials, biomanufacturing, biochemicals, and agri-biotech sectors, reduce our reliance on fossil fuels and improve the economic perspectives of our rural areas. How to unleash the bioeconomys potential? Create an internal market for bio-based products through incentives and mandates, enabling/accelerating the transition towards a fossil-free future. A coherent policy framework would positively impact the confidence of private investors in research, development and innovation. This would increase production and consumption of renewable products, giving impetus to the growth in European economy. Rearranging tax tariff structures taking into account the environmental harm caused by fossil-based products and gains in the field of sustainability and decreased dependence delivered by use of biobased products. For our full position on the EU Bioeconomy Strategy, please see the attached file.
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Meeting with Koen Dillen (Head of Unit Agriculture and Rural Development)

25 Mar 2025 · Preparatory meeting for the FEDIOL event of 13 June 2025

Meeting with Catherine Geslain-Laneelle (Director Agriculture and Rural Development)

11 Mar 2025 · Exchange on view on the Vision on Agriculture and Food

FEDIOL demands removal of contract revision clause for oilseeds

10 Mar 2025
Topic — Targeted amendments to CAP regulations aimed at strengthening farmers' power in food supply chains.
Message — FEDIOL requests the removal of the revision clause for contracts in the oilseeds sector. They argue allowing farmers to renegotiate would stop buyers from meeting their own commitments.12
Why — This exemption would allow them to continue using financial markets to manage price volatility.34
Impact — Downstream food manufacturers and consumers could face higher costs and broken supply chains.5
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Meeting with Benoit Cassart (Member of the European Parliament)

30 Jan 2025 · Vision pour l'agriculture

EU Vegetable Oil Industry Urges Pilot Testing Before Biofuel Database Expansion

5 Nov 2024
Topic — Extension of EU traceability database to cover biofuel raw material production data.
Message — The industry requests pilot testing with operators before implementing new requirements, and a sufficient phase-in period with step-by-step integration. They argue current timelines for data entry are unrealistic and the database has technical problems that must be fixed first.1234
Why — This would reduce their administrative burden and allow time to adapt systems.567
Impact — Transparency advocates lose stronger real-time oversight of biofuel supply chain sustainability claims.8
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Meeting with Valérie Hayer (Member of the European Parliament) and Association Générale des Producteurs de Maïs

17 Sept 2024 · Divers

Response to Evaluation of the European Food Safety Authority (EFSA) 2017-2024

5 Apr 2024

FEDIOL is the European federation representing the interests of the European vegetable oil and protein meal industry. We welcome the possibility to provide feedback on the evaluation of performance 2017-2024 of the European Food Safety Authority. You will find our feedback attached. We thank you in advance for your consideration.
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Meeting with Taru Haapaniemi (Cabinet of Commissioner Janusz Wojciechowski)

13 Mar 2024 · Meeting with the Fediol Concerns of the producers of the vegetable oils, especially EU soya producers, regarding the implementation of the EU Deforestation Regulation

Meeting with Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius) and European farmers and

9 Feb 2024 · Deforestation issues

Meeting with Ulrike Müller (Member of the European Parliament)

14 Nov 2023 · NGT

Meeting with Raphaël Glucksmann (Member of the European Parliament, Shadow rapporteur) and Clean Clothes Campaign / Stichting Schone Kleren Kampagne

3 Apr 2023 · APA - Forced labour

Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur)

27 Mar 2023 · Forced Labour ban

Response to Act amending Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions

11 Jan 2022

Art. 38 of the ETS Monitoring and Reporting Implementing Regulation (EU) 2018/2066 disincentives the energetic self-use of biomass residues from biomass processing. This is because such use concerns biomass flows that are relatively small compared to the agricultural raw materials they are derived from. Having to prove that such biomass is compliant with the sustainability criteria of the Renewable Energy Directive is disproportionate and has no positive impact on environmental sustainability in the EU. The case of biogas production from wastewater treatment in oilseed and vegetable oil processing plants can be taken as an illustrative example (annex). The sector uses anaerobic digesters to transform the biomass fraction of oil processing wastewater into gaseous biomass fuel. Biogas produced in this way is most often self-used, blended into natural gas for combustion within the combined heat and power installation of the factory. However, art. 38 in its current form would require the certification of every tonne of oilseed that is transformed by the factory which defeats its purpose. FEDIOL, the EU vegetable oil and protein meal industry therefore requests that to Art. 38, para. 5 the following subparagraph be added after the second subparagraph: “Biofuels, bioliquids and biomass fuels produced from waste and residues for self-use shall not be subject to the sustainability and the greenhouse gas emissions saving criteria laid down in paragraphs 2 to 7 and 10 of Article 29 of Directive (EU) 2018/2001.”
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Meeting with Anthony Agotha (Cabinet of Executive Vice-President Frans Timmermans)

23 Nov 2021 · Deforestation

EU Vegetable Oil Industry Urges Higher Biofuel Targets and Preservation of Crop-Based Fuels

18 Nov 2021
Topic — Review of EU Renewable Energy Directive to align with 55% climate target by 2030.
Message — The industry requests increasing the greenhouse gas emissions savings target to at least 16% and preserving the 7% cap for crop-based biofuels as an EU-wide limit. They oppose allowing Member States to reduce transport targets if conventional biofuel shares are lowered, arguing this ignores verified higher GHG savings by producers.123
Why — This would maintain market space for their vegetable oil-based biofuels and prevent penalties for producers who invested in reducing emissions.45
Impact — Climate advocates lose stronger pressure to phase out conventional biofuels in favor of advanced alternatives.6
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Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

FEDIOL, as a member of the Renewable & Low-Carbon Liquid Fuels Platform, is committed to the climate-neutral economy by 2050, supporting a pathway which encompasses breakthrough technologies and an appropriate enabling policy framework. The Commission’s Fit-for-55 package is a step in the right direction. However, we have serious concerns on the lack of recognition of the renewable and low-carbon liquid fuels as a crucial element to the decarbonisation of transport and the value of multiple technological pathways to achieve both 2030 and 2050 targets respectively. More detailed views are attached.
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Response to Sustainable food system – setting up an EU framework

26 Oct 2021

FEDIOL supports the development of a legislative framework for sustainable food systems, because we consider imperative for our food systems to transition towards enhanced sustainability. Beyond the stated objective of reducing the GHG emissions and environmental impacts linked to food production and consumption, we note, however, that the Inception Impact Assessment does not offer any vision, or even a definition, with regard to key characteristics of a sustainable food system. FEDIOL trusts that sustainability should address environmental, social and economic aspects. FEDIOL considers that terms like “sustainable food system” or “healthy and sustainable diet” need to be carefully circumscribed, considering where the EU wants to land, which efforts are required, whilst building upon numerous initiatives launched by industry so far. FEDIOL notes the different options that will be considered and anticipates that a new comprehensive framework legislation on sustainability of the EU food system (options 4) may appear as a tempting approach based on the positive experience gained within the EU on the General Food Law. The task that lies ahead is complex and difficult. Overall, it will require changing production practices. It will require adapting consumption patterns with buy-in from citizens and consumers. And both developments need to move at unprecedented pace towards alignment. Any new EU legislative framework on sustainability will require to set top line objectives and principles that are scientific and evidence-based and follow an approach of good governance (i.e. stakeholder consultations, impact assessments etc.). Having in mind the General Food Law, which is based on risk assessment, risk management and risk communication, FEDIOL wonders whether and if so, how, this would be applied for sustainability. At the same time, other policy tools that are not within the EU responsibility also need to be considered. In our view, such fundamental change will first of all require a holistic approach to sustainability across all EU policies. In addition, FEDIOL would like to point out that links with other policies at national level such as on nutrition, health, but also education and taxation are crucial to be effective in supporting the transition. We trust that the primary objective of any food system is and should remain food safety. This should not be jeopardized by the possible setting of a new EU law on sustainable food systems. FEDIOL further considers that reducing food waste and food loss should be a target that can deliver tangible results rapidly and should involve all actors across the supply chain where food is wasted. In this context, we want to draw attention to the impact of food losses due to actual or potential non-compliance with EU legislation. Fear of regulatory non-compliance, restrictive enforcement of EU legislation without food safety justification, are raising concerns as to whether the EU will be able to reconcile its food quality and safety ambitions with an ethical food system management. FEDIOL notes that there are inherent contradictions in several described objectives the initiative attempts pursuing, which appear difficult to reconcile and will require either spelling out implications for the consumer more clearly or adjusting and mitigating some of the sub-targets that have been chosen so far. For example, the objective of making sustainable products more affordable will have to overcome the fact that all studies looking at the implementation of the Farm-to-Fork Strategy show an overall increase of consumer prices, due to a considerable reduction of production volume, in a quite substantial manner. In this process there is a clear danger to create an uneven playing field with imported goods which will not be subject to equivalent sustainability requirements. This would substantially undermine the transition of the EU food system towards better and more sustainable practices.
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EU Vegetable Oil Industry Challenges New Biofuel Sustainability Rules

27 Jul 2021
Topic — EU implementing regulation on verifying sustainability criteria for biofuels and biomass.
Message — The industry requests a six-month transition period and withdrawal of retroactive July 2021 application. They argue the low ILUC-risk certification test prevents farmers from qualifying and propose rewarding compliance with specific farming practices instead.123
Why — This would reduce compliance disruption and allow their members more time to implement certification changes.45
Impact — Environmental goals lose if unworkable provisions prevent farmers from adopting yield-improving sustainable practices.67
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Response to Setting of nutrient profiles

2 Feb 2021

FEDIOL welcomes the opportunity to provide feedback to the Inception Impact Assessment on the Proposal for a revision of Regulation (EU) No 1169/2011 on the provision of food information to consumers. FEDIOL, which represents the EU vegetable oil and protein meal industry, has been actively engaged for many years in the discussions on the topics covered by the Inception Impact Assessment. As such, FEDIOL would like to bring the following points in the discussions. FEDIOL stands ready to further contribute in the subsequent steps. FEDIOL considers that any Front of Pack Nutrition Labelling (FOPNL) system should be based on the following 6 criteria:  It should address consumer behaviour including ease of understanding of the label and level of information provided, enabling informed choice;  It should consider also positive aspects/benefits of food, such as mono- and polyunsaturated fatty acids;  The system should be in line with relevant existing nutritional recommendations incl. WHO and official national dietary recommendations;  Criteria must be defined per food group/category to enable consumers to make a fully informed comparison within a food group/category;  Food groups/categories should be based on consumer usage and as well as their place in a balanced and varied diet;  The system should take into consideration existing EU approved nutrition and health claims in its scoring criteria. FEDIOL assessed the suggested 5 options of the Impact Assessment vis-à-vis the above criteria in the case of vegetable oils and fats. The full analysis is available in the attached document. According to our analysis, none of the options in their current state satisfy the criteria above and the objectives of the FOPNL. In order to provide a meaningful consumer information, a nuanced approach is called for, avoiding oversimplification. FEDIOL considers that EU nutrient profiles are not required anymore with the implementation of Regulation (EU) No 1169/2011. However, should the outcome of the impact assessment result in a decision to set EU Nutrient profiles, FEDIOL strongly believes that criteria for nutrient profiles should be based on available science, be achievable, through reformulation, even if challenging, and be developed per food category/considering food category specificities. For single botanical origin bottled oils, it should be highlighted that reformulation as such is not possible. In addition, looking at existing FOPNL models, FEDIOL does not support the setting of one single model applicable for both FOPNL and nutrient profiles, if it was to be based on the existing systems (listed in Commission options 0 to 4). Most existing systems listed above (options 1-4) lead today to contradicting cases where “healthier” oils meeting criteria for approved EU nutrition or health claims are still discouraged for consumers. Should a new/modified system be proposed meeting the FEDIOL criteria listed above, FEDIOL could support the setting of one single model for both FOP and nutrient profiles depending on the system set-up. The full FEDIOL response is available in attachment.
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Response to Contingency plan for ensuring food supply and food security

12 Jan 2021

FEDIOL – representing the EU Vegetable Oil and Proteinmeal Industry – welcomes the Commission’s initiative and encourages the establishment of a Contingency Plan aimed at ensuring food supply and food security across the EU in times of crises. The roadmap explains that the plan would include the development of an EU food crisis response mechanism, in the form of a permanent forum of experts, and it refers to the participation of food supply chain stakeholders in the forum as a possibility. In this sense, we would like to stress the importance of ensuring the participation of this category in the forum. The handling of the COVID-19 crisis in the food sector has shown that the input coming from food supply chain stakeholders is vital to react appropriately and adopt effective supporting measures. Indeed, the Commission or Member States’ authorities alone cannot always have the full picture on the functioning of the sector and may fail to comprehend the concrete impact of certain decisions on business operators. Coordination with sectoral experts in case of crisis is therefore needed to ensure the right approach is taken and supplies to the EU market can be smoothly maintained. The COVID-19 crisis response coordinated by the EU Commission through its Green Lanes agreement also highlighted the critical importance of maintaining global trade in food and feedstuffs. As the crisis has shown, a well-functioning internal market is of vital importance in ensuring food security in Europe. Therefore, broader awareness of the crucial role of grain trade, oilseed crushing and feed production is needed at national level to address persisting key short-term challenges on transport logistics. As such, we believe that a key element of the Contingency Plan should be to include recommendations to national authorities for personnel in the food and feed supply chain to be legally considered as essential workers. That would imply assuring special mechanisms for the deployment of essential tasks, such as exceptions on confinement rules, priority inclusion of professionals among vaccination plans, etc. On a general note, we agree with the idea that any decision should be made on an EU-wide level, so as not to risk having individual Member States taking separate solutions, which would distort the functioning of the EU Single Market. FEDIOL remains available to provide additional input during the foreseen consultation phase ahead of the finalisation of the Commission’s Action Plan.
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Vegetable oil industry opposes restrictions on food-based biofuels

18 Dec 2020
Topic — This consultation establishes a classification system for environmentally sustainable economic investments.
Message — FEDIOL requests the removal of rules banning food and feed crops from being used as sustainable bio-based feedstock. They also oppose including indirect land use change impacts in livestock production criteria.123
Why — This would protect the sector's competitiveness by allowing current agricultural feedstocks to qualify as sustainable.4
Impact — Environmental groups and land-use advocates lose protections against the conversion of food-producing land for fuel.5
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EU vegetable oil industry demands better treatment for cogeneration

26 Nov 2020
Topic — Updating the EU Emissions Trading System to reach 2030 climate targets.
Message — The industry requests that road transport fuels remain separate from the main carbon market. They also want to redefine onsite electricity production to protect their right to free emission allowances.123
Why — Redefining their facilities would prevent the loss of valuable free carbon permits.45
Impact — Less efficient heat generators would face increased competition from subsidized industrial cogeneration sites.6
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

FEDIOL acknowledges the EU carbon neutrality objective by 2050 and the associated need to increase its emissions reduction target by 2030. This ambition must be translated into concrete and practical actions to ensure an effective, sustainable and successful decarbonisation of the European economy, specifically in the transport sector. In fact, while the EU has made overall progress in renewables incorporation and emissions reduction, the picture in the transport sector is dire, with a 94% reliance on fossil fuels, and emissions 19% higher than 1990 levels. FEDIOL is concerned by the policy options considered in the Inception Impact Assessments for the EU ETS and ESR, including the phasing out of the ESR or a reduced ESR scope. Going forward, the ESR should be strengthened by setting higher GHG emissions targets for transport, so as not to place a higher burden on other non-ETS sectors such as agriculture and households. Reducing GHG emissions in the transport sector is comparatively more difficult and costly than in any other sector. The current system is too complex and would discourage investments on new technologies for the production of advanced biofuels. Therefore, CO2 pricing of road transport fuels must be separate from the existing EU ETS to consider the specificities of the sector. Including road transport in the EU ETS, given the present and future levels of ETS allowances, would be very unlikely to trigger the important efforts needed to decarbonise EU transport, and weaken any real decarbonisation progress.
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Response to Sustainable corporate governance

8 Oct 2020

FEDIOL welcomes the European Commission’s initiative aimed at further incorporating sustainability into the governance framework of corporate activities. The objective of FEDIOL members is to source agricultural raw materials that are sustainably produced and to address potential issues in the supply chain with a view to improving production practices. To do so, our companies commit already today to the implementation of voluntary due diligence and would welcome the development of a harmonised mandatory system to accelerate the sustainable transformation of supply chains at risk of causing adverse environmental and social impacts. The suggestion to build on existing authoritative guidelines, as developed by the UN and the OECD, would indeed support practices that have been applied by many companies in our sectors that process agricultural commodities. Our complete contribution to the ongoing Commission's exercise is attached.
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Vegetable oil industry urges continued role for crop-based biofuels

21 Sept 2020
Topic — Revision of the Renewable Energy Directive to increase EU climate targets.
Message — The industry requests that certified sustainable crop-based biofuels remain in the transport mix. They also oppose reopening the sustainability criteria for biofuels and suggest separate mandates for aviation and shipping.123
Why — This would protect their market share and avoid new regulatory burdens and costs.45
Impact — Road transport drivers face higher costs if fuel production is incentivised away from cheaper alternatives.6
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Response to Sustainable use of pesticides – revision of the EU rules

15 Jul 2020

FEDIOL - the EU association representing the vegetable oil and protein meal industry - welcomes the opportunity to provide comments on the consultation on the European Commission combined evaluation roadmap/inception impact assessment on the revision of the Sustainable Use of pesticides Directive. FEDIOL comments can be found in the attached document.
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Meeting with Virginijus Sinkevičius (Commissioner) and

9 Jul 2020 · To discuss issues related to global deforestation, such as measures to tackle deforestation and initiatives related to supply chain sustainability.

Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski), Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and

22 Apr 2020 · Responsible sourcing of commodities aimed at avoiding deforestation or other adverse environmental and climate change impacts

Response to Farm to Fork Strategy

13 Mar 2020

FEDIOL recognizes the importance of accelerating the transition towards an EU sustainable food system. The Farm to Fork strategy and its implementation requires first of all to maintain the same level of EU food safety. At the same time, reconsidering the current food production system is likely to put European food security at risk as EU produced agricultural raw materials will become less competitive, affecting the viability of the EU industry processing. Envisaged changes need assessment and will lead to political trade-offs which should be clearly communicated. Through the processing of agricultural raw materials, our sector contributes to the production of food and feed as well as to bio-chemicals, biofuels and other bio-materials. It provides a clear value added in terms of the management of food and feed safety risks and contributes to affordable prices for consumers. Whilst we acknowledge the need to take our share of responsibility, efforts should be made at each step of the chain for an effective systemic change to happen. FEDIOL would like to highlight the following key topics which are further detailed in the attached FEDIOL position paper: 1. FEDIOL can understand the need for a new policy on pesticides to significantly reduce the use and risk of chemical pesticides. At the same time, measures helping to mitigate the impacts on supply chain players as well as transition measures should be set. The future work should also comprehend availability of viable alternatives to chemical pesticides and agricultural practices like IPM. Instead of a fully new regulatory framework, an adapted regulatory framework building on the existing one should be put in place. FEDIOL is ready to engage in the production of organic oils and fats, but advances in agriculture and process are required for production at industrial scale. 2. New Genomics Techniques hold exceptional promise for adapting agriculture to changes in climate, growing more with less and improving nutrition and agricultural sustainability and they should be governed by an adapted regulatory framework which considers their unique characteristics. 3. Vegetable oils and fats play an important role in a healthy and balanced diet. WHO recommends favouring vegetable oils rich in omega 3 fatty acids and polyunsaturated fatty acids and this is further recognized through EU health and nutrition claims. Any EU harmonized FOP nutrition labelling should take this into account. FEDIOL sector will continue supporting reformulation efforts in the final food products, and stands ready to further support the omega 3 consumption by making available a broad spectrum of such bottled vegetable oils in all EU countries. As regards origin labelling, the existing voluntary COOL Regulation provides a sufficient framework for our products. 4. While FEDIOL can support the harmonization being offered by PEF methodology, a potential policy framework should ensure that it remains voluntary. Before setting any claims based on PEF, FEDIOL recommends undertaking a full assessment of its possibilities and limitations. 5. In terms of food waste, our sector is already resource efficient and ensures full raw materials valorization through the effective use of all by-products. FEDIOL requests to reconsider the inclusion of edible oils as producing food waste into the Commission Delegated Decision for the uniform measurement of levels of food waste. 6. As regards the links between the Farm to Fork strategy and the CAP, FEDIOL considers that they should be set clearly. Should the CAP environment and climate change aspects be strengthened, it would require accompanying additional budget and incentives. 7. As regards biodiversity and climate resilience, FEDIOL considers that partnership between the EU and origin countries is required, with a view to tackling deforestation or conversion. Incentives for a broader engagement and implementation should form an integral part of the EU framework.
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FEDIOL warns against simply diverting trade to avoid deforestation

28 Feb 2020
Topic — The consultation explores measures to reduce EU-driven deforestation and forest degradation.
Message — FEDIOL requests policy tools that promote better farming practices in origin countries through cooperation. They also demand the Commission use recent data to reflect recent industry progress.12
Why — Focusing on global cooperation protects their existing supply chains from disruptive trade shifts.3
Impact — Farmers in producing countries could lose vital income if the EU blocks trade.4
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Response to Import of used cooking oils

19 Jul 2019

FEDIOL - representing the EU Vegetable Oil and Proteinmeal Industry association - welcomes the opportunity to comment on the proposed regulation. In line with what already specified in the premises to the draft text by the European Commission, we would suggest to add under the enlisted recitals the following paragraphs aimed at specifying that products under this regulation are not intended for human consumption: - "Regulation (EC) 852/2004 on the Hygiene of Foodstuffs set rules for the food dedication of transport of foodstuffs in Chapter IV of Annex II; as used cooking oil is not a foodstuff, transport in food dedicated transport is not allowed". - "Commission Regulation (EU) No 579/2014 of 28 May 2014 grants a derogation from the food dedication of Regulation (EC) 852/2004 as regards the transport of bulk liquid oils and fats by sea for products in the ANNEX LIST OF ACCEPTABLE PREVIOUS CARGOES; used cooking oil is not mentioned in that Annex and is therefore not an acceptable previous cargo to a cargo of edible oil by sea".
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Response to Enhancing Market transparency in the agri-food chain

18 Jun 2019

FEDIOL represents the EU vegetable oil and protein meal industry. Our sector crushes oilseeds, notably rapeseed, sunflower seed, soybeans and linseed into oils and meals and refines those crude oils from crushing and crude tropical oils, notably palm oil, palm kernel oil and coconut oil. The meals and the crude and refined oils are sold for food, feed, technical and energy uses essentially on the European market. FEDIOL acknowledges with concern the proposed implementing regulation aimed at increasing transparency in the EU food chain and therefore welcomes the opportunity to state its views via a public consultation. Our full contribution is attached.
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FEDIOL urges EU to recognize sustainable biofuel sourcing practices

5 Mar 2019
Topic — The Commission is establishing criteria to determine indirect land-use change risks for biofuels.
Message — FEDIOL requests a comprehensive impact assessment and criteria that recognize sustainable sourcing practices at the point of origin. They argue for allowing market access for sustainable production, even for crops labeled high-risk.12
Why — Maintaining access to the EU market protects investments and supports the biodiesel industry's survival.34
Impact — The European transport sector may struggle to meet 2030 climate targets due to reduced investment.5
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FEDIOL Urges EU to Use Updated Deforestation Data

14 Jan 2019
Topic — This consultation seeks to establish an EU approach to combat global deforestation.
Message — FEDIOL requests that the EU rely on an updated and accurate set of data. They advocate for building effective partnerships with producer countries to address deforestation on the ground. The federation regrets the use of outdated studies that disregard recent environmental efforts.123
Why — Accurate data would ensure a fair assessment of the industry's role in importing commodities.4
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Response to Establishing a legal limit for the industrial trans fats content in foods

26 Oct 2018

FEDIOL welcomes the opportunity to provide feedback to the Commission Regulation amending Annex III to Regulation (EC) No 1925/2006 of the European Parliament and of the Council as regards trans fat, other than trans fat naturally occurring in animal fat, in foods intended for the final consumer. FEDIOL represents the EU vegetable oil and proteinmeal industry. For many years, FEDIOL and its members have engaged heavily on the topic of trans fatty acids (TFA). This has enabled our industry to deliver reformulated products with lower TFA content below 2% TFA to customers and consumers. A FEDIOL Code of practice on refining has also been established to ensure that all refined vegetable oils and fats do not contain more than 2% TFA. For many years, FEDIOL has been supportive of the setting of an EU legislation on TFA. FEDIOL can therefore support the content of the draft Regulation as proposed for public consultation. This will ensure a level playing field, given the many national legislations having implemented the same approach over the years, and target the remaining hotspots in some EU countries. Whilst understanding the focus set on industrial TFA for practical reasons, FEDIOL would however like to recall that “the available evidence is insufficient to establish whether there is a difference between ruminant and industrial TFA consumed in equivalent amounts on the blood lipid profile and/or the risk of CHD”, as confirmed by EFSA in its Scientific and technical assistance report on trans fatty acids published in June 2018. FEDIOL also supports further work on the availability of analytical methods, as currently developed by the Joint Research Center (JRC). With the setting of such a maximum TFA level in final products, FEDIOL would also like to highlight that the existing mandatory labelling of “partially hydrogenated” and “fully hydrogenated” vegetable oils or fats becomes redundant. Indeed, all food products available on the market - as from the application time of the new Regulation - will all contain TFA levels below the 2% TFA. Maintaining the existing mandatory labelling under Regulation (EU) No 1169/2011 will therefore further confuse consumers into thinking that higher TFA products would still be available on the market, which will not be the case. FEDIOL therefore calls on the need to delete such “partially hydrogenated” and “fully hydrogenated” labelling from Regulation (EU) No 1169/2011 as soon as possible.
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Response to Derogations as regards previous cargoes for the transport of oils and fats for human consumption by sea

17 Oct 2018

The European Commission services are already stating in the Draft Regulation that: - Commission Regulation (EU) No 579/20142 provides for a derogation from point 4 of Chapter IV of Annex II to Regulation EC (No) 852/2004 as regards the transport in seagoing vessels of liquid oils and fats intended for or likely to be used for human consumption under certain conditions. - Those conditions relate to criteria as regards substances to be transported in a seagoing vessel as previous cargo. - Substances that fulfil those criteria are listed in the Annex to Regulation (EU) No 579/2014 (list of acceptable previous cargoes). - In its scientific opinion of 24 November 2016, the European Food Safety Authority (‘the Authority’) evaluated methylacetate and ethyl-tert-butyl ether for acceptability as previous cargoes. The Authority concluded that methylacetate and ethyl-tert-butyl ether meet the criteria for acceptability as a previous cargo. As the measures provided for in this Regulation are in accordance with the opinion of the Standing Committee on Plants, Animals, Food and Feed, we agree that it is therefore appropriate to amend the list of acceptable previous cargoes set out in the Annex to Regulation (EU) No 579/2014 (namely to add methylacetate and ethyl-tert-butyl ether, ETBE).
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Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and European Margarine Association

26 Sept 2018 · EU initiative on transfats

Response to Transparency and sustainability of the EU risk assessment model in the food chain

12 Jun 2018

FEDIOL welcomes the Commission proposal on the transparency and sustainability of the EU risk assessment in the food chain. Overall, it supports work to address public perceptions on the EU risk assessment in the food chain and improvements in risk communication. Industry supports increased transparency and access to data, provided that any data are put into context and are not released before EFSA final scientific opinion is finalised. FEDIOL is convinced that releasing data not supporting a request for authorisation at the same time as EFSA final opinion would equally achieve the objective of increased transparency and support the risk assessment process, in an objective and scientifically sound manner. Further details are available in FEDIOL position paper as attached. FEDIOL welcomes the proposed introduction of a new section 1a on risk communication. FEDIOL trusts that the setting of objectives, general principles and a general plan for risk communication by the Commission – in close cooperation with EFSA, Member States and public consultation – is a way to ensure a better and more targeted work. FEDIOL is convinced that strengthened collaboration between Member States and the Commission to avoid different or contradicting messages - for issues under normal conditions or in case of crisis – would be a clear improvement. FEDIOL therefore welcomes accurate, appropriate and timely information (…) to provide a sound basis for understanding risk management decisions, (…) whilst taking into account risk perceptions and promoting appropriate involvement of all interested parties (…) as key objectives and principles foreseen under article 8a and 8b. FEDIOL supports EFSA work. EFSA’s work is indispensable for the trust in our food system. There is a need to maintain the existing high level of scientific expertise within EFSA to continue guaranteeing its risk assessments robustness. FEDIOL welcomes that the additional tasks foreseen by the proposal are also accompanied by additional staff resources (as provided for in Commission staff working document). However, EFSA core tasks should not be hampered by such additional tasks. Hence, EFSA available resources for existing tasks should also be re-evaluated, with a view to increase those to continue maintaining its high performing work. Given the increasing level of requests to EFSA on numerous issues, it is crucial to allocate adequate resources to maintain its leading scientific role in Europe and beyond. FEDIOL also concurs with the need to strengthen scientific cooperation between Member States and EFSA, but also the collaboration between EFSA and other international bodies such as JECFA. Links with international bodies should also be explicitly mentioned in the proposal. FEDIOL further welcomes that each Member State will have to nominate an equal number of experts into EFSA scientific panels for appointment after evaluation (article 5a). It also supports the principle of independence of such experts, including from any instruction at national level (article 5d).
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Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and CropLife Europe and

17 May 2018 · Import tolerance, Commission's proposal on general food law, REFIT on pesticides

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

18 Apr 2018 · Protein plan for Europe

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and European Margarine Association

13 Apr 2018 · Trans fats acids

Response to Commission Implementing Regulation on the provision of voluntary indication of origin or place of provenance of foods

30 Jan 2018

FEDIOL, the EU vegetable oil and proteinmeal industry, welcomes the opportunity to provide input into the draft implementing Regulation laying down rules on the implementation of the voluntary country of origin or place of provenance (COOL) (Ares(2018)34773). Since 2013, FEDIOL has provided detailed input on voluntary COOL, starting from the external study on voluntary COOL and in subsequent consultations afterwards. FEDIOL supports overall the proposed rules. It particularly welcomes the recognition of the multiple or variable supply sources and particular production processes which trigger the setting of a specific framework, as per recital 13. In this context, FEDIOL welcomes the flexibility given by introducing a statement, whereby the primary ingredient would be declared as not coming from the country of origin/place of provenance of the food. However, we still note a number of open questions, which could lead to different interpretations on the scope or the way such conditions would apply in practice. FEDIOL therefore calls upon the Commission to prepare an EU guidance on the new implementing Regulation, before its date of application. Such guidance would clarify the interpretation and implementation of the new implementing Regulation, and avoid divergences across food business operators and Member States.
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Response to Transparency and sustainability of the EU risk assessment model in the food chain

16 Jan 2018

FEDIOL welcomes the opportunity to provide input. FEDIOL participated in past consultations steps on the General Food Law. FEDIOL also provided feedback on EFSA functioning such as in EFSA external evaluation 2017. FEDIOL is also an accredited EFSA stakeholder since the start. FEDIOL supports overall work to address public perceptions on the EU risk assessment in the food chain and risk communication, as described in the problem definition. We however see no easy and immediate “quick fix” to address these complex issues. Rather, a mix of different initiatives should be implemented, ranging from building upon existing transparency initiatives and strengthening them, to communicating through appropriate channels to investing into consumer education, etc. Transparency is indeed a way to pursue, it should first build upon the existing initiatives, in particular those from EFSA. Just to name a few, its new stakeholder engagement or its data warehouse project. FEDIOL supports EFSA overall approach on transparency and stakeholder engagement. Any discussions on transparency should be done in line with Regulation (EC) No 1049/2001 and Regulation (EC) No 1367/2006. Notably, giving access to further information and open data could be further explored, provided that protection of privacy of the individual and commercial interests as per Regulation (EC) No 1049/2001 are met. Ultimately, any new initiative should ensure legal certainty and predictability for industry and maintain the competitiveness of the food chain. As already highlighted, FEDIOL supports in general the principle of increasing guarantees of independence, objectivity and reliability of studies. We support a risk assessment that is based on sound science and takes into account the most recent scientific and methodological developments – irrespective of the source of funding– public or private. FEDIOL further concurs with the need to strengthen scientific cooperation between Member States and EFSA, but also the collaboration between EFSA and other international bodies such as JECFA. There is a need to maintain a high level of scientific expertise within EFSA to guarantee its risk assessments robustness. EFSA is already working on this. As regards risk communication, FEDIOL agrees with the need to develop a more effective and transparent communication with the public. Such communication would benefit in promoting consumer awareness on the existing risk assessment process as well – EU food has never been safer – highlighting the risk-benefit approach of available technologies. Clear, simple and timely communication from the Commission and EFSA in partnership is essential. Clear improvements on the way EFSA communicates (e.g. press releases) have been made in the last months. Further channels of feedback of all accredited stakeholders exist e.g. EFSA communicators’ lab. Collaboration between Member States and the Commission in terms of communication also needs to be improved. This would help to avoid false messages are sent to the general public, with detrimental consequences for food business operators. A balance has to be found to better manage communication: timely communication of information so that appropriate action can be taken, whilst fear avoided. More investments should be done on education in explaining in lay-man words what EU risk assessment is about and which tools exist. TV and web campaigns, web-based interactions with consumers (Twitter, Facebook, etc.), education in schools, etc. are all vectors of communication to be strengthened by EU institutions. FEDIOL stands ready to continue provide feedback in the stakeholder consultation expected in January 2018.
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Response to COMMISSION IMPLEMENTING REGULATION (EU) concerning the denial of authorisation of formaldehyde as a feed additive

14 Dec 2017

1. Efficacy and alternatives Recital 13 of the proposal states: "As regards possible alternative products to formaldehyde as an additive belonging to the functional group of hygiene condition enhancers, research is currently being conducted to develop additives which would prove both safe and efficacious in reducing microbiological contamination in feed. An additive has already been authorised under that functional group and is therefore considered as an alternative, although with a different mechanism of action, in order to reduce the number of bacterial pathogens, including Salmonella spp, in feed, without causing the concerns over users' safety raised by the use of formaldehyde. Several applications for authorisation of other additives under that functional group have been submitted and are being assessed in accordance with Regulation (EC) No 1831/2003. In addition, other authorised feed additives may, as zootechnical additives, improve the quality of animal products through a reduction of contamination with enteropathogens such as Salmonella spp." As far as we are able to ascertain, available research into the efficacy of organic acid alternatives suggests that although there is a reduction in Salmonella in feed, the rate of elimination in contaminated feed may be less efficient when compared to formaldehyde and in particular may work less well in keeping feed Salmonella free over the course of time following treatment. We understand that formaldehyde is the only substance that has been approved by the US FDA to protect feed from Salmonella contamination for twenty-one days post treatment and to be able to claim this level of efficacy. Fediol understands that a formaldehyde producer has commissioned an independent source to look into the efficacy of formaldehyde compared to existing alternatives. Fediol believes that it would be a legitimate request to ask for the deferral of the proposal to await this and allow informed and up to date public debate in terms of product efficacy. 2. Health and safety at work and exposure limits - EFSA 2014 opinions on the safety and efficacy of formaldehyde EFSA concluded that it had no safety concerns with formaldehyde’s usage in feed nor that it would pose a risk for the environment. It noted however regarding user safety that: "Formaldehyde is a strong irritant, a potent skin and respiratory sensitiser. Measures should be taken to ensure that the respiratory tract, skin and eyes of any person handling the product are not exposed to any dust, mist or vapour generated by the use of formaldehyde. The FEEDAP Panel recommends that consideration should be given to whether the strict protection measures, once established, would effectively protect users at the level of feed compounders and farmers." On that note, Fediol understands that the Commission (DG EMPL) within the aegis of the Carcinogens and Mutagens Directive 2004/37/EC is currently proposing to set legally binding occupational exposure limits for formaldehyde, acknowledging safe exposure limits for users and has published an Inception Impact Assessment to this end (with an indicative timeline described as April 2018). In our view given the potential impact of the proposal, it would be reasonable to make reference to this work and await its outcome/conclusions before anticipatively delisting formaldehyde on user health and safety grounds which may not be justifiable and/or applied in other industrial sectors.
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Response to Commission Regulation on maximum levels for glycidyl esters in certain foods

18 Sept 2017

FEDIOL, the EU vegetable oil and proteinmeal industry, welcomes the opportunity to provide input into the draft Regulation setting maximum levels on glycidyl esters (GE). The vegetable oil and fat industry views food safety and quality as a top priority. For a number of years, industry has been engaged in intensive work on 2- and 3-MCPD esters and glycidyl esters. The scope of this work has covered research to understand their occurrence in vegetable oils and fats, factors influencing occurrence, analytical methods, sponsoring development of an exposure model and evaluating potential mitigation techniques. Focusing initially on glycidyl esters due to their risk profile in published science, in 2015, FEDIOL members made a clear joint commitment to limit levels of glycidyl esters in all refined vegetable oils and fats delivered to the market for food use as from September 2017. FEDIOL therefore supports the proposed limit for GE on Vegetable oils and fats placed on the market for the final consumer or for use as an ingredient in food and on vegetable oils and fats destined for the production of baby food and processed cereal-based food. For reasons of legal certainty and clarity, we would also support the inclusion of an explicit transitional measure for those products already lawfully placed on the market prior to the entry into force of the Regulation. As regards 3-MCPD esters, FEDIOL acknowledges the Commission decision to await the outcome of EFSA opinion reopening before taking regulatory measures (recital 3). Industry continues to work hard to assess and implement the best available tools to further address these substances. FEDIOL stands ready to continue providing feedback on this issue.
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Meeting with Arunas Ribokas (Cabinet of Commissioner Vytenis Andriukaitis), Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

31 Aug 2016 · 3-MCPD and Glycidyl Esters in vegetable oil and fats

Response to Criteria to identify endocrine disruptors for plant protection products

28 Jul 2016

FEDIOL and COCERAL comments on the Commission’s proposal setting out scientific criteria for the determination of endocrine disrupting properties FEDIOL and COCERAL, the European associations representing respectively the vegetable oil and protein meal industry and the trade in cereals, rice, feedstuff oilseeds, olive oil, oils and fats and agrosupply, wish to share their comments on the Commission’s proposal on the criteria to identify Endocrine Disruptors (EDs) in Plant Protection Products (PPPs). FEDIOL and COCERAL are concerned that the definition of EDs proposed by the Commission, which is purely hazard-based, may be restrictive beyond the needs of safety concerns. The related major concerns for FEDIOL and COCERAL are: • A decreased availability of safe and necessary PPPs on the market. Substances could be withdrawn even when the risks to human health and the environment are negligible and their socio-economic benefits are important. Such a reduced availability of PPPs on the EU market may negatively impact the yield and quality of agricultural and horticultural production in Europe while reduce productivity. Besides, it may lead to higher risks to develop resistance in populations of harmful organisms. • Increased hurdles with regards to food and feed imports. Considering the strong EU dependency on the global market for the supply of protein-rich raw materials, a high attention must be paid to mitigate the potential impact of ED criteria on EU imports via the setting of Import Tolerances (ITs). FEDIOL and COCERAL deem necessary to call on the Commission to: • Introduce at least hazard characterisation elements in the criteria identifying EDs, thus using the possibility foreseen by the so-called option 4 of the 2014 roadmap, i.e. “WHO/IPCS definition to identify endocrine disruptors and inclusion of potency as element of hazard characterization”. Indeed, option 4 ensures the same level of consumers safety than option 2 (i.e. sole WHO/IPCS definition), whilst having a significantly lighter impact on the economic sector than option 2. While considering two options of equal benefit in terms of public health, priority should be given to the one with the less adverse impact on economic operators. • Reconsider the opportunity to base EDs related decision on a sound risk assessment, including also exposure. FEDIOL and COCERAL believe that a risk, rather than a hazard-based approach, would ensure the necessary human health and environmental protection, whilst allowing the production of safe, sufficient and affordable food for the EU population. This is in line with recent scientific indications by the European Food Safety Authority (EFSA opinion on the identification/characterisation of EDs and related scientific criteria and test methods (2013), also supported by the Scientific Committee on Consumer Safety (SCCS) in 2014, with its Memorandum on Endocrine Disruptors). • Take account of the socio-economic impacts. • Avoid letting the EDs criteria severely impact on the procedures set by Regulation 396/2005 to set Maximum Residue Levels and ITs. FEDIOL and COCERAL share the commitment to provide EU consumers with high quality food and feed, in compliance with the safety requirements established by the EU in order to safeguard human, animal and plant health and to protect the environment. At the same time, FEDIOL and COCERAL are aware of the need to face global competition, to promote the EU high standards and to meet the world food and feed demand. A continued availability of a range of safe PPPs, authorised by a transparent, reliable and predictable science-based process, is necessary for meeting the challenges at stake.
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Meeting with Daniel Calleja Crespo (Director-General Environment)

13 May 2016 · Deforastation

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

14 Oct 2015 · Trans Fatty Acids

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

5 Mar 2015 · Intro meeting

Meeting with Ladislav Miko (acting Director-General Health and Food Safety) and FoodDrinkEurope and

26 Feb 2015 · GM import authorizations

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

11 Feb 2015 · Trans Fatty Acids