The Vegetarian Society of Denmark
DVF
At skabe et bæredygtigt, etisk og sundt plantebaseret fødevaresystem samt fremme plantebaseret mad gennem vidensdeling, samarbejde og handling.
ID: 180008594613-12
Lobbying Activity
Response to General revision of the General Block Exemption Regulation
6 Oct 2025
To the European Commission We welcome the initiated review and revision of the GBER. The below suggestion for new GBER rules will strengthen European competitiveness, as it will help facilitate innovation within the plant-based food industry and benefit SMEs. ------------- When SMEs apply for state aid to develop, market and innovate new foods, the level of processing in the end product is decisive for the level of state support the project holder can achieve. The current rules consider several types of dairy products (which are processed) as agricultural products (ABER), while even the mildest forms of processing of plants makes them not considered as agricultural products (ABER), but instead GBER. When a product falls under GBER instead of ABER, it has a direct influence on the level of support. While projects that fall under ABER can always receive 100 % state support; projects that fall under GBER are typically only able to receive between 50-70 % support. This creates, in our view, unfair competition between food products, undermining the principle of a level playing field, hinders food innovation and makes it unnecessarily difficult for SMEs and start-ups within the food industry. Furthermore, GBER rules mean that large established companies can get much more state support for development, education and promotion, since they can more easily pay 30-50 % in own contribution, while also generally having larger amounts available for own contribution. For example, a large company can pay e.g. 1 million Euros in own contribution to get 1 million Euros in state support, while a small company can only pay e.g. 100.000 Euros and get 100.000 Euros in state support. While there is some differentiation between smaller and larger companies under GBER, even in those cases where the percentage of support for smaller companies is higher, the result is still much more state aid measured in Euros flowing to large companies. The overall consequence is that state support rules are more attractive for large companies than for small and medium size companies, since large companies will overall be able to secure much larger amounts of state support. This is also, in our view, unfair competition and in contradiction to wanting to support innovative SMEs. Denmark has created a Plant-Based Food Grant with 170 million Euros (2023-2030), to support innovation, education and promotion within the plant-based sector. The experience from setting up this funding scheme is that current GBER regulations are not favorable for the development of the sector. Therefore, in 2024, the Government of Denmark applied for an exemption from state aid regulations for the Plant-Based Food Grant. The Commission rejected this application. However, we refer to the arguments raised by the Government of Denmark in that letter, as they support our proposal below. If our proposal became reality, it would achieve many of the same objectives. PROPOSALS FOR AMENDING THE GBER REGULATION Allow 100 % state support for processed foods (under GBER), if the recipient has less than e.g. 10 Mio. EUR turnover a year Increase the de-minimis ceiling to e.g. 1 Mio. EUR per year (3 Mio. Euros over 3 years) for plant-based foods, and/or for recipients with less than e.g. 10 Mio. EUR turnover a year The proposed amendments will deliver on the EU-Commissions goal of reducing the administrative burden, preserving fair competition in the internal market and giving Member States more flexibility in designing support measures. Please see more on our proposal in the attached file.
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