THOFFOOD SL
Thoffood es una empresa dedicada a la asesoría estratégica en asuntos UE , especialmente en lo relativo a la cadena agroalimentaria y energía.
ID: 284609348291-29
Lobbying Activity
Meeting with Carmen Crespo Díaz (Member of the European Parliament, Committee chair)
9 Dec 2025 · Sustainable tuna sector in the EU
Response to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)
12 May 2025
Espirituosos de España is the Spanish Federation of Spirits, an entity that groups 100% of the producer and distributor sector of spirits and derived products in Spain. i. Packaging materials We welcome the revised wording clarifying that certain packaging materials used to support, protect or carry another product placed on the market, and presented with that product, are excluded from scope. However, we would be grateful if the guidance could be amended in this respect, as the latest version is not sufficiently clear in explaining the circumstances under which such packaging is considered to 'give a product its essential character' and therefore will not benefit from this exemption. ii. Second-hand and used products Espirituosos de España welcomes the clarification offered in the Annex under point (ee), which specifies the following: the entry 4416 Casks, barrels, vats, tubs and other coopers products and parts thereof, of wood, including staves is replaced by the following: ex 4416 Casks, barrels, vats, tubs and other coopers products and parts thereof, of wood, including staves (not including used products and second-hand products) Ex-American whiskey casks, as well as other wine/spirits casks, are necessary for the maturation and distilling of certain European spirit drinks. As the product specifications of Bourbon, Tennessee Whiskey, and most other American whiskeys require that such casks can only be used once, they are exported to other markets including EU Member States as they have reached the end of their life cycle in the USA and would otherwise be disposed of as waste. Ex-spirit/wine casks are also used in the maturation and distilling of certain spirit drinks. In all cases used casks released to market will have fulfilled their original purpose (production of the initial spirits/wine) and are therefore no longer required by primary user thus therefore placed on the market as a means of disposal or to be discarded by the original user. The lack of specificity related to used products and second-hand products in the original EUDR was a cause of concern for EU spirits producers: this additional regulation and bureaucracy may have endangered the supply chain of these ex-American whiskey casks and other ex-spirits and ex-wines casks adding to the price of such casks, and therefore placing the production of certain EU spirit drinks at risk. The proposed amendment included in the Delegated Regulation amending the wording of 2 ee clarifies that ex-Bourbon/American oak and ex-wine/ex-spirit casks/barrels are outside of the scope of EUDR being used or second-hand. This clarification, offers clarity to our sector and ensures that sustainable practices refined by decades of distilling can continue. We therefore fully support this change be adopted and reflected in the final text of this Regulation.
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