Union Européenne du Commerce du Bétail et des Métiers de la Viande

U.E.C.B.V.

The UECBV represents livestock and meat traders and processors across Europe, promoting trade and defending industry interests in EU policy.

Lobbying Activity

Meeting with Brigitte Misonne (Acting Director Agriculture and Rural Development)

10 Nov 2025 · EU policies relevant for meat trade

EU Meat Industry Backs Broader Emergency Slaughter Rules

27 Oct 2025
Message — The organization requests extending emergency slaughter rules to include animals unfit for transport, not only those injured by accident. They want this change while maintaining food safety standards.1
Why — This would reduce financial pressures on farmers and preserve economic value of animals.23

EU meat industry welcomes end to Brazilian certificate of origin restrictions

29 Sept 2025
Message — The industry supports replacing certificates of origin with supply contracts for poultry import quotas. They request faster implementation to apply for 2026 instead of 2027, and want similar protections extended to other import quotas being abused by third countries.123
Why — This would eliminate artificial trade restrictions that harm EU businesses and consumers economically.45
Impact — Brazilian certificate issuers lose their ability to restrict EU market access through administrative control.67

Meeting with Caroline Boeshertz (Head of Unit Health and Food Safety)

18 Sept 2025 · HPAI situation in Brazil in relation to imports of poultry into the EU

UECBV urges science-based and realistic animal welfare standards

16 Jul 2025
Message — UECBV insists that improvements are grounded in science and economic sustainability. They argue that producers should be granted a sufficiently extended transition period.12
Why — This approach prevents production shifts outside the EU and protects producer viability.3
Impact — Animal welfare groups lose their campaign for an immediate and total cage ban.4

Meeting with Alisa Tiganj (Cabinet of Commissioner Christophe Hansen) and European farmers and

30 Apr 2025 · • ELV five recommendations for the Vision for the Future of EU Agriculture and for the mandate • Presentation of ELV (European Livestock Voice) • Exchange of views: Vision for the future of Livestock • EU Trade policy review: State of play

Meeting with Brigitte Misonne (Acting Director Agriculture and Rural Development)

14 Apr 2025 · Exchange of views on the meat market situation and on the EU Vision for Agriculture and Food

Meeting with Pierre Bascou (Deputy Director-General Agriculture and Rural Development) and Comité Européen des Entreprises Vins and

17 Mar 2025 · Exchange of views on the Vision for the Future of Agriculture and agri-food trade.

Meat industry group UECBV rejects mandatory contracts for livestock

10 Mar 2025
Message — UECBV requests exempting small livestock sales from mandatory contracts to prevent high administrative costs. They suggest extending payment windows to 14 days and removing production cost requirements.123
Why — Limiting contract requirements would reduce administrative expenses and preserve flexible, market-based pricing models.4
Impact — Farmers lose the security of having their actual production costs reflected in mandatory contract terms.5

Meeting with Catherine Combette (Head of Unit Agriculture and Rural Development) and Comité Européen des Entreprises Vins and European Liaison Committee for Agriculture and agri-food trade

28 Jan 2025 · Exchange of views on the on-going trade negotiations in the Indo-Pacific region

Meeting with Elisabetta Siracusa (Director Agriculture and Rural Development) and Comité Européen des Entreprises Vins and

28 Jan 2025 · Introduction of CELCAA’s new President and exchange of views on recent developments on international agricultural trade.

Meeting with Brigitte Misonne (Head of Unit Agriculture and Rural Development), Luis Carazo Jimenez (Head of Unit Agriculture and Rural Development)

21 Jan 2025 · Exchange of views on the implementation of the EU-Mercosur Partnership Agreement

Response to Amendment of some rules applicable to the reference quantity requirement

2 Jul 2024

UECBV thanks the Commission for the opportunity to contribute to this initiative. UECBV shares the desire to support Ukraine in this context of Russian aggression, and understands the desire to limit the bias due to the liberalisation of trade by excluding volumes of poultry originating in Ukraine from the calculation of reference quantities. On the other hand, UECBV does not agree with the content of this proposal, as it does not seem to address the problem and could lead to serious market disturbances. You will find attached UECBV contribution.
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UECBV Urges Substantial Revision of Proposed Animal Transport Rules

12 Apr 2024
Message — The organization requests a substantial revision focusing on enforcement rather than stricter requirements. They oppose journey limits, increased space allowances, and mandatory veterinarian supervision during loading.123
Why — Revised rules would avoid doubling transportation requirements and maintain the economic viability of meat production.4
Impact — Consumers would face unaffordable prices for basic animal products due to increased transport costs.5

UECBV Demands More Flexible EU Animal Health Transport Rules

3 Apr 2024
Message — UECBV calls for revising transport rules to allow one vehicle to deliver animals to multiple destinations. They also advocate for more proportionate movement restrictions during outbreaks of vector-borne diseases.12
Why — This would lower logistics costs and prevent trade shutdowns for livestock and meat operators.34

Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Nov 2023

UECBV supports the Commission's efforts to reduce food waste in the European Union and is dedicated to helping reach the targets proposed, thereby mitigating the climate impact and lowering emissions. Our members have undertaken multiple initiatives to decrease the food waste in the meat sector and show daily commitment to the goals proposed with initiatives targeting food companies and stakeholders in the food chain, including consumers. Food waste results in economic losses for food business operators, who strive to optimise the use of their products. Moreover, disposal costs in the meat industry are substantial, and producers aim to minimise them. However, occasional food waste in the meat industry results from factors beyond operators' control. This is evident, especially when competent authorities inadvertently fill out paperwork incorrectly, and legal regulations prevent the utilisation of such waste as food in specific situations. In addition, there is currently a lack of clarity and consistency across Member States regarding the measurement and definition of food waste. Requirements for data reporting (voluntary and/or regulatory) vary considerably, and the associated bureaucracy is significant. This poses challenges in terms of data availability and accuracy when setting and monitoring targets. The differing methodologies among Member States and considerations on categorisations of food waste, byproducts, and animal byproducts further exacerbate this problem. For these reasons, we encourage the Commission to establish rules for standardised measurement methods for food waste, but also to establish clear definitions and guidelines for a standardised approach between Member States. UECBV is open to dialogue and emphasises its dedication to reducing food waste. This commitment is demonstrated through its endorsement of the EU Code of Conduct on Responsible Food Business and Marketing Practices, as well as its alignment with the 12th UN Sustainable Development goal. The European Livestock and Meat Trades Union (UECBV), founded in 1952, is the EU voice of national federations representing livestock markets, livestock traders (cattle, horses, sheep, pigs), meat traders (beef, horsemeat, sheep meat, pig meat), and meat industry (slaughterhouses, cutting plants and meat preparation plants). Brought together within the UECBV are: an international association i.e. the European Association of Livestock Markets (AEMB); a Young European Meat Committee (YEMCo); the European Natural Sausage Casings Association (ENSCA) the Organisation of European Ship Sppliers (OCEAN) fifty-three national or regional federations in twenty-three of the twenty-seven Member States of the European Union, as well as Japan, Norway, United Kingdom, Switzerland and Ukraine. In total, some 20,000 firms of all sizes and 230,000 jobs are represented within the UECBV through its national member federations.
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Response to Amendment of the list of products and substances authorised in organic production

22 Aug 2023

UECBV supports the amendment on the extension of the use of ascorbic acid (E300) in meat preparations, in addition to meat products which are already authorized. This amendment brings clarity to the industry as well as variety, which positively contributes to the increase of food safety and food security and reduction of food waste. In fact, evidence shows that E300, due to its reducing properties, prevents oxidation of meat, which reduces the discolouring of the food during storage and the formation of metmyoglobin. Lipid oxidation is likely reduced as well, as ascorbic acid (also known as Vitamin C) binds with oxygen and reduces the oxygen available for the breakdown of lipids. This increases shelf-life and meats colour, which in retour increases food safety and food security, while reducing food waste (1). As a hydro soluble vitamin, vitamin C has very low acute toxicities and there are no genotoxicity, chronic toxicity or carcinogenicity concerns, even at high doses, as tests have shown. EFSA reports have concluded that there is no safety concern for the use of ascorbic acid, and so it can be safely used as an additive (2). In conclusion, due to the positive aspects shown on food safety, food security and food waste and the negligible risk for the human health that the use of ascorbic acid brings to the table, UECBV is pleasant to support this amendment. Bibliography: 1 Expert Group for Technical Advice on Organic Production (EGTOP). Food VIII Final Report (2022). Retrieved August 7, 2023, from https://agriculture.ec.europa.eu/system/files/2023-05/egtop-report-food-viiii_en.pdf 2 EFSA ANS Panel (EFSA Panel on Food Additives and Nutrient Sources added to Food), 2015.Scientific Opinion on the reevaluation of ascorbic acid (E 300), sodium ascorbate (E 301) and calcium ascorbate (E 302) as food additives. EFSA Journal 2015;13(5):4087, 124 pp. doi:10.2903/j.efsa.2015.4087 The European Livestock and Meat Trades Union (UECBV), founded in 1952, is the EU voice of national federations representing livestock markets, livestock traders (cattle, horses, sheep, pigs), meat traders (beef, horsemeat, sheep meat, pig meat), and meat industry (slaughterhouses, cutting plants and meat preparation plants). Brought together within the UECBV are: fifty national or regional federations in twenty-four of the twenty-seven Member States of the European Union, as well as Japan, Norway, United Kingdom, Switzerland and Ukraine. the European Association of Livestock Markets (AEMB); a Young European Meat Committee (YEMCo); the European Natural Sausage Casings Association (ENSCA) the Organisation of European Ship Suppliers (OCEAN) In total, some 20,000 firms of all sizes and 230,000 jobs are represented within the UECBV through its national member federations
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UECBV calls for clear rules on environmental green claims

21 Jul 2023
Message — UECBV supports the effort to harmonise claims and labels to ensure sector credibility. They argue that additional criteria like animal welfare should not be part of this directive. They also demand clearer wording to ensure a level playing field.123
Why — This would allow companies to get credit for specific environmental improvements.4
Impact — Animal welfare groups may lose visibility if excluded from these labels.5

Response to Updating the legislation related to the hygiene rules for products of animal origin

25 May 2023

UECBV welcomes the draft Commission Delegated Regulation amending Annexes II and III to Regulation (EC) nº 853/2004 of the European Parliament and of the Council as regards specific hygiene requirements for certain fresh meat, fishery products, dairy products, and eggs. For UECBV, one of the most relevant aspects of this draft is the update on the rules for transport of meat. UECBV thanks the European Commission for taking into account the outcomes of the Workshop on F2F: optimizing the framework and conditions for carcass transport for more impact on sustainability in the EU organised by UECBV on 2nd June 2022. In this context, UECBV has some aspects to point out. On other topics such as aged meat, UECBV welcomes the initiative. However, some aspects of the proposed rules need to be reviewed in order to make the practice of meat dry aging feasible for industries. This document intends to go into detail on the most relevant aspects that affect the meat industry, mainly contained in the annex to the draft attached to the relevant public consultation. We will not raise any comments on the draft about topics that do not affect the meat sector.
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Response to Review of poultry marketing standards

19 May 2023

UECBV welcomes the revision of the marketing standards for poultry products as it is an opportunity to align these standards with the current reality of market and technology. In this context, UECBV would like to highlight some elements on this draft that need to be revised, in particular the standards on the water content of poultry meat imported from third countries, as this draft does not foresee any changes on this matter. The document in attachment intends to cover the public consultations for both, delegated and implementing draft regulations.
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Response to Review of poultry marketing standards

19 May 2023

UECBV welcomes the revision of the marketing standards for poultry products as it is an opportunity to align these standards with the current reality of market and technology. In this context, UECBV would like to highlight some elements on this draft that need to be revised, in particular the standards on the water content of poultry meat imported from third countries, as this draft does not foresee any changes on this matter. The document in attachment intends to cover the public consultations for both, delegated and implementing draft regulations.
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Meeting with Sandra Gallina (Director-General Health and Food Safety)

11 Apr 2023 · Legislative framework for sustainable food systems Animal welfare

European meat union demands clearer rules for livestock vessel inspections

6 Dec 2022
Message — The group requests deleting ambiguous wording to ensure harmonised enforcement of welfare rules across Member States. They demand that video evidence remains private and is never transferred to third parties. They also propose limiting the storage of inspection data to a maximum of three years.123
Why — This would protect the sector from subjective interpretations and the misuse of employee data.4
Impact — Animals lose protection if inspectors cannot intervene against conditions likely to cause harm.5

UECBV calls for flexible, cost-effective livestock vessel welfare checks

6 Dec 2022
Message — The group supports the database but seeks flexibility for shipboard welfare inspections. They propose allowing designated technicians to perform checks instead of official veterinarians.12
Why — This would reduce the high and variable costs of mandatory vessel inspections.34
Impact — Animal welfare standards may suffer if technicians replace specialized official veterinarians.5

Response to Further cutting of carcases pending outcome Trichinella control.

13 Jun 2022

UECBV welcomes the proposal for an implementing regulation amending Implementing Regulation (EU) 2015/1375 as regards Trichinella control in relation to cutting of carcasses and alternative analytical methods. UECBV thanks the Commission for reassessing and reviewing rules and regulations on risk and science base. Allowing meat processors to cut carcasses into more than 6 parts will contribute to a more efficient use of energy for chilling meat. It will contribute to optimise energy and to reach the goals of F2F Strategy and Green Deal.
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Response to Application of EU health and environmental standards to imported agricultural and agri-food products

16 Mar 2022

The European Livestock and Meat Trades Union (UECBV) welcomes the call for evidence on the application of EU health and environmental standards to imported agricultural and agri-food products. Through the EU Green Deal, the objective of the EU is to address and reverse climate change. We all agree with this objective. The methods of getting there however differ and we welcome the debate with this call for evidence to discuss the application of EU health and environmental standards to imported agri-food products. As stated in the call for evidence, the EU is the largest global exporter and the third largest importer of agri-food products. The EU, with its 500 million consumers has a role to play to gear towards greater sustainability in the agri-food sector in the EU, but also globally. In the context of the call for evidence, UECBV would like to flag some aspects as they are considered crucial for keeping a healthy trade activity. The import rules for foodstuff in the EU are fair and equal for all supplying third countries. These rules ensure the food safety of the imported products while contributing to the food security in the UE and the development of third countries. Private certification schemes are the result of consumers’ ethical expectations on food products. These schemes are important drivers for internal but also for international trade. One of the main uncertainties is whether stricter rules related to environmental aspects such as “deforestation free” for imported agricultural products shall really have the expected global impact or will jeopardise the EU food security. In addition, if this is requested to third countries, then the EU should not produce or export products that do not meet these requirements. Measures could even have a counter-effect as supplying third countries could divert the destinations for their products to territories requiring lower standards than the current requirements in the EU. More details on our feedback can be found in the document in attachment.
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Response to Food waste reduction targets

29 Oct 2021

UECBV - the European Livestock and Meat Trades Union - supports the Commission’s initiative to reduce food waste and contribute to sustainable food systems. We would like to remind the Commission about the efforts made by the slaughterhouses, turning bio-waste, residues, and discards into valuable resources, and bring the most value of the carcases to support the nutritional circulations which is vital for both human and environmental health. In the past decades, the meat and livestock industry have significantly optimised their operation through innovation and research to increase the percentage of the slaughterhouses output for human consumption and minimalise waste in the meat production chain. A recent report shows that at the beef slaughterhouse level food waste is less than 2% when using the EU definition . Regarding the scope, we recommend adopting Option S2, which brings efficient and effective approaches by identifying and incentive the hot spots in the production chain to reach the reduction target. Targets and methods applied should not distort competition, neither go against internal market principles. Each part of the chain has its own responsibilities; notwithstanding, the whole system should be coherent. The EU initiative should leave flexibility to the Member States to apply them also through public-private agreements. There are many policies and strategies that address food waste, and a harmonized approach must be considered to make sure the approach to Food Loss and Waste reduction is consistent with other food policy initiatives. We also identify the need for better and more validated data on food waste. In general, the data on food waste is very scarce in the different sectors. The first public data on food waste from all Member States will not be available until mid-2022. There is a great need for better and more validated data on food waste and in addition, more harmonized methodology for reporting food waste in the Member States. Therefore, setting a reduction target on food waste in 2023 based on proper evidence might be unrealistic. Targeting food waste can be tricky as there may be trade-offs, such as between food safety and sustainability (when it comes to the preservation process with salt, for example, packaging, etc). A scientifically based targeted Impact Assessments on the various proposed policy measures/options needs to be carried out. We believe that in any case sustainability can’t be at the expense of food safety. However, the management of the trade-offs need to be clarified. We would like to highlight the need to bring more research and innovation to unlock the potential reduction on waste and the importance to take scientific-based target, measure, and act approaches which carefully exam the balance between different trade-offs. European funded research project Water2Return, which aims to create value from slaughterhouses wastewater by grow algae that can be used in animal feed or organic fertilizer, is one example which contributes to both food waste and circular economy . Lastly, we would like to address the role of education. Too often food is wasted due to lack of understanding of the importance of the maintenance of the cold chain and the behavior towards the expiry date. We believe that simple advice for handling meat at consumer level could lead to a sharp reduction of the meat that is wasted at household level. This includes recommendations such as keeping the meat at no more than 3 ° C, cooking the meat before the expiry date and keep it few more days cooked before consumption or putting the meat in the freezer if it cannot be consumed before the expiry date.
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Response to Sustainable food system – setting up an EU framework

26 Oct 2021

UECBV supports the shift towards increasingly sustainable food systems and welcomes the opportunity to comment on the Inception Impact Assessment on sustainable food system framework initiative. UECBV is aware of the urgency to take actions to mitigate climate changes and is willing to play its role. Please find attached UECBV contribution to the Inception Impact Assessment.
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Response to Animal welfare labelling for food

24 Aug 2021

UECBV welcomes the Inception Impact Assessment on the Revision of the EU legislation on animal welfare. Consumers have high expectations in terms of animal welfare. They want guarantees on the conditions under which animals are reared, transported and slaughtered. These expectations are legitimate, and, to this end, many measures have already been implemented to guarantee animal welfare at all stages of the animal's life. These measures are not well known to the general public, but the European regulations to ensure animal welfare during transport and at the time of slaughter (Regulations EC 1/2005 and EC 1099/2009) lay down a large number of effective rules and are in fact very protective of animals. However, some of the requirements of these regulations need to be re-evaluated in the light of feedback and new scientific knowledge. We recall that scientific data is a necessary but not sufficient basis for a decision on animal welfare: operational feasibility and interactions with other imperatives (safety, animal health, economic viability, social issues, environmental issues and limitation of the administrative burden) must be taken into account with the objective of producing sustainable European meat. The Incept Impact Assessment seems to be based on the information provided by the Fitness Check. Nevertheless, as the Fitness Check is not finalised at this date, the details of the present Inception Impact Assessment should be coherent to the information currently available or should be postponed until the fitness check is completed. Furthermore, the Commission should: • Make laws based on independent scientific evidence. • Ensure a level playing field in the trade context, as a requirement of higher animal welfare standard. • Ensure the economic sustainability of livestock and meat sector via fair distribution of costs and benefits between all the actors (from the farmer to consumers). Some comments and proposals for the relevant document can be found in attachment.
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Response to Union tariff rate quota for High Quality Beef from Paraguay

13 Aug 2021

UECBV thanks for the possibility to react on this consultation. The European Livestock and Meat Trades Union is of the opinion that the setting of import quotas reflects a deliberate and balanced approach to the EU market. In this respect and due to WTO-handling as well, the proposed correction seems appropriate and necessary in view of the Brexit circumstances. Specifically the 1 000 t import quota for high-quality beef from Paraguay has usually been filled to more than 90 % in the past years and the relevant consumer demand on the European market could be met with the help of the import quota. Importing companies in Europe, mainly from Germany and the Netherlands, were enabled to establish trusting business relationships with exporters in Paraguay so it has to be kept in mind that the formally corrected reduced quota volume makes it more difficult for operators in the main importing countries to meet the usual volume of demand for quality beef from Paraguay. It has to be pointed out that the EU has made an omission for Brexit-issues which led to a change in EU legislation which should not have taken place. The only way The EU Commission can do is correct this omission and bring EU legislation back into line how it was before the change on basis of this omission for this specific point, Union tariff rate quota for High Quality Beef from Paraguay. So taking into account that hardly any deliveries within the quota were destined for the United Kingdom and that the quota should not have been divided in the first place, restoring the quota volume of 1 000 t is the only correct course of action.
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Meeting with Frans Timmermans (Executive Vice-President) and European farmers and

31 May 2021 · Exchange on Farm to Fork Strategy with European Livestock Voice

Response to Authorisation to feed poultry with processed animal protein derived from farmed insects or domestic porcine animals

6 Apr 2021

UECBV, the livestock and meat trade EU voice, acknowledges the “COMMISSION REGULATION (EU) …/… of XXX amending Annex IV to Regulation (EC) No 999/2001 of the European Parliament and of the Council as regards the prohibition to feed non-ruminant farmed animals, other than fur animals, with protein derived from animals”. The amendment provides for the re-authorisation of the use of processed animal proteins from pigs in poultry feed and processed animal proteins from poultry in pig feed and the lifting of the ban on feeding ruminant collagen and gelatine to non-ruminants. UECBV supports the European Commission's draft regulation to partially lift the ban on feeding animal proteins to non-ruminants, welcomes the proposal including the lifting of restrictions to the use of former foodstuffs containing ruminant gelatine plus the use of insect PAPs in pig/poultry feed and proposes additional options. Please see the full UECBV-contribution in the annex.
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Response to Information and promotion measures for agricultural and food products in the internal market and in non-EU countries

9 Mar 2021

The Promotion policy is of very high importance for the EU Agri-Food products, including for the meat sector. EU standards are high and costly for the EU Agri-Food producers. The promotion scheme is an important tool allowing to valorise the efforts of these producers and promoting EU values. It is an important tool for the competitiveness of the Union’s agricultural sector. Please find UECBV' s contribution in annex.
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Response to Laying down rules on equine passports

4 Mar 2021

UECBV welcomes the Commission's initiative to refine the identification of horses and make passports more fraud-proof. The fraud-resistance of horse passports is of great importance to the meat industry in view of the problems they are now facing. Today, the reality is that the control of passports and, on this basis, the authorization to slaughter for human consumption is not uniform in the various Member States. Some types of passports are validated without problem in one Member State, while in other Member States every possible means is used to prove that a passport has been used for fraud, often incorrectly. In addition, the current passport system is too susceptible to fraud. The industry is not responsible for any passport fraud, much less for the different interpretations by the control authorities in the different Member States. The industry needs legal certainty. This means that once a horse has been found suitable for human consumption after verification of identification, passport verification, ante-mortem and post-mortem inspection, this cannot be questioned later on the basis of deficiencies in the field of identification and passport. The task of the Commission is to put in place a system that eliminates fraud by making identification and passports 100% fraud-proof. Making a Community database compulsory instead of one per Member State, the issuing of passports by one official authority per Member State and the mandatory recovery of identification chips after death or slaughter would already represent significant progress. Some mistakenly regard the horsemeat sector as susceptible to fraud. We have to conclude that for too long there has been too little interest among the Member States to exclude fraud. UECBV especially welcomes in the proposal that the exclusion from human consumption by the owner/operator is no longer possible but regrets that the Commission does not tackle the problem of the still growing number of horses for the reason of administration of unauthorised veterinary medicinal products. There are no scientific arguments for a lifetime exclusion form the food chain. A waiting period of 6 months should resolve this problem. We would also like to point out that: • the demand for high-quality animal protein continues to rise as a result of the growth of the world population and the rise in the standard of living in a number of countries with large populations; • in these harsh economic times, many horses are neglected for lack of residual value at the end of their lives; • if horses that were initially destinated to sports, pleasure or other activities go into the food chain when that purpose ends, it would contribute to circular economy and sustainability since we turn it into value added meat instead of waste; • the Commission fights against food waste while 50,000 tons of horse meat are banned from the food chain for unjustified reasons; • the European Commission has a Green Deal Project in which animal welfare, sustainability, reduction of carbon emissions, food safety and food security are important elements.
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Response to Revision of EU marketing standards for agricultural products

16 Feb 2021

The European Livestock and Meat Trades Union (UECBV), is the EU voice of national federations representing livestock markets, livestock traders (cattle, horses, sheep, pigs), meat traders (beef, horsemeat, sheep meat, pig meat), and meat industry (slaughterhouses, cutting plants and meat preparation plants). UECBV herewith contributes to the Inception Impact Assessment - Agricultural products - revision of EU marketing standards - see annex.
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Response to Setting of nutrient profiles

3 Feb 2021

Thank you for the consultation. Please find UECBV feedback in the attached document.
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Response to Contingency plan for ensuring food supply and food security

13 Jan 2021

UECBV as livestock- and meat trade union welcomes the idea of a contingency plan and in particular a special position to the food sector about the whole chain according to the farm-to-fork approach. UECBV is available for discussing further developments and refers to its experiences clearly proven its performance. You will find attached our first feedback to the contingency plan deadline 13.1.2021.
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Meeting with Carlos Morais Pires (Cabinet of Commissioner Mariya Gabriel)

15 Dec 2020 · To introduce UECBV (European Livestock and Meat Trades Union) and YEMCo (Young European Meat Committee).

Response to New EU Soil Strategy - healthy soil for a healthy life

10 Dec 2020

UECBV supports the EU-Commission’s objective to address soil degradation and preserve land resources, as part of the EU biodiversity strategy for 2030 protect. We would like to highlight the importance of livestock to biodiversity and to nutrition cycle in soil. In the study on Future of EU livestock, published by EU Commission early this year in 2020, clearly mentioned that livestock, especially ruminants, can have a positive impact on biodiversity and soil carbon via the maintenance of permanent grassland and hedges and optimized use of manure. Livestock can also contribute to protect soil fertility. The contribution of livestock manure with a high C / N ratio (compost, manure) has a generally favorable impact on soil organic matter content and macrofauna (earthworms). Regular supply of effluent appears to improve soil biological functions and to influence soil microbial biodiversity because they are both a source of many nutrients for native soil flora and they are also complex inoculum. Soil is a valuable resource for a thriving ecosystem. The new Strategy must acknowledge the role that livestock play in maintaining healthy soils and facilitate the sector to continue preform better practices to improve land management and nutrient circle.
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

UECBV supports the overall ambition to act on climate change and finds it essential that the agricultural and forestry sector contributes to the debate on climate action. It profoundly supports the initiative to significantly raise the sustainability standards in the EU in a harmonized way. It agrees that sustainable initiatives should be encouraged but it does not understand that it is indicated that “decrease in the consumption of animal-derived products” is mentioned as a good example. It is not in line with what the Commission representatives affirm that no one must be left behind and what must be encouraged is a sustainable production of animal products. We need a sound, fair and a balanced approach, excluding misinformation. Please find attached the UECBV position paper on the Farm to Fork strategy.
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Meeting with Janusz Wojciechowski (Commissioner) and

23 Nov 2020 · Green Deal and Farm to Fork objectives.

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

12 Nov 2020 · Increasing sustainability in the meat sector

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Ines Prainsack (Cabinet of Commissioner Stella Kyriakides)

9 Nov 2020 · VC Meeting - Farm to Fork Strategy and Animal Health

Response to Model health certificates for certain categories of animals and goods

3 Nov 2020

UECBV thanks the Commission services for the opportunity given in commenting about this topic. Please find attached our contribution in PDF format.
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Response to Revision of specific rules of food of animal origin

30 Oct 2020

UECBV thanks the Commission for this public consultation. Please find our comments in the attached file as it will be easier to read.
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Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

16 Sept 2020 · current African swine fever (ASF) situation

Response to Environmental claims based on environmental footprint methods

31 Aug 2020

UECBV sees the upcoming legislative proposal on substantiating green claims as the basement for allowing businesses to go to carbon neutrality. It is of the utmost importance to go towards scientifically based, fair and “harmonised claims” so that efforts are comparable, looking for the same goals and no one is left behind but creating incentive to move forward. Methods of calculation must be agreed by stakeholders and paving the way to a feasible reduction of carbon footprint, step by step. Impact assessments with relevant stakeholders must be performed regularly so that no radical decisions with damaging consequences are taken. Nevertheless, UECBV is worried by that issue as it is a highly complex issue. Each sector has its reality and even each part of the expertise has its point of view depending on the angle from which it looks at the issue. There could be some conflicts of interest: Food safety v/carbon footprint: will food safety be a criterion of sustainability? Methane emissions v/carbon sink; land management; natural fertilizers (safeguarding EU soils and biodiversity), circular economy: Ruminants are often mentioned as bad for the environment, but their positive roles need also to be acknowledged and taken into account. The EU livestock sector provides many valuable natural by-products and services to our society and support for eco-system services, mainly in rural areas. In addition, the livestock sector provides many raw materials & components for the manufacturing of consumer products such as pharmaceutical products, cosmetics, leather, wool and fur products, feed for food producing animals and pet food, biodiesel, porcelain & insulation material. All European agricultural sectors and their diverse production methods must be respected. Different systems have different advantages. They all must be able to make their local contribution in sustainability. In our livestock and meat sectors, we need further investments to make this happen, with the support of decision-makers for consistent, complementary and common EU agri-food chain policies. Furthermore, even at local level, the realities may differ. What can be efficient in one place, could be less in another place. EU geography is diverse. Efforts made by the front runners must be acknowledged so that they are not punished by the future rules. The system must be fair and flexible to adapt to each situation. For example, the principle of a fixed mass fraction does not allow the flexibility to be fair and it does not create incentive for slaughterhouses to improve practices.
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Response to Fitness Check of the EU legislation on animal welfare

24 Jul 2020

UECBV thanks the Commission services for the possibility of forwarding comments of the Fitness check of the EU legislation on animal welfare of farmed animals. UECBV believes that the fitness check can be an opportunity to check the legislation with the current scientific information. However, the check must consider not only the scientific information, but also the people on the work floor, those that must implement this regulation, to give them the chance to speak and to be listened. It is important that EU focus on helping farmers and producers of food to provide Europe and the global market with high quality, affordable and safe food in a sustainable manner. Animal welfare aspect is sometimes misused by some stakeholders to disapprove the meat consumption or industrial animal farming, without taking into account that the legislation is objective, practicable and that the political decisions are (and must be) based on facts and not on emotional feelings. Further, UECBV is of the opinion that this is an opportunity to bring all European Member States to the same level. UECBV is happy to provide comments on some of the basic acts which are undergoing the fitness check, more in details: • Council Regulation (EC) No 1099/2009 of 24 September 2009 on the protection of animals at the time of killing; • Council Regulation (EC) No 1/2005 of 22 December 2004 on the protection of animals during transport. Please find attached a document containing the complete review of the two legislations abovementioned.
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Response to Food & feed imports -“first-come, first-served” tariff quotas (delegated rules)

8 Jun 2020

The consultation refers to the ongoing comprehensive revision of the management rules for the agricultural sector's first-come, first-served quotas (FCFS). As with the licence quotas currently under revision, the individual quota-specific provisions for the FCFS quotas will be brought together in a delegated regulation and an implementing regulation. In addition, some licence quotas that have been little used will be converted into FCFS quotas. As far as can be seen at present, hardly any material changes are planned compared to the previous regulations. Except for the abolition of import rights and licences, the previous handling of the quotas is provided for, whereby the obligation to provide evidence pursuant to Article 5 of Regulation (EC) No 412/2008 for quotas under the a+b rule is not applicable. Among the FCFS quotas, which will in future be administered via the combined legal acts, is also the hqb II quota under EC No. 481/2012. Its function remains essentially the same, except for the definition of "frozen" beef. Some FCFS quotas, such as the import quota 09.0833 for sheep meat from Iceland, are not (yet) covered by the present draft of Annex I. In addition, the related legislation (EU 2018/1206) is not (yet) repealed. UECBV requests the justification for this and demands that transparency and congruence must be ensured with regard to the comprehensive new regulations.
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Response to Climate Law

1 May 2020

UECBV shares the general concern about climate change and welcomes the Commission’s proposal for a European climate law which was published on 4 March. The enshrinement of the 2050 climate neutrality goal in legislation and the holistic view taken by the Commission in the context of the European Green Deal will help engage all economic actors collectively in a common trajectory and encourage the swifter development of enabling conditions. It is also essential to provide long term guidance and predictability to businesses to invest in the transition. As mentioned in the Paris agreement, the Climate law should aim at “Increasing the ability to adapt to the adverse impacts of climate change and foster climate resilience and low greenhouse gas emissions development, in a manner that does not threaten food production. (Article 2)” UECBV welcomes the goals mentioned in the recitals, in particular: (Read the paper)
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Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski)

8 Apr 2020 · An exchange of views for market-stabilization

Response to Farm to Fork Strategy

16 Mar 2020

The F2F strategy is and has to be ambitious. It must be seen first of all as a growth strategy for the EU and not an additional burden that the EU would put on itself. To be successful, the F2F strategy needs to be a collective exercise with a fair and objective share of not only benefits, but also efforts. All value chain stakeholders (including consumers), all systems must feel co-responsible and committed in the process so that it can be a fair and win-win exercise, building on legislative acquis (animal health and welfare, feed and food safety, etc.) and objective facts and science. The complexity must be acknowledged and impact assessments with relevant stakeholders must be performed regularly so that no radical decisions with damaging consequences are taken. It is important to keep in mind that some measures may have consequences that could be in conflict with the initial goal. All European agricultural sectors and their diverse production methods must be respected. Different systems have different advantages. They all must be able to make their contribution in sustainability. In our livestock and meat sectors, we need further investments to make this happen, with your support for consistent, common EU agri-food chain policies. The livestock proteins have an important role to play both on the environmental and circular point of view (maintenance of the grasslands, improved carbo storage practices, biodiversity, reduction of use of chemical fertilisers, renewable energies such as biodiesel and biogas, pharmaceuticals, etc.) and nutritional (essential and exclusive nutrients). This should be clearly acknowledged. The strategy should create incentive to all to improve, leaving from the specific situation of everyone, as a guide to good practices. The F2F strategy creates a good momentum to screen today’s legislation to make it more sustainable when no food safety issue is at stake. Examples: Processed Animal Proteins (PAPs), Age to remove the vertebral column from 30 to 60 months, etc. Need a boost for Research & Innovation but also a politic commitment to make the results usable by the EU food sector as, today, some results cannot be used. The European Innovation Partnership (EIP-AGRI) of DG AGRI has undertaken great efforts in screening the potential innovation that could be implemented in the agri-food sector (including the livestock value chain). Complexity needs structure and overview for getting an order for next steps. The F2F strategy must ensure tight coherence and consistency between the various pillars within the F2F strategy itself and with other EU policy initiatives.
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Response to Minimising the risk of deforestation and forest degradation associated with products placed on the EU market

3 Mar 2020

UECBV supports the EU-Commission’s objective to help counter deforestation, loss of biodiversity violations to human rights and greenhouse gas emissions. We realize that part of the soy production might take place in areas with non-negligible deforestation risk, placing soy as a forest risk commodity. By far the major part of the production is a fully legitimate agricultural production in the producing countries and that trade in soy represents an economic opportunity for exporting countries and an important input to the European livestock sector. We agree that the EU and actors in the supply chain should take responsibility not to contribute to practices in the supply chain that lead to deforestation, loss of biodiversity and violations to human rights. The upcoming commission initiative should encourage and support initiatives that invest in sustainable supply chains, including public-private initiatives. It is important for us that the initiative aims at a level playing field in EU and internationally. Business actors that invest in responsible supply chains should not be penalized in the market. The issues involved are complex. Sustainable land management and the implementation and enforcement of national and regional legislation will play a relevant role for the whole livestock value chain. EU Policy initiatives should be designed in a close cooperation with producer countries in order to have a real impact on the ground and in respect for the interests of those countries. The growing global demand for proteins – most of it coming from emerging economies outside the EU - will lead to a continuing pressure on land resources. An important element of an EU policy should be to find solutions to the global increased demand (in the EU this demand is pretty stable). We suggest that the EU initiative would include legislative and financial support to feed innovation, including biorefining of grass and insects (elaborated in the attached file the whole document and DG AGRI - EIP and ENRD efforts).
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Response to Structure, format, submission process and review of climate information reported under Energy Union Governance

2 Mar 2020

UECBV welcomes the efforts of the European Commission in standardizing the Climate Change reporting of EU Governments. Since the beginning of the 90' the sector has continuously researched for solutions aiming at improving its environmental performances (i.e. reusing/recycling its coproducts, waste - reducing and mitigating its GHGs emissions). Due to livestock, it is today possible to recycle/reuse human inedible by-products coming from other agro-food industries (for instance, beer, soybean, rape seed oil and sugar value chains), if this material wouldn't be used to feed animals, it wouldn't have a comparable efficient use in compliance with the agreed EU methodology regarding waste hiearchy https://ec.europa.eu/environment/green-growth/waste-prevention-and-management/index_en.htm. EU livestock value chain plays a relevant role in the circular economy and climate change mitigation, in the essential maintenance of area with Natural Constraints (marginal lands not usable for crops) and in the adaptationto climate change also in terms of renewable energy (i.e. biogas and biodiesel from manure), carbon sequestration and natural fertilisers production. Renewable energy and natural fertilisers are reflected in the Commission's Green Deal communication. Further to the production of sustainable energy and fertilisers, livestock can further avoid emission in the atmosphere due to fossil carbon thanks to the use of other value chain by-products, for instance leather instead of plastic polymers used by the textile industry. Thus there are already several EU livestock operators producing “zero waste” (because of the fully reuse of the whole animal carcase), we believe that this virtuous behaviour should be supported by public authorities through incentives of different nature (sustainable financing, taxation, R&I founding, CAP). Animal by-products are largely used also in the pharmaceutical industry, one example is the heparine, used as an anticoagulant (blood thinner) overall when heart attacks incur. The EU livestock sector represents today a model and a solution for the future nutritional worldwide challenges. According to the 2019 statement UN (https://www.un.org/development/desa/en/news/population/world-population-prospects-2019.html), the world's population is expected to increase by 2 billion persons in the next 30 years, from 7.7 billion currently to 9.7 billion in 2050, and could peak at nearly 11 billion around 2100. FAO confirms that total demand for animal products in developing countries is expected to grow, by contrast, demand for animal products in the industrial world has been growing at low rates. Today EU is probably the most important meat trades partner of countries where this livestock proteins growing demand is actually happening. By quoting the EC agricultural outlook report (2019), EU public policy choices addressing environment and climate change challenges have led the EU livestock sector to requirements being set in national regulations. These high standards, which must be respected by the operators and which are regularly monitored by the public competent authorities, are unfortunately not respected in a large share of extra EU countries. Environment rules have become more stringent and our companies and farmers have already achieved great progress, in reducing GHG emissions from the EU livestock sector (according to Eurostat below 6% of the EU´s total GHG emissions comes from the livestock sector) https://ec.europa.eu/eurostat/statistics-explained/index.php?title=File:Figure_1_Contribution_of_agriculture_to_total_GHG_emissions_(%25),_EU-28,_2015.png). If we consult the IPCC special report on Climate Change and Land, published in 2019 (https://www.ipcc.ch/srccl-report-download-page/) [please open the attachment to read more...]
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Response to Europe’s Beating Cancer Plan

2 Mar 2020

UECBV welcomes the efforts of the European Commission in supporting, coordinating and complementing Member States' efforts in terms of beating cancer in the EU. In order to make more clarity and to address correctly our contribution, UECBV prefers to keep separate environmental/sustainability aspects related to environmental burden of the EU diets. Since other public consultations on that matter have been already launched either are still ongoing (we reported some of them at the end of this contribution), in order to avoid confusion and to get the points of the consultation, we prefer to keep separate the topics cancerogenity and sustainability and to leave the European Commission to undertake its legitimate and science based actions. The impact of nutrition on health is the subject of many scientific studies. In this context the consumption of red meat and its effect on various diseases is frequently reported. Advocating a reduction of the intake of red meat is generally a claim that is unambiguously supported by scientific literature. A closer look at the currently available data demonstrates that most of the scientific literature regarding this bases on observational studies. At this point UECBV wants to emphazise that observational studies can only provide correlations but no causalities. Generally foodstuffs cannot be considered isolated. It is always about an overview of the whole diet and lifestyle of a person. It can’t be an evidence-based result of a scientific study that the consumption of red meat (part of a balanced diet) increases the incidence of mortality and certain chronic diseases. Conflicting messages have lead to the confusion of the public, whether red meat consumption plays a role in a healthy diet. There is no evidence to suggest that consumption of red meat causes cancer. Cancer is known to be caused by genetics and a combination of lifestyle factors, such as smoking, drinking alcohol, cooking improperly, missing a balanced diet able to safeguard our immune system. Despite many criticism of the influence of meat on health, the impact of red meat on carcinogenicity is not concluded. IARC Monograph (2015) stated it as a ‘probability', based on limited evidence through epidemiological research and its positive association with meat consumption and development of cancer. The World Cancer Research Fund International (WCRF) Cancer Prevention Recommendations advise limiting red meat consumption to 350–500 g per week. Reccomendations are very often expressed in terms of weight of cooked meat, which is a parametre to standardise with raw meat. For Europe, the EFSA collected data from national food consumption surveys of member states of the European Union (EU). The mean meat consumption for adults was about 35 g/d, therefore in our continent there is no need to spread alarmism. Apart from this, the total amount of red meat in the EU has been declining in recent years. The findings in the IARC report are based on people who eat more than 100 g daily of red meat. This is far above the intakes of red and processed meat that most people are consuming today. Public consultations regarding environmental claims: - Deforestation and forest degradation - Reducing the impact of products placed on the EU marker https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12137-Minimising-the-risk-of-deforestation-and-forest-degradation-associated-with-products-placed-on-the-EU-market - Sustainable food – ‘farm to fork' strategy https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12183-Farm-to-Fork-Strategy- -Safeguarding nature – EU 2030 biodiversity strategy https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12096-EU-2030-Biodiversity-Strategy/F502607 -Circular economy – new action plan to increase and reuse of products in the EU https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12095-A-new-Circular-Economy-Action-Plan/F502612
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Response to Climate Law

6 Feb 2020

[Attached the full detailed UECBV feedback with technical and scientific references] The EU livestock value chain welcomes the European Green Deal commitments for Europe's economy and society to become climate-neutral by 2050. Since the beginning of the 90' the sector has continuously researched for solutions aiming at improving its environmental performances (i.e. reusing/recycling its coproducts, waste and reducing its GHGs emissions). The sector plays a crucial role in a circular economy context. Due to livestock, it is today possible to recycle/reuse human inedible by-products coming from other agro-food industries (for instance, beer, soybean, rape seed oil and sugar value chains). EU livestock value chain plays a relevant role in the circular economy also in terms of renewable energy (i.e. biogas and biodiesel from manure), carbon sequestration and natural fertilisers production. Renewable energy and natural fertilisers are reflected in the Commission's Green Deal communication. Further to the production of sustainable energy and fertilisers, livestock can further avoid emission in the atmosphere due to fossil carbon thanks to the use of other value chain by-products, for instance leather instead of plastic polymers used by the textile industry. Thus there are already several EU livestock operators producing “zero waste” (because of the fully reuse of the whole animal carcase), we believe that this virtuous behaviour should be supported by public authorities through incentives of different nature (sustainable financing, taxation, R&I founding, CAP). Animal by-products are largely used also in the pharmaceutical industry, one example is the heparine, used as an anticoagulant (blood thinner) overall when heart attacks incur.
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Response to A new Circular Economy Action Plan

20 Jan 2020

The European Livestock and Meat Trades Union welcomes the road map for the “New Circular Economy Action Plan” of the European Commission and appreciates the possibility to provide inputs and comments to the plan. The European livestock and meat sector has throughout decades had a continuous focus on the resource efficiency, improving it environmental performances (i.e. reusing/recycling its coproducts, waste and GHGs emissions reduction). The sector therefore plays a crucial role in a circular economy context, e.g. in closing bio based industries loops, while at the same time producing high value added value nutritious food and generating societal and economic benefits for rural areas. Due to livestock, it is today possible to recycle/reuse by-products from other agro-food industries (for instance, beer, soybean and rape seed oil and sugar production), which is inedible for humans. The most common livestock species (ovine, porcine, sheep and cattle), cover different aspects in this process. For instance, porcine needs less feed to grow (low feed conversion ratio (FCR)), while sheep and cattle are able to digest better certain raw materials. Improving feed performance on continuously basis, incl. identifying alternative feed sources, improving the FCR, genetic improvements, etc. is a strong priority for the sector and there is a large room for innovation improvements (https://www.ecology.com/2016/03/29/worlds-livestock-industry-offers-huge-potential-greenhouse-gas-reduction/). In this context, UECBV and its members are in close contact with the so-called Animal Task Force, a public-private partnership for a sustainable and competitive livestock sector on for instance feed projects. Livestock value chain plays a relevant role in the circular economy also in terms of renewable energy (biogas and biodiesel from manure and other meat industry industry coproducts) and for natural fertilisers production. The b oth points (renewable energy and reduction of the use of chemical fertilizers) are reflected in the Commission´s Green Deal communication. At slaughterhouse level, a lot of efforts have been put to reduce energy and water consumption. Currently, UECBV is participating in the H2020 project Water2Return https://water2return.eu/. Furthermore, a more flexible, but at the same time more specific, way to define the required water quality for the different slaughterhouse processes could also be worth exploring in the context of the circular economy action plan. Through new technologies and best practices, slaughterhouses have also been able to increase the edible parts of the slaughtered animal, which is an important element in the waste hierarchy. Whilst we are in support of reducing the waste generated by the meat sector, especially plastic packaging waste, it is important to bear in mind some possible unintended consequences of doing so. Plastic packaging plays an important role in keeping food, especially meat, safe for consumers. It enhances shelf-life and enables us to move food safely around the economy. We have a role to play in finding innovative solutions to reduce plastic packaging waste but any action on reducing the amount of plastic packaging in the food sector should be carefully designed so as not to impact negatively on food waste, a major greenhouse gas contributor according to the FAO (http://www.fao.org/3/i3347e/i3347e.pdf). Another solution may be to undertake appropriate research initiatives (supported also by the EASME) in order to find economic affordable plastic alternatives, either to maximise the recyclability rate of plastic packaging In September 2019, in cooperation with the EU red meat industry, UECBV published a Life Cycle methodology, taking into account the principles of the Product Environmental Footprint Category Rules and adapting to the livestock sector and its by-products. T
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

The sustainable and active management of rural areas, such as through ecosystem services, climate change mitigation and biodiversity conservation, must be recognised as contributing to preserve and to restore our ecosystems objectives and compensated accordingly. Carbon storage and sequestration should be promoted and supported as biodiversity related measures, soils with a poor organic carbon content are affected by a low biodiversity and organic carbon soil content is certainly boosted thanks to good practices livestock grazings systems (https://portals.iucn.org/library/sites/library/files/documents/2018-004-En.pdf). Specific measures for Areas with Natural Constraints (ANCs) should be maintained as this will prevent land abandonment and promote biodiversity. Sustainable use of ANCs is compatible with the Habitat Directive and it can avoid wildfires and as a consequence Carbon Dioxide emissions into the atmosphere. Natural dry grasslands (Festuco-Brometalia) (Natura 2000 code: 6210 https://ec.europa.eu/environment/nature/natura2000/management/habitats/pdf/6210_Seminatural_dry_grasslands.pdf) can be found almost in the entire European continent and are among the most species-rich plant communities in Europe (containing a large number of rare and endangered species). This habitats are possible thanks to sustainable grazing systems where livestock is managed by calculating the correct livestock load (LIFE97 NAT/IT/004145). Grazing stock can furthermore transport some of the less mobile species to new areas. Farmers have a key role as environmental managers and in safeguarding the EU biodiversity, nevertheless the complexity of the EU geography and ecosystems should be taken into account. Investments are needed to increase a more competitive and environmental friendly sector.
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Response to Rules on operations to be carried out during and after the documentary check identity and physical checks at the border

23 Sept 2019

UECBV (European Livestock and Meat Trades Union) would like to thank the European Commission services for ithe opportunity to comment this implementing act on documentary, identity and physical checks (SANTE/7164/2019). It is also appropriate to congratulate the Commission services for its work in this implementing act. UECBV would also like to congratulate the Commission on the inclusion of Art. 2(b)on the rule on sealed consignments. As of now, any sealed compartment can fall under reduced checks and that is a welcomed change. UECBV would like to raise a point for improvement. Regarding digital seals, to be able to streamline the process, it would be important to foresees the following situation. In case of a digital seal, the seal number is known at the moment that a decision is taken for a consignment to fall under reduced control. Given that the seal number can be checked and compared with the one on the CHED and proven to be identical, the consignment should be ok at that moment for EU entrance at veterinary level, making the process much faster and simpler. UECBV hopes for these concerns to be taken into consideration. Thank you for your attention.
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Response to Rules for the uniform application of frequency rates for identity and physical checks

23 Sept 2019

UECBV (European Livestock and Meat Trades Union) would like to thank the European Commission services for ithe opportunity to comment this implementing act on rules for uniform application for identity and physical checks (SANTE/7140/2019). It is also appropriate to congratulate the Commission services for its work in this implementing act. Nevertheless, UECBV would like to raise some points that are of importance for our members. It would be important for all acts regarding OCR to be risk-based. On that principle, there should be a legal basis for reduced frequency of checks for good track record producers in the third countries. Also, and although some base level checks have been already reduced (e.g. poultry), there should be always a risk-based approach to the products being controled, meaning that there should be a fast process to increase checks when needed but also a fast process to to reduce the level of checks when appropriate. UECBV hopes for these concerns to be taken into consideration. Thank you for your attention.
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Meeting with Günther Oettinger (Commissioner)

9 Sept 2019 · MFF

Response to Tariff quotas with licences

22 Aug 2019

Background There is an ongoing revision of the EU regulations governing tariff rate quota (TRQ) management and in particular on some aspects of the proposed administration for the overdemanded TRQs. Main objectives to administer TRQ in a fair, objective and transparent manner, is to increase the efficiency of the administration for genuine operators, to prevent its misuse by so called “shelf companies” and to avoid market disruption. Key point The priority for UECBV is to keep bargaining power in Europe and to protect EU SME’s. Position Due to the consultation opened 25. July 2019 and closed 22. August 2019 UECBV’s position is as available in the uploaded annex.
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Response to Tariff quotas with licences

22 Aug 2019

Background There is an ongoing revision of the EU regulations governing tariff rate quota (TRQ) management and in particular on some aspects of the proposed administration for the overdemanded TRQs. Main objectives to administer TRQ in a fair, objective and transparent manner, is to increase the efficiency of the administration for genuine operators, to prevent its misuse by so called “shelf companies” and to avoid market disruption. Key point The priority for UECBV is to keep bargaining power in Europe and to protect EU SME’s. Position Due to the consultation opened 25. July 2019 and closed 22. August 2019 UECBV’s position is as uploaded as annex.
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Response to Draft Implementing Regulation on the procedures for coordinated performance of intensified official controls at borders

7 Aug 2019

UECBV thanks for the opportunity to take part in this consultation and wants first to stress out, that the format of the intensified controls proposals would increase administrative burden extremely with even lacking a risk based approach. So at the moment due to weight and consignment our position is as follows if there is no possibility to get away from the weight criterion we propose a reduction of max 5 times the weight. The total minimal weight criterion of 300 tonnes introduced at a later stage in order to overcome that too many consignments would have to be sent in, if the targeted consignment would be 40 tonnes or even more does still introduce the obligation to sent in too many consignments (20 or even more instead of the normal 10 consignments rule) if a producer does deliver small consignments for export. A change in the minimal weight criterion of 300 tonnes is therefore needed. Just for an explanation, the administrative burden will increase enormously at the level of consignments from small third country producers since they will bring down the weight of their consignments to two to three metric tons, by doing so they reduce the risk of being pushed from the market by the format of the intensified controls proposal. If however also big Third country producers e.g. from South America might seek a risk reduction by splitting up their volumes in for instance 3 parts, this will lead to a big push in the administrative burden at total level. Finally we are of the opinion that regarding the approach of this proposal a reconsideration would be welcomed. In this reconsideration the question should also be included to look in the results and effectiveness of using the 10% weight criterion which currently is used.
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Response to Animal health requirements for movements of terrestrial animals and placing on the market of products of animal origin

23 Jul 2019

UECBV (European Livestock and Meat Trades Union) would like to thank the European Commission services for ithe opportunity to comment this delegated act on rules on movement of land animals within the EU (SANTE/7072/2019 CIS). It is also appropriate to congratulate the Commission services for its work in this delegated act. Nevertheless, UECBV would like to raise several points that are of paramount importance for our members. Please find here-attached the comments of UECBV (European Livestock and Meat Trades Union) and AEMB (European Association of Livestock Markets). UECBV hopes for these concerns to be taken into consideration. Thank you for your attention.
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Response to Animal disease prevention and control measures

19 Jul 2019

UECBV (European Livestock and Meat Trades Union) would like to thank the European Commission services for ithe opportunity to comment this delegated act on rules for the prevention and control of certain listed diseases (SANTE/7070/2019 Rev. 2 CIS). It is also appropriate to congratulate the Commission services for its work in this delegated act and its alignment with science-based data and international standards. Nevertheless, UECBV would like to raise a point regarding the risk mitigating treatments for casings in Annex VI of the delegated act. Please find here-attached the comments and suggestions on that point. UECBV hopes for these concerns to be taken into consideration. Thank you for your attention.
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Response to Animal health requirements for the entry into the Union of animals, products of animal origin and germinal products

12 Jul 2019

UECBV (European Livestock and Meat Trades Union) would like to thank the European Commission services for its work regarding this delegated act on the animal health requirements for entry into the Union (SANTE/7068/2019 CIS). Firstly, UECBV would like to congratulate the Commission services for this delegated act and its alignment with science-based data and with its risk-based approach. Nevertheless, there are some points that UECBV would like to highlight: In article 6, point 2 (National legislation and animal health systems of the third country or territory of origin): ‘Consignments of animals, germinal products and products of animal origin intended for entry into the Union shall only be permitted to enter the Union from a third country or territory or zone thereof where such consignments may be lawfully placed on the market and traded in that third country or territory of origin or zone thereof.’ As it is it could potentially lead to situations where because the exporting market has different requirements to the EU requirements the product produced there can’t be exported to the EU because it does not meet the exporting market’s requirements, even though it meets the EU requirements. Which could potentially restrict trade in an unjustified way. In article 132 (Derogation from direct dispatch of the kept animals of origin of the fresh meat to a slaughterhouse), it states “By way of derogation from Article 124(a), consignments of fresh meat of kept ungulates not complying with those requirements shall be permitted to enter the Union provided that the fresh meat was obtained from ungulates of the species Bos taurus, Ovis aries, Capra hircus and Equus caballus, not including Equus caballus hippotigris (zebras), and…”. Couldn’t Bos Indicus be also included in the list of species mentioned here-below? Article 5, point 2 (c) states that operators should ensure consignments are “not diverted for uses other than those for which they were certified by the competent authority of the third country or territory of origin for the entry into the Union.” Is this article taking into account situations like if a product imported and certified for human consumption is at the end, for commercial reasons only, used as pet food? UECBV hopes for these concerns to be taken into consideration. Thank you for your attention.
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Response to Animal disease notification, reporting, surveillance, eradication and disease-free status

3 Jul 2019

UECBV (European Livestock and Meat Trades Union) would like to thank the European Commission services for its work regarding this delegated act on surveillance, eradication programmes, and disease-free status for certain listed and emerging diseases (SANTE/7066/2019 CIS Rev. 3). However we would like to point out some points of improvement regarding Tuberculosis (TB) and Bluetongue (BT) provisions. Regarding TB, UECBV would like to specifically point to the proposed rules for testing (Annex IV, Chapter 1, Section 1, pages 21 to 26): The current draft regulation will lead to unnecessary increased control costs as it will require herds with a confirmed TB outbreak to be under movement restrictions for a minimum of a year, rather than the current minimum of 4 months. It also proposes more constraints on movement for herds within an Official TB Free (OTF) zone than for herds within a high incidence zone or zones where cattle are on an annual testing regime, which does not seem to be just or appropriate, especially because in those regions there is no evidence of disease re-occurrence, no evidence of current disease controls being ineffective and no evidence of significant wildlife reservoirs. Also, in practice we see that the current system works as occasional outbreaks are confirmed and eradicated rather quickly and with no evidences of reoccurrence. The proposal to extend the minimum period of movement restrictions to 12 months is inappropriate and an unnecessary burden in OTF regions where there is no evidence of disease reoccurrence. The existing controls of two clear tests 60 days apart have been shown to be effective with no evidence of benefit to be gained by the proposed two tests at 6 monthly intervals. Furthermore, the derogations in the proposed Regulation will do very little to help reduce the number of holdings caught up in prolonged restriction and will serve only to help herds in the higher risk areas where annual testing takes place. The derogation to allow herds that have had a clear herd test in the previous 12 months will only assist herds in high-risk areas where testing is on an annual or 6 month testing regime, the very herds that it might be argued are most likely to have disease reoccurrence. Regarding Bluetongue, and also having in mind the delegated act on movement of terrestrial animals within the Union, UECBV thanks the Commission on include derogations that in some way emulate the current bilateral agreements in order to permit the movement of animals from lower BT-health status regions to higher BT-health status regions. However, the acceptance of the guarantees between two Member-States (MSs) should not automatically be extended to all other MSs. Different MSs have different contexts and realities. There should at least be a provision that includes a risk assessment or other type of procedure that is able to maintain the trust and confidence between MSs, has it happened before with the bilateral agreements. UECBV hopes for these concerns to be taken into consideration. Thank you for your attention.
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Response to Enhancing Market transparency in the agri-food chain

19 Jun 2019

UECBV, the European Livestock and Meat Trades Union The European Livestock and Meat Trades Union (UECBV), is the EU voice of national federations representing livestock markets, livestock traders (cattle, horses, sheep, pigs), meat traders (beef, horsemeat, sheepmeat, pigmeat), and meat industry (slaughterhouses, cutting plants and meat preparation plants). In total, some 20,000 firms of all sizes and 230,000 jobs are represented within the UECBV through its national member federations. UECBV believes in a healthy and competitive European livestock and meat sector and the need for a transparent market and, therefore, supports Commission initiatives, such as EU Market Observatories. UECBV is, however, deeply concerned about the potential effects of the Commission’s proposed market transparency initiative. While UECBV is generally in favour of increased transparency in the form of improved existing data, it believes that the EU meat market is already very transparent. Since the launch of the Meat Market Observatory (MMO), market transparency of the EU meat sector has already improved. However, market transparency in the scope of the new initiative by the Commission would undermine trade and commercial confidentiality that should not be made publicly transparent in order to maintain competition between companies, competitors and customers. UECBV believes that the level and frequency of price data reporting proposed by the Commission lead to coordination between competitors and price-fixing which will, in the end, harm the food chain. Furthermore, excessive price transparency can reduce operators’ negotiating capacity and, thus, restrict competition and undermine overall returns from the marketplace. In addition, due to the lack of harmonised product description, market information can be misinterpreted and contribute to a distorted picture of the supply chain as scientific research clearly demonstrate as shown last 2018 which was send to the Commission in the context of our Position Paper. Broadening market transparency beyond the level already achieved poses not only the threat of unintended consequences, but, in practice, might also be very hard to achieve due to confidentiality issues. In the livestock and meat sector, products and cut specifications are vast in number, complex and very difficult, if not impossible, to compare between Member States. For years, prices for beef, lamb and pork carcasses have been collected and reported on the basis of EU carcass classification schemes. However, these prices are not easily comparable and only indicate trends because many other parameters that influenced them are not EU harmonised. Therefore, in terms of market transparency, the priority should be the improvement of these prices instead of adding further confusion. In UECBV’s opinion, the objectives should be first to make the best possible use of existing data from public and private sources; this may also be more cost-effective, even if Commission services purchase data. Second focus on the quality of the collection and reporting of prices paid to the producers, mainly in terms of comparison. Third improve data on EU figures a) intra-trade figures, b) on Production and c) Consumption. Fourth proposal of improvement is to adapt the ambition for downstream prices to the limits that are described by the UECBV concerns. This ambition should also comply with the outcomes of a cost/benefit analysis. For instance, as a preliminary step, UECBV would like to propose to the Commission Services an annual Market Transparency update, the selection of a small number of reference cuts, the publication of price index at EU level. Finally, regarding the Organic meat price premium (mainly for the beef sector), UECBV suggests looking for an organic price when collecting carcass price data.
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Response to The Information Management System for Official Controls regulation (IMSOC)

17 Jun 2019

The European Livestock and Meat Trades Union (UECBV) would like to thank the European Commission for the opportunity to provide comments to the draft Implementing act on IMSOC. The delegated and implementing acts of Regulation EU/625/2017 are of the utmost importance to guarantee the safety of animals, foods and/or products on the EU single market. However, they also impact the activity of EU operators across the whole EU food sector. UECBV would like to repeat the need for the Commission to be flexible and simplify the legislation when it does not impact animal or food safety. On that note, we would like to make the following comments on the CHED models included in this draft Implementing act: The information provided in today’s certificates is of paramount importance to guarantee the safety of EU imports and maintain the high-level of safety that Europe is recognised to have. In the models proposed in the draft IMSOC regulation there are a number of newly required data that can be considered as redundant or not needed for authorities. As representatives of the EU operators, we agree with the proposal made by the Dutch authorities (see "NL Comments on 7042-EN and 7042-EN ANNEX-PAFF (as distributed on 4 April 2019)") and urge the Commission to make sure the data required in the certificates is of sufficient added value, actually deliverable and proportionate to the economic impact it can cause. If no change is done to the draft, the EU operators will be faced with new administrative and economical burdens. More data in the certificate also means less simplification and bigger potential for mistakes in the certificate that can lead to delays at the border or maybe even rejections which given the absence of impact on food safety would be an unwanted result. A possible solution would be to put boxes with information that does not contribute to animal or food safety as an optional requirement instead of obligatory. Furthermore, on Article 19 point 3 (news notifications) UECBV believe there should be clear criteria for verifying news articles, to ensure they reflect the facts. UECBV would urge part of the verification criteria to include contacting the country concerned by the news article to discuss the contents and to establish the facts. Thank you for your attention and for taking UECBV comments into account. UECBV
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Response to Evaluation of the EU Animal Welfare Strategy (2012-2015)

14 Jun 2019

The European Livestock and Meat Trades Union (UECBV) would like to thank the European Commission for the opportunity to provide comments to the roadmap for the evaluation of the 2012-2015 EU Animal welfare strategy. UECBV and its members support the high standards of Animal Welfare put in place by the EU legislation. They explain and promote them towards operators in order to facilitate their implementation, as it was done for example with the guides to good practice on animal welfare during transport. UECBV acted always as a partner of both the European Commission and the EU Member-States and, as such, it is fully available and expects to be heavily involved in all the evaluation process. UECBV welcomes the consultation process stated in the “Consultation of citizens and stakeholders” part, and stress the importance of stakeholders participation in all the consultation initiatives. It strongly advises the Commission to confirm a stakeholder conference/workshop/seminar, as it would be an important tool to get the feedback from the stakeholders, as well as to have a constructive exchange of views. Finally, UECBV recommends to the Commission services to set up a detailed calendar of the evaluation process so that it will be easy for business associations and other stakeholders to keep themselves permanently involved in the process. Thank you for your attention. European Livestock and Meat Trades Union (UECBV)
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Response to Rules for establishments keeping terrestrial animals and hatcheries and their traceability

22 May 2019

UECBV (European Livestock and Meat Trades Union) would like to thank the European Commission services for its work regarding this delegated act on rules for establishments keeping terrestrial animals and hatcheries, and the traceability of certain kept terrestrial animals and hatching eggs (SANTE/7016/2018). It is important to highlight the addition of the derogation provided in Article 46 of the draft Act, permitting the use of a single EID tag for lambs intended for slaughter within 12 months of age, but not moving directly from their holding of birth to slaughter, as it is crucial for the functioning of the livestock chain and, more especially, the activity of several European livestock markets. On the other hand, there are still some concerns regarding the information and record keeping obligations for operators, as in some cases they do not provide relevant information for disease control purposes, thus creating unnecessary administrative burden for operators. Namely, in Article 36, where operators have to record the name and address of the purchaser of the animal: the information is unnecessary with regard to traceability and disease control measures. Only place of residence of the animals should be required. In Article 20, the wording is “The competent authority shall include in its register of operators conducting assembly operations for kept ungulates and poultry registered with it, independently of an establishment, including those who buy and sell those animal…”. Does this mean that the broker of the deal will also have to register? If so, what is the basis with regard to disease control measures? The important thing is to know origin, transportation and destination of the animals. UECBV asks the Commission services to not include unnecessary or redundant information and records that could be cumbersome, not only for operators, but also for competent authorities. Lastly, in Annex I, Part 1, the biosecurity requirements laid down in Annex 1 Part 1 are particularly detailed and could prove cumbersome for some types of establishments. It would be best to give Competent authorities more flexibility in order for them to be able to take into account the context of each situation and activity. UECBV hopes for these concerns to be taken into consideration. Thank you for your attention.
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Response to Establishment of a methodology of measurement of food waste

1 Apr 2019

In general, in the EU all edible products in slaughterhouses and cutting plants are merchandised. Residues are classifies under CAT 1 – 2 – 3, in the majority of the cases they re-enter in the circular economy as co-products (i.e. biodiesel, energy, leather, pet-food). From the meat industry perspective, we do not see the need for a burdensome new measurement or obligatory reports. The main issue today is to reduce food waste at retail and customer levels, representing the places where the majority of food waste is produced.
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Response to Rules on border control posts and measures to be taken in cases of non-compliant consignments of animals and goods

26 Mar 2019

UECBV thanks the Commission services for the work achieved. Nevertheless, UECBV would like to propose more flexibility regarding the the provisions for the specific minimum requirements for border control posts that are set out in chapter II, article 5, paragraph 4 and article 6, paragraph 3. Without more flexibility, the impact for EU operators could be very negative. For more on the proposal please see position paper attached. Thank you for your attention.
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Response to Regulation on the measures to be taken in case of non-compliances related to VMPs and their residues.

13 Mar 2019

UECBV thanks the Commission services for the consultation. The key message UECBV would like to address is to apply a risk based approach whenever possible. This principle is the corner stones of the whole EU food legislation and it is the best way to have a balance approach on a case by case basis depending on the substance used, the amount, the impact on human and animal health and the intended use. UECBV would like to draw the attention in particular on articles 3 and 5.1. Food and feed should not be condemned in cases where tests or calculations can demonstrate compliance within the MRLs and thereby fulfil the efficient use of natural resources according to UN World Goal 12. Please see the position paper attached.
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Meeting with Anne Bucher (Director-General Health and Food Safety)

30 Jan 2019 · introductory meeting

Response to Practical arrangements for official controls of food of animal origin

25 Oct 2018

UECBV thanks the Commission services for the work achieved. Nevertheless UECBV would like to propose three points for improvement in the document attached. Thank you for your attention.
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Response to Transparency and sustainability of the EU risk assessment model in the food chain

25 Jun 2018

Founded in 1952, the European Livestock and Meat Trades Union (UECBV) is the voice of national federations representing livestock markets, livestock traders (cattle, horses, sheep, pigs), meat traders (beef, horse meat, sheep meat, pig meat), and the meat industry (slaughterhouses, cutting plants and meat preparation plants). Are brought together within the UECBV: an international association i.e. the European Association of Livestock Markets (AEMB); a Young European Meat Committee (YEMCo); the European Natural Sausage Casings Association (ENSCA) the Organisation of European Shipsuppliers (OCEAN) fifty-four national or regional federations in twenty-four of the twenty-eight Member States of the European Union, as well as Japan, Norway, Russia, Serbia, Switzerland, Turkey and Ukraine. In total, some 20,000 firms of all sizes and 230,000 jobs are represented within the UECBV through its national member federations. UECBV welcomes the EU Commission proposal and its objectives for further transparency and better communication to increase trust and confidence in the EU’s procedure for risk assessment in the food chain. UECBV fully supports EFSA in its role as the European authority on food safety. Food safety is of crucial importance to maintain consumer trust and confidence, and business reputation. For this reason, EFSA is highly significant to our sector, as the EU’s authoritative voice on food safety and as a strong advocate for science and science-based legislation. Regarding transparency, UECBV would like to highlight that it fully supports the principle. Nevertheless, it has to be put in place in a way so that no confidential information is disclosed. It is important to think when drafting the requirements: can this jeopardise research and innovation? This should be the absolute limit to transparency. The research and innovation process within the EU has to be protected. In case EFSA does not agree with the FBO on the confidential status of some information, a procedure should be put in place so that a satisfactory wording is found. In any case, a reasonable time should be given to FBOs to react. 2 weeks look short, in particular when it comes to SMEs. An impact assessment on this aspect would have proved necessary. UECBV highly welcomes the requirements dealing with risk communication. It is especially important for the communication to take place in a timely manner and to fully take into account Consumer’s risk perceptions. The risk communication principles should focus on easy-to-understand, digestible messages and background information that provides the necessary context for end-users allowing them to put the findings and conclusions in the right perspective. To reach this goal, it is important that coordination between the risk assessor, risk manager, Member States and stakeholders is strengthened and that key communication principles are agreed upon by all parties. UECBV welcomes the increased Member States involvement in EFSA’s governance structure. Nevertheless, when it comes to scientific panels, the only basis for selection should be the best scientific expertise. It may happen that there is no expert in each Member State; in any case, the EFSA independence from political pressure has to be guaranteed.
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Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development)

26 Mar 2018 · Exchange of view

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

1 Feb 2018

For UECBV, also a member of CELCAA, it is crucial that the EU single market is protected against any national protectionism attempt. Therefore, we welcome this draft Implementing Act in view to harmonize the practices around voluntary origin labelling. We understood that one of the aims of the draft will be to replace national schemes by this EU system. UECBV supports strongly this aim. It considers that the draft should expressly preclude the possibility of such co-existence between current (and even future) Member State mandatory COOL measures, and the voluntary EU COOL regime the EC is proposing. At least an assessment on its effect on discouraging (or not) national schemes, should be foreseen. In addition, UECBV would like to make the following more specific comments: • Identification mark: Recital 9 says that identification marks should not be considered as an indication of the country of origin. There is nothing about that in the Articles. • Customary and generic names containing geographical indications: Recital 8 says that those should not be covered by this Regulation – also not mentioned in the Articles. • Article 2: the Article leaves out the possibility that some parts of the primary ingredient may come from the named area and some may not. That case should also be included in the possible declarations. • Article 4 on transition period stipulates that the new provisions should apply as from 1st April 2019. Traders of EU agri-food products unanimously call for a longer transition period. Food Business Operators (FBO) need a longer period of time to be able to introduce and roll in the labelling changes throughout their operations, at an affordable cost. Therefore, UECBV calls for a transition period of two years. • On Article 3 on the presentation of information, UECBV believes that the provisions for the font size for the indication of the origin or provenance of the primary ingredient should be the same as for all other mandatory particulars and foreseen in Article 13 of Regulation 1169/2011.
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Meeting with Phil Hogan (Commissioner)

22 Jan 2018 · Agriculture matters

Meeting with Vytenis Andriukaitis (Commissioner) and

23 Nov 2017 · African swine fever

Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström)

20 Sept 2017 · FTA negotiations with Mercosur

Meeting with Peter Power (Cabinet of Commissioner Phil Hogan)

18 Sept 2017 · EU offer on beef

Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan) and European farmers

11 Jul 2017 · Future of the CAP

Response to Revision of temperature conditions for transport of meat

30 May 2017

UECBV fully supports the Commission proposal as: • It takes into account the evolution of innovation (cold chain control), in that sense, it encourages it to continue progress; • It is based on sound science and in compliance with EFSA opinions; • It will allow operators to better answer consumers' request for freshness; • It is in compliance with environment and social concerns as it will allow saving energy and better organising the timetable of workers; • It will give an incentive to FBOs to have a performant chilling system as only those who will be able to fill in the conditions will be able to use it. The sanitary aspects are well framed; • It appears to be practical and controllable. The European Livestock and Meat Trades Union (UECBV) is the EU voice of national federations representing livestock markets, livestock traders (cattle, horses, sheep, pigs), meat traders (beef, horse meat, sheep meat, pig meat), and the meat industry (slaughterhouses, cutting plants, meat preparation plants).
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Meeting with Jean-Luc Demarty (Director-General Trade)

24 Jan 2017 · USTR MoU on tariff rate quota on high quality beef

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

18 Jan 2017 · Business discussion

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

18 Jan 2017 · Issues related to the beef industry

Response to Production, use and export of certain processed animal proteins and products containing such proteins

8 Dec 2016

Under European Union law, a prohibition is still imposed to export to third countries processed animal proteins derived from ruminants originating from EU Member States, even if those are recognised as posing a negligible BSE risk.However, despite this prohibition to export, it is authorised, instead, the import of meals containing animal proteins and Meat and Bone Meals (MBMs) from ruminants originating from third countries with a BSE negligible risk status. The EU also allows the import from third countries of live animals (such as pigs, poultry, fish and shellfish) fed with MBM derived from ruminants (and, therefore, with meal that could have been produced also with category 2 materials under European Union law), as well as fresh meats from those animals and animal by-products, whereas it prohibits the export of PAPs from ruminants originating from EU Members States representing a negligible risk and produced only using materials of category 3. The damages suffered by operators in the European Union due to the aforementioned export ban are huge. While in third countries there is a demand for PAPs from ruminants originating from EU Member States, the export ban exercises significant pressure on EU prices as a consequence great volumes of PAPs are sold there as raw material for pet food, effectively at the price of a fertiliser. - the wording in Section E point 1 can be understood as follows: only pure ruminant PAP or pure ruminant PAP mixed with pure non-ruminant PAP is allowed for export. - Section E point 2 should be reworded as: “The export of processed animal protein or of processed animal protein mixed exclusively with processed animal protein derived from non-ruminants, shall …” as the term “processed animal protein” is as such then very general and must be understood very general. Another option could be “The export of processed animal protein containing ruminant protein, or of processed animal protein containing ruminant protein mixed exclusively with processed animal protein derived from non-ruminants, shall ….” - Other wordings like “PAP of all species” or “mixed species PAP“ or” PAP derived among others from ruminant” are neither elegant nor precise or object to another misunderstanding. The naming of “ruminant” in this regard would be a strong signal especially with regard to the fact that export was forbidden for a long time, but the risk for a misunderstanding of the current wording seems to high.
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Response to Measure on the removal of specified risk materials in sheep and goats

8 Dec 2016

UECBV is fully supporting the review of the SRM list for ovine as proposed by the draft. The motivations are well explained in the “whereas”. UECBV underlines more especially: o the alignment to the international standards, o the risk assessment that highlights that there is no epidemiological evidence to suggest that scrapie is zoonotic, o the level playing field with imported products. UECBV wonders whether there is a scientific ground to limit the review to the Member States having a negligible BSE risk status and to exclude those having a controlled BSE risk. In case of a lack of such science-based reason, UECBV suggests to extend the review to the latter. If so, an harmonized reviewed SRM list for ovine across the EU will simply the control for the enforcement and more especially in the case of the movements of sheep.
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Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

22 Nov 2016 · Agri matters

Meeting with Vytenis Andriukaitis (Commissioner) and

20 Oct 2016 · Country of origin labelling, Russian ban on exports from EU, African swine fever, Horse meat in the food chain

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

13 Oct 2016 · AGRI matters

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

12 Oct 2016 · Agri matters

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

15 Sept 2016 · Business discussion

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis)

27 May 2016 · Russian pork ban

Meeting with Vytenis Andriukaitis (Commissioner) and

18 May 2016 · Russian pork ban

Meeting with Xavier Prats Monné (Director-General Health and Food Safety)

22 Jan 2016 · Courtesy visit

Meeting with Arunas Ribokas (Cabinet of Commissioner Vytenis Andriukaitis)

19 Jan 2016 · Russian Restrictions of pig mean exports

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

19 Jan 2016 · Business discussion

Meeting with Vytenis Andriukaitis (Commissioner) and

9 Dec 2015 · Animal health, Animal welfare, Food authenticity and integrity, Official controls, Market access and SPS barrier

Meeting with Arunas Ribokas (Cabinet of Commissioner Vytenis Andriukaitis)

18 Nov 2015 · Export of pork meat to Russia

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

18 Nov 2015 · Business discussion

Meeting with Phil Hogan (Commissioner)

12 May 2015 · Agri Issues

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

24 Apr 2015 · Follow-up of the meeting of 6 February 2015

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström)

22 Apr 2015 · Meat exports to Russia and elsewhere

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

26 Feb 2015 · GM import authorizations

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

6 Feb 2015 · Take stock of the issue with Russia following the agreement reached in Berlin

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

19 Dec 2014 · Export of agricultural products