OpenLobby.EU
Explore

Växtbaserat Sverige

VBS

Växtbaserat Sverige vill främja omställningen till ökad produktion och konsumtion av växtbaserade livsmedel.

Lobbying Activity

Response to Review of the EU school fruit, vegetables and milk scheme - EU aid

27 Jul 2021

Plant-food Sweden appreciates the opportunity to provide the Commission with feedback on the EU school fruit, vegetables and milk scheme which has the aim of contributing to a sustainable food consumption, in line with the Farm to Fork Strategy, Europe’s Beating Cancer Plan and the Action Plan for the Development of Organic Production. We would like to submit following comments: Importance of policy coherence We welcome the fact that all EU policies and strategies presented since December 2019 have converged towards creating a regulatory framework for sustainable food systems, where the Farm to Fork Strategy recognises the environmental and health benefits of more plant-based diets and where the European Parliament has called for specific actions to promote plant-based food consumption . The Farm to Fork Strategy states that “the transition towards a sustainable and healthy food system will not take place without a change in people's dietary habits”. In this sense, Plant-food Sweden’s view is that a revision of the EU school fruit, vegetables and milk scheme (hereafter the school milk scheme), to include a focus on the environment and health, would create a valuable tool in the promotion of sustainable and healthy eating habits of children and young people since schools play an important role in children’s lives, including with regard to nutrition. Such a revision would fit well both with the EU’s overarching policy goal, as well as with the aim of the EU school scheme, which is to ‘reconnect children with agriculture’ and educate them about healthy and sustainable eating habits. Schools are powerful agents in spreading common knowledge, both among the pupils and the staff. School canteens provide one of the three daily meals. A 2019 report of the Imperial College London acknowledges the role of public-sector catering in enabling the shift to sustainable diets. Their contribution is twofold: First, they provide a testing ground, where they can try new food products – the first step towards adopting different habits. Second, they are instrumental in informing and raising awareness among children about nutrition, what composes healthy diets, and food composition. As national nutritional recommendations are up-dated, consumption of plant-based drinks are more and more often included in these recommendations. It is therefore important that the school scheme also takes this into account given the need to shift to a more plant-based diet.
Read full response

Response to Agriculture - List of products and substances authorised in organic production

23 Apr 2021

In addition to the general remarks submitted by Plant-food Sweden, we would like to add the following specific remarks: From a business and product development perspective, the restrictions for organic plant-based food mean limited number of authorized ingredients, ingredients with low quality in terms of functional properties, and insufficient and/or uncertain supply of ingredients due to the limited supply and growing demand. It is currently not possible for producers of plant-based food and drinks to produce an organic plant-based product that has the same nutrition value, taste and functional properties as the conventional product. In a wider perspective, it puts producers of plant-based food in a vulnerable situation and risks leading to reduced focus on organic. We consider the following substances and ingredients relevant to allow in organic plant-based products. Vitamins and minerals (fortification): From a public health and public perception point of view we would suggest to allow fortification of organic plant-based alternatives to traditional food so that we can offer nutritionally relevant organic plant-based food and drinks: • Calcium • Vitamin D • Riboflavin • B12 • Iodine We would also suggest that the alge Lithothamnium calcareum continues to be allowed in processed foods as an acidity regulator, in non-organic and/or an organic form as an acidity regulator is often needed to improve stability of the product. The supply of acidity regulators is very limited for organic plant-based products. We also suggest that other acidity regulators become authorized; citrates, phosphates and carbonates.
Read full response

Response to Revision of EU marketing standards for agricultural products

16 Feb 2021

Plant-food Sweden endorses the feedback submitted by European Alliance for Plant-based foods in this matter. Plant-food Sweden would like to underline that it is key that marketing standards reflect changing consumption attitudes, increasing interest in sustainable diets, and are aligned with the objectives of the Farm to Fork Strategy to promote more sustainable food systems. Such a harmonisation is necessary as marketing standards are used as references for various regulatory purposes, e.g. for setting rules for green claims calculations or selecting products eligible for school schemes. In this respect, they should not rely on too narrowly defined product categories, but allow for fair comparison between products intended for similar use or function.
Read full response

Response to Setting of nutrient profiles

3 Feb 2021

Feedback Plant-food Sweden on Commission’s inception impact assessment on proposal for a revision of Regulation (EU) No 1169/2011 on the provision of food information to consumers This feedback is submitted on behalf of the Swedish industry organization Plant-food Sweden (Växtbaserat Sverige), which is an organization representing companies that produces plant-based food and drinks. The members of Plant-food Sweden are Alpro, Fazer, Findus, Food for Progress, Nestlé/Hälsans Kök (Garden Gourmet), Noquo foods, Oatly, Orkla Foods Sweden, Simple Feast and VegMe/Nordic Lunch. General remarks Plant-food Sweden welcomes the opportunity to contribute to the public consultation on the Inception Impact Assessment (IIA) on the proposal for a revision of Regulation 1169/2011 (EU) on the provision of food information to consumers (FIC). The FIC Regulation has been a key factor in establishing a harmonized framework for food labelling in the EU, and it has helped consumers make better-informed choices. Given the European Commission’s ambition to further strengthen the FIC Regulation and align it with the objective of the EU Farm to Fork Strategy regarding the transition to healthy and sustainable food systems, Plant-food Sweden supports the overall aim of the revision of the FIC Regulation. In order to improve a harmonized approach, and to avoid a variety of national legislations, there is a need for a discussion on food labeling at EU level. Transparent and adequate consumer information is important for the functioning of the Single Market. Plant-food Sweden would like to stress the importance that any extension of requirements and labeling schemes is evidence-based. Furthermore, it is key that any extended or existing mandatory labeling requirement serves its purpose and contributes to better-informed choices and the achievement of the targets and objectives set out in the Farm to Fork Strategy. Specific remarks Front-of-pack nutrition labeling In the Commission’s further process of the impact assessment, Plant-food Sweden would like to stress the importance that FOP nutrition labeling is easy-to-understand and provides non-misleading information about the nutritional characteristics of foods. A harmonized EU FOP scheme should apply to all products. It should avoid discriminatory practices which may entail targeting specific food categories, and it should avoid assessing products from the same functional category differently (e.g. meat/dairy products and plant-based alternatives). It should not hamper the development of new plant-based food and drinks by an unintentional distortion of the competition between plant-based products and traditional products. All new, harmonized labeling rules should be based on the following principles and be: • derived from a common methodology, • evidence-based, • transparent, • comparable across all foods, and, • a concrete tool for guiding the consumer to make better-informed choices. Nutrient profiles When considering nutrient profiles, it is important to take into account that food traditions, product supply, health challenges and dietary advice vary between Member States. The purpose of establishing nutrient profiles in Regulation 1924/2006 differ from the purpose of front-of-pack nutrition labeling, making it uncertain whether it is appropriate to use the same profiles in both these cases. Date marking Plant-food Sweden welcomes the European Commission’s commitment to reduce food waste but would like to underline that date marking is only one of many tools available to reduce food waste. It will not in itself solve the problem with food waste. More measures are required to reach the objective of reducing food waste with 50 % by 2030, and other options should be considered such as broad information campaigns.
Read full response

Response to Action plan for the development of EU organic production

23 Oct 2020

The regulations for organic food hinder the development of plant-based foods There is an accelerating increase in demand for plant-based foods. New, often complex, products are constantly entering the market. The need to enable EU organic certification of these foods is key. Today’s consumers often demand products that are both organic and plant-based. Unfortunately, it is at current however often difficult to use the EU organic label on compound plant-based products due to regulatory obstacles. A concrete example of regulatory obstacles is that organic plant-based drinks, e.g. oat drink or soya drink, are not allowed to be enriched with vitamins and minerals according to the organic regulatory framework, even if organic cow´s milk can be enriched (through the feed). From a nutritional point of view, it is important to facilitate enrichment. Consumers who choose to plant-based food and drinks should not need to choose between an organic or an enriched product. It is therefore necessary to develop EU regulations for organic foods and remove obstacles to enable the EU labelling of plant-based foods. Regarding the example above on plant-based drinks, there is a great need for creating an opening for increased use of enrichment agents in plant-based compound organic foods. Another obstacle is that there is a lack of access to suitable organic ingredients in the manufacturing process. The list of approved additives needs to be expanded so more plant-based products can gain an organic label. There are texture additives, e.g. methylcellulose, which are common in plant-based protein alternatives, but difficult to replace. Overall, without these changes in EU regulations for organic foods, it will be difficult to meet consumer demand for plant-based organic foods. A shift to a more plant-based diet supports the EU’s climate targets The AGRI Committee has voted to boost the EU climate ambitions and adopted a position calling on the EU to increase its emissions reduction target for 2030 from at least 40% to 55%. This increased climate ambition will require engagement and action on the ground by all economic sectors, citizens, authorities and civil society. In this context, the production and consumption of food is key. The Farm to Fork Strategy stresses that agriculture is responsible for 10.3% of the EU’s GHG emissions and nearly 70% of those come from the animal sector. In addition, 68% of the total agricultural land is used for animal production. It is thus clear that the transition to a sustainable food system and reduced emissions will not happen without a shift to more plant-based foods in people’s diets. EU strategies and actions need to put more focus on sustainable food consumption than on organic farming. It is important to at least ensure that the strategy for organic farming does not stand in the way of the development of plant-based food. Organic farming is important for biodiversity. However, its impact on reducing emissions is limited and will not help the EU to reach its ambiguous 2030 climate targets and the overall objective to become climate-neutral by 2050.
Read full response

Response to Environmental claims based on environmental footprint methods

31 Aug 2020

This feedback is submitted on behalf of the Swedish industry organisation Plant-food Sweden (Växtbaserat Sverige), which is an industry organization representing food producing companies of plant-based food and drinks. The members of Plant-based Sweden are Fazer, Findus, Food for Progress, Nestlé/Hälsans Kök (Garden Gourmet) Oatly, Orkla Foods Sweden, VegMe – Nordic Lunch and Simple Feast. Plant-food Sweden welcomes and actively supports the overall aim of the Commission’s inception impact assessment on substantiating green claims. As producers of plant-based food and drinks we can confirm that the increasing awareness among consumers that their choice of food and drinks have an impact on the planet has led to an increased demand for product specific sustainability information. A changing consumer behaviour with regards to consumption can help facilitate a more circular and sustainable economy. In order to empower consumers with effective tools to speed-up this shift, green claims can be a helpful guidance. For the next steps in the process of elaborating a framework for green claims, Plant-food Sweden would like to underline the importance that such a framework is: • derived from a common methodology, • evidence-based, • transparent and, • comparable across all foods The information in green claims should be easily accessible for consumers and facilitate the comparison between all food products – whereas PEF only allows for comparison between products in the same category which use the same type of functional unit. We do not think it is a useful enough comparison to compare only within a product category when it comes to food, especially with significant amounts of scientific evidence showing that we need to reduce our animal-based food consumption and increase our plant-based food consumption – both for environmental and health reasons. Plant-food Sweden has several member companies that are successfully working with calculations and declarations of greenhouse gas emissions, we would therefore be happy to contribute to the continuous dialogue and policy development in this area.
Read full response

Response to Climate Law

1 May 2020

Plant-food Sweden warmly welcomes the Commission’s initiative to establish a European Climate Law, which sets out the binding objective of EU climate neutrality by 2050 in pursuit of the long-term temperature goal set out in the Paris Agreement. The enactment of a European climate law is an essential step forward to ensure alignment within the EU according to the Paris agreement and the Green Deal. We are hopeful that the Climate Law will enshrine the EU’s leadership and, consequently, will enhance trust in the EU’s commitment to reach its targets. The Climate Law will evaluate all EU policies, looking for inconsistencies or lack of progress in line with the 2050 climate-neutrality objective. In this light, Plant-food Sweden would like to stress that the food industry is responsible for 25% of global emissions, which should be taken into account when setting targets for reducing emissions. As an industry organisation representing food companies, we want to emphasise the correlation between the global climate crisis and the European Union’s food and agricultural policies. The member companies of Plant-food Sweden are experiencing a significant growth in the market of innovative and sustainable plant-based foodstuffs, driven by a consumer demand as a response to the global climate crisis and the increasing number of diet-related non-communicable diseases. While consumers across the European Union already try to impact climate change by making conscious decisions relating to their choice of food, European food policies do not yet fully reflect this awareness. The growing plant-based food sector is an example of a sector offering solutions to climate change (and with further growth opportunities). Looking at food sector-specific European policies, including the Common Agricultural Policy (CAP), the need for a transition to a sustainable food system in Europe is however yet to be adequately reflected in EU policy. It is against this background that Plant-food Sweden truly hopes that the Climate Law will stimulate innovation and the deployment of clean technologies in the food sector, relating to each step of the food chain; from the use of fertilisers for organic farming and cultivation (with nutrient recycling); to the processing, packaging and distribution of foodstuffs. Furthermore, the carbon footprint from plant-based foodstuffs produced within the EU is, in general, significantly lower than that of corresponding animal-based products. To be able to reach the long-term emission targets, it will prove necessary to shift consumption of food towards more plant-based diets. Plant-food Sweden would like to stress the need for the EU climate law to be bold and propose ambitious measures and targets. We would like to urge the Commission to set sector-specific targets for emission reductions, including targets for the food sector, as all sectors must play their part and all relevant policies should contribute to reaching the climate goals. The experience from Sweden is that in the absence of sector specific targets on a broader range, it is difficult to take the measures necessary for reducing emissions. The agriculture and food sectors can become essential sectors to mitigate and tackle climate change, and urgent decisions and actions are needed to achieve this end. As shown by IPCC and other research reports, we need policies facilitating the shift towards a more plant-based food system addressing farming, industry and consumption, and at the same time promote a prosperous EU. Today there are a number of examples, and even fresh political initiatives, contradicting these ambitions. As a conclusive remark, Plant-food Sweden would like to urge the Commission to ensure policy coherence between the current proposal and the up-coming proposals of the Farm to Fork strategy and the Green Deal, as well as the CAP. We are looking forward to a continued dialogue with the European Commission.
Read full response

Response to Evaluation and checks of the EU school fruit, vegetables and milk scheme

23 Apr 2020

This feedback is submitted on behalf of the Swedish industry organisation Plant-food Sweden (Växtbaserat Sverige), which is an industry organization representing food producing companies of plant-based food and drinks. Plant-food Sweden appreciates the opportunity to provide the Commission with feedback on the EU school fruit, vegetables and milk scheme and would like to submit following comments: When evaluating the school milk scheme, Plant-food Sweden would like to stress that one indicator that should be taken into account and consequently included in the evaluation of the school milk scheme is the change in direct and indirect consumption of drinking milk by children (quantity and/or frequency). As such, the school scheme hopes to increase the daily intake of healthy foodstuffs with children. Following this line of reasoning, Plant-food Sweden advocates the extension of the school scheme (as limited under Article 23 of Regulation 1308/2013 establishing a common organisation of the markets in agricultural products (COM(2018)0394 – 2018/0218(COD)) to also cover nutritious plant-based alternatives to ‘milk’ drinks and processed milk products. The exclusion of plant-based alternatives to ‘milk’ drinks, the current school scheme distorts the market. According to the preamble of Regulation 1308/2013 (Article 23), the purpose of the scheme is to give children the opportunity to drink and eat more of these goods and to permanently increase the proportion of these products in the children's diet at the age when their eating habits are established. Nutritious fortified plant-based alternatives to milk and milk products have existed for many years and their inclusion in the school scheme can be justified by the following reasons: • Ensuring equality for children with intolerances or allergies: The school scheme fails to recognize that lactose intolerance, and to some extent cow’s milk protein allergy, is a common condition with many children. Furthermore, many children/families abstain from animal-based dairy on cultural and/or ethical grounds, or as a means to reduce their climate footprint. In many schools, children are required to produce documentation of a disability or a special medical or dietary need in order to receive an alternative to cow’s milk. In addition, there are schools where plant-based alternative drinks, if available, cost the pupil extra. The school milk scheme hence risks leading to unfair treatment of children who either cannot, or do not want to drink cow’s milk by limiting the choices available. • Ensuring children have access to a wide taste palate of healthy foodstuffs, to encourage healthy eating habits: It is essential for young people to encounter a range of tastes, including of plant-based foodstuffs, to ensure that they develop a full range of taste preferences as their palate develops. Extending the school scheme to also include plant-based drinks would ensure this and will remove this artificial and unfair regulatory barrier. • Plant-based foods and drinks from a public health and climate perspective: Research, IPCC among others, shows that a change in the food system and a shift to consumption of plant-based food and drinks is needed to tackle challenges linked to climate change and public health, as well as managing to feed the growing population. This also recognized and addressed in the EU Initiatives Green deal and Farm to Fork-strategy. Plant-based alternatives to dairy have a considerably lower carbon footprint compared to their animal-based counterparts. As a conclusive remark, Plant-food Sweden would like to urge the Commission to ensure policy coherence between the current proposal and, the up-coming proposals of the Farm to Fork strategy and the Green Deal. We are looking forward to a continued dialogue with the European Commission.
Read full response

Response to Farm to Fork Strategy

16 Mar 2020

Plant-food Sweden welcomes the European Commission’s new initiatives, the Green Deal and the Farm to Fork strategy, as time critical and crucial to transform the European food systems and set a new course where the wellbeing of people and the planet is at the core of the policies shaping the food system. As an industry organisation representing food producing companies, who promote a shift to an increased production and consumption of plant-based food and drinks to tackle climate change and public health challenges, we particularly appreciate the overall objective to ”accelerate the transition towards a sustainable food system that should have a neutral or positive environmental impact, is capable to adapt to climate change and at the same time contributes to climate change mitigation, ensures food security and creates a food environment which makes healthy diets the easy choice for EU citizen.” Plant-food Sweden particularly welcomes that the European Commission recognizes and highlights the fact that the food sector counts for about 25-30% of greenhouse gas emissions, and would therefore like to underline the importance that the revision of the CAP suggests and adopts ambitious goals accelerating the necessary transition to a sustainable food system. The initiative should be aligned with other policies and include concrete actions and mechanisms to facilitate a shift to sustainable production and eating, where we need to feed a growing population and at the same time find new ways of producing food. Plant-food Sweden would like to stress the need for Farm to Fork strategy to be bold and have the courage to propose ambitious measures that will change the EU agricultural system towards a more sustainable food system in the long term, and also make it competitive by meeting the rapidly growing demand for processed plant-based foods and drinks. Although the Farm to Fork strategy sets the target of ensuring sustainable food production, the measure and objective mainly relate to feed additives. Plant-food Sweden would like to urge the Commission to see the potential in the rapidly growing plant-based food sector and propose measures that would remove the barriers that currently distort the playing field for processed plant-based products to fully expand and operate under the same conditions as the traditional food industry. We would also like to highlight the role of innovation and technology to speed up the development of innovative, safe and healthy solutions to tackle the challenges we, and future generations are facing. The Farm to Fork strategy need to put forward tools and measures that can guide consumers towards a more sustainable and healthy diet. Plant-food Sweden urges the Commission to acknowledge that processed plant-based foods and drinks can provide solutions for a multitude of challenges within our food system, and encourages the Commission to see the potential in plant-based foods and drinks and ensure that plant-based diets will receive required attention in the Farm to Fork Strategy. Please find our full feedback and proposed actions in the document attached.
Read full response