Zentralverband der Deutschen Geflügelwirtschaft e.V.
ZDG
Der Zentralverband der Deutschen Geflügelwirtschaft e.V.
ID: 423643730288-43
Lobbying Activity
30 Mar 2021
The German Poultry Association welcomes the presented draft of the Commission to amend Annex IV of Regulation (EC) No. 999/2001. The approval of processed animal protein (PAP) as feed is an important step and a strong signal towards more sustainability in farm animal husbandry, a topic that is highly relevant in the public and political discussion and a declared aim of "Farm to Fork" strategy initiated at EU level as part of the "European Green Deal".
The use of processed animal protein in feeding offers an opportunity to introduce valuable nutrients into the cycle that have remained unused:
- Bone meal is a high-quality, easily digestible source of phosphorus, an element that is finitely available on our planet and is currently extracted from plant sources through complex processes.
- Phosphorus is particularly needed in the formation of bones and joints and must be available to animals in sufficient quantities at every stage of development.
- Processed animal protein, including insect protein, provides a valuable and affordable source of protein and fat.
- Currently, the European Union is heavily dependent on soy imports from third countries to meet the protein needs of livestock. Although PAP will not replace soy from the feed market, an approval of protein from animal sources will be a first step towards more self sufficiency.
Since a health risk to consumers from the use of processed animal protein is virtually ruled out according to the available opinions of the European Food Safety Authority (EFSA), the German poultry industry is now calling for PAP to be approved as feed for mono gastric omnivors in the EU.
In the interest of sustainability, existing resources must be used to a larger extend and the independence of the European Union from third countries must be strengthened. Only in this way can we achieve the ambitious goal of a climate-neutral EU by 2050.
Read full responseResponse to Revision of EU marketing standards for agricultural products
9 Feb 2021
The German Poultry Association welcomes the chance to comment on the revision of the EU-Marketing Standards.
The European marketing standards for poultrymeat and eggs (hereinafter referred to as "marketing standards") have proven to be a successful and effective instrument for ensuring the continuity and proper functioning of the common market organisation within the European Union since their application in 1991. Industry, trade, controlling authorities and consumers benefit equally from the application of the marketing standards:
• By defining uniform standards for the respective products, a minimum quality of the products in conformity with the standards is ensured.
• By harmonising requirements for products and thus allowing products to be marketed on the same terms throughout the internal market.
• By creating transparency for the consumer, who can be sure that a product meets certain (minimum) requirements.
The German poultry industry is therefore strongly in favour of retaining the marketing standards for poultry meat and eggs, as their use has clearly proven successful. However, a revision is necessary due to outdated requirements. While the marketing standards for eggs have already undergone a fundamental revision in 2007, the marketing standards for poultry have not done so since 1991. The German poultry industry therefore sees the need for adjustments to both the marketing standards for poultry meat and eggs, which must be made in the con-text of a revision.
Marketing standards are of great importance for the poultry industry. Harmonised labelling of poultry meat and eggs in relevant areas such as calibration, definition of cuts, water content, storage/temperature, weight classes and husbandry systems must continue to be regulated EU-wide in the marketing standards. The relevant requirements listed therein are to be regarded to as final. Any deviation from this must not be allowed as it leads to misleading of the costumer. In particular, the labelling of farming methods should be mentioned here.
The German poultry industry takes a critical view of the European Commission's announcement to include marketing standards for the fulfilment of ecological and social objectives within the scope of the Farm to Fork Strategy. Because:
• the marketing standards primarily serve the free movement of goods within the European Union.
• for other areas such as animal welfare, consumer and environmental protection, there are independent requirements, such as a directive on transport and slaughter or husbandry regulations.
• EU marketing standards promote animal welfare or consumer protection aspects only indirectly.
This means that the individual legal acts must be coherent with each other in order to ensure appropriate implementation. Under no circumstances, however, should there be any confusion.
Conclusion of the German poultry industry on the revision of the marketing standards:
• The EU marketing standards have proven to be an effective instrument for harmonising the free movement of goods in the European Union and a uniform market organisation and must be maintained.
• Marketing standards for poultry meat and eggs need to be revised and modernised.
• Marketing standards must cover all points relevant to poultry meat and eggs. Where possible, streamlining should take place. The regulations contained are then to be judged as conclusive.
• Marketing standards primarily regulate the free movement of goods in the EU and must not be used to regulate other policy areas such as the environment or animal welfare.
• The compatibility of the individual legal standards with the marketing standards under Community law must be ensured and monitored by the EU Commission.
Please find attached the legal opinion on the final validity of the European marketing standards that supports our points.
Read full responseResponse to Contingency plan for ensuring food supply and food security
13 Jan 2021
The German Poultry Association welcomes the contingency plan for ensuring food supply and food security in EU in event of future crises. The European food system has proven resilient and successfully managed to provide healthy and high quality food to the European citizens. The industry has done its very best to ensure food security and safety, while the situation was challenging.
A contingency plan with clear rules is therefore necessary and important!
The poultry meat sector came under huge pressure mainly due to the almost overnight disappearance of large sections of key demand from restaurants, hotels, and catering, as well as to mobility restrictions and to new sanitary requirements.
The German Poultry sector, who provides a highly valued protein sources to the European Population was struck by the sudden closing of borders, leading to shortages in workforce in all branches, starting from the laying hens, ending in the slaughter houses. Due to the long practiced and close trade relations among member states of the European Union, a sudden closing of borders must be avoided at all costs.
The loss of an entire market segment is hard for
The communication amongst the member states needs to be precise and quick, especially when it comes to transportation of living animals. Clear communication from the authorities to the officials must be ensured. The room for interpretations should be as small as possible. We support the implementation of the so called "Green Lanes". A long delay leads to negative effects on animal welfare.
The German Poultry Association supports the creation of a common EU food crisis response mechanism – and we find that it is of huge importance that the stakeholders in the food chain will participate in the permanent forum, together with the Commission and the Member States. This will without any doubt result in the most efficient results.
We also support the inclusion of international trade in the contingency plan. A globalized world needs responses that cover global trade.
Read full responseResponse to Action plan for the development of EU organic production
21 Oct 2020
The German Poultry association represents the entire German poultry sector, including all kinds of poultry in all production stages. As an agricultural sector, our main concern is the provision of high-quality food for an appropriate affordable price, knowing about our social responsibility.
Especially in the egg sector, the organic production system is already well established, having a market share of approx. 12% in Germany. This has been a process of several years, serving the demand of the market.
When it comes to promotion measures for organic farming, we see some clear obstacles arising. Evidently, organic farming practices are not more efficient: more resources are needed for an equal or even lower outcome. Due to all the scientific research performed in conventional agriculture, a highly efficient system has been built that produces a maximum output using minimum resources. With regards to a growing world population, this must be taken into account. Organic farming can be seen as an additional option for food production but not as an alternative .
Further, there are clear legal and moral conflict of interests regarding organic production, e.g. keeping animals outdoor while minimizing emissions originating from livestock farming. These need to be solved.
To establish a 25% share of organic farming on the entire European Agricultural Area, is therefore as ambitious as it is problematic from a resource efficiency and self-sufficiency point of view.
The promotion of organic farming through tools such as tax benefits or special grants is a disproportionate intervention in the market and undermines the efforts taken by conventional farming procedures. There is already a considerably high market share for organic products and the costumer has the option to buy them. The ultimate purchase decision though, must stay with the costumer without governmental interference- a fundamental part of the social market economy.
Read full responseResponse to Fitness Check of the EU legislation on animal welfare
20 Jul 2020
The German Poultry Association welcomes the Fitness Check on the EU legislation on animal welfare. We believe it is important to update, strengthen and harmonise the EU animal welfare legislation.
We would like to encourage the EU to put an end of cage production systems for laying hens. This should include imports from third countries. The efforts of the European Egg Producers should no longer be undermined by third countries with no welfare regulations. The Commission should ensure that the EU animal welfare legislation is coherent with the EU Trade policies.
As for animal health, we support the goal of the Farm2Fork Strategy to reduce the use of antibiotics. This must however not mean that animals who suffer from diseases do not receive treatment. We are in line with the approach "as little as possible, as much as necessary".
We welcome the approach of an EU-wide welfare labelling system. However, currently there is no harmonised way to assess welfare or controll the competence of animal keepers. We would like to encourage the European Union to harmonise welfare measures in order to be able to reach a comparable welfare level in all memberstates. It is of the utmost importance that the EU animal welfare legislation is uniform across all memberstates of the EU.
We do notice that certain species, even though reared in livestock production systems, do not underlie any regulation what so ever. Turkeys, a different species with different needs, should get an appropriate European regulation. A union wide solution must be found to ensure fair competition.
It is however important to protect European livestock production. The EU provides already the highest standards for animal husbandry worldwide. In case the regulations become unreasonably high, we risk the migration of livestock farming to third countries where lower or no legislation for animal keeping applies.
Given the importance of sustainability in the Farm2Fork strategy, we hope for the integration of this topic in scientific opinions and possible amendments. The discrepancies between improved animal welfare and environmental sustainability should be taken into account.
We are looking forward to work along with the Commission and our stakeholders to achieve a sustainable, succesfull and efficient future for the poultry sector in the European Union.
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