Document 20
Ref. Ares(2020)1567901 - 13/03/2020
EUROPEAN COMMISSION
Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs
ISC/2020/01398 Farm to Fork Strategy
DG GROW COMMENTS
I. Overall comments
DG GROW welcomes the text of the communication and attached action plan. We
welcome the inclusion of initiatives to support SMEs in the food chain and actions in
relation to the sustainability performance of operators downstream in the chain. DG
GROW supports the need for decisive action in the international domain and ensuring a
level playing field for EU food producers.
Nonetheless, DG GROW considers necessary to rethink and reformulate certain sections,
particularly in relation to fertiliser use, country of origin labelling and front-of-pack
nutritional labelling. More detailed input on these and further comments on other issues
are presented below per chapter. It is of high importance that any action related to the
strategy does not pose a threat to the functioning of the Single Market, as fragmentation
may also have undesired effects on sustainability.
II. Specific Comments per chapter
1. Need for action
On page 2, DG GROW suggests to
replace
‘progress is still needed to reduce dependency on pesticides and fertilisers’
with
‘progress is still needed to reduce dependency on pesticides and excess of nutrients
from fertilisers in the environment’.
replace
‘They are part of the solution but require the right incentives and support
throughout the transition. Other actors across the value chain, including manufacturers
and retailers also have an important responsibility to deliver change and a fairer and
more efficient food system’.
with:
‘They are part of the solution but require the right incentives and support
throughout the transition. Other actors across the value chain, including manufacturers
and retailers also have an important responsibility and need support and incentives to
deliver change and a fairer and more efficient food system’.
replace
“Nevertheless, citizens’ demand is evolving. Consumers’ habits are driving
significant change to the food market. Citizens increasingly pay attention to
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environmental, health and ethical issues. They want green, organic food, with less
pesticides, sugar and additives. Even as societies become more urbanised, citizens want to
feel closer to their food, having it fresher, less processed and locally sourced. Consumers
expect transparency across the entire supply chain to be sure that they are buying ‘healthy
food form a healthy planet’. Food processors and retailers play a key role in ensuring that
such demand is met. In recent years, consumer trust has been eroded through intentional
violations of food supply rules. Achieving a sustainable food system requires a zero
tolerance policy as regards food fraud.”
With:
‘Nevertheless, citizens’ demand is evolving. Consumers’ habits are driving
significant change to the food market, which farmers, food processors and retailers play a
key role in meeting. Citizens increasingly pay attention to environmental, health and
ethical issues. They want green, organic food, with less pesticides, sugar and additives.
Even as societies become more urbanised, citizens want to feel closer to their food, having
it fresher, less processed and responsibly/sustainably sourced. Consumers expect
transparency across the entire supply chain to be sure that they are buying “healthy food
from a healthy planet”. In recent years, consumer trust has been eroded through
intentional violations of food supply rules. Achieving a sustainable food system requires a
zero tolerance policy as regards food fraud.”
Rationale: With regard to fertilizers, please see page 3. Furthermore, GROW proposes to
replace the term “locally sourced” with
“responsibly sourced” or
“sustainably sourced”
as local is not always synonymous with more sustainable. In addition, it would be
contradictory for the Commission to refer to local sourcing when it has recently launched
infringement proceedings against certain Member States to prevent them from imposing
requirements on retailers to stock certain percentages of nationally produced products on
their shelves, which is contrary to Article 34 (the free movement of goods).
In addition, the positioning of the sentences, “Food processors and retailers play a key role
in ensuring that such demand is met” and “In recent years, consumers trust has been
eroded through intentional violations of foods supply rules”, can be read as it only relates
to retailers and manufacturers, when all actors in the food chain bear their responsibility.
2. The way forward
2.1 Ensuring sustainable food production
On page 4, DG GROW suggests to:
replace ‘
to deliver better environmental results, increase climate resilience and reduce
input use (e.g. pesticides, fertilisers)
with
‘to deliver better environmental results, increase climate resilience and reduce the
use of pesticides and the surplus in the environment of nutrients from fertilisers’
replace ‘
The excessive use of nutrients in agriculture i.e. those that are not absorbed by
plants,’
with
’The excess of nutrients in the environment, stemming from the fact that not all
nutrients used in agriculture are effectively absorbed by plants,’
replace
‘The overuse of fertilisers’
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by
‘It’.
On page 5, DG GROW suggests to:
replace ‘
The Commission will take actions to reduce by XX% the use of fertilisers by
2030. This will be achieved by the full implementation and enforcement of the relevant
environmental and climate legislation, identifying with Member States the nutrient
reduction loads needed’.
by
‘The Commission will take actions to increase the nitrogen use efficiency of fertilisers.
This will be achieved by the full implementation and enforcement of the relevant
environmental and climate legislation, identifying with Member States the nutrient load
reductions needed’.
On page 5, in relation to the Bio economy DG GROW suggests to mention bio based
products, hence to replace: ‘
New innovative techniques, including biotechnology, may
play a role in increasing sustainability provided they are safe for consumers…’
with ‘
New innovative techniques, including biotechnology and the development of bio
based products, may play a role in increasing sustainability provided they are safe for
consumers…’.
Rationale: When nutrient use efficiency increases, the loss of nutrients to the environment
decreases and farmers’ yields and incomes increase. In other words, a nutrient use
efficiency target would support both the 0-pollution ambition and the just transition
objective. We note that one of the objectives of the Farm to Fork Strategy is to deliver
better environmental results and higher profits by supporting i.e. research, innovation,
digitalisation, technology and knowledge sharing. All these activities are necessary in the
field of nutrient use efficiency, a field in which indicators are already available and
applied to some extent, but where much more could be done in terms of research,
innovation, digital tools, and knowledge sharing. Both research and innovation are much
more advanced for nitrogen than for phosphorus. A target of nitrogen use efficiency
increase is deemed efficient and realistic by experts.
Fertilisers cannot be subject to the same objectives as pesticides. Whereas pesticides are
toxic substances intended to kill living organisms, fertilisers are simply nutrients for
plants. It is not possible to reduce crops’ “dependency” on nutrients – with insufficient
access to nutrients, the growth of crops (as of human and animal bodies) will simply be
suboptimal, and so will farmers’ income. A simple use reduction target for fertilisers
would therefore inevitably reduce agricultural productivity, and thus not reflect the just
transition objective of the Green Deal and the Farm to Fork Strategy. Furthermore, it
would not necessarily lead to better protection of the environment, as even a reduced use
will lead to surplus in the environment as long as the core issue is not addressed, i.e.
crops’ inefficient absorption of the nutrients present in the fertilisers used. We also note
that the target has not been quantified in the draft, and wonder whether any assessment
has been made supporting any quantified use reduction target, both in terms of
environmental impact and in terms of impact on farmers’ yields.
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2.2 Stimulating sustainable food processing, wholesale, retail, hospitality and
food services’ practices
On page 7, DG GROW suggests to replace
“They have the power to influence consumers’
dietary choices by promoting more or less healthy and sustainable products.”
with “
They have the power to influence consumers’ dietary choices by promoting healthy
and sustainable products and responding to citizens’ evolving demands.”
Rationale: The paragraph should better recognise the fact that food processors, food
service operators and retailers are bound to react to consumer trends.
On page 7 DG GROW suggests to:
replace
‘The food industry itself should show the way by increasing the availability and
affordability of healthy, sustainable food options. To promote such practices and engage
food industry in a transparent and participatory process, the Commission will, as a
priority, develop an EU Code of Conduct, and its accompanying monitoring framework,
for responsible business conduct and marketing practices. It will seek commitments from
companies to: reformulate their food products in line with guidelines for healthy,
sustainable diets; reduce their environmental footprint; adapt their marketing and
advertising strategies taking into account the needs of the most vulnerable; ensure that
campaigns relating to food prices do not undermine citizens' perception of the value of
food and reduce packaging (cf. new CEAP). In the longer term, this could lead to rules on
sustainable corporate governance that will require the food industry to integrate
sustainability into corporate strategies'.’
with
‘The EU food industry and distribution, should show the way by increasing the
availability and affordability of healthy, sustainable food options. To promote this,
(together with food processors, retailers, consumer organizations and other relevant
stakeholders), the Commission will develop an EU Code of Conduct, and its accompanying
monitoring framework, for responsible business conduct and marketing practices. The
Code will be developed in a transparent and participatory process and build on the
experience gathered to date through relevant initiatives. It will seek timely commitments
from companies and organisations to take concrete actions on sustainability. [These can
be commitments to reduce the environmental footprint and increase overall sustainability
of production (including social aspects); reduce over-packaging (cf. new CEAP);
reformulate food products in line with guidelines on healthy, sustainable diets; adapt
marketing and advertising strategies to take into account the needs of the most vulnerable;
ensure that campaigns on food prices do not undermine citizens' perception of the value of
food etc.]. In the longer term, this could lead to rules on sustainable corporate governance
that will require food chain operators to integrate sustainability into corporate strategies'.
Rationale: On the Code for responsible business conduct, it can be contradictory after
saying that the Commission will engage with stakeholders in a transparent and
participatory process to then prescribe exactly what the code will include. A more nuanced
approach may be better perceived, hence more effective and leave the door open for other
actions that are supported and realistic for stakeholders to implement in a timely manner.
The Commission can build on existing and completed initiatives such as the work of the
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Retailer Sustainability Forum, the High Level Food Forum, work on best environmental
management practices and international guidelines on responsible business conduct. DG
GROW would work closely with other DGs on this.
2.3 Promoting sustainable food consumption, facilitating the shift towards
healthy, sustainable diets
On page 8, regarding
mandatory front-of-pack nutrition labelling: DG GROW
supports efforts to harmonise labelling requirements in the Single Market. Yet, the
proposal in the Communication goes beyond what has been agreed in the ISSG on the
front-of-pack labelling report. The report aims at harmonising front-of-pack labelling,
whereas the Farm to Fork strategy text proposes to make it mandatory. Mandatory front-
of-pack labelling requirements can be particularly burdensome, especially for SMEs
(considering higher costs and major difficulty to reformulate products in relation to
labelling). DG GROW would also like to clarify what ‘taking into account the diversity of
diets’ exactly means: if for example this would translate into specific exemptions for
some foods or in some MS with a particular diet. If so, this could entail further
renationalisation of the regulatory framework and, therefore, a step back for the objective
of harmonisation and free movement of foods. DG GROW believes this should be further
discussed in detail among services before being announced in the strategy, and a
comprehensive assessment of the impacts of mandatory labelling should be carried out
beforehand.
The text can be amended as follows to reflect the intention:
“To this end, it will propose to
introduce harmonised front-of-pack nutritional labelling”.
DG GROW
does not support the proposal to extend mandatory (country of) origin
indication to milk as well as milk and meat used as an ingredient. Recent experience with
national initiatives in this area clearly shows that mandatory country of origin labelling for
these foodstuffs has proven negative impacts on the Single Market, it can incite
consumers to buy local/domestic products (irrespective of their quality or sustainability
indications), to the detriment of similar products originating from other Member States.
This contradicts the free movement of goods principle (Art. 34 TFEU), as well as the
narrative on showing the benefits of the single market for goods, in terms of consumer
access to a wide diversity of products, better prices, etc.
The relevance of mandatory origin indication at national level (“country of origin”) should
be assessed against the specific objectives of the Farm to fork strategy and the risk to
simply feed “gastro nationalism” and hence fragmentation. Same country of origin cannot
be considered as synonymous to having the same quality or sustainability features (e.g.,
the milk produced in Lille could have more similarities with the one produced in Belgium
than the one produced in Corsica). The argument that origin indication would support
farmers as part of short supply chains does not account for the wellbeing of farmers in
other parts of the Internal Market (who could potentially be more sustainable).
Here as well, DG GROW believes that this should be discussed in detail among services
before being announced in the strategy and a comprehensive assessment of the impacts of
mandatory labelling should be carried out beforehand.
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DG GROW would like to be involved in the discussions on sustainable labelling.
3. Enabling the transition
3.2. Advisory services, data and knowledge sharing
On p.10, DG GROW suggests to:
Replace:
‘The Commission will ensure support to SME food processors, small retail and
food service operators with tailored solutions to promote new skills and business models,
while avoiding administrative and cost burden. It will develop and SME-friendly
Sustainability Manual for Food processors and for retailers to disseminate best
environmental management practices. The Enterprise Europe Network will provide
advisory services on sustainability for SMEs, foster dissemination of best practices and
improve their access to finance.’
With:
‘The Commission will also ensure support to SME food processors, small retail and
food service operators with tailored solutions to promote new skills and business models,
while avoiding administrative and cost burden. It will encourage through guidance how
retailers and food processors can adopt best practices on sustainability. The Enterprise
Europe Network will provide advisory services on sustainability for SMEs and foster
dissemination of best practices. The Commission will further facilitate access to finance
for SMEs in line with the EU SME Strategy objectives.’
Rationale: allow space for designing the best instrument for SMEs guidance (which could
be a Sustainability Manual, but may include also other means).
3.3 Promoting the global transition
DG GROW supports stronger action in relation to third countries to ensure a level playing
field for EU food producers and promote EU exports of sustainable food products
(including as a means for strengthening the markets for sustainable food in other
countries). EU food companies need certainty of supply of reliable, sustainably produced
raw materials. We support actions on transparent supply chains. The EU promotion policy
can be further used to promote EU food exports as ‘sustainability champions’.
We would like to be further informed regarding the developments on ‘Further measures to
be added based on discussions at political level’ mentioned on p.11.
General comment: Across the board, it is important to clarify the status of the targets
currently set as xx% (whether these are put as aspirational targets or if a number will be
given before the official launch of the strategy; if so how these will be defined and on
what scientific grounds.)
In the Action plan
GROW suggest to word the action on the Code of conduct as below, to be coherent with
the wording under section 2.2, keeping in mind that transparency is included in the
concept of responsible business conduct (RBC).
‘Develop an EU code, and monitoring framework, for responsible business and marketing
conduct’ in the food supply chain’.
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