Document 8
From:
To:
CAB KYRIAKIDES CONTACT
Cc:
(CAB-KYRIAKIDES);
(CAB-KYRIAKIDES);
;
;
Subject:
Letter from EuroCommerce on Sustainable Food
Date:
mercredi 29 janvier 2020 11:53:54
Attachments:
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letter Kyriakides Sustainable Foods JAN29.pdf
Dear Commissioner Kyriakides,
Please find attached a letter from
on Sustainable Food.
Best regards,
EuroCommerce
Director-General
–
www.eurocommerce.eu
Ms Stella Kyriakides
Commissioner for Health and Food Safety
European Commission
Rue de la Loi, 200
1000 Brussels
Brussels, 29 January 2020
Sustainable Food Strategy – Retail & wholesale contribution
Dear Commissioner,
We welcome the ambition and comprehensive strategy set out by the Commission last month in
the European Green Deal. In this letter, we wanted to share with you some initial thoughts on the
Farm-to-Fork sustainable food strategy under the Green Deal, on which we will be keen to work
with you and offer more detailed input as you take it forward.
Food retailers and wholesalers are a central actor in the food supply chain: they are in daily contact
with Europe’s 500 million consumers; they operate sophisticated and efficient systems ensuring
the reliable and safe distribution of foods, and both act to meet consumers’ ever-changing
demands and help them in leading a healthy lifestyle. Millions of companies, large and small, and
millions of people working in the sector, are engaged in these activities. On this basis, we hope you
will find our points below a useful contribution as you and your services prepare the strategy.
‘FROM FARM to FORK’ OR FROM THE CONSUMER BACK TO THE PRODUCER?
Consumers want sustainable and healthy food - and choice. We are, as retailers and wholesalers,
keen to help farmers produce food in an economically and environmentally sustainable way. But
this can only happen if farmers and the food industry match what they produce with what
consumers want. We believe, therefore, that the strategy needs to start with the consumer and
work back. Retailers have been pivotal in implementing and encouraging the necessary changes.
In responding to consumer demand, retailers are at the forefront of offering organic food, vegan
products, local products, alternatives to animal-based products, ‘free-from’ alternative options,
and providing nutritional and sustainability information and other means to encourage consumers
to choose them.
Recent supplier-retailer tensions in France illustrate this point: a well-known supplier of
carbonated sugar drinks refused to supply a retailer who wanted to restrict the range of the
company’s drinks and reserve shelf-space for healthier alternatives.
We therefore ask that
consumers and retailers be given a clear and prominent role in developing the strategy. And that
the title of the initiative ‘from farm to fork’ be adapted to reflect the more consumer-centric and
planet-centric approach we believe will be necessary for it to succeed.
PROMOTING FRUIT AND VEGETABLES, SELLING FRESH FOOD
Shops are the place where consumers make their choices about a healthy diet. Fruit and vegetables
feature at the front of the store and many retailers have introduced concrete initiatives to
encourage consumers to consume more fruit and vegetables. We have subscribed to EU initiatives
to promote this.
We ask the Commission to engage with retailers as key partners in their strategy
to promote the consumption of fruit and vegetables.
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Avenue des Nerviens 85 - B-1040 Brussels
www.eurocommerce.eu
REFORMULATING PACKAGED FOOD FOR LOWER SALT, SUGAR, AND FAT
Retailers and wholesalers have led the way in decreasing salt, sugar or fat content in their retailer
brand (also known as private label) products, and encouraging manufacturers to do the same.
We
ask the Commission encourages and takes account of these voluntary private initiatives, coupled
with continued public education campaigns on healthy diets. We do not believe that taxation
presents a viable alternative, as it has been shown to be both ineffective and too rigid.
SHIFTING TOWARDS ORGANIC AND ANIMAL-FRIENDLY AGRICULTURAL PRODUCTION
Consumers are radically changing their food consumption patterns. Not only are consumers
concerned about the healthy and nutritious nature of their food, they also increasingly want to
know how food is produced, the impact on the environment and climate, and the way farm animals
are treated. Hence the growing demand for organic food and the reduction or elimination of
pesticides and harmful chemicals, for vegetarian and vegan options, for higher animal welfare
standards, and for alternatives to animal-based products. Retailers and wholesalers have been the
first to respond to these consumer demands and offer the products they want.
We would welcome
Commission action to reinforce compliance with current rules and to recognise the value of
private certification schemes in making the market for those products more fluid.
RESPONSIBLE SOURCING
Retail and wholesale have led numerous initiatives to monitor and improve the sustainability of
their supply chains. Work has focused on phasing out certain non-sustainable products, working
with local actors in the supply chain to improve production conditions and environmental impacts
of the products we buy and sell.
We ask the Commission to promote mutual recognition of current
initiatives and to support the effectiveness of such actions in increasing the availability of
sustainable products.
REDUCING FOOD WASTE
Apart from environmental and social considerations, it simply doesn’t make good business sense
to waste wholesome food. This is why food retailers and wholesalers have reduced waste over the
years by increasing the efficiency of logistics in their own operations. Retailers have developed
attractive products such as store-made soups, using products that have lost their commercial value
but remain fit for human consumption. As a result, retail and wholesale is only responsible for less
than 5% of total food waste volumes. Retailers and wholesalers are also working with others in the
supply chain to reduce waste elsewhere in the chain, not least in encouraging consumers, who
make up the greatest proportion of food waste, but also working with food banks to provide
wholesome food to those in need.
The Commission can help by continuing and stepping up its
successful actions to encourage food chain cooperation, and by mandating the exemption of VAT
and wider tax treatment of the writing off of stock for food donations. It should also look at
providing other financial incentives, as is the case already in several countries.
REDUCING MATERIAL AND PACKAGING WASTE – BALANCING FOOD SAFETY, CONVENIENCE AND
REDUCING PACKAGING
Plastic waste is major issue that must be addressed, and packaging represents a significant source
of plastic waste. This is why retailers and wholesalers have taken the lead, both voluntarily and
supported by legislation, in drastically reducing or eliminating unnecessary plastic packaging at
store level. Apart from mandatory measures in some countries, voluntary initiatives by Europe's
retailers to encourage consumers to switch from plastic bags have resulted in reductions of 65-
90%. We are making the same efforts with single-use plastic items. On the other hand, plastic
packaging is unavoidable. It plays an important role in maintaining the safety and quality of our
food, in reducing food waste and enhancing convenience. An example is cut fruit salad, which
consumers buy more of than the whole fruit in some cases, such as pineapple.
We ask the
Commission to work towards a circular economy by better enforcing, with Member States, the
agreed targets. The waste hierarchy in the circular economy principles needs to govern the
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approach to choice of materials, including in packaging. The approach needs to be practical, and
balance environmental objectives with the need for safety and convenience, and enable the
Single Market to function. To achieve this, we ask for financing and promotion of research on
renewable and recyclable packaging; waste management programmes and infrastructure need
to become more efficient; and legislation should be more consistent with these agreed objectives
and principles.
NUTRITIONAL AND ENVIRONMENTAL INFORMATION ON PRODUCTS
Retailers and wholesalers have led in the drive to provide accurate nutritional information to
consumers, and for harmonised approach to this. This started the Food Information Regulation
with detailed back-of-pack nutritional information, based on GDA (guidance on daily allowance). A
number of leading retailers in Europe have embarked on applying front-of-pack information to
complement this, many adopting the Nutri-Score label for their own retailer brands (aka private
labels) and asking other suppliers to do the same.
We ask that, once the Commission completes
and releases its study of the various front-of-pack nutrition label schemes, it establishes EU-
harmonised criteria to ensure any scheme in the market is based on robust scientific evidence
and proven consumer understanding.
Labels that cover the end-of-life and waste management of products are not harmonised and
confusing. We recognise that this is often the result of different waste management systems and
rules in different member states
. We ask the Commission to encourage a more coherent approach
to such labels and the rules underpinning them.
Environmental and health objectives can sometimes conflict with each other (e.g. eating avocados,
which are healthy but involve long-distance transport). Or some products receive a negative label
score, while being nutritionally valuable when consumed in smaller quantities (e.g. olive oil).
Simple sustainability labels that seek to combine environmental and nutritional information do not
properly reflect these dilemmas
We ask the Commission to do further work to address these
conflicting objectives and reduce complexity for consumers seeking to choose a healthy and
environmentally sustainable diet.
On-pack labelling, in-store display and personal advice, online apps and digital information are all
ways of informing consumers and nudging them towards a wide range of more sustainable
products. Information should fit the needs of the individual consumer in making an informed
decision.
We ask the Commission to incentivise the use of factual digital information in order to
help expand and tailor the information to suit consumer needs.
DIGITAL TECHNOLOGY - HELPING PRECISION AGRICULTURE, CONSUMER INFORMATION AND
TRACEABILITY
Digital technology has made enormous progress in many areas and finds applications throughout
the whole supply chain. Data-driven agricultural practices have enabled the development of
precision agriculture, reducing significantly the use of synthetic fertilisers and pesticides. Digital
data storage and transmission can supplement the labels on the package and provide a wealth of
additional information. Blockchain technology can provide more accurate and reliable information
and traceability.
We ask the Commission to take developments in digital technology into account
when setting policies in these areas, seeking effective outcomes while allowing scope for
innovation.
AFFORDABLE FOOD – THE SINGLE MARKET, GLOBAL TRADE, FREEDOM OF CONTRACT
Price remains the key driving factor for consumers and for many this is not a matter of choice: no
less than a fifth of Europe’s people are at risk of poverty, and struggle to feed their families well.
Intense competition among retailers has supported the development of sophisticated and
optimised distribution systems, reducing unnecessary costs, and thus bringing foods and a more
diversified and healthier diet to consumers at an affordable price. Open trade, with global trade
liberalisation and the European Single Market, has enabled millions of consumers in the EU to
benefit from a wide choice of good quality products at competitive prices. Retailers and
wholesalers have been the engine of open trade, leveraging its benefits for consumers and
safeguarding consumers’ purchasing power through negotiating fair prices with the best suppliers.
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Environmental and health considerations, local production and short supply chains may pull in a
different direction than simple price optimisation, but for legitimate other benefits. Other
tendencies have less justification: member states’ gold-plating of EU requirements and differing
food standards, and suppliers fragmenting the single market to impose unjustified territorial
supply constraints, harm consumers and hold back growth in the EU economy.
We ask the
Commission, when pursuing other important objectives, to continue their support for open
markets, in particular the Single Market, and freedom of negotiation between retailers and
suppliers with the objective of keeping food affordable for all consumers.
A DECENT INCOME FOR FARMERS THROUGH DIALOGUE AND MARKET ORIENTATION
Consumer demand is constantly changing, but people will continue to look for healthy, sustainable,
quality products which respect the planet’s environmental needs. Ensuring long-term
sustainability of supply of products that meet consumer demand is a critical issue for retailers, who
compete daily for consumers’ attention. Farmers work hard. They deserve a decent income and to
reap real benefit from their work. But this will not be served by increasing bureaucratisation
nationally and at EU level, which adds costs but offers little benefit to those it intends to help.
Rather improving farmers’ income needs them to be better organised and more able to respond
to market signals. Ultimately, they can only get a good price for foods which consumers want to
buy. Many retailers and wholesalers are helping farmers with a range of initiatives, such as securing
long-term contacts with farmers to support their transition towards organic production, or
shielding them from excessive volatility by guaranteeing floor prices. Our sector knows from day-
to-day what sells and what not, and has a shared interest with farmers in passing on this
information and helping match what the consumer chooses to put on their fork with what the
farmer produces.
We have supported, will continue to support, and ask the Commission to
support these initiatives by private actors and recognise their value. We ask the Commission to
accelerate the strengthening of producer organisations and wholesalers (while ensuring respect
of EU competition rules). The work on market transparency should avoid requiring retailers and
food operators to collect and report meaningless data, and instead work to strengthen the useful
role of Market Observatories in exchanging data with farmers. Finally, dialogue between all
players in the supply chain at local, national and European level can lead to valuable cooperation
between farmers, processors and distributors to the benefit of all, including not least, consumers.
I hope that above points will help to give you an impression of the contribution of the sector to
creating such benefits and of our policy priorities. We want also to contribute in a positive way to
your work in designing and elaborating your strategy, and will offer further thoughts to you and all
the services involved as the strategy develops.
We would meanwhile be happy to meet to discuss these points at your earliest convenience.
Yours sincerely,
Director-General
Cc:
Executive Vice-President Timmermans
Commissioner Wojciechowski
Commissioner Hogan
Commissioner Breton
Commissioner Sinkevičius
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