Ref. Ares(2021)7938574 - 22/12/2021
PPA(21)2224:3 –
A
Brussels, 9th April 2021
Copa and Cogeca’s Contribution to the
20 22 Annual Work Programme (AWP)
of the EU Promotion Policy
Main Comments
•
Main aim of the Promotion Policy: The core of the Promotion Policy is to ensure the
competitiveness of all EU agricultural products as laid down in Article 2 of Regulation
(EU) 1144/2014. We would like to underline that it is thus crucial that the 2022 AWP be
aligned with this objective. We believe that the Promotion Policy can certainly help to
enhance food sustainability, and already does given the high sustainability standards of
EU agricultural products compared to those from third countries. However, we would like
to
remind the Commission that this new Promotion Policy focus proposed in
the Farm to Fork Strategy is currently only a proposal and is not enshrined in
any legal text approved by the EU co-legislators. Therefore, we would like to stress
that the Commission has no grounds to shape the 2022 AWP according to the objectives
proposed in the Farm to Fork Strategy. While the Promotion Policy can certainly increase
its contribution to sustainability, those changes need to follow the normal legislative
process.
•
A budget aligned with current challenges: In 2021, the AWP budget was down by
9% on the 2020 budget. We call for
the budget to be restored to a minimum of 200
million euros. Indeed,
agricultural markets have been severely impacted by
the COVID-19 crisis. In addition, the trade war with the USA and Brexit have added to
the already heavy burden of the COVID-19 crisis. It is thus more important than ever to
provide a strong and well-funded Promotion Policy to enable EU farmers to survive and
adapt to these difficult times. The Promotion Policy has been a key tool for ensuring the
maintenance of the competitiveness of EU agriculture since its creation and has shown
significant positive results as demonstrated by the evaluation commissioned by the
Commission (SWD(2020) 401 final of 22 December 2020) and many national farming
organisations across Europe. It is thus essential to maintain a strong budget.
•
Proportionate support for all agricultural practices: In the 2021 AWP, a
significant part of the budget (29%) has been entirely dedicated to organic products.
Given the objective to have 25% of agricultural land under organic farming by 2030, we
believe that the organic sector in particular should be supported by the promotion policy,
even above its market share. Our only fear is that the Commission’s
ambition to
dedicate 29% of the total promotion budget to organic farming, albeit well-
intentioned, is inappropriate. Today, the organic farming segment only represents
8% of total EU agricultural production. While the organic sector certainly has potential for
growth, the current budget proposal does not correspond to the market reality and is
therefore not realistic.
Promotion opportunities should be adjusted to the
natural growth of the production potential and the market demand, otherwise
the profitability of this agricultural segment will be seriously at risk and European funding
could even benefit organic products from outside the EU. The Commission could thus end
up making the organic sector more fragile instead of strengthening it. Furthermore, we
strongly believe that due to the often small size of their structures, the applicants
representing the organic sector may not have the necessary resources to submit projects
for the budget share proposed for organic on the internal market. In addition, if the
Copa - Cogeca | European Farmers - European Agri-Cooperatives
61, Rue de Trèves | B - 1040 Bruxel es | www.copa-cogeca.eu
EU Transparency Register Number | Copa 44856881231-49 | Cogeca 09586631237-74
intention is to boost the Promotion Policy’s contribution to sustainability, an objective
that has not yet been approved by co-legislators, the focus should be on proportionately
supporting all agricultural practices that demonstrate commitment in terms of
sustainability.
Disproportionately focusing on a single production method
could prevent the others from contributing further to EU agricultural
sustainability, which would reduce the Promotion Policy’s overall capacity to increase
sustainability.
•
Proportionate support for all EU quality schemes: The 2021 AWP has allocated
29% of its budget to the EU organic quality scheme and has considerably reduced its
support for other EU quality schemes such as GIs. Both the organic quality scheme and
GIs are important tools to showcase the quality of EU products. When adequately
supported, GIs in particular are quite efficient at creating new market opportunities in
third countries thanks to their renown. These products then open up the doors of those
new markets to other EU products. Furthermore, GIs are also important from a
sustainability point of view as they are intrinsically sustainable thanks to their promotion
of local rural development, local varieties, species and agricultural techniques adapted to
small scale productions and regional landscapes and biotopes. We thus call for a more
significant share of the 2022 AWP budget to be dedicated to EU quality schemes as a
whole, irrespective of whether they are organic, GI or other quality schemes.
•
Need for flexibility:
The COVID-19 crisis is still ongoing and it is thus
not yet
possible to fully assess the extent to which each sector has been impacted. Nor is it
possible to foresee the consequences that this crisis will have for the different sectors in
the coming months or years. Therefore, we believe that it is
essential to take this
uncertainty into account when defining the promotion policy priorities and to
retain some flexibility to adapt to this exceptional situation. Based on intermediate
evaluations and evolutions, adjustments to the running programs should be smoothly
possible, in order to increase the impact.
•
Need to focus on digitalisation: In light of the COVID-19 pandemic, the lockdown
and an already prominent trend towards digitalisation, we believe that some of the
promotional actions should partly focus on digital platforms and digital campaigns.
•
The deadline to apply for the programmes are often too short to be able to have
all the required papers. More time should be provided to submit the programmes
applications.
•
The administrative work for both the applications and the management of
the programmes is too burdensome and complicated. A simplification of the
administrative part would be extremely beneficial for both the programmes runners
and the managing authorities.
Specific Comments
A. A. Simple programmes
1. Simple programmes on the internal market:
• The
budget allocations should be balanced so as to give the same opportunities
to every sector via generic promotion. All products should be eligible for both simple
and multiple programmes.
• The
support that simple programmes on the internal market provide is
especially
key for those sectors that, in addition to the COVID-19 crisis, were
already facing difficulties due to:
◦ A
steady decline in consumption and in the overall value of EU products as
witnessed in the beef (especially high-value cuts) and milk sectors.
◦ Logistical difficulties (i.e. highly perishable sectors, extremely expensive
logistics, etc.) or
SPS barriers preventing access to alternative markets as
2 | 3
seen in the flowers and plants, and fruit and vegetables sectors.
◦ The fact that they face competition
from continuously increasing imports
and want
to promote the EU’s model of production, high standards
and sustainable agriculture as is the case for rice, honey and other hive
products.
◦ Market disturbances resulting from trade wars as is the case in the wine
and olive oil sector.
2. Simple programmes in third countries:
• We are convinced that
trade opportunities in third countries will continue to
play a key role in enhancing the competitiveness of our sector and in
raising consumer awareness about the high-quality and added value of our
European products worldwide.
• Copa and Cogeca believe that it is
essential to map out the current and
upcoming opportunities. This is why the
macro-economic analysis carried out
every year
by the Commission services plays a decisive role.
•
Different economic indicators (e.g. export and import growth potential) for the
different agricultural products are indeed fundamental. However, we also need to
include other economic indicators in the analysis, such as the purchasing power of
consumers and the development of the middle class in these countries. The trade
agenda and policy evaluation of free trade agreements (FTAs) must also be considered.
• In addition to the analysis issued by the Commission, many of our agricultural actors
applying for promotion programmes conduct their own
market studies to identify
the relevant markets to target. These studies are essential for agricultural actors to
make valid decisions regarding their promotion efforts. Therefore, we believe that the
costs of these studies should be
eligible for reimbursement under the
promotion programmes.
• Given the COVID-19 circumstances, it is no easy undertaking to identify specific third
countries that should be targeted. Nonetheless, taking into account current knowledge
of the situation and previous trends, we believe that the following countries or regions
should be included:
the Middle East, North America, South East Asia,
Southern Asia, Japan and China.
• Within these priorities in third countries, we also believe that it is
important to look
at neighbouring regions and countries, especially for those sectors with highly
perishable goods or those facing export difficulties due to logistics.
• As the UK is close to the European market, it is a very important export
market for many European agricultural products and it is thus advisable to
foresee a
specific budget for UK within the budget for third
countries. Brexit was a major test for trade relations and some extra
resources may bring back stability.
• As the volume of European organic production, available for export to third
countries is very limited and the equivalence not always recognised,
the
budget for promoting organic products should better be
invested in the internal market.
B. Multi-country programmes
• We believe that
all products should be eligible for multi-country
programmes (as well as simple programmes) as each type of programme, both multi
and simple, has its own specific strengths and advantages.
3 | 3