Document 1
- Ref. Ares(2020)1564377 -1:W3/2020
EUROPEAN COMMISSION
DIRECTORA1E-GENERAL FOR AGRICULTURE AND RURAL DEVELOPMENT
The Director-General ( acting)
Bmssels, 13/03/2020
AGRI.DDG
l .CI
IA.1:es 1718509
NOTE FOR THE ATTENTION OF
DGSANTE
Subject:
Reply to interservice consultation on Communication from the
Commission to the European Parliament, the European Council, the
Council, the European Economic and Social Committee and the
Committee of the Regions on the Farm to Fork Strategy for a
Sustainable Food System
Decide consultation ref.: ISC/2020/01398
Directorate-General for Agriculture and Rural Development
gives a positive opinion
subject to the following comments reasons
Please see documents attached
Maria de los Angeles
BENITEZ SALAS
Contact:
Enclosures:
2
Commission europeenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIE - Tel. +32 22991111
- Tel. direct line + 3 2
- Electronically signed on 13/03/2020 15:50 (UTC+0l) in accordance with article 4 2 (Validity of electronic documents) of Commission Decision 2004/563
Ref. Ares(2020)1564377 - 13/03/2020
Subject: Comments for the inter-service consultation on the Farm to Fork strategy
First, DG AGRI would like to thank DG SANTE and MARE for a very constructive
cooperation throughout this process that resulted in a solid and ambitious draft of the Farm to
Fork strategy. Working together across sectors was essential in delivering on such a
comprehensive and also challenging task of setting our food system on the path of major
transformation. This process built on the previous experience of working together both in
preparing the Future CAP proposal, on the preparatory work of AGRI and SANTE of a
comprehensive approach to Food Policy, and of the early anticipation of climate and
environmental challenges as the catalysts for farm policy reform in the impact assessment
accompanying the CAP legal proposals.
The latest version of the strategy is clearly an improvement. We worked together in
highlighting the opportunities and the growth potential that the transition to sustainable food
systems should bring to EU farming. This embodies the objectives of the Green Deal which
is - after all - a growth strategy for Europe. EU farmers play a decisive role in delivering this
transition and we as policy makers need to create the right enabling framework for them to
do so.
Having said this, certain important areas of concern remain and AGRI would want to see
them addressed before the adoption.
I.
The narrative
The narrative of the strategy, which transpires through the introductory section, lacks the
necessary balance between what has worked and what has not, often mixing global
developments with EU-specific challenges. Instead, the strategy should show a more positive
story where EU policies and food systems actors have delivered results, while also
acknowledging the limitations of our policy decisions where these are merited.
The Green Deal set us on the irreversible track of transformation of both the EU economy
and our society. Understanding dynamics and limitations of this pathway as well as those of
the world food systems, is essential in making this process inclusive, transparent and
engaging for all actors. The Farm to Fork strategy is a great opportunity to demonstrate how
the EU can address the global food challenge of producing more with less by doing it better.
With farmers managing 50% of our land, an integrated land management approach for all
agricultural area is the means to increase ambition on environment and biodiversity without
jeopardising food security – and the way to do it is by demanding from
all types of production
a clear improvement in climate footprint and environmental impact. The Farm to Fork
Strategy should reflect the concrete reality of how, in this on-going major transformation of
food systems worldwide, the EU experience can become pertinent by promoting policy- and
private-driven initiatives that demonstrate that sustainable best practices can be successful
in jointly increasing economic and environmental/climate efficiency.
GHG emissions
The
Paris Agreement makes a clear
link between climate change and food security by:
"Recognizing the fundamental priority of safeguarding food security and ending
hunger, and the particular vulnerabilities of food production systems to the adverse
impacts of climate change,"
focusing on "Increasing the ability to adapt to the adverse impacts of climate change
and foster climate resilience and low greenhouse gas emissions development, in a
manner that does not threaten food production"
recognising agriculture as not just part of the problem, but also of the “Agenda for
solutions”
As it appears now, the introduction of the strategy presents emissions from the “food
systems” in a way that does not give a full picture of the real situation. The striking figure on
global GHG emissions of food systems in the introduction (21-37%) fails to recognise
progress already achieved in the EU.
In this way, the reader fails to understand what lessons can be drawn from the fact the EU
agriculture is the only one among the global big farm producers whose emissions declined by
20% since 1990 – at a time when these increased significantly in Brazil (by 47%) China and
India (by 24%) and were relatively stable in the US (+6%). Omitting this fact bypasses both
what worked in the early stages of CAP reforms (the positive impact of support price drops
and then decoupling) as well as what has not worked as planned more recently (greening).
Proposed reformulation in section 1:
Food systems worldwide contribute to total GHG emissions, with significant effects on water
and soil pollution, and especially on biodiversity [to provide updated figure]. The resulting
pressure on carbon sink is one of the principal causes of resource depletion and degradation
of natural ecosystems.
At global level, GHG from agriculture have increased by 15% from 1990 to 2016, with most
major global players increasing their emissions (Brazil by 47%, China and India by 24 %, US
by 6%). Notable exception is EU agriculture, whose emissions have declined by 22% over
the same period. However, this progress, the result of a combination of previous reforms of
the CAP and private innovation, has reached its limits in recent years. A new push in terms
of more targeted policy measures to promote more sustainable practices and the higher
uptake of enabling technologies needed.
The role of livestock farming and meat consumption in perspective
There is no doubt that the livestock sector plays a crucial role in any strategy that seriously
wants to address climate change. The texts mainly mixes EU with global trends and omits
certain facts that we believe to be important.
Not all meat production methods have the same environmental impact, be it on land, water,
soil, biodiversity or air.
The major share of EU farmland used for animal production is grasslands (64%), more than
two-thirds of which is permanent grassland. This land has a much higher environmental
value than any crops that might be alternatively produced in its place. This type of livestock
therefore helps preserving the role of permanent grassland in carbon sink, biodiversity and
resilience in remote rural areas. Furthermore, while at world level 14.5% of global GHG
emissions is linked to livestock chains, this share is evidently lower in the EU (6% of EU
GHG emissions, the rest of agriculture adds another 4% to come to a total of 10% of EU
GHG emissions from agriculture). In addition, EU livestock production is characterised by
high efficiency in terms of GHG emissions per kilogram product1. Ignoring this minimises the
potential risk of environmental leakage from the potential of transferring animal production
from the EU to other places in the world, which will result in increased GHG emissions
globally.
This is more so since close to 5 million farmers (50% of all EU farmers) make a living in the
livestock sector (livestock specialist and mixed farming altogether), in particular in marginal
and remote areas. The message of sustainable agriculture must also include a reference to
the sustainable future of livestock farming in Europe, which plays an important role in the
nutrient cycle: increasing organic area will only be possible when increasing organic livestock
to produce manure to fertilise soils, for example.
Such a message would also strongly support the strategy’s emphasis on healthy and
balanced diets. Such diets are not just linked to what is produced, but more so to how it is
produced, processed and consumed. The Communication should pass a strong message on
the link between sustainability at producer, food processor, retail and consumer level and
health, but this should does imply the promotion of uniform dietary patterns.
Proposed addition in section 2.1:
EU agriculture is responsible for 10% of EU GHG emissions out of which nearly 60% is linked to
animal farming. To reduce the environmental and climate impact of animal production, and avoid
carbon leakage through imports, the development of sustainable livestock in the EU will be crucial. For
example, extensive grassland livestock systems have demonstrated their positive contribution by
converting grass into food, producing wool and biomass, maintaining biodiversity, storing carbon,
controlling soil erosion, and preserving landscapes. Intensive livestock systems, on the contrary,
would need to go through a major transformation, including by introducing technological innovation,
developing new husbandry practices or new breeds, so that unsustainable production in the EU would
belong to the past. Taking into account significant differences in livestock production in the EU, the
CAP should accompany this transformation by supporting such innovative solutions and requiring
sustainable production practices.
II.
The targets
AGRI understands that the targets will be set at the political level. In the preparatory work,
the position of AGRI has been to set targets that clearly raise significantly the level of
ambition from a “business as usual” level, while being aware of the potential risk that too high
targets could have on environmental leakage and food security. This is particularly the case
in fertilisers and organic production, where we believe that
doubling the expected outcome
form what is currently the trend is both realistic and consistent with a new sustainable growth
strategy. Setting these targets should also account for the major opportunities that
digitalisation of agriculture provides to
all farming systems albeit organic, agro-ecological, or
conventional, to simultaneously improve their economic
and environmental performance.
Instead of prioritising one type of production over the other, the farm to fork strategy should
prioritise the delivery of measurable results in soil, and thus consequently in air, water and
biodiversity.
1 In 2016, according to Climatewatchdata.org using IPCC data, emissions for beef meat equalled 16 kg CO2
eq./kg product in the EU, as compared to a global average of 26. Figures for important exporters are: 36 for
Brazil and 20 for Australia.
Items No 11 (reformulation is inherently linked to AGRI
Please add AGRI to these actions
work on e.g. directives on jams or fruit juices)
Lead DG: add
AGRI
Item 6: Review of the existing animal welfare legislation,
To ensure consistency with the changes
including on animal transport
and slaughterhouses
proposed in the strategy
Item 16: Proposal to require origin indication
for certain
To ensure consistency with the changes
food products for milk as well as milk and meat as
proposed on origin labelling in the
ingredient to enable consumers to identify locally
strategy
produced food and stimulate short supply chains to the
benefit of farmers
ANNEX
TARGET ON ORGANIC FARMING AREA
The
current drafts of the Farm to Fork Strategy and the Biodiversity Strategy mention:
In page 5, paragraph 2 of the Farm to Fork Strategy:
Organic farming is an
environmentally-friendly practice that needs to be further developed. In addition to
CAP measures, the Commission will stimulate the overall demand for organic
products and ensure consumer trust as well uptake of the scheme. In line with the
ambition defined in the EU Biodiversity Strategy 2030, the aim is to achieve the (XX
of the area) under organic farming by 2030.
In page 7, last paragraph of the Biodiversity Strategy:
Organic farming is the best
known and best regulated agro-ecological practice. It is a sector with positive
employment trends that attracts younger workers, provides 10-20 %more jobs per
land area than conventional farms, and creates added value for agricultural products.
For these reasons, it needs to account for (X%) of agricultural land by 2030.
Page 12, in the box on
commitments of the Biodiversity Strategy: […]
[at least XX%]
of agricultural land is under organic farming.
Between services, the figure of
30% of agricultural land under organic farming has been
tabled.
Problems with this target:
Target should send the right messages highlighting the importance of boosting the
organic production for all the inherent benefits of this production method, but it should
be also
realistic and credible. The organic production is projected to increase from
8% to 12% UAA by 2030. Achieving a 30% target is impossible and will put the
whole sector at risk.
Targets should consider very
different starting points, the improvement potential
and the gap that needs to be bridged. Enormous differences exist between Member
States and sectors, as is also shown in the annexed table with modelled increases
necessary to reach 20% or 30% organic area.
Balancing demand and supply: Organics should be, in fact, market driven in order to
allow the offer to adapt to the demand, gradually, triggering at the same time an
increase of surfaces. For this, it is necessary to encourage production, processing and
distribution sectors to meet demand, allow optimal pricing of organic products, and
guarantee a balanced distribution of value between the different actors. Top down
approaches would bear the risk of disturbing this balance, causing the organic market
to quickly reach its saturation, organic production to lose its profitability and farmers
leaving this sector, thus not delivering the environmental benefits.
Despite an upward trends in absolute terms, the growth trend for the organics is
showing signs of slowing down both in terms of consumption as well as surfaces.
Market differentiation, such as competition with zero pesticide labelling, local
products etc, is also weighing on the growth of the organic market. A 2018 report from
Rabobank estimates that growth rates of organic sales will slow down to 3-4% over
2017-2025 (compared to 6-7% in the previous years).
Furthermore, there are significant differences in the dynamics of various sectors, with
strong growth in the fruit and vegetable sectors, signs of stagnation in the animal
sector (where part of organic production is sold as conventional due to the absence of
demand). In the arable crops, there is much lower level of engagement as the
significant gap in yields, the lower environmental footprint of new technologies and
the absence of a price premium hamper growth prospects.
A first modelling outcome from the JRC shows that with 30% organic area and an
estimated yield gap of about 1/3 compared to conventional agriculture, a decrease of
about 7% of agricultural production would be expected, and EU cereal production
would decrease by an estimated -15%. Prices will inevitably increase in cereals (but
not necessarily in organic cereals), negatively impacting the livestock sector (increase
in feed prices). EU food prices may rise, resulting in a public debate similar to the
effect of biofuels on food security. A significant side effect could be higher pressure
for intensification of production on remaining non-organic land. The EU would have
to import more, with the risk of biodiversity loss in third countries, and export less,
which would lead to price increases in particular in North Africa, these countries
becoming more dependent on imports from Ukraine and Russia.
The above characteristics demonstrate that the organisector has more growth capacity
based on value rather than on area, and therefore it is essential that its development is
driven by demand.
Alternative proposal:
The commitment should be:
1. Boost the development of the EU organic farming area, with the aim to double the
organic agricultural area by 2030. This would translate into 16% of organic land out
of total EU-27 farmland.
As the projected area by 2030 is around 12%, doubling of the area under organic production is
ambitious and could not be achieved with the current policy intervention; this is why it needs
a further impetus provided by the European Green Deal.
The purpose of doubling organic area would better reflect the need to stimulate higher
ambition overall, and especially in Member States that are currently well below average.
TARGET ON FERTILISERS
The
current draft of the Farm to Fork Strategy mentions:
In page 4, par 2.1:
The excessive use of nutrients in agriculture i.e. those that are not
absorbed by plants, has been a major source of water pollution, impacts on climate
and has reduced biodiversity in rivers, lakes and wetlands by about one-third globally.
The oversuse of fertilisers can also cause economic and social harm as fish stocks
collapse under the pressure of polluted sea.
In page 5, par 2.1, as
commitment:
The Commission will take actions to reduce by
[XX%] the use of fertilisers by 2030. (…)
The
current draft of the Biodiversity Strategy mentions:
In page 11:
The Commission will promote zero pollution from nitrogen and
phosphorous flows from fertilisers through an effective reduction of use and an
elimination of excess use by 2030 and the application of balanced fertilisation and
sustainable nutrient management. This will be achieved through an Integrated
Nutrient management Action Plan in 2020.
In page 13, as
commitment:
There is a zero pollution from nitrogen and phosphorous
flows from fertilisers
NB: here fertilisers and nutrients refer to both mineral and organic sources
Problems with this text and the targets:
Incoherence, as:
o in the Biodiversity Strategy the target is “Zero pollution”2 and “elimination of
excess”. Zero pollution means “the reduction of excess of nutrients to the level
as to not cause hazards to human health, harm to living resources and to
aquatic ecosystems, damage to amenities or interference with other legitimate
uses of water”. In practice, to achieve this target would imply a full
implementation of the relevant environmental legislation.
o in the Farm to Fork Strategy the target is the reduction of the use of fertilisers.
While reducing the excess also leads to a reduction of the total amount of
fertilisers used, reducing the fertilisers used not necessarily leads to a reduction
of the excess (e.g. in MS where fertilisation is rather balanced, there is no need
to reduce the fertilisers used).
o The mere reduction in the use of fertilisers makes therefore little sense for the
purpose of reducing pollution; it will not be sufficiently effective to tackle the
damaging effects of the excess.
Potentially misleading definition of the target:
o The words “elimination of excess use” may imply that the quantity of fertiliser
allowed to be used by farmers is simply limited to the amount absorbed by the
crops.
2 Zero pollution is the reduction of the excess of nutrients to the level of which nutrient are not such as to cause
hazards to human health, harm to living resources and to aquatic ecosystems, damage to amenities or
interference with other legitimate uses of water.
9
o This is simplistic and does not take account of the unavoidable inefficiencies in
nutrient use, which are necessary for the assimilation of nutrients by the crops
as in all the biological processes. Instead, what is relevant for our purpose, is
that losses resulting from such inefficiencies are as low as possible and to a
level that causes no hazard to human health and the environment.
o It has been estimated that to reach this level, fertiliser excess should be reduced
by 42% (50% is the limit to prevent risk of soil impoverishment).
o Nutrients are essential for agricultural production but also for keeping soil
healthy. With too low fertiliser use, there is a risk of impoverishing the soil,
soil degradation, erosion, loss of biodiversity and carbon sink capacity.
Alternative proposals:
Keep the commitment in box of the Biodiversity Strategy: There is a zero pollution from
nitrogen and phosphorous flows from fertilisers.
In the Farm to Fork Strategy , the text on page 5, para 1 (“The Commission will take
actions
to reduce by XX% the use of fertilisers by 2030...
“) would be replaced with the
following text, to align it with the wording in the biodiversity strategy:
The Commission will promote zero pollution from nitrogen and phosphorous flows from
fertilisers through an effective reduction of use and excess by 2030 and the application of
balanced fertilisation and sustainable nutrient management.
10
Target on pesticides
Current proposal
The use of chemical pesticides in agriculture is responsible for pollution of soil, water and
air and can negatively impact on non-target plants, insects, birds, mammals. The Commission
will take actions to
reduce by XX% the use and risk of chemical pesticides by 2030 and
reduce by XX% the use of high-risk pesticides by 2030. To this end, it will revise the
Sustainable Use of Pesticides Directive, enhance provisions on
integrated pest management and promote greater use of alternative ways to protect harvest from pests and diseases. It will
also facilitate placing on the market of
plant protection products containing biological
active substances and reinforce the environmental risk assessment of pesticides. The
Commission will revise the
Regulation concerning statistics on pesticides to overcome the
existing data gaps and reinforce evidence-based policymaking. Finally, the Commission will
enforce actions to curb delays in the authorisation process.
…
5 paragraphs later
….
Climate change brings new threats to plant health. The sustainability challenge in the field
calls for measures
to strengthen the protection of plants from emerging pests and diseases
and for innovation. The Commission will adopt EU rules to reinforce vigilance on imports of
plants and surveillance of the Union territory. New innovative techniques, including
biotechnology, may play a role in increasing sustainability provided they are safe for
consumers and the environment while bringing benefits to society as a whole. The
Commission is carrying out a study to assess the potential of new genomic techniques to
improve sustainability along the food supply chain.
Drafting suggestion: putting the two paragraphs together
The use of chemical pesticides in agriculture can be is responsible for the pollution of soil,
water and air and can negatively impact on non-target plants, insects, birds, mammals.
Simultaneously, climate change brings new threats to plant health. At the same time, climate
change brings new threats to plant health and the sustainability challenge calls for measures
to
strengthen the protection of plants from emerging pests and diseases and for innovation.
The Commission will take actions to
reduce by XX% the use and risk of chemical
pesticides by 2030 and reduce by XX% the use of high-risk pesticides by 2030. To this
end, it will revise the Sustainable Use of Pesticides Directive, enhance provisions on
integrated pest management and promote greater use of alternative ways to protect harvests
from pests and diseases. It will also facilitate placing on the market of
plant protection
products containing biological active substances and reinforce the environmental risk
assessment of pesticides. The Commission will revise the
Regulation concerning statistics
on pesticides to overcome the existing data gaps and will
enforce actions to curb delays in
the authorisation process. The Commission will reinforce vigilance on imports of plants and
surveillance of the Union territory. New innovative techniques, including biotechnology, may
play a role in increasing sustainability provided they are safe for consumers and the
environment while bringing benefits to society as a whole. The Commission is carrying out a
study to assess the potential of new genomic techniques to improve sustainability along the
food supply chain.
11
correct, of is the approach broader? The
text seems to suggest much more. Clarity
on this is required!
2.1. Ensuring sustainable food production,
Page 4, para 1, second sentence, addition:
Such solutions will require human and financial
investments but also promised higher returns
e.g. by
allowing…
Page 4, para 1, last sentence, line 8, change:
… at the centre of a food value chain that promotes
circular use of food
natural resources
Page 4, para 2, from line 6
Proposed reformulation in line with the
The Commission and Member States should pay a
Staff working document on the link of
particular attention to the implementation and resource
the CAP with the Green Deal.
allocation of eco-schemes in the strategic plans
and the
Commission will support the introduction of a minimum
ring-fencing for eco-schemes in CAP legislation. In that
context, but not only, the Commission will ensure, in its
work with the co-legislators, that the Green Deal
ambition is squarely reflected in the agree CAP
legislation
. In particular, it will support a requirement to
take the relevant Green Deal targets into account as
soon as Member States draw up their CAP Strategic
Plans as well as a requirement to set explicit values at
the level of impact indicators for a limited number of
targets addressed by the Green Deal (area under
organic farming, and the use of fertilisers, pesticides
and antibiotics). Such impact-level values would
influence the setting of targets at the level of result
indicators within CAP plans. This will ensure that the
Member states strategic plans adhere to a concerted and
ambitious approach in line with the Farm to Fork
Strategy.
Moreover, as part of its wider efforts to
support Member States in their preparation of the CAP
Strategic Plans, the Commission will also make
individual recommendations to each Member State
addressing the nine specific objectives of the Common
Agricultural Policy.
Page 4, para 3, line 1, proposed nuancing of the text:
Proposed nuancing of the text
An promising example of new green business models is
carbon capture by farmers…
Page 4, para 4, line 3, addition:
…will take actions to reduce by XX% the
overall use and
risk of chemical pesticides by 2030…
3
2.1. Ensuring sustainable food production,
The text of the F2F strategy should be
consistent with the Biodiversity Strategy
page 5, para 1, :
which establishes the ambition to
achieve Zero pollution. Zero pollution
The Commission will take actions
to reduce by XX% the
means the reduction of the excess of
use of fertilisers by 2030...
nutrients to the level of which nutrient
are not such as to cause hazards to
Replace this text with to following to align it with the
human health, harm to living resources
wording from the biodiversity strategy:
and to aquatic ecosystems, damage to
The Commission will promote zero pollution from amenities or interference with other
nitrogen and phosphorous flows from fertilisers through legitimate uses of water.
an effective reduction of use and excess by 2030 and the
application of balanced fertilisation and sustainable
nutrient management.
page 5, para 1, line 8, addition:
Insert at the end:
”… including through the measures in
the CAP strategic plans
such as the use of the Farm
Sustainability Tool for nutrient management.”
2.1. Ensuring sustainable food production,
DG AGRI advises to use the GHG
emission figures reported by MS (2017)
page 5, para 2, line 1:
rather than “approximated GHG
EU agriculture is responsible for
10% of EU GHG
inventory for the year 2018.” The
emissions out of which nearly 60%
is linked to animal
agricultural share of GHG emission is
farming.
10.15% of total EU28 (year 2017)
To reduce the environmental and climate impact of
according to the same reference
animal production,
and avoid carbon leakage through
document provided in footnote.
imports, the development of sustainable livestock in
Do we have EU-27 data?
the EU will be crucial. For example, extensive grassland
livestock systems have demonstrated their positive
DG AGRI proposes adding these
contribution by converting grass into food, producing
sentences to distinguish between the
wool and biomass, maintaining biodiversity, storing
important role of sustainable livestock to
carbon, controlling soil erosion, and preserving
meet climate and environmental targets,
landscapes. Intensive livestock systems, on the
and unsustainable production, which
contrary, would need to go through a major
should change. It also believes the CAP
transformation, including by introducing technological
has an important role to play to support
innovation1, developing new husbandry practices or
this transformation and considers it
new breeds, so that unsustainable production in the EU
important to include this reference here.
would belong to the past. Taking into account
significant differences in livestock production in the EU,
the CAP should accompany this transformation by
supporting such innovative solutions and requiring
sustainable production practices. In addition to CAP
measures, […]
Add footnote:
1 For example, treatment of manure in aerobic digesters
would reduce non CO2 emissions and produce biogas.
2.1. Ensuring sustainable food production,
It will be very important to highlight the
page 5, para 2, line 7:
role of EU grown plant proteins in this
text to reinforce the ongoing efforts in
4
It will also examine EU rules to foster the replacement of
this promising area.
critical feed materials (e.g. soya from deforested land) by
more sustainable feed materials such as
EU grown plant
proteins, insects, marine feed stocks…
page 5, para 2, line 10 last sentence:
DG AGRI agrees with the intention to
scrutinise Voluntary Coupled Support
replace the last sentence with the following which will
from the angle of sustainability. The
also delete footnote 17
:
reformulation is proposed in line with
the analysis of the Staff Working
The Commission will carefully assess any proposals for
Document on the links between the CAP
coupled support in Member States’ CAP Strategic Plans
and the Green Deal.
from the perspective of the need for overall
sustainability.
2.1. Ensuring sustainable food production,
DG AGRI considers it important to extend
the scope of the review in particular also
page 5, para 4, lines 3-6, addition:
to the rules in relation to
slaughterhouses.
The Commission will revise the animal welfare
legislation, including on animal transport
and
slaughterhouses, with a view to update it based on the
latest scientific evidence, make it more encompassing
and easy to enforce, and in the end achieve a higher level
of animal welfare.
Organic farming, page 6, para 2:
DG AGRI proposes to add to the
Proposed reformulation for the paragraph:
paragraph on organic farming and
proposes to expand language on
Organic farming is an environmentally friendly practice
stimulating demand for organic food in
that needs to be further developed.
(…) In line with the
line with the request received.
ambition defined in the EU Biodiversity Strategy 2030,
the aim is to achieve the XX% of area under organic
farming by 2030.
In addition to CAP measures
supporting further uptake of the organic scheme, it is
pivotal to stimulate in parallel the consumer demand
for organic products. To this end, the Commission will
propose actions that will help Member States invigorate
consumer demand, for example through the promotion
of organic products and the organic logo, campaigns to
build confidence and consumer trust in the organic
system, green public procurement, institutional
procurement and promoting out-of-home consumption
of organic food (public sector canteens, hospitals…).
2.2. Stimulating sustainable food processing, retail…
DG AGRI proposes to delete this
statement as there is no hard evidence
Page 7, paragraph 3, line 2 - “ensure uptake and supply
that marketing standards lead per se to
of sustainable agricultural, fishery and aquaculture
food losses and waste. The evaluation
products and reduce food loss and waste” :
study on agricultural marketing
standards, which is foreseen to be
published on 25 March in parallel with
5
the F2F strategy corroborates this
absence of evident link between
marketing standards and food losses and
waste.
Page 7, end of paragraph 3,
DG AGRI proposes to align the text to the
“It will also
strengthen revise the legislative framework
mission letter of Commissioner
on geographical indications
(GIs) including to reinforce
Wojciechowski (use of the word
the sustainability of
the GI scheme criteria for such
‘strengthen’) and rephrase the end of the
indications.
sentence to focus on the entire scheme.
Page 7, paragraph 7:
It is important to also refer to the retail
The food industry
and retail itself should show the way… sector in this paragraph.
Add before the last sentence:
DG AGRI proposes to add a phrase on the
widespread phenomena of marketing
For example, marketing campaigns advertising meat at
campaigns for meat at very low prices.
very low prices must be avoided.
These are often used by retail to attract
customers, thus encouraging higher meat
consumption for very low prices,
hampering farmers from investing in
more sustainable animal production
systems. Signalling that such practices
should be avoided will be welcomed by
the farming community, environmental
NGOs and improve sustainability of the
food system.
Last sentence:
In the
medium longer term,
depending on whether
The approach to food business in the
sufficient progress has been reached, the Commission
strategy is voluntary (Code of conduct,
will consider proposing sustainability criteria to be met
voluntary commitments). The text refers
by food industry and retail, including on this could lead
to integrating sustainability into
to rules on sustainable corporate governance that will
corporate strategies. Practically all large
require the food industry to integrate sustainability into
food business operators already do so.
corporate strategies.
This would therefore be an empty
requirement.
The reference to the
longer term passes
the message that nothing really needs to
be done in the processing sector. A
reference to medium term is more
pertinent and in line with the
transformative ambition of the Green
Deal.
This section should rather be used to
indicate that in case the voluntary
commitments approach is not successful,
the Commission will take regulatory
steps to require food industry to respect
criteria, including on corporate
6
R&I projects (around EUR 2 billion) that deliver new knowledge reflected in the text.
and diverse solutions to enable
producers to manage natural
resources on land and sea in a sustainable way and empower
consumers to choose sustainable and healthy diets. To
demonstrate these solutions, the Commission is preparing for
2020 an additional call of around EUR 1 billion allocated to
Green Deal priorities.
Under Horizon Europe, the Commission proposed to spend
EUR 10 billion on R&I related to
food, bioeconomy, natural
resources, agriculture and environment. Horizon Europe
programming reflects the importance of systems’ approaches
to research and innovation. The R&I actions will
advance
knowledge, build capacities and develop innovative solutions – including nature-based, social, digital solutions – to enable
the progress towards the
targets set in the Farm to Fork
Strategy. Results of R&I will help, for instance, to speed up
action for
sustainable soil management ensuring that soils
continuously deliver food and vital ecosystems services under
changing climatic conditions. New knowledge and innovations
will also scale up
agroecological approaches in primary
production, including organic farming and agroforestry, which
substantially reduce the use of contentious pesticides,
fertilizers and antimicrobials. Primary producers, food
industries and consumers will as well benefit from
new, more
diversified value chains with
lower climate and
environmental impact. Upgraded
sustainability assessments will facilitate implementation of
innovative food labelling
systems that reward producers for their efforts and make the
sustainable and healthy choice the easy choice for consumers.
The Commission will strengthen the major innovation
deployment initiative – the
European Innovation Partnership
'Agricultural Productivity and Sustainability' (EIP-AGRI) –
which speeds up knowledge exchange and innovation on the
ground through collaborative R&I projects involving farmers,
food entrepreneurs, consumers, advisors, researchers, etc. To
maximise impact of R&I, the Commission will also reinforce
the
multi-actor approach in projects and leave space for new
approaches, such as an
R&I mission in the area of soil health
and food and R&I partnerships with Member States on
agro-
ecology living laboratories and
sustainable food systems.
The Commission will foster the application of data
technologies, such as artificial intelligence to
satellite imagery and other
agricultural data. This will boost the use of digital
technologies,
precision farming, and the capacities for
monitoring the environmental and climatic conditions in
primary production. They will be also deployed to increase
traceability, transparency and efficiency throughout the food
value chains.
Paragraph 3.1 – last phrase:
DG AGRI proposes to reformulate this
phrase to ensure the link to the
Proposed reformulation:
broadband target is in line with the
digital strategy and proposes to move
In its long term vision for rural areas
The Commission will also
the reference to the long-term vision for
aim to accelerate the roll-out of fast broadband internet in
rural areas to the end, as its scope is yet
rural areas
in order to achieve the set objectives of 100%
to be defined and should not be limited
8
access to by 2025. This will not only foster the development
to specific digital targets at this stage.
and uptake of digital technologies enabling sustainability from
farm to fork, but it will also increase farmers’ incomes and
make rural areas a better place to live and do business
; of
great importance for the forthcoming EU long term vision for
rural areas.
Section 3.2 Advisory services, data and knowledge sharing
DG AGRI welcome and agrees with the
importance of advisory services for
Proposed reformulation of the section on knowledge and
farmers. It proposes to reformulate part
advice:
of this section to introduce the concept
of Agricultural Knowledge and Innovation
Knowledge and advice are key to enable all actors
across food
Systems. This is to reflect that advice is
systems to become sustainable. Primary producers have a
particular need for tailored advice
on sustainable
no longer a top-down process, but rather
management choices
. The Commission will therefore
something that takes place in multi-actor
promote effective Agricultural Knowledge and Innovation
networks. We would like to highlight in
Systems (AKIS), involving all food chain actors, including in
particular the role of producer
particular producer and interbranch organisations, that
organisations in this regard and highlight
generate, share, and use knowledge and innovation from
the fact that Member States should
farm to fork. In their CAP Strategic Plans, Member States will
consecrate more resources to this in
need to scale up support
for AKIS and strengthen resources
their CAP Plans.
needed to develop and maintain appropriate advisory services. Integrated pest management should become a
common standard for every farmer and advisory services have
a crucial role to play in making this happen. Advisory services
are also key to reducing excess use of nutrients and promoting
the appropriate use of antimicrobials.
Section 3.2 Advisory services, data and knowledge sharing
DG AGRI underlines the importance of
this initiative, which will entail a
Proposed reformulation to replace the last phrase in the first
legislative proposal. It would propose to
paragraph of section 3.2 on the Farm Sustainability Data
create a short separate paragraph on
Network:
this, along the lines indicated to explain
the purpose and functioning of this
To this effect, the Commission will propose legislation to
initiative.
convert its Farm Accountancy Data Network (FADN) into the
Farm Sustainability Data Network with a view to also collect
data on the Farm to Fork targets and other sustainability
indicators, in full compliance with provisions on the
protection of data privacy. The new network will benchmark
farm performance against regional, national or sectoral
averages. Through tailored advisory services, it will provide
feedback and guidance to both small and big farmers on best
practices to improve their economic, environmental and
climate performance, and link their experience to the
European Innovation Partnership and research projects. This
will improve the sustainability of participating farmers,
including their incomes.
In
section 3.3 to rephrase the following sentence:
The reasons for these changes are a) we must
retain a WTO reference to avoid massive
“As part of the general approach to food labelling,
and
criticism from third countries; and b) to
consistent with our WTO obligations, the EU will promote
reflect the sentiment in section 1 above that
appropriate labelling schemes – including an EU sustainable
measures need to be taken regarding imports
9
Item 6: Review of the existing animal welfare legislation,
To ensure consistency with the changes
including on animal transport
and slaughterhouses
proposed in the strategy
Item 16: Proposal to require origin indication
for certain
To ensure consistency with the changes
food products for milk as well as milk and meat as
proposed on origin labelling in the
ingredient to enable consumers to identify locally
strategy
produced food and stimulate short supply chains to the
benefit of farmers
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