Document 6
From:
To:
Cc:
; FEDIOL Secretariat
Subject:
FEDIOL preliminary input on the future Farm to Fork strategy
Date:
mardi 17 décembre 2019 17:20:46
Attachments:
19SAF459 FEDIOL preliminary input on the future Farm to Fork strategy - 17 December 2019.pdf
Dear
and
.
,
In the context of the last meeting of the Advisory group of the food
chain, animal and plant health, we would like to share with you our
preliminary FEDIOL input on the upcoming Farm to Fork strategy.
We remain at your disposal to further discuss at your best convenience.
Good afternoon!
Scientific & Regulatory Affairs
@fediol.eu
Ref. Ares(2020)836369 - 10/02/2020
Date
17 December 2019
Ref. 19SAF459
FEDIOL preliminary input on the future Farm to Fork strategy
FEDIOL welcomes the possibility to provide preliminary feedback to DG SANTE on the
upcoming Farm to Fork strategy, in the context of the Advisory group of the food chain,
animal and plant health.
As we understand, the future Farm to Fork strategy will be an integral part of the Green
Deal. Hence, ensuring alignment and coherence between the different pillars of the Green
Deal is vital to secure a functioning system. This also requires full participation and
agreement among various DGs such as DG TRADE, DG AGRI and DG GROW.
FEDIOL welcomes any policy initiatives aimed at strengthening environmental
sustainability on the long term. Such initiatives, however, should not compromise European
food security in the short term nor the viability and competitiveness of food processing in
the EU. Overall, the Farm to Fork strategy should empower the EU to maintain or even
increase its competitiveness and embrace all actors in the food and feed chain equally. In
this context, education and further communication of how the EU food and feed chain
model works are equally important tools to consider to further promote science-based
policy strategies.
Trade considerations should be an integral part of the Strategy. The EU has already
established a set of instruments in trade and international cooperation. The implementation
of additional initiatives on food sustainability might be detrimental to the EU
competitiveness or to our trading partners’ ability to access the EU market, if not
appropriately balanced and harmonised via multilateral fora. Open markets and
multilateralism should remain the core approach of the EU trade strategy and not be put
at risk by excessively restrictive requirements.
FEDIOL would like to highlight the following specific non-exhaustive list of issues to be
considered in the development of the strategy:
1) Pesticides: strengthening consumer, health and environmental protection
whilst ensuring access for EU operators to sourcing from the global market
With a view to strengthening consumer, health and environmental protection, the EU
intends to implement stricter rules on plant protection products and favour alternatives to
pesticides. FEDIOL can understand the need for a new policy on pesticides, given the strong
public pressure. However, this should not come at all costs.
Such new policy should consider climate change challenges and its influence on pests and
diseases. In this respect, the outcome of the ongoing
CLEFSA project led by EFSA, which
is assessing impacts of climate change related topics on the food and feed, should be
considered.
FEDIOL members are already facing an increased threat of crop contamination, both at
production and post-harvest level, in turn leading to losses in yield, revenue and in overall
environmental performance. We can anticipate that these effects could increase as a
consequence of climate change. In this context, FEDIOL members support the availability
of other pesticides, alternatives or other tools, as long as based on EFSA rigorous
assessment and readily provided to farmers. From experience, our sector is aware that the
development of such alternatives takes time and cannot be achieved from one day to
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17 December 2019
Ref. 19SAF459
another. Hence appropriate accompanying programs and measures for farmers but also
for other sectors like ours need to be put in place. Transition should also be provided to
still enable access to raw materials from outside the EU.
Overall, the impact of further EU regulatory changes on the ability of operators to continue
sourcing from global markets needs to be assessed with great care. Overlooking external
effects of domestic policy initiatives risks leading to unintended consequences, such as the
outsourcing of processing capacities and imports of products processed from the very same
raw materials that EU operators cannot access.
Whilst we understand the need to lower the environmental impact of fertilisers and the
declared ambition to reduce their use, we believe that this objective should be weighed
against the need to maintain and even increase efficiency of land use, productivity of food
production and circularity in the agricultural cycle.
2) New Breeding Techniques (NBTs): setting up a new policy framework open
to new technologies.
Increased global demand for food, feed and renewable energy, linked to a global population
increase, creates additional pressure on the EU to produce its fair share of agricultural raw
materials. This challenge requires collective efforts to address diminishing or stagnating
yields and tackle farmland abandonment. At the same time, climate and environmental
considerations are increasing pressure to produce more food with fewer inputs. In this
challenge, new breeding techniques are essential to the development of smart agriculture
and sustainable intensification of production. Any assessment of the ECJ ruling on NBT
needs to consider those aspects. Allowing farmers to access these new technologies is
essential to provide adequate responses to climate change challenges and as such an
appropriate policy framework should be put in place.
It has indeed become increasingly clear that NBTs are not adequately addressed by the
EU’s GMO directive as it stands today. FEDIOL believes that plants obtained with new
breeding methods should not be considered under the same legal requirements as GMOs
when they could also have been obtained, for example, through earlier mutagenesis
techniques, traditional hybridisation methods or from spontaneous processes in nature.
3) Food Information to consumers: empowering consumers through effective
food labelling
Vegetable oils and fats can play an important role in a healthy and balanced diet. They
provide essential nutrients for our body like omega 3 and polyunsaturated fats. They are
also a key vector for vitamin absorption. EU labelling and nutrition policies should take into
account the nutritional benefits of their use in different foods.
Customers’ and consumers’ concerns, preferences and requirements drive how we operate
as an industry. For example, industry initiatives to define best practice for refining and
reformulating oil blends have proved very effective in responding to public health concerns
on trans-fatty acids (TFA) across a number of EU countries, thereby reducing TFA levels
significantly.
Regulators can help consumers make healthy and informed choices through effective
labelling and nutrition policies. Nevertheless, food labelling policies can be driven by
considerations that go beyond health and nutrition concerns and/or scientific evidence.
Mandatory country of origin labelling on our products risks misleading consumers on a non-
substantiated link between safety or quality and a specific origin. As regards vegetable oils
and fats and as substantiated in past Commission work, quality is dependent on the know-
how of a refiner and not on where the refining occurred.
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17 December 2019
Ref. 19SAF459
As regards nutrient profiles, FEDIOL awaits the upcoming Commission report on nutrient
profiles which will shed light on next EU steps. Whilst FEDIOL can recognise the need for a
simplified system to drive and support consumers’ choices, any system should be aligned
with existing international, EU and national dietary guidelines as well as EU Nutrition and
Health claims. Failure to do so will lead to further confusion and provision of diverging
messages to consumers. For example, as assessed in details by FEDIOL, the Nutriscore in
its current format is not meeting these criteria as regards bottled vegetable oils and fats.
Any revision/reform of the existing rules on food information to consumers should empower
consumers to make informed choices through more effective food labelling. In this context,
the establishment of any new labelling should be carefully assessed. Similarly, existing
labelling requirements should be assessed if still fit-for-purpose. The existing fully and
partially hydrogenated labelling is an example of a redundant and even confusing labelling,
now that the EU legislation setting a maximum level on trans fatty acids (TFA) is in force.
Last but not least, as regards obesity, this is a complex and multi-faceted issue, which
include food intake but also other criteria like lack of physical activity, socioeconomic and
environmental factors etc. Whilst consumption of vegetable oils and fats should be
moderated to less than 30% of total energy intake in the context of a healthy diet as
recommended by WHO, stopping eating vegetable oils and fats is actually detrimental for
consumers’ health. Vegetable oils and fats are needed as part of a healthy and balanced
diet for the reasons outlined above. Hence, reformulation of final food products should
rather focus on the one hand on reducing saturated fats to the level possible depending on
each food product, and increase the content in polyunsaturated fats on the other hand, as
recommended by WHO1 among other.
4) Food waste: avoiding unnecessary restrictions on an already efficient
sectoral processing
The recent European Commission’s Draft Delegated Decision for the uniform measurement
of levels of food waste categorises the processes from the vegetable oil and protein meal
industry, and from other primary processors alike, as producing food waste which should
be measured across the EU. This does not reflect the realities of production for our sector,
since our industry strives for resource efficiency and optimise the valorisation of raw
materials by producing a wide range of products and by-products for use in food, feed and
industrial applications, leaving virtually no waste.
As such, we already provide an efficient example of food waste prevention and directly
contribute to the circular economy ambitions of the EU.
FEDIOL asks the European Commission to reconsider the inclusion of edible oils processing
in the Delegated Act on food waste measurement published on the 3rd of May 2019, as no
food waste results from the processing of edible oils. Any mandatory measurement of food
waste would create administrative burden without delivering any environmental benefit.
FEDIOL remains available to further discuss and intends to provide further detailed input
in the next steps.
1 WHO, Healthy Diet Factsheet, 23 October 2018. https://www.who.int/news-room/fact-sheets/detail/healthy-
diet
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