Ref. Ares(2020)4945942 - 22/09/2020
A FAIR, HEALTHY AND
ENVIRONMENTALLY-
FRIENDLY FOOD SYSTEM
EU SUGAR MANUFACTURERS’ CONTRIBUTION TO THE FARM TO FORK
AND BIODIVERSITY STRATEGIES
July 2020
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A FAIR, HEALTHY AND ENVIRONMENTALLY-FRIENDLY FOOD SYSTEM
INTRODUCTION
Sustainability is not a new concept for EU sugar manufacturers. Over the
years substantial efforts have been made to evolve:
• towards a zero-waste, circular economic production system based on
reduced GHG emissions,
• towards more innovative and sustainable cultivation and production tools,
• towards a competitive economic sector facing harsh international
competition whilst helping farmers and rural communities generating a
decent living.
CEFS stands behind the overall objective of the Green Deal and its related
initiatives to make the EU’s economy sustainable.
With the COVID-19 pandemic, which has hit hard, EU sugar producers
have demonstrated exceptional responsiveness, flexibility and solidarity to
continue supplying sugar and other products derived from beet processing
to the EU food industry, retailers and consumers. Through industrial
adaptation, the EU sugar sector has shifted a substantial part of its ethanol
production from fuel to pharma-grade ethanol.
The pandemic comes on top of several chal enges the agricultural community
in the EU, and more specifical y the European sugar beet chain, is facing:
producing sufficiently for a growing population, producing sustainably
to address environmental and climate change issues, dealing with the
recurrence of droughts and new pests, ensuring competitiveness in a sector
that is exposed to harsh international competition, whilst generating a
decent income to al . These chal enges and the answers we provide to them
affect everyone, in particular rural communities, farmers and consequently
primary food processors.
This brochure gives insights on how EU Sugar Manufacturers are wil ing to
continue on this journey provided some key requirements are taken into
account in the implementation of the Farm to Fork and Biodiversity Strategies.
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A FAIR, HEALTHY AND ENVIRONMENTALLY-FRIENDLY FOOD SYSTEM
CEFS supports the EU ambitions encrusted in the Farm to Fork (F2F) and
Biodiversity Strategies. European food is already a global standard for safety
and high-quality. Ensuring a global level playing field in international markets
and the respect of EU sustainability standards will be key in achieving the
objectives of the Strategies.
EU BEET SUGAR SECTOR’S JOURNEY TO
SUSTAINABILITY: KEY FACTS AND NUMBERS
+/- 80%
Every part
of the beet
of our GDP contribution
is used,
0%
(
15.6 billion €) is generated
translating
in rural areas supporting
into
zero
food waste
high-skilled jobs
10
Industry is
well on track to reduce
Sugar beet is a
key component
its own, as well as its supply chain’s,
of crop rotation
greenhouse gas (GHG) emissions
systems
by 2030 to be in line with the Green
Deal objectives (minus 50-55%
compared to 1990)
Sugar, which has been used
for many centuries to make
our traditional homemade
EU bio-based
SOIL &
COMPOST
foods, plays a role in a
circular economy ELECTRICITY
CONSTRUCTION
healthy and balanced diet
adapted to consumers’
DISTRICT
individual lifestyle.
HEATING
BIO GAS
FERMENTATION
PRODUCTS
ANIMAL
FEED
SUGAR
PRODUCTS
LIME
FERTILISER
VINASSE
BIOETHANOL
Footnote: WiFOR (2017). The Economic Contribution of the EU Sugar Industry. All figures exclude the UK and Switzerland.
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A FAIR, HEALTHY AND ENVIRONMENTALLY-FRIENDLY FOOD SYSTEM
23.700 sugar factory jobs
Total jobs
generated by the
362.200
sugar industry
Supporting 338.500 additional
jobs along the supply chain
14 JOBS SUPPORTED FOR EVERY
DIRECT JOB IN A SUGAR FACTORY
1KG
1KG
1KG
154,000 EUR
PER EMPLOYEE
47%
(vs 57,000 EUR in the wider
labour share
food & beverages industry)
Jobs are industrial
of GVA
Due to high efficiency
and highly-skilled
and capital intensity
We wish to share our positions on the various aspects the F2F and
Biodiversity strategies address:
1
2
3
4
CULTIVATION
PRODUCTION
NUTRITION
TRADE
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A FAIR, HEALTHY AND ENVIRONMENTALLY-FRIENDLY FOOD SYSTEM
1 CULTIVATING SUGAR BEET: GIVING FARMERS THE MEANS TO CULTIVATE
SUFFICIENT, HIGH QUALITY BEET TO MEET CONSUMER AND INDUSTRY NEEDS
The EU Commission sets the goal of reducing by supply the food chain.
CEFS pleads for a credible
2030 the overall use and risk of
chemical Plant approach with regard to targets and starting
Protection Products (PPPs) by 50%. The sugar
baselines, taking into account the efforts already
beet sector has substantial y reduced the use of
made which are explicitly recognized by the
PPPs in the past years. Setting quantitiative targets,
Strategy. Availability of alternatives and agriculture
could lead to dead-end situations in which farmers practices such as Integrated Pest Management must
are left without valid solutions to protect their crops be maintained and boosted, whilst at the same time
against certain diseases and pests and by extension guaranteeing decent farmer incomes and sector
where processors are lacking raw material to competitiveness.
INTEGRATED PEST MANAGEMENT
management and integration of different crop protection methods
Continuous monitoring for weeds, pests & diseases
Seed preparation
Treatments against
& sowing date
pests & diseases
ce
gen
er
g
in
ow
sowing of treated
e s
. . from crop
Crop
Choice of
Pr
& primed seed
ing/pre em
From sowing to crop
establishment to
rotation
varieties
establishment. .
harvest (strong focus
on disease)
Post-sow
Weed control (chemical & mechanical)
Any reduction of chemical PPPs must be The recommendations for the future Member States’
accompanied by a clear framework that al ows the national Strategic Plans will be key in this context and
development and use of new innovative techniques the Commission must ensure that Strategic Plans are
including biotechnology and the development of strictly monitored in a way that
no new distortions of
bio-based products which play a role in increasing
the single market emerge as a result of the proposed
sustainability, provided they are safe for consumers delivery model.
and the environment. The current lack of regulatory
clarity for New Breeding Techniques prevents them The EU Commission sets the goal of reaching at
from becoming mainstream and a permanent part of least 25% of the EU’s agricultural land under
organic
the agricultural toolbox in the EU.
farming by 2030. CEFS ful y understands citizens’
cal s for more organic products and overall supports
CEFS sincerely hopes that the results of the
it. However, setting an unrealistic compulsory EU
Commission study on the potential of new
target will prove to be counter-productive and
genomic techniques will final y lead to a proper
could potential y destroy the “new-born” market
regulatory framework based on state-of-the-art
for organic sugar. To ensure the objectives set by
scientific expertise and evidence.
the F2F and Biodiversity Strategies, there is a
need
for sufficient critical mass of sugar in order for
The
economic sustainability of sugar beet factories to process efficiently organic beets. This
cultivation is pivotal for the entire sector’s is why secondary EU organic legislation must al ow
competitiveness. The
Common Agricultural Policy, Ion Exchange Resins (IER) for sugar production. The
and direct payments, should be
funded at least at use of IER for organic sugar production is the only
the same level as currently. The CAP should integrate technical option that entails no change in the final
the objectives of the Green Deal ensuring a proper product composition, improves energy efficiency, and
transition and leaving no people and sector behind. reduces environmental impact.
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A FAIR, HEALTHY AND ENVIRONMENTALLY-FRIENDLY FOOD SYSTEM
2 ENSURING SUSTAINABLE FOOD PRODUCTION AND FOOD SECURITY
The
end of the quota system demonstrated in The contractual relationship between beet
2017/18 and 2018/19 that
sugar manufacturers have growers and sugar manufacturers is set out in a
suffered the most from this change. According comprehensive annex in the current Single CMO.
to CEFS confidential survey on sugar production There is no longer a unique beet price fixed at EU
costs, over this period, EU average white sugar level for all EU growers. More market orientation
prices decreased by 35% whereas world market is the new framework for EU agriculture sectors
price went down by 32%. Costs related to beets only set by the EU. It offers sugar beet farmers more
decreased by 20%. The operating results of sugar contractual security than in any other agricultural
companies were under high pressure resulting in sector stipulating inter alia that delivery contracts
financial losses far higher than the reduction of beet are compulsory and that the terms for buying sugar
costs, restructuring measures in the form of factory beet are to be fixed in compulsory agreements within
closures and costs reduction programmes.
the trade concluded between growers and sugar
undertakings (or their respective organisations).
The Commission Price Reporting Scheme has Value-sharing clauses may be agreed between
registered since December 2017 (> 2 years) an EU a sugar producer and its beet suppliers. The
white sugar price below the reference threshold of
comprehensive contractual relationship
404€/t. This threshold is a benchmark for triggering
between beet growers and sugar manufacturers,
private storage and other safeguard measures (i.e. which is set out in detail in the current Single CMO
withdrawal, import measures…). The situation we regulation,
should be preserved in order not to
are currently facing is complex due to a combination undermine the competitiveness of the sector.
of external factors, out of control of the EU, as well as
EU market tools which are no longer adapted to the
post quota period and the globalized trade realities.
To prevent new crisis in the sector, adequate
monitoring is key.
EU sugar manufacturers should
be granted a derogation to competition law, if
and when appropriate whatever the CAP legal
basis. More specifical y, article 222 of the Single
CMO should be interpreted or amended to ensure
that producers in a broad meaning (not only farmers)
are included in the scope. This is particularly true in The sugar beet sector is able and wil ing to provide
our sector where growers are producing beet and substantial amounts of “green”, sustainable
deliver them to their processors/producers who in products, al owing further GHG reduction in other
term mechanical y extract the sugar, the agricultural sectors (e.g. raw materials for the production of bio-
product regulated by the Single CMO.
based products). This will be possible provided that
an adapted enabling legal framework is properly set.
The political will to replace traditional fossil based
CEFS eagerly awaits the Commission Contingency
products by bio-based alternatives should be
plan for ensuring food supply in times of crisis and
supported by an adequate market environment.
the Commission intiatives to clarify of the scope of
The use of sugar beets in renewable materials
competition rules with regard to sustainability.
needs investment and still faces high competition
A swift and proper implementation by the
from traditional, fossil-based products. In order to
Commission of new market tools to tackle
boost their relative competitiveness, it is therefore
crisis adapted and fit for new realities of global
important to help bio-based alternatives reach
markets is a positive move and EU Sugar
economies of scale and supporting the production
manufacturers are ready to be part
of bioenergy and bio-based products as alternatives
of this process.
to fuel products.
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A FAIR, HEALTHY AND ENVIRONMENTALLY-FRIENDLY FOOD SYSTEM
3 NUTRITION: ADEQUATELY ADDRESSING A SET OF COMPLEX AND MULTIPLE
FACTORS FOR HEALTHY CONSUMPTION OF SUGAR
Healthy and sustainable diets are pivotal in
fighting on a sound scientific basis. This would require the
overweight and obesity, root causes of diet-related implication of EFSA. In the case of sugar, EFSA
non-communicable diseases such as type 2 diabetes, did not set an upper limit for sugars based on their
cardiovascular diseases and certain types of cancer.
effects on body weight and other issues such as
type 2 diabetes, cardiovascular risk factors, and
Obesity is a complex and multifactorial issue, but in
dental caries, despite recognizing that high intakes
the end always caused by an imbalance between
of sugars in the form of sugar-sweetened beverages
energy intake (consumption of all types of food
might contribute to weight gain.1
We will need to
and beverages, including sugars) and energy
see the outcome of EFSA’s review based on the
expenditure (the energy our body actual y uses).
latest scientific data, which is expected in 2021.
Therefore, any measure taken with regard to
nutrition in the context of the F2F must be framed
in a way that encourages calorie reductions in
products and in consumers’ diets.
Calorie reduction should be the new priority. There
is already a broad range of reformulated products
on the market (e.g. sugars-reduced and sugars-free
versions). The current coexistence of regular and
reformulated versions guarantees that consumers
CEFS supports initiatives that promote and
can compose a varied and balanced diet that will suit
facilitate consumers’ informed choices. The
their dietary needs. Several nutrients, among which
front-of-pack Nutri-Score scheme can be a tool to
sugars, have been tackled at EU level. The EU must complement the comprehensive information on the
now take stock of what has already been done and back-of-pack. Given the importance of energy intake
address the issue of calorie reduction.
in weight gain, the consumer should also be able
to readily view the energy content of the product
Sugar is a multifunctional ingredient and cannot next to any front-of-pack scheme.
The use of the
simply be “taken out” of food and drinks. Also, Nutri-Score should not outshine the need for the
less sugar does not necessarily mean fewer nutritional information provided on the back-of-
calories, notably not in solid foods. In order to
pack, which avoids consumers being misled.
maintain the texture and structure, reducing sugar
often requires adding other caloric ingredients (or
CEFS however remains sceptical about nutrient
additives).
Thus, ensuring that sugar reductions profiles for claims purposes and their ability to
lead to simultaneous energy reductions is crucial help fight obesity. If they focus only on certain
to ensure that reformulation activities effectively nutrients and ignore the products’ energy content,
contribute to fighting obesity.
they are likely to al ow claims on certain products
and not others despite these products’ similar impact
CEFS is concerned about the potential setting of on health, hence leading to deceptive claims (which
maximum limits of sugars in foods. By focusing is exactly what the Claims Regulation is meant to
on limiting certain nutrients without looking at prevent). It is worth recal ing that in 2008, EFSA,
the bigger context of the calories and the diet, whose advice is required by the Claims Regulation
this measure would not tackle the real problem of (EC) 1924/2006 on the question of nutrient profiles, did
excessive calorie intake and weight gain. Also, given not support sugars being a generic profiling criterion
the political intervention in companies’ free choice but stated that, if at al , sugars might be considered in
of formulation and freedom of competition, the the case of particular beverage/food groups (such as
abidance with the proportionality principle would sugar-sweetened beverages and confectionery).2
have to be ensured and would have to be based
1. European Food Safety Authority, Scientific Opinion on Dietary Reference Values for carbohydrates and dietary fibre. EFSA Journal 2010; 8(3):1462[77pp.]. doi:10.2903/j.efsa.2010.1462.
2. European Food Safety Authority, Scientific Opinion on Nutrient Profiles. The EFSA Journal 2008, 644, 1-44, p 14.
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A FAIR, HEALTHY AND ENVIRONMENTALLY-FRIENDLY FOOD SYSTEM
4 A LEVEL- PLAYING FIELD ON THE INTERNATIONAL SCENE REQUIRES
A STRONG AND COHERENT EU POLICY ON TRADE
The sugar sector
is now operating in a
Tackling world market unfair government support
deregulated environment at EU level due to the (e.g. the subsidies provided by India to its sugar
end of the production quotas on 30 September sector), recognizing the sensitivity of EU production,
2017. In contrast, at global level, the major sugar- ensuring efficient and
strict Rules of Origin and
producing players are increasingly supported and avoiding imports that violate social/environmental/
protected. This creates
unfair competition via sustainability norms must become
part of the new
trade-distorting measures.
European Trade Policy responding to a variety of
new global chal enges and taking into account the
lessons learned from the coronavirus crisis. This
CEFS asks for a fair level playing field on
is more than ever crucial in a context of uncertainties
the world market. The F2F and Biodiversity
related to the relations with the
EU and the UK which
Strategies need to address distortions
risk to
have damaging consequences for the sector.
on international trade and unfair
government support.
We also eagerly await the Commission’s initiatives
to avoid placing on the EU market of products
It is essential that the sugar entering the EU market
associated with deforestation or forest degradation.
is not produced in such a way that violates social
In this sense, the decision taken by Brazilian
rights or environmental norms, nor with trade-
authorities in 2019 to al ow sugarcane cultivation in
distorting direct or indirect government support.
the Amazon region is a step in the wrong direction in
view of the EU Biodiversity objectives for 2030.
DOMESTIC WHITE SUGAR PRICES COMPARED, EUR/TONNE
1,100
1,000
900
800
700
600
EUR/tonne
500
400
300
200
Jan-09 Jul-09 Jan-10 Jul-010 Jan-1 Jul-1 Jan-12 Jul-12 Jan-13 Jul-13 Jan-14 Jul-14 Jan-15 Jul-15 Jan-16 Jul-16 Jan-17 Jul-17 Jan-18 Jul-18 Jan-19 Jul-19 Jan-20
India (NCDEX futures)
Brazil (crystal)
EU (PRS)
US (beet wholesale)
London No. 5
Source: CEFS elaboration on the basis of public data European Commission, F.O. Licht, ISO, and USDA.
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A FAIR, HEALTHY AND ENVIRONMENTALLY-FRIENDLY FOOD SYSTEM
The EU Green Deal, the F2F and Biodiversity strategies raise hopes for a successful transition towards
even more sustainable production systems.
This transition must be well calibrated in order not to leave
sectors/people behind or create frustations.
EU Sugar Manufacturers have made impressive efforts over the years, financially and technologically,
to become a global standard for sustainability in world sugar production. Based on what is already
achieved, CEFS and its members are ready to take further action. CEFS will take part in these discussions
and contribute to constructive and workable solutions.
To realistical y reach these objectives, for CEFS any EU action needs to be:
•
science-based and relying on sound evidence from an environmental, social, nutritional but also
economic point of view and on proper impact assessments;
•
coherent ensuring notably a sustainable marriage and coherence between the Farm to Fork Strategy and
the different EU policies supporting an increase in environmental and climate ambitions, such as the CAP;
• based on
appropriate funds for the implementation of policies and for transition;
• based on a
coherent and strong trade policy.
Only in this way a sustainable food production and consumption chain can be created that works for
producers, consumers and environment whilst reinforcing the EU competitiveness.
CEFS
Comité Européen des Fabricants de Sucre
Avenue de Tervuren 268
B-1150 Brussels
xxxx@xxxx.xxx
Tel: +32 2 762 07 60
Fax: +32 2 771 00 26
www.cefs.org
www.sugardialogue.eu
twitter.com/SugarEurope
https://www.linkedin.com/company/cefs
CEFS stands for le Comité Européen des Fabricants
de Sucre, or in English: the European Association of
Sugar Manufacturers. CEFS is an international non-
profit organization and a recognised interlocutor for
the EU Institutions since 1953, sharing knowledge and
technical expertise on sugar. CEFS’ membership is
composed of sugar-producing companies in the EU,
the UK and Switzerland.