DG Trade - Mineral Oils contamination in food
Dear Trade,
On behalf of foodwatch international and under the right of access to information enshrined in the EU treaties and Regulation 1049/2001, I would like to request access to:
- All documents containing information about meetings held between European Commission DG Trade representatives and stakeholders on the topic of food contamination by Mineral Oils since 1st January 2025, including meeting agendas, meeting minutes, meeting supporting documents, or other records of such meetings;
- All documents received by European Commission DG Trade representatives from stakeholders on the topic of food contamination by mineral oils since 1st January 2025.
Yours faithfully,
Natacha Cingotti
Dear Sir or Madam,
We are writing to you concerning your request for access to documents sent
on 20/05/2025 and registered on 21/05/2025 under case number 2025/2772.
Since you have not indicated your postal address, we are not able to start
handling your request. The 15 working days to reply to your request will
start running only when you send us your postal address.
You can send your postal address by replying to this e-mail. If we do not
receive your reply we may close this case.
Please note that you can submit a request for access to Commission
documents via the portal [1]'Request a Commission document', which does
not require you to indicate your postal address.
Why do we need your personal postal address?
Since 1 April 2014, the submission of a postal address became a mandatory
feature when submitting an application for access to Commission documents
via an e-mail. We would like to explain why we need your postal address in
order to register and handle your application for access to documents when
submitted via e-mail:
• Firstly, to obtain legal certainty as regards the date you received
the European Commission reply to your application for public access to
documents. Article 297 of the Treaty on the Functioning of the
European Union (TFEU) states that 'decisions which specify to whom
they are addressed, shall be notified to those to whom they are
addressed and shall take effect upon such notification.' In line with
this provision, if the Commission does not grant full access to the
requested documents, it notifies the reply to the applicant via
registered mail with acknowledgement of receipt or via delivery
service. This requires an indication of a valid postal address by the
applicant;
• Secondly, to apply correctly the [2]Data Protection Regulation (EU)
2018/1725. Knowing whether the applicant is an EU resident (or not) is
necessary for deciding which conditions shall apply for the
transmissions of personal data to applicants for access to documents.
These conditions are not the same for recipients established in the
Union and for recipients in third countries. As the vast majority of
the documents requested contain personal data, the Commission cannot
ensure the correct application of the data protection rules in the
absence of a postal address;
• Thirdly, to apply correctly [3]Regulation (EC) No 1049/2001. Article
4(1)(b) of that Regulation refers to the protection of the privacy and
integrity of the individual and has to be applied in line with the
Data Protection Regulation;
• Fourthly, to protect the interest of other citizens and safeguard the
principle of good administration. The Commission has to treat all
citizens equally by ensuring that the legal framework for public
access to documents is respected. For example, it has to verify
whether Article 6(3) of Regulation (EC) No 1049/2001 is being evaded
by introducing several requests under different identities. Indeed, in
its Ryanair judgment ([4]EU:T:2010:511), the General Court confirmed
that Article 6(3) of Regulation (EC) No 1049/2001 cannot be evaded by
splitting an application into several, seemingly separate, parts. In
addition, the Commission has to make sure that the legal framework is
respected and the right of access to documents is not abused by making
requests under an invented identity.
The considerations above show that the request for and the consequent
processing of the applicant's postal address is not only appropriate, but
also strictly necessary for the performance of a task carried out in the
public interest within the meaning of Article 5(1)(a) of Data Protection
Regulation, namely providing a smooth and effective access to documents.
Yours faithfully,
Directorate-General for Trade and Economic Security - Access to Documents
European Commission
References
Visible links
1. https://www.ec.europa.eu/transparency/do...
2. https://eur-lex.europa.eu/legal-content/...
3. https://eur-lex.europa.eu/legal-content/...
4. https://eur-lex.europa.eu/legal-content/...
Dear DG Trade representatives,
Here below the postal address as requested:
Natacha Cingotti
foodwatch international
Mundo Madou
Avenue des Arts 7-8
B-1210 Bruxelles
Yours faithfully,
Natacha Cingotti
Dear Sir or Madam,
We hereby acknowledge the receipt of your request for access to documents
sent on 20/05/2025 and registered on 21/05/2025 under the case number
2025/2772.
We will handle your request within 15 working days as of the date of
registration. The time-limit expires on 13/06/2025. We will let you know
if we need to extend this time limit for additional 15 working days.
To find more information on how we process your personal data, please see
[1]the privacy statement.
Yours faithfully,
Directorate-General for Trade and Economic Security - Access to Documents
European Commission
References
Visible links
1. https://ec.europa.eu/info/principles-and...
Dear DG Trade representatives,
I am writing this email to enquire about the status of the above request, to which you previously aimed at responding by the 13th June. Do I understand it correctly that the delay for response has been extended by 15 working days, and can you give me then information on the new deadline for response?
Many thanks in advance for your response.
Yours faithfully,
Natacha Cingotti
Dear Ms Cingotti,
We confirm that the time limit to reply to your initial request has been
extended by 15 working days, in in accordance with Article 7(3) of
Regulation (EC) No 1049/2001 regarding public access to documents.
The new time limit expires on 4 July 2025.
We apologise for this delay and for any inconvenience this may cause.
Yours sincerely,
DG TRADE Access to Documents Team
European Commission
Directorate General for Trade
Unit R3 – Transparency, Civil Society and Communications
CHAR
1049 Brussels
Belgium
Dear Ms Cingotti,
We refer to your email application for public access to documents of 20
May 2025, registered on 21 May 2025 under the EASE reference number
2025/2772.
Your application is currently being handled and the reply to it should be
finalised very soon.
However, we will not be in a position to complete the handling of your
application within the time limit of 15 working days, which expires on 13
June 2025, i.e. today.
An extended time limit is needed as for the preparation of the reply
different services need to be consulted.
Therefore, we have to extend the time limit by 15 working days in
accordance with Article 7(3) of Regulation (EC) No 1049/2001 regarding
public access to documents.
The new time limit expires on 4 July 2025.
We apologise for this delay and for any inconvenience this may cause.
Yours sincerely,
DG TRADE Access to Documents Team
European Commission
Directorate General for Trade
Unit R3 – Transparency, Civil Society and Communications
CHAR
1049 Brussels
Belgium
Dear Ms Cingotti,
Please find attached the reply to your initial request for public access
to Commission documents registered under the above case number EASE
2025/2772.
Kindly acknowledge the receipt of this message by return email (including
to the present CC recipient). Thank you very much in advance!
Kind regards,
DG TRADE Public Access to Documents Team
Dear DG Trade Representatives,
I hereby acknowledge receipt of your response. Many thanks.
Yours faithfully,
Natacha Cingotti
Dear DG Trade representatives,
Hereby I thank you once again for your response to my access to document request and the document that you have already shared.
I am reaching out to you again to ask you to check that you do not hold any other document on the matter. I acknowledge that DG Trade is not leading on the topic of mineral oils; however I notice that you mention that the presentation that you shared was sent over by the European Commission Representation in France, but there is no document concerning the email exchange, only the attachment.
Could you kindly double-check your records for any other communication/correspondence in relation to what you shared?
Thanking you once again for your availability.
Yours faithfully,
Natacha Cingotti
Dear Ms Cingotti,
Thank you for reaching out.
Please note that the document identified and disclosed to you in reply to
your request EASE 2025/2772 had been received as an attachment to a purely
logistic email.
In accordance with Article 5(2)(c) regarding the 'Rules for the
registration of documents and the deletion of unregistered content' of the
Annex 'Detailed rules for the application of Regulation (EC) No 1049/2001
of the European Parliament and of the Council regarding public access to
European Parliament, Council and Commission documents' to the 'Commission
Decision (EU) 2024/3080 of 4 December 2024 establishing the Rules of
Procedure of the Commission and amending Decision C(2000) 3614',
[1]https://eur-lex.europa.eu/eli/dec/2024/3..., exchanges on
short-lived matters (such as exchanges regarding practical meeting
arrangements) do not need to be registered.
Therefore, the email exchange does not fall under the scope of your
request.
Yours sincerely,
DG TRADE Access to Documents Team
European Commission
Directorate General for Trade
Unit R3 – Transparency, Civil Society and Communications
CHAR
1049 Brussels
Belgium