Evaluation of the European Food Safety Authority (EFSA) 2017-2024

The International Organization of the Flavor Industry (IOFI) is the global trade association representing the flavor industry. Our associations membership includes both companies and national and regional trade associations that produce and use flavoring ingredients. IOFI functions as the leading flavor industry science provider.

PAN Europe supports the mission of EFSA. The EU needs an independent & transparent scientific agency to support the decisions about the protection of human and animal health, the environment, its resources and ecosystems from chemical pollution including that of pesticides.

FESASS welcomes with great interest the EFSA performance review process for the period 2017-2024. Thank you for giving us the opportunity to contribute to this process and to take into account our proposals and remarks made in the attached document.

Filed in French · English published by the European Commission

Please find enclosed GDS France’s comments on this call for contributions. Thank you for commenting and looking forward to providing specific qualitative and quantitative comments for the upcoming public and targeted consultations on the subject. Yours sincerely, GDS France

Filed in French · English published by the European Commission

Atova Regulatory Consulting is pleased to submit feedback regarding the performance of the European Food Safety Authority (EFSA). We are grateful for the opportunity to share our insights. Please find attached our comments and we thank the Commission in advance for considering our suggestions.

FEDIAF is the trade body representing the European pet food industry. Our association brings together 15 national trade associations from 18 countries and five companies that are members in their own capacity. We welcome the opportunity to contribute to the call for evidence and evaluation of EFSA performance in the years 2017- 2024 and thank the European Commission for consideration of our initial feedback as…

Contribution of the National Bovine Federation (FNB) to EFSA animal welfare studies (2017-2024): EFSA provides opinions to advise European organisations when constructing legislation. For this purpose, this body is based on studies and expert opinions that are sometimes very specific and often disconnected from the land realities and farming practices of European producers, which have to cope with ever more…

Filed in French · English published by the European Commission

The Central Union of Finnish farmers and forest owners appreciates and thanks Commission evaluation of EFSAs operation. Food safety is extremely important issue and EFSAs has done responsible work for it. Local circumstances should be better taken in to account. Specially we recognized this in poultry studies where Finnish production method was not taken into account.

The PC/BPA group of Plastics Europe represents the main producers of Polycarbonate (PC) and Bisphenol A (BPA) in Europe. We appreciate the opportunity to provide our observations regarding EFSA´s activities and approach based on our experiences during the re-evaluation of BPA by EFSA between 2017 and 2023.

CropLife Europe (CLE) represents sustainable crop protection solutions. CLE acknowledge the critical role EFSA plays in the assessment of regulated products. In general terms, the implementation of the Transparency Regulation has considerably increased the administrative burden and complexity of submissions to EFSA, and the new system and processes resulted in longer timelines for dossier preparation for the…

IBMA International Biocontrol Manufacturers Association welcomes the EU Commission's initiative in launching a "Call for Evidence" allowing stakeholders to provide feedback for the evaluation of EFSA's performance from 2017 to 2024. IBMA has observed a noticeable increase in EFSA's willingness to engage with stakeholders, and we appreciate the significant steps made towards greater openness and transparency.

FEFANA, the EU Association of Specialty Feed Ingredients and their Mixtures, welcomes the EC initiative to evaluate the performance of the European Food Safety Authority from 2017 to 2024. Please kindly find attached our feedback. We appreciate your consideration in advance.

CFE welcomes the opportunity to input into this call for evidence. The upcoming public consultation, targeted Member State consultation and stakeholder consultation must enable the evaluation of EFSAs performance specifically on the overall progress made towards the objective of the complete replacement of testing on animals.

First of all, FNSEA would like to thank the European Commission for this opportunity to give its views on EFSA’s mandate, performance and organisational framework. A number of complaints have been made by FNSEA about the animal welfare studies carried out by EFSA: 1.

Filed in French · English published by the European Commission

First of all, FNSEA would like to thank the European Commission for giving its views on EFSA’s mandate, performance and organisational framework. We make 3 main proposals: In order to implement in practice the ‘no no-solutions’ principle. FNSEA recognised EFSA’s scientific knowledge in the assessment of the risks of active substances to health and the environment.

Filed in French · English published by the European Commission

The work of EFSA has undeniably contributed to an environment where food and food ingredients can be safely consumed. EFSA's activities are crucial for the safety and innovative capacity in the food supplements sector. Food Supplements Europe thanks the Commission for the opportunity to contribute to this call for evidence.

PETA Science Consortium International e.V. is grateful for the opportunity to comment on the Commissions call for evidence for an evaluation of the European Food Safety Authority (evaluation of performance 2017 2024).

The Norwegian Scientific Committee for Food and Environment (VKM) is happy to be able to participate in this stage of the evaluation of EFSA. Please find our comments enclosed. Kind regards Gisle Solstad Senior Advisor, Administrative, Financial and International Affairs The Norwegian Scientific Committee for Food and Environment (VKM) - Secretariat

AESGP, the Association of the European Self-Care Industry, welcomes the opportunity to provide feedback on the performance of the European Food Safety Authority (EFSA) as part of its evaluation for the period 2017-2024. You will find our feedback attached. We thank you in advance for your consideration.

The Federation of Veterinarians of Europe (FVE) representing around 330,000 veterinarians across 38 European countries aims to enhance animal health, animal welfare, and public health and to protect the environment by promoting the veterinary profession. FVE appreciate the opportunity to contribute to the discussion and evaluation of the functioning of the EFSA consultative process.

About EFFA EFFA, the European Flavour Association, is a non-profit trade association representing European national associations and companies in the flavour industry based in Brussels. We welcome the EU-Commissions initiative to launch a Call for Evidence to enable the stakeholders to submit comments for an evaluation of EFSAs performance covering the years 2017-2024.

FEDIOL is the European federation representing the interests of the European vegetable oil and protein meal industry. We welcome the possibility to provide feedback on the evaluation of performance 2017-2024 of the European Food Safety Authority. You will find our feedback attached. We thank you in advance for your consideration.

The transparency offensive has become a problem for us. The platform for submitting new dossiers was/is very difficil, unclear, complicated. Registration on the platform such as up-loading a ‘horror’ (scusa) help was initially very difficult to reach and receive. Both sides, customer/EFSA, have gradually been able to cooperate usefully in the learning by doing.

Filed in German · English published by the European Commission

BEUC, the European Consumer Organisation, welcomes the opportunity to provide feedback on the performance of the European Food Safety Authority (EFSA) as part of its evaluation for the period 2017-2024. You will find our feedback attached. We thank you in advance for your consideration.

We at Eurogroup for Animals appreciate the opportunity to contribute to the discussion and evaluation of the EFSA functioning. Please see our feedback below. Enhancing NGO engagement and dialogue within EFSA One of the challenges in our engagement with EFSA has been participating in stakeholder forums that often prioritise information dissemination over actual dialogue.

EFSA is taking a very precautionary approach and whilst there is accepted that their role is not risk management but hazard identification we think it does need to take on board more of a risk management approach to its advice.

Evaluating EFSA performance 2017-2024 As a food business operator, we appreciate EFSAs independent scientific work on food safety risk assessments. However, we find there is an increased burden for industry to prove scientific measures, leaning towards pharma requirements, which doesnt match the risk food and food ingredients poses in an overall well-balanced diet.

1. The extended timelines of the application process create significant burdens, particularly for SMEs, impacting the market and creating financial difficulties. 2. Excessive demands on applicants potentially hindering innovation. We emphasize the need for a balanced approach. 3.

Compassion in World Farming EU appreciates the work of the European Food Safety Authority, especially with respect to the scientific Opinions provided for the sake of the revision of animal welfare legislation in the EU under the Farm to Fork Strategy.

As the European Industrial Hemp Association (EIHA), we'd like to highlight our main concerns regarding the EFSA's performance, particularly focusing on the Novel Food (NF) application process. The lengthy process imposes significant financial and operational challenges on our members, especially SMEs. Inconsistencies in application timelines and excessive demands complicate planning and innovation.

Please find attached EU Specialty Food Ingredients' feedback to this call for evidence. Thank you for the opportunity to comment. We look forward to providing specific qualitative and quantitatve feedback for the upcoming public and targeted consultations on the subject. Best regards.

As regards the subject of animal welfare that EFSA is studying, Young Farmers would like to inform the EU Commission that EFSA’s recommendations are too often far removed from agricultural realities on the ground. The conclusions drawn up by EFSA are not always applicable under real conditions because they would, in particular, generate excessive costs for the farmers concerned.

Filed in French · English published by the European Commission

EFSA should be more ambitious in meeting its objectives. We consider it vitally important to renew its Scientific Committee, improving its working conditions in order to achieve maximum excellence. We believe it is desirable to involve independent scientists working with non-profit organisations to carry out risk assessment of transgenic crops and food and greater food security.

Filed in Spanish · English published by the European Commission

Regarding novel foods so far the guidelines have been difficult to understand and unclear. There has not been a very clear understanding in terms of what is exactly required scientifically. It would be good to have more concrete examples published from various types of novel foods in terms of what kind of tests are required in order to prove the safety.

It is very unfortunate that the people at EFSA do not have any common sense and do not understand the science and the economics whatsoever. Since the Transparency regulation it became an extremely bureaucratic organisation. The applicant should decide on confidentiality not EFSA.

I understand 80% of the EU citizens care about animal welfare and are of the opinion that such must urgently be improved in the EU. As an animal lawyer I am of the opinion that European food safety is legitimated to take more measures to ensure: - that animal welfare is enforced in an effective way; e.g. by giving legal standing to any European civilian confronted with animal abuse.