Foodstuffs for human consumption: amending certain 'Breakfast' Directives

Hero Spain is a renowned manufacturer and market leader in the jam industry in Spain. With our brands like Hero Temporada, Hero 0%, and Hero Classica, we are known for producing high-quality products that have been enjoyed by consumers for generations.

Family Michaud Farmers welcomed the proposal to revise Directive 2001/110/EC on the labelling of honey. This initiative adequately addresses the lack of transparency of the market. It will allow consumers to make informed purchasing decisions and reduce distortions of competition that weaken the sector.

Filed in French · English published by the European Commission

The Fair Trade Advocacy Office speaks on behalf of the Fair Trade movement at EU level for trade and social justice. As a general note, the FTAO believes that the EC proposal to revise EU marketing standards on agrifood products has the potential to benefit Fair Trade and smallholder farmers in Europe and beyond.

in order to protect national and EU products and to make consumers aware of the true origin and quality of the product, it is important to revise the labelling system at EU level and in particular to ensure that, where honey originates from more than one Member State or third country, the country or countries of origin are correctly indicated.

Filed in Italian · English published by the European Commission

Unione Italiana Food is one of the most representative trade associations of the Italian food industry, with over 20 product sectors, made up of 550 companies. Among those companies, we also include three of the 4 sectors that will be affected by the Breakfast Directives: jams, fruit juices and honey. Representing these sectors, we enclose the position of our companies on the individual directives.

The following letter sets out the position of the Association of National Soice Producers (KUPS) on the Commission proposal for a Directive of the European Parliament and of the Council amending Council Directive 2001/110/EC relating to honey, Council Directive 2001/112/EC relating to fruit juices and certain similar products intended for human consumption, Council Directive 2001/113/EC relating to fruit jams…

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Please find enclosed the opinion of the Syndicat National d’Apiculture (SNA), a body representing almost 25 000 beekeepers (professionals, plural and leisure beekeepers) with regard to the proposal for a revision of the so called “Miel” Directive 2001/110 (EC).

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PROFELs European jam producers are alarmed by the proposed increase of the minimum fruit content in traditional standard jams (+29%); and extra jams (+22%). For extra jams, this would result in a drastic increase of energy input due to the longer cooking times required: adding more fruit means higher water input in the recipe (fruit consists of up to 90% water), requiring greater water evaporation to reach the set…

FDSEA’s response to the European Commission’s public consultation on its proposal for a revision of the Mixed Directive: FDSEA 68 expects measures to be put in place to guarantee the quality, origin and traceability of the product.

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LADEPALE, an association of food SMEs and ETI, processors in France, represents SMEs and mid-caps, which make the local economic fabric alive through their dynamism and are part of the everyday life of French people through emblematic products and brands that are well known and appreciated by consumers.

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Given the opportunity you give us, we would like to contact you on behalf of the organisation we represent, FENAVAL. All the main industrial producers of jams, marmalades and similar products in Spain are represented and associated. We must say that our positions, reflections and concerns are the same as those of our European organisation Profel, of which we are an intrinsic part.

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HERO Italia is a commercial company and market leader in jams in Italy. Brands like e.g. HERO Light jam or Frutta di Stagione, are standing for high quality and are enjoyed by consumer for generations. Over the last years the fruit preserving industry is facing new challenges.

Hero Slovakia Ltd. is an established brand in food distribution and one of the market leaders in premium jams in Slovakia. Brands like e.g., Schwartau Extra, are standing for high quality and are enjoyed by consumer for last 20 years. Over the last years the fruit preserving industry is facing new challenges.

Hero Czech Ltd.. is an established brand in food distribution and one of the market leaders in premium jams in Czech Republic. Brands like e.g., Schwartau Extra, are standing for high quality and are enjoyed by consumer for last 20 years. Over the last years the fruit preserving industry is facing new challenges.

In view of the right of consumers to be properly informed, bearing in mind the need for transparency and the demand expressed by European beekeepers to provide consumers with the necessary information to enable them to make their free choice in full knowledge of the facts, it is not acceptable that the indication of the countries of origin should not be accompanied by any quantification enabling the origin of the…

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F.E.E.D.M. Statement Re.: Proposal for a Directive of the European Parliament and of the Council amending amongst others Council Directive 2001/110/EC relating to honey. F.E.E.D.M. welcomes the opportunity to submit its position within the framework of the consultation process with regards to the revision of the EU Honey Directive (2001/110/EC).

Statement of the Honey Association e.V. Proposal for a Directive of the European Parliament and of the Council amending, inter alia, Council Directive 2001/110/EC relating to honey Gerne, we take the opportunity to position the Honey Association e.V. (shortly: Honey association) with regard to the draft Directive amending, inter alia, Council Directive 2001/110/EC relating to honey.

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Hero Benelux is an established brand in food, especially fruit products, for more than 100 years in the Netherlands. We are standing for high quality and we are enjoyed by consumers for generations. Over the last years the fruit preserving industry is facing new challenges.

Artisanal beekeeping guarantees the quality of honey in French regions. The European Union must protect this by imposing precise labelling on the provenance of mixed honeys: EU, outside the EU, which country and what percentage. Uncontrolled food products too often enter the European and French markets with the indication honey even though they are not or not fully.

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Helios Group is a jam producer located in Spain and with different factories located in some European countries. Helios group wants to express its concern with some aspects of this legislative proposal while welcomes the modification of other aspects that make the reference legislation more modern and adapted to the current times.

The Food Industries Association of Austria (FIAA) is the legal body representing the interests of the Austrian food industry and provides the attached position on the so-called EU breakfast directives.

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Labelling of honey’s country of origin (2001/110/EC), the proposal to mark the countries of origin of honey should be supported by a good reform. The proposal of the Farm to Fork Strategy to extend mandatory origin labelling is strongly supported. Fruit juices (2001/112/EC) The proposal to establish a new category of sugar-reduced juice products is to be supported.

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Schwartauer Werke is a food producing company and the market leader in jams and natural spreads in Germany. Brands like e.g. Schwartau Extra or Samt, are standing for high quality and are enjoyed by consumer for generations. Over the last years the fruit preserving industry is facing new challenges.

The following points are against raising the fruit content: Health – when the Directive is amended, the fruit effect is around 150 g or about 1 apple per year; No significant health benefits can be expected from this – the increase in the fruit content does not lead to a change in the sugar content of the final product – switching to alternative products (with possibly high fat content!) is to be expected in the…

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Contribution from FRSEA Brittany (France) The FRSEA Brittany expressed its disappointment at the lack of dambition in the European Commission’s proposal to revise the Migrant Directive: we expect strong measures to combat imports of non-compliant honey with even more precise labelling of honey lorigine, and we regret that there are no proposals to strengthen traceability, controls and the development of improved and…

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European beekeepers have already denounced for several years the unfair competition they are facing as a result of the import of fake honeys into the European market. These alerts have recently been confirmed and quantified in a coordinated action by the EU, which the Union Nationale de LApiculture Française (UNAF) welcomes, according to which 46 % of honeys imported into the EU are frauded, i.e.

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The Fédération Saveurs Commerce represents and defends specialist food businesses close to each other, in particular Primeurs, whether they are located in shops, on covered markets or on wind markets. In the press release published on 21 April 2023, the European Commission proposed revisions of marketing standards for agri-food products, in particular as regards waste and food waste.

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European beekeepers have already denounced for several years the unfair competition they face as a result of the import of fake honeys into the European market. These alerts have recently been confirmed and quantified in a coordinated EU action according to which 46 % of honeys imported into the EU would be frauded, i.e. they would not comply with the rules imposed by EU legislation.

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On behalf of the Austrian Chamber of Agriculture I would like to react as follows: "breakfast directives" o Honey Directive: The proposal goes into the right direction but not far enough. There is a need for better information on the origin in that cases where several countries are involved in mixed honeys.

In COAG we believe that the change proposed by the European Commission to the Miel Directive will not sufficiently reduce the risk of consumers being misled by the labelling of honey blends. The current proposal for amendment does not cover anything other than the obligation to mention on labels the country or countries of origin in which honey has been harvested, which has already been mandatory in Spain since 2020…

Filed in Spanish · English published by the European Commission

Hello, I am a beekeeper and I do not understand that the labelling of honeys does not include both the country of origin and the corresponding percentage of honey. It is a simple, reliable and effective method for combating fraud, adulterated honeys and promoting quality honeys. Thank you for not listening to industry and for promoting quality and local production.

Filed in French · English published by the European Commission

European beekeepers have already denounced for several years the unfair competition they are facing as a result of the import of fake honeys into the European market. These alerts have recently been confirmed and quantified in a coordinated action by the EU, which the Union Nationale de LApiculture Française (UNAF) welcomes, according to which 46 % of honeys imported into the EU are frauded, i.e.

Filed in French · English published by the European Commission

The Government of the Canary Islands considers that the proposal for a Directive submitted by the European Commission partially addresses the observations made by the Autonomous Community of the Canary Islands, since, in the case of honey, it will be obliged to indicate the country of origin or countries of origin in the case of mixtures.

Filed in Spanish · English published by the European Commission

La FDSEA de la Loire exprime sa déception face au manque dambition de la proposition de la Commission européenne de révision de la Directive Miel : nous attendons des mesures de lutte fortes contre les importations de miel non-conformes avec un étiquetage encore plus précis de lorigine du miel et regrettons labsence totale de propositions pour le renforcement de la traçabilité, des contrôles et le développement de…

Spanish Agri-Food Cooperatives consider that the changes proposed by the Commission with regard to the amendment of the Honey Directive are totally insufficient. The results of the fraud analysis carried out show that there is a very serious problem, especially with imported honey and the blends of these honeys with European honeys, which affects producers and consumers.

Filed in Spanish · English published by the European Commission

Contribution by FNSEA (National Federation of Farmers’ Unions) to the public consultation on the revision of the Migrant Directive, as part of the revision of marketing standards: FNSEA expressed its disappointment at the lack of ambition of the European Commission’s proposal to revise the Migrant Directive: we expect strong measures to combat imports of non-compliant honey with even more precise labelling of the…

Filed in French · English published by the European Commission

On behalf of the Austrian Chamber of Agriculture we would like to react to your request as follows: breakfast directives: o Honey Directive: The proposal goes into the right direction but not far enough. There is a need for better information on the origin in that cases where several countries are involved in mixed honeys.

BEUC is the European Consumer Organisation, representing 46 independent national consumer organisations across 32 European countries. We welcome the opportunity to submit feedback on the review of the marketing standards with regard to the Breakfast Directives. Our feedback can be found in attachment.

BEATLES (Co-creating Behavioural Change Towards Climate-Smart Food Systems) is a Horizon Europe project (2022-2026) that aspires to change the way agri-food systems currently operate and accelerate the systemic and systematic transition to climate-smart agriculture and smart farming technologies, fully aligned with the ambitions of the Farm to Fork and Biodiversity Strategies, and the new CAP at regional and EU…

As a company with the main objective to fight food waste because of aesthetic standards we would like to point out the importance of the further reduction of the remaining standards. All of the ten remaining regulations directly cause foodwaste by forcing producers to sort out or not even harvest produce meeting those requirements.

Oatly welcomes the opportunity to contribute to the public consultation on the Inception Impact Assessment (IIA) on the proposal for a revision of the EU Marketing Standards. Marketing standards help facilitate the functioning of the internal market, keep food of unsatisfactory quality off the market, provide relevant information to consumers, and ensure a level playing field for competing products.

VOG (Consortium of South Tyrolean Fruit Growers‘ Co-operatives) is glad to have the opportunity to comment on the European Commission’s Inception Impact Assessment (IIA) on the revision of EU marketing standards for agricultural products.

Upfield welcomes the Commission’s moves to modernise EU Marketing Standards for Agricultural Products. This roadmap recognises the need for food system transformation to support our planet and our health. Scientific consensus is that a shift towards plant-based foods is required in order to meet the goals of the Paris Climate Agreement.

One of the objectives that the EU should not lose sight of in the revision of marketing standards for agricultural products is subsidiarity: EU legislation on marketing standards has replaced heterogeneous national rules and has thus contributed to a level playing field for producers across the EU. This objective avoids distortions in the single market and protects producers and consumers.

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Plant-food Sweden endorses the feedback submitted by European Alliance for Plant-based foods in this matter. Plant-food Sweden would like to underline that it is key that marketing standards reflect changing consumption attitudes, increasing interest in sustainable diets, and are aligned with the objectives of the Farm to Fork Strategy to promote more sustainable food systems.

The European Livestock and Meat Trades Union (UECBV), is the EU voice of national federations representing livestock markets, livestock traders (cattle, horses, sheep, pigs), meat traders (beef, horsemeat, sheep meat, pig meat), and meat industry (slaughterhouses, cutting plants and meat preparation plants).

EuroCommerce welcomes the opportunity to provide feedback to the roadmap on the revision of EU marketing standards for agricultural products. Ensuring quality of food products, and consumers’ trust in food, is a priority for our sector. While standards are primarily meant for producers, they are important to enable retailers and wholesalers to match the needs of consumers.

The European Alliance for Plant-based Foods (EAPF) welcomes the opportunity to contribute to the public consultation on the Inception Impact Assessment (IIA) on the proposal for a revision of the EU Marketing Standards. Harmonised marketing standards are essential to the good functioning of the EU single market, and play a role in ensuring fair market access for a wide variety of products.

The Spanish Organic Farming Society (EEAS) highly appreciates that the Commission reviews product marketing standards to adapt them to new agreements such as the European Green Deal and associated strategies (F2F and Biodiversity).

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Copa and Cogeca generally welcome the Commission’s objectives for the revision of EU marketing standards for agricultural products. As rightfully underlined in the Commission IIA, it is extremely important to adapt, where it is necessary and convenient, marketing standards to new market realities, stakeholders’ needs, consumer preferences and available technologies.

Marketing standards for jams/fruit preserves, jellies, marmalades and similar products are regulated in Council Directive 2001/113/EC of 20 December 2001. These standards have played a major role in supporting and promoting a positive evolution of the sector since their entry into force, and have defined the most important parameters for high quality jams and similar products ever since.

The front-of-pack nutrition labelling, Nutri-Score, has received support from several member countries, where other countries wish to recover their present system. If Nutri-Score should be made into a joint EU labelling system it would risk turning the clock back multiple decrees for Swedish and Nordic public health work.

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The Federación Española de Asociaciones de Productores Exportores de Fruit, Vegetables, Flores y Plantas Vivas (FEPEX), the Spanish Federation of Associations of Producers Exporters of Fruit, Vegetables, Flores and Vivas Plants (FEPEX) appreciates the opportunity offered by the Commission to comment on the initial impact assessment on the review of EU marketing standards for agri-food products, which we consider to…

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As part of the public consultation launched by the European Commission on the evaluation and revision of marketing standards by sector or product, Interfel — the interbranch association of fresh fruit and vegetables — wishes to reaffirm the value of these texts.

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Dear Sir/Madam, in the hops sector, this consultation concerns the certification of each hops placed on the market in Germany by lot by producer, hops variety, year of cultivation and production area since the 16th century and is supposed to clearly determine the origin of each hops at that time, as is the case today.

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FruitVegetablesEUROPE (EUCOFEL) is the European private sectoral Association representing the European Fruit and Vegetables producers and exporters at the EU level. FruitVegetablesEUROPE's members are national and regional Federations and Associations (mainly PO and APO) and companies from the main European producing countries (France, Germany, Greece, Italy, Poland, Portugal, and Spain).

Manageability of the legal basis: — Regulation (EU) No 543/2011 of 7 June 2011, with updates for the fruit and vegetables and processed fruit and vegetables sectors, provides a legal basis which is perfectly manageable and perfectly correct.

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FRUCOM, representing the EU importers of dried fruit and nuts, thanks the Commission for the consultation on the EU marketing standards for agricultural products– inception impact assessment. As stated by the Commission, this initiative aims to update these standards to encourage the supply of more sustainable products to consumers and simplify current legislation.

The Regulatory Board for the Protected Geographical Indication ‘Cítricos Valencianos’/‘Cítrics Valencians’ is submitting its comments in the attached file.

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Freshfel Europe welcomes the opportunity to comment on the five options presented in the Inception Impact Assessment for a revision of EU marketing standards for agricultural products. In view of the current use and potential future use of marketing standards in the fresh produce sector, Freshfel Europe believes Option 3 “Revise the current marketing standards to modernise them (e.g.

EGGS We can summarize our position with these points: 1) FREE RANGE_the limit of 16 weeks for housing restrictions to protect animal health: the time of 16 weeks is too short in our experience. It could be useful to harmonize the rules between similar systems (for example, aligning with the organic rule which foresees at least 1/3 of the life of hens outdoors); 2) SUSTAINABILITY_solar panel outdoor: we believe that…

From the Spanish Poultry Meat Association, it is very important that Marketing Standards can be reviewed periodically since market changes very quickly and adjustments needs to be made. We are experiencing new needs from consumers and thus, a revision to consider technological changes, new production methods but also consumer preferences specifically in terms of water content, production methods, and labelling.

Remark to COMMISSION REGULATION (EC) No 543/2008: 1) Article 11, number (1), last sentence: The indication of "from foie gras production" for free-range production (points c/d/e) only is not okay. The consumer has the right to be informed about the origin of the cuts even if no free-range indicated or if other form of farming is indicated as well. Otherwise it would be consumer deception.

Dutch Meat Importers Association (DMIA) The European Marketing Standards for meat and poultrymeat have proven to be a successful and effective instrument for ensuring the continuity and proper functioning of the common market organization within the European Union. Industry, trade, controlling authorities and consumers benefit equally from the application of the marketing standards.

Hello, In the attached document you will find the contribution of SNIPO (Syndicat National des Industriels et Professionnelle des Oeufs), a French employers’ organisation representing egg packing centres and egg product manufacturers, on the revision of Regulation (EC) No 589/2008 on marketing standards for eggs laying down and implementing Regulation (EC) No 1234/2007.

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AviAlter considers that no change should affect the farming methods of chickens in Europe. The current legislation has enabled the development of poultry farming in Europe with differential added values and highly appreciated by consumers.

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The New Aquitaine Region, the New Aquitaine Regional Chamber of Agriculture and the PGI Canard in Foie Gras du Sud-Ouest reiterate their position in favour of maintaining EU marketing standards for agricultural products, in particular as regards the current definition of raw foie gras.

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The existence of marketing standards for fruit and vegetables has major advantages: - They promote transparency in the market and contribute to fair trade; - They contribute to high-quality production and thus serve the interests of the consumer; - They offer a clear distinction in quality so that the producer can get the price he deserves; - They provide uniform product definitions.

We strongly support maintaining hops certification as part of marketing standards. The current rules on the official designation of hops and compliance with minimum standards ensure a high level of quality in the hops sector for the whole marketing chain (producers/distributors/processors/breweries). They also create a high level of transparency and trust in the quality of hops from the European Union.

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INITIATIVE: Agricultural products — review of EU marketing standards ANSWER: Spanish Association of Designations of Origin — ORIGEN SPAIN. Submission of comments as part of the Roadmap in the process of updating marketing standards for EU agricultural products.

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The Confédération paysanne is a general agricultural union, representative at national level. This contribution, in PDF format, concerns the marketing standards for fruit and vegetables managed by Implementing Regulation No 543/2011.

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The COAG beekeeping sector calls on the European Commission to maintain (or in any case strengthen and improve) marketing standards in the EU. As regards honey in particular, we believe that market rules at European level should NOT be governed by private standards.

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(a) Article 4(1)(d) of Regulation (EU) No 543/2011: Inclusion of the date of minimum durability in the exception for sliced or disassembled products Convenience products usually undergo highly technical treatment during reprocessing.

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The COAG beekeeping sector calls on the European Commission to maintain (or in any case strengthen and improve) marketing standards in the EU. As regards honey in particular, we believe that market rules at European level should NOT be governed by private standards.

Filed in Spanish · English published by the European Commission

1) Regulation (EC) No 589/2008 — marketing standards for eggs Dual use of photovoltaic free area installations with the outlet area for free-range laying hens would be a potentially very suitable form of combining energy production with predominantly unimpaired agricultural use on the same area.

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European Commission Date 16.02.2021 [name removed]. Agricultural Master/GF Telephone: [phone removed]. E-mail: [email removed] Subject: Entry to update marketing standards for eggs in the EU Dear Sir/Madam, I hereby declare on behalf of my partner holdings: Warberghof GbR — Danneckerhof Tobias Vötsch — Hof Maier — Steinefurthof the following feedback on the EU marketing standard.

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Dear Sir/Madam, as Rhineland-Palatinate I join the majority of producers of eggs from Baden Würtenberg! 1. Free-range farming as a separate type of farming in the marketing standard. Improving husbandry conditions in livestock farming is a stated objective of the EU. In particular, access to an open-air area plays an important role in this process, according to many experts.

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Spanish Agro-Food Cooperatives present this document which supports and complements the position expressed by our organisation at EU level Copa-Cogeca. We provide comments in three specific sectors and in relation to marketing standards: — Fruit and vegetables. — Olive oil. — Miel.

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The ASPROCAN proposals are developed in two main areas developed below: 1. Protection of plant health reciprocity for the benefit of the environment. Fruit and vegetables are regulated by marketing standards which only affect their external appearance and not ‘invisible qualities’ as is the case, for example, in meat products.

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By Regulation (EC) No 543/2008 of 16 June 2008, the European Union repealed and replaced Regulation (EEC) No 1538/91. It is an integral part of the European Union’s common agricultural policy with other marketing standards. Article 11, read in conjunction with Annex V to the marketing standard, defines terms which indicate the type or type of farming.

Filed in German · English published by the European Commission

The Danish Agriculture & Food Council (DAFC) appreciates the opportunity to comment on the European Commission’s Inception Impact Assessment (IIA) on the revision of EU marketing standards for agricultural products. The following comments only relate to the Marketing Standard for poultry meat.

Improving husbandry conditions in livestock farming is a stated objective of the EU. Up to now, the farming method of ‘free-range laying hens’ has not been specifically regulated, but an ‘annex’ to the EU marketing standard for barn eggs. In order to better meet the needs of animals in terms of their health, a separate EU scheme should be established for this type of farming.

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ENSA, the European Plant-Based Foods Association, welcomes the opportunity to comment on the roadmap for the revision of the EU Marketing Standards. A review of the Marketing Standards’ legislative framework should be seen in the broader context of the EU Farm to Fork Strategy, which aims to make food systems fair, healthier, and environment friendly.

The Good Food Institute Europe welcomes the opportunity to provide feedback on the proposed revision of EU marketing standards for agricultural products. We particularly appreciate the Commission’s recognition that EU marketing standards should remain coherent with changing consumer needs and preferences as food production methods evolve over time.

Reaction DPA on Impact Assessment on the revision of EU Marketing standards for Agricultural Products, revision of marketing standards DPA represents the Dutch producer organisations for Fruit and Vegetables (F+V). Together with FPC she represents over 80 % of Dutch production, including traders, importers and exporters We would like to give the following observations regarding the objectives and expected impacts 1.

Article 4(3) of Regulation (EC) No 589/2008: By way of derogation from paragraph 1 (S, M, L, XL), where grade A eggs of different weight classes are packed in the same package, the minimum net weight of the eggs shall be indicated in grams and the words ‘eggs of different sizes’ or other equivalent words shall be indicated on the outside of the package.

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Assomela is glad to have the opportunity to comment on the European Commission’s Inception Impact Assessment (IIA) on the revision of EU marketing standards for agricultural products. We believe that EU marketing standards are an essential tool that serves as a common language to guarantee quality products, a fair competition frame, a right and proper fragmentation in the market avoiding at the same time…

Animal right: Strengthening animal welfare has been called for by EU citizens for many years. Citizens ask for more information on how animals in food production are kept and better opportunities to make informed choices, as well as enhanced basic protection in the regulatory framework. In the Jord to table strategy, a number of improvements are promised.

Filed in Swedish · English published by the European Commission

EUWEP’s Position and input for The European Marketing standards on Eggs EUWEP wants to express her appreciation regarding the possibility offered in the “Have your say system” to comment on the European Marketing standards for eggs. EUWEP represents het European Egg packers, Egg graders, Egg traders, Egg processors and Egg product traders all over Europe.

By Regulation (EC) No 543/2008 of 16 June 2008, the European Union repealed and replaced Regulation (EEC) No 1538/91. It is an integral part of the European Union’s common agricultural policy with other marketing standards. Article 11, read in conjunction with Annex V to the marketing standard, defines terms which indicate the type or type of farming.

Filed in German · English published by the European Commission

Feedback by Deutsche Umwelthilfe e.V./ Environmental Action Germany As consumer protection and environmental organization working on the topic of food waste, Environmental Action Germany appreciate the upcoming revision of marketing standards in line with the Farm to Fork strategy.

The revision of the EU’s marketing standards for agricultural products should pay special attention to marketing practices in which consumers are purposefully misled as to the origin of the product. Deceptive choices in product packaging (e.g. coloring and visual presentation) and product branding (e.g.

Good morning, We would like to thank us for this opportunity offered by the Commission to analyse a possible amendment/revision of marketing standards for agri-food products. Please find in the attached document the assessment of the Subdirectorate-General for Inspection, Certification and Technical Assistance of Foreign Trade of the Spanish Ministry of Industry, Trade and Tourism.

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CELCAA is the European association of the trade in agri-food products, representing 35 000 trading companies operating in imports and exports of major commodities- such as meat, dairy, wine, arable crops, grains, sugar etc.

Statement of the Poultry Industry Association Baden-Württemberg, Rheinland-Pfalz Germany Improving the conditions in which farm animals are kept is a declared goal of the EU. The EU marketing standards are irreplaceable for the free movement of goods, for the marketing of safe food and for the protection of consumers against deception.

Ensure correct egg coding The previous provision in Annex VII, Part VI, point III 2. Regulation (EU) No 1308/2013 allows egg producers, regardless of their size, to sell and deliver eggs without being labelled with the producer code. According to that provision, the marking of eggs may be carried out in the first packing centre instead of at the production site.

Filed in German · English published by the European Commission

Free-range farming as a separate form of farming in the EU marketing standard for eggs Improving husbandry conditions in livestock farming is a stated objective of the EU. Up to now, the farming method of ‘free-range laying hens’ has not been specifically regulated, but rather an ‘annex’ to the EU marketing standard for barn eggs.

Filed in German · English published by the European Commission

AGRUPOST “Grourupación Española de Servicios y Procesos Postharvest” brings together the main companies in the European sector for coatings and post-harvest treatments for fresh fruit. Providing protective formulations to cover fruit and sustainable processes and technologies are the main activities of AGRUPOST member companies with the aim of increasing the shelf-life of fresh fruit and thus contributing to the…

Filed in Spanish · English published by the European Commission

Free-range farming as a separate form of farming in the EU marketing standard for eggs Improving husbandry conditions in livestock farming is a stated objective of the EU. Up to now, the farming method of ‘free-range laying hens’ has not been specifically regulated, but rather an ‘annex’ to the EU marketing standard for barn eggs.

Filed in German · English published by the European Commission

Free-range farming as a separate form of farming in the EU marketing standard for eggs Improving husbandry conditions in livestock farming is a stated objective of the EU. Up to now, the farming method of ‘free-range laying hens’ has not been specifically regulated, but rather an ‘annex’ to the EU marketing standard for barn eggs.

Filed in German · English published by the European Commission

SYNALAF, representing poultry and egg producers Label Rouge and organic in France, thanked the European Commission for this initiative to comment on the process of revising EU marketing standards. SYNALAF underlines that, for poultry meat and eggs, the recent evaluation of marketing standards has demonstrated the effectiveness, efficiency, relevance, coherence and added value of these texts by the EU.

Filed in French · English published by the European Commission

Free-range farming as a separate form of farming in the EU marketing standard for eggs Improving husbandry conditions in livestock farming is a stated objective of the EU. Up to now, the farming method of ‘free-range laying hens’ has not been specifically regulated, but rather an ‘annex’ to the EU marketing standard for barn eggs.

Filed in German · English published by the European Commission

Free-range farming as a separate form of farming in the EU marketing standard for eggs Improving husbandry conditions in livestock farming is a stated objective of the EU. Up to now, the farming method of ‘free-range laying hens’ has not been specifically regulated, but rather an ‘annex’ to the EU marketing standard for barn eggs.

Filed in German · English published by the European Commission

Free-range farming as a separate form of farming in the EU marketing standard for eggs Improving husbandry conditions in livestock farming is a stated objective of the EU. Up to now, the farming method of ‘free-range laying hens’ has not been specifically regulated, but rather an ‘annex’ to the EU marketing standard for barn eggs.

Filed in German · English published by the European Commission

Free-range farming as a separate form of farming in the EU marketing standard for eggs Improving husbandry conditions in livestock farming is a stated objective of the EU. Up to now, the farming method of ‘free-range laying hens’ has not been specifically regulated, but rather an ‘annex’ to the EU marketing standard for barn eggs.

Filed in German · English published by the European Commission

Free-range farming as a separate form of farming in the EU marketing standard for eggs Improving husbandry conditions in livestock farming is a stated objective of the EU. Up to now, the farming method of ‘free-range laying hens’ has not been specifically regulated, but rather an ‘annex’ to the EU marketing standard for barn eggs.

Filed in German · English published by the European Commission

Free-range farming as a separate form of farming in the EU marketing standard for eggs Improving husbandry conditions in livestock farming is a stated objective of the EU. Up to now, the farming method of ‘free-range laying hens’ has not been specifically regulated, but an ‘annex’ to the EU marketing standard for barn eggs.

Filed in German · English published by the European Commission

Free-range farming as a separate form of farming in the EU marketing standard for eggs Improving husbandry conditions in livestock farming is a stated objective of the EU. Up to now, the farming method of ‘free-range laying hens’ has not been specifically regulated, but rather an ‘annex’ to the EU marketing standard for barn eggs.

Filed in German · English published by the European Commission

Free-range farming as a separate form of farming in the EU marketing standard for eggs Improving husbandry conditions in livestock farming is a stated objective of the EU. Up to now, the farming method of ‘free-range laying hens’ has not been specifically regulated, but rather an ‘annex’ to the EU marketing standard for barn eggs.

Filed in German · English published by the European Commission

Free-range farming as a separate form of farming in the EU marketing standard for eggs Improving husbandry conditions in livestock farming is a stated objective of the EU. Up to now, the farming method of ‘free-range laying hens’ has not been specifically regulated, but rather an ‘annex’ to the EU marketing standard for barn eggs.

Filed in German · English published by the European Commission

Improving husbandry conditions in livestock farming is a stated objective of the EU. EU marketing standards are irreplaceable for the free movement of goods, the placing on the market of safe food products and the protection of consumers against fraud.

Filed in German · English published by the European Commission

ERPA, the European Rural Poultry Association, welcomes the opportunity to provide feedback on the roadmap regarding the revision of EU marketing standards for agricultural products. Concerning poultry meat and eggs, we note that the recent evaluation of marketing standards proves the effectiveness, efficiency, relevance, coherence and the EU added value of these texts.

COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply appreciates the opportunity to respond to the Roadmap on the revision of EU marketing standards. The EU marketing standards are part of the Common Organisation of the Markets and apply to both EU and imported products.

Dear Sir/Madam, I hereby provide the following feedback on the EU marketing standard. I would ask you to take these points into account in the further discussion. 1. A winter garden must be mandatory. For example, 50 % of the indoor floor area should be mandatory as a cold spot to better respond to bad weather (– 10 degrees, snow or permanent rain) to protect laying hens.

Filed in German · English published by the European Commission

L’Institut Agrícola Català de Sant Isidre welcomes the opportunity to provide feedback on the roadmap on the revision of EU marketing rules for agricultural products. We particularly support the stated objective of the proposal to simplify current legislation, align with the evolving technology and production methods and add existing standards where desirable but currently lacking in existing legislation.

Marketing standard is to be applied to a number of 100 laying hens, not only 300 birds. The printing of all eggs with the stamp of origin should be compulsory at the laying holding and not only in the packing centre. — minimum durability of eggs always 28 days after the laying date.

Filed in German · English published by the European Commission

AVINED in The Netherlands appreciates the opportunity offered in the “Have your say system” to comment on the Marketing standards for eggs and the Marketing standards for poultry meat. First of all we would like to emphasize that the marketing standards created a level playing field within the European Union.

Input from the European Egg Processors Association for The European Marketing standards on Eggs First EEPA wants to express her appreciation regarding the possibility offered in the “Have your say system” to comment on the European Marketing standards for eggs.

Since their introduction, the EU marketing standards have assisted in improving farm animal welfare and creating a level playing field for EU farmers and products. The Dierenbescherming is happy with the planned revision of these standards, in order to modernise them and remove any obstacles for improving sustainability.

The Animal, Ethics and Sciences Foundation appreciates the European Commission’s intention to revise the marketing standards for agricultural products in the European Union. This revision is part of the “From Ferme to Fork” strategy.

Filed in French · English published by the European Commission

The previous provision in Annex VII, Part VI, point III 2. Regulation (EU) No 1308/2013 allows egg producers, regardless of their size, to sell and deliver eggs without being labelled with the producer code. According to that provision, the marking of eggs may be carried out in the first packing centre instead of at the production site.

Filed in German · English published by the European Commission

The previous provision in Annex VII, Part VI, point III 2. Regulation (EU) No 1308/2013 allows egg producers, regardless of their size, to sell and deliver eggs without being labelled with the producer code. According to that provision, the marking of eggs may be carried out in the first packing centre instead of at the production site.

Filed in German · English published by the European Commission

AVEC - European Poultry Association welcomes the chance to comment on the revision of the EU-Marketing Standards and would like to thank the European Commission for this initiative. The European Marketing Standards for poultrymeat has proven to be a successful and effective instrument for ensuring the continuity and proper functioning of the common market organization within the European Union.

The commercial relationship between the European Union and the main markets that produce agricultural products demonstrates that measures must be inclusive, proportional and based on scientific evidences. From these premises, the general lines of action are the following: • First, the metrics used to measure externalities of agricultural production must have solid and objective scientific basis.

The Danish Chamber of Commerce welcomes the opportunity to provide feedback to the roadmap on revision of EU marketing standards for agricultural products. We especially endorse the stated objective of the proposal to simplify current legislation and align with evolving technology and production methods.

The COUNCIL, Mr Emilio Sánchez Serrano, on its behalf, Mr Emilio Sánchez Serrano, firstly thanked us for the opportunity to comment on the revision of EU marketing standards. For this reason, and given that we understand that the revision of the marketing standards should be carried out in full detail, as many operators are affected, we will try to make our views as well as proposals for this initiative.

Filed in Spanish · English published by the European Commission

The European Alcohol Policy Alliance (Eurocare) welcomes the opportunity to comment on the Agricultural products – revision of EU marketing standards. Eurocare supports the comprehensive approach within the F2F strategy and the EU’s determination to introduce changes within the food system enabling EU citizens to lead healthy lifestyle regardless of social background by promoting sustainable food consumption…

The Association of Dutch Processing Industries thanked the European Commission for the initiative to respond to the marketing standards. In general, NEPLUVI welcomes these standards, how they function and how they create a level playing field and uniformity. However, there is a need for some topics to become modernised (Option 3).

Filed in Dutch · English published by the European Commission

Anevei’s position on and input for ‘The evaluation of the European Marketing standards on Eggs’ First and foremost Anevei, the Dutch organisation of egg packers, egg graders and egg traders, and egg processors, wants to express her appreciation in being given the opportunity to comment on the evaluation of the European Marketing standards for eggs through the “Have your say system”.

Ensure correct egg coding The previous provision in Annex VII, Part VI, point III 2. Regulation (EU) No 1308/2013 allows egg producers, regardless of their size, to sell and deliver eggs without being labelled with the producer code. According to that provision, the marking of eggs may be carried out in the first packing centre instead of at the production site.

Filed in German · English published by the European Commission

EUWEP’s Position and input for the European Marketing standards on Eggs EUWEP wants to express her appreciation regarding the possibility offered in the “Have your say system” to comment on the European Marketing standards for eggs. EUWEP represents het European Egg packers, Egg graders, Egg traders, Egg processors and Egg product traders all over Europe.

The European Federation of Foie Gras, Euro Foie Gras, fully agrees with the European Commission that “Marketing standards help facilitate the functioning of the internal market, keep food of unsatisfactory quality off the market, provide relevant information to consumers, and ensure a level playing field for competing products.” Euro Foie Gras also insists on the key role played by marketing standards in preserving…

Ensure correct egg coding The previous provision in Annex VII, Part VI, point III 2. Regulation (EU) No 1308/2013 allows egg producers, regardless of their size, to sell and deliver eggs without being labelled with the producer code. According to that provision, the marking of eggs may be carried out in the first packing centre instead of at the production site.

Filed in German · English published by the European Commission

Ensure correct egg coding The previous provision in Annex VII, Part VI, point III 2. Regulation (EU) No 1308/2013 allows egg producers, regardless of their size, to sell and deliver eggs without being labelled with the producer code. According to that provision, the marking of eggs may be carried out in the first packing centre instead of at the production site.

Filed in German · English published by the European Commission

Ensure correct egg coding The previous provision in Annex VII, Part VI, point III 2. Regulation (EU) No 1308/2013 allows egg producers, regardless of their size, to sell and deliver eggs without being labelled with the producer code. According to that provision, the marking of eggs may be carried out in the first packing centre instead of at the production site.

Filed in German · English published by the European Commission

AIJN is the representative association of the fruit juice industry in the EU since 1962. AIJN is hereby providing preliminary comments to the European Commission Roadmap on revision of EU marketing standards, and in particular the Council Directive 2001/112/EC relating to fruit juices and certain similar products intended for human consumption.

Thank you for the opportunity to provide feedback. The revision of marketing standards could be an important contribution to the improvement of animal welfare and sustainability standards in EU terrestrial and aquatic animal production.

Marketing standards are essential to respond to consumers’ demands, both in terms of food safety and to achieve additional objectives such as ensuring adequate levels of welfare to farmed animals and contributing to the fight against climate change. These objectives have been accepted and promoted by the European Commission, both through the Farm to Fork Strategy and in countless public statements.

The Association of the German Dairy Industry, Milchindustrie-Verband e.V. (MIV), welcomes the opportunity to provide comments on the European Commission’s In-ception Impact Assessment (IIA) on a revision of EU marketing standards (Ares (2021)427166 of 19.01.2021). A scientific definition of “sustainable products” is crucial before new legislation is proposed.

Eurogroup for Animals welcomes the planned revision of the EU marketing standards for agricultural products. European citizens clearly indicated that they want farmed animal welfare to be better protected and that they would like to have more information on the way in which animals reared for food are kept.

From the General Directorate of Food, Quality and Agrifood Industries from the Ministry of Agriculture, Livestock, Fisheries and Food of the Government of Catalonia, we suggest reviewing the regulatory framework, in particular the marketing standards rules of fruit and vegetables indicated in Regulation (EU) No 1308/2013 of the European Parliament and of the Council, of 17 December 2013, establishing a common…

From the General Directorate of Food, Quality and Agrifood Industries from the Ministry of Agriculture, Livestock, Fisheries and Food of the Government of Catalonia, we suggest reviewing the regulatory framework, in particular the marketing standards rules of fruit and vegetables indicated in Regulation (EU) No 1308/2013 of the European Parliament and of the Council, of 17 December 2013, establishing a common…

The European Public Health Alliance (EPHA) strongly supports a comprehensive transition towards sustainable food systems, with health and well-being as a key pillar of sustainability. Considering the new framework for EU food and agricultural policy established by the Farm to Fork Strategy, there is a need to ensure that all EU food-relevant policies and regulations contribute to the aims and priorities therein.

The aim of the marketing standards is, on the one hand, to meet the expectations of consumers and, on the other hand, to improve the economic conditions for the production and marketing of certain agricultural products and the quality of certain agricultural products.

Filed in German · English published by the European Commission

The Brigite Bardot Foundation welcomes the forthcoming revision of the marketing standards associated with EU agricultural products, and wishes to point out that animal welfare must be taken into account as one of the challenges of the sustainability of production systems.

Filed in French · English published by the European Commission

Dear sir/madam, herewith I would like to let you know that the Marketing standards for eggs (EC589/2008) need an update, namely Annex II, 1b about vegetation in open air runs. Furthermore, a paragraph on solar panels or whatelse the future might bring, is welcome too. Chickens originate from forest birds and go best outside if their free-range has shelter in the form of trees, bushes or artificial.

Introduction & Analysis Marketing Standards and common product definitions (sales descriptions and protected denominations) have proven very instrumental in assuring concise & transparent consumer information, guaranteeing a level playing field within the market competition and in facilitating trade.

Dear European Commission, Please find attached feedback from A.P. Moller - Maersk on the revision of EU marketing standards with regard to ripened banana imports. The attached document aims to provide the European Commission with some information regarding the technological developments within the logistics of fresh fruits and vegetables. The focus is here on the specific case of import of bananas to the EU.

IBMA, the International Biocontrol Manufacturers Association, welcomes this feedback request on a roadmap regarding a crucial matter for the transition to a future more regenerative agriculture as per the EU Strategies.

The old parameters entering the merit of each product should be exceeded and the absence of hazardous contaminants easily recognisable as mould or other types of contaminants (insects, mushrooms or other) should be established.

Filed in Italian · English published by the European Commission

The German Poultry Association welcomes the chance to comment on the revision of the EU-Marketing Standards. The European marketing standards for poultrymeat and eggs (hereinafter referred to as "marketing standards") have proven to be a successful and effective instrument for ensuring the continuity and proper functioning of the common market organisation within the European Union since their application in 1991.

This is a major initiative that needs a reflection process. In general, a distinction has to be made between marketing standards for local trade (direct primary producer — consumer), conventional trade and ecommerce. The parameters at local sale should be simple and would only require traceability control (Farm Farm Book) where plant protection treatments and fertilisers are recorded.

Filed in Spanish · English published by the European Commission

The third option I consider most appropriate for the revision of EU marketing standards for agricultural products would be: Review current marketing standards to modernise them, increase their contribution to the sustainability of the food system, align the rules with the requirements of the Lisbon Treaty, and simplify existing legislation by consolidating rules on marketing standards into less regulation.

Filed in Spanish · English published by the European Commission

I find the standards for fruit and vegetables essential. At trade and producer level, standards contribute to greater transparency and comparability. That is why I would also be in favour of developing standards for other agricultural products.

Filed in German · English published by the European Commission

The definition of agricultural raw material and processed food is problematic for us. The definition of processed food should be revised so that only harvested and washed products and food safety are guaranteed by sampling ovens should escape the requirements of an agricultural raw material.

Filed in Swedish · English published by the European Commission

Food marketing standards give producers the certainty that they will be able to market their products on a legal basis. On the other hand, quality standards give food retailers (LEH) the assurance that the products purchased meet a uniform quality standard.

Filed in German · English published by the European Commission

The marking systems for poultry meat in the Member States are not compatible with Article 11/1 of Regulation (EC) No 543/2008 Description of the problem Retailers have developed labelling systems for poultry meat production in different Member States. These do not comply with the binding legal requirements laid down in Article 11/1 of Regulation (EC) No 543/2008, but are not penalised by the Member States.

Filed in German · English published by the European Commission

Marketing standards are important and necessary as an effective instrument for harmonising the free movement of goods in the EU. However, they need to be updated. The update must cover all aspects relevant to poultry/eggs. Marketing standards have to be used only to a limited extent for animal welfare and consumer protection aspects.

Filed in German · English published by the European Commission

Eucolait, representing traders of dairy products and ingredients, firmly supports the marketing standards for dairy products, as they have proven that they are fit for purpose. Their continued inclusion in the single Common Market Organisation Regulation in the context of the ongoing CAP reform is certainly warranted.

In principle, marketing standards are to be welcomed, as they set uniform product standards. However, they should finally be adapted to market and product reality after 30 years. However, they should continue to be clear and understandable and not address too many conflicting concerns at once. Nor should they cover matters already covered by other regulations and standards.

Filed in German · English published by the European Commission

The necessary market balance between producers, traders and consumers should be fulfilled in the mandates to be followed. It is necessary to establish at least one regulation of legal action and practice in trade in the agricultural and food supply chain, as should be further developed than already published under Directive (EU) 2019/633.

Filed in Spanish · English published by the European Commission

Please check the marketing standards in particular in point 543/2008 20. Additional delivery, point d. free-range farming Paragraph (ix) — 95 days for geese intended for the production of fatty liver/foie gras and Magret I am of the opinion that the geese that are temporarily kept for stopping in cages or boxes are not eligible for the award “free-range farming”.

Filed in German · English published by the European Commission

Product standards need to exist for different reasons: — unifying criteria between administrations, producers, customers and consumers. Otherwise, the chain would be the one with different variable criteria. — Strengthen the EU’s position as a united market and with a globally recognised proposal. — use standards that guarantee minimum quality.

Filed in Spanish · English published by the European Commission

The Eu regulation on the import of Agro products from less developed countries like Nepal is very tough to identify the Mandatory, special and voluntary requirements for export to EU. It would be easy for country like Nepal which is a LDC to Export Agro products if such standards for import in the EU could be established by advising country-specific requirements for minimum compliance of conformity assessment.

— There are too many standards which all have to be tested individually by different companies (SKAL, Global Gap, Planet Proof, Demeter, etc.). For the same questions, you must fill in different forms. Make it possible to coordinate and exchange data (which should not now). As a result, you have a standard form and each certification raises a limited number of additional questions.

Filed in Dutch · English published by the European Commission

The free trade agreements do not play a role in European agriculture against imports. Food is allowed to balance trade equilibrium. And the LEH uses the cheap imports to depress the price of European products — see currently meat and milk (butter).

Filed in German · English published by the European Commission

Free trade agreements are beneficial for the economy as a whole. But it must be remembered that European agriculture is not played out by the ‘abundance’ of the import vo LEH. See currently the discount stores in Germany with meat and milk.

Filed in German · English published by the European Commission

I find the initiative suitable and am supportive of the needs for recognising more sustainable solution towards the harmonisation for Field sustainability products and developing a path for the future registration and review of new sustainable technology which is directly introduced to the environment, such as soil amendments and digital monitoring.