CEFS - European Association of Sugar Manufacturers

1. SELF-USE OF BIOMASS FROM BIOMASS PROCESSING IN RURAL AREAS SHOULD BE EXCLUDED FROM ART. 29 The revised sustainability criteria under the new draft Art. 29 are overly restrictive and would add dis-proportionate obligations for sugar manufacturers to certify the full amount of raw material beets and the biomass fuel derived from production residues.

The Packaging and Packaging Waste Regulation should drive recycling and the uptake of recycled and compostable packaging. CEFS approves of the general objective to reduce fossil carbon demand for plastic production. As modest users of plastics, CEFS members are all in the process of reducing their use of plastics for packaging their products.

CEFS, the European Association of Sugar Manufacturers, takes note of the European Commissions proposal for a regulation on the Certification of Carbon Removals (CCR). Decarbonising the beet sugar supply chain is a priority for our sector. In the field, sugar manufacturers work closely with beet growers to increase sustainability and reduce emissions, including within voluntary certification schemes.

The EU sugar industry reduced its CO2 emissions by 59 % between 1990 and 2021. By this metric, we are well on the way to meeting the objective of the ETS1 to reduce emissions by 62% by 2030. Sugar manufacturers recognise the importance of continued progress in reducing greenhouse gas emissions in order to reach climate neutrality by 2050.

The EU beet sugar sector uses the heat and fuel fallback benchmarks and, since 2025, process emissions have also been included under the EU ETS framework. The proposed values for the fallback benchmarks for 20262030 are highly concerning for the European beet sugar sector given the severe market difficulties currently facing the industry.

The EU sugar industry has reduced its CO2 emissions by 51 % compared to 1990. The industry is on track to meet the objectives of the Fit for 55 package for 2030. And we recognise the importance of transitioning to climate neutrality by 2050. In the sugar manufacturing sector, the heat and electricity required to produce beet sugar is generally provided by high efficiency Combined Heat and Power (CHP) systems.

Because of the rural location of sugar factories and limited access to high-voltage grids, full electrification is neither a cost-effective nor even feasible decarbonisation pathway for our sector. The use of biomass, especially own-produced (from residues and waste), in combination with the partial conversion to renewable electricity, presents a more promising avenue to decarbonise the industry.

Because of the rural location of sugar factories and limited access to high-voltage grids, full electrification is neither a cost-effective nor even feasible decarbonisation pathway for our sector. The use of biomass, especially own-produced (from residues and waste), in combination with the partial conversion to renewable electricity, presents a more promising avenue to decarbonise the industry.

The GHG emissions saving criteria for biomass fuels are restrictive and add disproportionate obligations for sugar manufacturers when it comes to the production of solid and gaseous biomass fuels. Thanks to the energetic usability of biomass residues from biomass processing, the sugar industry should be able to decarbonise without any burden on electricity grids and without having to wait for RFNBOs to become…

CEFS, the European Association of Sugar Manufacturers, supports the development of an adapted legislative framework that would allow the uptake of plants obtained by New Genomic Techniques (NGTs) in the EU. These new techniques are an important tool for farmers to face increasing challenges such as climate change adaptation and the loss of active substances, and may contribute to the achievement of the overall Green…

CEFS, the European Association of Sugar Manufacturers, welcomes the opportunity to contribute to the European Commissions Call for Evidence on the secondary legislation implementing Regulation (EU) 2026/1388 on plants obtained by certain new genomic techniques (NGTs) and their products.

CEFS, the European Association of Sugar Manufacturers, welcomes the opportunity to contribute to the European Commissions Call for Evidence on the secondary legislation implementing Regulation (EU) 2026/1388 on plants obtained by certain new genomic techniques (NGTs) and their products.

CEFS, the European Association of Sugar Manufacturers, represents at once an agricultural and an industrial sector. Beet sugar manufacturing is characterised by high energy- and trade-intensity, making it a carbon leakage sector under the EU Emissions Trading System (ETS). Sugar is the second largest energy user and the second largest CO2 emitter within the agri-food sector (after animal feed).

CEFS, the European Association of Sugar Manufacturers, recognises the urgent need to quickly and significantly reduce Greenhouse Gas (GHG) emissions to counter the rise in global temperatures, which risks huge impacts on people, biodiversity, the environment, and food production.

CEFS, the European Association of Sugar Manufacturers, would like to take the opportunity of this call for evidence to comment on Directive 96/53/EC. In particular, we would like to highlight an issue regarding cross-border transport.

CEFS welcomes the European Commissions Environmental Omnibus initiative to reduce administrative burdens in environmental legislation. The objectives of simplifying requirements and improving regulatory efficiency are essential to ensure that the EU environmental policy remains both effective and implementable for industrial operators.

CEFS, the European Association of Sugar Manufacturers, represents at once an agricultural and an industrial sector. Beet sugar manufacturing is characterised by high energy- and trade-intensity, making it a carbon leakage sector under the EU Emissions Trading System (ETS). Sugar is the second largest energy user and the second largest CO2 emitter within the agri-food sector (after animal feed).

CEFS, the European Association of Sugar Manufacturers, represents at once an agricultural and an industrial sector. Beet sugar manufacturing is characterised by high energy- and trade-intensity, making it a carbon leakage sector under the EU Emissions Trading System (ETS). Sugar is the second largest energy user and the second largest CO2 emitter within the agri-food sector (after animal feed).

FULL SUBMISSION IN ATTACHMENT CEFS, representing EU sugar manufacturers, takes note of the draft Delegated Directive proposing amendments to Annexes V and VI to the Renewable Energy Directive (RED). Annex V Part C, Point 11 First, CEFS supports a technical correction in point 11 of Part C, where the reference to solid or gaseous biomass fuel should be corrected to biofuel, in line with the scope and terminology of…

In the sugar manufacturing sector, the heat and electricity required to produce beet sugar is generally provided by high efficiency Combined Heat and Power (CHP) systems. This form of self-supply is necessary in view of the deficit network situation in rural areas, and to ensure security of supply during the production campaign.

SUMMARY CEFS consistent position is to maintain unchanged the current and longstanding provisions on contractualisation in Art. 125 and Annex X of the Single CMO Regulation, which take into account the unique specificities of the sugar sector and its contractualisation practices in a balanced and effective way.

CEFS, representing EU sugar manufacturers, would like to take the opportunity of this consultation to comment on Directive 96/53/EC. While we understand that this consultation deals with the codification of this directive, we would like to highlight an issue regarding cross-border transport.

CEFS, the European Association of Sugar Manufacturers, represents at once an agricultural and an industrial sector. Beet sugar manufacturing is characterised by high energy- and trade-intensity, making it a carbon leakage sector under the EU Emissions Trading System (ETS). Sugar is the second largest energy user and the second largest CO2 emitter within the agri-food sector (after animal feed).

CEFS welcomes the new legislative proposal for the new EU’s Generalised Scheme of Preferences (GSP) for the period 2024-2034 adopted by the Commission on 22 September 2021. In our assessment, the proposal moves to the right direction, especially when it comes to the introduction of more international conventions to be respected/ratified by the beneficiaries as well as to the introduction of a rapid withdrawal…

The current GSP provides sufficient support to LDCs and developing countries. The safeguard provisions must be effective, i.e. the Commission should be able to react in a timely manner. The respect of the conventions on labour and human rights, environment and governance principles need to be better monitored. In case of violation the COM should be able to take immediate steps to withdraw tariff preferences.