Cogeca

COPA and COGECA are the two main umbrella organizations representing farmers and agricultural cooperatives at the European Union level. A key concern is that farmers could become subject to direct or indirect mandatory obligations to use bio-based fertilisers, while having limited ability to recover the resulting additional costs. Agricultural markets are highly competitive, and farmers are generally price takers.

Copa and Cogeca represent th European farmers and Agri-Food Cooperatives. We would like to reiterate our comments on the revision of the Climate Delegated Act (CDA), which have not been sufficiently reflected in the current draft Delegated Regulation.

The disaggregated default values in Annex V, Part D play a central role in the RED GHG accounting framework by forming the basis for compliance calculations in the absence of actual data. The draft exhibits multiple material inconsistencies and apparent calculation errors, which significantly affect the accuracy and credibility of the methodology and must be addressed without delay.

Copa and Cogeca welcome the approach as such and the specific draft Annex III to the Nitrates Directive, with the aim to reduce dependence on imported commercial fertilisers or fertilisers produced in Europe at high energy costs by making widespread use of so-called RENURE fertilisers, i.e., fertilisers obtained from the processing of farm manure and comparable to synthetic fertilisers.

Copa and Cogeca represent the European farmers and their agri-food cooperatives. We call on the Commission to suspend the draft delegated regulation on Union Data Base for biofuels and biogas. We fear the lack of workability of the implementation of the UDB the efficiency of the database to check physically whether a certificate was legitimately issued the use of data from farmers and the data protection the…

Copa and Cogeca welcome regular evaluation of the Common Plant Variety Right (CPVO). Copa and Cogeca are strong advocates for Community Plant Variety Rights (CPVR), recognising the CPVR system as a significant advancement that has greatly benefited the plant breeding sector in Europe. Currently, breeders in Europe develop around 3,000 new varieties each year, demonstrating the success of this system.

We welcome the proposed amendments to Annex II (CMC 10) and Annex III of Regulation (EU) 2019/1009. The inclusion of additional derived productssuch as processed frass, glycerine from Category 2 and 3 materials, processed animal protein, meat-and-bone meal, blood products from Category 3, hydrolysed protein, dicalcium and tricalcium phosphate, as well as horn- and hoof-derived materialsrepresents a positive step…

Copa-Cogeca supports the proposed amendments in principle, as they bring useful flexibility and can help address staff shortages while maintaining safety standards. We welcome the use of remote inspection, trained inspection staff, and new technologies, provided these are properly validated, supervised, and implemented with clear safeguards.