Cogeca

Ref. CCC(23)[phone removed].3.2023 Copa-Cogeca feedback: Packaging and Packaging Waste Regulation 2022/0396(COD) Introduction In view of the publication of the Commission’s proposal for the Packaging and Packaging Waste Regulation, Copa and Cogeca – who represent 22 million farmers and their families, and over 22,000 cooperatives – would like to express their concerns as regards some of the extremely ambitious…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Copa and Cogeca represent 22 million farmers and their family members as well as 22000 cooperatives that are dedicated to providing 446 million EU citizens with safe, nutritious, high-quality and affordable food every day. Farmers, forest owners and their cooperatives are committed to the Paris Agreement and to contributing to the Sustainable Development Goals.

European farmers, forest owners and their cooperatives are the first to feel the impact of climate change. 22 million farmers and their family members and 23 000 agri-cooperatives are committed to the implementation of the Paris Agreement and support it as an essential part of the European and international political agenda.

Cogeca welcomes the Commissions efforts to create a unified and harmonized system across the EU, capable of providing a reliable and trustworthy system to promote a further uptake of carbon farming activities. Agri-cooperatives are part of the solution to fight climate change through storing carbon in the soil and biomass.

Agriculture and forestry production is one of the key instruments to reach the European climate targets in 2030. However, to control the delicate balance between climate change and agricultural and forest production, agro-environmental and economic parameters must be considered throughout the whole farming system – ensuring that our transition to a greener business model does meet consumers’ demands, farmers, and…

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.

NGT-1 verification should therefore be simple, science-based, predictable, low-cost and fully harmonised across the EU. Regulation should not create unnecessary barriers that reduce farmers access to new varieties or increase seed costs. Verification costs must remain proportionate, particularly as the number of NGT-1 applications is expected to grow.

The EU Directive 2010/75 EU pursues the goal of enforcing the same level of environmental protection at a similar technological level throughout Europe. In accordance with this Directive, the EU Commission adopted Commission Implementing Decision (EU) 2017/302 of 15 February 2017 establishing BAT conclusions of the BREF documents as binding guidelines for livestock installations in the field of pig and poultry…

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 are the united voice of farmers and agri-cooperatives in the EU. Together, we represent over 22 million farmers and their family members, as well as the interests of 22 000 agri-cooperatives. Farmers, forest owners and their cooperatives are the first to feel the impact of climate change. We are committed to the Paris Agreement and contributing to the Sustainable Development Goals.

Copa and Cogeca are the united voice of farmers and agri-cooperatives in the EU. Together we represent over 22 million farmers and their family members and the interests of 22.000 agri-cooperatives. Copa and Cogeca understand the importance of the problems that European Commission is trying to tackle with this initiative.

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 and Cogeca representing farmers and agricultural cooperatives all across the EU have been favourable to this Directive from the beginning even if in some aspects it could have gone further in protecting and defending the weakest links in the agri-food chain.

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.