Danish Agriculture and Food Council

Dato Side 20. april 2023 1 af 7 European Commission Proposal for a regulation on packaging and packaging waste regulation Commission adoption feedback Landbrug & Fødevarers høringssvar til udkast til Europa-Kommissionens forslag om regulering af emballage og emballageaffald. Kommissionen har udbedt kommentarer til et fremlagt forslag til regulering af emballage og emballageaffald.

Filed in Danish · English published by the European Commission

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

We would like to thank the European Commission for its work and for the opportunity to comment on the proposed amendments to Regulation (EU) 2018/848. We support the proposals and wish to see them implemented as swiftly as possible.

We thank the Commission for opening the possibility to amend specific but important aspects of organic production through adjustments to the basic act. Below are eight areas where targeted changes can improve animal welfare, legal clarity, and economic viability. Further details are provided in the attached document. 1.

The Danish Agriculture and Food Council welcomes this initiative from the Commission. It is important to point out that much more should be done to secure and reuse the valuable resource in organic waste and in biomass in general. We support the ECN's considerations and proposals for this consultation, which were submitted on 10 October.

The Danish Agriculture and Food Council (DAFC) welcomes the revised ESRS and acknowledges several important improvements. In particular, the significant reduction in datapoints is an important step towards lowering reporting complexity. The standards are also clearer and more accessible, improving their usability in practice.

Side 1 af 2 European Climate Law The Danish Agriculture & Food Council (DACF) welcomes the Commission’s European Climate Law initiative. The DAFC supports a climate-neutral EU by 2050 and look forward to the Commission’s presentation of the plan. In Denmark it has already been decided to reach net-zero emissions by 2050 and we strongly urge the EU to follow suit.

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

The Danish Agriculture & Food Council (DAFC) supports the Commission's focus on food waste and aims for a reduction in quantities at the EU level. This is necessary to meet the ambitions of the UN Sustainable Development Goal 12.3, which aims for a 50% reduction in food waste in households, retail, and food service sectors, as well as reduction throughout the rest of the chain.

Sustaiable Corporate Governance 23 May 2022 Reply on the EU Commission’s proposed directive on Corporate Sustainability Due Diligence from the Danish Agriculture and Food Council The Danish Agriculture and Food Council (DAFC) welcomes the Commission’s initiative to improve the regulatory framework for EU companies to manage sustainability matters in regards of human rights and climate change.

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

Feedback to EU-Commission regarding certification of carbon removals The Danish Agriculture and Food Council (DAFC) welcomes the possibility to contribute to the hearing on certification of carbon removals. The DAFC acknowledges that carbon removals cannot replace emission reductions but is an additional tool that can be used to reduce (biological) emissions in the agricultural sector.

The Danish Agriculture and Food Council (DAFC) welcomes the proposal for the Directive on Green Claims from the European Commission. DAFC sees a significant need for harmonized, reliable, and transparent requirements for communicating green claims in the European market, including harmonized calculation methods.

Comments on public consultation on Legislative proposal on Substances ating green claims: The Danish Agriculture and Food Council thanks the Commission for involving the public and relevant stakeholders in the development of a framework for green claims. We are representing the entire Danish food cluster from farm to fork and are actively working to develop the sector in a more sustainable direction.

Filed in Danish · English published by the European Commission

Updating the Emission Trading System Opinion of the Danish Agriculture & Food Council The Danish Agriculture & Food council (DAFC) welcomes the Commission’s effort on climate action and supports the joint work on the 2030-climate target as well as the objective of climate neutrality in 2050. DAFC urges the Commission to pursue cost-effective CO2-reductions such as reductions within the ETS.

General comments The Danish Agriculture & Food Council agrees with the need to update the Energy Taxation Directive. The current rates in the Directive are not balanced according to energy or CO2 content, and in some cases the Directive affects RES more heavily than fossil fuels. It does not contribute to the green transition.

Filed in Danish · English published by the European Commission

The Danish Agricultural and Food Council (DAFC) represent the whole value chain from plant breeders to farmers and producers of food, feed and nonfood products including organic producers. DAFC highly welcome the Commission proposal for future regulation of plants and products from these developed by new plant breeding methods within the NGT 1 category.

Danish Agriculture & Food Council welcomes a simple, predictable, science-based, and fully harmonized NGT-1 verification regarding the Regulation (EU) 2026/1388 on plants produced by certain new genomic techniques (NGTs). It is expected that the number of NGT-1 varieties will grow as soon as the implementation period is over in 2028.

Feedback from The Danish Agriculture & Food Council. DAFC represents the farming and food industries of Denmark including companies, trade and farmers’ associations. Please find below a short summery in English of our feedback in Danish (attached).

Overall, the roadmap addresses the most important overall issues like circular economy, better BREF process and implementation issues. Below we have listed elements that we think needs to be taken into consideration in the assessment. BREF process In the work on the BREF process we would like to have more focus in innovation. The current approach is too focused on end-of-pipe solutions.

Danish Agriculture & Food Council support the development of European harmonized rules for all FCM. Further harmonization and a clear and consistent regulatory framework will lead to a better functioning internal EU market, more transparence, decreased compliance costs, and increased safety for European consumers.

The Danish Agriculture & Food Council (DAFC) welcomes the EUs environmental omni-bus and is broadly positive about the simplification proposals affecting agriculture and the food industry. However, the package should have gone further.

While we welcome the harmonised approach and the fuel exemption principle established in the draft Implementing Act, we note that certain provisions may create unnecessary administrative burdens for economic operators. For instance, recital (3) could better reflect the inclusion of novel recycling technologies alongside mechanical PET recycling and closed-loop processes, as acknowledged elsewhere in the draft.

The Danish AgriFish Agency has the following comments on the rules for calculating, verifying and reporting genaxible plastic content: Recital 10 It is essential that controlled blending and mass balance principles are included in a future review so that new technologies can come into play, such as non-mechanical recycling.

Filed in Danish · 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.

The Danish Agriculture & Food Council (DAFC) welcomes the European Commission's initiative to establish a combined Water Resilience Research and Innovation Strategy. Overall, we would like to highlight the following issues that should be addressed: * Holistic approach and turning knowledge into action * Water resilience must be linked to food security and climate adaptation * Strengthening partnerships across…

The DAFC support the strong focus on carbon removals as part of the EU’s enhanced climate ambition since it constitutes an important step towards the climate target for 2030 and 2050. With the revision of the LULUCF regulation the Commission proposes to incentivize carbon removals through certification of carbon removals in the period until 2030.

The Danish Agriculture & Food council (DAFC) welcomes the Commission’s effort on climate action and supports the joint work on the 2030-climate target as well as the objective of climate neutrality in 2050. DAFC urges the Commission to pursue cost-effective CO2-reductions such as reductions within the emission trading system.

DAFC represents the farming and food industry of DK including companies, traders and farmers. We are disappointed that the proposal has been prepared without prior impact analysis and without considering the needs of the sectors in the individual countries. We rejects the Commission's proposal for targeted changes to the sCMO for Art. 148 and 168.

The Danish Agriculture & Food Council (DAFC) represents the entire Danish agriculture and food sector, including over 30,000 farmers and around 300 companies across the value chain. DAFC supports free price formation, market orientation, and places strong emphasis on strengthening farmers position.

“DAFC supports the EU-Commission’s objective to help counter deforestation, loss of biodiversity violations to human rights and greenhouse gas emissions. We realize that part of the soy production might take place in areas with non-negligible deforestation risk, placing soy as a forest risk commodity.

We support the proposal to extend the derogation allowing the use of up to 5% non-organic protein feed for young monogastric animals. In our experience, an appropriate amino acid composition is particularly important for the health, welfare, and development of piglets and young Gallus gallus poultry. At present, the supply of suitable organic protein sources is insufficient to meet these nutritional requirements.

Danish Agriculture & Food Council (DAFC) consider data collection in the framework of FADN as being essential for assessing the economic situation of EU farms and for monitoring and evaluating the impact of policies and measures implemented. For this, a harmonized framework, comparable, timely and reliable data is key. DAFC recommends keeping the economic dimension as a predominant feature of FSDN.

Today, data are provided in a wide range of areas, both at national and EU level, such as ifm. NEC, EUROSTAT, climate data, etc. An essential element of the evaluation should therefore take into account the fact that a wide range of requested data can be found in more or less detailed data in other registers.

Filed in Danish · English published by the European Commission

The AgriFish Agency estimates that the political agreement on a minimum global taxation could become a strong foundation for coherent international rules, of which the 137 countries can be proud. This can ensure a more level playing field for many Danish export-oriented companies.

Filed in Danish · English published by the European Commission