FoodDrinkEurope

FoodDrinkEurope welcomes the opportunity to comment on the draft implementing act establishing a harmonised format for national producer registers under Article 44 of Regulation (EU) 2025/40 (PPWR). FoodDrinkEurope believes that the implementing act on rules on national registers of producers under PPWR should contribute to reducing administrative burdens, improving legal certainty, and enabling efficient…

FoodDrinkEurope supports the European Commissions ambition to create a single market for secondary raw material by exploring opportunities for harmonization, incentives for uptake and assessing how waste management practices can be improved.

FoodDrinkEurope supports the general objectives set in the new Packaging and Packaging Waste Regulation (PPWR) of ensuring a well-functioning Internal Market through fully harmonised rules on packaging while tackling the packaging environmental impact.

Please refer to the document in the Annex for the full FoodDrinkEurope contribution to the Packaging and Packaging Waste Directive Inception Impact Assessment. The end goals of the future PPWD and the new Circular Economy Action Plan (CEAP) should be to reduce and limit the environmental footprint of the life cycle of providing products to the end consumer and ensure that no packaging waste ends up into the…

The food and drink industry welcomes the Commission’s proposal for a European climate law which was published on 4 March. The enshrinement of the 2050 climate neutrality goal in legislation and the holistic view taken by the Commission in the context of the European Green Deal will help engage all economic actors collectively in a common trajectory and encourage the swifter development of enabling conditions.

Climate change has an impact on food systems, whether directly or indirectly. It can have an impact on food security, food prices, and the quality and safety of food products. In particular, extreme weather events, such as droughts and floods or rising temperatures, hamper food production, which may affect the long-term supply of safe, high-quality and affordable raw materials for the food and drink sector.

FoodDrinkEurope views on EU food waste reduction targets set for food manufacturers under the EC revision of the Waste Framework Directive According to the latest estimates, in the EU, nearly 59 million tonnes of food waste (131 kg per inhabitant) are generated annually with an associated market value estimated at €132 billion euros1.

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

FoodDrinkEurope welcomes the initiative to review the Waste Framework Directive to further decrease waste generation and improve waste collection. To achieve these objectives, a combination of policy options should be considered to ensure an effective implementation of specific waste stream policies under revision, specially the packaging waste directive and specific targets on food waste.

Food waste is a missed opportunity to feed the growing world population, a major waste of resources and a needless source of emissions. The food and drink industry is committed to contributing to the implementation of UN Sustainable Development Goal (SDG) 12.3 which targets to halve per capita food waste at the retail and consumer level by 2030, and reduce food losses along the food production and supply chains.

STATEMENT Ref. Ares(2022)3876204 - 23/05/2022 FoodDrinkEurope views on the European Commission Proposal for a Directive on Corporate Sustainability Due Diligence Today, we are faced with growing global challenges such as climate change, environmental degradation, biodiversity loss and malnutrition.

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

FoodDrinkEurope welcomes and provides the attached feedback to the European Commissions proposal for a regulation establishing a Union certification framework for carbon removals. 1. The proposal must clarify the intended use of certificates and prioritise the agri-food chain decarbonisation for removals generated by carbon farming.

COMP/AGPO/023/22EFinal FoodDrinkEurope contribution to the public consultation on EU rules for a certification of carbon removals 1. General views FoodDrinkEurope strongly supports the European Union (EU) commitment to reaching netzero emissions by 2050, and as part of this target, to achieve a 55% reduction in emissions by 2030.

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

Annex 1 to ENVI/ENV-INFO/012/23E- FoodDrinkEurope position on the proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive) FoodDrinkEurope welcomes the European Commission’s proposal for a Green Claims Directive (GCD).

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

Methodology FoodDrinkEurope supports a credible and EU-harmonized environmental footprint methodology based on PEF. The harmonized PEF methodology should be the basis for identifying hotspots, promoting continuous improvement and provide product information to other businesses or consumers.

FoodDrinkEurope welcomes the European Commissions proposal for a European Biotech Act aimed at strengthening the Unions biotechnology and biomanufacturing ecosystem and facilitating the translation of innovation into marketable products.

FoodDrinkEurope welcomes the European Commissions initiative to develop a new Biotech Act and appreciates the opportunity to provide input to this call for evidence. We strongly support efforts to accelerate the transition from research to market for biotechnological innovations, particularly within the food and drink manufacturing sector, which plays a vital role in building more sustainable and resilient food…

FoodDrinkEurope position on the ‘Revision of EU legislation on hazard classification, labelling and packaging of chemicals’ Inception Impact Assessment FoodDrinkEurope is the organization representing Europe’s food and drink industry, composed of 294,000 businesses and 4.7 million workers and Europe’s largest manufacturing industry.

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

FoodDrinkEurope welcomes the European Commissions Call for Evidence on the upcoming European Biotech Act II and supports the objective of establishing an enabling EU framework for industrial biotechnology and biomanufacturing. The European food and drink industry is Europes largest manufacturing sector and a key actor in the biotechnology and biomanufacturing landscape.

FoodDrinkEurope represents the food and drink manufacturing industry, made up of 294,000 businesses, of which 99% are SMEs, with 4.6 million employees. Innovation in plant breeding is a key driver in delivering more sustainable and resilient crops, more secure harvests, and safe ingredients and food products.

FoodDrinkEurope welcomes the opportunity to contribute to the European Commissions evaluation of Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment (Single-Use Plastics Directive - SUPD). The SUPD represents an important step in addressing marine litter and supporting the EUs transition towards a circular economy.

STATEMENT Ref. Ares(2022)4617009 - 23/06/2022 FoodDrinkEurope views on the European Commission Proposal for a Revision of the Industrial Emissions Directive There is an urgent need to reduce greenhouse gas emissions significantly, and rapidly, to prevent a rise in global temperatures with devastating impacts on people, biodiversity, the environment, and our food production.

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

FoodDrinkEurope feedback to European Commission Inception Impact Assessment on the Revision of the Industrial Emissions Directive FoodDrinkEurope has cooperated with the European Commission in the 2019 Evaluation of the IED.

FoodDrinkEurope, the organisation representing Europe’s food and drink industry, welcomes the opportunity to contribute to the Inception Impact Assessment on the Revision of the EU rules on Food Contact Materials. Please find attached FoodDrinkEurope's detailed response to the Inception Impact Assessment.

FoodDrinkEurope appreciates the opportunity to contribute to the public consultation on the Delegated Regulation amending Annex I of the EU Deforestation Regulation. Please find attached FoodDrinkEurope's feedback, notably the request for clarification on certain specific provisions and the consideration of several key recommendations.

On behalf of FoodDrinkEurope, we would like to thank the European Commission for the opportunity to provide additional feedback on the legislative proposals included in the Environmental Omnibus. Please find FoodDrinkEurope's detailed input in the document attached. Our input focuses on the proposal COM (2025) 986 amending Directive 2010/75/EU on industrial and livestock rearing emissions.

FoodDrinkEurope welcomes the European Commissions initiative to develop a high-integrity, science-based framework for nature credits. We regard this as a crucial step towards closing the biodiversity finance gap, mobilising private investment, and ensuring that restoration and conservation efforts are credibly rewarded.

FoodDrinkEurope welcomes the European Commissions draft Implementing Act on harmonised rules to calculate, verify, and report the share of recycled plastic in single-use plastic (SUP) beverage bottles. We support its adoption by Q4 2025, as it will provide legal clarity, support investment, and scale up recycling technologies crucial for the food and drink sector.

FoodDrinkEurope supports increasing the use of high-quality post-consumer recycled plastic (PCR) in packaging and developing a strong EU market for secondary raw materials. For food and drink packaging, Article 7 PPWR must be implemented in a way that safeguards food safety, product quality, shelf life and food waste prevention, while remaining technically feasible and enforceable across global supply chains.

FoodDrinkEuropes input to the Call for Evidence on the Electrification Action Plan FoodDrinkEurope is the umbrella organisation representing Europes food and drink industry, Europes largest manufacturing sector in terms of turnover, employment and value added.

The European food and drink sector supports the Green Deal ambitions to make Europe the first climate-neutral continent by 2050 and to move towards more sustainable production and consumption. Consumers play a key role in this transition.

FoodDrinkEurope supports this initiative, and we ask the Commission that the envisioned actions are developed in such a matter that an open and common collection of chemicals-related data for use in assessments of the safety of chemicals can warrantee the development of clear, standardised approaches/protocols on the use and access of data for hazard and risk assessments.

FoodDrinkEurope supports the principle of strengthening farmers position in the supply chain and takes note of the proposal for targeted amendments to the CMO. The food and drink manufacturing sector comprises more than 300,000 businesses, with nine out of ten employing fewer than 20 people.

FoodDrinkEurope welcomes the revision of the Unfair Trading Practices (UTPs) Directive in the food chain. FoodDrinkEuropes State of the Industry 2026 survey signals a broad weakening of optimism across the food and drink industry with only 13% of companies reporting improved business conditions over the past year.

FoodDrinkEurope represents the food manufacturing industry. Made up of 294,000 businesses and 4.7 million workers, the food and drink industry buys 70% of all EU agricultural produce and is Europe’s largest manufacturing industry.

FoodDrinkEurope welcomes the Commission's roadmap/Inception impact assessment on 'Minimising the risk of deforestation and forest degradation associated with products placed on the EU market’ as an integral part of the EU Green Deal mainstreaming biodiversity and resource efficiency with climate objectives, thus contributing to the implementation of the UN 2030 Agenda for Sustainable Development (SDGs), alongside…

Thank you for the opportunity to contribute, please find FoodDrinkEuropes feedback attached. Our contribution addresses Question 2 (EU added value of the CAP) and Question 3 (continued relevance of the CAP in addressing current and emerging challenges), reflecting the perspective of the EU food and drink manufacturing sector as a key stakeholder in the agri-food value chain.

FoodDrinkEurope represents Europe’s food and drink industry, Europe’s largest manufacturing sector in terms of turnover, employment and value added. Firstly in is relevant to highlight that Food and drink products are already covered or have been recently assessed under a large number of European Policies cited in the roadmap: • Product Environmental Footprint (PEF) and Organisation Environmental Footprint (OEF)…

FoodDrinkEurope, representing Europes food and drink industry, welcomes the start of the evaluation process of the Directive (EU) 2019/633 on unfair trading practices (UTPs) in business-to-business relationships in the agricultural and food supply chain, and the opportunity to provide feedback.

FoodDrinkEurope welcomes the opportunity to share its views on the European Commission’s initiative for a Single Market Emergency Instrument (SMEI). We support the Commission’s ambition to create an instrument to ensure the free movement of persons, goods and services, as well as greater transparency and coordination in times of crisis.

FoodDrinkEurope, representing the EU food and drink industries, welcomes and supports the European Commissions proposed Regulation to enhance cross-border enforcement against unfair trading practices (UTPs) in the EU.