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9
positions filed
in the 665 files tracked
3
legislative files
of 665 tracked
1
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,800 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Landwirt filed 9 positions between 20 Jan 2021 and 17 Nov 2025, across 3 of the 665 legislative files tracked here, attaching a full position paper 1 time.
90 % of the open-air areas of organic pigs should remain covered. As 50 % of the open roof area is a reasonable assumption for pigs and farmers (rain, snow, fog and permanent wet open-air areas), it would be a huge additional workload for the farmer. (Sun and heat) stress for pigs and the risk of sunburn.
Filed in German · English published by the European Commission
The grazing regulation from month 4 onwards is particularly problematic for me and many other holdings, as these animals are mostly kept without direct access to grazing areas because they often still receive milk and are kept close to the dairy chamber. In addition, organic holdings are still to be regarded as organic even though they cannot comply with the Grazing Regulation.
Filed in German · English published by the European Commission
Minimum total area and functional areas instead of minimum indoor area and minimum outdoor climate area! Themes: EU Implementing Regulation 2020/464 laying down detailed rules for the application of Regulation (EU) 2018/848, Annex I, Part III, specifies stocking densities, minimum indoor areas and minimum outdoor areas for pigs referred to in Article 10.
Filed in German · English published by the European Commission
Full grazing is hardly feasible for most farms. The Regulation should therefore be designed in such a way that it remains workable for both animals, farms and humans. We are a suckler cow holding with bull and heifer fattening, where the suckler cows and calves are on the pasture from spring to winter. The animals can decide on a daily basis whether they go to pasture or prefer to stay in the house.
Filed in German · English published by the European Commission
Dear Sir/Madam, my feedback relates to the subject of ‘grazing requirements for organic farms’. In this connection, I can once again urge you to withdraw the grazing obligation that goes beyond practice, or at most to limit it to one animal group per holding. A full grazing obligation for all animal groups would mean up to 70 % of dairy farms in Germany!
Filed in German · English published by the European Commission
The free trade agreements do not play a role in European agriculture against imports. Food is allowed to balance trade equilibrium. And the LEH uses the cheap imports to depress the price of European products — see currently meat and milk (butter).
Filed in German · English published by the European Commission
Free trade agreements are beneficial for the economy as a whole. But it must be remembered that European agriculture is not played out by the ‘abundance’ of the import vo LEH. See currently the discount stores in Germany with meat and milk.
Filed in German · English published by the European Commission
The Nitrates Directive cannot be replaced. This is cutting red tape. Because fertiliser prices are very much higher, in any event, no longer excessive. And if the rules are reduced, organic fertilisers can also be used/exchanged more effectively. Throughout the system, other nitrate sources are completely neglected.
Filed in German · English published by the European Commission
In the view of the Bavarian Farmers’ Association, a revision of the nitrates directive is overdue. The goal of clean groundwater and surface waters must be kept in mind, but much more flexible and practicable regulations must be found regionally.
Filed in German · English published by the European Commission
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