Position Papers

We, the undersigned organisations, are active in preparing for the implementation of the EU Deforestation Regulation (EUDR) with our member companies and across our respective supply chains. As part of our commitment to support a successful implementation of this regulation,considering the significant adjustments that are needed from suppliers, operators and traders, we would like to express serious concerns regarding the pace of preparation of EUDR-related legislative acts, the mandatory systems (i.e. Information System), and the guidance and clarifications required for implementation by operators and traders and enforcement by competent authorities.

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COCERAL, UNISTOCK, and EUROMALT acknowledge the ongoing technical and political debate in the EU on managing residues of Plant Protection Products in food and feed, in a way that is safe for human and animal health, and respectful for the environment. At a time of severe trade disruptions, climate change, pest pressure, and geopolitical uncertainty, it is relevant to frame the debate in a non-ideological way, considering all available methods to protect crops and related products along all stages of cultivation, storage, and transformation, to ensure food security.

In particular, COCERAL, UNISTOCK, and EUROMALT welcome harmonized measures that reflect the agricultural needs of the EU Member States and third-export countries and can favor international cooperation, underpinned by a rules-based order established in science. With crop protection considerably moving to greener and more sustainable alternatives, including low-risk substances, biological tools, agroecology, and Integrated Pest Management, it is relevant to maintain the options the farming community needs to grow crops and feed the planet.

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COCERAL, UNISTOCK Europe and EUROMALT, welcome the intention of the EU Commission to ensure a high level of human health protection against possible contamination of food by Mineral Oil Aromatic Hydrocarbons (MOAH), as proposed in the draft SANTE PLAN 2023/2345 Rev.1, and its annex.
However, COCERAL, UNISTOCK Europe and EUROMALT are not in favour of the two suggested options, which:
• opens the door to set maximum levels of MOAH in some food categories or all foods (with some exceptions), including the raw ingredients and products listed in footnote1
• keeps the previous categorization from the SCoPAFF enforcement levels, based on fat percentage.

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Brussels/Washington – 7 December 2023
With less than a month before the reimposition of tariffs in the U.S.-EU steel and aluminium dispute on 1 January 2024, 87 sectors unrelated to the EU-U.S. steel and aluminium and the large aircraft disputes urge U.S. and EU leaders to reach an agreement to permanently remove all retaliatory tariffs on products unrelated to these disputes. The prospect of the return and increase of retaliatory tariffs in the steel and aluminum dispute, barely a month away, is causing unbearable uncertainty and instability for unrelated sectors.

COCERAL, FEDIOL and FEFAC welcome a balanced proposal that acknowledges the potential of NGTs to contribute to the transition to more sustainable food systems, in line with societal expectations and the Green Deal strategy, including the Farm to Fork objectives. At the same time, attention should be paid to avoid trade disruption and preserve farmers and other operators of the feed and food chain from misuse of certain provisions (labelling, coexistence) in a way that would make production, use, and trade of NGT products hardly possible.

European business remains supportive of the objectives of the proposed directive on corporate sustainability due diligence (CS3D) and we urge co-legislators to work on a reasonable approach that is manageable for companies in practice. The European economy, including SMEs which will be impacted even if formally out of the scope, need a workable due diligence framework that is drafted in a balanced and proportionate way. There should be no room for legal uncertainty and fragmentation which will hamper the possibility for European companies, already facing a legally complex and crisis abundant environment, to contribute to the sustainability transition

COCERAL has recently gave support and perspectives on a joint, multi-stakeholder letter (31 partners), regarding the upcoming framework legislation for Sustainable Food Systems (SFS).

Among the concerns raised in the letter:

• the vagueness of the legislation aim, according to the info shared so far by the Commission. Definitions are welcome, but principles and objectives are not clear. Constructive collaboration is welcome.
• Policy coherence and interdisciplinary approach are not always present.
• Availability and affordability of food (how to solve the trade-off between food sustainability and food security) must form part of the framework.
• Global world and international aspects of trade – the legislation must fly at the international level.

The letter was also discussed during the Advisory Group on Sustainable Food Systems (AGSFS) on 12 May, at the DG SANTE premises,  with the Commission Officials in charge  for Food Sustainability. On this occasion, the Commission made clear that the regulatory framework for SFS will follow the General Food Law on Food Safety (Reg. (EU) 178/2002) blueprint,  with a general legislation and then more detailed implementing regulations to come.

In terms of regulatory timeline on a legislative Framework for Sustainable Food Systems, as per the “Farm to Fork” Strategy Action Plan:

-              The Impact Assessment is ongoing, after a negative opinion from the Regulatory Scrutiny Board- this however will not require additional (research of) data.

-              There are gaps of the law in particular on the internal market dimension. Whenever national legislations have emerged in the meantime, they must be put under the EU framework.

-              Definitions will be there along with Principles that should guide the revision of topical sectoral legislations.

-              Meeting with stakeholders will be scheduled at a later stage, to get input on the legal proposal (possibly, end of June)

-              The Regulation will be published in September.

Coceral has participated in the Impact assessment study of the Commission, and has stressed since the beginning the need to work on policy coherence at the international level.

Coceral, in a joint statement with 20 stakeholders active at the EU level, has delivered a letter on the evolutionary legislation on New Genomic Techniques. The new legislative framework is expected to be unveiled in late June, according to the latest information available, and some political choices must still be made, including on traceability and transparency of “conventional-like” NGTs.

In our perspective, it is important not imposing traceability, labelling, and coexistence measures  that place specific obligations on farmers growing conventional-like NGT varieties. This is  specifically important in the global context, considering the trade-related challenges that might  arise in case the EU's approach would not align with the enabling policies increasingly being adopted by Europe’s trade partners.

In addition, Imposing extra-requirements (traceability, segregation and labelling) to conventional-like NGTs products would be discriminatory, not proportionate and not science-based.

Eventually in a market-oriented, consumer-driven food value chain, freedom of choice means that legitimate production choices have economic consequences, i.e., food business operators have to bear the costs for the benefits they (can) get:  transparency, traceability and segregation should reflect this baseline principle. This assumption, so far has well governed the relationship between conventional and premium price/niche markets, including the organic sector, and should remain in place.

In a concerted effort at the Brussels level, some 17 stakeholders have stressed some inconsistencies of the current Commission’s proposal on the Sustainable Use of Pesticides Regulation.

The AgriFood Chain Round Table stakeholders ask to have a thorough impact assessment, and also to deliver alternatives to PPPs before asking rigid reduction targets.

Our organisations represent European industry sectors trading, using and processing agri-food products as palm oil, coffee, soy, livestock and meat. We would like to express our views regarding the ongoing negotiations on a regulatory framework for deforestation-free supply chains (Regulation (EU) No 2021/0366).

Emissions reduction: the fuel is more important than the engine.

COCERAL, FEDIOL and FEFAC agree on the need for the EU to take a leading role in the global fight against deforestation. EU actions can provide an important contribution towards reducing or halting deforestation, provided a comprehensive set of smart tools is set up and it is acknowledged that no one-size-fits-all approach will work across all commodities. The way we design the different requirements and how those will either support or hamper the EU engagement with producer countries will be critical to avoid or mitigate unintended consequences. It can only work hand in hand with building partnerships with producer countries and company engagement on the ground with farmers, local communities and authorities.

In order to effectively tackle global deforestation, the EU’s toolbox should be based on the use of a clearly defined due diligence system which this paper helps design further.

The agribulk commodities trade sector plays an important role in maintaining food security in the EU, by moving agricultural commodities from areas of surplus to areas of deficit in an efficient way. Thanks to its position in the EU supply chain, COCERAL and its members balance the different requests of the food, feed and non-food markets, from the farmers, processing industry and the consumers through the retailers’ demands. Our businesses thrive on seamless supply chains, which need clarity, predictability and clear regulatory regimes in order to avoid disruption.

Through this short position paper, COCERAL would like to highlight important concepts for a successful EU Agricultural sector and Common Agricultural Policy (CAP).

A ‘smart mix’ of measures by the EU is necessary to help tackle the negative impacts on forests associated with the production of forest risk  commodities.

This is the conclusion of a large and growing group of companies from across the supply chain, and NGOs, that participated in the Tropical Forest  Alliance’s series of roundtable discussions on action to protect forests held between April and July 2020.

We recognise the role of the EU, as one of the world’s largest importers and consumers of almost all the major forest risk commodities, in driving deforestation. We applaud the publication, in July 2019, of the European Commission’s communication on ‘Stepping up EU Action to Protect and Restore the World’s Forests’, and we welcome the opportunity to contribute to the impact assessment of demand-side measures currently under way. We look forward to the publication of proposals for an ambitious smart mix of measures at the conclusion of this exercise. 

COCERAL, FEDIOL and FEFAC welcome the possibility to provide views on the public consultation on a “Deforestation and Forest Products Impact Assessment” launched by the European Commission. Our associations – representing the EU grain and oilseed trade, crushing and feed industry – acknowledge the responsibility they have for the sustainable production of commodities that they trade or process.

Since 1973, trade relations led to the creation of multi-layered, efficient and competitive value chains across the Channel. These chains range from input industries for agriculture trading direct to farmers, to the primary processing and food, feed and non-food agricultural production.
With the withdrawal negotiations ongoing, it is paramount to maintain the integrity of the EU Single Market as well as to prepare the foundations of the strong trade relationship with the UK. 

The European Union is a net importer of coarse grains, rice, oilseeds, vegetable oils and meals from the countries of Mercosur and Mercosur countries have proved to be a reliable source of these agricultural raw materials. 
Here below the Position Paper

COCERAL, representing trade in cereals, rice, feedstuffs, oilseeds, olive oil, oils and fats and agrosupply, supports a market oriented and competitive Common Agricultural Policy (CAP) for the period after 2020.
Here below the Position Paper

Policy makers should consider the following key guiding principles to deliver on the twin objectives of renewables uptake and decarbonisation in the transport sector.

CELCAA comment on the proposed reform on the tariff rate quota (TRQ) administration currently managed by DG AGRI, stressing that the current system should be improved and adapted to reflect evolving realities when needed, and for sectors where the current system has provide to work efficiently, the current system should be maintained.

COCERAL is concerned that the definition of Endocrine Disruptors (EDs) proposed by the Commission in its draft criteria to identify EDs in Plant Protection Products (PPPs), being purely hazard-based, may be restrictive beyond the needs of safety concerns.

AIBI, COCERAL, EFFPA, FEFAC, FoodDrinkEurope and PFP fully support the proposed amendment to the Waste Framework Directive as this clarification of the non-waste status of feed materials will be an essential contribution to ensuring efficient implementation of feed safety management and, in addition, contribute to the strategic policy goal of food waste reduction.

As the Commission is approaching its internal deadline for deciding on the practical rules of MiFID implementation (the Regulatory Technical Standards, RTS), COCERAL has been stepping up even further its outreach to promote a workable framework for non-financial entities exemption

COCERAL, FEDIOL and FEFAC urge the Plenary of the European Parliament to reject the Commission proposal allowing Member States to opt-out from the EU GM food and feed authorisation system.

COCERAL, FEDIOL and FEFAC call upon the European Parliament’s Environment, Public Health and Food Safety Committee to reject the Commission proposal allowing Member States to opt-out from the EU GM food and feed authorisation system.

In view of the Genetically Modified Organisms (GMOs) latest discussions, COCERAL together with the Food and Feed Chain Coalition (FFC) advocates for a functioning evidence-based EU policy on GMOs in order to contribute to a competitive and sustainable Europe. The FFC partners require and demand a reasonable level of legal and regulatory certainty, such as an EU-wide authorisation of safe products, an enabling regulatory environment, trade facilitating measures.

The EU food and feed chain expresses their views to the discussion relating to the review of the EU’s decision-making process to authorise Genetically Modified Organisms (GMOs) for food and feed uses, as announced in the European Commission’s work programme for 2015.

Agricultural commodity trade needs consistent and well-functioning futures markets with sound rules which take into account the particular nature of agricultural commodities markets so that the operators in the food supply chain can hedge the typical risks linked to their physical businesses. COCERAL continues to be active in the financial reform and contributes to the definition of level 2 legislation, i.e. technical standards.

Key interest of COCERAL is to ensure the quality and health of the plant reproductive material that is distributed. In general, COCERAL believes that the current legal framework of the seed marketing legislation has proven to work satisfyingly in the market. Any new Plant Reproductive Material proposal should include all relevant stipulations to allow stakeholders to assess what is intended with it.

COCERAL welcomes the negotiations for the EU-USA Transatlantic Trade and Investment Partnership (TTIP) and calls on the EU to reach a comprehensive trade deal that will harmonise rules and curb technical barriers to transatlantic trade, including in agriculture.

Food and feed safety is of upmost importance to COCERAL and EUROMALT. As part of their commitment, COCERAL and EUROMALT welcome the Commission’s intention to harmonize, modernize and sharpen the EU system of official control along the agri-food chain by simplifying and modernizing its regularity framework.

CELCAA welcomes the upcoming EU-USA Transatlantic Trade and Investment Partnership (TTIP), looking forward to an agreement that will cover all aspects of trade and investment with also a view of protecting Geographical Indications and truly sensitive products.

COCERAL calls for a predictable biofuel policy to support the domestic supply of plant proteins and to reduce the EU dependence on imported protein meals. COCERAL also questions the use of scientifically controversial data as a basis for potentially wiping out the European production of biofuel crops together with the whole industry and supply chain. The negotiations of free trade agreements should be seen as an opportunity also to address the actual issue of direct land use change and related emissions right where they occur.

COCERAL recognises and acknowledges the important role of bees for the ecosystem and for the entire food chain and highlights that all COCERAL members are working to conserve and protect pollinators.

COCERAL welcomes the Council’s General Approach designing a new market-orientated CAP that could also grant increased flexibility in the greening measures. In this period of high price volatility in agricultural commodities and of increased need for supply worldwide, the text agreed by the Council of Ministers gives special attention for sustainable intensification of EU agricultural production.

Feed Hygiene:a responsibility across the supply chain
The trading community remains highly vigilant to the management of mycotoxins in their activities. Traders continue monitoring with due diligence to ensure the delivery of safe feed materials, in compliance with the European legal framework. The recent incidents of increased Aflatoxin content in grains should be treated as isolated cases giving an opportunity to review and discuss together with the whole supply chain the top-of-the-pyramid approach.

COCERAL welcomes the steps taken by the European Parliament to grant increased flexibility in the measures to green the CAP and the COMAGRI intention to adhere to the Commission’s proposal about the managing import and export licences system. However, COCERAL is still concerned about the extension of functions given to producer and interbranch organisations and also warns the co-legislators about the negative implications of regular reviews of the reference prices for intervention and other market measures. 

COCERAL welcomes the Commission’s decision to reopen negotiations with the Mercosur area, which is a main source of agri-bulk commodities for the EU. In view of ensuring the necessary supply, our members ask that the future free trade agreement with Mercosur brings further market opening for agri-products for which the EU is not self-sufficient.

COCERAL brings its contribution to the current discussions on the future Common Agricultural Policy: the Single Common Market Organisation and the Greening of the Direct Payment Scheme. Following the European Parliament amendments to the Commission proposals, COCERAL conveys the grain trade perspective on issues such as public intervention, import/export licences, producers organisations as well as on the measures for greening the CAP.

COPA-COGECA, COCERAL, FEDIOL and EUROMALT welcome the positive steps forward on MiFID taken by the European Parliament in its report of 26th October as well as by the latest European Council compromise proposal. Our associations would like to express their position on exemptions, position limits and reporting in view of the trilogue discussions. The particular nature of the agricultural commodities markets must be taken into account to allow the operators in the food supply chain hedging the typical risks linked to their physical businesses.

As important agri-business player worldwide, Europe needs to reflect on the kind of agriculture for the future. It is crucial for the EU to have access to multiple sources year round in order to meet the demand as well as to tap into surplus areas to cover its internal supply deficit. 

CELCAA, the European Liaison Committee for Agricultural and Agri-Food Trade welcomed the reform process towards a market oriented, competitive and sustainable Common Agriculture Policy, which was started with the reform in 2003. The future CAP ensures the active participation of traders of agricultural and agri-food products in the market place in order to secure value for all participants in the suplly chain and to reduce price volatility.

On the basis of a literature review and quantitative survey data, the present article is intended to contribute to a common effort between regulators, scientists and food business operators with a view to reduce the many sources of uncertainty in modern mycotoxin analysis.

This article was published in "Food Control"22 (2011) 1145-1153 by David Siegel (BAM) and Teresa Babuscio (COCERAL), copyright Elsevier 2011. http://www.sciencedirect.com/science

Coceral reconfirms that the future CAP has to remain a common EU policy and acknowledges its role as main provider of public goods. Facing the current challenges, Coceral asks for a CAP endowed with better legislation and instruments which would ensure sufficient supply of goods and stimulate the competitiveness of EU agri-bulk trade.

COCERAL would like to share its reflections and considerations on the Commission's proposals to grant national flexibility for authorising the cultivation of Genetically Modified Organisms (GMOs) within the framework of the revision of the GM cultivation legal framework currently under discussion. Members are very much concerned that the Commission's proposals represent a serious dereliction of regulatory responsibility, creating an EU-wide charter for discrimination against the products of agricultural biotechnology and establishing the basis for future innovation, GM or not, to be blocked or restricted without scrutiny or justification.

In the context of proliferation of third country trade agreements and of the stalling of the Doha Round, Coceral, Euromalt and Euroflour support the conclusion of a free trade agreement agreement (FTA) with the Mercosur. As the Doha Round would ensure a level playing field, overcoming the fragmentation of bilateral agreements, our members ask that the Commission ensures a smooth passage between the two trade regimes.