The European Fruit and Vegetables Association (FruitVegetablesEUROPE) welcomes the opportunity to comment on the European Commission’s roadmap on the Farm to Fork Strategy for Sustainable Food and appreciates the opportunity to provide comments and input ahead of its adoption.

FruitVegetablesEUROPE (EUCOFEL) is the European private sectoral Association representing the European Fruit and Vegetables producers and exporters at the EU level. FruitVegetablesEUROPE’s
members are national and regional Federations and Associations (mainly PO and APO) and companies from the main European producing countries (France, Germany, Greece, Italy, Poland, Portugal, and Spain).

FruitVegetablesEUROPE’s direct members account for more than 4,500 companies. FruitVegetablesEUROPE and its members are committed to the Farm to Fork (FTF) strategy. Protection of the environment and food safety are two main pillars of the sector. This is why we have high expectations in fulfilling its goals and ensure the sustainability of the food chain. Nevertheless, we are concerned about the impacts it might have on the farmer’s income and the competitiveness of the sector.

FruitVegetablesEUROPE agrees that a sustainable food strategy is key to achieving the goals of the EU’s Green Deal. Furthermore, the FTF strategy needs to set out regulatory and non-regulatory actions to create more efficient, climate-smart systems that provide healthy food while securing a decent living for EU farmers.

FruitVegetablesEUROPE welcomes many of the initial ideas outlined in the Green Deal communication and the Farm to Fork roadmap. Nevertheless, we would like to contribute to these following areas:

1. Pesticides, fertilizers and endocrine disruptors.

As Health Commissioner Stella Kyriakides has claimed several times, reducing the use of pesticides, fertilizers and antibiotics is a priority of the FTF strategy. In that sense, we consider that:

  • The reduction of the use of pesticides needs to be driven on scientific criteria, avoiding rhetoricbased statements.
  • Policies must be coherent and avoid fragmentation of standards in different legislations.
  • The European Commission must present comprehensible alternatives to the use of the current pesticides. Farmers need new tools to control weeds, insect infestation, and diseases.

Climate change is already affecting the production of European farmers. Issues as extreme weather and new invasive alien species are causing substantial economic losses. In this regard, the reduction of pesticides cannot lead to an increase in production costs. This would put further pressure on European Fruit and Vegetables producers.

2. Circular Economy.

FruitVegetablesEUROPE and its members are working on the Fruit and Vegetable production challenges regarding the Circular Economy. The goal is to contribute to a sustainable food system that has a neutral environmental impact. Among the main challenges the sector tackled, we encourage to take action in:

a) Initiatives for producers to carry out self-management of organic waste. FruitVegetablesEUROPE’s feedback: Roadmap on the Sustainable food – ‘farm to fork’ strategy We are facing many problems due to administrative procedures, especially in the case of plant remains using composting and vermicomposting techniques. Regulatory barriers prevent the self-management of organic waste in the short term. Consequently, the producer opts for a faster management route, such as
the dump.

The use of the landfill site represents an extra cost for the producer and an opportunity loss to make farms more sustainable. If we want to encourage self-management of organic waste, these administrative procedures should be reduced. Moreover, it will be useful to create and distribute handbooks to guide
producers on the best conditions for their safe implementation of organic waste.

b) Oil waste management: Farms with combustion equipment and vehicles produce waste oil. These oils must be delivered to the Integrated Waste Oil Management System (SIGAUS). However, the SIGAUS centers do not accept oils from self-maintenance. These points are private centers that only take the delivery of waste oils from the maintenance work carried out by themselves, not from waste oils from farms.

c) Plastic waste management: Manufacturers, importers, intra-community purchasers, or those who place on the market plastics for use on farms should take responsibility for the correct management of the waste produced. To this end, waste should be managed through authorized management bodies, such as the integrated management systems.

d) Packaging of phytosanitary products and fertilizers: Phytosanitary product packaging with the SIGFITO logo (Fertilizer Packaging Collection System) must be managed through its integrated management system. However, packaging without this logo must be handed
over to its distributor or an authorized manager.

SIGFITO’s scope of activity has been extended to agricultural packaging, so it can also manage the packaging of fertilizer products. However, some manufacturers and marketers are not members of SIGFITO and do not take responsibility for the waste produced.

We propose to increase control over manufacturers and marketers of plant protection products to ensure that they take charge of management.

3. Food Waste.

The European Fruit and Vegetables sector is aware of and engaged in the fight against food waste. A part of our product is lost both at origin and during transport. For this reason, we recommend that the FTF consider the following aspects:

  • Make investments to improve the Fruit and Vegetables transport between the source and the consumer/retailer.
  • Improve the condition of the storage infrastructure.
  • Integrate food loss and waste in education and professional training, both public and private sectors.
  • Carry out educational actions for buyers concerning the consumption period and alternatives uses of fresh products.
  • Put in place regulations and actions to promote food donation among farmers.
  • Develop a better system on the quantification of food wastage at the primary production stage to reduce food waste. This should not impose any additional administrative burden on producers.
  • Gather best practices in the Member States concerning food waste management on farms.
  • Better matching of supply and demand in the food chain. Improving farmers’ access to information on market outlooks will help them to avoid over-supply and food waste

4. Organic farming

Promoting the organic agriculture of Fruit and Vegetables is another priority claimed by Commissioner Kyriakides.

FruitVegetablesEurope believes that organic production has a role to play to meet growing consumer demands. However, it is essential to note that there are ecological trade-offs implied by an increase in organic agriculture. Therefore, while organic production has many advantages, it also has weaknesses that must be taken into account in the FTF strategy.

The Fruit and Vegetables producers want to emphasize that:

  • The costs for the conversion of conventional agriculture to organic are high and imply no profits during the first years of the transition.
  • Organic farming does not safeguard greater competitiveness of the sector or better incomes for farmers. These two elements are essential to ensure the sustainability of the sector in the long term.
  • Organic products are not exempt from treatment with products that pose a risk to the environment and the consumer.
  • Organic farming is also labor and machine intensive. This implies a higher consumption of fossil resources, contributing to the emission of greenhouse gases.
  • Organic farmers are forced to sell their products at a higher price since they obtain yields around a third less and crops are more random.

The elements mentioned above make us question to what extent organic agriculture is generalisable to the whole Agriculture. If all producers switch to organic farming, how will they cope with the high pressure from plagues?

In parallel, the macroeconomic challenges in the Eurozone should not be forgotten. The prospects for economic growth are moderate. According to the ECB, real GDP growth is projected to decline slightly to 1.1% in 2020, before increasing to 1.4% in 2021 and 2022. Simultaneously, the purchasing power of the population does not increase sufficiently to cope with high increases in the shopping basket. How will be the affordability of organic Fruit and Vegetables ensured? If this element is not taken into account, it can end up generating first-class consumers, able to consume fresh fruit and vegetables, and second-class consumers with access to processed and low-quality products.

European farmers comply with the most demanding standards of quality and food safety in the world. Not taking them into account would be a waste of many economic resources, as well as all the investments made by European farmers in the last decade.

Therefore, FruitVegetablesEurope calls for the European Commission not to undermine the EU conventional Agriculture versus Organic Agriculture.

6. Coherence with other policies.

FruitVegetablesEurope would like to underline the necessity for consistency between the EU agricultural, food, trade, innovation, and competition policies, as well as the EU Budget policy.

a) EU Budget: The Multiannual Financial Framework (MFF) must be in line with the objectives set by the Commission. With a low budget allocation, the Green Deal and the FTF strategy will only be a document of good intentions, generating frustration among the sectors involved.
b) Research and Innovation To face future challenges in the food chain, it is necessary to bet on research and innovation policies
(R+D+i). The agricultural sector is being confronted with obstacles not only at the environmental level. For instance, due to the unfair competition from 3rd counties, EU Agriculture is losing competitiveness, productivity, and limiting its trade capacity.
Therefore, it is essential to invest in the technological and innovation part of the food chain to increase EU competitiveness and give further added value to EU Agriculture.
c) Trade The current trade policy is not sustainable either at the environmental or the social level. The Fruit and Vegetables producers are suffering the consequences of free trade agreements. Products are being imported with much laxer phytosanitary regulations. If we want to bet on a sustainable food model, we must prioritize the European F&V consumption.

4. Organic farming

It is a fact that we need to find a way to feed a much larger world population in 2050 without harming our planet, and the EU has a crucial role to play in that matter.

Commissioner Kyriakides mentioned that the Farm to Fork strategy must reflect the ambition of the Green Deal. However, in our view:

  • The incentives proposed in the Green Deal and the Farm to Fork strategies are not sufficient and appropriate for EU farmers to achieve an ecological transition.
  • The reduction of the use of pesticides needs to be driven on scientific criteria. The European Commission must present comprehensible alternatives to the use of the current pesticides.
  • There is a need for coordinated actions to contribute to a sustainable food system that will achieve a neutral environmental impact.
  • It is necessary to urgently act to reduce the food waste and food losses at the EU level.
  • EU conventional Agriculture complies with the most demanding standards of quality and food safety in the world. Therefore, not only organic agriculture should be considered.
  • It is necessary to increase the number of actions regarding the information and promotion of the EU mandatory labelling of origin, particularly for Fruit and Vegetables, within the EU.
  • We need concise and realistic proposals that are backed by strong budgetary support.

FruitVegetablesEurope believes that no one is to be left behind; the environmental transition cannot leave the burden on European farmers. European farmers are struggling to keep the sector alive, which is very much affected by intense international competition.

Finally, FruitVegetablesEurope encourages the European Commission for more coherence in the EU policies affecting the EU Agriculture sector. The coherence of EU Policies and its adaptation to the new Green Deal and the Farm to Fork strategies should be a priority.

FruitVegetablesEUROPE looks forward to working closely with the European Commission, the European Parliament and the Council to develop the best sustainable Farm to Fork strategy and remains at your disposal to discuss them in more detail.

“As the sanitary sector, the EU fruit and vegetables producers are also on the front line battle against the COVID-19. Since the beginning of the COVID-19 pandemic, all the EU fruit and vegetables producers have been working intensively in the fields and in the warehouses. At the same time, they are also ensuring that the factories, the logistics, the distribution, the marketing, and the points of sale
around the EU are functioning well to guaranteeing the maintaining of the supply in order “to put food on
our tables”. These vast efforts have extra costs and producers must be helped.”

Juan Marín

President of FruitVegetablesEurope (EUCOFEL)

 “The EU market disturbances in the fruit and vegetables sector are real, several sectors are suffering from the consequences of the COVID-19 (extra costs for transportation, decrease in consumption, difficulty to have seasonal workers, etc.). The response to this global sanitary, social and economic crisis should be European. So, the EU should pledge to propose EU-wide measures that would reassure EU markets, producers and consumers alike.”

Alba Ridao-Bouloumié

Secretariat General of FruitVegetablesEUROPE (EUCOFEL)

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