CEBP campaigns for all relevant policy issues in Europe, which are important for bakers and confectioners.

Labelling obligations will be more comprehensive according to the Regulation on the Provision of Food Information to Consumers, which had been approved in 2011 (Food Information Regulation, FIR). For instance, the new FIR determines that the name of a allergen substance shall be emphasized through a typeset that clearly distinguishes it from the rest of the list of ingredients, for example by means of the font, style or background colour. The regulation implements also a new labelling obligation for non-prepacked food with regard to allergens. The modalities of these labelling obligations shall be defined by the EU-member states. In the absence of national measures, the provisions of the regulation concerning prepacked food are applicable to non-prepacked food as regards the labelling of substances or products causing allergies or intolerances.

Position of CEBP

The implementation at national level is pursued by the particular national associations of CEBP. National solutions of allergen information for loose goods need to consider the feasibility and the specifics of the craft. It may not be required, what cannot be done in practice.

According to the Regulation on the Provision of Food Information to Consumers an indication of the country of origin is currently only mandatory with regards to specific meat products respectively when the failure to indicate might mislead the consumer as to the true country of origin or place of provenance of the food. The Food Chain Evaluation Consortium (FCEC), led by Agra CEAS Consulting, has been mandated by the DG Health and Consumers of the European Commission (DG SANCO) to carry out a study on the application of rules on the mandatory indication of country of origin or place of provenance of unprocessed foods, single ingredient products, and ingredients that represent more than 50% of a food. The study should be finalized in August 2014. In December 2013 the European Commission released a report on the arguments for and against a mandatory indication of the Country of Origin for meat products. The report analyses the feasibility and consequences of mandatory measures as well as the impact on the internal and international markets. The European Commission will now consult the European Parliament and the Member States in preparation of its next steps.

Position of CEBP

The CEBP campaigns for a simple and practical solution. Bureaucracy must be avoided as well as, due to real conditions (e.g. flour as an ingredient, which makes up more than 50%), not realizable information requirements.

According to Annex V Nr. 19 of the regulation, handcrafted food which is directly supplied by a manufacturer of small quantities of products to the final consumer or to local retail establishments is exempted from the mandatory nutrition declaration. It is currently unclear in different member states what this means in detail and how these requirements have to be defined.

Position of CEBP

The exception need to be understood like that: Craft companies are excluded of the mandatory nutrition declaration according to Article 9, paragraph 1, letter l) of the FIR.

We also expect that an interpretation, which companies are meant by these terms is reserved by the particular Member State.

The Commission published its proposal in May 2013. Main element of the draft is the introduction of general and comprehensive control fees in all EU-member states. Within that framework, there shall be exemptions for micro enterprises. Furthermore, a bonus-malus system for all enterprises has been proposed. Nevertheless, the introduction of general fees is objected by most of the food industry associations. The proposal of the Commission is now being discussed in the Council and in the Parliament. The leading committee in the European Parliament is the Committee on the Environment, Health and Food Safety (ENVI). Advisory Committee is the Committee on Agricultural and Rural Development. The ENVI-Committee adopted its report on 20 February 2014. This report clearly favors the European Commission´s approach for a system of control fees. Only the basic costs of the competent authorities (staff and other resources necessary to perform official controls) may be financed by resources available from general tax revenue. Unlike the Commission´s proposal, the report does not foresee exceptions for SMEs.

Position of CEBP

  • The introduction of regular fees is basically being rejected. Obviously, such a change of system will create considerable financial burdens for our mostly small – and medium-sized member companies. Objectively this burden is unjustifiable. The food control administration is a part of the services for the public and thus must be organized with public funds. Therefore, it must remain in the fundamental option of Member States to use tax money, in order to finance official controls and not to make rigid specifications for a funding with mandatory charges.
  • The transparency provisions (Art. 7, 10 of the draft regulation) are also regarded very critical. This, especially concerning the jointly applicable fundamental rights, such as presumption of innocence, double jeopardy prohibition, and privacy policy, might be able to appear an extensive publication policy as illegal.

The Health Department of the United Kingdom recently proposed a so called “GDA-Hybrid-Scheme” (also called: UK Traffic Lights System), which recommends a traffic light labelling system for food products concerning the quantity of ingredients such as salt, sugar and fat. This could become a precedent for other EU- member states.

In reaction to that, the Italian government presented a discussion paper at the last Competitiveness Council on 20 and 21 February 2014. The Italian delegation, supported by several delegations, drew the attention of the Council to a “traffic light” system for food labelling developed by the United Kingdom which aims at classifying foods on the basis of a color code, based on the content of the product, and the effects of that system on the free circulation of goods in the internal market as well as the correct information for consumers.

The European Commission promised to check on the compatibility of the British system with the principles of the internal market as well as with the provisions of the Food Information regulation.

Position of CEBP

The CEBP clearly and vehemently militate against the UK- Traffic Light System. From a legal perspective, we see that marking as a striking violation against the EU’s plan, to unify the food labeling law in Europe. Products marked with “red”, are discriminated in a not comprehensible manner. Ultimately, the consumer is not informed with this kind of labeling, however is led in unscientific manner astray.

Each food is inherently a combination of “red, yellow and green”. Therefore the proposed system cannot reflect the real value of a food – seems absolutely arbitrary and thus is giving false signals.

On 21 November 2013 the Commission presented a draft reform of the information and promotion policy for European agricultural and food products. The aim is to develop and open up new markets for European agricultural products on the Internal Market and in the Third Countries, and to increase consumer awareness of their quality. The campaigns can run inside the EU, or beyond its borders with the objective of opening up new markets for EU farmers. Promotional activities can include advertising campaigns in the press, on television, on radio or on the Internet, point-of-sale promotions, public relations campaigns, participation in exhibitions and fairs, and a range of other activities.

EU financing can cover half of the cost of a campaign. The professional organisation behind the campaign must contribute at least 20 percent of the cost. National authorities can provide the remainder of the funding.

The European Commission proposed to include agricultural products and foodstuffs in the scope of the new regulation. Bread, pastry, cakes, confectionery, biscuits and other baker’s wares could now be promoted with the aid of the EU.

Position of CEBP

Basically, we recommend the promotion policy of the European Union and consider the regular reorganization, of the underlying regulations, to be appropriate. We are much appreciated, that according to this current draft, bread and baked goods are listed in the proposed regulation for food, which may be subject of promotion measures.

The topic salt and the creation of so-called nutrient profiles are discussed at national, European and international level for some time. For a long time politicians require, to reduce the salt content in certain foods – this should also include bread – with reference to a supposed causal link with high blood pressure and thus the risk of cardiovascular diseases.

In current discussions about revisiting the proposals for the introduction of nutrient profiles, obviously even at European level raise concerns over the corresponding plans of DG SANCO, since it has been recognized that on the one hand the underlying scientific findings (concerning the relationship between salt intake and the mentioned diseases) are not clearly and on the other hand the quality and nutritional balance is not determined by a single food, however by the diet as a whole.

Position of CEBP

Vehemently the CEBP campaigns always, against the planned nutrient profiles according to Regulation No 1924/2006 and thus a reformulation of traditional recipes, due to supposedly health policy considerations. Any political interference in the composition of food and thus in existing recipes are rejected. In particular, it applies when a causal relationship is not objectively justifiable and a political activism results only in discrimination of food and paternalism of consumers.

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