# Benefits and costs of EU marketing standards in the cider sector: Results from interviews with stakeholders

Aymeric Ricome, Gloria Solano-Hermosilla, Pavel Ciaian

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Aymeric Ricome, Gloria Solano-Hermosilla, Pavel Ciaian. Benefits and costs of EU marketing standards in the cider sector: Results from interviews with stakeholders. Publications Office of the European Union, Luxembourg. 2022. hal-04985167

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JRC TECHNICAL REPORT

# Benefits and costs of EU marketing standards in the cider sector

*Results from interviews with stakeholders*

Aymeric Ricome, Gloria Solano-Hermosilla and
Pavel Ciaian

2022

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This publication is a Technical report by the Joint Research Centre (JRC), the European Commission's science and knowledge service. It aims to provide evidence-based scientific support to the European policymaking process. The contents of this publication do not necessarily reflect the position or opinion of the European Commission. Neither the European Commission nor any person acting on behalf of the Commission is responsible for the use that might be made of this publication. For information on the methodology and quality underlying the data used in this publication for which the source is neither Eurostat nor other Commission services, users should contact the referenced source. The designations employed and the presentation of material on the maps do not imply the expression of any opinion whatsoever on the part of the European Union concerning the legal status of any country, territory, city or area or of its authorities, or concerning the delimitation of its frontiers or boundaries.

Contact information

Name: Pavel Ciaian

Address: Edificio EXPO, C/Inca Garcilaso 3, 41092 Seville (Spain)

Email: pavel.ciaian@ec.europa.eu

EU Science Hub

https://joint-research-centre.ec.europa.eu

JRC127345

EUR 31140 EN

PDF

ISBN 978-92-76-54520-0

ISSN 1831-9424

doi:10.2760/036422

Luxembourg: Publications Office of the European Union, 2022

© European Union, 2022

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How to cite this report: Ricome, A., Solano-Hermosilla, G., Ciaian, P. *Benefits and costs of EU marketing standards in the cider sector: Results from interviews with stakeholders*, EUR 31140 EU, Publications Office of the European Union, Luxembourg, 2022, ISBN 978-92-76-54520-0, doi:10.2760/036422, JRC127345.
# Contents

<table><tr><td>EXECUTIVE SUMMARY</td><td>1</td></tr><tr><td>ACKNOWLEDGEMENTS</td><td>3</td></tr><tr><td>1 INTRODUCTION</td><td>4</td></tr><tr><td>2 BRIEF DESCRIPTION OF THE EUROPEAN CIDER SECTOR</td><td>5</td></tr><tr><td>3 METHODOLOGY</td><td>7</td></tr><tr><td>3.1 ANALYSIS OF THE RESPONSES</td><td>8</td></tr><tr><td>4 RESPONDENTS' CHARACTERISTICS</td><td>8</td></tr><tr><td>5 RESULTS</td><td>9</td></tr><tr><td>5.1 CURRENT PUBLIC AND PRIVATE MARKETING STANDARDS</td><td>9</td></tr><tr><td>5.2 INTRODUCING EU MARKETING STANDARDS</td><td>17</td></tr><tr><td>6 CONCLUSIONS</td><td>25</td></tr><tr><td>REFERENCES</td><td>28</td></tr><tr><td>APPENDIX A: INTERVIEW GUIDE</td><td>29</td></tr><tr><td>APPENDIX B: SUGAR CONTENT UNDER THE SPANISH AND FRENCH CIDER NOMENCLATURES</td><td>32</td></tr><tr><td>LIST OF ABBREVIATIONS</td><td>33</td></tr><tr><td>LIST OF FIGURES</td><td>34</td></tr><tr><td>LIST OF TABLES</td><td>35</td></tr></table>
**Executive summary**

The EU marketing standards aim to ensure that the single market is supplied with products of standardised and satisfactory quality, taking into account consumers' expectations. The standards are based on two main instruments: (i) minimum quality standards – which define the rules that must be respected when marketing agricultural products in the EU; and (ii) optional reserved terms (ORTs) – which consist of voluntary labels introduced to make it easier for producers to communicate the value-adding characteristics or attributes of their products to buyers and consumers. The first EU marketing standards were developed to cover fresh fruits and vegetables in the mid-1960s, and have since expanded to cover numerous agricultural products. Under the farm to fork strategy launched in 2020, the European Commission aims to revise the EU marketing standards to pursue the goal of transitioning towards a more sustainable food system and to make the standards compatible with the needs of stakeholders, preferences of consumers and changes in technologies. Cider is one of the products not covered by the EU marketing standards. The European Commission evaluation of EU marketing standards carried out in 2019 recommended that, despite the absence of EU marketing standards for the cider sector, the possible benefits of establishing such standards should be investigated (Areté and Agra CEAS Consulting, 2019; European Commission, 2020a).

The objective of this report is to qualitatively assess the added value of introducing EU marketing standards in the cider sector, and their costs and benefits from socioeconomic, environmental and health perspectives. For this purpose, the report also analyses the current public and private marketing standards that operators in the cider sector apply in different Member States. The analyses in the report are based on semi-structured interviews conducted with 22 stakeholders from the cider supply chain between 4 October and 17 December 2021. The respondents interviewed are from 10 Member States and a European-level cider-related association. Note that the analyses conducted in this report are based primarily on information collected from cider producers, as the majority of respondents interviewed are from the production stage of the cider supply chain.

The results from the structured interviews on existing marketing standards suggest the following main findings.

* Most of the Member States covered in the report have their own public marketing standards in place. Only a few Member States covered do not have public national standards; some of these Member States rely on private marketing standards.

* The existing (private and public) marketing standards are very heterogeneous between Member States, broadly falling into two categories: light standards (the cider is less than 100 % apple juice) and strict standards (the cider is 100 % apple juice). Among the Member States covered in this report, strict standards are implemented in Spain, France and Romania, whereas light standards are implemented in Denmark, the Netherlands, Poland, Slovakia and Sweden. Germany and Ireland have no public standards, although, in Germany, there are strict standards in place for apple wine (*Apfelwein*), which is a beverage similar to the cider produced in Member States with strict standards.

* The main perceived benefits of the existing public and private marketing standards for the cider sector include reducing transaction costs, improving the functioning of the cider supply chain, reducing unfair competition, ensuring a minimum quality of cider offered on the domestic market and reducing the potential to mislead consumers. Strict standards may support local and EU apple producers and small (craft) cider producers that use more apple juice in their cider. Light standards may foster innovation and promote growth of the cider sector, facilitate trade and provide access to a larger variety of cider products on the market.

* The main perceived disadvantage (cost) of the existing national marketing standards is their heterogeneity across Member States, which is considered to hamper intra-EU trade. Strict marketing standards also have other drawbacks: cider producers in Member States with strict standards face unfair competition/trading (they must compete with cider imported from countries with light standards) and strict standards may restrict the sector's capacity for innovation and reduce product differentiation; in addition, strict standards are usually associated with higher production costs, potentially making cider more expensive for consumers.

Interviewees were asked about the implications of potentially introducing EU-wide marketing standards in the cider sector. The main findings are as follows.

* The majority of respondents interviewed (21 out of 22) support the introduction of EU marketing standards. However, respondents differ significantly in terms of their preferred level of stringency of EU standards. Of the 21 respondents in favour of EU standards, 10 support strict standards (100 % apple juice content), seven support light standards (less than
100 % but more than 15 % apple juice content), three support EU standards with no minimum apple juice requirements and one expressed no opinion on the type of standards that should be implemented.

* Respondents from Member States with light national standards in place prefer less strict EU-wide standards, whereas the reverse is true of respondents from Member States with strict standards. Large-scale cider producers and their representative associations are in favour of light EU standards with no or low minimum apple juice content, whereas small/craft cider producers support strict EU standards.

* The majority of respondents (18 out of 22) are in favour of introducing ORTs at EU level. Most of these respondents favour the introduction of ORTs at EU level to categorise cider according to certain attributes/characteristics, primarily to reduce the misleading of consumers and to avoid the misuse of various claims and labels ('pure juice', 'fresh juice', 'premium cider', etc.).

* The main economic benefits of EU standards perceived by respondents include their potential to reduce transactions costs and improve the functioning of the cider supply chain (increase transparency, facilitate business-to-business relationships, reduce barriers to trade), and their ability to reduce unfair competition from cider imported from non-EU countries. Many respondents from Member States with strict existing standards perceived a further benefit to be the potential of EU standards to reduce unfair competition among EU cider producers. In particular, this, it is believed, will help to reduce 'regulation arbitrage' (the production of cider in Member States with light standards – particularly by large-scale multinational cider producers – to then sell it in Member States with strict standards) and regulation-induced differentiation of cider (selling both 'regulated' cider and 'non-regulated' cider on the same domestic market). In addition, respondents thought that the introduction of EU standards would enable producers to communicate more effectively to consumers information about cider quality, and may prevent the misuse of claims and labels. Several respondents (primarily those producing cider with a high apple juice content) said that EU standards may avoid misleading consumers. The respondents suggested that strict EU standards may support local/EU apple producers and local cider producers, whereas light EU standards are perceived to foster innovation and enhance competition in the sector.

* The main perceived economic cost of the EU standards is potentially higher production costs for cider producers that currently apply lower minimum requirements, depending on the stringency of the adopted standards. Some respondents suggested that, if too strict, EU marketing standards could reduce product differentiation, restrict innovation by hampering producers' ability to tailor cider products to consumers' preferences and increase production costs, leading to higher cider prices and potentially causing consumers to replace cider with other beverages. Regarding the potential implications of the introduction of light EU marketing standards, some respondents suggested that these would be unlikely to reduce unfair competition between EU cider producers because it would be more difficult for craft cider producers (mostly those producing cider with high apple juice content) to differentiate their products from cider with low apple juice content. Light standards may result in the loss of consumers' trust and may confuse/mislead consumers when making beverage purchase choices, resulting in potentially lower cider consumption. Some respondents suggested that light EU standards may leave the EU market unprotected from low-quality cider imported from non-EU countries. Overall, given the heterogeneity of existing national standards and stakeholders' preferences, EU-wide marketing standards may deviate from the Member States' socially optimal standards for some stakeholders or Member States. To avoid these risks, the majority of respondents from Member States with strict standards would prefer to introduce EU standards categorising cider into quality groups (e.g. by apple juice content) and EU-regulated ORTs.

* In terms of the sustainability implications of EU marketing standards, most respondents struggled to identify the standards' sustainability implications, as the standards are usually seen as a technical tool that should be restricted to setting the quality attributes of products. Several respondents stated that the sustainability issue should be addressed at a broader food chain level and not at sectoral level. Overall, only a minority of respondents (7 out of 22) were in favour of EU marketing standards addressing sustainability issues.

* Those respondents who were in favour for EU marketing standards to address sustainability suggested some specific potential impacts of the EU standards on environmental, health and socioeconomic aspects related to the cider sector. Depending on the stringency of the EU marketing standards, the sustainability impacts could include:

* environmental impacts: carbon sequestration and preservation of biodiversity by apple orchards, reduction in transportation costs and carbon dioxide emissions, reduction in energy consumed for the production of cider produced from fresh apple juice and reduction in waste/losses in the apple sector;

* emerging health benefits if banning or limiting the use of artificial additives or added sugar in cider;

* socioeconomic impacts: promoting the development of the rural economy and rural employment, and supporting the development of the local cider sector.
**Acknowledgements**

We would like to thank all operators, associations and individuals from the cider sector for participating in the interviews and for sharing their insight and experience. Without their contribution, this report would not have been possible.

**Authors**

Aymeric Ricome

Gloria Solano-Hermosilla

Pavel Ciaian
# 1 Introduction

The EU marketing standards can be defined as 'a set of rules aimed to ensure that the single market is supplied with standardised quality agricultural products that meet consumer expectations' (European Commission, 2020a). They cover technical definitions, classification, presentation, marking and labelling, packaging, production methods, conservation, storage, transport, related administrative documents, certification and time limits, and restrictions of use and disposal. EU marketing standards are usually defined by sector or product and aim to (European Parliament and Council, 2013; Areté and Agra CEAS Consulting, 2019):

* improve the economic conditions for production and marketing of agricultural and food products (level playing field, facilitating trade);

* improve the quality of products in the interests of producers, traders and consumers;

* take into account the fact that consumers expect to receive adequate and transparent product information;

* enable the market to be easily supplied with products of standardised and satisfactory quality.

EU marketing standards utilise two types of instrument. The first type, 'obligatory rules', are the rules that must be respected when marketing agricultural products in the EU; they include rules on definitions, minimum requirements, production methods, presentation and labelling. The second type is 'optional reserved terms' (ORTs), which are voluntary labels introduced to make it easier for producers to communicate the value-adding characteristics or attributes of their products to buyers and consumers (European Parliament and Council, 2013). Obligatory rules are established in many agricultural sectors and for products such as fresh and processed fruit and vegetables, meat, eggs, dairy products, olive oil, hops, fruit juices and coffee. ORTs are currently restricted to poultry meat, eggs and olive oil. Although EU marketing standards are set for many products, some – such as cheese, potatoes and cider – are not covered (Areté and Agra CEAS Consulting, 2019).

With the farm to fork strategy, launched in 2020 as part of the European Green Deal, the European Commission intends to address comprehensively the challenges of sustainable food systems by making the food systems fair, healthy and environmentally friendly. The farm to fork strategy lists 27 actions needed to achieve its objectives, including the revision of EU marketing standards for agricultural products to pursue the goal of transitioning towards more sustainable food production and food processing. More specifically, the farm to fork strategy attempts to 'revise marketing standards to provide for the uptake and supply of sustainable agricultural, fisheries and aquaculture products and to reinforce the role of sustainability criteria taking into account the possible impact of these standards on food loss and waste.' Furthermore, the European Commission aims to update the marketing standards to make them compatible with the needs of stakeholders, the preferences of consumers and changes in technologies (European Commission, 2019, 2020b, 2021).

The European Commission carried out an evaluation of the current EU marketing standards in 2019. Although the evaluation found that EU marketing standards 'have generally been effective in achieving their intended objectives, without causing significant unintended/unexpected effect', it provides several recommendations and identifies some room for improvement. One recommendation refers to the cider sector and states that, despite the absence of EU marketing standards for the cider sector, the possible benefits of establishing such standards should be investigated (Areté and Agra CEAS Consulting, 2019; European Commission, 2020a).

The absence of EU marketing standards for cider implies that there is no harmonised definition of cider at EU level. However, at Member State level, there is great heterogeneity in the regulatory approach in the cider sector. Some Member States have no specific legislation on cider in place; among those that do, national standards differ significantly in terms of the definition of cider and the underlying minimum requirements for selling cider in a given national market. As a consequence, cider marketed in the EU can have very different characteristics, to such an extent that producers and/or consumers from some Member States do not consider certain products produced in other Member States to be 'real' cider. More importantly, the absence of harmonised standards may generate transaction costs, information asymmetries between operators in the cider sector and inefficiencies in coordination among operators in the cider supply chain. Furthermore, consumers are not always aware of differences in the relevant national legislation, and thus unharmonised standards may make consumers uncertain about the quality of the cider offered on the market. Hence, introducing EU-wide cider standards may 'level the playing field' between operators, as it would make the rules transparent and the same for all actors active in the sector, as well as potentially reducing consumers' purchase distortions. However, standards harmonisation may have some unintended effects, such as constraining adaptation in response to technology changes and to meet consumers' preferences. EU-wide standards may distort consumers' purchasing behaviour if the standards are inconsistent with consumer preferences. Although the literature suggests that the benefits of EU marketing
standards outweigh the costs, the actual benefits and costs may vary strongly across sectors depending on, among other things, the product type, production process, organisation of the food chain, concentration and existing private standards (Areté and Agra CEAS Consulting, 2019; Nes and Ciaian, 2021; Russo et al., 2022).

The objective of this report is to qualitatively assess the added value of introducing EU marketing standards in the cider sector, and their costs and benefits from socioeconomic, health and environmental perspectives. For this purpose, the report also analyses the current public and private marketing standards that operators in the cider sector apply in different Member States. The report provides the first results to disentangle the potential positive and negative impacts of introducing EU marketing standards in the cider sector. It also contributes to a better understanding of the potential implications of the European Commission policy initiative to revise EU marketing standards in the context of the farm to fork strategy (European Commission, 2021).

The analyses in this report are based on semi-structured interviews conducted with 22 stakeholders from the cider supply chain between 4 October and 17 December 2021. The majority of interviewed respondents represent companies producing cider or their associations (91 % of total respondents); one respondent represents a distributors' association and another an apple juice producers' association (9 %) (¹). Therefore, the analyses in this report are based primarily on information collected from the production stage of the cider supply chain. Furthermore, the report relies primarily on qualitative assessment because, as there are currently no EU marketing standards in the cider sector, it is not straightforward for stakeholders to quantify the perceived costs or benefits of introducing EU-wide marketing standards.

The rest of the report is organised as follows. Section 2 provides a brief description of the cider sector. Section 3 describes the methodology (i.e. semi-structured interviews). Section 4 outlines the respondents' characteristics. Section 5 presents the results split into two subsections: the first analyses the current private and public marketing standards, while the second analyses the implications of the potential introduction of EU marketing standards. Finally, Section 6 presents the conclusions of the report.

## 2 Brief description of the European cider sector

Cider is an alcoholic beverage obtained mainly from fermenting the juice of apples (²) (³), and historically has been produced and consumed in large quantities in a few European countries, such as Germany (⁴), Ireland, Spain and France. Furthermore, cider is mainly produced in specific areas of these traditional cider-making countries, usually those with large apple orchards. For example, in Spain, cider has for centuries been produced exclusively in the north of the country, from Galicia to the Basque Country. In France, the main traditional areas of production are Brittany and Normandy. In Germany, apple wine is mainly produced in the Hessen region. In each country, the specific rules and regulations for cider production are usually set by national governments and producer organisations.

Cider has been considered a local and even a seasonal drink for a long time in many countries (⁵). However, the cider sector has considerably evolved since the beginning of the 21st century, and is experiencing rapid growth. Although the cider market remains much smaller than the beer, wine or spirit markets, its average annual growth rate internationally was above 5 % between 2010 and 2019. During this period, the total volume produced worldwide increased from 1 861 million to 2 808 million litres (⁶) (Baker, 2021). The main cider producers in the EU are France and Spain (Areté and Agra CEAS Consulting, 2019). The most important markets in the EU are Spain, where total consumption in 2020 amounted to 94 million litres, followed by France and Germany, each accounting for about 65 million litres, and Poland and Ireland, both with consumption of slightly more than 60 million litres. In 2020, the highest per capita consumption in the EU was recorded in Ireland (12.1 litres), Finland (5.8 litres) and Spain (2.0 litres) (Table 1).

Two key factors explain the recent expansion of the cider sector. First, some flavoured alcoholic beverages sold as cider are emerging on the market. These products are a mix of apple juice, water and sugar, and can be flavoured after fermentation with

<footnote>(¹) Apple producers and consumers' associations are not represented in the sample.</footnote>

<footnote>(²) Perry or pear cider is an alcoholic beverage made by fermenting the juice of pears.</footnote>

<footnote>(³) Cider can be made from specific cider apples or other apple varieties.</footnote>

<footnote>(⁴) In Germany, the traditional beverage is apple wine (Apfelwein); German respondents view this as a different product from cider (see further).</footnote>

<footnote>(⁵) In France, cider was mainly consumed on the Epiphany, Candlemas and Shrove Tuesday.</footnote>

<footnote>(⁶) With the COVID-19 pandemic, the volume of cider produced reduced to 2 479 million litres, a level comparable to that of 2016.</footnote>
added fruit juices – such as cherry, strawberry, blackberry, blackcurrant – or other flavourings. Colourings or other additives are sometimes added. The fermented sugar can come from both the apple juice and the added sugar (usually glucose syrup). The apple juice content of this (flavoured) cider is usually lower than 50 %, and can be less than 25 % in the case of some brands and regions. These beverages are mainly targeted at the urban market and at young people. When these beverages do not comply with the standards and regulations established, where applicable, by national governments, they are marketed under the English term cider and not by their local regulated name (e.g. *sidra*, *cidre* or *Apfelwein*).

The 'sessionability' (the ability to drink a large amount of a beverage in a given time) of these new types of cider is greater than that of more traditional cider that is made from fermenting apple juice from special cider apples, and which is more tannic and astringent. Cider produced with a low content of apple juice, water and sugar is mainly produced by large multinational and national companies. Often, these companies were originally brewers and diversified their activities with the production of these new cider products, sometimes called apple beers. With large industrial companies entering the market, the cider sector is becoming increasingly globalised and the method of production has changed extensively over time (Lallemand, 2018). The sector is becoming more concentrated, with a few beverage companies producing the vast majority of the cider sold in Europe. Currently, the key factor that differentiates producers is size: a few large multinational companies operating in the beverage industry produce cider for mass consumption and a multitude of medium-sized and small cider producers produce traditional cider (with no water added to the cider, among other differences).

<table><caption>**Table 1: Main cider markets in Europe**</caption><thead><tr><td>Country</td><td>Compound annual growth rate over the 2015-2020 period (% change)</td><td>Volume consumed in 2020 (thousand hectolitres)</td><td>Consumption per capita in 2020 (litre/year)</td></tr></thead><tbody><tr><td>United Kingdom</td><td>-3.94</td><td>7 837</td><td>11.65</td></tr><tr><td>Spain</td><td>-1.59</td><td>949</td><td>2.01</td></tr><tr><td>France</td><td>-4.41</td><td>656</td><td>0.98</td></tr><tr><td>Germany</td><td>-0.72</td><td>652</td><td>0.78</td></tr><tr><td>Poland</td><td>9.98</td><td>635</td><td>1.66</td></tr><tr><td>Ireland</td><td>-0.80</td><td>600</td><td>12.06</td></tr><tr><td>Ukraine</td><td>24.66</td><td>331</td><td>0.75</td></tr><tr><td>Finland</td><td>-4.50</td><td>322</td><td>5.82</td></tr><tr><td>Russia</td><td>11.99</td><td>226</td><td>0.16</td></tr><tr><td>Czechia</td><td>21.15</td><td>206</td><td>1.93</td></tr><tr><td>Sweden</td><td>4.63</td><td>178</td><td>1.71</td></tr></tbody></table>

*Source: AICV and GlobalData (2022)*

The second factor explaining the rapid growth of the sector is the increasing demand for cider in eastern Europe. Between 2010 and 2020, the market grew by over 400 % in this region, increasing from 36 million litres in 2010 to 234 million litres in 2020 (Baker, 2021). Figure 1 shows the size and growth rate of the cider market in eastern Europe.
<figure><img src="image_6.png" /><figcaption>**Figure 1:** Cider markets in Eastern Europe</figcaption></figure>

NB: The x-axis shows the volume sold in 2020 in thousands of hectolitres. The column on the right-hand side of the figure shows the compound annual growth rate over the period 2015–2020.

Source: Baker (2021)

## 3 Methodology

The analyses in this report are based on information collected through semi-structured interviews with stakeholders (companies and associations) active in the EU cider supply chain. The purpose of the interviews was to collect relevant information about the existing marketing standards and to understand EU marketing standards' main potential implications for the cider sector. The interviews aimed to assess the perceived costs and benefits of introducing EU-wide standards from socioeconomic, health and environmental perspectives.

The interview guide consisted of 13 questions, organised into three sections. The questions in the first section aimed to elicit information about the organisation (company or association), in terms of the type and size of the business (or businesses they represent, in the case of associations) and country coverage. The second section comprised questions on the current public and/or private marketing standards applied by the organisation (company or the members of the association), and their related economic costs and benefits for the business. The last section collected information on the need to adjust the current standards or to introduce new marketing standards, their potential costs and benefits for the business and the impacts on socioeconomic, environmental and health sustainability. Respondents were also asked what they thought would be the appropriate level (Member State, EU or even international level) at which to apply these adjusted/new standards. The interview guide is provided in Appendix A.

The respondents' contact information was obtained through an intensive internet search. In total, 37 potential respondents were contacted, of whom 22 agreed to participate in the interviews, giving a response rate of 59%. The interviews were conducted between 4 October and 17 December 2021 using an online video conferencing tool. The majority of respondents (11) represented cider-producing companies. Of the remainder, nine were from associations representing the interests of or serving cider manufacturers, one was from an association representing the interests of distributors and one represented an apple juice producer association. The majority of those who did not respond were apple producers or represented consumers' associations and distributors. These groups may perceive marketing standards to be less directly relevant to them than they are to cider producers (and their associations). However, some of the respondents interviewed were vertically integrated and were involved in activities at more than one stage of the cider supply chain (i.e. some cider producers also produced apples).

The information collected through the interviews is based on convenience samples and is not representative of the underlying population. As mentioned above, to partially address the lack of representativeness and small sample size, we interviewed
several national and European cider associations, given that associations usually represent a larger number of companies (the members of the association). Regarding country coverage, the potential respondents were selected to include all geographical regions of the EU and cover the main EU cider-producing countries. Furthermore, potential respondents included companies of different sizes: from small (craft) cider producers to large cider companies. However, given that the majority of respondents are cider producers and their associations, the analyses conducted in this report are primarily based on information collected from this production stage and less so from other stages of the cider supply chain.

## 3.1 Analysis of the responses

The analyses in this report are based on the descriptive analysis of the collected information. To provide more structured analyses, we have also attempted to classify responses into group of answers or structured them in tables/figures.

The relatively small sample size prevents us from performing any exhaustive and robust statistical or econometric assessment of the collected information. The information collected through the interviews is primarily qualitative. We could not conduct quantitative (monetary) assessments, and we qualitatively elicited respondents' perceived costs and benefits of marketing standards in the cider sector. Furthermore, the elicitation of costs and benefits of EU marketing standards was particularly complicated given there are no established standards. Hence, the costs and benefits are not observed, but rather hypothetical or expected.

## 4 Respondents' characteristics

This section presents the characteristics of respondents who participated in the interviews. It describes the distribution of respondents according to stage in the cider supply chain in which they operate, business size and geographical location.

Table 2 shows the number of respondents according to their stage in the cider chain and their business size. Most respondents (20/22) represent the cider production stage; the other two respondents were from associations representing apple juice and concentrate producers and distributors. Among the 20 operators from the cider production stage, 11 were from companies or businesses producing cider and the remainder (9) were from associations that represent the interests of or provide services to cider producers. In terms of the size of cider producers (or the size of the members of the associations), 14 respondents are (or represent) small and medium-sized cider producers, 4 are (or represent) large-scale cider producers and two are associations covering different sizes of cider producers.

<table><caption>Table 2: Respondents by their stage in the cider sector and business size</caption><thead><tr><td>Type of respondent</td><td>Number of respondents</td><td>Number of associations</td></tr></thead><tbody><tr><td>Apple producers</td><td>0</td><td>0</td></tr><tr><td>Apple juice and concentrate producers and their associations</td><td>1</td><td>1</td></tr><tr><td>Cider producers and their associations</td><td>20</td><td>9</td></tr><tr><td>Small (craft) and medium-sized cider producers and their associations</td><td>14</td><td>6</td></tr><tr><td>Large-scale (multinational) cider producers and their associations¹</td><td>4</td><td>1</td></tr><tr><td>Cider producer associations representing businesses of all sizes</td><td>2</td><td>2</td></tr><tr><td>Wholesalers, retailers and their associations (distributors)</td><td>1</td><td>1</td></tr><tr><td>Consumers' associations</td><td>0</td><td>0</td></tr><tr><td>Total</td><td>22</td><td>11</td></tr></tbody></table>

<footnote>(1) A large-scale cider producer is defined here as a company owning several brands and producing and selling in several countries.</footnote>
In terms of geographic coverage (Table 3), the respondents interviewed come from 10 Member States (Denmark, Germany, Ireland, Spain, France, the Netherlands, Poland, Romania, Slovakia and Sweden). Among these countries, Spain is the most represented Member State, with six respondents, followed by France and Germany, with three respondents each. There are fewer than three respondents from each of the other seven Member States. One of the respondents interviewed was a European-level cider-related association. Multinational cider producers are present in several countries and thus the geographical coverage is greater than that indicated in Table 3.

<table><caption>Table 3: Respondents by Member State¹</caption><thead><tr><td>Member State</td><td>Number of respondents</td></tr></thead><tbody><tr><td>Denmark</td><td>2</td></tr><tr><td>Germany</td><td>3</td></tr><tr><td>Ireland</td><td>1</td></tr><tr><td>Spain</td><td>6</td></tr><tr><td>Netherlands</td><td>1</td></tr><tr><td>Poland</td><td>2</td></tr><tr><td>Romania</td><td>1</td></tr><tr><td>Slovakia</td><td>1</td></tr><tr><td>Sweden</td><td>1</td></tr><tr><td>European cider-related association</td><td>1</td></tr><tr><td>Total</td><td>22</td></tr></tbody></table>

(1) In the case of multinational companies, the respondent was considered to come from the Member State in which the company's headquarters is located.

# 5 Results

## 5.1 Current public and private marketing standards

### 5.1.1 What public and private marketing standards are in place?

This section provides analyses of the responses related to information on the private and public standards that the respondents (or their members, in the case of associations) currently apply – at national, European or international level – when producing or marketing cider.

According to the responses of the apple juice and concentrate producer association, companies from this stage of the cider supply chain must follow the European Fruit Juice Directive (European Parliament and Council, 2012), which applies to all drinkable fruit juices and defines basic standards of juice. The private and voluntary European Fruit Juice Association (AIJN) code of practice for the evaluation of fruit and vegetables juices is a complementary tool and is the reference guideline in the industry. This guideline gives the minimum and maximum values authorised for a range of important characteristics found in fruit juices. A company's compliance with the code of practice allows its juice to be classified as 'authentic'. The code applies to both semi-products (apple juice and concentrated apple juice, for example) and final products, which are the juices intended for direct human consumption. According to the information provided by respondents, the European directive and the private AIJN code complement each other and greatly facilitate trade between operators.

Based on the answers of the cider producers and their associations, Table 4 lists the main characteristics of the current public and private marketing standards in the cider sector in the respondents' countries covered by the survey. Among the 10 countries
covered, Germany and Ireland do not currently have (public or private) marketing standards for the production of cider, whereas Denmark has private standards only (⁷). The remaining seven countries have public standards in place (one has both public and private standards) (⁸).

In Germany, there are well-defined standards for apple wines and fruit wines, the former being very similar to the cider produced in Member States with strict standards, such as France and Spain. However, the German respondents made a clear distinction between their traditional apple wine and cider, which in Germany is a relatively new product (emerging only in the last 10 years in Germany, according to the German respondents) that is a mix of apple juice or apple wine and water. They are considered two separate beverages, competing in different segments of the market. According to the German respondents, the minimum apple juice content of 50 % is set in relation to the bottle deposit scheme in Germany (i.e. to avoid payment of a deposit on non-returnable bottles that applies if the apple wine/juice content is less than 50 %). In Ireland, which has no public standards, the respondent interviewed applies a private self-regulated Irish label, which is actually used by a dozen craft cider producers. As this label is used by very few cider producers, accounting for a relatively small proportion of the total volume of cider produced in Ireland, it is not included in Table 4. This private label requires the cider to be processed in Ireland, with 100 % fresh juice and without the addition of colourants. As seems to be the case in Belgium, Ireland classifies cider according to its alcohol content, which is used to calculate the amount of excise tax for cider.

In Denmark, a private voluntary standard proposed by the Danish Brewers' Association seems to be applied by the whole Danish cider industry. According to the respondents, the private standard was proposed and introduced 10 years ago, when the national definition of cider was removed from the Danish Fruit Juice Directive. Hence, the minimum private standards for cider were proposed as a response to the lack of regulation. Another important reason for setting minimum private standards in Denmark relates to fiscal regulations. Private standards were established in response to a tax on soft drinks introduced by the Danish government. The aim was to distinguish cider from soft drinks to prevent the latter from being sold under the label of cider in order to avoid the tax (which had previously been the case).

The other seven countries have public marketing standards but no major private standards (according to respondents from these countries). As shown in Table 4, national marketing standards can be distinguished by a few key elements that have a strong impact on the cider producers' production costs and the characteristics of the final cider products. The first two elements are the minimum apple juice content of cider (including fresh apple juice and/or concentrate) and the minimum fresh apple juice content of cider (excluding concentrate) (⁹). The minimum requirement for apple juice content (either fresh or concentrate) varies widely across the Member States covered: from close to 0 % in the Netherlands, where the requirement is not explicitly specified, to 100 % in Spain, France and Romania. Only France applies a mandatory minimum fresh apple juice content (50 %). Nevertheless, marketing cider under specific labels in Spain and France (i.e. *sidra natural* in Spain or *cidre pur jus* in France) requires 100 % fresh juice. According to respondents, the minimum requirement for apple juice content has the largest impact on production costs and on the final characteristics and taste of the product.

The third key element of public marketing standards is the option of adding water to the cider before and/or after fermentation. The ability to add water before fermentation is strongly linked to the juice content; for example, if a cider is 50 % apple juice, it is highly likely that the other 50 % is actually water. Hence, as confirmed in Table 4, when the apple juice content can be below 100 %, it is always possible for cider producers to add water before and after fermentation – with the exception of Poland, where water can be added only before fermentation.

The last important element of public marketing standards is the possibility of adding sugar (usually glucose syrup) before (¹⁰) and/or after fermentation. Similarly to water, the marketing standards allow the use of sugar before and after fermentation when the minimum content of apple juice is lower than 100 % (e.g. sugar is added before fermentation to achieve a sufficient alcohol level in the cider). In the countries with a minimum apple juice content of 100 %, sugar can be added after fermentation only.

<footnote>(⁷) The German respondents made a distinction between *Apfelwein*, for which public standards are well established, and cider, which is considered a different beverage (see below).</footnote>

<footnote>(⁸) Note that the presence of private cider standards in the covered Member State may be more widespread than presented in this report. The information provided on private standards in this report is based solely on information received from respondents.</footnote>

<footnote>(⁹) Fresh apple juice is the juice obtained from the crushing and pressing of apples. Apple juice from concentrate is produced by evaporating the water from the pressed apple juice; it is reconstituted by the cider producer by adding water.</footnote>

<footnote>(¹⁰) Chaptalisation is the addition of sugar during fermentation to increase the level of alcohol.</footnote>
Overall, standards differ widely between Member States, which leads to the production and marketing of cider with very diverse characteristics and with different production costs across the EU. According to the elements considered in Table 4, (private and public) marketing standards can be categorised into two types in terms of their level of stringency: (i) 'light' (minimum apple juice content is less than 100 %) or (ii) 'strict' (minimum apple juice content of 100 %). Spain, France and Romania have strict standards, whereas Denmark, the Netherlands, Poland, Slovakia, and Sweden have light standards (their minimum apple juice content is between 15 % and 60 %). Germany is unique in that there are no public standards for cider, but the regulation of apple wine is strict: it must have an apple juice content of 100 %, and there is no possibility of adding water or sugar (sugar can be added before fermentation only in years when the sugar content of the apples is too low to reach 5 % alcohol by volume). According to the three German respondents, cider producers in Germany are in favour of light public standards for cider (as part of the legislation on apple wine and fruit wine), especially because it is easy for consumers to distinguish apple wine from cider (the German labels are quite different). Based on information obtained from respondents on some of the Member States not covered by the survey, Czechia, Greece and Finland have light public standards (e.g. in Greece, the minimum apple juice content is 51 %), whereas Belgium and Bulgaria do not have public marketing standards.

Other elements are sometimes part of marketing standards, such as the possibility of adding carbon dioxide (CO2); the prohibition of the addition of alcohol (fortification); the minimum and maximum alcohol content; and the use of flavourings, colourants and other additives. These elements are not listed in Table 4 either because they are similar in all national marketing standards (e.g. the possibility of adding CO2, the prohibition of the addition of alcohol) or because they have a much smaller impact on the cider production costs and the final quality of the product than the main elements mentioned.

In France and Spain, where strict standards are applied, cider must be classified according to the residual sugar content. For example, it can be sweet, semi-dry, dry or brut. The exact names of the categories and the range of residual sugar content that define each category differ slightly between countries (see Appendix B for a comparison). In addition, in France and Spain, not only do the public marketing standards define the minimum requirements for each cider category, but special official labels identify quality and origins (EU quality schemes) such as protected designation of origin (eight in France and two in Spain) and protected geographical indications (two in France).

National public cider standards have recently been introduced in some Member States, and in others have been amended to account for new types of cider, such as flavoured cider. For example, in Poland, a new national regulation awaiting approval provides for a more flexible approach that allows the production of flavoured cider. If adopted, the new standards will add a new cider category ('quality' cider) with a minimum apple juice content of 80 %, but no possibility of using concentrate: that is, cider with a minimum apple juice content of 60 % (as set in the current public standards) will be labelled 'normal' cider (Table 4), while 'flavoured' cider will require a minimum apple juice content of 80 % and can contain up to 20 % other fruit juice (e.g. strawberry, blackberry). In Slovakia, the first legislation on cider was introduced in 2014; before that, there were no public marketing standards. In Romania, strict standards were adopted in 2015 and, according to respondents, they seem to have been set following the cider standards in France. In Spain, public marketing standards were amended in 2017 to consider flavoured cider (sidra con zumo de frutas, sidra aromatizada). In Germany, as mentioned above, some stakeholders are lobbying to set marketing standards on cider that would be different from those for traditional apple wine.

It should be noted that regulations in other areas of the food and beverages sector can affect the cider sector (including in Member States with no cider-specific standards). For example, the alcohol tax on spirits affects the tax classification of cider (four respondents), and the general food law on labelling (one respondent). According to one respondent, 16 Member States do not impose an alcohol tax on cider, while the rest do.

Regarding private standards, besides the Danish and Irish cases discussed above, other private standards are applied in the cider sector. One respondent representing a large cider company reported that the company has its own standards regulating the minimum apple juice content (25 %). In addition, two respondents stated that they use the International Featured Standards, which cover the production processes the company uses along the supply chain.

Finally, it is interesting that all small cider producers interviewed use 100 % apple juice (sometimes only fresh juice) in their cider production, even in countries with minimum apple juice requirements lower than 100 %, whereas larger producers usually use a significantly lower apple juice content (between 15 % and 60 %).
<table><caption>Table 4: Public and private marketing standards by Member State</caption><thead><tr><th>Member State</th><th>Type of marketing standards</th><th>Minimum apple juice content (fresh or concentrate) (%)</th><th>Minimum fresh apple juice content (%)</th><th>Addition of water before/after fermentation</th><th>Addition of sugar before/after fermentation</th><th>Global level of stringency</th></tr></thead><tbody><tr><td>Denmark</td><td>Private</td><td>15</td><td>0</td><td>Permitted before and after</td><td>Permitted before and after</td><td>Light</td></tr><tr><td>Germany</td><td>None<sup>2</sup></td><td>Not specified</td><td>0</td><td>Permitted before and after</td><td>Permitted before and after</td><td>Light</td></tr><tr><td>Ireland</td><td>None</td><td>Not specified</td><td>0</td><td>Permitted before and after</td><td>Permitted before and after</td><td>n/a</td></tr><tr><td>Spain</td><td>Public</td><td>100</td><td>0</td><td>Permitted after<sup>3</sup></td><td>Permitted after</td><td>Strict</td></tr><tr><td>France</td><td>Public<sup>1</sup></td><td>100</td><td>50</td><td>Permitted for rémiage only (before)</td><td>Permitted after</td><td>Strict</td></tr><tr><td>Netherlands</td><td>Public</td><td>Not specified</td><td>0</td><td>Permitted before and after</td><td>Permitted before and after</td><td>Light</td></tr><tr><td>Poland</td><td>Public</td><td>60</td><td>0</td><td>Permitted before</td><td>Permitted before and after</td><td>Light</td></tr><tr><td>Romania</td><td>Public</td><td>100</td><td>0</td><td>Not permitted</td><td>Permitted after</td><td>Strict</td></tr><tr><td>Slovakia</td><td>Public</td><td>25</td><td>0</td><td>Permitted before and after</td><td>Permitted before and after</td><td>Light</td></tr><tr><td>Sweden</td><td>Public</td><td>15</td><td>0</td><td>Permitted before and after</td><td>Permitted before and after</td><td>Light</td></tr></tbody></table>

NB: n/a, not applicable.

### 5.1.2 Economic costs and benefits of the current public and private marketing standards

This section summarises the economic costs and benefits of existing public and private marketing standards as provided by respondents. However, given that most respondents apply public markets standards, the economic costs and benefits described in this section primarily refer to the existing public marketing standards that are in place in the Member States covered. Most respondents were unable to quantify the costs and benefits of the adoption and implementation of their current marketing. This is probably explained by the fact that most respondents did not experience the counterfactual situation before the current marketing standards, which would have allowed them to compare the situation before and after the adoption. Instead, respondents qualitatively identified several types of costs and benefits related to the adoption and implementation of the current marketing standards. The respondents' responses regarding their perceived economic benefits and costs of the current marketing standards are summarised in Figure 2 and Figure 3, respectively. The figures provide the share of respondents by type of identified benefits and costs, indicating whether they refer to firms or consumers, and whether they concern all types of marketing standards, strict standards or light standards.

#### Economic benefits

From the respondents' responses, we have identified several types of benefits related to the implementation of the current marketing standards in the Member States covered.

First, marketing standards reduce transaction costs and facilitate the functioning of the cider supply chain by contributing to a more transparent domestic market (four respondents). They make negotiation and trade between agents in the supply chain in the domestic market easier (facilitating business-to-business transactions and relationships), as they provide a common definition of cider (three respondents). That is, the standards reduce transaction costs by ensuring that the product bought or sold conforms to common expectations. This was also mentioned in relation to the AIJN code of practice for juice production, suggesting that the code facilitates trade as it ensures the quality of juice for the buyers (cider producers) (one respondent).

<footnote>(1) In France, the *rémiage* technique can be used, which consists of adding some water to the pulp obtained from the first press to achieve a second press.</footnote>

<footnote>(2) The German standards refer to cider and not to apple wine, which is a traditional beverage in Germany, very similar to the French *cidre* or Spanish *sidra*, that must follow strict marketing standards. According to German respondents, there are no official standards (neither public nor private) in place in Germany; 'cider' is merely a marketing name used by most cider producers.</footnote>

<footnote>(3) Only for some types of cider.</footnote>
Furthermore, marketing standards have the potential to reduce unfair trading practices and unfair competition because they ensure that all competing companies operate on the same level playing field in a given Member State (five respondents).

From a consumer's perspective, marketing standards ensure a minimum quality for the cider offered on the domestic market (five respondents). They provide consumers with better information and more efficient communication about the cider's quality (three respondents), and reduce the potential for misleading information related to the production of cider (six respondents).

Other benefits of marketing standards identified by respondents include the fact that they provide clarity for taxation purposes (e.g. excise tax) (one respondent), or impede the sale of soft drink or any other non-cider beverage under the label of cider (e.g. to avoid paying certain taxes such as those on soft drinks in Denmark, as discussed previously) (one respondent)

Some benefits expressed by respondents refer to specific stringency levels of marketing standards. Respondents identified the following benefits of strict marketing standards:

* they support national craft cider producers, which usually use 100 % apple juice content (two respondents);

* they contribute to the preservation of the traditional way of producing cider (one respondent);

* a high minimum (fresh) apple juice content in cider production supports local and EU apple producers and the local agricultural sector (five respondents);

* they ensure higher selling prices for cider with a higher apple juice content (two respondents).

Respondents identified the following benefits specific to light marketing standards:

* they foster innovation, which contributes to the steady growth of the cider sector (three respondents);

* given the heterogeneity of existing standards across Member States, they facilitate trade, as they impose minimum requirements for apple juice content on the cider that can be imported from other Member States (one respondent);

* they allow consumers to have access to a larger variety of cider products (i.e. they facilitate product differentiation) (one respondent).

Overall, the summary statistics in Figure 2 show that the benefits most frequently identified by respondents for all types of standards are a reduction in transaction costs, facilitation of the functioning of the cider market and avoiding misleading consumers. Other frequently mentioned benefits for all types of standards include reducing unfair trading practices / competition, avoiding the labelling of other types of drinks as cider, ensuring minimum cider quality, providing better information and communication to consumers; supporting apple producers was frequently mentioned as a benefit of strict standards.

## Economic costs

Respondents identified some costs related to the implementation and adoption of marketing standards in a Member State. The results from the interviews suggest that cider producers perceive the cost of complying with the existing marketing standards to be marginal or non-existent. However, two respondents from Member States with strict standards deemed the compliance costs to be high, but considered them a normal part of business; that is, the compliance costs can be considered part of the production cost of making cider.

Multinational producers whose products have a low apple juice content, that is, they produce cider in Member States with light standards, consider the costs of implementing the existing standards insignificant. It would be more costly for these companies if they were required to comply with stricter standards than those they currently apply, suggesting a significant difference in the costs of implementing light and strict standards (one respondent).

Costs often mentioned by respondents related to EU trade, with respondents stating that the heterogeneity of national marketing standards hampers intra-EU trade in particular, given the fact that the rules are not transparent and vary by Member State (seven respondents).

Respondents identified several costs specific to strict marketing standards.

* Cider producers from Member States with strict marketing standards may face unfair competition / trading conditions. First, cider producers in Member States with strict marketing standards are less competitive than producers in Member States with less strict standards because their production costs are higher (two respondents). Thus, the export market is more difficult for cider producers that must adhere to strict marketing standards. Second, for the same reason,
cider producers in Member States with strict marketing standards are less competitive in their home market than cider producers from Member States with light standards (seven respondents). For example, in Romania, 80 % of the cider sold on the market comes from Bulgaria, where light marketing standards are in place (one respondent). One respondent observed a similar finding (but affecting a smaller share of imported cider) in Spain. However, cider imported into Spain that does not comply with current national legislation cannot be marketed under the local regulated name (*sidra*), but is marketed under the English term.

* Some respondents stated that strict marketing standards can restrict the capacity for innovation in the sector, jeopardising the possibility of adjusting cider to consumers' demands. The standards' adverse effect on the cider sector could result in consumers replacing cider with alternative products (e.g. beer) (three respondents). For example, one respondent argued that strict regulations are the reason for the lack of growth of the cider sector in France. This respondent stated that the cider sector is small in Romania for the same reason, whereas in Czechia, which has light regulation, the cider sector's growth is stronger.

* They reduce product differentiation, or increase the homogeneity of the cider produced and sold in a given Member State (two respondents).

* They cause higher production costs because of the higher fresh juice content, thus potentially making cider more expensive. As a consequence, consumers may switch to substitute products (e.g. beer) (three respondents).

* One respondent argued that, to protect the domestic market, some Member States with strict standards (e.g. France, Spain) have in place other regulations (e.g. excise tax on imported cider) for cider that work to reinforce national standards.

Figure 3 shows that the costs of national marketing standards most frequently identified by respondents are the heterogeneity of national marketing standards, which hampers intra-EU trade (for all types of standards), and the unfair trading and competition that cider producers face in Member States with strict standards.
<figure><img src="image_7.png" /><figcaption>Figure 2: Respondents' perceived benefits of national marketing standards</figcaption></figure>

NB: The percentages do not sum to 100 % because respondents could indicate more than one benefit.
<figure><img src="image_8.png" /><figcaption>Figure 3: Respondents' perceived costs of national marketing standards</figcaption></figure>

NB: The percentages do not sum to 100 % because respondents could indicate more than one cost.
## 5.2 Introducing EU marketing standards

Respondents were asked to express their opinions on the need to adjust the current marketing standards or to implement new ones. Regarding new marketing standards, the respondents were asked (i) whether the standards should be public or private, and (ii) at what level they should be introduced (i.e. international, EU or Member State level).

None of the respondents thought it appropriate to introduce international marketing standards for the cider sector, but all of the respondents interviewed who stated that existing marketing standards should be adjusted or new standards introduced also suggested the EU was the most suitable level at which to do this. Some respondents indicated that the existing national standards should be adjusted to address specific aspects (e.g. the introduction of new/additional grading of cider). Overall, out of the 22 respondents, only one did not support the introduction of EU-level standards. Moreover, all 21 respondents in favour of EU standards opted for public standards.

However, although the respondents agreed that the introduction of EU standards has the potential to add value, they differed in their preferred level of stringency of the potential EU standards. Respondents' preferences regarding the appropriate stringency level of standards can be considered to fall into three categories: (i) strict minimum requirements, (ii) light minimum requirements or (iii) no minimum requirements (¹¹). Furthermore, respondents differ in their preferences regarding the introduction of ORTs. The criterion we use to differentiate the three levels of stringency for standards is based on the minimum content of apple juice required to be able to market the beverage as cider in the single market. We consider respondents to be in favour of strict standards if they prefer a minimum apple juice content of 100 % in cider, whereas they are considered in favour of light standards if they prefer a minimum that is less than 100 % but at least 15 %. Finally, the third group (standards with no minimum requirements) comprises those respondents who prefer standards that do not specify a minimum apple juice content in cider (¹²). This group could be considered respondents in favour of 'very light' standards, as cider producers would be free to sell any product as cider provided it contains some level of apple juice (¹³).

Table 5 shows respondents' preferences for EU-wide marketing standards structured by respondents' Member State. Overall, out of 22 respondents, 10 are in favour of strict minimum requirements, seven favour light minimum requirements and three favour standards with no minimum requirements. Of the remaining two respondents, one expressed no opinion on the issues and one does not support the introduction of EU-wide standards. In addition, 18 respondents are in favour of introducing ORTs. The results in Table 5 seem to indicate a 'status quo bias' in respondents' preferences. The respondents from Member States with light national standards in place prefer less strict EU-wide minimum requirements, whereas the reverse is true for respondents from Member States with strict existing standards. This result is to be expected because EU-wide standards that are similar to the existing national standards minimise companies' (production and marketing) adjustment costs if the new standards were introduced.

Table 6 shows respondents' preferences for EU-wide marketing standards according to their profile (stage in the cider supply chain and size of the business). The key result from this table is not the relative proportion of respondents in favour of different stringency levels for the standards, since our sample is not representative; rather, it is the fact that the choice between different stringency levels for the standards is largely influenced by the profile of the cider producers. The majority (9 out of 14) of respondents from small and medium-sized cider producers (or their representative associations) are in favour of strict minimum requirements. Hence, small and medium-sized and craft cider producers usually prefer the introduction of more ambitious EU marketing standards with a minimum fresh juice content of 100 %. All the large-scale cider producers (or their representative associations) are in favour of either light minimum requirements (three respondents) or standards with no minimum requirements (one respondent). Of the cider producer associations covering all business sizes, one prefers standards with no minimum requirements and the other is against the introduction of any type of EU marketing standards.

<footnote>(¹²) Note that none of the respondents said that they would prefer a minimum apple juice content of less than 15 %.</footnote>

<footnote>(¹³) Respondents in favour of EU marketing standards that do not specify any minimum apple juice content also prefer to restrict the possibility of adding exogenous alcohol to cider (see below).</footnote>
<table><caption>Table 5: Respondents' preferences for EU-wide marketing standards and their level of stringency, by Member State</caption><thead><tr><th rowspan="3">Member State</th><th rowspan="3">Total number of respondents</th><th rowspan="3">Current standards</th><th colspan="5">Number of respondents supporting EU-wide standards</th><th rowspan="3">Number of respondents not supporting EU-wide standards</th></tr><tr><th colspan="4">Minimum requirement</th><th rowspan="2">Support ORTs¹</th></tr><tr><th>Strict</th><th>Light</th><th>None</th><th>No opinion</th></tr></thead><tbody><tr><td>Denmark</td><td>2</td><td>Light</td><td>0</td><td>0</td><td>1</td><td>0</td><td>0</td><td>1</td></tr><tr><td>Germany</td><td>3</td><td>Light</td><td>0</td><td>3</td><td>0</td><td>0</td><td>3</td><td>0</td></tr><tr><td>Ireland</td><td>1</td><td>None</td><td>1</td><td>0</td><td>0</td><td>0</td><td>1</td><td>0</td></tr><tr><td>Spain</td><td>6</td><td>Strict</td><td>4</td><td>0</td><td>1</td><td>1</td><td>6</td><td>0</td></tr><tr><td>France</td><td>3</td><td>Strict</td><td>3</td><td>0</td><td>0</td><td>0</td><td>2</td><td>0</td></tr><tr><td>Netherlands</td><td>1</td><td>Light</td><td>0</td><td>1</td><td>0</td><td>0</td><td>1</td><td>0</td></tr><tr><td>Poland</td><td>2</td><td>Light</td><td>1</td><td>1</td><td>0</td><td>0</td><td>2</td><td>0</td></tr><tr><td>Romania</td><td>1</td><td>Strict</td><td>1</td><td>0</td><td>0</td><td>0</td><td>1</td><td>0</td></tr><tr><td>Slovakia</td><td>1</td><td>Light</td><td>0</td><td>1</td><td>0</td><td>0</td><td>1</td><td>0</td></tr><tr><td>Sweden</td><td>1</td><td>Light</td><td>0</td><td>1</td><td>0</td><td>0</td><td>0</td><td>0</td></tr><tr><td>European association</td><td>1</td><td>n/a</td><td>0</td><td>0</td><td>1</td><td>0</td><td>1</td><td>0</td></tr></tbody><tfoot><tr><td><strong>Total</strong></td><td><strong>22</strong></td><td></td><td><strong>10</strong></td><td><strong>7</strong></td><td><strong>3</strong></td><td><strong>1</strong></td><td><strong>18</strong></td><td><strong>1</strong></td></tr></tfoot></table>

n/a, not applicable.

Among the three respondents who support standards with no minimum requirements, one is a medium-sized cider producer that is in favour of ORTs at EU level only, while the two other respondents prefer to define cider in general terms only. They propose defining cider as 'an alcoholic drink fermented from apple and/or pear, made from concentrate or fresh juice, with or without addition of water and sugar. This product can be flavoured (addition of fruit juice other than apple and pears).' This definition does not require a minimum apple juice content and is expected to have a minimal impact on the producers' current cider production processes. The key restriction in this definition is that it prevents cider producers from adding distilled alcohol to the cider. Of the large-scale cider producers and their associations, three support EU standards with a minimum apple juice content (one suggested 15%, one suggested 25% and the third suggested 60%), while one is in favour standards with no minimum requirements. All the large-scale producers interviewed are in favour of light minimum requirements or standards with no minimum requirements, as, in their opinions, these facilitate trading cider across the whole EU without causing an impact on production process and marketing (e.g. without the need to adjust the label of cider products depending on the destination Member State) (¹⁴).

The apple juice and concentrate producers association prefers strict minimum requirements because this would support apple producers and juice processors. The association representing the interests of distributors is in favour of EU-wide standards but did not provide preferences for specific elements of the standards.

If we examine preferences regarding ORTs, 18 out of the 21 respondents that support the introduction of EU standards are in favour of introducing ORTs at EU level to categorise cider according to some attributes/characteristics (¹⁵). They support EU-level ORTs primarily because they perceive them as a relevant tool for reducing the misleading of consumers and avoiding the misuse of various claims and labels (e.g. pure juice, fresh juice, premium cider). Overall, three respondents do not support EU-level ORTS, although they do agree on the need for EU marketing standards. Of these, two represent large-scale cider producers (or their

<footnote>(¹⁴) Their preference is also to reduce excise duties on or exempt from excise duties on all cider including on cider that does not meet the standards of the country in which it is sold.</footnote>

<footnote>(¹⁵) The respondent that is not in favour of introducing EU standards (i.e. does not support adopting minimum requirements for juice content in cider) is more open to discussing the possibility of having ORTs at EU level.</footnote>
representative associations), one of whom prefers EU standards without minimum apple juice content requirements, while the other supports a regulation with a minimum apple juice content of 15 %. The third respondent (one of the small and medium-sized cider producers or their associations), while agreeing that EU marketing standards should be in place, does not consider an alcoholic beverage with less than 100 % fresh apple juice content to be a cider product (and was of the opinion that such a product should be prohibited from being labelled as cider). Hence, this respondent is against the introduction of ORTs for cider with less than 100 % fresh apple juice content.

All the respondents who support introducing EU-level ORTs proposed a categorisation of cider based on apple juice content and/or residual sugar content.

One of the two large-scale cider producers in favour of ORTs did not propose specific ORTs, while the other suggested several ORTs, such as cider categorisation based on the residual sugar (sweet, semi-dry, dry, extra-dry, etc.) or the use of claims such as 'pure juice cider' (cider with 100 % apple juice content with no sugar added before fermentation), 'fresh juice cider' (cider made with fresh apple juice only) or 'premium cider' (cider with at least 51 % apple juice content).

Out of the 13 small and medium-sized cider producers (or their representative associations) in favour of ORTs, four proposed having three categories of cider along the following lines:

* cider made from fresh juice: cider made from fresh apple juice only, without no water, sugar, syrup or flavourings added prior to the fermentation process,

* cider made from 100 % apple juice (or pure apple juice): cider made from 100 % apple juice (fresh or concentrate), with no water, sugar, syrup or flavourings added prior to the fermentation process,

* generic cider: all other types of cider.

Two other medium-sized cider producers proposed a similar categorisation of cider and additionally suggested the category of flavoured cider for cider that is flavoured after fermentation. Furthermore, three medium-sized cider producers proposed placing mandatory categories on the label (front or back) according to the percentage of apple juice content in the cider. For example, one medium-sized cider producer proposed differentiating between a 'real cider' with 100 % apple juice content and a 'half-cider' with 50 % apple juice content. Another respondent suggested indicating the exact percentage of apple juice in the cider on the label.

The apple juice and concentrate producer association interviewed is also in favour of introducing ORTs that are defined based on apple juice content. All the other respondents in favour of ORTs did not propose any specific ORTs, but stated that the percentage of apple juice content is an important element to consider when defining ORTs.

We observed some small differences in preferences across large-scale (industrial) cider producers. Some industrial cider producers, particularly those from Scandinavian Member States, support only standards with no minimum requirements (one respondent) or light standards with a 15 % minimum content of apple juice or would even prefer no EU-level marketing standards (one respondent). In addition, they are not in favour of introducing ORTs. Other industrial producers are supporting somewhat higher minimum apple juice content: 25 % (one respondent) or even 60 % (one respondent). These industrial producers also support the introduction of ORTs at EU level.

Finally, according to one respondent, EU marketing standards should be set for fruit wines, but they should be separate from the EU cider standards (if adopted) because the respondent claims the two are different products.

Overall, the results reveal a relatively high level of heterogeneity in stakeholders' preferences, suggesting that there may be difficulties in finding a common ground regarding the specifications of the potential EU-wide marketing standards. The vast majority of respondents support the introduction of EU-wide marketing standards, but the respondents differ in their preferences for the type of standards (i.e. levels of stringency). Respondents are well aware of this heterogeneity: 12 of them acknowledged the difficulty of introducing standards at EU level, mainly due to the relatively large variety in existing national standards, and the very heterogeneous preferences, marketing strategies and production processes present among cider producers in the EU.
<table><caption>Table 6: Respondents' preference for EU-wide marketing standards and their level of stringency by respondents' stage in the cider supply chain and business size (number of respondents)</caption><thead><tr><th rowspan="3">Stage in the cider sector</th><th colspan="5">Respondents supporting EU-wide standards</th><th rowspan="3">Respondents not supporting EU-wide standards</th></tr><tr><th colspan="4">Minimum requirement</th><th rowspan="2">Support ORTs</th></tr><tr><th>Strict</th><th>Light</th><th>None</th><th>No opinion</th></tr></thead><tbody><tr><td>Apple juice and concentrate producers and their associations</td><td>1</td><td>0</td><td>0</td><td>0</td><td>1</td><td>0</td></tr><tr><td>Cider producers and their associations</td><td>9</td><td>7</td><td>3</td><td>0</td><td>16</td><td>0</td></tr><tr><td>Small (craft) and medium-sized cider producers and their associations</td><td>9</td><td>4</td><td>1</td><td>0</td><td>13</td><td>0</td></tr><tr><td>Large-scale (multinational) cider producers and their associations</td><td>0</td><td>3</td><td>1</td><td>0</td><td>2</td><td>0</td></tr><tr><td>Cider producer associations covering all business sizes</td><td>0</td><td>0</td><td>1</td><td>0</td><td>1</td><td>1</td></tr><tr><td>Wholesalers, retailers and their associations (distributors)</td><td>0</td><td>0</td><td>0</td><td>1</td><td>1</td><td>0</td></tr><tr><td><strong>Total</strong></td><td><strong>10</strong></td><td><strong>7</strong></td><td><strong>3</strong></td><td><strong>1</strong></td><td><strong>18</strong></td><td><strong>1</strong></td></tr></tbody></table>

### 5.2.1 Economic costs and benefits of EU marketing standards

As described above, there is a high level of heterogeneity of national marketing standards across Member States. In this section, we summarise the respondents' responses regarding the perceived costs and benefits that adopting EU marketing standards may imply for their businesses. It is important to note that the benefits and costs indicated by respondents correspond to their preferred (type and stringency of) EU-wide marketing standards. This implies that the actual costs and benefits may be different if EU standards are eventually established, as the new standards may differ from respondents' preferences.

As for the existing national marketing standards, respondents were unable to quantify the costs and benefits of introducing EU marketing standards. Therefore, this section qualitatively assesses the costs and benefits of potentially introducing EU marketing standards, as reported by respondents.

#### Economic benefits

One of the overall benefits of EU marketing standards mentioned by several respondents is the standards' potential to reduce transaction costs and improve the functioning of the cider supply chain through:

* increasing transparency by providing all market participants with a common understanding of what cider is (one respondent);

* facilitating business-to-business transactions and relationships (e.g. for distributors and retailers) (three respondents);

* reducing barriers to trade (four respondents).

Several respondents suggested that, by levelling the playing field, EU marketing standards may have implications for the fairness of competition in the sector. Given the heterogeneity of the existing national marketing standards, their harmonisation at EU level may lead to a reduction in unfair competition both with cider imported from non-EU countries and among EU cider producers. The potential benefit of reducing unfair competition with non-EU cider was suggested by four respondents.

Unfair competition among EU cider producers was the most common benefit of EU-wide standards suggested by respondents. First, findings from the interviews indicate that EU-wide standards may reduce 'regulation arbitrage' by eliminating (or reducing) the variation of rules among the existing national standards (five respondents). Regulation arbitrage is when a (multinational) cider producer produces cider in Member States with light (or no) standards and sells it in Member States with strict standards under a different label (usually as 'cider' instead of the nationally regulated label). This behaviour results in regulation-induced differentiation of cider products (eight respondents). The potential for EU standards to address the problem of regulation
arbitrage was expressed mainly by respondents from Member States with strict standards or craft cider producers from countries
with light standards.

Regulation-induced differentiation implies that at least two types of cider products are marketed in some Member States with strict standards: (i) cider following the national regulations and (ii) cider not following the regulations. Usually, the two cider types are distinguished through labelling on the front packaging. For example, in Spain, cider that meets Spanish standards is labelled as *sidra*, whereas cider that does not follow national standards is labelled as cider. In France, regulated cider is labelled as *cidre*; the term 'cider' is used for unregulated cider. In Germany, the regulated apple wine is distinguished from the unregulated cider, which is labelled as cider (eight respondents). A similar situation occurs in Romania, which has strict standards in place and where the majority of the cider sold on the market comes from Bulgaria, which implements light marketing standards (one respondent). Note that unregulated cider varieties are not necessarily the only ones imported from other Member States.

As a result, to remain competitive some domestic cider producers from Member States with strict standards offer cider in both market segments (i.e. regulated and unregulated) with either the same or different content of apple juice. One Spanish cider producer reported selling cider products labelled as both *sidra* and cider on the Spanish market, but the products have the same/similar contents of apple juice (as required by Spanish standards). In Germany, the market segmentation is between *Apfelwein* and cider. However, German consumers are expected to be able to distinguish between the traditional *Apfelwein*, which is made of 100 % apple juice, and the cider made with a much lower content of apple juices because the German label and the 'international' labels are very different. This seems to avoid the risks of unfair competition and misleading consumers because cider is not perceived as competing in the same segment of the market as *Apfelwein* (three respondents) (¹⁶).

Second, regulation arbitrage may also occur in Member States with light standards that still have more stringent standards than other Member States. For example, according to one respondent, in Poland, cider produced in other Member States can be sold on the Polish market under the nationally recognised cider label even if it has lower apple juice content than the minimum content specified in the Polish standards (i.e. 60 %), as long as it follows the national standards of the importing Member State. However, domestically produced cider cannot be called cider if it is not produced in line with the national rules (one respondent).

A third type of 'regulation arbitrage' that could be addressed by EU standards is the practice, implemented by some large companies, of categorising a beverage product in different ways (e.g. labelling it as cider or as beer) in different markets in order to exploit the heterogeneity of rules across Member States. For example, in Poland, a ban on advertising cider products combined with a lower excise tax on beer led some industrial producers to label a product as beer despite it usually being sold as cider in other Member States (one respondent).

Overall, eliminating regulation arbitrage opportunities through the introduction of EU standards may address two types of distortions. First, it may reduce the possibility of some cider producers circumventing stricter rules by producing cider in less regulated Member States in order to minimise regulatory burdens. Second, the EU marketing standards may reduce consumers' confusion, as cider products originating from different Member States will follow the same rules and thus will be labelled in the same / a similar way.

How the EU standards actually eliminate regulation arbitrage will depend on the type of standards established. Introducing strict EU standards will prevent regulation arbitrage completely, whereas light EU standards will remove the need for regulation arbitrage, as all Member States would then have light standards.

It is important to note that, although regulation arbitrage and the regulation-induced differentiation of cider products may be perceived as distortive, they can also be understood as a strategy for firms to bypass the strict standards and offer cider varieties not allowed by some national standards (potentially reducing the strict standards' adverse effect on innovation, allowing them to adapt varieties to consumers' demands and reducing production costs).

Furthermore, EU marketing standards may address potential unfair competition from substitute beverages. For example, according to one respondent, sparkling alcoholic drinks containing fermented sugar have recently emerged on the EU market. If these drinks use a small quantity of fermented apple juice, they could, in principle (in some circumstances), be labelled as cider in the absence of EU standards (one respondent).

<footnote>(¹⁶) This is also one of the main reason why the German respondents prefer light EU standards for cider.</footnote>
Introducing EU standards may also reduce the unequal treatment of imported cider under other national regulations. For example, cider that does not follow the national marketing standards could be currently assigned different rates of excise duty when imported from other Member States, if the cider falls into a different taxation group from domestically produced cider (one respondent).

With respect to consumers, respondents suggested that EU marketing standards may communicate information about the cider quality more effectively to consumers through product labelling and/or they may avoid misuse of claims and labels. The standards are expected to reduce the problem of misleading consumers in relation to the applied production process of cider marketed in the EU. This was expressed mainly by respondents producing cider with high levels of apple juice content (nine respondents). Thus, EU marketing standards are largely perceived by respondents as a tool for reducing consumers' uncertainty over the attributes and quality of cider marketed in the EU.

Potential benefits suggested by respondents that are specific to strict EU marketing standards are that they may support local and EU apple producers, and local cider producers if a high minimum (fresh) apple juice content is set (six respondents). One respondent stated that establishing strict EU standards could limit the 'power' of the industrial cider producers.

Regarding the benefits related to light EU marketing standards, some respondents suggested that they may foster innovation and enhance competition with other alcoholic beverages (e.g. beer, vodka, rum) and thus promote the growth of the sector (three respondents). Light standards could be perceived to facilitate trade to a greater extent than strict standards as they impose looser constraints defining what beverages can be marketed/sold as cider in the EU (one respondent). Finally, light standards provide greater flexibility for cider producers to offer a larger variety of cider products to consumers (i.e. they facilitate product differentiation) (one respondent).

## Economic costs

Respondents identified several types of costs related to the introduction of EU marketing standards. In particular, several respondents suggested that EU marketing standards may lead to higher production costs (compliance costs) for cider producers that currently apply lower minimum requirements if the EU standards are stricter than the existing national standards (five respondents). This is expected to be particularly the case for industrial cider producers, most of which currently apply light standards. Most small (craft) cider producers interviewed already follow rather strict standards, implying relatively lower adjustment costs if (light or strict) EU standards are introduced.

Another important cost suggested by respondents is that EU standards could curb innovation in the cider sector, especially if strict standards are introduced (three respondents). Indeed, several respondents indicated that strict EU marketing standards is likely to discourage innovation by restricting the possibility of adjusting cider products to consumers' demands. As a consequence, consumers could switch to substitute products (e.g. beer) (three respondents). Too strict standards may restrict the growth of the cider sector (e.g. consumption), as respondents suggest is currently the case in France and Romania. According to these respondents, this is because strict standards make cider more expensive to produce and thus less affordable for consumers, and because the growth of the cider sector is largely driven by flavoured cider containing less than 100 % apple juice (three respondents). In turn, potentially higher cider prices due to strict EU marketing standards may drive consumers towards substitute beverages. Furthermore, strict EU marketing standards are expected to reduce product differentiation (two respondents).

Related to the potential introduction of light EU marketing standards, respondents stated that, if cider is not produced with pure/fresh juice, this will result in the loss of consumers' trust and therefore a potential reduction in cider consumption (two respondents). Furthermore, the introduction of light EU marketing standards in combination with ORTs or cider categorisation may confuse/mislead consumers in terms of their purchase choices (one respondent). Finally, some respondents suggested that light EU standards cannot protect the EU market (producers and consumers) from low-quality cider imported from non-EU countries (two respondents).

The current cider sector and the cider products found on the EU market are very heterogeneous across Member States, which means there may be non-negligible 'negotiation costs' to agreeing common EU-wide marketing standards. This outcome is a result of market forces (e.g. response to consumers' preferences), path dependency and existing national standards that vary across Member States and stakeholders (the definition of cider differs between operators from different countries). Hence, given the heterogeneity of the existing national standards and the heterogeneity of stakeholder preferences, EU-wide marketing
standards may deviate from the Member States' socially optimal standards for some stakeholders or Member States (seven respondents).

### 5.2.2 Potential implications of EU marketing standards on the social and environmental sustainability of the cider sector

There is a common view among most respondents that the current national marketing standards do not directly affect environmental, health or socioeconomic aspects of the sector's sustainability. Respondents often have difficulty identifying the standards' implications in terms of sustainability. Some respondents see marketing standards as a technical tool that should be restricted to setting the quality attributes of products and they do not necessarily need to refer to environmental, health and socioeconomic aspects of cider production or consumption (10 respondents). Large-scale cider producers and their associations plus the cider producer associations covering all business sizes stated that the sustainability issue should be addressed at a broader food chain level (e.g. beverage, agri-food sector or packaging level) and not at sectoral level (six respondents).

Yet few respondents stated that if EU marketing standards are introduced they should directly include sustainability criteria. Table 7 summarises respondents' preferences on whether EU marketing standards should address sustainability (environmental, health or socioeconomic) issues. Of the total of 22 respondents, only seven were in favour of EU marketing standards addressing sustainability issues, whereas 14 respondents did not support standards playing this role. The remaining respondent was neutral about including sustainability criteria in the EU marketing standards because it is not a well-defined issue and because it has different implications for different types of cider producers.

The results in Table 7 indicate that the two respondents who would not be directly affected by the introduction of EU standards (i.e. the juice and concentrate producer association, and the distributors association) were in favour of including sustainability aspects, whereas the majority of respondents who could be directly affected by the EU standards (i.e. cider producers) did not support sustainability aspects being considered within the marketing standards. None of the large-scale cider producers or their associations were in favour of directly addressing the sustainability issue through EU standards in the cider sector, whereas some of the small cider producers (five respondents) supported this. This divergence in preferences between small and large cider producers could be explained by the fact that some craft cider producers and medium-sized producers already consider their businesses sustainable (locally rooted) and believe that they may be less affected by, or could even benefit from, the inclusion of sustainability in EU market standards (see below).

The respondents that were in favour of EU marketing standards addressing sustainability suggested some specific indirect impacts of the EU standards on environment, health and socioeconomic aspects related to the cider supply chain.

The potential environmental impacts of EU marketing standards are as follows.

* If EU standards stimulate use of more local/EU apples to produce cider, they could lead to a reduction of transportation costs and CO₂ emissions (one respondent). By contrast, if cider is not produced locally to where the apples are produced (¹⁷), this may have adverse environmental implications (e.g. the costs of transporting apples or juice). This may also have implications for traceability, as it might be more difficult or more costly to trace the products' origins along all stages of the cider supply chain as the chain becomes more complex (one respondent).

* More energy is needed to produce concentrate from apple juice and to reconstitute the juice for cider production. Hence, EU standards requiring greater minimum levels of fresh juice content may reduce the overall energy consumed in the production of cider (two respondents). However, this may restrict trade to regional trade, as cider production would require relying primarily on the procurement of fresh juice from more local markets (one respondent).

* EU standards stimulating craft cider production may contribute to the conservation of apple tree biodiversity because craft cider is expected to support the preservation of autochthonous apple varieties (one respondent).

* EU standards supporting the growth of the cider sector may stimulate the expansion of areas cultivated for apple orchards (through providing apples for juice production), which could contribute to carbon sequestration (one respondent). They may also reduce pesticide use given that the production of cider apples requires less pesticide than the production of eating apples (two respondents).

<footnote>(¹⁷) According to several respondents, the main producer of apple concentrate is China, followed by Poland.</footnote>
* EU standards supporting the growth of the cider sector may also reduce waste/losses in the apple sector because apples that are not suitable for direct consumption (e.g. in terms of shape, size) could, in some cases, be used for cider production (¹⁸) (two respondents).

The potential health impacts of EU marketing standards are as follows.

* If EU marketing standards ban or limit the use of artificial additives in cider, they could have a positive impact on consumers' health (one respondent).

* EU marketing standards may reduce the amount of added sugar in cider if the minimum apple juice content is set higher. This is because there seems to be a positive relationship between the amount of apple juice contained in cider and the sugar added post fermentation: the more apple juice is used for cider production, the less sugar needs to be added post fermentation (one respondent).

* On the one hand, cider is generally perceived as a 'healthy' product (low levels of alcohol and natural ingredients) and therefore EU standards supporting its growth may benefit consumers (one respondent). Cider with a higher content of juice is 'healthier' (e.g. contains more minerals) (one respondent). On the other hand, stricter EU marketing standards may induce higher cider prices, which may encourage a better 'appreciation' of cider by the consumers (one respondent), and lower (moderate) consumption (two respondents) (¹⁹).

The potential socioeconomic impacts of EU marketing standards are as follows.

* Small cider producers are often located in rural areas. Therefore, if EU standards support craft cider through strict EU standards, this will support the rural economy and rural employment (two respondents).

* EU standards with higher minimum content of fruit juice support the development of the apple sector and employment in rural areas (one respondent).

* Similarly, if EU standards imply more local/EU apples being used to produce cider, they may foster the local economy (more localised sourcing of primary ingredient) (five respondents).

<table><caption>**Table 7: Respondents' preferences for EU marketing standards addressing sustainability (environmental, health or socioeconomic) issues (number of respondents)**</caption><thead><tr><th rowspan="2">Stage in the cider sector</th><th rowspan="2">Total respondents</th><th colspan="3">Should new EU marketing standards address sustainability issues?</th></tr><tr><th>Yes</th><th>No</th><th>Neutral</th></tr></thead><tbody><tr><td>Apple juice and concentrate producers and their associations</td><td>1</td><td>1</td><td>0</td><td>0</td></tr><tr><td>Cider producers and their associations:</td><td>20</td><td>5</td><td>14</td><td>1</td></tr><tr><td>Small (craft) and medium-sized cider producers and their associations</td><td>14</td><td>5</td><td>8</td><td>1</td></tr><tr><td>Large-scale (multinational) cider producers and their associations</td><td>4</td><td>0</td><td>4</td><td>0</td></tr><tr><td>Cider producer associations covering all business sizes</td><td>2</td><td>0</td><td>2</td><td>0</td></tr><tr><td>Wholesalers, retailers and their associations (distributors)</td><td>1</td><td>1</td><td>0</td><td>0</td></tr><tr><td><strong>Total</strong></td><td><strong>22</strong></td><td><strong>7</strong></td><td><strong>14</strong></td><td><strong>1</strong></td></tr></tbody></table>

<footnote n="18">¹⁸) Note that cider is usually produced from cider apple varieties that are not suitable for direct consumption.</footnote>

<footnote n="19">¹⁹) These two arguments seem to be contradictory to some extent given that the first suggests that cider is a healthy product, whereas the second implies that higher cider consumption at least may not be necessarily healthy for consumers.</footnote>
# 6 Conclusions

This report aims to provide analyses of the current public and private marketing standards that operators from the cider sector apply in different Member States, and their economic costs and benefits for the sector. The report also aims to analyse the potential implications and added value of introducing EU-wide marketing standards for the cider sector by investigating their potential costs and benefits from socioeconomic, health and environmental perspectives. The analyses in this report are based on semi-structured interviews conducted with 22 stakeholders from the cider supply chain between 4 October and 17 December 2021. The respondents interviewed are from 10 Member States and a European-level cider-related association. The majority of respondents represent the cider production stage, but two respondents were from associations representing apple juice and concentrate producers and distributors. Therefore, the analyses in this report are based primarily on information collected from the production stage and less so from other stages of the cider supply chain.

The main findings of the report are the following. According to respondents', most of the Member States covered in the report have their own public national marketing standards in place. Only a few Member States covered do not have public national standards, with some of these Member States relying on private marketing standards. Second, the existing (private and public) marketing standards are very heterogeneous between Member States, broadly falling into two categories: light standards and strict standards. The main difference between the two categories is the minimum percentage of apple juice (either fresh or concentrate) content allowed in cider: 100 % for strict standards and less than 100 % for light standards. Of the Member States covered in this report, strict standards are implemented in Spain, France and Romania, whereas there are light standards in Denmark, the Netherlands, Poland, Slovakia and Sweden (20). In Ireland, there are no public marketing standards. In Germany, there are strict public standards for the traditional apple wine and fruit wine, which are similar to the cider produced in Spain or France. Other elements of private and public marketing standards are also heterogeneous across Member States, such as the possibility of adding water, sugar (before or after fermentation) or CO2; the prohibition of added alcohol (fortification); the minimum and maximum alcohol content; and the use of flavourings, colourants and other additives.

Respondents responses suggested several main benefits of the existing public and private marketing standards in the cider sector, such as reducing transaction costs and facilitating the functioning of the cider supply chain, reducing unfair competition by ensuring that all companies operating in a given Member States operate on the same level playing field. From the consumer's perspective, marketing standards ensure that cider offered on the domestic market is of a minimum quality, facilitate better information communication about the cider's quality and reduce the potential for misleading information. Regarding strict standards, some respondents stated that more stringent standards support local and EU apple producers and small (craft) cider producers that use higher apple juice content in their cider. By contrast, some of the main benefits of light standards, as perceived by respondents, include the fact that they are more conducive to innovation, promote the growth of the cider sector, facilitate trade and provide customers with access to a larger variety of cider products.

The main perceived cost of the existing national marketing standards that was identified by respondents is related to their heterogeneity in that the standards hamper intra-EU trade, as the rules are not transparent and vary between Member States. Other costs identified by respondents refer to strict marketing standards; strict standards may lead to unfair competition/trading with cider imported from Member States with light standards (usually industrial cider made for mass consumption), may restrict the capacity of innovation in the sector, may reduce product differentiation, and usually imply higher production (compliance) costs.

Given the absence of EU-wide marketing standards in the cider sector, an important finding from the interviews is that the majority of respondents (21 out of the total 22) support the introduction of EU marketing standards. The respondents seem to perceive that EU standards could bring added value with respect to the current heterogeneous standards established at Member State level. However, respondents' preferences differ significantly in terms of the stringency levels of EU standards. Overall, of the 21 respondents in favour of EU-wide marketing standards, 10 support strict standards (100 % minimum apple juice content), seven support light standards (less than 100 % and more than 15 % minimum apple juice content), three support standards with no minimum requirements (no specification of a minimum share of apple juice content) and one expressed no opinion on the issue. Respondents' preferences for EU marketing standards seem to differ according to the stringency of the existing standards in the Member States where the respondents operate and according to the size of their businesses. First, the

<footnote>(20) Note that, as long as the threshold separating light and strict standards is above 60 %, the classification of the Member States into the two types of standards will not change.</footnote>
respondents from Member States with light existing national standards prefer less strict EU-wide standards, whereas the reverse is true of respondents from Member States with strict standards. Second, large-scale cider producers and their representative associations seems to be in favour of light EU standards with no or low minimum apple juice content, whereas small/craft cider producers support strict EU standards.

Furthermore, the majority of respondents (18 out of the total of 22) are in favour of the introduction of ORTs at EU level. Their main motivation is categorising cider according to certain attributes/characteristics, primarily to reduce the misleading of consumers and to avoid the misuse of various claims and labels (e.g. pure juice, fresh juice, premium cider).

Some of the main perceived economic benefits of introducing EU standards suggested by respondents include the standards' potential to reduce transaction costs and improve the functioning of the cider supply chain through increasing transparency by providing all market participants with a common understanding of what cider is, facilitating business-to-business transactions, and reducing barriers to trade. EU standards could contribute to reducing unfair competition with cider imported from non-EU cider-producing countries and among EU cider producers. In particular, it may reduce regulation arbitrage (producing cider in Member States with light standards and selling it in Member States with strict standards), which is mainly pursued by large-scale cider producers, and the resulting regulation-induced differentiation of cider products, which involves selling regulated cider and non-regulated cider on the same domestic market. From consumers' perspective, EU standards are expected to communicate the information about cider quality to consumers more effectively. According to some respondents, the benefits of EU-wide standards will depend on the type of EU standards established. For example, strict EU standards may avoid misleading consumers, and support local/EU apple producers and local cider producers, whereas light standards are perceived to foster innovation and enhance competition in the sector.

In terms of the perceived economic costs of introducing EU standards, several respondents indicated that stricter EU marketing standards may lead to higher production costs for cider producers that currently apply lower minimum requirements. Furthermore, some respondents suggested that too strict EU marketing standards may reduce product differentiation, restrict innovation in the sector by limiting the possibility of adjusting cider products to consumers' demands and may increase production costs, leading to higher cider prices. These effects could reduce the growth of the EU cider sector and may induce consumers to replace cider with other beverages. Related to the potential introduction of light EU marketing standards, some respondents suggested that the standards are not expected to reduce unfair competition among EU cider producers because it will be more difficult for craft cider producers (mostly those producing cider with 100 % apple juice content) to differentiate their products from cider with low apple juice content. In addition, some respondents stated that light standards may result in the loss of consumers' trust and may confuse/mislead consumers in terms of their purchase choices, resulting in potentially lower cider consumption. Some respondents suggested that light EU standards may leave the EU market unprotected from low-quality cider imported from non-EU countries. Overall, given the heterogeneity of the existing national standards and of stakeholders' preferences, if common EU-wide marketing standards are introduced, they may deviate from the Member States' socially optimal standards for some stakeholders or Member States.

In terms of the sustainability implications of EU marketing standards, most respondents had difficulty identifying the standards' socioeconomic, environmental and health sustainability implications, as the standards are largely seen as a technical tool that should be restricted to setting the quality attributes of products. Large-scale producers stated that the sustainability issue should be addressed at a broader food chain level and not at sectoral level. Overall, only a minority of respondents were in favour of EU marketing standards addressing sustainability issues (7 out of 22). There seems to be a negative correlation between the size of the business and respondents' preference for sustainability criteria to be included in the EU marketing standards for cider. That is, small and medium-sized cider producers are more inclined than large-scale producers to include sustainability criteria in the EU marketing standards. Respondents from organisations representing businesses that would not be directly affected by the introduction of EU standards (i.e. the juice and concentrate producer association and the distributors' association) were in favour of including sustainability aspects, whereas the majority of respondents potentially directly affected by the EU standards (i.e. cider producers) did not support sustainability aspects being considered within the EU marketing standards.

Respondents who were in favour of EU marketing standards addressing sustainability suggested some specific indirect impacts the EU standards may have on environment, health and socioeconomic aspects related to the cider sector, depending on the nature and stringency of the standards. Regarding environmental impacts in particular, a higher apple juice content in cider may reinforce the demand for apples and increase the area of cultivation of orchards, which could contribute to carbon sequestration and to the preservation of biodiversity if local varieties of apple trees are used. EU marketing standards could also contribute to a reduction in transportation costs and CO2 emissions (if local/EU apples are used to produce cider), may reduce the amount
of energy consumed in the production of cider (if higher minimum levels of fresh juice content are applied), and may reduce waste/losses in the apple sector. Similarly, the health impacts of EU marketing standards could include health benefits for consumers if the standards ban or limit the use of artificial additives or added sugar in cider. Finally, respondents suggested that strict EU marketing standards could generate some socioeconomic impacts such as supporting the development of the rural economy and rural employment.

Overall, the results of this report indicate that, owing to the heterogeneity of the existing national standards and of the cider firms (e.g. differences in the production processes applied by the relatively small number of large multinational companies, which usually produce cider with low apple juice content, and those used by the multitude of medium-sized and small cider producers, which usually produce cider with high apple juice content), different actors are likely to gain and lose depending on the stringency of the eventual EU standards. The key element of EU standards that is expected to have the greatest impact on the cider sector is the stringency of the technical definition, particularly the minimum apple juice content requirements and ORTs.

Although the establishment of light standards may facilitate innovation in the sector and intra-EU trade growth, it may be detrimental to cider producers from Member States with strict existing national standards. Those most adversely affected are expected to be small (craft) cider producers producing cider with high apple juice content. Multinational companies producing cider with low apple juice content are expected to be the most likely to gain from light standards. That is, the introduction of EU light standards may lead to an increased supply of cider with lower juice content, especially in Member States with strict standards, making small (craft) cider producers less competitive and potentially causing them to lose their market shares. Moreover, small cider producers may be less competitive if they adapt by entering the market segment for beverages with lower apple juice content because of their low scale compared with that of large multinational companies, which can benefit from economies of scale. From the consumer's perspective, introducing light EU standards without implementing ORTs may fail to provide the opportunity to transparently differentiate cider varieties (including indicating those with high apple juice content) so that consumers can identify their preferred ciders. Therefore, the lack of ORTs could increase the misleading of consumers. The establishment of ORTs at EU level may therefore be necessary to allow differentiation of cider products according to attributes/characteristics in order to reduce the level of asymmetric information between producers and consumers. Otherwise, private standards (potentially heterogeneous across markets and firms) will probably emerge to sustain cider products' differentiation and firms' abilities to adjust cider to consumers' preferences.

On the other hand, the establishment of strict EU standards is expected to be detrimental to cider producers that use low apple juice content; currently, this covers mainly the large multinational companies and large cider producers from Member States with light existing national standards. To be able to sell cider products, these companies would need to adapt their cider products in line with stricter EU standards, potentially leading to higher production costs. Alternatively, to continue selling cider with low apple juice content, such cider would need to be labelled it differently from EU-regulated cider. This will probably split the cider market into two segments: a segment complying with the EU standards and an alternative segment selling 'beverages made from apples' or 'cider-like products'. Thus, it is expected that large companies will probably continue producing and selling cider-like products with low apple juice content in the unregulated market segment even when there are strict EU standards in place. Furthermore, this market segmentation may mislead consumers. Again, as with the light EU standards, the establishment of EU-level ORTs may tackle this problem by allowing differentiation of cider varieties (including cider varieties with lower apple juice content).

One must be aware when drawing conclusions that the findings of this report reflect methodological assumptions and data limitations. First, the information collected through the interviews and used to derive analyses in the report is based on convenience samples and is not representative of the underlying population of stakeholders active in the cider sector. In particular, the sample under-represents the primary agricultural sector (apple farmers), distributors and consumers' associations. A second caveat of the analysis is that the information collected through the interviews is primarily qualitative, which prevented quantification of the costs and benefits of marketing standards. A third caveat is that private cider standards may be more widespread in the covered Member States than presented in this report. The information provided about private standards in this report is solely based on information received from respondents; the report does not cover private standards that may be applied by operators not covered in the report.
## References

AICV (European Cider and Fruit Wine Association) and GlobalData (2022), *European Cider Trends 2021*, AICV, Brussels (www.aicv.org).

Areté and Agra CEAS Consulting (2019), *Evaluation of marketing standards contained in the CMO regulation, the 'Breakfast Directives' and CMO secondary legislation*, Directorate-General for Agriculture and Rural Development, European Commission, Brussels (https://op.europa.eu/en/publication-detail/-/publication/309c4642-7ec0-11ea-aea8-01aa75ed71a1).

Baker, K. (2021), 'Cider across the globe - moving up in times of crisis', conference presentation, Global Cider Forum 2021, 17 November 2021 to 24 January 2022.

European Commission (2019), The European Green Deal, COM(2019) 640 final (https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52019DC0640&from=EN).

European Commission (2020a), *Executive summary of the evaluation of marketing standards (contained in the CMO regulation, the 'Breakfast Directives' and CMO secondary legislation)*, Commission Staff Working Document, SWD(2020) 231 (https://op.europa.eu/en/publication-detail/-/publication/61cd0b11-19fd-11eb-b57e-01aa75ed71a1/language-en).

European Commission (2020b), A farm to fork strategy for a fair, healthy and environmentally-friendly food system, COM(2020) 381 (https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020DC0381&from=EN).

European Commission (2021), 'Agricultural products - revision of EU marketing standards' (https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12772-Agricultural-products-revision-of-EU-marketing-standards_en).

European Parliament and Council (2012), Directive 2012/12/EE of the European Parliament and of the Council of 19 April 2012 amending Council Directive 2001/112/EC relating to fruit juices and certain similar products intended for human consumption, OJ L 115, 27.4.2012.

European Parliament and Council (2013), Regulation (EU) No 1308/2013 of the European Parliament and of the Council of 17 December 2013 establishing a common organisation of the markets in agricultural products and repealing Council Regulations (EEC) No 922/72, (EEC) No 234/79, (EC) No 1037/2001 and (EC) No 1234/2007. OJ L 347, 20.12.2013.

Lallemand (2018), *Technical Overview on Cider Production*, Proceedings of the XXVII Entretiens Scientifiques Lallemand, Tallinn, 25 April 2017, Montréal.

Nes, K. and Ciaian, P. (2021), *Marketing standards for food products: a review of literature*, EUR 30904 EN, Publications Office of the European Union, Luxembourg.

Russo, C., Sansone, M., Colamatteo, A., Pagnanelli, M. A. and Twum, E. K. (2022), *Benefits and costs of EU marketing standards for agri-food products: workshop report*, Publications Office of the European Union, Luxembourg.

Spain, Ministerio de la Presidencia y para las Administraciones Territoriales (2017), 'Real Decreto 72/2017, de 10 de febrero, por el que se aprueba la norma de calidad de las diferentes categorías de la sidra natural y de la sidra', *Boletín Oficial del Estado*, No 44, Section I, pp. 11416-11422.
# Appendix A: Interview guide

## INTRODUCTION

* We are from the Joint Research Centre (JRC) of the European Commission (EC), Directorate D, Sustainable Resources, Unit D4, Economics of Agriculture, in Seville. The role of the JRC is to provide scientific support to EC policy needs.

* We would like to thank you for agreeing to participate in our interview.

* Before going to the specific questions, we would like to give you some brief background information about the project.

* As you may know, the European Commission, in the general framework of its farm to fork strategy, aims to 'revise marketing standards to ensure the uptake and supply of sustainable agricultural ... products, and to reinforce the role of sustainability criteria, especially by taking into account the possible impact of these standards on food loss and waste.'

* You may know that EU marketing standards have been a 'feature of the CAP since its early days, and are usually defined by sectors or products. Their main objective is to take into account the expectations of consumers and to contribute to the improvement of the economic conditions for the production and marketing of agricultural products, as well as for the improvement of their quality in the European market.'

* Marketing standards concern, among others, technical definitions, classification, presentation, marking and labelling, packaging, production methods, conservation, storage, transport, related administrative documents, certification and time limits, restrictions of use and disposal.

* The European Commission carried out a first assessment of the current EU marketing standards in 2019. One recommendation of that report refers to cider. It states that, despite the absence of EU marketing standards for the cider sector, the possible benefits of establishing such standards for cider should be investigated.

* Following this, the purpose of this interview is to assess the added value of introducing EU marketing standards in the cider sector and, if relevant, which types, and to determine their costs and benefits from socioeconomic, environmental and health perspectives.

* We are interviewing in particular companies and businesses (including small and medium-sized enterprises and farmers) that are active at all stages of the cider chain (producer, processor, wholesaler, retailer, consumer group) as well as related organisations that represent or serve these companies and businesses.

Please note that the questionnaire is relatively short and the interview will last 30 minutes.

All the answers will be treated in the strictest confidence and the analysis will be done anonymously. The analyses based on the results from the interviews will be published in a report. No specific answers or personal or company names will be published in the report. The report will be fully anonymous.

We would like to ask for your permission to record the interview. It will be used only to prepare the report. It will not be published. It is just a way for us to ensure that none of the information provided in your answers will be lost. However, if you do not agree to record the interview, we will just take written notes.

## QUESTIONS

### Warm-up questions

1. Could you please describe the business or organisation that you represent? Main activity and type(s) of cider produced (name(s), quality, etc.), size of the business, country coverage. If it is an association, which kind of members belong to the association?

2. What is your role in the business or organisation that you represent?

3. Are you aware of the European Green Deal and the farm to fork strategy for a more sustainable food system that the European Commission wants to implement?
Questions on the current standards

4. Does your business (or the business you represent) respect/apply any public standards, at national, European or international level to produce and/or sell the cider?

If yes:

* Could you briefly explain what they are and who requires them?

* Could you explain the related costs and benefits for your business, provide an estimate of their values (example: amount of euros or percentage of the unit cost ...) and/or could you tell us if the estimated benefits are higher or lower than the estimated costs?

* Could you explain if they have positive or negative impacts on the sustainability of the cider sector (e.g. related to social, health, waste, and environmental aspects)?

5. Is your business (or the business you represent) involved in any private standards to produce and/or sell the cider?

If yes:

* Could you briefly explain what they are and who requires them?

* Could you explain the related costs and benefits for your business, provide an estimate of their values (example: amount of euros or percentage of the unit cost ...) and/or could you tell us if the estimated benefits are higher or lower than the estimated costs?

* Could you explain if they have positive or negative impacts on the sustainability of the cider sector (e.g. related to social, health, waste, and environmental aspects)?

If the respondent says YES to Q4 or Q5, go to Q6. Otherwise, go to Q8.

6. Regarding the existing public/private standards, would it be better for them to remain/be made public (mandatory and defined as minimum standards to respect) at international level, EU level or at Member State level, or should they be made/remain private standards (voluntary)?

Why?

If Member State level only: to which Member States should they be applied?

Questions on the respondent's opinion on adapted/new marketing standards

7. In your opinion, are there any current standards in the cider sector that you find inappropriate or need to be adjusted, and do you think there is a need to introduce new marketing standards in the sector that may improve your business or enhance the functioning of the sector?

If yes:

* What are these standards (description)?

* Why are they inappropriate or why should they be adjusted or why should they be introduced?

* Could you explain what would be the related costs and benefits for your business, provide an estimate of their values (example: amount of euros or percentage of the unit cost ...) and/or could you tell us if the estimated benefits would be higher or lower than the estimated costs?

* Could you explain if they would have positive or negative impacts on the sustainability of the cider sector (e.g. related to social, health, waste, and environmental aspects)?

8. In your opinion, is there a need to introduce marketing standards in the cider sector that may improve your business or enhance the functioning of the sector?

If yes:

* What are these standards (description)?

* Why do you think these (new/additional) standards should be introduced?
* Could you explain what would be the related costs and benefits for your business, provide an estimate of their values (example: amount of euros or percentage of the unit cost ...) and/or could you tell us if the estimated benefits would be higher or lower than the estimated costs?

* Could you explain if they would have positive or negative impacts on the sustainability of the cider sector (e.g. related to social, health, waste, and environmental aspects)?

If the respondent says NO to Q7 or Q8, go to Q9. Otherwise, go to Q10.

9. Why do you think there is no need to introduce (new/additional) marketing standards for the cider sector?

10. In your opinion, if [new/these] marketing standards are introduced, should they be public (mandatory and defined as minimum standards to respect) at Member State level, EU level or at international level, or should they be private standards (voluntary)?

Why?

In your opinion, is there value added of having EU-level marketing standards as compared to member-state level or private standards?

If Member State level only: to which Member States should they be applied?

11. In your opinion, which stage of the cider chain would be affected by the introduction/adjustment of the marketing standards (farmers, processors, wholesalers, supermarkets, retailers, etc.), and how?

12. In your opinion, should marketing standards be used to improve the sustainability of the cider sector (e.g. for the environmental aspects, social aspects, consumer or worker health, waste reduction, etc.)?

If yes:

* What would these standard(s) be (description)?

* Are there drawbacks or trade-offs between the different sustainability dimensions (economic, health/social, environmental, etc.)?

* How should they be implemented (member-states vs EU vs international levels, vs private standards) and why?

**Concluding question**

13. Do you have any information/reflection on the topic that you would like to share with us?

**Thanks for your participation!**
## Appendix B: Sugar content under the Spanish and French cider nomenclatures

<table><thead><tr><th colspan="4">Spanish legislation</th><th colspan="2">French legislation</th></tr><tr><th>Sidra natural</th><th>Grams per litre</th><th>Sidra</th><th>Grams per litre</th><th>Cidre</th><th>Grams per litre</th></tr></thead><tbody><tr><td>Brut nature</td><td>&lt; 3</td><td></td><td></td><td>-</td><td>-</td></tr><tr><td>Extra brut</td><td>3-6</td><td>-</td><td>-</td><td>Extra brut<sup>1</sup></td><td>&lt; 15</td></tr><tr><td>Brut</td><td>6-12</td><td></td><td></td><td>Brut</td><td>&lt; 28</td></tr><tr><td>Extra-seca</td><td>12-20</td><td>Extra-seca</td><td>&lt; 20</td><td>-</td><td>-</td></tr><tr><td>Seca</td><td>20-30</td><td>Seca</td><td>20-30</td><td></td><td></td></tr><tr><td>Semi-seca</td><td>30-50</td><td>Semi-seca</td><td>30-50</td><td>Demi-sec</td><td>28-42</td></tr><tr><td>Dulce</td><td>&gt; 50</td><td>Dulce</td><td>&gt; 50</td><td>Doux</td><td>&gt; 42</td></tr></tbody></table>

Source: Spanish nomenclature: Spain, Ministerio de la Presidencia y para las Administraciones Territoriales (2017); French nomenclature: French respondents interviewed.

<footnote>(1) Extra brut is not (yet) an official category, but it is used by the French cider producers.</footnote>
List of abbreviations

AIJN European Fruit Juice Association

CO₂ carbon dioxide

EU European Union

ORT optional reserved term
List of figures

<table><tr><td>FIGURE 1: CIDER MARKETS IN EASTERN EUROPE</td><td>7</td></tr><tr><td>FIGURE 2: RESPONDENTS' PERCEIVED BENEFITS OF NATIONAL MARKETING STANDARDS</td><td>15</td></tr><tr><td>FIGURE 3: RESPONDENTS' PERCEIVED COSTS OF NATIONAL MARKETING STANDARDS</td><td>16</td></tr></table>
List of tables

<table><tr><td>TABLE 1: MAIN CIDER MARKETS IN EUROPE</td><td>6</td></tr><tr><td>TABLE 2: RESPONDENTS BY THEIR STAGE IN THE CIDER SECTOR AND BUSINESS SIZE</td><td>8</td></tr><tr><td>TABLE 3: RESPONDENTS BY MEMBER STATE¹</td><td>9</td></tr><tr><td>TABLE 4: PUBLIC AND PRIVATE MARKETING STANDARDS BY MEMBER STATE</td><td>12</td></tr><tr><td>TABLE 5: RESPONDENTS' PREFERENCES FOR EU-WIDE MARKETING STANDARDS AND THEIR LEVEL OF STRINGENCY, BY MEMBER STATE</td><td>18</td></tr><tr><td>TABLE 6: RESPONDENTS' PREFERENCE FOR EU-WIDE MARKETING STANDARDS AND THEIR LEVEL OF STRINGENCY BY RESPONDENTS' STAGE IN THE CIDER SUPPLY CHAIN AND BUSINESS SIZE (NUMBER OF RESPONDENTS)</td><td>20</td></tr><tr><td>TABLE 7: RESPONDENTS' PREFERENCES FOR EU MARKETING STANDARDS ADDRESSING SUSTAINABILITY (ENVIRONMENTAL, HEALTH OR SOCIOECONOMIC) ISSUES (NUMBER OF RESPONDENTS)</td><td>24</td></tr></table>
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