# EUR-Lex - 52014DC0354 - EN

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# 52014DC0354

**REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Development of the dairy market situation and the operation of the "Milk Package" provisions /* COM/2014/0354 final */**

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REPORT
FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND

THE
COUNCIL

Development
of the dairy market situation and the operation of the "Milk Package"
provisions

1.           Scope

Article 225(b)
of Regulation
(EU) No 1308/2013[1]
provides that the Commission shall present a report to
the European Parliament and to the Council by 30 June 2014 on the development
of the market situation in the milk and milk products sector, and in particular
on the operation of Articles 148 to 151, Article 152(3) and Article 157(3), assessing
in particular the effects on milk producers and
milk production in disadvantaged regions in connection with the general
objective of maintaining production in such regions, and covering
potential incentives to encourage farmers to enter into joint production
agreements, together with any appropriate proposals.

The conference
"The EU dairy sector: developing beyond 2015" held in Brussels on 24
September 2013 explored new challenges that the milk sector will face and discussed
whether additional instruments were needed and feasible, taking into account
the end of the quota system in 2015. Deliberations in the EU institutions on
the results of the conference are ongoing. This report brings additional
elements for the discussion and the Commission is keen to continue the debate
with Parliament, the Member States and stakeholders on how best to manage the
markets once the quotas have disappeared with a view to making further
proposals where appropriate.

2.         evolution of the market situation for milk and milk products

The
EU milk market is currently[2] in a
quite favourable situation. The EU average milk price in January 2014 was 40.03
c/kg which is 17% higher than in January 2013, and the highest average milk
price for January ever recorded (statistics since 1977). This upward trend has
also been observed in the price of dairy products, although butter prices have
been under some pressure since the beginning of 2014. Up to now, the strong
global demand has supported firm prices. However, a correction in prices should
not be excluded, given the milk production increase observed across the major
exporters.

The medium-term
prospects for milk and dairy commodities are favourable on both the world and
domestic markets. World demand remains dynamic, especially in the emerging
economies. Despite the slowdown in economic growth, dairy products are
featuring more prominently in people’s diets due to a higher proportion of
middleclass households. Production increases resulting from the lifting of
quotas can be expected especially in those Member States currently restricted
by the quota such as Ireland, Germany, the Netherlands, Denmark, Austria and Poland, as well as in France. Production will depend on the pace of
consumption increase in both the EU and the world and on other factors such as
environmental constraints.

More extensive
information of the evolution of the market situation is supplied in the
Commission staff working document accompanying this report.

3.           the operation of the
"milk package" provisions

The so-called
"Milk Package"[3] was
published in March 2012, has been fully in force since 3 October 2012 and applies
until 30 June 2020. Implementing and delegated regulations[4] were
published in June and September 2012.

The provisions
of the Milk Package (as integrated in Regulation (EU) No 1308/2013) and their
operation are described below. The report is based on the replies from Member
States to a specific questionnaire[5]
as well as the notifications provided for in the implementing rules.

3.1.        compulsory contracts (article
148)

Contracts lay
down the responsibilities of operators in the dairy chain, increase awareness
of market signals, improve price transmission, adapt supply to demand and avoid
certain unfair commercial practices. After abolition of the milk quota system,
they are a useful tool for producers and processors to plan their production
volumes. Under Article 148 Member States have the possibility to make written
contracts between farmers and processors compulsory and to oblige purchasers of
milk to offer farmers a minimum contract duration. These contracts should be
made in advance of delivery and contain specific elements such as the price,
volume, duration, details concerning payment, collection and rules for force
majeure. All these elements should be freely negotiated between the parties and
farmers have the right to refuse an offer of a minimum duration in a contract.
Deliveries by a farmer-member to his cooperative are exempted from this
contract obligation if the statutes or rules of the coop contain provisions
that have similar effects as the prescribed contract.

So far, 12 Member
States provided for compulsory contracts, some even before the Milk Package
entered into force.

Table 1                 Compulsory
contracts

Member State || National Legislation || Minimum Contract Duration

Latvia || September 2009 || -

France || April 2011 || 5 years

Italia || March 2012 || 6 months

Spain || October 2012 || 1 year

Lithuania || October 2012 || -

Hungary || December 2012 || 6 months

Slovakia || December 2012 || -

Croatia || June 2013 || 6 months

Cyprus || June 2013 || 6 months

Portugal || June 2013 || 6 months

Bulgaria || November 2013 || 6 months

Romania || 1st quarter 2014 || 6 months

7 Member States
provided that the contract proposed by the purchaser to the farmer should have
a minimum duration of 6 months, while Spain opted for 1 year and France for 5
years contracts. Inspired by the Milk Package provisions, in the United Kingdom a Voluntary Code of Practice was agreed between producers and processors, providing
for contracts under similar conditions as those specified in the Milk Package
and covering more than 85% of raw milk production. Also in Belgium a code of good practice has been signed by 98% of the processors and the three most
important farmer's organisations. It notably includes quality agreements,
agreements on the period of notice of farmers and buyers, sustainability
agreements and arrangements on the role of producer organisations. In Germany, for deliveries negotiated via POs, model contracts are commonly used which, in
addition to quality, price parameters and duration, in future also would
comprise more details on the milk volume.

Contracts have
been made compulsory notably in Member States where the cooperative structure
of contractual relations between producers and processors in the dairy sector
was less pronounced. Graph 1 gives an overview of the share of cow's milk
production by type of contractual arrangements distinguishing deliveries by
member farmers to processing cooperatives and collecting cooperatives and
deliveries by farmers to private processors and under other arrangements. The
latter predominantly concern deliveries to private collectors or trading
companies. Approximately 64% of all deliveries of cow's milk are made by member
farmers to their processing or collecting cooperative. For France no distinction could be made between deliveries to processing and collecting
cooperatives. For Germany, deliveries to private processors mainly take place
through producer organisations or their associations. In general, the shares of
the respective types of contractual arrangements are reported to be rather
stable over recent years. Nevertheless, several Member States (EE, IT, LV, AT, SK) reported an increase in deliveries to private collectors, though their share
in absolute terms is rather limited.

Graph.1                Contractual
 relations

3.2.        producer organisations (article 152(3))

Member States
are obliged to formally recognise Producer Organisations (POs) constituted by
producers in the milk sector on the initiative of producers and pursuing a
specific aim which may include (i) ensuring that production is planned and
adjusted to demand, particularly in terms of quality and quantity; (ii)
concentration of supply and the placing on the market of the products produced
by its members; (iii) optimising production costs and stabilising producer
prices. Member States can set a minimum number of members and/or a minimum
volume of marketable production that POs have to fulfil in order to be
recognised (see annex, table 3).

All recognised POs focus on
cow's milk, except one solely for ewe's milk in Spain. A large number of the
total 228 POs in the EU dairy sector, notably in Germany and Italy, already existed before the Milk Package came into force. Nevertheless, the number
recognitions has increased in 2013 (BE +1; CZ + 8; DE + 18; ES + 3, FR + 27). In
  Germany, one association of POs has been recognised in 2013 resulting in a
total of two. In
several Member States national legislation for recognition came only recently
in force.

The rather large variation
in minimum requirements shows the difficulty of finding a balance between the
ambition to aim at large POs that have a potential to increase the bargaining
power of producers and the encouragement to create POs by setting realistic thresholds.
Nevertheless, it should be born in mind that in a second phase several POs can
join in an association of POs that has the same possibilities for collective
negotiation as a PO, but at a bigger scale.

It is suggested that the
relative favourable market developments in recent year (see point 2) would not
have stimulated farmers to join in POs.

In their report "Analysis on the future developments in
the dairy sector"[6]
expert's suggested, among other things, to strengthen the role of POs notably by
ensuring that they have an adequate size in order to have sufficient bargaining
power.

The possibility
for extension of certain rules of recognised POs and their associations (and
interbranch organisations) to non-members and compulsory contributions by
non-members under the reformed CAP[7]
now also applies to those organisations in the milk sector and is expected to qualify
as an incentive for the creation of representative organisation.

Further
incentives for farmers to join in POs are treated under point 3.8.

3.3.        collective negotiations (article
149)

In order to
reinforce the bargaining power of milk producers, farmers can join together in
producer organisations (PO) that can negotiate collectively the contracts terms
including the price of the raw milk. The volume of milk that a PO can negotiate
is bound by certain clearly defined limits (i.e. 3.5% of the EU production, 33%
of the national production of the Member State). Deliveries by member farmers
to their processing cooperatives cannot be subject of joint negotiations under
the Milk Package, while collecting cooperatives can form POs that can negotiate
collectively with processors.

Four Member
States reported deliveries of raw milk in 2013 under contracts collectively negotiated
in the context of this provision.

Table 2.
Actual deliveries of cow's milk in 2013 under contracts collectively negotiated

Member State || Volumes raw cow's milk x 1 000 tonnes || Approximate  share of deliveries

Czech Republic || 445 || 18%

Germany || 11 158 || 33%

Spain || 255 || 4%

France || 2 689 || 11%

In Germany, 2 associations of POs together with the 143 POs cover almost all milk deliveries
to non-cooperative processors. In France almost 90% of the annual marketable
volume of the recognised POs was actually negotiated collectively, while in Spain collective negotiations were conducted for about 16% of the marketable volumes of
recognised POs. In addition, Spain reported deliveries in 2013 of 68 000 tonnes
of ewe's milk compared to a production of 571 000 tonnes. As deliveries by
member farmers to their processing cooperative cannot be negotiated under the Milk
Package, there is still some potential for collective negotiations, except for Germany and Member States with a high share of cooperative processors.

3.4.        regulation of supply for pdo/pgi cheeses (article 150)

In view of the
importance of cheeses with a protected designation of origin (PDO) or protected
geographical indications (PGI), notably for vulnerable rural regions and in
order to ensure the value added and quality, Member States are allowed to apply
rules to regulate the supply of PDO/PGI cheeses upon request of a producer
organisation (PO), an interbranch organisation (IBO) or a PDO/PGI group. So far,
two Member States have adopted rules for supply management for cheese. France adopted measures related to "Comté", applicable from 1 April 2012, to
"Beaufort" from 27 February 2014 and Italy adopted rules for
"Asiago", applicable from 12 February 2014. In both of these Member
States further requests are under examination or being elaborated.

3.5.        interbranch organisations
(Article 157(3))

Specific rules
for interbranch organisations (IBOs) in the milk sector allow the actors in the
dairy supply chain to dialogue and to carry out a number of activities that under
certain conditions can be partially exempted from competition rules (Article
210). These joint activities concern, amongst others things, the improvement of
knowledge and transparency of production and the market, promotion, research,
innovation and improving quality. IBOs should be made up of representatives of
the producers of raw milk and at least one or more of the following stages in
the supply chain: processing or trade (including distribution).

IBOs for the
dairy sector have been recognised in Spain (one for cow's, ewe's and goat's
milk), France (one for cow's milk, one goat's milk and two for ewe's milk), Hungary (for cow's milk) and Portugal. They generally operate at national level, except for the two
IBOs for ewe's milk in France that have a regional coverage. They all comprise production
and processing, while retail is only represented in the IBO in Hungary.

One practice of a
French IBO, notably concerning the dissemination of certain market information
and economic indicators, has been accepted in the context of Article 177a of
Regulation (EU) No 1234/2007[8].

3.6.        compulsory declarations milk deliveries (Article 151)

In order to
closely follow the development of the market after the milk quota regime
expires and for the sake of transparency, this provision caters for timely
information on delivered volumes of milk. It applies from 1 April 2015.
Implementing rules are being prepared.

3.7.      the effects of the milk package on milk producers and milk
production in disadvantaged regions

As there is no
uniform definition of "disadvantaged regions" in relation to milk
production Member States were asked what criteria they used in this context. Member
States mostly refer to mountain areas but also to less-favoured areas affected by
specific handicaps, areas in danger of abandonment, less-favoured areas (LFA)
in general and outermost regions (e.g. Azores). Some Member States apply
different gradations of handicap and/or add specific criteria e.g. remoteness, island,
fragmented structure, soil, climate, low milk yields, high production costs
etc. mostly referring to their national rural development programmes. Some Member
States report that they have no data available on the issue (BG, LT, LU, HU, MT, SK).

On the basis of these rather
heterogeneous definitions of "disadvantaged areas" the following data
and developments have been registered:

Graph. 2               Milk
production in disadvantaged regions

The general
decreasing trend in the number of milk producers in all Member States over the
recent years can also be observed in these disadvantaged regions, though in Poland the reduction is reported to be higher than in not disadvantaged regions. On the
other hand, in France, Austria and Slovenia the decrease in mountain areas is
less pronounced than in other regions, while Spain reports a slower reduction in
the number of milk producers since 2006 when direct payments were introduced in
the milk sector. Milk production volumes in disadvantaged regions are decreasing
in Estonia, Greece and Poland, while increasing in Germany, Ireland, Latvia and Austria. Spain registered a significant production increase in particular in
regions with low population (representing almost 40% of the national
deliveries).

The contractual
arrangements in disadvantaged regions, in so far as data are available, are
more or less similar to those indicated under point 3.1, however, with a higher
share of deliveries to processing cooperatives in Belgium, Ireland, Italy,
Poland, Sweden and France. Information on activities of POs in disadvantaged
regions is scarce; only France reported that 14 out of the 36 POs operate
partly also in such regions, although no notifications for collective
negotiations under Article 149 in such regions were received.

Member States
did not report a significant effect of the Milk Package on the milk sector in disadvantaged
regions notably because the provisions have been implemented only recently and the
period of actual application was too short. In addition, most Member States
were not able to provide detailed data on the issue.

The inventory
shows that the situations and developments on the milk sector in disadvantaged
regions in and between Member States are quite heterogeneous and would require
a targeted approach. Similar statements can be found in the European Parliament
resolution of 11 December 2013 on maintaining milk production in mountain
areas, disadvantaged areas and outermost regions after the expiry of the milk
quota[9].
Existing and new measures under the reformed CAP cater for such targeting.

Under their
Rural Development Programmes[10]
Member States can address the specific needs of the dairy sector with a
strategic approach by drawing up tailored thematic sub-programs targeted e.g.
at restructuring of milk production if the sector has a specific impact on the
development of the rural area or at mountain areas. Furthermore, the support
for areas facing natural and other specific constraints provides for payments
compensating for income foregone and additional costs in those areas where
agricultural production is suffering from natural constraints. This could of
course also concern milk producers in case they are located in an area under
constraint. These payments are particularly important to prevent farmland
abandonment. Moreover, the new Rural Development Regulation also features an
increased ceiling for payments for areas facing natural or other specific
constraints – from 250 to 450 €/ha in mountain areas and from 150 to 250 €/ha
in other areas.

Under Direct
Payments[11],
for example, Members States may decide to provide voluntary coupled support,
for dairy farmers, up to a certain limit of their national envelope and to the
extent necessary to create an incentive to maintain current levels of
production. This support will be targeted at sectors or regions where specific
types of farming or specific agricultural sectors that are particularly
important for economic, social or environmental reasons undergo certain
difficulties. Moreover, Member State may decide to grant a payment for areas
with natural constraints, up to 5% of the national envelope.

In addition, for
EU ́s outermost regions the POSEI arrangements[12]
("Programme d'Options Spécifiques à l'Éloignement et l'Insularité")
are designed to take account of their geographical and economic handicaps such
as remoteness, insularity, small size, difficult topography and climate,
economic dependence on a few products.

It is worth
mentioning that between 2010 and 2013, 14 Member States have implemented
specific support in the dairy sector under Article 68(1)(b) of Regulation (EC)
No 73/2009 with a total allocated amount of around EUR 1 billion.

3.8.      potential incentives to encourage farmers to enter into
joint production agreements

In reply to the
questionnaire (see point 3) a number of Member States suggest financial
support for notably for producer organisations (some referring to the Fruit and
Vegetable sector as an example) as an appropriate incentive to encourage
farmers to enter into joint production agreements. Other suggestions point to
increasing the POs ability to develop other functions, beyond collective
negotiations of raw milk deliveries, e.g. more implication in market regulation,
joint negotiations with animal feed suppliers or beef fatteners. Also
information campaigns raising awareness of the benefits of a PO membership and
presenting successful examples were proposed. Another group of Member States
saw no need for such incentives referring to the well-developed cooperative
structure of their milk sector.

In this context, the reformed Rural Development Policy
offers notably the following possibilities:

Support
  for the setting up of producer groups has been extended to producer
  organisations in the period 2014-2020.

· 
The
new measure on cooperation (which is potentially open to producer groups,
cooperatives and interbranch organisations) provides for possibilities to
support e.g. the development of new products and practices, short supply chains
and local markets as well as the cooperation of small operators in organising
joint work processes and sharing facilities. In combination with support under
the investment measure collective investments may benefit from higher aid rates
(possible increase by 20 percentage points).

· 
Groups
of farmers can additionally also benefit from a series of rural development
measures, such as investment support, participation in quality schemes and
information/promotion activities, agro-environment-climate measures, etc.

4.           Final remarks

The EU milk market situation is
currently favourable and the medium term prospects are good, though with
probably more episodes of extreme price volatility.

The Milk Package
provisions have been transposed into national legislation. 12 Member States
have provided for compulsory contracts between farmers and processors. In two other
Member States codes of good practice inspired by the Milk Package have been
agreed between farmers and processors organisations.

Almost all
Member States have adopted national criteria for the recognition of Producer
Organisations (POs), though some only recently. In 6 Member States a total of
228 POs were recognised by the end of 2013, a number of which existed before
the Milk Package came into force. The creation of (new) POs requires time and
of course a strong dynamic coming from farmers themselves. The recent
favourable market developments and prospects might not have stimulated farmers
to join in POs. In this context potential incentives to encourage farmers to
enter into joint production agreements have been provided in the reformed Rural
Development Policy (support for setting op of POs, new measures on cooperation
and eligibility of groups of farmers for a series of rural development measures). 
Furthermore, the possibilities for extension of certain rules of POs and
compulsory contributions for non-members might stimulate the creation of large
POs.

Collective
negotiations under the Milk Package have been conducted by recognised POs in
four Member States. Such negotiations lead to actual deliveries in 2013,
varying between 4 to 33% of the total deliveries in the respective Member
States.

Regulation of
supply for PDO/PGI cheese has, so far, been provided by 2 Member States for 3
cheeses. Further initiatives have been announced.

The
possibilities for extension of rules and financial contributions referred to
above also apply for interbranch organisations (IBOs) and might be an incentive
for their creation. So far, IBOs have been recognised in four Member States.

It is too early
to see significant effects of the Milk Package on the milk sector in
disadvantaged regions. In so far as data are available and based on the variety
of criteria used by Member States to identify "disadvantaged regions",
the trends of milk production in those regions vary significantly between
Member States and between regions within the same Member State. Nevertheless, in
several Member States the share of deliveries to cooperative processors in disadvantaged
regions is reported to be higher than in other regions. It was not possible to
obtain concrete data on activities of POs in disadvantaged regions.

At the
conference "The EU dairy sector: developing beyond 2015" held in
Brussels on 24 September 2013, the idea of a European Milk Market Observatory was
launched and is currently being implemented by the Commission services. The
Observatory is a tool within the European Commission responsible for the
dissemination of market data and short-term analysis for the dairy market, with
the involvement of producers, processors, trade and retail as well as
independent experts, and the ambition of addressing the growing need for
transparency through more detailed and timely information. Stakeholders
contribute with their expertise and market knowledge, adding a qualitative
aspect to the quantitative approach of data collection and market analysis. The
ultimate objective is to give quantitative and qualitative tools for economic
operators to increase their market awareness and help them with their business decisions.
The Observatory will also be in a position to send early warnings to the
Commission services, when the market situation so requires.

Under the new
CAP (2014-2020), the dairy sector is equipped with a safety net (intervention
buying-in for butter and skimmed milk powder, private storage aid for butter ,
skimmed milk powder and PDO/PGI cheeses), coupled with a regulatory framework
for the Commission to react to exceptional circumstances (e.g. extension of the
intervention buying-in period, private storage aid for other dairy products,
export refunds, authorise a temporary derogation from competition rules as
regards agreements and decisions of recognised organisations to take certain
measures, exceptional counter-cyclical payments). In addition, milk producers
benefit from direct payments and rural development programmes, under which
Member States enjoy a considerable leeway to target measures specifically to
the milk sector.

The current
outlook for world dairy markets remains largely positive. However, there are
still doubts on the capacity of the EU regulatory framework to deal with
episodes of extreme market volatility or with a crisis situation after the
expiry of the quota regime, especially with a view to ensuring the balanced
development of milk production across the European Union and avoiding extreme
concentration in the most productive areas.

The creation of
the Milk Market Observatory will help the Commission to monitor market
developments and deploy "safety net provisions" in a proactive
manner. Various suggestions to go further and strengthen the available
instruments have been put forward. In particular, ideas have been presented on
how to equip the EU with the means to preserve viable dairy production in crisis
situations, to better manage harmful consequences for milk production in
disadvantaged regions and to provide tools to counter a surge in production
that could seriously affect long-term market stability. Questions have also
been raised on how market actors can be made responsible for their decisions to
exploit development opportunities and to contribute to crisis resolution.

The Commission
will pursue the debate to address these concerns. In particular, it will
explore the need and scope for additional tools for better anticipating crisis
situations and for coping better with crisis situations and market
volatility. Additionally, further analysis is needed to find more
efficient ways of supporting the milk sector so as to contribute to improved
competitiveness and sustainability of milk supply across the EU after thirty
years of milk quotas. The debate on the instruments already in force and the
need for additional ones will take place without delay, before the next
Commission report on the operation of the Milk Package and on market
developments scheduled for 2018.

[1] 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 (O.J. L 347, 20.12.2013, p. 671)

[2] based on data
available till mid-March 2014

[3] Regulation
(EU) No 261/2012; OJ L 94, 30.3.2012, p. 38.

[4] Commission
Implementing Regulation (EU) No 511/2012; OJ L 156, 16.6.2012, p. 39 and Commission
Delegated Regulation (EU) No 880/2012; OJ L 263, 28.9.2012, p. 8

[5] http://ec.europa.eu/agriculture/milk/milk-package/questionnaire-implementation-2013_en.pdf

[6] External study prepared by Ernst & Young
for the EC Agriculture and Rural Development Directorate-General.  See: 
http://ec.europa.eu/agriculture/events/dairy-conference-2013_en.htm

[7] Article 164 and 165 of Regulation (EU) No 1308/2013

[8] Now
Article 210 of Regulation (EU) No 1308/2013

[9] http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+TA+P7-TA-2013-0577+0+DOC+XML+V0//EN&language=EN

[10] Regulation (EU) No 1305/2013; OJ L 347, 20.12.2013, p. 487.

[11] Regulation (EU) No 1307/2013; OJ L 347, 20.12.2013, p. 608.

[12] Regulation (EU) No 228/2013; OJ L 78, 20.03.2013, p. 23

ANNEX

Producer Organisations: Minimum criteria set by Member States / Recognitions

Member State || National Legislation || Minimum Number of Farmers || Minimum Marketable Production    x 1 000T * || Number of POs recognised by end 2013

France || before 2012 || 200 || or 60 || 36

Portugal || before 2012 || 12 || 20 ||

Spain || November 2011 || || 200 || 7

Finland || May 2012 || 15 || 3 ||

Netherlands || June 2012 || 150 || 90 ||

Estonia || September 2012 || || 5% ||

Austria || October 2012 || 20 || or 3 ||

Czech Republic || October 2012 || 10 || || 8

Lithuania || October 2012 || 20 || 1 ||

Belgium || December 2012 / August 2013 || 40/20 || || 2

Italia || December 2012 || 5 || 3 || 32

Slovakia || December 2012 || 5 || ||

Hungary || December 2012 || || 30 ||

Denmark || early 2013 || 5 || 3 ||

Latvia || January 2013 || 10 || 0.125 ||

United Kingdom || April 2013 || 10 || 6 ||

Sweden || May 2013 || 10 || 6 ||

Croatia || June 2013 || 5 || 3 ||

Cyprus || June 2013 || 35 || 20 ||

Greece || September 2013 || 5/20 || 0,5/5 ||

Germany || November 2013 || 5 || || 143

Poland || November 2013 || 20 || 2 ||

Romania || 1st quarter 2014 || 5 || 0.035 ||

Slovenia || March 2014 || 20 || 2.000 ||

Luxemburg || March 2014 || 10 || ||

- Cumulative to the requirement for numbers of farmers, unless
indicated

Several Member States have differentiated requirements for e.g.
organic farmers, ewe's or goat's milk producers and POs in a specific
geographical area.