# EUR-Lex - 52013SC0437 - EN

*|*

# 52013SC0437

**COMMISSION STAFF WORKING DOCUMENT Origin labelling for meat used as an ingredient: consumers' attitude, feasibility of possible scenarios and impacts Accompanying the document Report from the Commission to the European Parliament and the Council regarding the mandatory indication of the country of origin or place of provenance for meat used as an ingredient /* SWD/2013/0437 final */**

			*

			*

Table of Contents

Introduction. 3

1............ The FIC Regulation
on origin of foods. 3

1.1......... Background to the
adoption of the FIC Regulation concerning origin labelling of foods  3

1.2......... The provisions of the
FIC Regulation on the origin labelling of foods. 4

1.2.1...... Provisions concerning
mandatory origin labelling of unprocessed meat of swine, poultry, sheep and
goat 4

1.2.2...... Provisions concerning the
origin of main ingredients. 5

1.2.3...... Commission report on the
mandatory indication of origin for meat used as an ingredient 6

2............ The EU Supply chain
of foods with meat ingredients. 7

2.1......... Overview of the EU
sector 7

2.2......... EU consumption of meat
and meat-related products and global trends. 8

2.3......... EU production and
outlook – Global trends. 10

2.4......... Structure of the sector 11

2.5......... Sourcing practices of
the supply chain. 15

2.6......... Traceability systems. 17

2.6.1...... Existing EU traceability
systems. 17

2.6.2...... Evaluation of existing
traceability systems for the purposes of origin labelling. 21

3............ Consumers' attitude
towards origin labelling of meat used as an ingredient 22

3.1......... Consumers' attitude
towards origin labelling of foods. 23

3.1.1...... Broader studies. 23

3.1.2...... National studies and
international literature. 25

3.2......... Consumers' attitude
towards origin labelling of meat 27

3.2.1...... Broader studies. 27

3.2.2...... National studies. 29

3.3......... Consumers' attitude
towards origin labelling of meat used as an ingredient 30

3.3.1...... General attitudes and
perceptions of origin labelling. 30

3.3.2...... WTP for origin labelling
of meat used as an ingredient 32

3.3.3...... Reasons for consumer
demand for origin labelling. 40

4............ Possible scenarios
on the provision of origin information for meat used as an ingredient 42

4.1......... Scenario 1 – Maintain
origin labelling on voluntary basis. 42

4.2......... Scenario 2 – Introduce
mandatory origin labelling based on (a) EU/non-EU or b) EU/third country  42

4.3......... Scenario 3 – Introduce
mandatory origin labelling indicating the Member State or third country  44

4.4......... Other scenarios that
have not been examined in detail 46

4.4.1...... Mandatory labelling
indicating a higher/lower level of detail than a country/lower administration  46

4.4.2...... Mandatory origin labelling
based on origin split in three stages – "born, raised and slaughtered"
– following the model already applicable for unprocessed beef. 46

4.4.3...... Mandatory origin labelling
based only on the place of birth, or place of birth and slaughter or only place
of slaughter 47

5............ Feasibility and
Analysis of costs and benefits of the different scenarios concerning the
provision of origin labelling for meat used as an ingredient 47

5.1......... Impact concerning
consumer behaviour 47

5.2......... Technical feasibility. 48

5.3......... Economic impacts. 50

5.3.1...... Operating costs of FBOs. 50

5.3.2...... Traceability costs of FBOs. 52

5.3.3...... Competitiveness and trade. 55

5.3.4...... Administrative burden on
businesses. 57

5.3.5...... Burden on public
authorities. 57

5.3.6...... Costs for consumers and
possible social impacts. 58

5.3.7...... Environmental impacts. 59

5.4......... Overview of the costs
and benefits of the different scenarios under consideration. 60

ANNEX I: Glossary. 70

ANNEX II: Applicable definitions in the FIC Regulation
concerning origin. 72

Introduction

Consumers' sensitivity
to origin of foods has grown over the years. Many food businesses rely on
origin branding for marketing purposes due to favourable connotations of
specific countries or regions. Therefore, origin has become a relevant issue
not only for businesses but also for policy makers.

This Staff Working Document accompanies the
Commission report to the European Parliament and the Council regarding the
mandatory indication of the country of origin or place of provenance for meat
used as an ingredient, foreseen in Article 26(6) of Regulation (EU) No
1169/2011 of the European Parliament and of the Council on the provision of
food information to consumers (hereinafter, 'the FIC Regulation').[1]

It intends to present available information
and data concerning the potential extension of mandatory origin labelling for
meat used as an ingredient in prepacked foods, while taking into account
consumers' attitude and their need to be informed, the feasibility of providing
the mandatory indication of the country of origin or place of provenance and an
analysis of the costs and benefits of the introduction of such measures, including
the legal impact on the internal market and the impact on international trade.
It mainly builds upon the results of an external study commissioned by DG SANCO
and carried out between October 2012 and June 2013 by the Food Chain Evaluation
Consortium (FCEC), titled "Study on the application of rules on
voluntary origin labelling of foods and on the mandatory indication of country
of origin or place of provenance of meat used as an ingredient"
(hereinafter the 'FCEC study')[2]
as well as on other available sources on this subject.

1            The FIC Regulation on origin of foods

1.1         Background to the adoption of the FIC Regulation
concerning origin labelling of foods

Prior to the adoption
of the FIC Regulation, there were no Union provisions imposing mandatory origin
labelling on foods in general on a horizontal basis.  Directive 2000/13/EC of
the European Parliament and of the Council of 20 March 2000 on the
approximation of the laws of the Member States relating to the labelling,
presentation and advertising of foodstuffs[3]
requires that labelling must be such as not to mislead the consumer as to the
characteristics of the food including its origin or provenance.[4] In addition, it
provides that indication of the place of origin or provenance of a food is
mandatory where its omission might mislead the consumers as to the true origin
or provenance of the food.[5]

Mandatory origin
provisions have been developed on the basis of vertical approaches for certain
foodstuffs. Indeed, the indication of origin is currently mandatory for unprocessed
beef and beef products (e.g. minced beef) in the Union following the
bovine spongiform encephalopathy crisis. Regulation (EC) No 1760/2000 of the
European Parliament and of the Council of 17 July 2000 establishing a system
for the identification and registration of bovine animals and regarding the
labelling of beef and beef products[6]
requires the indication of the country of birth, rearing and slaughter on
(prepacked and non-prepacked) unprocessed beef meat and beef products[7] (or the indication of
one origin where all three stages took place in the same country).[8] Similarly, Commission
Regulation (EC) No 543/2008 of 16 June 2008 laying down detailed rules for the
application of Council Regulation (EC) No 1234/2007 as regards the marketing
standards for poultry meat[9]
requires the indication of country of origin on prepacked imported poultry
meat.[10]
Finally, mandatory origin provisions have also been developed for some other
specific products, such as honey,[11]
fruit and vegetables,[12]
fish,[13]
and olive oil.[14]
However, the underlying motivations for these provisions are different. While
in the case of beef and beef products, the introduction of mandatory origin
labelling is rooted in a food safety crisis, for all other specific food
products, the rationale is rather the close link between the origin and the
specific characteristics of the foods in question.

1.2         The provisions of the FIC Regulation on the origin
labelling of foods

The FIC Regulation
introduces – for the first time – specific provisions concerning the indication
of origin on foods[15]
on a horizontal basis. It introduces mandatory origin labelling for unprocessed
meat of swine, poultry, sheep and goat. It also provides harmonised rules
concerning the origin of the primary ingredient(s), when the origin of a food
is given. Finally, it acknowledges the need to explore the possibility to
extend mandatory origin labelling for other specific categories of foods on the
basis of Commission reports, including meat of all species when used as an ingredient
in prepacked foods.

1.2.1      Provisions concerning mandatory origin labelling of
unprocessed meat of swine, poultry, sheep and goat

The impact assessment
that supported the FIC Regulation indicated that the origin of meat appears to be
consumers' prime concern.[16]
Accordingly, Article 26(2)(b) of the FIC Regulation requires the mandatory
indication of country of origin or place of provenance for prepacked
unprocessed[17]
meat of swine, poultry, sheep and goats as from 13 December 2014.

The foods concerned are
the following:[18]

- 
CN Code 0203: Meat of swine, fresh, chilled or
frozen;

- 
CN Code 0204: Meat of sheep or goats, fresh,
chilled or frozen; and,

- 
CN Code Ex 0207: Meat of the poultry of heating
0105 (fowls of the species Gallus domesticus, ducks, geese, turkeys and
guinea fowls), fresh, chilled or frozen.

The FIC Regulation
requires the Commission to adopt implementing acts by 13 December 2013, setting
out the modalities of such mandatory origin labelling, following an impact
assessment, and taking into account the following points in the life of the
animal: place of birth; place of rearing; and, place of slaughter.[19] For this purpose, the
Commission commissioned an external study to consider the impact of mandatory
origin labelling to the supply chain of unprocessed meat of swine, poultry,
sheep, as depicted below. [20]

1.2.2      Provisions concerning the origin of main ingredients

In some cases, food
business operators ('FBOs') indicate the origin of a food on a voluntary basis
to draw consumers' attention to the qualities of their product. The FIC
Regulation sets out harmonised criteria for such labelling. Accordingly,
Article 26(3) of the FIC Regulation provides that where the country of origin
or the place of provenance of a food is given and where it is not the same as
that of its primary ingredient:

a) the country of origin or place of provenance of the primary
ingredient in question shall also be given; or,

b) the country of origin or place of provenance of the primary
ingredient shall be indicated as being different to that of the food.

The Commission is
required to adopt implementing acts setting out the modalities for the
application of this origin requirement by 13 December 2013, following an impact
assessment.[21]

1.2.3      Commission report on the mandatory indication of origin
for meat used as an ingredient

The present analysis
supports the Commission report regarding the mandatory indication of the
country of origin or place of provenance for meat used as an ingredient,
foreseen in Article 26(6) of the FIC Regulation.  In order to collect the
necessary data and input, the Commission commissioned the FCEC study. The present
Staff Working Document is largely based on the findings of that study. It also
takes into account relevant findings from the impact assessment underpinning
the mandatory indication of origin for prepacked unprocessed meat of swine,
poultry, sheep and goats[22]
as well as other available information.

1.2.3.1   Scope
of the Staff Working Document

The present Staff Working Document concerns
only prepacked foods with meat used as an ingredient. In the EU, meat (in
general) is sold pre-packed. Around 70% of the EU respondents buy fresh meat,
including meat preparations as well as processed meat products covering beef,
pig, lamb and poultry meat either in hypermarkets, supermarkets, convenience or
discount stores, where such products are generally prepacked. [23]

It covers meat ingredients of all species, i.e.
beef, pig meat, poultry, sheep and goat meat, game, rabbit meat and horse
meat.

Foods with meat used as an ingredient and
placed on the EU market, are quite varied. In broad terms, three categories of
such foods in an increasing order of processing can be identified: [24]

- 
Category I - Meat preparations and products
made from mechanically separated meat ('MSM'): This
category is closer to unprocessed meat in the food chain.

- 
Category II - Meat products

- 
Category III - Multi-ingredient foods with
meat used as an ingredient: The multi-ingredient foods with meat used as an ingredient include
foods where meat is the primary ingredient, e.g. beef lasagne, chicken
soup etc., as well as foods where meat is not the primary ingredient,
e.g. pizza with ham.  This category is the farthest from unprocessed meat in
the food chain.

1.2.3.2   Context
of the analysis

The present Staff
Working Document explores the possibility to extend mandatory origin labelling
for meat of all species used as an ingredient in prepacked foods, taking into
account the following:

a) Characteristics of the food supply and processing chain concerning
meat ingredients: The current structure and characteristics of the food supply
and processing chain in relation to meat preparations/products made from MSM,
meat products and multi-ingredient foods with meat ingredients is analysed. It
presents an estimation of the frequency of changing supply sources and mixing
meat of different sources by the food industry for the purposes of foods with
meat ingredients.  It also explores the adequacy of existing traceability
systems to support the possible introduction of mandatory origin labelling for
meat used as an ingredient;

b) The consumers' attitude towards origin labelling of meat
ingredients: The focus is on the consumers' interest, understanding and
preferences in relation to information on origin, to different types of origin
labelling of meat ingredients as well as on consumers' willingness to pay more
for the provision of origin information; and,

c) The feasibility and an analysis of costs and benefits in terms of
impacts of the main possible scenarios to be considered for origin labelling of
meat used as an ingredient, including an analysis of advantages and
disadvantages of the modalities for the determination of origin indications.

2            The EU Supply chain of foods with meat ingredients

2.1         Overview of the EU sector

The EU food sector[25] represents a total turnover of EUR 1017 billion with
approximately 287,000 companies employing 4.25 million people in the EU. Around
98% of these companies are SMEs, which represent around 49% of total turnover
and 63% of the employment in the sector. It is the largest EU manufacturing
sector in terms of turnover, value added and employment. It contributes around
15% of the gross value added of the EU manufacturing sector. The net trade
balance was EUR 13.2 billion in 2011.

Table 1: EU27 data on Food and drink industry
(turnover, number of employees, trade)

|| 2010 || 2011 || 2011/2010 (%)

Turnover (EUR billion) || 953 || 1.017 || + 6,8

Number of employees (million) || 4,25 || 4,25 || 0

Exports (EUR billion) || 65,2 || 76,2 || + 16,6

Imports (EUR billion) || 55,5 || 63 || + 13,5

Source:
Eurostat 2011

However, while the food sector is big in
size, combining several important sub-sectors (e.g. meat and dairy, beverages,
fish), it is also highly heterogeneous across its various sub-sectors.

The EU meat sector is the largest
sub-sector of the EU food and drinks industry, representing 20% of total food
and drinks turnover in 2010 and 20% of the total food and drinks valued added.
It employs around 21% of total workers in the EU food and drink industry (2010
figures). The EU meat processing industry represents more than 13,000 companies,
which generate an estimated EUR 85 billion in turnover and employs about
350,000 people. [26].

The meat supply chain
of meat to be used as an ingredient is both highly heterogeneous in actors involved
as well as in products: The processed meat sector is characterised by a
significant share of small and medium-size enterprises ("SMEs"). Regarding
products, it can range from relatively simple, e.g. fresh meat with
spices/additives to extremely sophisticated meat-related products, especially
in the case of meat products and multi-ingredient foods with meat ingredients.

Moreover, the supply
chain of meat used as an ingredient is quite complex, involving several steps
in production and marketing of the final products.

Figure 1: Overview of the supply chain[27]

2.2         EU
consumption of meat and meat-related products and
global trends

The overwhelming majority of EU consumers
(83%) eat meat at least two or three times a week.[28] In addition, 88% of the EU27 consumers bought pre-packed
(unprocessed and processed) meat in the past month.[29] The majority of meat (processed and unprocessed) is pig (49%),
poultry (29%) and beef (19%), while sheep, goat and other meats (e.g. horse,
rabbit and game) account only for 3% of EU meat consumption.

Figure 2: Consumption of different types of meat in
the EU[30]

Direct human consumption in 16 Western
European countries is valued at EUR 117.3 billion (2008), or 10.6% of the all
food and drink market of EUR 1111 billion. The largest country market is
Germany, with a 33% share of the total EUR 117.3 billion (2008) for 20% of the
total population; France, Italy, the U.K. and Spain make up 80% of the West
European market for 77% of the total population.[31]

In the EU, the consumption
of meat is expected to decrease in total by 0.4% in 2013. Only poultry meat has
shown signs of growth throughout the year 2011 and is therefore expected to
increase further (2.2% projected growth) also due to its healthy image and
relative cheapness.

When focusing on the
beef meat sector, the firm beef meat prices in 2013 cause per capita
consumption to continue to decrease, albeit at a slower rate. Nevertheless,
improvement in the economic situation of most EU countries and slightly more
meat supplies in 2014 could stabilize consumption at 10.8 kg per capita.

For pig meat, firm
prices and limited supply are expected to lead to a decrease in both
consumption and exports in 2013. Projected lower cereal prices on the assumed
good 2013 harvest are expected to help increase production and stabilise
consumption in 2014.

Lastly, the total
consumption of sheep meat in 2013 is likely to increase after several years of
continuous decline thanks to higher availabilities implying relatively lower
prices in 2013.

However, regarding
global meat consumption, per capita consumption is expected to increase by 3,2
kg per annum, with poultry accounting for 70% of this increase. Until 2021, a
further increase mainly in developing countries by an extra 3,6 kg of meat per
capita compared to the base period is expected. This increase will mostly be in
poultry meat. The high prices of meat will not discourage the developing
countries to increase their imports, increase driven mainly by population and
income growth expected in years to come.

Table 2: World meat consumption

Source: AVEC
Annual report 2012

2.3         EU
production and outlook – Global trends

Generally, 30-50% (depending on the Member State concerned) of the total slaughtered meat volume is estimated to be processed
into meat ingredients for foodstuffs (mostly into minced meat/meat
preparations/meat products).[32] The EU pig meat sector has the largest
share of processing compared to other meat sectors. In total, an estimated 70%
of the EU processed meat production volume is made of pig meat, followed by
poultry meat (18%) and beef meat (10%).

In that respect, the bulk of EU imports for
processing is accounted by a handful of suppliers, with Brazil and Thailand being the leading exporters to the EU for poultry and beef. Imports of pig meat
and sheep meat from third countries for processing are virtually non-existent.

Figure 3: Share of processed meat sector, by animal
species (%)

Source: FCEC
based on consultation with industry stakeholders

In 2012, EU total fresh meat production was
43.5 million tonnes carcass weight equivalent (around 33.8 million tonnes
boneless meat equivalent). According to medium term market forecasts, total EU
meat production, after having increased during both in 2010 and 2011, will contract
by 2% over the next two years. After this reduction, total meat production is
projected to steadily recover over the ten year horizon and to reach almost 45
million tonnes in 2022, approximately the same level recorded in 2011[33].

As far as
global trends are concerned, the developing countries will continue to conquer
global production share in meat categories, which by the end of the period will
account for 63% in poultry production, 58% for bovine, 64% for pig and 78% for
sheep meat.

Table 3: World meat production forecast

Source: AVEC
Annual report 2012

2.4         Structure
of the sector

The EU meat processing sector is characterised by a low
degree of vertical integration[34], with the majority of companies being SMEs (90%).
Characterised by a high level of specialisation, these SMEs operate
independently at different stages of the supply chain. This is particularly the
case for the pig meat and beef meat sectors. Larger vertically integrated
companies represent a small share of all companies operating in the EU meat
processing industry and tend to be more prevalent in the poultry sector.

Table
4: Share of micro-enterprises in total
number of enterprises in EU MS by sub-sectors (2008)[35]

|| Processing and preserving of meat and production of meat products || Total

|| Total || Micro || Share || Total || Micro || Share

AT || 1,092 || 763 || 70% || 1,312 || 907 || 69%

BE || 823 || 571 || 69% || 1,470 || 1,020 || 69%

BG || 475 || 201 || 42% || 885 || 381 || 43%

CY || 71 || 46 || 65% || 256 || 201 || 79%

CZ || 1,467* || : || : || 1,613 || : || :

DK || 147 || 89 || 61% || 408 || 232 || 57%

EE || 53 || 20 || 38% || 156 || 63 || 40%

FI || 204 || 142 || 70% || 480 || 355 || 74%

FR || 10,410* || : || : || 12,363 || : || :

DE || 11,044 || 6,558 || 59% || 12,098 || 7,028 || 58%

HU || 592 || 334 || 56% || 901 || 517 || 57%

IE || 133 || 26 || 20% || 318 || 83 || 26%

IT || 3,559 || 2,495 || 70% || 7,875 || 5,606 || 71%

LV || 128 || 62 || 48% || 294 || 121 || 41%

LT || 176 || 69 || 39% || 336 || 162 || 48%

LU || 27 || 14 || 52% || 32 || 15 || 47%

NL || 491 || 325 || 66% || 1,046 || 691 || 66%

PL || 3,283 || 2,134 || 65% || 4,872 || 3,224 || 66%

PT || 633 || 382 || 60% || 1,411 || 891 || 63%

RO || 909 || 532 || 59% || 1,711 || 1,058 || 62%

SK || 72 || 17 || 24% || 178 || 23 || 13%

SI || 163 || 110 || 67% || 271 || 198 || 73%

ES || 4,153 || 2,771 || 67% || 7,141 || 4,295 || 60%

SE || 494 || 367 || 74% || 935 || 746 || 80%

UK || 1,035 || 545 || 53% || 2,347 || 1,354 || 58%

Total || 29,757** || 18,573 || 62% || 60,709 || 29.171 || 48%

Source: Eurostat (GR and MT are not included in Eurostat dataset; Figures in Total column includes all available data) *2007 figure  ** Sum does not include CZ and FR.  *** Sum does not include BE, FR, DE

Meat processors tend to
procure raw material mainly from traders. Indeed, unprocessed standard quality
meat ingredients, such as pig meat, which is the predominant ingredient in EU
processed products, is generally sold on spot markets.[36] As such, there is almost no relation between slaughterhouses and
meat processors. However, larger vertically integrated companies tend to
procure both from slaughterhouses/cutting plants and traders.

Once the companies
process meat ingredients and incorporate them into meat-related products, these
are then further sold to retailers/catering/butchers, whether or not sliced
and/or packed.

Due to the
characteristics of the EU meat processing sector, including the increase in the
level of homogeneity of raw material in the meat supply, there seems to be
limited demand from processors for origin information on meat ingredients.
Indeed, there is no demand for origin information with respect to re-composed
products (e.g. meat preparations containing minced meat) or other
products involving trimmings[37] (e.g. mortadella, sausages, burgers, salami).

Any limited demand for
origin information mostly concerns:

- 
specific meat preparations coming from a 'single
meat piece', e.g. dried ham, cooked ham, pancetta/bacon, etc.;

- 
products for which meat is a specific condition
for the production process, such as:

Ø 
pig meat products from special breeds of pigs,
which fall under "protected designations of origin" ('PGIs'), e.g.
Iberian black pigs;

Ø 
specific beef products, e.g. bresaola,
require quality specifications of meat that can be assured in sufficient
quantity only by a specific origin (e.g. beef from Brazil or Argentina).

For the majority of products – and in
particular meat preparations such as burgers and sausages – the raw materials
arrive at the processing stage already cut, mixed and/or trimmed. The product
sectors using trimmings are quite extensive. For example, the German meat
industry (BDVF) indicated that 30-40% of their sausage production involves
trimmings (Boeckwurste) and often all ingredients are already mixed in
the cutting plants.[38] In that context, origin is not viewed as a quality specification by
the food chain operators.

Even when trimmings or blending of raw
materials is not involved prior to the arrival at the processing plant, origin
labelling may still be a challenge due to the extent of the mix of suppliers.
According to the Italian processed meat industry (ASSICA), even though Italian
products such as pancetta and dried ham do not involve mixing of
different meat ingredients, in practice they do have a continuous mix of source
of suppliers.

Producers of multi-ingredient foods with
meat ingredients procure raw materials for their products from a wide-range of
suppliers along the food chain, (e.g. cutting plants, processors, MSM
producers, wholesalers or traders). These operators do not have enough
bargaining power to impose the indication of origin to their suppliers, as the
quantities supplied are relatively small compared to other key buyers (e.g.
butchers).[39]

Slaughterhouses and meat cutting plants are
key actors with respect to passing meat origin information to the next player
in the food chain. Moreover, the higher the degree of vertical integration and
the larger the company size is, the easier it is to ensure that origin
information is passed along the food chain.  However,
because of this structure of the supply chain (mostly independent SME companies
operating in the meat sector) and the absence of any
significant 'business-to-business' interest in this information as explained
above, the transmission of origin information tends to stop at the earlier
stages of the supply chain (slaughterhouses and cutting plants).

Box 1: SME survey

In early 2013, a special survey was conducted through
the Enterprise European Network (EEN) for the purposes of the Commission report
on the possibility to extend mandatory origin labelling to meat used as an
ingredient. It was answered by 285 FBOs from EU27 MSs. The main findings
concerning the structure of the sector can be summarised as follows:

v Approximately 51% of the sampled FBOs were active in
the production of meat and poultry meat products sector, approximately 33% of
the sampled FBOs were active in the manufacturing of prepared meals and dishes
sector, while another 31%  were active in the processing and preserving of meat
sector (some FBOs are active in more than one sector). Almost 80% of the sampled
FBOs were manufacturing firms.

v Concerning the location of the trade/commercial
activity of the sampled FBOs, 31% of those reported that 81%-100% of their
activity is local. For 64% of those, none of their production is described as
"Intra EU" (i.e. it is limited within a Member State) and for 72%,
none of their production is set "Extra EU".

v About the origin of their primary raw material, 20% of
the sampled FBOs identified their raw materials as national, whereas 44%  and
75% of the sampled FBOs stated that almost none of their raw materials
originated in Intra-EU"  and "Extra-EU" respectively.

v 58% of the sampled FBOs do not have separate storage facilities
for raw materials from different sources.

v According to the sampled FBOs, the main advantages
stemming from informing the consumer about the provenance of the meat are
mainly the fact that it gives reassurance about the quality of the product
(61%) and that it helps differentiating amongst the available products (44%).

Box 2: Current application of origin labelling to meat and
meat-based products – Overview of voluntary schemes[40]

According to both Member States' competent authorities
('MS CA') and the EU meat processing industry (CLITRAVI, UECBV), the use in
meat and meat-based products of voluntary schemes approved at national or
concerted industry level concerning the origin of meat ingredients is generally
limited. The existence of a scheme comprising the geographical origin of meat
(or more generally of food) was indicated by 11 MS CAs out of the 19 MS CAs
that responded to the FCEC consultation. Where such schemes exist, they tend to
be mostly private and are not related only to geographical origin labelling but
form part of a wider quality initiative.

Only Austria indicated it had a national scheme, while
some MSs have private schemes in place which in some cases are supported by the
public sector or may be implemented in the framework of national legislation.
These schemes considered to account for a significant part of the market in only
a few MSs and if so, it tends to be for the specific species and meat products
covered by the scheme. For example in France, the brand Viande Porcine
Française (VPF) now account for 25% of the total French pig meat production
and 40% of French cooked ham production.  CA and FBOs in several MS (e.g. DK, SK, EL, ES, LT, PT) indicated that there are no national schemes that include origin
labelling information and that they are not aware of any such private schemes
in their countries. Analysis of the uptake of such schemes demonstrates that a
key constraining factor for consumers is the fact that these products are sold
at a price premium.

2.5         Sourcing practices of the supply chain[41]

The sourcing decisions
taken at production level largely depend on the following factors:

- 
availability of suitable raw material in
sufficient volumes;

- 
standard quality specifications, determined by
the quality specifications of the final products (i.e. premium or lower value);

- 
the competitive price;

- 
the need to quickly adapt to any shortages,
market disruptions and/or price fluctuations, by switching suppliers.

Single sourcing
practices for foods with meat used as an ingredient are limited, if not
negligible. The most common sourcing practices are multiple sourcing from
different sources/counties (either only EU, or a combination of EU/non EU).
This means that different stages of the production of foods containing meat as
an ingredient often take place in different EU Member States ('MSs) and there
is significant intra-Union trade of meat-related raw materials.

In general, the
sourcing practices can be described as follows:

- 
Multiple sourcing within the EU is the prevailing
practice for (a) pig meat based products, as the EU is self-sufficient in terms
of pig meat production, and (b) multi-ingredient foods with meat ingredients.

- 
Multiple sourcing from EU and non-EU countries
is common feature for beef and poultry meat based products.

The frequency of
changes in the mix of suppliers is affected by the same factors as sourcing
patterns. The differentiation of sources in particular is a common strategy to
reduce the risk of delivery failure driven by external factors (e.g. animal
diseases or food safety crises). FBOs, and especially SMEs, tend to change
their suppliers three or more times per year, in order to guarantee an adequate
level of raw material at an affordable price.

Figure 4:
Structure of the supply chain[42],

2.6         Traceability systems

Food traceability is
the ability to track any food, food producing animal or substance that may be
destined for human consumption through all stages of production, processing and
distribution of foods. For the proper application and enforcement of origin
labelling, an effective traceability system is required to ensure the passing
of the origin information along the food chain.

2.6.1      Existing
EU traceability systems

2.6.1.1   General EU traceability
requirements

The EU traceability legislation aims at
ensuring food safety. Accordingly, Regulation (EC) No 178/2002 of the European
Parliament and of the Council of 28 January 2002 laying down the general
principles and requirements of food law, establishing the European Food Safety
Authority and laying down procedures in matters of food safety[43] sets out a comprehensive system of traceability within food and
feed businesses to meet this objective.  The
traceability requirements can be summarised as follows:[44]

- 
The traceability of food, feed, food-producing
animals, and any other substance intended to be, or expected to be,
incorporated into a food or feed should be established at all stages of
production, processing and distribution.

- 
FBOs must be able to identify any person from
whom they have been supplied with a food, a feed, a food-producing animal, or
any substance intended to be, or expected to be, incorporated into a food or
feed. To this end, FBOs must have in place systems and procedures that allow
for this information to be made available to the CAs on demand.

- 
FBOs must have in place systems and procedures
to identify the other businesses to which their products have been supplied.
This information must be made available to the CAs on demand.

- 
Food or feed which is placed on the market or is
likely to be placed on the market in the Union must be adequately labelled or
identified to facilitate its traceability, through relevant documentation or
information in accordance with the relevant requirements of more specific
provisions.

The requirement to identify suppliers and
other businesses to which products are supplied is known as the ‘one step
back - one step forward’ approach. The ‘one step
back - one step forward’ approach implies for FBOs that:

- 
They must have in place a system enabling them
to identify the immediate supplier(s) and immediate customer(s) of their
products;

- 
a link ‘supplier-product’ must be established
(which products supplied from which suppliers);

- 
a link ‘customer-product’must be established
(which products supplied to which customers). Nevertheless, FBOs do not have to
identify the immediate customers when they are final consumers.

As such, the existing traceability
requirements do not foresee a cumulative traceability system.

The traceability requirements set out in Regulation
(EC) No 178/2002 are worded in terms of their goal and intended result, rather
than in terms of prescribing how that result is to be achieved. This allows certain flexibility to the FBOs in the implementation of
these requirements.

As far as foods of animal origin are
concerned, Commission Implementing Regulation (EU) No 931/2011 of 19 September 2011 on the traceability
requirements set by Regulation (EC) No 178/2002 of the European Parliament
and of the Council for food of animal origin[45] sets out additional traceability
requirements. In particular, it applies to unprocessed and processed foods of
animal origin.[46] It requires FBOs to ensure that the following information
concerning consignments of food of animal origin is made available to the FBO
to whom the food is supplied and, upon request, to the CA:

a) 
an accurate description of the food;

b) 
the volume or quantity of the food;

c) 
the name and address of the FBO from which the
food has been dispatched;

d) 
the name and address of the consignor (owner) if
different from the FBO from which the food has been dispatched;

e) 
the name and address of the FBO to whom the food
is dispatched;

f) 
the name and address of the consignee (owner),
if different from the FBO to whom the food is dispatched;

g) 
a reference identifying the lot, batch or
consignment, as appropriate; and

h) 
the date of dispatch.

These information requirements must be
updated on a daily basis and kept at least available until it can be reasonably
assumed that the food concerned has been consumed.

In addition, Regulation (EC) No 853/2004 of
the European Parliament and of the Council of 29 April 2004 laying down
specific hygiene rules for food of animal origin[47] requires that products of animal origin should have an
identification mark indicating the last approved establishment in which the
product was handled. The identification mark must indicate the country where
the establishment is located and its approval number. Establishments located
within the Union must be indicated as EC (or equivalent abbreviation in other
languages).

Imports of live animals and animal products
from third countries into the EU are governed by detailed legislation in the
veterinary field. Third countries exporting to the EU must have traceability
systems in place for exports, which are able to provide equivalent standards to
those in the EU. In that respect, Regulation (EC) No 853/2004 sets out general
obligations for the importation of products of animal origin from third
countries, including the fact that foods of animal origin can only be imported
from countries and establishments laid down in EU lists.

2.6.1.2   Specific
requirements for unprocessed beef

With regard to bovine animals and
unprocessed beef, Regulation (EC) No 1760/2000[48] and Commission Regulation (EC) No 1825/2000[49] lay down mandatory origin labelling as well as detailed
traceability requirements for bovine animals and fresh, chilled or frozen beef
products for the purposes of food safety, origin labelling and animal health
including disease control. Operators at all stages of production up to the
point of sale must have systems in place to ensure the link between bovine
animals, carcasses and/or cuts of fresh, chilled or frozen beef including
minced beef. In that respect, the following indications must be included on the
label of such food products:

- 
a reference number or code linking the meat to
an animal or group of animals;

- 
the approval numbers of the slaughterhouse and
cutting plant;

- 
the Member State or third country of birth;

- 
the Member State or third country of rearing;

- 
the Member State or third country of slaughter;

- 
the Member State or third country of cutting.

Where meat is derived from animals born,
reared and slaughtered in the same Member State or third country, the
indication may be given as ‘Origin: [name of Member State/third country]’.Where
beef is derived from animals that have been reared for 30 days or less, the
indication of origin should provide:

- 
the Member State or third country of birth, or;

- 
the Member State or third country where
slaughter took place;

Where full information is not available for
beef imported from third countries, it may be permitted to state the country of
origin as ‘non-EU’, provided that the name of the third country of slaughter is
indicated. In this case, live animals must generally have been kept for a
minimum of six months in the designated country before slaughter and export of
the beef into the EU.

A derogation is allowed for minced meat
where the label must indicate as a minimum ‘Prepared: [name of Member
State/third country]’ to show where the minced meat was prepared; and ‘Origin:
[name of Member State/third country]’ if the meat originated from a country or
countries other than the country of preparation.

Traceability of processed beef meat is
subject to the general requirements of Regulations (EC) No 178/2002 and
931/2011, which do not address the passing of origin information along the food
chain.

2.6.1.3   Specific
traceability requirements for sheep and goats

Council Regulation (EC) No 21/2004[50] concerns the identification and registration of live sheep and
goats to permit individual traceability throughout their lifetime via
electronic identification for animals born after 1 January 2010, subject to
certain derogations.

The sheep and goat traceability system
enables the complete traceability within the EU of live sheep and goats through
individual electronic identification. Traceability, however, of unprocessed and
processed sheep and goat meat is subject to the general requirements of
Regulations (EC) No 178/2002 and 931/2011, which do not address the passing of
origin information along the food chain.

In addition, national databases containing
information on individual sheep and goat movements are not compulsory but may
be implemented voluntarily in Member States. The lack of national databases
makes full information on the origin of sheep and goat meat more difficult to
access than in other systems, particularly traceability of unprocessed beef.

2.6.1.4   Specific
traceability requirements for pig meat

Council
Directive 2008/71/EC[51]  concerns the
identification and registration of live pigs. Pigs must be identified and
registered in such a way that movements of animals and the farm of origin can
be traced rapidly and accurately. The pig identification system is based on batch
identification and not individual identification. In particular, Directive
2008/71/EC requires:

- 
identification marks to be applied before pigs
leave the holding of birth, making it possible to determine the holding of
origin;

- 
animal keepers must keep records of movements of
animals entering and leaving a holding, at least on a batch basis and including
the origin or destination, as applicable;

- 
keepers must supply the CA on request with all
information concerning the origin, identification and where appropriate the
destination of animals that they have owned, kept, transported, marketed or
slaughtered;

- 
these procedures apply to intra-Union movements;
and,

- 
pigs imported from third countries must be
similarly identified and a link established and recorded to identify the third
country. Imported animals going direct to a slaughterhouse need not be
re-identified.

The pig identification and recording system
enables identification of the holding and country of birth, and identification
of the last holding from which an animal has come. Intermediate holdings may be
traced through records of movements, although the system does not guarantee the
traceability of all intermediate holdings prior to the last holding for
individual animals. This system of traceability does not allow the passing of
information on origin along the full chain.

Traceability, however, of unprocessed and
processed pig meat is subject to the general requirements of Regulations (EC)
No 178/2002 and 931/2011, which do not address the passing of origin
information along the food chain. In addition, the national databases for pigs
do not contain information on individual movements, making it more difficult to
ensure the full origin information as regards pig meat, compared to the
traceability of unprocessed beef.

2.6.1.5   Specific
traceability requirements for poultry

Traceability of poultry meat is subject to
the general requirements of Regulations (EC) No 178/2002 and 931/2011, which do
not address the passing of origin information along the food chain. However,
Commission Regulation (EC) No 543/2008 requires mandatory origin labelling in
the case of prepacked poultry meat imported from third countries.

2.6.2      Evaluation
of existing traceability systems for the purposes of origin labelling

The existing
traceability systems are not adequate to pass on origin information along the
food chain for the following reasons:

- 
The existing EU food traceability rules are
based primarily on the need to ensure food safety: General EU traceability is
set up on the basis of the 'one step back – one step forward' approach along
the food chain to meet the objective of food safety. However, these
traceability requirements do not foresee readily origin information, as such.
Consequently, on the basis of the existing EU traceability legislation,
"cumulative traceability for origin purposes" is not currently
required at EU level.

- 
Where more detailed traceability systems exist,
these vary between the different animal species and do not extend beyond the
unprocessed phase: To date, the most developed traceability system with the
objective of passing origin information along the food chain is in the area of
unprocessed beef. This is not the case, however, for unprocessed and processed
meat of pigs, poultry, sheep and goats, as existing EU legislation does not
require all movements of these individual animals to be recoded on national
databases (although this may change with the future adoption of an implementing
act pursuant to Article 26(2)(b) of the FIC Regulation)[52], let alone for meat of other species, such as game, horse and
rabbit. Therefore, the access to origin information varies per animal species
and level of processing. Furthermore, the existing detailed traceability
systems, e.g. for beef (and in the future for pig meat, poultry, sheep and goat
meat), do not extend beyond the slaughterhouse/packing establishment stage.
This means that to ensure the passing of information on origin for processed
beef, additional traceability requirements would be needed.

- 
The implementation of the existing traceability
requirements result in varied traceability systems that are not always
homogeneous: As stated above, the EU requirements are worded in terms of their
goal and intended result, rather than in terms of prescribing how that result
is to be achieved, allowing certain flexibility to the
FBOs in the implementation of these requirements. However, the traceability
systems established by each FBO are not always homogeneous and can widely wary
in terms of performance, reliability and costs.[53]

- 
The more complex the cutting and processing
stages are and the more advanced the level of processing is, the more difficult
traceability becomes for the purposes of origin labelling: This is especially
the case for trimmings, which is a 'by-product' of the cutting operation. In
many instances, trimmings are used as raw material in foods with meat
ingredients. They arrive at the stage of further processing for incorporation
into intermediary or final products mixed up in batches and cannot be distinguished
by origin.[54] As such, origin labelling for any trimmings-based foods becomes
extremely difficult.

3            Consumers'
attitude towards origin labelling of meat used as an ingredient

This Chapter focuses on
consumer interest, understanding and preferences in relation to information on
origin of meat ingredients, taking into account the consumer willingness to pay
('WTP') for additional origin information. For the
purposes of this analysis, this Staff Working Document mainly relies on the
following consumer-related studies:

- 
FCEC consumer study (February 2013):[55]
The FCEC consumer survey was conducted in the context of the FCEC study. It
focused on the origin of meat used as an ingredient in foods covering meat
preparations, meat products and multi-ingredients foods with meat ingredients.
It covered 3,000 consumers in 15 MSs, accounting for 89% of the total EU
population. The FCEC study included also questions on WTP for each of the
categories of three product groups concerned.

- 
Consumer market study on the functioning of
the meat market for consumers in the European Union (2013):[56] The consumer market study on the functioning of the meat market for
consumers in the European Union ('GfK consumer study') focused on the following
meat related foods covering beef, pig, lamb and poultry meat, which are
available to the final consumers at the end of the food supply chain (at retail
level):

Ø 
Fresh meat (cuts and pieces of meat, for example
whole chicken, steak, minced meat etc. including frozen meat) and meat
preparations;

Ø 
Meat products processed in some way such as
marinated or cooked meat (e.g. salami, hot dogs, cooked ham, precooked sausages
etc.)

It covered
13,477 consumers in the EU 27 MSs and it was carried out in September 2011. In
addition, a mystery shopping audit of 10,570 products in the EU27 Member States
was conducted in order to gather data on the availability of products and
information items and to collect the prices of different meat products across
countries and purchase channels. The results of the consumer survey and the
mystery shopping exercise were also complemented with the results of
stakeholder consultations and desk research.

- 
BEUC consumer survey on origin labelling on
food (2013):[57]
The BEUC online consumer survey ('BEUC study') covered 4,168 consumers in four
MSs, i.e. Austria, France, Poland and Sweden and it was carried out in
July 2012. It focused on the origin of foods in general and addressed, amongst
others, fresh and processed meat. However, this study did not address the
consumer WTP for the additional origin information.

These findings are
further complemented with input from national CAs and industry stakeholders.

3.1         Consumers' attitude towards origin labelling of foods

3.1.1      Broader
studies

The results of the FCEC
consumer survey indicate that the origin of food products in general is the fifth
most important aspect influencing consumers' purchase decisions out of 11
aspects considered (47.4%), following taste (82%), 'best before'/'use by' dates
(62%), appearance (61.3%) and price (48.3%).

Figure 5:
Importance attached to different aspects influencing food product purchases
(average data for 15 EU countries)

Note:
percentages may not add up to 100% due to rounding

Source: FCEC consumer survey, 2013

Amongst the various food groups covered by
the FCEC study, interest in origin labelling for meat-based food has scored the
highest.

Figure 6:
Importance attached to the indication of origin on the food label (average data
for 15 EU countries)

Note:
percentages may not add up to 100% due to rounding

Source: FCEC consumer survey, 2013

These findings are also confirmed by the
BEUC study. According to the BEUC study, the origin of food comes at the fifth
or sixth place (ranging between 61% and 77% of respondents) in terms of the
factors consumers say they look at the most when choosing food in the four MSs
concerned, behind taste (ranging between 95% and 97%), price (89% to 93%), and
'best before'/'use by' dates (ranging between 81% and 94%). Moreover, in all four MSs surveyed, interest in origin labelling for meat (in
general) has scored the highest amongst eight categories of food products.[58]

3.1.2      National
studies and international literature

The findings of the
FCEC consumer survey are also confirmed by certain national studies.

- 
In the UK, research carried out for the
Food Standards Agency (FSA, 2010) includes a synthesis of findings from five
studies (BMRB, NatCen, Campden-BRI, Ipsos Mori and Oxford Evidentia) on
consumers’ perceptions and understanding of food labels. The omnibus survey
carried out for the UK FSA (NatCen, 2010)[59]
concluded that half of UK respondents (52%) reported looking for country of
origin labelling. Of these respondents, the food products they most commonly
used origin labelling for were fruit and vegetables (69%), fresh meat (57%) and
meat products (30%). Moreover, consumer research carried out in the UK 2011 and
2012 indicates that country of origin ranks as the fourth or fifth factor in
consumer purchase decisions behind price (clearly the leading factor),
health/nutritional values and promotions, at the same roughly position as brand
names and quality assurance scheme logos.[60]

- 
In Denmark, consumer
research provided by the DK CA on the reasons why Danish consumers buy Danish
food products indicates that price is the most important factor affecting
consumer choice (56% of respondents rate it as one of the top 3 factors),
followed closely by freshness (55%); origin related considerations are only
taken into consideration as one of the top 3 factors by
30% of respondents.

- 
Consumer organisations in Belgium, Czech Republic, Denmark, Spain, Greece, Italy and Portugal carried out consumer surveys
applying a similar approach as the BEUC survey.[61] The results of those
national consumer surveys are consistent with the findings of the FCEC consumer
survey.

All these studies indicate that price and
quality/sensory aspects are the most important factors affecting consumer
choice and in some cases well ahead of the origin of the meat. This is also
reflected in the limited studies that have explored the WTP issue vis-à-vis the
consumer interest in origin labelling information on foods:

- 
In a recent study carried out in the Netherlands,[62] it appears that only
10% of Dutch consumers are prepared to pay extra for origin labelling on food.  According
to respondents, among the reasons why people are unwilling to pay more for
origin labelling on food are that food is already expensive enough and should
not be made more expensive; they do not feel the need for it; origin labelling
should be provided as an additional free service; they do not consider that
origin labelling should involve extra costs; they have not asked for it.  When
asked who should pay for the costs of labelling, Dutch consumers pointed to the
producer, the government, the supermarket or the EU. Respondents did not seem
to feel it logical that they or the farmers should contribute to the costs.

- 
In a recent study carried out in Belgium,[63] only one third
of the consumers agree to pay until 5% more to know the country of origin of
food.

- 
The GFK Custom Research study carried out in Austria on WTP for regional food[64]
showed approximately one third would pay ≥15 %, another third would pay up to
10 % more and approximately one third is more or less not willing to pay more.

This low willingness among consumers to pay
for country of origin labelling on food is also demonstrated in international
literature. For example, for pork: Sweden (5.8%), France (4.8%), Britain (4.0%), Denmark (-2.9%).[65]

3.2         Consumers' attitude towards origin labelling of meat

3.2.1      Broader
studies

According to the 'GfK
consumer study on the meat market', the country of origin is the fourth key
information aspect (out of 15 information aspects) – looked for by the
consumers when they buy meat-related products, i.e. 48% of EU consumers,
without much difference between EU15 and EU12). Origin follows 'best
before'/'use by' dates (68%), price per kilogram (67%) and price (67%). Moreover, EU consumers are more likely to
look at the country of origin when buying fresh meat including meat
preparations (45%) than meat-based products (38%).[66]

Figure 7: Aspects
looked for when buying meat

The classification
of the country of origin with respect to the information aspects consumers look
for is to some extent consistent with the consumers' priorities at the moment
of the meat purchase. Survey respondents were asked to indicate the most and
least important factors they take into account when they buy meat. The factor 'meat
produced in consumer's country' ranked fifth, after freshness, taste, hygienic
display and 'the price is reasonable'.[67]

Figure 8: Factors
consumers take into account when buying meat (% share of each factor out of
100% for all 17 factors)

Again, the price aspect takes priority over
the origin of the meat. In that respect, for more than one third of consumers
(39%) who would like to buy origin certified meat more often (meat with quality
certifications referring to its origin), a common reason why they do not do so
is the higher price.[68]

3.2.2      National
studies

The origin of meat has also been the
subject of certain national studies. In Finland, consumers' interest in
origin labelling for meat has mainly been studied by several studies on food
more generally[69]:

- 
Omnibus surveys made in 2009 (n=1027) and 2010
(n=1028) indicate that more than 70% of the consumers said that the origin
labelling was important in making purchase decisions.

- 
"Suomi Syö 2011" survey (n~2000):
country of origin information was the third most-read labelling for making
purchasing decision, in particular regarding meat and fish. About 40 % of the
consumers checked the Good from Finland -labelling.

- 
"RISK 2012, Discover Food 2012 - Attitudes,
Trends, Events" survey (n=7062): more than one third of Finnish consumers
think that origin of food is important information. Factors most affecting the
consumption of meat are in terms of importance: price, country of origin and
quality.

3.3         Consumers' attitude towards origin labelling of meat
used as an ingredient

3.3.1      General attitudes and perceptions of origin labelling

With a more targeted examination on
different types of processed meat-based products, the FCEC survey results indicate that more than 90% of consumer
respondents find it important that origin is labelled, as follows:[70]

- 
On
meat preparations, 63% find it ‘very important’ and 31% ‘fairly
important’;

- 
On
processed meat, 60% find it ‘very important’ and 32% ‘fairly important’;
and,

- 
On
prepared food containing meat, 52% find it ‘very important’ and 35% ‘fairly
important’.

Nonetheless, the survey results reveal that
there are significant differences at MS level on this specific aspect. While
between 65% and 85% of respondents in Bulgaria, Greece, Italy and Romania
consider ‘very important’ that origin is labelled on all the three
meat-related products considered, only around 50% of respondents in Germany,
Spain and Lithuania deem it ‘very important’.

Consumers were asked more specifically the
level of detail that they find necessary to know on the origin of the meat
ingredients for each of the three meat-based product groups on the basis of
indicative examples:

- 
Example of meat preparations: uncooked
sausages or burgers;

- 
Example of meat product: cooked ham; and,

- 
Example of multi-ingredient food with meat
ingredients: frozen pizza with salami.

The following findings emerge from their
answers:

- 
Consumers
are, by and large, interested in knowing more about the origin of meat for all
the  three meat-based product groups;

- 
Consumers
indicated in all cases the highest interest to know the ‘country where meat
was produced’: nearly half of consumers (EU average) require this level of
detail on the origin, while roughly only a third of consumers require any other
level of detail (whether more general such as ‘produced in the EU or outside
the EU’, or more specific such as ‘the country where the animal was
born/raised/slaughtered’);

- 
There
are significant differences in all cases between MS, with consumers in some MS
consistently indicating more (or less) interest in origin information than in
others:

Ø In terms of the
most preferred type of information at EU level (the ‘country where meat was
produced’), 51%-69% of consumers, depending on the MS, want to know this in
the case of uncooked sausages or burgers, while in the case of cooked
ham this ranges from 33% to 67%. In the case of frozen pizza with salami
37%-64% of consumers, depending on the MS, want to know the ‘country where
salami was produced’.

Ø In terms of ‘the
country where the animal was born/raised/slaughtered’, in the case of uncooked
sausages or burgers 20%-55% of consumers, depending on the MS, want to know
this, while in the case of cooked ham this ranges from 17% to 49% of
consumers, and in the case of frozen pizza with salami from 12% to 41%
of consumers;

- 
Interest
to know more on the origin is the highest, irrespective of the level of detail,
in the case of uncooked sausages or burgers (example of a meat
preparation), which can be considered as the closest to fresh meat of all the 3
categories covered by the survey, followed (closely) by cooked ham (example
of meat product). Only 6% of consumers (EU average; at MS level, 2%-11% and
2%-13% of consumers respectively for each of these two products, depending on
the MS) indicated they are not interested at all in origin information, while
roughly a third of consumers indicated they need to know at least whether the
meat is of EU or non-EU origin;

- 
In
the case of frozen pizza with salami, although interest to know more on
the origin of the meat ingredients is lower than for the other two products, it
is still significant. Only 11% of consumers (EU average; 4%-24% of consumers
depending on the MS) indicated they are not interested at all in origin
information; while again roughly a third of consumers indicated they need to know
at least whether the meat is EU or non-EU origin.

The FCEC study did not explore what
consumers understand by the reference to "country where meat was
produced". However, the consumers’ understanding on the notion of origin
for processed meat, i.e. whether this refers to the place of provenance
of raw materials or place of processing, has been tested in BEUC’s consumer
survey and the surveys carried out independently by the other MS consumer
organisations (in BE, CZ, DK, ES, GR, IT and PT).[71]

BEUC’s research found that in terms of
consumers’ preferences for origin labelling on processed meat, the majority of
respondents in the 4 MS (between 53% and 69% depending on the MS) deemed it
equally important to know the country where the animal was farmed and where the
meat was processed. Similarly, the vast majority of respondents in Denmark (60%), Czech Republic (83%) and Greece (82%) have indicated that both pieces of information
are equally important.

Both the BEUC consumer survey and the
independent consumer surveys carried out by consumer organisations in Denmark, the Czech Republic and Greece reveal that consumers’ understanding of origin labelling on
processed meat varies between MS.

The results of the consumer surveys carried
out in Belgium, Portugal, Spain and Italy, reveal that the
indication of the country of origin specified on the label/poster of some
processed food products, including some meat based products (e.g sausages and
chicken nuggets) would in most cases be interpreted by the respondents as
referring to “the food [that] was processed into the final product in that
country, but some of the ingredients can originate from other countries”[72].

3.3.2      WTP for origin labelling of
meat used as an ingredient

The strong consumer interest in origin labelling is based on
qualitative data. As such, most existing studies on consumer interest in origin
labelling information do not explore the consumer's WTP. In the studies,
however, where the latter is explored, the strong consumer preference for
origin information is not reflected in the consumer WTP.

Box 3: WTP studies

If the focus is on individual well-being, a frequently-used
economic measure is one that will accurately measure individuals’ WTP. Although
these WTP studies elicit only values impacting the person whose value is
measured, missing values can be added later if the analysis is focused on
social costs.

The most direct means of assessing WTP is through a
stated preference survey asking individuals to state the value, for instance,
of acquiring more information on the origin of the meat contained in the
products that they consume. These studies will only be accurate, however, if
individuals answer survey questions in a fully informed and nonbiased manner.

Revealed preference (hedonic) studies are an
alternative to stated-preference surveys. Using this method, economists look at
actual behaviour in the marketplace and infer a value for a given attribute
(i.e. origin labelling) from product price differentials with varying levels of
the particular attribute. This type of study will only yield accurate estimates
if consumers have an intuitively accurate estimate of the risks associated with
alternative products.

The FCEC study included a question on WTP for each of the three product
groups covered by the survey (examples
for each group: uncooked sausages or burgers; cooked ham; and, frozen
pizza with salami).[73] Respondents were asked to highlight
their preference amongst the various labelling formulations and indicate what
price level (i.e. base price and increase on the base price) they are willing
to pay for this preference.

The following conclusions can be drawn from the results:[74]

- 
At
the base price, the majority of consumers opt for the highest possible level of
detail on origin information;

Figure 9: Uncooked sausages or burgers: WTP for
detailed information on the origin of meat (average data for 15 EU countries)

“When purchasing
uncooked sausages or burgers, how much more would you be willing to pay to have

more detail on the
‘origin’ of the meat?” (Question 12 of the
survey)

Figure 10: Cooked ham: WTP for detailed information on the
origin of meat (average data for 15 EU countries)

“When purchasing cooked ham, how much more would you be willing to pay
to have more

detail on the ‘origin’ of the meat?” (Question 14 of the survey)

Figure 11: Frozen pizza with salami: WTP for detailed
information on the origin of meat (average data for 15 EU countries)

“When purchasing a frozen pizza with salami, how much more would you
be willing to pay to have more

detail on the ‘origin’ of the meat?” (Question 16 of the survey)

Figure 12: WTP by type of indication of origin
(average data for 15 EU countries)

Base option including:
“No indication on the origin of the meat” and “Indication on the label whether
meat was produced in the EU or outside the EU”;

Country-region
level option” including:
“Indication on the label of the country where meat was produced” and
“Indication on the label of the country and the precise region/area where meat
was produced”;

Country-region
level option with 3 stages including: “Indication on the label of the country where
the animal was born / raised / slaughtered” and “Indication on the label of the
country and the precise region/area where the animal was born / raised /
slaughtered”.

- 
The
proportion of consumers willing to pay more than the base price for origin
information falls significantly, i.e. by 60-80%, depending on the
labelling option and the product, at the first price increase over and above
the base price (+5% to 9% depending on the level of information required). The
consumer WTP continues to fall with every further price increase, although less
dramatically, as it has reached already fairly low levels). Overall, for every
option on the level of detail on origin information, there is a 60-80% fall
(depending on the labelling option and the product) in the percentage of consumers
willing to pay the first price increase from the base price.

Figure 13:
WTP according to the level of detail provided on the indication of origin
(average data for 15 EU countries)

Note: Assuming
as equal to 1 the prevalence of consumers who are willing to pay the base price
(A), the graph represents the relative prevalence of consumers willing to pay
different price options.

(continued)

Figure 13
(continued): WTP according to the level of detail provided on the indication of
origin (average data for 15 EU countries)

- 
The
above-mentioned general findings apply in all three product categories covered
by the FCEC study, as there are no significant differences amongst them. Only
for the labelling options ‘country where meat was produced’, ‘country
where the animal was born/raised/slaughtered’ and ‘country and the
precise region/area where meat was produced’, the consumer WTP falls more
dramatically in the case of frozen pizza with salami (example of
Category III) followed by cooked ham (example of Category II) and
uncooked sausages or burgers (example of Category I).

These findings confirm a 'paradox' or a
discrepancy between consumers' interest in origin labelling and WTP for that
information. Consumers are largely unwilling to pay more than the
current base price for origin labelling information. However, they would be
interested in receiving the information – at the highest level of detail
possible - if this information was to be offered without any increase in price.

A recent Dutch study on the cost analysis
for producers and consumers of country of origin labelling explored the
consumer paradox.[75] According to the latter, consumers are generally not aware of the
additional costs related to origin labelling and believe that these are just
confined to 'the cost of some extra ink for printing'. This paradox is also
manifested in the gap that has been observed in a number of previous studies
between intentions and actual purchasing behaviour, with price being an
important factor that explains this gap.[76]

The FCEC consumer study findings on
consumer WTP for origin labelling for meat ingredients concur with the views of
MS CAs and of FBOs. The majority of MSs[77] considered consumer WTP for such information to be weak and in some
cases moderate, while 1 MS considered this to be absent; no MS considered it to
be strong.

Figure 14: Consumers’ WTP for additional origin information on meat
ingredients, in your country (responses from MSs CAs, n=19)[78]

Source: FCEC,
based on consultation with MS CAs

An indication that
supports the finding that consumer WTP for additional origin information on
meat ingredients is relatively weak is the fact that voluntary schemes as such
remain confined to particular MSs and product groups. Indeed, should consumers be
willing to pay more for additional origin information, there would have been a
bigger proliferation of such schemes, which is not the case to date. Moreover,
analysis of the uptake of such schemes demonstrates that a key constraining
factor for consumers is the fact that these products are sold at a price
premium (19% more expensive than regular meat). [79]

3.3.3      Reasons for consumer demand for origin labelling

Information about a
product's country of origin influences the consumer decision-making process. Therefore,
it is appropriate to explore the reasons underpinning the consumer demand for
origin labelling.

The GfK consumer study
on the meat market found that the indication 'meat produced in consumer's
country', received a high score (5th most important factor in the
consumer decision-making process).[80]
In that respect, some of the national stakeholders mentioned that consumers in
their respective countries express a preference for national meat. This was
particularly mentioned for Greece, France, Poland, Austria and Sweden. Only a handful of stakeholders thought consumers in their countries preferred
foreign meat; this was mentioned for Portugal and Slovakia. This national
preference can be emotional, in terms of nation identity or pride, but also
rational, as consumers may have a better knowledge of national products and
processes.

In past consultations
and in relation to meat and meat products, consumers had also linked origin
with safety. While there are legitimate reasons for wanting to know the origin of
a food (e.g. support for local produce, characteristics of the product, ethical
and environmental concerns), other reasons that have been quoted are not
pertinent. This is the case specifically when origin is linked with safety, as
products produced anywhere in the EU or imported into the EU are, by
definition, 'safe'. [81]

This finding was
confirmed also in the GfK consumer study on the meat market. According to the
latter study, origin is also related to safety as far as consumers are
concerned. Due to a tendency to ethnocentrism, consumers perceive meat (in
general) from their own country as safer than foreign meat. Disease outbreaks
also lead consumers to mistrust foreign meat and trust more domestic meat.[82]

A similar tendency
seems to have been confirmed in the recent horsemeat crisis, which broke in
late 2012/early 2013. Indeed, following official controls in a number of Member
States, it was established that certain pre-packaged foods contained horsemeat,
which was not declared in the list of ingredients appearing directly on the
package or on a label attached thereto. Instead, the name of certain foods
and/or the accompanying list of ingredients misleadingly referred solely to the
presence of beef.

In that context, there
were calls from consumers' associations, members of the European Parliament and
national authorities for introducing mandatory origin labelling for foods
containing meat as an ingredient. In response to these calls, the Commission
underlined in many occasions that the undeclared presence of horse meat in
foods sold/marketed as containing beef misled the consumers as to the content
of the food and therefore constituted fraud in food labelling. Mandatory origin
labelling is not a tool to prevent fraud by malicious operators. The horsemeat
scandal would have occurred even if origin labelling was mandatory for the
foods in question. Such deceptive practices can be eliminated by appropriate
enforcement of EU legislation mainly by means of regular official controls by
national authorities based on appropriate risk analysis and the imposition of
effective dissuasive sanctions, in accordance with Regulation (EC) No 882/2004
on official controls.[83]

These findings are also
confirmed by a number of national surveys. In the UK, the omnibus survey carried
out for the UK FSA (NatCen, 2010)[84]
concluded that of those who looked for country of origin labelling (i.e. 45% of
respondents, independent of the food category), the most commonly cited reason for
doing so was in order to buy British (34%). Similarly, in France, the results
of the national consumer’s organisation (CLCV) carried out recently an on-line
survey[85]
show that the provision of origin is considered primarily as a means to
contribute to the economic development of a region or country (cited by 71% of
respondents), followed by reasons related to the environment (66%), social
(63%) and product safety (62%).

4            Possible
scenarios on the provision of origin information for meat used as an ingredient

In this chapter, the
main possible scenarios, accompanied by proposed modalities where appropriate,
are being presented concerning the provision of origin information for meat
used as an ingredient. These scenarios and modalities take into account the
following elements:

- 
The stages in the life of an animal: place of
birth, place of rearing and place of slaughter.

- 
The geographical level of origin or provenance:
third country/EU/Member State/region /local level.

4.1         Scenario 1 – Maintain origin labelling on voluntary
basis

Under this scenario,
the origin or provenance of meat used as an ingredient would remain voluntary.
In addition, in the case of foods with meat as a primary ingredient (e.g. meat
preparations, MSM, meat products), there would be scope for the application of
Article 26(3) of the FIC Regulation. According to the latter provision, where
the country of origin or the place of provenance of a food is given and where
it is not the same as the origin of the primary ingredient (meat), then the
country of origin or place of provenance of the meat ingredient must also be
given or the country of origin or place of provenance of the meat ingredient
must be indicated as being different to that of the food, in accordance with
the Commission implementing act to be adopted by 13 December 2013.[86]

4.2         Scenario 2 – Introduce mandatory origin labelling based
on (a) EU/non-EU or b) EU/third country

Under this scenario,
mandatory origin labelling would be introduced at the level of EU/third
country. For the determination of origin, different modalities per product category
should be considered. These modalities are less detailed than those under
consideration for the mandatory origin labelling for unprocessed pig, poultry,
sheep and goat meat, since the origin information is set at EU/ third country
level. [87]

- 
Category I: Meat preparations and products made
from MSM:

For the purposes of
this category, the following sets of modalities are analysed:

Ø 
Origin as defined in the Customs Code, i.e. the
country where the ingredient was wholly obtained or the country of the last
substantial transformation of the meat ingredient:

In that
respect, the label of meat in meat
preparations/products made from MSM would read: "Origin: [EU or third
country of origin]".

Ø 
Origin information relating to the provenance
of the raw material, i.e. place of minimum period of rearing prior to slaughter
and place of slaughter:

The indication of
the place of slaughter does not appear to result in significant costs for the
meat processing companies.[88]
Accordingly, where the minimum period of rearing and the slaughter take place
either within the EU or outside the EU/in a third country, the label of meat
ingredients in meat preparations/products made from MSM would read:
"Origin: [EU or non-EU/third country of origin]".

In all other cases,
the label would read:

§ 
"Reared in: [EU or non-EU/third country of
origin]"; and,

§ 
"Slaughtered in: [EU or non-EU/third
country of origin]".

- 
Category II: Meat products

For the purposes of
this category, two sets of modalities are analysed.

Ø 
Origin as defined in the Customs Code, i.e. the
country where the ingredient was wholly obtained or the country of the last
substantial transformation of the meat ingredient:

This modality, where
the country of the last substantial transformation applies, places emphasis on
the place of processing, which may be more appropriate for meat products. The
label of meat ingredients for meat products would read: "Origin: [EU or
non-EU/third country of or origin]".

Ø 
Origin information relating to the provenance
of the raw material, i.e. place of minimum period of rearing prior to slaughter
and place of slaughter:

This modality
places more emphasis on the provenance of the raw material for the
manufacturing of meat products. Where the minimum period of rearing and the
slaughter take place either within the EU or outside the EU/in a third country,
the label of meat ingredients in meat products would read: "Origin: [EU or
non-EU/third country of origin]".

In all other
cases, the label would read:

§ 
"Reared in: [EU or non-EU/third country of
origin]"; and,

§ 
"Slaughtered in: [EU or non-EU/third
country of origin]".

- 
Category III:  Multi-ingredient foods with
meat used as an ingredient

For the purposes of
this category, the following sets of modalities are analysed:

Ø 
Origin as defined in the Customs Code i.e. the
country where the ingredient was wholly obtained or the country of the last
substantial transformation of the meat ingredient:

This modality, where
the country of the last substantial transformation applies, could be more
appropriate for meat products used as an ingredient in multi-ingredient foods,
as such products involve certain degree of processing. The label of meat
ingredients in multi-ingredients foods would read: "Origin: [EU or third
country of or origin]".

Ø 
Origin information relating to the provenance
of the raw material, i.e. place of minimum period of rearing prior to slaughter
and place of slaughter:

This modality
would place more emphasis on the provenance of the raw material. Where the
minimum period of rearing and the slaughter take place either within the EU or
in a third country, the label of meat ingredients in multi-ingredients foods
would read: "Origin: [EU or non-EU/third country of origin]".

In all other cases,
the label would read:

§ 
"Reared in: [EU or non-EU/third country of
origin]"; and,

§ 
"Slaughtered in: [EU or non-EU/third
country of origin]".

4.3         Scenario 3 – Introduce mandatory origin labelling
indicating the Member State or third country

Under this scenario,
mandatory origin labelling would be introduced at the level of a Member State
or third country, which provides similar level of detail as the one under
consideration for the mandatory origin labelling for unprocessed pig, poultry,
sheep and goat meat.

- 
Category I: Meat preparations and products
made from MSM:

For the purposes of
this category, the following sets of modalities are analysed:

Ø 
Origin as defined in the Customs Code, i.e. the
country where the ingredient was wholly obtained or the country of the last
substantial transformation of the meat ingredient:

The label of
meat ingredients in meat preparations/products made from MSM would read:
"Origin: [Member State or third country of origin]".

Ø 
Origin information relating to the provenance
of the raw material, i.e. place of minimum period of rearing prior to slaughter
and place of slaughter:

Where the minimum period of rearing and the
slaughter take place within the same country, the label of meat ingredients in
meat preparations/products made from MSM would read: "Origin: [Member
State or third country of origin]".

In all other cases, the label would read:

§ 
"Reared in: [Member State or third country
of rearing]" and,

§ 
"Slaughtered in: [Member State or third country of slaughter]".

These modalities could
apply for any single piece of meat pre-packed separately. If several cuts of
the same or different types of meat are packed in the same package or in the
case of minced meat/trimmings, the label would:

§ 
Either list the different Member States or third countries of rearing and slaughter; or,

§ 
The different Member States or third countries
of origin, where the rearing and slaughter took place within the same Member State or third country. In the case of minced meat and trimmings, the labelling of
several EU Member States could be replaced by "Origin: [EU]".

- 
Category II: Meat products

For the purposes of
this category, two sets of modalities are analysed.

Ø 
Origin as defined in the Customs Code, i.e. the
country where the ingredient was wholly obtained or the country of the last
substantial transformation of the meat ingredient:

This modality, where
the country of the last substantial transformation applies, places emphasis on
the place of processing, which may be more appropriate for meat products. The
label of meat ingredients for meat products would read: "Origin: [Member State or third country of origin]".

Ø 
Origin information relating to the provenance
of the raw material, i.e. place of minimum period of rearing prior to slaughter
and place of slaughter:

This modality
places more emphasis on the provenance of the raw material for the
manufacturing of meat products. The relevant modalities for indicating the
origin are the same as those for Category I, as elaborated in the previous
paragraph.

- 
Category III:  Multi-ingredient foods with
meat used as an ingredient

For the purposes of
this category, the following sets of modalities are analysed:

Ø 
Origin as defined in the Customs Code, i.e. the
country where the ingredient was wholly obtained or the country of the last
substantial transformation of the meat ingredient:

This modality, where
the country of the last substantial transformation applies, could be more
appropriate for meat products used as an ingredient in multi-ingredient foods,
as such products involve certain degree of processing. The label of meat
products in multi-ingredients foods would read: "Origin: [Member State or third country of origin]".

Ø 
Origin information relating to the provenance
of the raw material, i.e. place of minimum period of rearing prior to slaughter
and place of slaughter:

This modality
places more emphasis on the provenance of the raw material concerning meat
ingredients in multi-ingredients foods. The relevant modalities for indicating
the origin are the same as those for Category I, as elaborated in the previous
paragraph.

4.4         Other scenarios that have
not been examined in detail

The following scenarios
are not considered feasible and therefore have not been examined in detail.

4.4.1      Mandatory
labelling indicating a higher/lower level of detail than a country/lower
administration

Under this scenario,
mandatory origin labelling would be introduced at the level of place of
provenance. However, this scenario is not considered appropriate for the
following reasons:

Mandatory labelling of
place of provenance at a level lower than a country (e.g. Sicily) provides the
following difficulties:

- 
the lack of harmonised legal definition of this
geographical level across the Union;

- 
the high implementation costs involved requiring
elaborated meat traceability systems at a low geographical level; and,

- 
 the risk for consumers to be misled due to
confusion with quality labels established at Union level, i.e. protected
designations of origin ('PDOs'), protected geographical indications ('PGI's)
and traditional specialities guaranteed ('TSGs').

Similarly, mandatory labelling of place of
provenance embracing several countries or regions in one single area (e.g.
Scandinavia, the Alps) would be problematic due to the lack of commonly agreed
definitions of such regions at Union level.

However, the modalities foreseen under the
second and the third scenario address certain aspects of place of provenance,
where the customs code definition of 'country of origin' is not followed.

4.4.2      Mandatory origin labelling based on origin split in three
stages – "born, raised and slaughtered" – following the model already
applicable for unprocessed beef

This scenario, although in line with the
beef model, would be more detailed than that currently under consideration for
the mandatory origin labelling for unprocessed pig, poultry, sheep and goat
meat.[89]Thus, to provide for more detailed origin rules for meat (including
but not limited to pig, poultry, sheep and goat meat) when used as an
ingredient in goods than for unprocessed meat of pig, poultry, sheep and goat
would be inconsistent and not pragmatic.

4.4.3      Mandatory
origin labelling based only on the place of birth, or place of birth and
slaughter or only place of slaughter

This scenario would not
be sufficiently informative for consumers, as most consumers give more emphasis
on the placed of rearing of the animal rather than on the place of birth and/or
slaughter of the animal concerned.[90]

5            Feasibility and Analysis of costs and benefits of the different scenarios
concerning the provision of origin labelling for meat used as an ingredient

The following
paragraphs set out the evidence base and the assessment on feasibility as well
as an analysis of costs and benefits in terms of impacts of origin labelling
for meat used as an ingredient on the basis of the scenarios under consideration.

5.1         Impact concerning consumer behaviour

Origin labelling provides consumers with
additional information to make informed choices about the food they wish to
purchase and consume. Overall, origin labelling is associated with a range of positive
attributes by many consumers, including quality and food safety.[91] It is difficult to estimate the impact of origin labelling to
consumers in terms of a cost-benefit analysis.[92]

The present analysis mostly relies on
available information as to whether origin is a priority for the consumer and
on the consumer WTP estimates. With respect to the former, despite the overall
strong consumer interest, origin labelling consistently
ranks behind price and quality/sensory aspects in terms of the most important
factors affecting consumer choice.[93] With respect to the latter, a weak consumer WTP has been
established.[94]

The first scenario does
not guarantee that consumers are systematically provided with origin
information on meat used as an ingredient in foods. This would be particularly
the case for foods where the origin of the final food is not given as well as
for foods where the origin of the final food is given but the meat is not the
primary ingredient e.g. pizza with a meat ingredient.  When, however, origin information
would be provided voluntarily on foods with meat as the primary ingredient (e.g.
meat preparations and meat products), then the consumers would be able to
compare different products, as the criteria for the provision of voluntary
origin information would be harmonised. Although this scenario would not
provide a fully satisfactory solution to consumer demand to know more about the
origin of meat ingredients, it would better correspond to the low WTP for
additional origin information. Moreover, consumers, who do not attach any
specific importance to origin, would not have to bear the additional
origin-related costs when they purchase such products.

The second and third
scenarios provide consumers with origin information on meat used as an
ingredient on a systematic basis. The second scenario is not as informative as
the third, as the information it provides (EU or third country) may be
considered as too generic and not worthy of the additional costs passed onto
the final consumers, even if they are less than the third scenario.

The third scenario may
provide meaningful information to consumers. However, due to the level of
detail required, the additional costs are expected to be higher than the second
scenario, which are likely to eventually be passed onto to the final consumers.[95] Should mandatory origin labelling result in a price increase for
the consumers and given the fact that already consumers consider that the
existing prices for meat related products are high and prohibit them from
consuming more of such products, it may result in a decrease in the consumption
of meat-related products under the third scenario.

5.2         Technical
feasibility

For an individual
FBO, the feasibility of origin labelling depends largely on the additional
costs occurred. The three most impacted cost items across all sectors are:

- 
Costs of adaptation of storage and production
facilities, often involving amortization of substantial investments (especially
in sectors with continuous production processes, and/or where scale economies
play an important role);

- 
Costs of adaptation of sourcing practices,
especially where use of multiple ingredients or raw materials, use of multiple
sources in different Member States and/or third countries, frequent changes in the
origin of ingredients or raw materials, and frequent mixing of different
origins before arrival of ingredients or raw materials at the plant occur;

- 
Costs of implementation of cumulative
traceability and for systematic update of labels/packaging to changes in origin
of ingredients.

Regarding the frequency with which these
costs occur, there is a significant difference between recurring and one-off
costs. This mainly depends on the FBO sourcing practices:

- 
The
higher the degree of processing (e.g. multi-ingredient foods with meat
ingredients) and the larger the FBO in terms of quantitative output, the more
likely is that multiple sources for raw materials (meat) is being used. This in
turn means that any such costs as separate storage, change to batch production
and additional traceability requirements and labelling changes, while generate
recurring costs;

- 
The
lower the degree of processing (e.g. single meat pieces such as dried
ham) and the smaller the FBO, the higher the likelihood that single sources,
often on long term commercial relations and in close proximity are being used.
In this case, costs generated by the decision to label the origin of the
products occur on a one-off basis;

Taking into account the above, the main
findings on the feasibility of the different scenarios can be summarised as
follows:

According to FBOs, the first scenario
(voluntary origin) would be more appropriate especially whenever meat of EU and
non-EU origin is mixed in the production process for the purposes of products
that require certain degree of processing, e.g. meat products.

The second (EU/non-EU or third country) and
third (MS/third country) scenarios, which involve mandatory origin labelling,
would pose serious operational challenges and would require radical
adaptations. Indicatively:

- 
Incompatibility with the sourcing decisions
for raw materials: As elaborated in Section 2.5,
the currently applied sourcing practices are often quite complex and involve
multiple EU and also non-EU origins, especially for beef and poultry-related
products. In many cases, origins change frequently over time. In addition, the
mixing of different origins can occur at various stages in the food chain and
already before the arrival of meat at plants where it is used as an ingredient
in foods. As such, the second and third scenario would have a considerable
impact on the sourcing decisions.

- 
Certain modalities would require operators to
switch to smaller production batches and/or to interrupt continuous phases of
the production process to achieve segregation by origin within the plants: This could be particularly the case for minced meat used as an
ingredient in foods and filling wrappings with meat content when producing
sausages and similar products, especially in large-scale automated plants.

- 
Systematic adaptation of labelling/packaging
to changes in the origin(s) of meat used as an ingredient: The frequent changes in the mix of suppliers would require frequent
adaptations of packaging and labels and additional investment in printing
equipment.

However, the second scenario was considered
more feasible than the third. In that respect, certain FBOs considered that the
third scenario would not be feasible for pork and chicken used as ingredients.

Box 4: SME survey

The SME survey conducted in early 2013 through the Enterprise
European Network aimed at assessing the potential impacts on SMEs of
introducing mandatory origin labelling for meat used as an ingredient. The main
findings of that survey are summarised below:

v Almost 52% of the respondents consider that a voluntary
labeling scheme (first scenario) would be more cost-efficient than a mandatory
scheme (second and third scenario);

Table 5: Cost-efficiency of voluntary versus mandatory labelling scheme

· 
The majority of enterprises
in the sample agreed that the introduction of mandatory origin labelling
(second and third scenarios) would increase the administrative burden imposed
on the company (68%);

· 
Should mandatory origin
labelling be introduced (second and third scenarios), the required changes in
operations that would impose the biggest costs on the companies are technical
adaptations to the label (according to 41% of the respondents) and separation
of storage facilities and production lines (24%);

· 
The majority of
enterprises sampled estimate that the average time needed to adapt their
business in terms of workforce, technology and enforcement requirements would
be under 6 months. A longer time is estimated for the adaptation of marketing
and retail practices (6 to 12 months).

· 
According to 83% of the
respondents, a general exemption from compliance for SMEs would be at least
marginally effective in reducing the possible negative impacts of the mandatory
labelling obligations. However, 81% of the respondents would favour a specific
exemption as a more effective tool.

5.3         Economic
impacts

This Section aims at identifying the most
significant economic impacts connected with origin labelling and subsequently
assess the three scenarios under consideration. However, the impact of the
different modalities has not been explored in detail.

5.3.1      Operating
costs of FBOs

The additional operational costs for
FBOs derive from specific additional costs for the implementation of origin
labelling as well as from the following specific adaptations:

a. 
Adaptation
of sourcing practices and potential changes in the mix of suppliers of live
animals, fresh meat, or meat / meat products used as ingredient;

b. 
Adaptation
of production and/or marketing process of live animals, fresh meat, or meat /
meat products used as ingredient;

c. 
Adaptation
of production process of the final product containing meat as an ingredient;

d. 
Adaptation
of packaging and labels/labelling process;

e. 
Adaptation
of marketing practices of the final product;

f. 
Adaptation/implementation
of traceability systems;

g. 
Additional
internal controls required to ensure compliance with COOL rules;

The
extent of additional costs can vary remarkably, and will depend on the specific
operational situation of FBOs including sourcing practices, the degree of
vertical integration, the existing traceability systems and practices in places
(also linked to the animal species concerned). Also, the position of FBOs in
the food chain in terms of the competitive structure and the resulting
bargaining power in the meat supply chain can play a significant role. Thus, Member State level estimates made by national organisations can differ significantly from
EU average estimates.

Industry
stakeholders have identified the four most impacted cost items as follows:

1. 
adaptation
of sourcing practices and possible changes in the mix of suppliers;

2. 
adaptation
of production process of the final product;

3. 
adaptation
of packaging and labels/labeling process;

4. 
implementation/adaptation
of traceability (taking into account of existing systems).

Under the first
scenario, the operating costs would be kept to the minimum, as origin
information for meat ingredients would be provided on a voluntary basis. The
businesses that would be affected are those that provide the origin of the
final food and that origin is different from the origin of meat used as a
primary ingredient in the food concerned. Those businesses are likely to incur
certain operating costs. Their extent would depend on the level of precision of
the origin indication of the primary ingredient as opposed to the origin of the
final product.

FBOs in general are
likely to incur additional operating costs under the second and the third
scenario (mandatory origin labelling), pursuant to estimates of FBOs across a
wide range of sectors, including processing, distribution and retail stages of
the supply chain. A number of stakeholders provided more or less detailed
quantitative estimates of additional cost while other stakeholders could only
provide qualitative considerations on the matter. The evidence base has been quite
heterogeneous and did not allow the systematic analysis of the information or
extrapolation of the quantitative estimates provided as they refer to specific
situations and assumptions.

The main additional
costs involved under the second and third scenario providing for mandatory
origin labelling for meat used as an ingredient can be summarised as follows: [96]

- 
The additional costs stemming from the second
scenario (EU/non EU or third country) are generally lower, or much lower, than
those of the third scenario (MS/third country). With all due caveats relating
to the limited comparability of data, the FCEC study concluded that additional
costs (EU-average) for the second scenario, expressed as a percentage increase
of total production costs range from negligible up to +25%, whereas additional
costs for the third scenario range from +15-20% up to +50%.

- 
The extent of additional costs could very, as
they would depend on the specific operational situation prevailing for each FBO
at the time of the potential introduction of mandatory origin labelling. The
main factors that are also likely to influence the extent of additional costs
are the animal species concerned and the sourcing practices/additional
traceability systems. Indeed, the more extensive and diversified the range of
suppliers and the higher the frequency in changing suppliers, the more complex
the additional traceability systems and the higher the additional costs
involved would be.

5.3.2      Traceability
costs of FBOs

For each individual operator, the extent of
the additional costs for traceability (as part of the overall operational
costs) will depend on a range of factors:

- 
The
animal species concerned: The more advanced the systems currently used per
animal species (which is the case generally in the beef and which could be the
case in the future for unprocessed pig, poultry, sheep and goat meat), the less
the adaptation cost to implement the additional traceability requirements.

- 
Sourcing
practices: the more extensive and diversified the range of suppliers and the
higher the frequency in change of suppliers, the more complex the additional
traceability systems and the higher the additional costs involved would need to
be.

- 
The
degree of vertical integration: the higher the degree of vertical integration
and potential reliance on internal sourcing of the raw material quantities and
qualities required for the final product, the lower will be the additional
traceability cost;

- 
The
current status of traceability systems and practices: the more advanced the
systems currently used, the less the adaptation cost to implement the required
full traceability. This is also linked to the animal species, as currently,
traceability is most advanced in the beef and sheep/goat meat sector;

- 
The
competitive structure and resulting bargaining power in the meat supply chain:
the first actor in the supply chain where additional costs for origin labelling
occur would be slaughterhouse, while the processing plant can rely on demanding
detailed information on every delivery from their suppliers. The ability of the
slaughterhouse to transfer this cost to their customers would depend on their
bargaining power vis-à-vis those customers. Similar situations will
prevail further downstream the supply chain between processors and actors in
the distribution sector.

The case studies conducted in the context
of the LEI study demonstrate that current traceability practices at
slaughterhouse and meat cutting plant level differ between species and also
between operators. In addition, on the basis of the experience gained following
the introduction of mandatory origin labelling for beef, FBOs consider more
cost effective to adapt the supply structure (sourcing, batch sizes, reducing
intermediaries) than upgrading the internal traceability and administration
systems.[97]

The most common operational implications of
achieving cumulative traceability along the supply chain are the following:

a) Adaptation
of sourcing patterns and practices for live animals, fresh meat, or meat / meat
products used as ingredient.

b) Separation
of storage facilities and production lines, to allow segregation by origin.

c) Switch
to batch production and/or use of smaller batches (with the associated decrease
in efficiency).

d) Adaptation
of internal monitoring.

e) Systematic
update of labels/packaging, to follow changes in the origin of live animals,
fresh meat, or meat / meat products used as ingredient.

Under the first
scenario, the traceability costs would be kept to the minimum, as origin
information for meat ingredients would be provided on a voluntary basis. The
businesses that would be affected are those that provide the origin of the
final food and that origin is different from the origin of meat used as a
primary ingredient in the food concerned. The extent of the additional
traceability costs would depend on the level of precision of the origin
indication of the primary ingredient as opposed to the origin of the final
product.

Under the second and third scenarios, an indicative
quantification of the additional traceability costs for all three product
categories have been estimated in the range of +3% to +10% of the total
production costs of these products. [98]

Table 6: Estimated additional costs for FBOs due to implementation of traceability for the relevant policy options and related modalities Sector (a) || Additional costs (b)

Meat preparations / meat products (CLITRAVI) || DE case study – Scenario 3 (MS / TC level): significant additional costs (uncooked or cooked sausages – pig meat) UK case study Scenario 2 (EU/non-EU or EU/TC) · Sausages (pig meat): +3-5% · Burgers (beef): +3-5% Scenario 3 (MS / TC level) · Sausages (pig meat): +5-10% · Burgers (beef): +5-10%

Prepared meals (ECFF + CULINARIA) || ECFF: Scenario 2 (EU/non-EU or EU/TC): + 3-5% (on average, across the range of products) CULINARIA: significant additional costs

a) Organisations contributing to the assessment from processing, distribution and retail sectors (including inputs from MS-level member organisations/companies). b) Only the organisations that provided specific evidence on this are included. The following organisations did not provide any specific evidence on this: AVEC (poultry meat-based products); IBC (butchers); UNAFPA (pasta products). FDE referred to the sector-specific organisations for this issue. UECBV supports the replies provided by CLITRAVI on this issue. c) The costs indicated are specific to the production cost of the final products, and are largely in addition to the costs likely to be incurred at the earlier stages of the supply chain up to slaughterhouse/meat cutting plant (where the latter was not the place of the last processing of the final product). Source: FCEC based on industry consultation

The trade of trimmings
and fat will be impacted under the second and third scenario.[99]  Given the difficulty
to implement an appropriate traceability system for these types of products, FBOs
consider that they are likely to use such products less and less, in the
manufacturing process. This would result in additional losses in terms of
foregone revenue from these products, which is generally estimated at 10% of
the turnover of slaughterhouses/meat cutting plants. However, the impact would
largely depend on the applicable modalities for determining origin labelling.
There could also be additional costs for the safe disposal of such products as
well as the environmental impact of food water. These costs could be mitigated
to some extent, should these products be exported or destined to other non-food
uses, where appropriate.

FBOs have shown very limited
(if any) confidence in the potential contribution of innovation (e.g. use
of Radio Frequency Identification Devices ('RFID') technology for what concerns
traceability costs) in limiting additional costs in the mid-term.

Box 6:
Innovation and new technologies

Innovation
and new
technologies, in particular RFID tools and isotope analysis,
could also help mitigate costs, but not in the short to medium term, as the
technology uptake at the moment in the processed meat, and more generally food
industry, is virtually non-existent. FBOs have shown very limited (if
any) confidence in the potential contribution of innovation (and especially
RFID technology for what concerns traceability costs) in limiting additional
costs in the mid-term.

The industry indicated that RFID tools
have been tested by a number of meat processing companies in a range of
different meat products and have proven not cost-effective. MS CAs by and large
(with the exception of only one MS) remain unconvinced that isotope analysis
can provide a cost-effective solution for wider implementation of origin
verification controls, as both the costs of this testing are high and the
available test methods are not widely tested yet.

Key providers of new technologies (Isotope
testing) suggest that this could be a promising technology for confirmatory
origin labelling analysis. However, there are significant constraints at
present for a more widespread uptake of this technology. The key constraints
identified are the significant costs involved and, as it stands, this type of
technology is applicable only to products more or less wholly obtained from an
animal (i.e. not to cuts, blends, trimmings, mixes of species etc.),
in relation to a reference library of isotopes from specific geographical
regions (which do not correspond to administrative country or region
boundaries), and with the aim to identify the place of farming only. Isotope
testing was therefore not considered likely to provide the answer in short to
medium term, both due to its high cost and because it remains an imperfect
solution (i.e. it does not provide clear answers; is it reliable? is it
practical/simple to use?).[100]

5.3.3      Competitiveness
and trade

The potential impacts of origin labelling
on the competitiveness of FBOs in the internal market depends on the following
key factors:

- 
Costs
of production and/or other dimensions of competitiveness (product
differentiation, product innovation, safeguard of sensitive business
information, etc.);

- 
Intra-EU
trade flows of the relevant products, in particular: extent of possible
geographical segmentation of the EU market; possible changes in the
geographical structure and/or in the volume of intra-EU trade flows.

Under the first
scenario, if there would be a demand from upstream players with considerable
market power for origin of meat ingredients on a voluntary basis, a competitive
advantage would be accrued to more vertical integrated companies supplying
upstream players, including slaughterhouses and large-scale cutting plants with
tracing and labelling facilities, as opposed to small operators. The voluntary
character of origin information for meat as an ingredient would not result in a
re-nationalisation of consumption, and as such EU domestic trade and
international trade would not be affected. Similarly, the Union exports are not
likely to increase.

The second and
especially the third scenario are likely to affect the Union's domestic trade,
as follows:

- 
Adaptation of the sourcing patterns, with the
aim to focus on a more limited number of origins (countries/regions) for their
sourcing of meat ingredients. These changes in the supply chain would result in
a segmentation of trade of meat ingredients. On the basis of the experience
gained following the introduction of mandatory origin labelling for beef, FBOs
consider more cost effective to adapt the supply structure (sourcing, batch
sizes, reducing intermediaries) than upgrading the internal traceability and
administration systems.[101]
These "re-structuring" changes are more likely to take place under
the third scenario than the second one. In particular, it is likely that
different retailers in self-sufficient Member States would offer consumers
meat-related products predominantly or wholly of domestic origin, not least for
reducing the risk of errors in origin labelling and the possible consequences
of this in terms of image and sales. Both scenarios and especially the third
one could also lead to a decrease in the number of intermediaries involved in
the supply chain of foods with meat used as an ingredient as well as in the
number of suppliers to each FBO.

- 
 FBOs are likely to face higher prices as their
overall supply base within the retained countries/regions would be would be
limited. In this case, the most significant impacts are expected for FBOs in
MSs that are not self-sufficient in raw material and for FBOs that rely on
specific types of mat ingredients for which a more extended supply base is
necessary to ensure the required volume and specifications.

- 
The adaptation in the sourcing patterns could
also lead to problems finding outlets for meat ingredients of mixed origin or
for trimmings and fat.

- 
Under the second and third scenarios, FBOs using
meat as an ingredient could be adversely affected as opposed to FBOs that do
not use meat as an ingredient (e.g. in the prepared meals sector).

- 
Potential changes in intra-EU trade flows for
live animals, unprocessed meat and meat ingredients, as a result of the
adaptation of sourcing practices of FBOs are likely. A reduction in traded
volumes is expected with respect to MSs that are highly specialised in
supplying meat ingredients (e.g. France, Germany, Denmark, Netherlands,
Belgium, Spain etc.) occurring the most significant impacts.[102]

- 
A risk for market segmentation of food products
may emerge especially in the case of scenario 3, given the consumer preference
for national meat.[103]

The main potential
impacts on international trade identified under the second and the third
scenarios, pursuant to the FCEC study[104]
can be summarised as follows:

- 
A shift of EU FBOs towards EU suppliers is
expected to take place so as to avoid the complexities deriving from multiple
EU and third country origins.

- 
Additional costs for third country FBOs,
especially if origin indication is required at the level of country detail (i.e.
third scenario). The FBOs based in developing third countries may be especially
disadvantaged, as they might lack the resources and the know-how to implement
the adaptations required for compliance with EU mandatory origin labelling
requirements.

These impacts would
concern especially those third countries that currently export significant
quantities of unprocessed meat/meat ingredients to the EU: Thailand and Brazil for poultry, Brazil and Argentina for beef. However, the extent of the impact
will depend on the national provisions in place concerning origin labelling.
For example, in the case of Brazil, the competent national authorities and
stakeholders noted that traceability and origin labelling is currently provided
at country level on the basis of the place of farming and rearing (second
scenario). Imports of pig meat and sheep meat for processing are virtually
non-existent.

5.3.4      Administrative
burden on businesses

This administrative burden would consist of
compliance costs including costs for new staff for the verification of
production lines for compliance to origin labelling.

The first scenario involves certain
administrative burden only for the businesses that provide the origin of the
final food and that origin is different from the origin of meat when and where
is used as a primary ingredient.

On the basis of two examples provided at EU
level (pig meat sector: sausages and cooked ham), the total costs are
negligible under the second scenario.

However, these costs become more
substantial under the third scenario, pursuant to which an increase of up to
+8-12% of the total production costs would be expected. These costs include
additional new staff for the verification of production lines for compliance to
origin labelling as the current traceability systems remain manual based on
paperwork; however, these costs could in the long term be mitigated by more
complete and computerized traceability systems. Moreover, these are normal
control costs and do not include costs incurred in the context of controls in
extraordinary situations, e.g. in case of erroneous labelling and
product recalls.

5.3.5      Burden
on public authorities

National authorities are entrusted with the
enforcement of labelling requirements. The division of responsibilities amongst
the national CAs for inspecting traceability and origin labelling is often
complex and heterogeneous.[105]
Moreover, the controls on food labelling are part of the overall controls on
foods. Therefore, it is difficult to separate the costs that could result from
any new information obligations from the overall costs on foods. According to
the national CAs, the higher the level of precision of the origin indication,
the higher the control costs involved.[106]
Taking into account these constraints, the following impacts are likely to
occur:

Under the first
scenario, no additional control costs would be expected apart from the costs
entailed by the general application of Article 26(3) of the FIC Regulation.

The main findings of
the FCEC study for the second and third scenario can be summarised as follows:

- 
An increase in control costs (including
verification checks and administrative burden) is expected under the second and
the third scenarios. The anticipated additional control costs are expected to
be increased by 10-30% under the second and third scenario. However, the more
detailed the information to be controlled, the higher the cost. Therefore, the
second scenario would result in lower costs than the third scenario.[107]

- 
The increase in control costs would be more in
terms of the number of staff needed. Especially the third scenario, it is
likely to result in an increase of the staff/staff time needed. In that
respect, if the funding allocated to control authorities by the state budgets
is not increased – which seems likely in the current economic environment – the
expected increase in staff time needed may lead to a reduction in the frequency
of controls or a change in priorities. This could jeopardise the effectiveness
of controls under the third scenario.

- 
Compliance controls are currently based on
documentary checks. The more detailed the level of information to be provided
(third scenario), the higher the challenge for the CAs would be to verify the
information, especially in the case of multi-ingredient foods. Certain stakeholders
have raised certain concerns on the potential risk of fraudulent practices; the
more detailed the rules in place (third scenario), the higher the risks. This
could be particularly the case in the poultry and pig sector where there is
significant movement of live animals and meat between countries. These concerns
could be addressed by the establishment of an additional efficient and reliable
traceability system. In addition, new technologies, in particular RFID tools
and isotope analysis could also help to mitigate costs but only in the longer
term, when such tools will become more efficient and effective.

- 
Any increase in control costs is expected to be
reduced in the long term, taking into account the introduction of traceability
systems by the FBOs, of the required databases to monitor compliance at the
level of the control authorities and the progressive familiarity of the control
authorities with the new rules. Moreover, this increase in costs is likely to
be mitigated, should fees for the conduct of official controls be introduced.

5.3.6      Costs
for consumers and possible social impacts

The provision of origin information is
expected to result in increased costs. These costs are most likely to be
distributed between the consumer and the producer, but not evenly. Overall, it
is estimated that approximately 90% of the costs would be passed onto to the
consumer and only 10% to the producer, although these percentages may vary
depending on the sector and the country concerned as well as the prevailing
degree of vertical integration and market concentration.[108]

In terms of the net impact of consumer
welfare, the monetary cost of the consumer price increase has to be balanced
against the – non monetarised – benefits of the additional information to
determine whether consumers are better off with the second and third scenario
than the first scenario. This is an exercise that could not be conducted in the
scope of the present exercise.

Under the first
scenario, an overall price increase on foods with meat as an ingredient would
not be likely to occur. However, a certain price increase could occur where the
origin of the final food is given and the meat is the main ingredient, provided
that the origin of the meat is different from that of the origin of the final
food. In the latter case, the larger part of the price increase is likely to be
passed on to the consumer.

The second and third
scenarios are likely to result in higher price increases for the final consumer
than that estimated under the first scenario. However, the price increase that
is likely to be passed onto the consumer will be greater under the third
scenario than the second scenario. It is assumed that as prices increase under
the second and third scenario, consumers would be likely to buy fewer foods
with meat as an ingredient and consequently more such foods would need to be
exported. Market segmentation of meat consumption is also likely to take place.
As mentioned in previous sections, following the introduction of mandatory
origin labelling for beef, adaptation of structures (e.g. sourcing,
batch sizes, reduction of intermediaries) was proven more cost effective than
upgrading the internal traceability and administration systems. By drawing a
parallel with the second and third scenarios at issue, adaptations in the
sourcing patterns of meat ingredients as well as elimination of intermediaries
are likely to take place, which may also have an impact on employment.

5.3.7      Environmental
impacts

Under the first
scenario, the environmental impact of this scenario is likely to be minimal. Under
the second and third scenarios, there is a risk of increasing the size of
labels/packaging. Both are likely to increase waste ingredients, especially in
the case of trimmings/fat, as analysed in the previous paragraphs. The third
scenario could provide an incentive to consume products produced in proximity.

5.4         Overview
of the costs and benefits of the different scenarios under consideration

Table 7 below provides an overview of the
costs and benefits of the three scenarios under consideration.

Table 7: Overview of costs and benefits

Scenarios || Information to consumers || Technical feasibility || Economic impacts

First scenario – Maintaining voluntary origin of meat used as an ingredient || Costs || - Does not guarantee that consumers are systematically provided with origin information on meat used as an ingredient in foods; || - Minimal adaptations in terms of feasibility || - Operating costs would be kept to the minimum – these would be incurred only by those FBOs that fall within the scope of Article 26(3) of the FIC Regulation (voluntary origin labelling – harmonised rules on the origin of primary ingredient); - Limited administrative burden on businesses  - this is to be incurred only by those FBOs that fall within the scope of Article 26(3) of the FIC Regulation; - No additional control costs (including administrative burden on public authorities), apart from the burden entailed from the general application of Article 26(3) of the FIC Regulation; - Limited price increases on meat used as an ingredient; - Limited environmental impact;

Benefits || - It better corresponds to the low willingness of consumers to pay for additional origin information; - Consumers, who do not attach any specific importance to origin, would not have to bear the additional origin-related costs; || - More appropriate especially when meat of EU and non-EU origin is mixed for the production of processed products (e.g. meat products); || - It would not result in a market segmentation  and therefore intra-EU and international trade would not be affected;

Second scenario – Mandatory origin labelling at EU/non EU or third country level || Costs || - The origin information provided would not be quite informative, as it would be too general; - The additional origin costs are likely to be passed onto the consumers; - Taking into account the low willingness of consumers to pay for additional origin information and the current consumer perception that existing prices for meat are high, it may result in a decrease in the consumption of meat-related products. || - It could pose operational challenges/ adaptations Ø Especially where meat of EU and non EU origin is mixed; Ø Operators would need to switch to smaller production batches and adapt structures to achieve segregation by origin within the plants; Ø Labelling/packaging would need to be adapted frequently (but less frequently than the third scenario) depending on the sourcing; || - All FBOs would incur certain operating costs. These costs are estimated from negligible up to 25% of total production costs; - Additional traceability costs are estimated from +3% up to 10% of the total production costs; - Administrative burden on businesses is likely to be negligible; - The additional control costs (including administrative burden on public authorities) are estimated from +10 to +30%. Compared to the second scenario, these costs are expected to be higher; - Higher consumer prices for final products with meat used as an ingredient. However, these prices would be lower than under the third scenario. This price increase may result in less meat consumption; - Certain environmental impact is likely to take place given the increase of waste ingredients, especially in the case of trimmings/fat; - It would result in a market  segmentation of the meat consumption, although to a lesser degree than under the third scenario; - The adaptation of sourcing patterns (limiting the overall supply base within the EU or outside the EU) could result in higher prices for the supply of meat as raw material; - It would result to a reduction of intermediaries which in combination with the adaptation in sourcing patterns may have an impact on employment; - International trade likely to be impacted given the risks for adaptation in sourcing patterns and additional costs that are likely to be incurred by 3rd country exporters to the EU. Exports of foods with meat used as an ingredient are likely to increase.

Benefits || - Guarantees that consumers are systematically provided with origin information on meat used as an ingredient in foods; || - It could allow certain flexibility in sourcing at the level of EU, especially in the case of epizootic disease outbreaks; ||

Third scenario – Mandatory origin labelling at MS/third country level || Costs || - The additional origin costs, which are expected to be the highest amongst the 3 scenarios, are likely to be passed onto the consumers. - The low willingness of consumers to pay for additional origin information and given the current consumer perception that existing prices for meat are high, may result in a decrease in the consumption of meat-related products. || - It would pose operational challenges/radical adaptations (at higher degree than under the second scenario): Ø Especially where meat from different Member States and/or third countries is mixed as well as for pork and chicken used as meat ingredients; Ø Constraints access to a larger sourcing area in case of epizootic disease outbreaks; Ø Operators would need to switch to smaller production batches and adapt structures to achieve segregation by origin within the plants; Ø Labelling/packaging would need to be adapted frequently depending on the sourcing; || - All FBOs would incur certain operating costs. These costs are estimated from +25-20% up to 50% of total production costs; - Additional traceability costs are estimated from +3% up to 10% of the total production costs; - Administrative burden on business is estimated from +8 up to 12% of the total production costs; - The additional control costs (including administrative burden on public authorities) are estimated from +10 to +30%. - Higher consumer prices for final products with meat used as an ingredient under all three scenarios under consideration. This price increase may result in less meat consumption; - Certain environmental impact is likely to take place given the increase of waste ingredients, especially in the case of trimmings/fat; - It would result in a market segmentation of meat consumption; - The adaptation of sourcing patterns (limiting the overall supply base within a specific MS or third country) could result in higher prices for the supply of meat as raw material; - It would result to a reduction of intermediaries which in combination with the adaptation in sourcing patterns may have an impact on employment; - International trade likely to be impacted given the risks for adaptation in sourcing patterns and additional costs that are likely to be incurred by 3rd country exporters to the EU. Exports of foods with meat used as an ingredient are likely to increase;

Benefits || - Guarantees that consumers are systematically provided with origin information on meat used as an ingredient in foods; - Informative value for consumers, as it provides meaningful information to consumers; || ||

Table 8 below provides
an overview of the advantages and disadvantages of the different modalities for
the definition of origin under the second and third scenarios:

Table 8: Advantages and disadvantages of different modalities under 2nd and 3rd scenarios

Modalities under 2nd and 3rd scenarios (mandatory origin labelling) || Advantages || Disadvantages

Category I: Meat preparations/products from MSM || Country where ingredient was wholly obtained or country of last substantial (Customs Code) || - Provides meaningful information to the consumer; - Trimmings and fat could be used as ingredients, where origin is determined as the country of the last substantial transformation. || - Additional  traceability systems would be required; - If multiple origins are involved in upstream stages of the supply chain, implementation could be challenging; - Trimmings and fat are not likely to be used as ingredients in cases, where origin is determined as the place of minimum rearing prior to slaughter, given the challenges in storage/traceability.

Place of minimum rearing prior to slaughter + place of slaughter || - Places more emphasis on the provenance of the raw material where the ingredient was not wholly obtained in a country. || - Additional  traceability systems would be required; - If multiple origins are involved in upstream stages of the supply chain, implementation could be challenging; - Trimmings and fat are not likely to be used as ingredients, given the challenges in storage/traceability.

Category II: Meat products || Country where ingredient was wholly obtained or country of last substantial transformation (Customs Code) || - Places more emphasis on the place of processing where the country of last substantial transformation applies; - Technically feasible for FBOs; - More practical, if multiple origins are involved in upstream stages of the supply chain; - Trimmings and fat could be used as ingredients. || - Provides no information on the provenance of the raw material where the country of last substantial transformation applies.

Place of minimum rearing prior to slaughter + place of slaughter || - Places more emphasis on the provenance of the raw material where the ingredient was not wholly obtained in a country. || - Provides no information on the place of processing; - Additional  traceability systems would be required; - Particularly challenging where multiple origins would be involved; - Trimmings and fat are not likely to be used as ingredients, given the challenges in storage/traceability.

Category III: Multi-ingredient foods with meat used as an ingredient || Country where ingredient was wholly obtained or country of last substantial transformation (Customs Code) || - Places more emphasis on the place of processing where the country of last substantial transformation applies; - Trimmings and fat could be used as ingredients. || - Provides no information on the provenance of the raw material where the country of last substantial transformation applies; - Additional traceability systems would be required; - Particularly challenging where multiple origins would be involved, which is often the case in multi-ingredients foods.

|| Place of minimum rearing prior to slaughter + place of slaughter || - Places more emphasis on the provenance of the raw material where the ingredient was not wholly obtained in a country. || - Provides no information on the place of processing of the meat ingredients; - Additional traceability systems would be required; - Particularly challenging where multiple origins would be involved, which is often the case in multi-ingredients foods; - Trimmings and fat are not likely to be used as ingredients, given the challenges in storage/traceability.

ANNEX
I: Glossary

Technical terms and acronyms

ASSICA:                    Associazione
Industriali delle Carni e dei Salumi

AU:                                         Austria

AVEC:                        Association of Poultry Processors and
Poultry Trade in the EU countries

BMPA:                        British Meat Processor Association

BAU:                          Business-As-Usual (costs)

BE:                              Belgium

BEUC:                                    The European Consumer
Organisation

BG                              Bulgaria

BVDF:                                    Bundesverband der Deutschen
Fleischwarenindustrie

CAs:                            Competent Authorities

CLITRAVI:               Liaison Centre for the Meat Processing
Industry in the European Union

COM:                          European Commission

COPA-COGECA:      Committee of Professional Agricultural
Organisations and General Confederation of Agricultural Co-operatives in the
European Union

CULINARIA:            Federation of Associations and Enterprises of
Industrial Culinary Products Producers within Europe

CZ:                              Czech Republic

CWE                           Carcass weight equivalent

DE:                              Germany

DEFRA:                      Department for Environment, Food and
Rural Affairs

DK:                                         Denmark

DG AGRI:                  Directorate General for Agriculture and
Rural Development

DG SANCO:              Directorate General for Health and Consumers

EE                               Estonia

EEN:                           Enterprise Europe Network

EL:                              Greece

ES:                              Spain

EU:                              European Union

EUROCOMMERCE: Retail, Wholesale and International Trade
Representation to the EU

FBO/s:                         Food Business Operator/s

FCEC:                         Food Chain Evaluation Consortium

FDE:                           Food Drink Europe Association

FIC:                             Food Information to Consumers
(Regulation (EEC)1169/2011)

FL                                           Finland

FR:                              France

HS                               Harmonised System

IE                                Ireland

IOs:                                         Information Obligations

IT:                               Italy

LT                                           Lithuania

LU                                           Luxembourg

LV                                           Latvia

MS(s):                                     Member State(s)

MSM                                       Mechanically separated
meat

MT                                          Malta

NL:                                          Netherlands

PL:                                          Poland

PT:                                           Portugal

RO:                                                     Romania

SE:                                          Sweden

SCM:                                       Standard Cost Model

SK                                           Slovakia

SME(s):                                   Small and medium
enterprise(s)

SV                                           Slovenia

TCs:                                         Third Countries

UECBV:                                 European Livestock and Meat
Trading Union

UK:                                                     United Kingdom

WTP                                        Willingness to Pay

WTO:                                      World Trade Organisation

ANNEX
II: Applicable definitions in the FIC Regulation concerning origin

The FIC Regulation lays
down the following definitions concerning origin, which are pertinent for the
present Staff Working Document:

v 
'Prepacked
food' means any single item for presentation as such to the final consumer and
to mass caterers, consisting of a food and the packaging into which it was put
before being offered for sale, whether such packaging encloses the food
completely or only partially, but in any event in such a way that the contents
cannot be altered without opening or changing the packaging; ‘prepacked food’
does not cover foods packed on the sales premises at the consumer’s request or
prepacked for direct sale.[109]

v 
'Primary ingredient' means an ingredient or
ingredients of a food that represent more than 50% of that food or which are
usually associated with the name of the food by the consumer and for which in
most cases a quantitative indication is required.[110]

v 
'Country of origin'[111] refers to the origin
of a food as determined in accordance with Articles 23 and 26 of Council
Regulation (EEC) No 2913/92 of 12 October 1992 establishing the Community Customs
Code.[112] Article 23 of Regulation (EEC) No 2913/92 provides that goods
originating in a country shall be those wholly obtained or produced in that
country. In that respect, the expression ‘goods wholly
obtained in a country’ means, amongst others, products
derived from live animals raised therein, products of hunting or fishing carried
on therein as well as goods which are produced therein exclusively from all the
above-mentioned goods or from their derivatives, at any stage of production.
Article 24 clarifies that 'goods whose production involved more than one
country' shall be "deemed to originate in the country where they underwent
their last, substantial, economically justified processing or working in an
undertaking equipped for that purpose and resulting in the manufacture of a new
product or representing an important stage of manufacture".

v 
'Place
of provenance' means any place where a food is indicated to come from, and that
is not the ‘country of origin’ as determined in accordance with Articles 23 to
26 of Regulation (EEC) No 2913/92; the name, business name or address of the
food business operator on the label shall not constitute an indication of the
country of origin or place of provenance of food within the meaning of this
Regulation.[113]

v 
'Meat' means edible parts of the following
animals, including blood:[114]

Ø 
‘Domestic ungulates’ means domestic bovine
(including Bubalus and Bison species), porcine, ovine and caprine animals, and
domestic solipeds.

Ø 
‘Poultry’ means farmed birds, including birds
that are not considered as domestic but which are farmed as domestic animals,
with the exception of ratites.

Ø 
‘Lagomorphs’ means rabbits, hares and rodents.

Ø 
‘Wild game’ means:

§ wild
ungulates and lagomorphs, as well as other land mammals that are hunted for
human consumption and are considered to be wild game under the applicable law
in the Member State concerned, including mammals living in enclosed territory
under conditions of freedom similar to those of wild game; and

§ wild
birds that are hunted for human consumption.

Ø ‘Farmed game’ means farmed ratites and farmed land mammals other
than domestic ungulates referred above.

Ø ‘Small wild game’ means wild game birds and lagomorphs living freely
in the wild.

Ø ‘Large wild game’ means wild land mammals living freely in the wild
that do not fall within the definition of small wild game.

v 
Meat preparations cover fresh meat, including
meat that has been reduced to fragments, which has had foodstuffs, seasonings
or additives added to it or which has undergone processes insufficient to
modify the internal muscle fibre structure of the meat and thus to eliminate
the characteristics of fresh meat.[115]

v 
Mechanically separated meat ('MSM') is the
product obtained by removing meat from flesh-bearing bones after boning or from
poultry carcases, using mechanical means resulting in the loss or modification
of the muscle fibre structure.[116]

v 
'Meat products cover processed products
resulting from the processing of meat or from the further processing of such
processed products, so that the cut surface shows that the product no longer
has the characteristics of fresh meat.[117]

[1]    Regulation (EU) No 1169/2011 of the European Parliament of the
Council of 25 October 2011 on the provision of food information to consumers,
amending Regulations (EC) No 1924/2006 and (EC) No 1925/2006 of the European
Parliament and of the Council, and repealing Commission Directive 87/250/EEC,
Council Directive 90/496/EEC, Commission Directive 1999/10/EC, Directive
2000/13/EC of the European Parliament and of the Council, Commission Directives
2002/67/EC and 2008/5/EC and Commission Regulation (EC) No 608/2004, (OJ L 304,
22.11.2011, p. 18).

[2]    Not yet published.

[3]    OJ L 109, 6.5.2000, p. 29. The latter Directive remains
applicable until it is repealed and replaced by the FIC Regulation on 13
December 2014.

[4]    Article 2(1)(a)(i) of Directive 2000/13/EC.

[5]    Article 3(1)(8) of Directive 2000/13/EC.

[6]    OJ L 204, 11.8.2000, p. 1.

[7]    Regulation (EC) No 1760/2000 covers all beef products falling
within CN codes 0201, 0202, 0206 10 95 and 0206 29 91.

[8]    Article 13(5) of Regulation (EC) No 1760/2000.

[9]    OJ L 157, 17.6.2008, p. 46.

[10]  Article 5(4) of Commission Regulation (EC) No 543/2008.

[11]  Council Directive 2001/110/EC of 20 December 2001 relating to
honey, (OJ L 10, 12.1.2002, p. 47).

[12]  Commission Implementing Regulation (EU) No 543/2011
of 7 June 2011 laying down detailed rules for the application of Council
Regulation (EC) No 1234/2007 in respect of the fruit and vegetables and
processed fruit and vegetables sectors, (OJ L 157, 15.6.2011, p. 1).

[13]  Council Regulation (EC) No 104/2000 of 17 December 1999 on the
common organisation of the markets in fishery and aquaculture products, (OJ L
17, 21.1.2000, p. 22).

[14]  Commission Implementing Regulation (EU) No 29/2012 of
13 January 2012 on marketing standards for olive oil (OJ L 12, 14.1.2012,
p. 14).

[15] The applicable definitions set out in the FIC Regulation relating
to the origin of foods are to be found in Annex II thereto.

[16] Commission Staff Working Document accompanying the Proposal for a
Regulation of the European Parliament and of the Council on the provision of
food information to consumers – Impact Assessment Report on General Food
labelling issues, SEC(2008)92, 30.1.2008, at p. 22.

[17]  Unprocessed meat includes all fresh, chilled and frozen meat,
which has not been processed further than cut, minced and packed, e.g. minced
meat (without spices).

[18]  Annex XI to the FIC Regulation.

[19]  Article 26(8) and (9) of the FIC Regulation.

[20] "Study on mandatory origin labelling for pig, poultry and
sheep and goat meat", LEI Wageningen University (2013) (hereinafter
'the LEI study').

[21]  Article 26(8) of the FIC Regulation.

[22] Impact Assessment – Commission Staff Working Document – Mandatory
Origin indication for Unprocessed Pig, Poultry, Sheep and Goat Meat, not yet
published.

[23]  Commission Report on the functioning of
the meat market for consumers in the European Union, May 2013, to be found at: http://ec.europa.eu/consumers/consumer_research/market_studies/docs/mms_commission_report_en.pdf.
The report is based on findings of the "Study on the Functioning of the
meat market for consumers in the European Union", prepared by GfK EU3C (EU
Custom Research and Coordination Centre) on behalf of the European Commission,
Directorate General for Health and Consumers, December 2012. The study
supporting this report was performed before the accession of Croatia to the EU and therefore the data provided refer to EU27.

[24] The applicable definitions are laid down in Annex II. See also
para. 5.3 of Guidance document on the implementation of certain
provisions of Regulation (EC) No 853/2004 on the hygiene of food of animal
origin, dated 1.8.2013, to be found at: http://ec.europa.eu/food/food/biosafety/hygienelegislation/docs/guidance_doc_853-2004_en.pdf
.

[25]  FDE 2013: 'Data
and Trends of the European Food and Drink Industry 2012", 2013.

[26]  Annex C to the FCEC study.

[27]  FCEC study and LEI study.

[28]  Impact Assessment – Commission Staff Working Document – Mandatory
Origin indication for Unprocessed Pig, Poultry, Sheep and Goat Meat, not yet
published.

[29]  Commission Report on the functioning of
the meat market for consumers in the European Union, May

2013, at p. 31.

[30]  Impact Assessment – Commission Staff Working Document – Mandatory
Origin indication for Unprocessed  Pig, Poultry, Sheep and Goat Meat, not yet
published.

[31] Food for thoughts 2009: 'Overview of the Processed Meat
Market in Europe', to be found at http://foodmarkets.wordpress.com/2009/09/29/overview-of-the-processed-meat-market-in-europe/

[32]  FCEC study, at p. 44.

[33]  DG AGRI 2013: 'Prospects for Agricultural markets and income in
the EU 2012-2020', 2013.

[34]  I.e. companies owing slaughtering, cutting and
manufacturing including slicing/packaging operations.

[35]  Preparatory work
to support the impact assessment on reviewing the rules on the financing of
official control - A final report to DG SANCO", GHK in association with ADAS, UK - 2011

[36] Pig meat from
common breeds is considered a commodity, for which demand for origin
information is negligible. The indication of origin is
valuable information only in the case of pig meat products from special breeds
of pigs (e.g. Iberian pork). FCEC study, at p. 56.

[37] Trimmings are the leftovers, when a carcass is cut up to pieces,
which can have a high value. They are mostly used in re-composed products.

[38]  FCEC study, at p. 55.

[39]  FCEC study, at p. 54.

[40]  Section 2.3 of the FCEC study, at p. 27.

[41]  Section 3.2, at p. 56.

[42] Note: The first
figure represents the supply chain for pork, notably uncooked sausages (cat I),
cooked sausages (cat III) and sausages used as ingredient in food products (cat
II), source CLITRAVI. The second figure represents poultry meat, source Culinaria
Europe (poultry).

[43]  OJ L 31, 1.2.2002, p. 1.

[44]  Article 18 of Regulation (EC) No 178/2002; Guidance on the
implementation of Articles 11, 12, 14, 17, 18, 19 and 20 of Regulation (EC) No
178/2002 on General Food Law - Conclusions of the Standing Committee on the
Food Chain and Animal Health, January 2010, to be found at: http://ec.europa.eu/food/food/foodlaw/guidance/docs/guidance_rev_8_en.pdf.

[45]  OJ L 242, 20.9.2011, p. 2.

[46]  However, it does not apply to foods containing both products of plant origin
and processed products of animal origin.

[47]  OJ L 139,
30.4.2004, p. 55.

[48]  Regulation (EC) No 1760/2000 of the
European Parliament and of the Council of 17 July 2000 establishing a system
for the identification and registration of bovine animals and regarding the
labelling of beef and beef products and repealing Council Regulation (EC) No
820/97 (OJ L 204, 11.8.2000, p. 1).

[49]  Commission Regulation (EC) No 1825/2000 of
25 August 2000 laying down detailed rules for the application of Regulation
(EC) No 1760/2000 of the European Parliament and of the Council as regards the
labelling of beef and beef products (OJ L 216, 26.8.2000, p. 8).

[50]  Council Regulation (EC) No 21/2004 of 17
December 2003 establishing a system for the identification and registration of
ovine and caprine animals and amending Regulation (EC) No 1782/2003 and
Directives 92/102/EEC and 64/432/EEC (OJ L 5, 9.1.2004, p. 8).

[51] Council Directive 2008/71/EC of
15 July 2008 on the identification and registration of pigs (OJ L 213,
8.8.2008, p. 31).

[52]  See Section 1.2.1 above.

[53] Commission Report to the Council and the European Parliament on the
implementation of Title II of Regulation (EC) No 1760/2000 of the European
Parliament and of the Council establishing a system for the identification and
registration of bovine animals and regarding the labelling of beef and beef
products, COM(2004)316 final, dated 27.4.2004, at para. 4.1.3.

[54]  This was also the conclusion drawn by the Commission in its report
on the mandatory origin rules for beef and beef products as regards beef
trimmings, COM(2004)316 final, at para. 7.3.

[55]  The results of this study are set out in Annex D to the FCEC
study. Given the fact that the FCEC consumer study took place in the midst of
the horse meat scandal (December 2012-March 2013) affecting consumer trust in
the meat product/meat-containing product sector, it cannot be excluded that
this factor might have influenced the outcomes of the study.

[56]  "Study on the Functioning of the meat market for consumers in
the European Union", prepared by GfK EU3C (EU Custom Research and
Coordination Centre) on behalf of the European Commission, Directorate General
for Health and Consumers, December 2012.

[57]  "Where does my food come from" – BEUC Consumer survey on
origin labelling on food, January 2013, to be found at: http://docshare.beuc.org/docs/1/JOBICFGABOJHOBGGIOEIPGLOPDW69DBDG69DW3571KM/BEUC/docs/DLS/2013-00043-01-E.pdf
.

[58]  BEUC study, at p. 5.

[59]  The UK FSA commissioned research to investigate consumer usage,
understanding and perceived importance of country of origin labelling on food
products. The sample was recruited using a multi-stage sampling design and a
representative sample of 1601 adults, aged 16 or over in the UK, living in private households, was interviewed.

[60]  FCEC study, at p. 16.

[61]  In Denmark, the national consumers' association used its own
consumer panel based on the BEUC questions.  In Greece and the Czech Republic, the respective consumer organisations used a similar questionnaire to that
of BEUC, which was addressed to their members only. Similar consumer research
was also carried out in Belgium, Italy, Spain and Portugal by the national
consumer associations (i.e. Test-Achats/Test-Aaakoop, Altroconsumo, OCU,
Deco Proteste (2012): Origin of Food, Final Version, September 2012). Data were
simultaneously collected in these Member States through self-administered
online questionnaires from 4 September to 19 September 2012.

[62] Haaster-de Winter,
M.A van and Ruissen A. (2012). Voedsel labelen met land van herkomst: leuk,
maar geen voorwaarde; Onderzoek onder Nederlandse consumeren. LEI report 2012-021. The Hague: LEI.
Translated: Food labelling by country of origin, nice, but no conditions.
Research of Dutch consumers. Also cited in the LEI study, at p. 64.

[63] FCEC study, at p. 26.

[64] Id.

[65]  LEI study, at p. 64.

[66] Commission Report on the functioning of the meat market for
consumers in the European Union, May 2013, at p. 5.

[67]  Id., at p. 16.

[68]  Id., at p. 23.

[69] The first three surveys (2009, 2010 and 2011) were conducted by
Taloustutkimus market research; the third survey (2012) was conducted by TNS
Gallup.

[70]  FCEC study, at p. 10.

[71]  FCEC study, at p. 14.

[72]  FCEC study, at p. 15.

[73]  WTP is a difficult and complex issue to address. Given the scale
of the FCEC consumer survey, the approach followed was the simplest possible.

[74]  FCEC study, at p. 23.

[75]  Herkomst in de supermarkt Consumenten over
de rol van herkomst bij hun voedselaankop. LEI report
2011-044 Wageningen  Marzo 2012, cited in the FCEC study at p. 25.

[76]  FCEC study for cited studies, at p. 25.

[77]  I.e. 12 of the 19 MS CAs that responded to the FCEC
consultation. It is noted that 6 MS CAs provided no answer to this question,
due to lack of specific evidence on consumer WTP in their countries.

[78]  The individual bars cannot be added, as in some cases MSs CAs
responded that WTP varies by product (and/or by meat species). In addition, six
MSs provided no answer.

[79]  Commission Report on the functioning of
the meat market for consumers in the European Union, May 2013, at p. 24. The EU
average covered four products: minced beef; pork cutlets; pork sausages; and
whole chickens. ‘Origin
certified meat’ was defined in the study as meat with specific geographic
certifications, including quality schemes such as 'protected designation
origin' (PDOs) products or national equivalents (such as: Certified Irish
Aberdeen Angus Beef, Liptovský salám, Agneau du Périgord). The higher average
price therefore is most likely to be also attributable to other quality aspects
of these schemes and not to be only origin-related.

[80]  Commission Report on the functioning of the meat market for
consumers in the European Union, May 2013, at p. 7.

[81] Commission Staff Working Document accompanying the Proposal for a
Regulation of the European Parliament and of the Council on the provision of
food information to consumers - Impact Assessment Report on General Food
Labelling Issues, SEC(2008)92, dated 30.1.2008, at p. 22.

[82]  GfK consumer study on the meat market, at p. 31.

[83]  Regulation (EC) No 882/2004 of the European Parliament and of the
Council of 29 April 2004 on official controls performed to ensure the
verification of compliance with feed and food law, animal health and animal
welfare rules, (OJ L 165, 30.4.2004, p. 1).

[84]  The UK FSA commissioned research to investigate consumer usage,
understanding and perceived importance of country of origin labelling on food
products. The sample was recruited using a multi-stage sampling design and a
representative sample of 1601 adults aged 16 or over in the UK, living in private households, was interviewed.

[85]  This survey was posted on line between 13 December 2012 and January 28,
2013, and covered a total 1040 consumers.

[86]  Article 26(8) of the FIC Regulation.

[87]  Draft Commission Implementing Regulation laying down rules for the
application of Regulation (EU) No 1169/2011 of the European Parliament and of
the Council as regards the indication of the country of origin or place of
provenance for fresh, chilled and frozen meat of swine, sheep, goats and
poultry, notified under the Technical Barriers to Trade Agreement, G/TBT/N/EU/158.

[88]  LEI study.

[89]  Impact Assessment – Commission Staff Working Document – Mandatory
Origin indication for Unprocessed Pig, Poultry, Sheep and Goat Meat, not yet
published.

[90]  Id.

[91]  See Section 3.3.3.

[92]  Origin labelling of meat products may have
a positive impact on purchasing, if it inspires confidence in the authenticity
of the product; it may have a negative impact related to perceived attributes
of the product or concerning the country or area in question; or it may have no
impact if origin is of not a priority for to the purchaser. LEI study, at para. 5.2.

[93]  See Section 3.2.

[94]  See Section 3.3.2.

[95]  LEI study at para. 5.2. See also Impact Assessment –
Commission Staff Working Document – Mandatory Origin indication for Unprocessed
Pig, Poultry, Sheep and Goat Meat, not yet published.

[96] Section 4.5 of FCEC study, at p. 97. It should be noted that the Member
State level estimates differ significantly from the EU-average estimates as
depicted in the FCEC study, given the fact that the former refer to specific
products and the operational conditions that apply in the relevant Member
State, whereas the latter refer to two broad categories (i.e. cooked
sausages and cooked ham) and consider "average" operational
conditions applying throughout the EU.

[97]  LEI study at p. 79. See also COM(2004)316 final.

[98]  FCEC study at p. 95. As noted in the FCEC study the evidence base
was quite heterogeneous and it did not allow the systematic analysis of the
information or extrapolation of the quantitative estimates provided by few
stakeholders as they referred to specific situations and assumptions.

[99] Trimmings, i.e. off-cuts of meat and trimmings from
carcasses, come from different batches and are assembled for sale by the full
pallet. The quantity produced in a day's work by small cutting plants is not
always sufficient for a full pallet. In practice, operators are not generally
able to make batches of trimmings that are of homogenous origin."
COM(2004)316, at para. 4.2.2. Similar conclusions can also be drawn in the case
of animal fat.

[100] FCEC study, at p. 116.

[101] LEI study at p. 79. See also COM(2004)316 final.

[102] For example, the most significant trade flows in the pig meat
sector are mostly occurring amongst those countries. FBOs especially that are
situated close to borders of those MSs appear to be involved in significant
cross-border trade and therefore are expected to be mostly affected.

[103] Section 3.3.

[104] Section 4.8 of the FCEC study.

[105] COM(2004)316 final, at para. 4.3.

[106] Section 4.6.2 of the FCEC study.

[107] The FCEC study attempted to draw a parallel from other cases, in
particular the costs of controls on mandatory labelling for beef. Where such
data exist, the costs were indicated to be relatively high. In Denmark, the additional control costs (including administrative burden) stemming from the
labelling requirements for beef (Regulation (EC) No 1760/2000) were estimated
at an amount of 19.7 million EUR in 2007. The current annual expenditure for
beef labelling controls in Demark is estimated at approximately 4.2 million
EUR.

[108] Impact Assessment – Commission Staff Working Document – Mandatory
Origin indication for Unprocessed Pig, Poultry, Sheep and Goat Meat, not yet
published.

[109] Article 2(2)(e) of the FIC Regulation.

[110] Article 2(2)(q) of the FIC Regulation.

[111] Article 2(3) of the FIC Regulation.

[112] OJ L 302, 19.10.1992, p. 1.

[113] Article 2(2)(g) of the FIC Regulation.

[114] Article 2(1)(f) of the FIC Regulation read in conjunction with
point 1.1 of Annex I to Regulation (EC) No 853/2004.

[115] Article 2(1)(f) of the FIC Regulation read together with point 1.15
of Annex I to Regulation (EC) No 853/2004.

[116] Article 2(1)(f) of the FIC Regulation read together with point 1.14
of Annex I to Regulation (EC) No 853/2004.

[117] Article 2(1)(f) of the FIC Regulation read together with point 7.1
of Annex I to Regulation (EC) No 853/2004.