# IMMC.EESC-2022-05926-AC.ENG.xhtml.EESC-2022-05926-00-01-AC-TRA-EN.docx

| OPINION |
| --- |
| European Economic and Social Committee |
| Labelling of organic pet food |
| _____________ |
| Proposal for a Regulation of the European Parliament and of the Council

  on the labelling of organic pet food
  [COM/(2022) 659 final – 2022/ 0390(COD)] |
| |
| NAT/875 |
| |
| Rapporteur: Arnaud SCHWARTZ |
| |

OPINION

European Economic and Social Committee

Labelling of organic pet food

_____________

Proposal for a Regulation of the European Parliament and of the Council

  on the labelling of organic pet food
  [COM/(2022) 659 final – 2022/ 0390(COD)]

NAT/875

Rapporteur: Arnaud SCHWARTZ

EN

Referral

| Referral | Council of the European Union, 08/12/2022 |
| --- | --- |
| Legal basis | Article 43(2) of the Treaty on the Functioning of the European Union |
| Section responsible | Agriculture, Rural Development and the Environment |
| Adopted in section | 10/01/2023 |
| Adopted at plenary | 24/01/2023 |
| Plenary session No | 575 |
| Outcome of vote
  (for/against/abstentions) | 187/0/4 |

Referral

Council of the European Union, 08/12/2022

Council of the European Union, 08/12/2022

Legal basis

Legal basis

Article 43(2) of the Treaty on the Functioning of the European Union

Article 43(2) of the Treaty on the Functioning of the European Union

Section responsible

Section responsible

Agriculture, Rural Development and the Environment

Agriculture, Rural Development and the Environment

Adopted in section

Adopted in section

10/01/2023

10/01/2023

Adopted at plenary

Adopted at plenary

24/01/2023

24/01/2023

Plenary session No

Plenary session No

575

575

Outcome of vote
  (for/against/abstentions)

Outcome of vote
  (for/against/abstentions)

187/0/4

187/0/4

1.Conclusions and recommendations

1.

Conclusions and recommendations

1.1The European Economic and Social Committee (EESC) welcomes the proposal for a Regulation on the labelling of organic pet food and calls for its swift adoption in order to ensure continuity with current requirements, before the entry into force of the new Regulation on organic production and labelling of organic products
  1
  .

1.1

The European Economic and Social Committee (EESC) welcomes the proposal for a Regulation on the labelling of organic pet food and calls for its swift adoption in order to ensure continuity with current requirements, before the entry into force of the new Regulation on organic production and labelling of organic products

1

.

1.2The EESC believes that the pet food sector has a role to play in contributing to the European Green Deal objectives, and that these new labelling measures will help to develop and promote the sector, both by selling products to consumers mindful of the organic content of what they buy, and through the opportunity to bring added value to organic by-products. The sector will thus be able to contribute, albeit moderately, to achieving the 25% target of EU agricultural land under organic farming by 2030, as included in the Farm to Fork and Biodiversity Strategies, and in the Action Plan for the development of EU organic production.

1.2

The EESC believes that the pet food sector has a role to play in contributing to the European Green Deal objectives, and that these new labelling measures will help to develop and promote the sector, both by selling products to consumers mindful of the organic content of what they buy, and through the opportunity to bring added value to organic by-products. The sector will thus be able to contribute, albeit moderately, to achieving the 25% target of EU agricultural land under organic farming by 2030, as included in the Farm to Fork and Biodiversity Strategies, and in the Action Plan for the development of EU organic production.

1.3The EESC encourages the Commission and European institutions to communicate on this new Regulation and its objectives, in order to further strengthen consumer demand and confidence in organic products.

1.3

The EESC encourages the Commission and European institutions to communicate on this new Regulation and its objectives, in order to further strengthen consumer demand and confidence in organic products.

1.4Given that pet food is intended for sale to consumers, the EESC recommends involving and consulting the industry in legislative work on the sustainability of food products, such as the labelling of sustainable food products, the environmental performance of products and sustainable packaging
  2
  .

1.4

Given that pet food is intended for sale to consumers, the EESC recommends involving and consulting the industry in legislative work on the sustainability of food products, such as the labelling of sustainable food products, the environmental performance of products and sustainable packaging

2

.

2.Background

2.

Background

2.1The entry into force on 1 January 2022 of the new EU Regulation on organic production and labelling of organic products
  3
  introduced strict requirements for the labelling of organic food, feed and pet food. Previously, pet food, in particular cat and dog food, could be labelled as organic in accordance with national rules or private standards even if not all the agricultural ingredients were organic. Since 1 January 2022, this type of labelling is no longer possible.

2.1

The entry into force on 1 January 2022 of the new EU Regulation on organic production and labelling of organic products

3

introduced strict requirements for the labelling of organic food, feed and pet food. Previously, pet food, in particular cat and dog food, could be labelled as organic in accordance with national rules or private standards even if not all the agricultural ingredients were organic. Since 1 January 2022, this type of labelling is no longer possible.

2.2On 28 November 2022, the European Commission therefore issued a proposal for a Regulation on the labelling of organic pet food
  4
  , with the aim of establishing specific labelling rules for pet food. The aim is to allow pet food, especially cat and dog food, to bear the organic production logo of the European Union, if they meet the strict criteria laid down by the European legislator.

2.2

On 28 November 2022, the European Commission therefore issued a proposal for a Regulation on the labelling of organic pet food

4

, with the aim of establishing specific labelling rules for pet food. The aim is to allow pet food, especially cat and dog food, to bear the organic production logo of the European Union, if they meet the strict criteria laid down by the European legislator.

2.3The labelling rules proposed for organic pet food mirror the labelling rules applicable to food: in order to be labelled organic and bear the organic production logo of the European Union, at least 95% in terms of weight of the agricultural ingredients will have to be organic (when less than 95% of the agricultural ingredients are organic, the reference to organic may only be used in the list of ingredients in relation to organic ingredients with an indication of the total percentage of organic ingredients in proportion to the total quantity of agricultural ingredients).

3.General comments

3.1The EESC reiterates its support for the Action Plan for the development of EU organic production
  5
  , recognising the role played by organic farming in achieving the European Green Deal objectives and, in particular, measures to further strengthen consumer demand and confidence in organic products.

3.2In this context, the EESC acknowledges the need to adopt this proposal for a Regulation as soon as possible, in order to authorise the use of the EU organic production logo for pet food that is not composed of 100% (but at least 95%, in weight) organic ingredients, which is the reality for some products. However, the EESC calls for the this type of regulatory act to be implemented in the future at the same time as the entry into force of the basic act, in order to avoid legal loopholes that would adversely affect both producers and consumers/buyers.

3.3The EESC supports the proposed labelling rules for organic pet food, given the high level of organic products required (95% in weight) and the similarity with the rules applied to organic food, which encourage a uniform use of the EU logo and easier understanding for consumers for whom these two types of products are intended.

3.4The EESC points out that, despite its small proportion of organic products, the pet food sector is growing rapidly (3.1% annual growth, with 46% of European households owning at least one pet
  6
  ). According to the sector itself, the trend towards "humanising" pets sees many pet owners looking for food that reflects their own taste, leading to the purchase of premium range products, including organic ones
  7
  . The EESC therefore welcomes these new labelling measures, which could boost this organic pet food market, both by selling products to consumers mindful of the organic content of what they buy, and through the opportunity to bring added value to organic by-products.

3.5The EESC therefore believes that these new labelling measures could contribute, albeit moderately, to achieving the 25% target of EU agricultural land under organic farming by 2030, as included in the European Green Deal's Farm to Fork and Biodiversity Strategies, and in the Action Plan for the development of EU organic production.

3.6The EESC welcomes the application of measures requiring mandatory information on the origin of the food with regard to the raw materials used in the composition of the pet food, bearing the labels "EU Agriculture", "Non-EU Agriculture" and "EU/non-EU Agriculture", or even "Agriculture + name of country" or "Agriculture + name of country and region."

3.7The EESC encourages the Commission and European institutions to communicate on this new Regulation and its objectives, in order to further strengthen consumer demand and confidence in organic products.

3.8Lastly, the EESC believes that these labelling measures should enable, or even broaden, dialogue with pet food producers so as to ensure the sector's commitment to the principles of sustainable food systems and to foster their contribution to the European Green Deal objectives.

Brussels, 24 January 2023

Christa Schweng

President of the European Economic and Social Committee

_____________