EN    EN 
 
 
 EUROPEAN  
COMMISSION   
Brussels, 20.5.2015  
COM(2015) 205 final  
  
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 
milk, milk used as an ingredient in dairy products and types of meat other than beef, 
swine, sheep, goat and poultry meat   
 
2 
 1. INTRODUCTION  
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 
introduces a set of provisions on origin labelling for foods.  
In particular, Articles 26(5) and (6) of the FIC Regulation require the Commission to 
submit a series of reports to the European Parliament and the Council concerning the 
possibility to extend mandatory origin labelling for other foods. A first report on 
mandatory origin labelling for meat used as an ingredient in prepacked foods was 
adopted on 17  December 2013.2  
The present report covers the obligation of the Commission to submit reports to the 
European Parliament and the Council by 13 December 2014 regarding the mandatory 
indication of the country of origin or place of provenance for milk, milk used as an 
ingredien t in dairy products and types of meat other than beef, swine, sheep, goat and 
poultry meat. For the scope of this report, milk and dairy products are considered as 
defined in Regulation (EU) No 1308/2013, Annex VII, Part III. The types of meat 
concerned ar e fresh and frozen meat from horses, rabbits, reindeer and deer, from 
farmed and wild game, as well from birds other than chicken, turkey, ducks, geese 
and guinea fowls.  
As outlined in Article 26(7) of the FIC Regulation, this report takes into account:  
– the need for the consumer to be informed;  
– the feasibility of providing the mandatory indication of the country of origin or 
place of provenance for the different products and  
– an analysis of the costs and benefits of the introduction of such requirements 
on both food business operators and administrations as well as their impact on 
the internal market and on international trade.  
With the purpose of carefully assessing mandatory origin labelling for the foods 
under the remit of this report, the Commission serv ices entrusted an independent 
consultant with a survey3 (hereinafter, the ‘study’) to analyse the impact of different 
labelling scenarios. Its main findings are discussed in this report. Voluntary or 
mandatory origin labelling were evaluated in 9 Member St ates for drinking milk and 
products using milk as an ingredient such as cheese, yoghourt, etc., and in major 
producing countries for horse, rabbit and game meats.  
2. MANDATORY  AND VOLUNT ARY ORIGIN LABELLING  
Mandatory origin labelling rules exist for several products, such as honey4, fruit and 
vegetables5, unprocessed fish6, beef7, olive oil8, wine9, eggs10, imported poultry11 and 
                                                            
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 rep ealing 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 COM(2013)755, 17.12.2013.  
3 http://ec.europa.eu/agriculture/external -studies/index_en.htm  
4 Council Directive 2001/110/EC relating to hone y (OJ L 164, 3.6.2014, p. 1).  
 
3 
 spirits drinks12. As provided for in the FIC Regulation, the Commission adopted 
detailed rules with regard to the mandatory origin labelling of  fresh, chilled and 
frozen meat of swine, sheep, goats and poultry13. These rules require the compulsory 
indication of the country where the animal was reared for a substantial part of its life 
together with the indication of the country of slaughter. The new requirements will 
apply as from 1st April 2015 to pre -packed meat but Member States may decide to 
extend them to non -prepacked meat as well.   
Although detailed data to assess the market share of food products participating in 
voluntar y food labelling schemes is not available, existing inventories show that the 
milk and meat sectors have a relatively higher penetration of food labelling schemes. 
Milk and meat products sold on the EU market are already labelled voluntarily, 
either via an  EU scheme (PDO, PGI or TSG14) or via private or public organisations 
(such as group of operators, retailers, NGOs or public authorities). Such labelling 
usually refers to a Member State or a lower geographical level (region). The criteria 
used in these vol untary schemes to link certain attributes with a geographical 
provenance can differ considerably from one to another.  
 
3. MILK AND OTHER TYPES OF MEATS – OVERVIEW OF THE SECT ORS 
3.1. Supply and processing chains  
Dairies, slaughterhouses and processing pla nts are key actors for passing origin 
information to the next player in the food chain. The higher the degree of vertical 
integration, the easier it is to ensure that origin information is passed along the food 
                                                                                                                                                                                          
5 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 vegetab les sectors, (OJ L 157, 15.6.2011, p. 1).  
6 Regulation (EU) No 1379/2013  of the European Parliament and of the Council of 11 December 2013 
on the common organisation of the markets in fishery and aquaculture products, (OJ L 354, 28.12.2013, 
p. 1).  
7 Regu lation (EC) No 1760/2000 of the European Parliament and the Council establishing a system for 
the identification and registration of bovine animals and regarding the labelling of beef and beef 
products,(OJ L 204, 11.8.2000, p. 1).  
8 Commission Implementin g Regulation (EU) No 29/2012 of 13 January 2012 on marketing standards for 
olive oil (OJ L 12, 14.1.2012, p. 14).  
9 Regulation (EU) No 1308/2013 of 17 December 2013 establishing a common organisation of the 
markets in agricultural products and repealing Co uncil Regulations (EEC) No 922/72, (EEC) No 
234/79, (EC) No 1037/2001 and (EC) No 1234/2007 (OJ L 347, 20.12.2013, p.671).  
10 Commission Regulation (EC) No 589/2008 of 23 June 2008 laying down detailed rules for 
implementing Council Regulation (EC) No 1234/ 2007 as regards marketing standards for eggs (OJ L 
163, 24.6.2008, p. 6).  
11 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  
poultrymeat (OJ L 157, 17.6.2008, p. 46).  
12 Regulation (EC) No 110/2008  of the European Parliament and the Council of 15 Ja nuary 2008 on the 
definition, description, presentation, labelling and protection of geographical indications of spirit drinks 
and repealing Council Regulation (EEC) No 1576/89  (OJ L 39, 13.2.2008, p.16).  
13 Commission implementing Regulation (EU) Nº 1337/2013 of 13 December 2013 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 (OJ L 335, 14.12.2013, p. 19).  
14  PDO = Protected Designation of Origin; PGI = Protected Geograp hical Indication; TSG = Traditional 
Speciality Guaranteed  
 
4 
 chain. On the contrary, the more complex and sophisticated the processing is, the 
more burdensome origin labelling becomes.  
Data on the structure of the EU dairy industry available from an enquiry carried out 
in October -November 2009 shows that small and medium size enterprises, producing 
less than 1 00 000 tonnes of milk, account for 81% in milk processors and processed 
28,5% of the total volume of milk. In large producing Member States about 50% of 
processing is often concentrated in the 5 largest companies. Farmers are heavily 
dependent on local pro cessors given the perishable nature of the product and 
continuous flow of production. Dairy processors generally buy raw milk and other 
milk ingredients from multiple sources and in those dairies located in border regions, 
it is common that milk from sever al origins is processed together in the same plant.  
The types of meat under the remit of this report tend to involve also short supply 
chains often within the same Member State. Retailers buy these meats mainly from 
traders on spot markets, abattoirs or c utting plants. Horsemeat can have longer 
supply chains with more operators involved and more intra -EU and external trade.  
3.2. Consumption of milk, dairy products and types of meat under the remit of this 
report  
Average per capita consumption in the EU is  around 62 kg for drinking milk, 17 kg 
for cheese, 16 kg for acidified milk, 5 kg for cream, 4 kg for butter and 9 kg for other 
fresh dairy products (Eurostat, 2013).  
The EU milk market is rather mature and sizeable increases in per capita 
consumption are only likely to materialise in the Member States that acceded in the 
last decade, while consumption is expected to increase only marginally in the ‘old’ 
Member States.  
Consumption of the types of meat under the remit of this report account only for 3% 
of to tal EU meat consumption15 although figures available from Member States are 
not always updated. Consumption of horse and rabbit meats is more relevant in Italy, 
France, Spain, Belgium and the Netherlands. Game meat is mainly consumed during 
the hunting seas on, i.e. from October till December.  
3.3. Production and trade  
The EU is largely self -sufficient in milk and dairy products with nearly 65% of the 
milk collected being processed into consumer products, mostly for the domestic 
market. The manufacture of ch eeses and fresh products constitutes the most 
important segments in terms of milk use (53 and 43 mio tonnes of milk equivalent 
respectively). By volume, powders (skimmed, whole and whey) and butter 
production are relatively smaller (12 and 25 mio tons milk  equivalent respectively). 
Their intra -EU trade is nevertheless significant (1,6 and 0,6 mio tonnes respectively) 
but less important than for cheeses (3,6 mio tonnes). Volumes fluctuate slightly 
every year depending on supply and market conditions.  
Import s of dairy products are limited to preferential access granted to some third 
countries within bilateral or multilateral agreements, while dairy exports account for 
some 10% of milk production. Overall, the EU is a net exporter of dairy products.  
                                                            
15 Impact Assessment – Commission Staff Working Document – Mandatory Origin indication for 
Unprocessed Pig, Poultry, Sheep and Goat Meat.  
http://ec.europa.eu/smart -regulation/impact/ia_carried_out/docs/ia_2013/ia_meat_origin_labelling.pdf   
 
 
5 
 The annua l production of other types of meat under the remit of this report is 
estimated to be only 2% of the overall EU  meat production. Rabbit, horse, and game 
meats account for around 490, 73 and 131 thousand tonnes respectively (FAO, 2012) 
while production figu res for other types of meat covered by this report are 
substantially smaller. The intra -EU trade involves almost 52 and 22 thousand tonnes 
respectively of horse and rabbit meats whereas there are around 25 thousand tonnes 
of imports from third countries of  either horse meat, mainly from Argentina, USA, 
Canada and Mexico and rabbit meat, primarily imported from China (more than 7 
thousand tonnes). Imports of venison originate principally from New Zealand.  
3.4. EU traceability systems  
The traceability system in the EU for food products aims to ensure food safety and is 
not necessarily fitted to pass origin information along the food chain:  
–  Food safety16requires to register information 'one step back – one step forward' 
along the food chain: food business opera tors must be able to identify the 
businesses to which their products have been supplied and those from which 
they sourced their material. For foods of animal origin, more detailed 
information requirements are imposed17without however requiring a systematic 
link to the country of origin or place of provenance of the raw material used.  
– A health or identification mark indicating the last establishment of 
production/processing/packaging, and the Member State in which it is located, 
has to appear on the labelling  of products of animal origin (Article 5 and 
Annex II section I of Regulation 853/2004)18 but this does not necessarily 
relate to the origin or provenance of the raw material used.  
– Although identification and registration systems for live animals exist, th eir 
operation varies across species and, for most of them do not constitute a 
sufficient base to generate information for a full origin labelling 
(born/reared/slaughtered).  
– For the meats under the remit of this report, the only case for which a system of 
identification and registration of live animal exists is for equidae (e.g. horses). 
Equidae have to be accompanied in the movements across the EU by an 
identification document or passport in accordance with Commission Decision 
2000/68/EC and Commission Reg ulation (EC) No 504/2008 laying down rules 
on the identification of equidae born in or imported into the Union. However, 
this system does not include a compulsory centralised database to trace the 
movements of the animals. Work on strengthening the registr ation 
                                                            
16 Article 18 of 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 matter s of food safety (OJ L 31, 
1.2.2002, p. 1).  
17 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 ori gin (OJ L 242, 20.9.2011, p. 2).  
18 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 (OJ L 139, 30.4.2004, p. 55).  
 
6 
 requirements is ongoing and new requirements will be applicable as from 
201619. 
 4. CONSUMERS ' ATTITUDE TOWARDS MAN DATORY ORIGIN LABELL ING FOR MILK AND 
OTHER TYPES OF MEAT  
According to the Eurobarometer survey 201320, most EU citizens consider necessar y 
to indicate the origin of milk, whether sold as such or used as an ingredient in dairy 
products (84%). A similar percentage (88%) has been recorded for the meats under 
the remit of this report. However, even in these cases, expectations on the precise 
information that consumers would like to receive under the notion “origin” vary 
greatly.  
For milk and dairy products, preference was expressed for the country of milking or 
processing whereas the place where the animal was raised and slaughtered were the 
main points of interest for meats, with the place of birth attracting less interest. 
Information at Member State or third country level was considered more appropriate 
than the regional or “EU/non EU” levels.  
Consumer surveys reveal that the origin is an i mportant purchase factor for milk, 
dairy and meat products but only after price, taste, and best before/use by dates.  
Nonetheless, most of them also show that there are significant differences in 
consumer preferences between Member States and discrepancy b etween consumers' 
interest in origin labelling and their willingness to pay for that information.  
Therefore, in spite of their interest to be informed, consumers are not necessarily 
ready to buy products at a higher cost to have that information. Varying 
methodologies show that there are difficulties in estimating the real willingness to 
pay either because of a methodological bias or because consumer replies to surveys 
do not always correspond to their purchasing behaviour. In the 2013 Eurobarometer  
only around half of consumers declared their willingness to pay 1 -2% more to have 
origin information for the products under the remit of this report.  
5. POSSIBLE SCENARIOS AN D MODALITIES OF ORIG IN LABELLING  
For milk and milk used as an ingredient  
The following scenarios are examined:  
– Scenario 1 – Status quo (voluntary origin labelling);  
– Scenario 2 – Mandatory origin labelling as “EU/non EU” (or “EU/third 
country”);  
– Scenario 3 – Mandatory origin labelling indicating the Member States or third 
country where the milk (a) was milked or (b) was processed.  
For the types of meat  
The following scenarios are examined:  
– Scenario 4 – Status quo (voluntary origin labelling);  
                                                            
19  Commission Implementing Regulation ( EU) No 2015/262 of 17 February 2015 laying down rules 
pursuant to Council Directives 90/427/EEC and 2009/156/EC as regards the methods for the 
identification of equidae (Equine Passport Regulation (OJ L 59, 03.3.2015, p. 1).  
20 http://ec.europa.eu/public_opinion/archives/eb_special_419_400_fr.htm   
 
7 
 – Scenario 5 – Mandatory origin labelling indicating the Member States or third 
coun try where the animal has spent a substantial period of rearing prior to 
slaughter as well as the place of slaughter;  
– Scenario 6 – Mandatory origin labelling indicating the Member States or third 
country where the animal was born, reared and slaughtered.  
For wild game meat, the only scenario examined is the indication of the place of 
hunting.  
Furthermore, the scenario “EU/non EU” (or “EU/third country”) was discarded for 
the meats under the remit of this report due to the limited consumer interest in  such  a 
wide geographical framework confirmed during the study and on the impact study on 
mandatory origin labelling for pigmeat, poultry, sheep and goat meats21.  
Additionally, the option of mandatory labelling at regional level within the EU was 
disregarded  d ue to its very high implementation costs (requiring the establishment of 
more detailed traceability systems and involving a greater segmentation of the supply 
chain) together with the absence of an harmonised legal definition of this 
geographical level acr oss the Union.  
6. ANALYSIS OF IMPACTS A ND COSTS AND BENEFIT S OF THE DIFFERENT S CENARIOS  
6.1. Impact on consumer behaviour  
It is difficult to estimate the impact of origin labelling on consumers in terms of a 
cost-benefit analysis. Origin labelling provid es consumers with additional 
information to make informed choices on the food they purchase and consume. 
Overall, origin labelling tends to be perceived by the consumers with a range of 
positive attributes, including quality.  
In the status quo scenarios w ith voluntary origin labelling, the extent of information 
on the provenance of the product would be provided depending on the demand from 
consumers. As such this would not fully meet consumer demands for systematic 
origin information but it would be more i n line with the limited consumer willingness 
to pay for compulsory origin information.  
When operators voluntarily decide to label origin information, this is presented as 
adding value to the product and influencing the purchasing decisions of those 
consume rs for whom this information is relevant.  
For milk and milk used as an ingredient  
Scenarios with mandatory origin labelling either at “EU/non -EU” or “Member State” 
would systematically provide consumers with origin information.  
The option “EU/non -EU” woul d simply differentiate EU production from that of 
third countries. Considered as too generic, it does not appear worth any price 
increase from the consumer point of view. On the contrary, the scenario “Member 
State” seems more meaningful for consumers, esp ecially when origin labelling is 
given with regard to the place of milking. Conversely, the preference of dairies is to 
indicate the place of processing, which is much simpler to implement.  
For the types of meats  
                                                            
21 http://ec .europa.eu/smart -regulation/impact/ia_carried_out/docs/ia_2013/ia_meat_origin_labelling.pdf   
  
 
8 
 Surveys show that consumers are mainly inte rested in the place where the animal 
was raised and slaughtered (or hunted).  
The case of horse meat sector, with recent scandals and consequent negative public 
perception, has triggered requests from different organisations and institutions for 
more exten sive information.  
6.2. Economic impacts  
6.2.1.  Operating costs of food business operators (FBOs)  
The study found that, except in the case of voluntary labelling where operating costs 
would remain unchanged, new mandatory labelling obligations would entail  
additional costs for FBOs.  
For milk and milk used as an ingredient  
Scenarios“EU/non EU” and “Member State” would pose operational challenges and 
require profound adaptations especially with respect to milk ingredients of mixed 
origins.  
The cost for labell ing the origin of drinking milk would depend on the rules defined 
and the characteristics of every plant. While labelling the place of processing would 
be much simpler, indicating the place of milking would be challenging for processors 
sourcing milk from several origins and its implementation would result in additional 
operating costs. With mixes of origin in a given product costs can differ when 
labelling several Member States/third countries. If eventually retained, further 
technical work would be needed  to determine tolerances and lower limits above 
which the Member State of origin would have to be indicated (milk being a liquid 
product, it blends naturally when put together).  
In contrast to milk for direct consumption, providing origin labelling for mil k used as 
an ingredient in dairy products appears much more difficult in practice, and hence 
expensive, in particular for highly processed dairy products with multiple 
manufacturing stages and where milk ingredients tend to travel long distances. FBOs 
using milk ingredients from several origins would be adversely affected along the 
following lines:   
– The most relevant cost items depicted in the study refer to the adaptation of 
sourcing practices, possible changes in the mix of suppliers, switching to 
smalle r production batches, adaptation of production processes to achieve 
segregation by origin, adaptation of packaging/labelling and 
implementation/adaptation of traceability systems.  
– Costs can differ depending on the specific operational situation of the FBO s 
concerned, the dairy product and milk ingredient in question and the 
traceability systems in place.  
The analysis indicated that the additional costs are likely to range from negligible up 
to 8% of the cost of production at processor level but certain co mpanies claim they 
may reach up to 45%  in particularly disadvantageous circumstances.  
For the types of meat  
– Costs would be relatively minor (less than 3%) as compared to the wholesale 
price and vary depending on the size and location of the company. Bigg er 
companies sourcing domestically or from one third country would be able to 
 
9 
 absorb costs more smoothly. These costs would include the need to reinforce 
the traceability downstream through the processing and supply chain.  
– The more complex the labelling r ules, the more costly the adaptation of the 
identification systems for live animals would be.  
– Operators working with meats from several provenances would readapt 
supplies towards a rather homogeneous origin with the view to reduce 
operational costs.  
6.2.2 . Competitiveness, trade and investment flows  
The consultants in charge of the study estimate that mandatory origin labelling would 
possibly push consumers towards domestically produced goods. As a result, there 
will be a certain renationalisation of the s ingle market.  
For milk and milk used as an ingredient  
– Under the scenario “EU/non -EU”, the internal market is expected not to be 
greatly affected. A shift among processors towards fewer suppliers of milk 
ingredients is likely to occur so as to avoid the com plexities deriving from 
multiple EU and third country origins, with possible impact on international 
trade.  
– The outlets for milk and milk ingredients of mixed origin would become more 
limited in case the indication of the Member States becomes compulsory.  
FBOs would  likely see the price of their raw materials increase as their overall 
supply base would become more restricted.  
For the types of meat  
– The scale of the impact of the different scenarios would be modest for most of 
the meats under the remit of t his report. On the contrary, changes in the supply 
chain of horses can result in a segmentation of intra -EU trade and a decrease in 
the number of intermediaries. Furthermore, FBOs may consider more cost 
efficient to adapt their supply structure (sourcing, batch sizes, reducing 
intermediaries) rather than upgrading the internal traceability system in order to 
be able to work simultaneously with several origin sources.  
– Impacts of an origin labelling obligation would concern especially those third 
countries th at currently export some quantities of unprocessed meat to the 
Union. External trade of small game and wild bird meats is virtually non -
existent and intracommunity trade is very limited.  
6.2.3.   Regulatory burden on businesses  
For FBOs, additional adminis trative costs would be due to the need to record the 
origin of supplies and adapt their traceability system.  
In general, smaller dairies dependant on local supplies would be less affected than 
collector centres of large companies. Also, smaller slaughterh ouses and cutting 
plants that source generally animals locally would be not obliged to adjust 
considerably their sourcing practices and this would not entail high additional costs. 
Therefore, the bulk of the burden would concern dairies/abattoirs operating  in border 
regions and those located in areas non self -sufficient on raw milk/meat.  
 
10 
 The study estimated that the burden would not change from the present situation with 
origin labelling remaining voluntary, and it is  expected to increase only modestly 
should the indication of the Member State become compulsory for drinking milk.   
In contrast, the additional burden may be significant if the Member State of origin 
has to be labelled for highly processed and composite products such as yoghourts and 
milk base d desserts. A heavy control burden on food manufacturers would push them 
to source their milk from fewer countries, to the detriment of the single market.  
For the meats under the remit of this report, the consultants in charge of the study  
are of the view  that companies would manage to reduce additional unit costs after the 
necessary adaptation period, especially as regards administrative costs. The impact 
would only be noteworthy for horse meat operators with substantial differences 
between horses reared for meat in specialised farming systems (of limited relevance 
in quantitative terms) and the rest.  
6.2.4.  Burden on public authorities  
Although the study does not provide detailed figures it indicates a low increase in 
control costs in case of a mandatory “EU/non EU” labelling for drinking milk.  
In case of the compulsory labelling of the Member State, costs would be higher and 
depend significantly on the level of detail of the origin information required, i.e. 
place of farming/milking or processing/slaughte ring.  
The “born/raised/slaughtered” model would be costly to implement for horse meat. 
Furthermore, the current traceability and identification system does not always 
provide the competent authority with a comprehensive information as to where the  
horse was raised and born.  
In general, the burden increase results in more staff needed to perform documentary 
checks. If the funding allocated to control authorities by the State budgets is not 
increased, the expected rise in staff time may lead to a reduction  in the frequency of 
controls or a change in priorities, which may also result in an increased risk of fraud. 
The burden on public authorities could be mitigated in case fees are put in place for 
the conduct of official controls. Such costs would normally be transferred down the 
chain by the FBO's through the prices.  
6.2.5.  Costs for consumers  
The status quo is not likely to result in an overall price increase. Where origin is 
provided, additional costs are generally passed onto consumers with products bei ng 
sold at a premium price.  
The provision of mandatory origin information at Member State level expected to 
result in increased costs, which are expected to be passed mainly onto consumers but 
also onto producers. The exact rates vary depending on the sect or, the Member State 
concerned and the degree of vertical integration and market concentration.  
6.2.6.  Environmental and social impacts  
These impacts were not analysed by the study. However, it can be assumed that by 
providing more detailed information on  the origin, consumers would favour "local 
food" or even actively refuse products from other countries. This may have an impact 
on the transport of live animals, raw milk, milk ingredients and dairy/meat products. 
Whether this would turn out to be positive  for the environment (e.g. in terms of a 
reduction of greenhouse gas emissions), is impossible to assert as most intra -EU 
 
11 
 trade occurs between neighbouring countries where distances may actually be shorter 
than within certain Member States. Scenarios other  than voluntary labelling can 
result in a slight increase in product waste.  
Any option making the indication of the Member State in the label compulsory might 
also foster a purchasing behaviour increasingly oriented towards local produce and 
possible shift s in consumption, the elimination of intermediaries, sourcing and 
processing. This may even include knock -on effects on employment if price 
increases result in a certain contraction of consumption.  
6.3. Advantages and disadvantages of mandatory origin lab elling modalities for 
milk, milk used as an ingredient in dairy products and other types of meat  
The following tables provide a summary of the advantages and disadvantages of 
possible mandatory origin labelling modalities:  
– for milk and milk used as an ingr edient:  
Mandatory Origin modality  Advantages  Disadvantages  
Milk  Place of first 
processing   Low costs (< 1%).   No information on 
the origin of raw milk.  
Place of milking   Low costs (<1%);  
 Meaningful 
information to 
consumer at 
Member 
State/country level.   Additional traceability 
systems required 
from factories 
sourcing milk from 
several origins;  
 Technically 
challenging if multiple 
origins involved;  
 Cross border trade 
impacted;  
 Need to establish a 
minimum tolerance 
for multiple sourcing.  
Milk used as an 
ingredient in 
dairy products  Place of the first 
processing of the raw 
milk   Low costs (<1%) if 
EU/non -EU chosen, 
except for highly 
processed products.  
  No information on 
the origin of milk;  
 Additional traceability 
systems required 
from factories 
sourcing mi lk from 
several origins;  
 Technically 
challenging where 
multiple origins are 
involved;  
 Trade flows 
impacted;  
 Need to establish a 
minimum tolerance 
for multiple sourcing;  
 High costs if 
multicountry origin 
chosen (up to 8% at 
MS' level and up to 
 
12 
 45% at indivi dual 
factory level).  
 
Place of milking  Meaningful 
information to 
consumer at 
Member 
State/country level.   Additional traceability 
systems required 
from factories 
sourcing milk from 
several origins;  
 Particularly 
challenging where 
multiple origins 
involved;  
 Trade flows 
impacted;  
 Need to establish a 
minimum tolerance 
for multiple sourcing;  
 High costs if 
multicountry origin 
chosen (up to 8% at 
MS' level and up to 
45% at individual 
factory level).  
 
– for the types of meats under the remit of the study:  
Mandatory Origin Modality  Advantages  Disadvantages  
Horse meat  Place of birth + place 
of rearing + place of 
slaughtering   Provides meaningful 
information to the 
consumer at 
MS/country level;  
 Reassure consumer 
confidence.   Additional traceability 
systems;  
 Challenging with birth 
information if the 
rules on the 
identification are not 
correctly monitored;  
 Challenging when 
several rearing places 
are involved;  
 Limited application 
due to low rate of 
pre-packed horse 
meat.  
Place of minimum 
rearing prior to 
slaughter + place of 
slaughtering   Put more emphasis 
on the last stages of 
the life of the 
animal.   Additional traceability 
systems;  
 Need to establish a 
minimum rearing 
period during the 
lifetime of the animal;  
 Limited app lication 
due to low existence 
of prepacked meat.  
Rabbit meat +  Place of birth + place 
of rearing + place of  Provides meaningful 
information to the  Birth place:  Not 
important for short 
 
13 
 Farmed game and 
birds meats  
 slaughtering  consumer at 
Member 
State/country level.  production cycles;  
 It would require 
additional 
identification system;  
 Additional traceability 
systems;  
 Trade flows can be 
affected.  
Place of minimum 
rearing prior to 
slaughter + place of 
slaughtering   Put more emphasis 
on the growing and 
final killing places of 
the animal;  
 Provides meaningful 
information to the 
consumer at 
Member 
State/country level.   Additional traceability 
systems;  
 Need to establish a 
minimum rearing 
period during short 
cycle life;   
 Trade flow s can be 
affected.  
Wild game and 
bird meats  Place of hunting   
 Provides meaningful 
information to the 
consumer at 
Member 
State/country level.   Additional traceability 
systems;  
 Trade flows can be 
affected;  
 Limited application 
due to low existence 
of prepacked meats.  
7. CONCLUSIONS  
Currently for the foods under the remit of this report consumers may, if they so wish, 
opt for milk or meat products where origin information is voluntarily provided for by 
food business operators. This can be a suitable option without imposing additional 
burden on the industry and the authorities.  
Mandatory origin labelling would entail higher regulatory burden for most of the 
products assessed in the report and therefore, the question at stake is to assess 
whether the balance between costs and benefits i s such that it would justify its 
mandatory indication.  
Additional findings that emerge from this report are that:  
– In spite of a consumers' interest for the origin of milk, milk used as an 
ingredient in dairy products and for meats under the remit of this report, 
consumers' overall willingness to pay for this information appears to be 
modest.  
– When mandatory origin labelling scenarios are considered, consumers seem to 
express preference for this indication to be made at Member State's level.  
– Although the co st of labelling the origin of milk could be generally modest, its 
impact among operators will be uneven with some of them having to introduce 
additional traceability systems with substantial increases of costs, particularly 
those located in border regions or in areas non -self-sufficient in milk.  
– The study shows that the mandatory origin labelling of milk used as an 
ingredient in dairy products can result in adverse economic impacts, further 
 
14 
 traceability requirements and would be burdensome for highly proces sed 
products.  
– There will be additional operational costs to impose mandatory origin labelling 
for the meats under the remit of this report.