Opinion of the European Economic and Social Committee on the "Proposal for a Council Regulation on the common organisation of the market in dried fodder for the marketing years 2004/2005 to 2007/2008" (COM(2003) 23 final — 2003/0010 (CNS))
Date: 2003-05-14
Institutions: European Economic and Social Committee
Subjects: aid to agriculture, common agricultural policy, common organisation of markets, fodder

3.9.2003

EN

Official Journal of the European Union

C 208/41

Opinion of the European Economic and Social Committee on the ‘Proposal for a Council
Regulation on the common organisation of the market in dried fodder for the marketing years
2004/2005 to 2007/2008’

(COM(2003) 23 final — 2003/0010 (CNS))

(2003/C 208/11)

On 10 February 2003 the Council decided to consult the European Economic and Social Committee,
under Article 37 of the Treaty establishing the European Community, on the above-mentioned proposal.

The Section for Agriculture, Rural Development and the Environment was responsible for preparing the
Committee’s work on the subject on 25 April 2003. The rapporteur was Mr Wilms.

At its 399th plenary session on 14 and 15 May 2003 (meeting of 14 May), the European Economic and
Social Committee adopted the following opinion by 102 votes, with 18 abstentions.

1. Summary of the Commission proposal

1.1.
The Commission proposal provides for the complete
phasing out of support for dried fodder production and the
budget for the COM in dried fodder over the four-year period
from 2004. The Commission proposes an initial budget cut of
55 % rising to 100 % in 2009, together with the inclusion of
dried fodder in the single payment system, entailing the
abolition of support measures for the sector. Aid to the
industry would be progressively reduced from EUR 33/t in the
2004/2005 marketing year to EUR 0/t in 2007/2008, and
would be granted without distinction between artificially and
naturally dried product. Half of the present budget would be
divided between farmers as part of the new single farm
payment.

2. General comments

The EESC welcomes the fact that the Commission is
2.1.
addressing the common organisation of the market in dried
fodder: ‘since the last two Common Agricultural Policy (CAP)
reforms and the World Trade Organisation (WTO) agreements,
the European Union’s degree of self-sufficiency in plant
proteins has again fallen, last year [2001] sinking to below
25 %. This constantly deteriorating situation does raise the
question of Europe’s dependence on imports, entailing risks
for European livestock farmers’ supplies of plant proteins’ (1).

2.2.
In its opinion of January 2002, the EESC referred to
the importance of plant proteins in animal feed and noted
that a gap had opened up between the European Union’s
requirements in plant proteins and its production potential (1).

In its work on plant proteins, the Committee also emphasised
that despite the foreseeable increase in demand within the EU,
acreage is currently falling and therefore dependence on
imports is increasing (1).

Current regulations for dried fodder aid (2) under the
2.3.
COM for producer countries, together with a series of favour-
able weather and soil conditions, have enabled an economy
based on alfalfa to develop, whose main players (farmers and
industries) are located in rural areas and which provides more
than 15 000 jobs across the EU. It also enables a high-quality
vegetable protein to be obtained, helping to offset the EU’s
huge shortfall in such substances. The climate in some areas
of southern Europe has made possible major energy savings
per unit of product due to the relatively low humidity levels of
field fodder following harvesting, thanks to techniques such as
pre-drying. These savings are additional to those produced by
alfalfa as a permanent crop requiring little tillage or nitrogen-
based fertilisers. It is important to point out that thanks to
countries such as Spain, the Community’s maximum guaran-
teed area has been covered, ensuring continuity. That said,
suitable reforms should be undertaken in order to harness the
potential energy savings brought about by natural conditions
in southern Europe, without thereby having to jeopardise the
beneficial effects of this type of farming.

2.4.
In order to harness the EU’s full production potential
and make best use of the budget earmarked for the sector, the
policy of joint responsibility in calculating excess of maximum
guaranteed quantities should continue. Member States which

( 1) EESC opinion on New impetus for a plan for plant protein crops

(2) 38,64 EUR/t for sun-dried fodder; 68,83 EUR/t for dehydrated

in the Community, OJ C 80, 3.4.2002, pp. 26-34.

fodder.

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exceed their individual national quantities should only be
penalised when the Community’s overall maximum guaranteed
quantity is exceeded.

3.3.

Ecological consequences

3. Possible consequences of changes to the organisation

of the dried fodder market

3.1.

Energy consumption in production

From an ecological standpoint, reducing the two aid
3.1.1.
rates based on the drying process to a single rate is clearly a
positive measure. When fodder is machine-dried, 40 % of total
production costs are heat energy costs. Only 8 % of drying
plants in the EU use sustainable fuels, while 92 % are powered
by fossil fuels. Our health is affected by classic smog symptoms
due to the emission of air pollutants, although this effect is
mitigated in rural areas by the lower concentration of pol-
lutants. Moreover, these emissions contribute to the green-
house effect, which causes climate change. Fodder processing
aid should therefore be refocused in order to boost energy
savings and promote the replacement of fossil fuels with
renewable energy sources, as is already occurring to a signifi-
cant extent with artificial evaporation. The odour emissions
given off by fodder dehydration also cause problems. More-
over, in some Member States the use of irrigation in dried
fodder production is both ecologically and economically
problematic.

3.2.

Employment consequences

3.2.1.
Throughout Europe, approximately 15 000 people
are employed full-time in drying plants and related upstream
and downstream industries. The number employed in the
actual drying plants must
therefore be lower. Processors
usually sign contracts with producers, thereby providing a
guarantee for both production and processing.

3.2.2.
European dried fodder producers fear that the 350
or so production plants will have to cease their operations if
they no longer receive enough raw materials under the new
In future it will principally be the contract
regulations.
negotiations which determine whether processing plants are
able to operate at full capacity and thus pay a competitive
price for raw materials. Entrepreneurs need to be supported in
developing the skills required to adapt
their business to
changing conditions (1).

3.3.1.
Farmers must be able to earn a reasonable income
from the cultivation of plants for dried fodder production.
This is the only way to safeguard the positive ecological effects
of fodder crop cultivation. Year round crop cover prevents soil
erosion, and in many regions of Europe means that farming
can continue in disadvantaged areas on market terms, which
strengthens the social situation of small farms. In its opinion
on plant proteins the Committee clearly indicated that culti-
vation of fodder plants was of great importance for protecting
soil structure and for the sustainable development of farm-
ing (2). The cultivation of fodder plants plays an important role
in environmental protection and the balance of activities in
rural areas (2). It must continue to fulfil these functions in the
future.

3.4. The world market

3.4.1.
The world market will remain available for trade in
plant protein crops. The Committee has previously explained
that the objective need not be to cover total demand by
production within the Community (2). It should be pointed out
that imported soya beans account for some 70 % of the plant
protein crops used for animal
feed in the EU. However,
Community production should be the mainstay of dried fodder
production; as things stand at present, however, this can be
achieved only if a system of financial aid is provided. There are
more questions marks over high ratios of imported dried
fodder and the presence of genetically modified organisms
than, for instance, locally produced dried fodder.

4. Dried fodder production in the Community: towards

sustainable production

4.1.
In the financial year 2001/2002, 4 800 000 tonnes of
dried fodder were produced (3); the entire fodder sector in the
EU produced 200 000 000 tonnes. Production quantities in
individual States vary greatly according to climate (4).

( 1) Green Paper Entrepreneurship in Europe, COM(2003) 27 final,

réforme de la PAC, S. 13.

p. 23.

(4) MGQ Austria: 4 000 t; MGQ France: 1,6 t.

(2) EESC opinion on New impetus for a plan for plant protein crops

in the Community, OJ C 80, 3.4.2002, pp. 26-34.

(3) CIDE, Dossier d’information, Les enjeux de la luzerne face à la

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4.2.
Artificial drying of green fodder in particular has been
criticised in the past (1). The EU should oblige the Member
States to introduce official animal feed checks which would
improve the effectiveness of the control measures and allow
stricter implementing measures. Assistance and cooperation
between administrations should be made compulsory.
In
addition,
financing arrangements must be introduced for
measures to improve animal fodder safety, with the frequency
of the checks being determined by the risk. The level of risk
involved in dried fodder production is high due to the
numerous abuses possible in the thermal process. After all,
animal feed safety is synonymous with food safety.

5.3.
Farms can only safeguard production if drying plants
guarantee to take what they produce. This is the only way
European farming can make sustainable use of the important
ecological effects of plant protein cultivation.

5.4.
In order to receive further aid, processors must review
the energy efficiency of their facilities and install energy saving
technology; reduced energy costs should create competitive
plants. The consequences this will have on the environment
and on employment are clear.

In future, the Community should only support pro-
4.3.
duction methods that are committed to social, economic
and ecologic sustainability. Dried fodder producers should
therefore review the energy efficiency and safety of their
facilities.

5.5.
The installation of environmentally-friendly heating
and processing technology in drying plants will create and
maintain jobs, both directly and in related sectors. In this
respect the processors should be reminded of their social
responsibility, which is particularly relevant when they are
making their own economic decisions.

4.4.
In the last 20 years, producers of machine-dried fodder
have been able to reduce their energy input by 50 % (2). This
process must continue in order to guarantee sustainable dried
fodder production.

5.6.
The EU should make Member States’ approval for
drying plants’ applications for aid dependent upon, amongst
other things, job security and ecological criteria.

5. Measures to implement sustainable dried fodder pro-

duction: EESC demands

5.1.
The current cost structure of drying plants depends on
substantial Community support for production (see point 1).
The Committee welcomes the new balance in the aid proposed
for the sector as it accommodates both producers and
processors.

5.2.
Production plants for machine-dried fodder must be
able to maintain production. Similarly, Community plant
protein crop cultivation must be safeguarded. This will ensure
the relative independence of European farming from world
market production.

5.7.
The EESC suggests the establishment of an aid regime
for drying plants that rewards low energy consumption. This
means that processors would only be eligible for aid when
energy use in production is as low as technically possible.
The Committee therefore urges the Commission to grant
enterprises a transition phase, within which they can modify
their technology. Processors could use their innovative poten-
tial to cut the use of fossil fuels. Such a transition phase could
be based on the initially planned phase of degressive aid until
2008. Enterprises are, however, only likely to consider making
such modifications if they can assume that an aid system
geared to promoting environmentally sustainable practices
will continue to exist for a relatively long period of time. If the
aid system lasts only four years, most enterprises will cease
production, rather than modify their production.

Older plants that operate on high energy input should
5.8.
no longer receive aid after the transition phase. There should
be no aid for environmentally damaging technologies after the
transition phase.

( 1) In Germany (Bundesland Thüringen) a drying plant produced and
sold 250 t fodder contaminated with dioxins. This was due to a
technical fault and came to light during official fodder checks —
see report by the Ministry for Consumer Protection, Food and
Agriculture dated 19.2.2003.

( 2) CIDE, Dossier d’information, Les enjeux de la luzerne face à la

réforme de la PAC, S. 13.

5.9.
The aid regime should particularly benefit those pro-
cessors that forgo the use of fossil fuels in favour of renewable
energy sources. Aid should also take account of mixed energy
usage (e.g. 2/3 natural gas and 1/3 wind power) and reward the
renewable energy portion with a higher processing payment.

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5.10.
In order to support such sustainable methods of dried
fodder production, the planned degressive reduction of support
payments to zero should be replaced by support arrangements
which reward low energy consumption.

5.11.
The recommended regime would not ensure that the
dried fodder sector remains a structural factor in rural areas,
because the possible savings generated by removing aid for
both artificially and naturally dried fodder would not be
enough to offset the loss of income to the industry while
maintaining profitable prices for farmers. The COM reform
provides an opportunity to improve the Community’s supply
of vegetable protein, environmental balance and the balance
between the players in the sector, while establishing a sustaina-
ble legislative framework. This demands an effort on the part
of all concerned, which must be rewarded and encouraged by
Common Agricultural Policy instruments. All those concerned
would be obliged to cooperate to ensure that the EU has a
sustainable supply of plant protein. The recommendation is
not far-reaching enough since it does away with the main
instrument available to the present COM instead of adjusting
it
to the objectives set. However, considering the many
problems of dried fodder production, the tasks and social
objectives it is required to fulfil, it must be shown that tried-
and-tested methods have a viable future and are part of the
future of European agriculture.

Brussels, 14 May 2003.

5.12.
It should be borne in mind that grazing and direct
consumption of fodder by livestock are optimal systems from
the point of view of energy balance, animal welfare and food
security and autonomy. The Committee therefore suggests that
measures be considered to encourage these methods and
safeguard their different forms. The cultivation of grassland,
particularly in association with livestock grazing, should
remain an integral part of sustainable milk and meat pro-
duction. The disadvantage suffered by grassland in previous
aid policies has, in combination with the common market
organisation in dried fodder, contributed to its steady decline.
The Common Agricultural Policy should encourage the econ-
omically and ecologically profitable use of land and prevent
the decline in fodder legumes, by ensuring that full use is made
of the benefits they provide. However, drying of fodder crops
is a traditional system used to preserve one season’s surpluses
for the next, and is ideally suited to the agricultural and
climatic conditions of certain European regions. Artificial
drying now enables maximum use to be made of the agricul-
tural and nutritional advantages of alfalfa as a protein and fibre
input for livestock. Dried fodder production will continue to
livestock rearing
be essential,
involved, insofar as holdings cannot achieve self-sufficiency in
such production. Furthermore the main dried fodder produc-
ing countries are located in southern Europe and could
therefore not develop their milk production on grasslands
(due to climatic restrictions). Due to the different climatic
conditions, a balance is required between dried fodder pro-
duction in northern and southern Europe.

irrespective of

the type of

The President

of the European Economic and Social Committee

Roger BRIESCH