Report from the Commission to the Council and the European Parliament on the implementation of Articles 105 et seq of Council Regulation (EC) No 1234/2007 on measures improving the general conditions for the production and marketing of apiculture products SEC(2010)655
Date: 2010-05-28
Institutions: European Commission
Subjects: apiculture, common organisation of markets, marketing, production improvement

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EUROPEAN COMMISSION 

Brussels, 28.5.2010 
COM(2010)267 final 

REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN 
PARLIAMENT 

on the implementation of Articles 105 et seq of Council Regulation (EC) No 1234/2007 
on measures improving the general conditions for the production and marketing of 
apiculture products 

SEC(2010)655 

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TABLE OF CONTENTS 

REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN 
PARLIAMENT on the implementation of Articles 105 et seq of Council Regulation (EC) No 
1234/2007 on measures improving the general conditions for the production and marketing of 
apiculture products ..................................................................................................................... 1 

1. 

2. 

2.1 

2.2. 

2.3. 

2.4. 

3. 

4. 

5. 

INTRODUCTION........................................................................................................ 3 

IMPLEMENTATION OF HONEY PROGRAMMES................................................ 3 

Census (Table 9) .......................................................................................................... 3 

Allocation of expenditure............................................................................................. 4 

Usage rate..................................................................................................................... 6 

Objectives..................................................................................................................... 6 

SUGGESTIONS BY MEMBER STATES.................................................................. 7 

SUGGESTIONS MADE BY THOSE WORKING IN THE SECTOR..................... 10 

CONCLUSION .......................................................................................................... 10 

This  report  is  accompanied  by  a  Commission  staff  working  paper  containing  the  tables  and 
figures mentioned in this report. 

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1. 

INTRODUCTION 

Article 184 of Council Regulation (EC) No 1234/2007 establishing a common organisation of 
agricultural markets and on specific provisions for certain agricultural products1 states that a 
report is to be submitted to the European Parliament and the Council, once every three years, 
on the application of measures to improve the conditions for the production and marketing of 
apiculture  products,  as  provided  for  in  Articles  105  et  seq  of  that  Regulation.  This  report 
meets  that  obligation,  covering  the  marketing  years  2006/07,  2007/08  and  2008/09.  These 
three years correspond to the last year of the previous three-year period (2005-07) and the first 
two years of the current three-year period (2008-2010). 

In  March  2007,  the  Commission  adopted  the  third  report  on  the  implementation  of  Council 
Regulation  (EC)  No 797/20042,  evaluating  the  last  three  years  of  its  implementation.  Given 
that good use was made of these national programmes and in view of the general satisfaction 
of  both  Member  States  and  operators,  that  report  was  not  accompanied  by  any  legislative 
amendments. However, since the last report, simplification measures have been introduced to 
Commission Regulation (EC) No 917/20043 on detailed rules.  

In  keeping  with  the  provisions  of  Community  legislation,  Member  States  have  provided 
notification of their national programmes in respect of the period 2008-10. 

It is important to note that all Member States, without exception, have provided notification of 
an apiculture programme; this is indicative of their interest in this area and the needs of the 
European apiculture sector. 

Situation in the sector 

The commercial context in which these programmes are applied has not changed significantly 
since 2007. The European market is still very dependent on imports (imports account for over 
40%  of  produce  consumed),  albeit  to  a  lesser  extent  than  in  the  past.  The  most  noticeable 
change  on  the  world  market  is  the  significant  increase  in  prices.  These  higher  price  levels, 
especially in Argentina (where production has fallen), which used to be the European Union's 
main supply source, has resulted in an increase in imports from China. 

In additional to commercial factors, the sector continues to suffer from the problem of fewer 
bee colonies. 

2. 

IMPLEMENTATION OF HONEY PROGRAMMES 

2.1 

Census (Table 9) 

In  accordance  with  the  legislation,  Member  States  provided  notification  of  a  study  on  the 
structure of the apicultural sector at the same time as their 2007 programmes. 

1 
2 
3 

OJ L 299, 16.11.2007, p. 1. 
COM(2007) 131 final. 
OJ L 163, 30.4.2004, p. 83. 

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According to figures provided by Member States in 2007, the total number of beekeepers in 
the  EU  was  595 775,  19 025  of  whom  were  considered  to  be  professional  beekeepers  (over 
150 hives). Although the number of beekeepers has increased slightly since 2004, this is due 
to  EU  enlargement  to  include  Bulgaria  and  Romania.  Without  beekeepers  from  these 
countries, the figure would have been considerably less. 

The  total  number  of  hives  is  13 602 719,  of  which  4 461 606  belong  to  professional 
beekeepers (3.2% of beekeepers have around 33% of hives). The number of hives in the EU 
has  increased  by  1 971 419  since  the  2004  census.  This  is  partly  due  to  EU  enlargement  in 
2007,  as  the  number  of  hives  recorded  in  the  two  new  Member  States  was  1 646 736. 
Nevertheless,  the  number  of  hives  in  the  EU-25  group  of  countries  also  increased  between 
2004  and  2007:  according  to  beekeepers,  this  increase  was  necessary  in  order  to  offset  bee 
mortality. 

The  Member  States  with  the  largest  number  of  hives  are  Spain  (17.06%),  Greece  (10.8%), 
France (10%) and Italy (8.5%) (figures 9a and 9b). 

Spain,  with  approximately  130 000  fewer  hives  than  in  2004,  has  seen  its  share  of  the 
Community total population fall significantly (17.1% as opposed to 21.9%). 

2.2. 

Allocation of expenditure 

Budget per Member State 

As  provided  for  in  Article  2  of  Regulation  (EC)  No  917/2004,  Member  States  provide 
notification of their programmes to the Commission before 15 April once ever three years (the 
submission in 2007 relating to the programmes for 2008, 2009 and 2010). 

On the basis of Member States’ expenditure forecasts, Commission budget funds available are 
distributed with reference to each Member State’s share in the total number of beehives in the 
Community, as shown in Annex I to Regulation (EC) No 917/2004. The hives belonging to 
each  Member  State,  calculated  as  a  percentage  of  the  total  number  of  hives,  determine  the 
theoretical maximum percentage of the budget to which each Member State is entitled, before 
any allocation of amounts not requested. 

The percentage of each Member State set out in figure 9b therefore represents its theoretical 
share of the budget. However, figure 9d indicates that the actual distribution of the budget for 
2008 differs slightly from the share in the population. This can be explained by the fact that 
some Member States have not claimed all of their theoretical shares. In accordance with the 
legislation,  the  balance  is  distributed  between  Member  States  claiming  more  than  their 
theoretical share. For example, Spain received a share of the budget equivalent to 18% of the 
total, although it only accounted for 17.1% of the hives. 

In 2008, seven Member States claimed less than their theoretical budget. 

In  2008,  three  Member  States  (Spain,  Greece  and France) used nearly 40% of  the available 
budget. The Member States with the largest number of hives are therefore those which ask to 
use these programmes to a larger extent.  

It  should  be  noted  that  the  impact  of  EU  enlargement  to  include  Bulgaria  and  Romania,  in 
terms of diluting the share enjoyed by ‘older’ Member States, has been offset by an increase 

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in the annual budget, from EUR 23 million to EUR 26.3 million. The reduction in the budget 
applicable for some Member States is purely due to a reduction in the number of hives. 

Expenses incurred per type of action and per Member State (table 10) 

The  analysis  of  expenses  incurred  is  based  on  the  figures  provided  by  Member  States  each 
year under Article 6(2) of Regulation (EC) No 917/2004. This obligation has been introduced 
since the last report, in order to enable the Commission to analyse the way in which Member 
States  actually  spend  their  budget.  This  is  because  the  way  in  which  expenses  are  actually 
incurred  can  differ  from  forecast  figures,  on  the  basis  that  greater  flexibility  for  amending 
programmes has been introduced by the Commission regulation. 

With regard to the period 2007-09, the two most common measures continue to be varroasis 
prevention  and  technical  assistance  (figures  10a  and  10b).  Even  though  technical  assistance 
expenditure continues to be relatively stable, accounting each year for approximately 26-27% 
of the budget used, a sharp reduction in the share of the budget used for varroasis prevention 
has been seen (this fell from 37% in 2007 to 27% in 2009). 

Technical assistance measures were used by the vast majority of Member States (figures 10a 
and  11a),  with  Italy  being  the  main  user  of  this  measure  in  terms  of  budget,  with  over 
EUR 900 000 per year. The other main users of this measure were Greece, France, Germany 
and the Czech Republic. It can be noted that the new Member States (Bulgaria and Romania) 
did not use this measure at all, preferring to focus their programme on other measures. 

Varroasis  prevention  measures  were  also  used  by  all  Member  States,  with  the  exception  of 
Slovenia  (figures  10a  and  11b);  the  Member  States  making  most  use  of  this  measure  were 
Spain, Hungary and Poland. After having been a major user of varroasis prevention measures 
in  2007,  Portugal  saw  a  significant  reduction  in  its  budget  allocated  to  this  measure.  By 
contrast,  Slovenia  had  made  very  little  use  of  this  measure  in  2007  and  2008  but  saw  its 
budgetary allocation to this kind of measure rise significantly in 2009. 

Measures designed to ensure rationalisation of transhumance continued to be the third most 
common  measure,  accounting  for  18%  of  expenditure  (figures  10a  and  11c).  Southern 
European  countries,  with  diversified  vegetation  and  a  long  period  of  cultivation  are 
traditionally  those  which  had  made  most  use  of  this  measure.  Greece  had  chosen  to  clearly 
redirect  aid  towards  this  measure,  in  particular  from  2008  and  2009  (more  than  half  of  its 
budget). By contrast, Spain, Italy and Hungary reduced investment in this measure from 2008 
onwards. 

Hive  restocking  measures  come  in  fourth  place.  Use  of  this  measure  is  rising,  and  a  large 
increase was noted between 2007 and 2009 (from 10% of expenditure to 15%) (figures 10a 
and  11e).  Since  being  introduced  in  2005,  expenditure  for  this  measure  has  increased  from 
6.2%  to  15%.  An  explanation  for  this  is  the  disappearance  of  colonies,  which  has  become 
more acute in recent years. Beekeeping organisations, which work together in order to prepare 
programmes,  are  very  interested  in  these  measures  to  offset  this  loss  of  colonies.  These 
measures are most often used by Poland and Romania; however, Poland has seen a sharp fall 
in allocation for this measure from 2009 onwards. 

Measures in favour of honey analysis and applied research are used less than in the past, and 
now only account for 6-7% in 2009 (figures 10a, 11d and 11f). 

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France  allocates 
to  applied  research,  allocating  approximately 
EUR 900 000  in  2009,  which  represents  more  than  half  of  the  total  sum  allocated  to  this 
measure at Community level. 

largest  budget 

the 

Spain  is  the  country  which  sets  aside  the  largest  amounts  to  honey  analysis  (a  very  large 
increase  between  2007  and  2009).  Other  Member  States,  with  the  exception  of  Austria, 
allocate very small amounts to this area. 

2.3. 

Usage rate 

The comments on the degree of use are based on figures communicated by the Member States 
on the implementation of the budget per type of measure, figures which have also been used 
with  reference  to  the  making  of  payments  (table  10).  These  figures  sometimes  differ  from 
EAGF data (tables 12a, b and c). 

In 2007, the average usage rate was 90%. This very good usage rate can be explained by the 
fact that it was the third time for the EU-25 countries and the 10 Member States which joined 
the  EU  in  2004  had  acquired  the  necessary  experience.  The  usage  rate  for  most  Member 
States  was  between  90%  and  100%.  The  Member  States  with  the  lowest  usage  rate  were 
Cyprus  (38%)  and  Luxembourg  (56%).  Portugal,  Slovenia  and  Slovakia  also  had  relatively 
low usage rates (between 69 and 76%). 

Although  usage  rates  fell  significantly  in  2008,  from  90%  to  80%,  this  reduction  can  be 
clearly explained by under-use in Bulgaria and Romania, for which this was the first year of 
experience. As in 2005 for the 10 new Member States, lack of experience was reflected in low 
usage rates (only 34% in Bulgaria and 17% in Romania). Portugal also had a very low usage 
rate (36%). As in previous years, the greatest beneficiaries were very effective in their use of 
budgets,  with  the  exception  of  France,  where  only  74%  of  budget  was  used.  Cyprus  and 
Luxembourg, whose usage rate in 2007 was very low, reversed this trend, using their budgets 
very effectively. 

Since  2009,  we  have  been  pleased  to  notice  a  significant  increase  in  the  use  of  the  budget 
(88%). Bulgaria and Romania have significantly improved usage rates, even if Romania’s rate 
(54%) was well below the Community average. Of the major beneficiaries of the Community 
budget,  France  significantly  improved  its  performance  compared  to  2008.  By  contrast, 
Poland, after two years of very high usage rates, only used 74% of its budget. Despite making 
progress, Portugal’s rate remained very low (58%) and Luxembourg's rate was once again low 
(60%). 

2.4. 

Objectives 

All measures proposed by the Member States are eligible, provided that they are undertaken 
solely to achieve the objectives of one of the priority measures. 

Specific objectives for eligible measures 

Since  the  last  report,  the  objectives  of  measures  eligible  for  Community  support  have  not 
changed. 

Technical  assistance  is  designed  to  enhance  the  efficiency  of  production  and  marketing  by 
introducing  better  techniques.  Courses  and  other  training  measures  for  beekeepers  and  those 

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responsible  for  groupings  or  cooperatives  relate  in  particular  to  such  areas  as  breeding  and 
disease prevention, collection and packaging, storage and transport of honey and marketing. 

The aim of varroasis prevention is to reduce expenditure incurred in treating hives or to ensure 
that part of the cost is met. This disease is caused by a parasite and at the present time is severely 
diminishing  the  honey  yield  in  the  EU,  leading  to  the  loss  of  bee  colonies  if  not  treated.  As 
varroasis  cannot  be  completely  eradicated,  the  only  way  to  avoid  its  consequences  is  to  treat 
hives  with  approved  products  (those  that  do  not  leave  any  residue  in  the  honey).  A  financial 
contribution  was  also  considered  necessary  to  ensure  that  beekeepers  do  not  treat  hives  with 
unauthorised chemicals or ineffective remedies. 

Aid for the rationalisation of transhumance is intended to assist with managing the movement 
of  hives  in  the  Community  and  with  providing  locations  for  the  strong  concentration  of 
beekeepers during the flowering season. Transhumance management can be facilitated by such 
measures as a transhumance register, investment in equipment and maps of honey varieties. 

Support measures for carrying out analyses of honey are intended to improve the marketing of 
honey.  Financing  of  analyses  of  the  physico-chemical  properties  of  honey  according  to  its 
botanical  origin  provides  beekeepers  with  precise  knowledge  of  the  quality  of  the  honey 
harvested, and enables them to get a higher price for their product. 

The  restocking  of  hives  makes  it  possible  to  compensate  for  losses  of  bees,  and  therefore  of 
production, by funding activities to promote queen production or purchasing of bee colonies. 

The opportunity provided by the Regulation for including specific applied research projects for 
improving  honey  quality  in  the  honey  programmes,  and  dissemination  of  the  results  of  such 
projects, can help to increase producer incomes in particular regions. 

3. 

SUGGESTIONS BY MEMBER STATES 

Overall, Member States are very satisfied with the way in which the programmes are run and 
there have been no persistent requests to amend Regulation (EC) No 1234/2007. Very often 
there are calls for measures to ensure that these programmes can continue. 

Since  the  last  report,  the  Commission  has  amended  the  implementing  rules  in  order  to 
simplify  the  implementation  of  programmes  by  giving  Member  States  greater  flexibility, 
especially with regard to modifying programmes which have already begun. The Commission 
removed  the  rule  of  20%,  which  involved  the  opinion  of  the  management  committee  being 
required  if  this  percentage  was  exceeded,  in  order  to  enable  funds  initially  allocated  to  one 
particular  measure  being  used  for  other  measures.  From  now  on,  provided  that  funds  have 
been  reallocated  to  measures  initially  provided  for  in  national  programmes,  Member  States 
are free to effect this reallocation without having to comply with a specific procedure. In the 
case of new measures not initially notified to the Commission, the Commission’s opinion is 
still  required.  In  exchange,  the  Commission  has  made  it  compulsory  for  Member  States  to 
provide notification, at the end of each year, in order to know exactly which type of measure 
the  funds  have  been  used  for.  This  means  programmes  can  be  assessed  more  effectively. 
Member  States  have  indicated  that  they  are  very  satisfied  with  this  simplification  and 
increased flexibility. 

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However,  the  Commission  has  received  a  number  of  requests  from  Member  States  in 
anticipation of the drafting of this report; the requests set out below were already made during 
the previous report: 

– 

– 

– 

– 

some Member States asked for measures to support laboratories conducting analyses 
of  the  physico-chemical  properties  of  honey  to  be  extended  to  other  apiculture 
products. 

The  Commission’s  response  was  the  same  as  that  given  in  2004:  in  view  of  the 
limited budget, this is not a priority, particularly considering the volumes sold. The 
cost of these analyses can be borne more easily by high added-value products than by 
honey. There is no major reason to amend the regulation in this respect. 

prevention  of  bee  diseases  other  than  varroasis;  it  must  be  clear  that  it  is  not  the 
objective of this scheme to create a health policy in the sector. The 2004 amendment 
made diseases related to varroasis ineligible for apiculture programmes precisely in 
order to avoid any confusion with veterinary policy. 

improvement of the statistical instrument: in order to benefit from the cofinancing of 
their  programmes,  the  Member  States  must  already  provide  notification  of  a 
structural study of the sector. It would be administratively cumbersome for Member 
States to forward an annual review of the statistics, and this would not be desirable. 
The  Commission  regularly  notifies  operators,  during  a  series  of  committees,  of  the 
statistics at its disposal regarding imports and exports; 

making it possible to carry out projects of a European nature across several Member 
States.  The  Commission  recognises  the  benefit  of  such  projects  and  points  out  that 
they  may  also  be  approved,  as  there  is  nothing  to  prevent  several  Member  States 
collaborating  on  a  single  project.  Each  Member  State  participating  in  the  project 
should  contribute  from  the  budget  which  it  has  been  allocated  individually. 
Reallocating  unrequested  funds  to  these  specific  projects  would  run  contrary  to 
administrative simplification, something which is sought by most Member States and 
the Commission. 

Other suggestions which have been made: 

– 

– 

– 

– 

The  repair  or  rehabilitation  of  demonstration  hives  could  be  covered  by  financing. 
This is already possible through technical assistance or through  restocking of  hives 
measures. 

Certain  measures  could  concern  new  products  (marketing,  processing,  etc.):  this  is 
already possible under technical assistance. There is no reason why the financing of a 
group of producers wishing to place new products or new types of packaging on the 
market  should  be  prevented.  In  addition  to  improving  production,  programmes  are 
also aimed at improving marketing. 

The ability to recover amounts which have not been used by certain Member States 
by  others,  or  to  extend  payment  deadlines.  The  annual  nature  of  the  budget  makes 
this difficult to implement, since the usage rate is only known after the event. 

Informing  beekeepers  more  effectively  on  the  results  of  applied  research.  The 
Commission shares this objective but it is difficult to provide a legal framework for 

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– 

– 

– 

– 

it.  It  should  be  noted  that  beekeeping  organisations  are  involved  in  preparing 
programmes  in  each  Member  State  and  they  are  therefore  able  to  ask  for  this 
information and possibly can share with their European organisations. 

Some  Member  States  have  also  criticised  the  fact  that  is  difficult  to  prepare 
programmes  without  knowing  in  advance  the  budget  that  they  will  have  available. 
The Commission understands this argument and will examine whether or not there is 
a way of rectifying it. Given that the budget is distributed depending on the number 
of hives in each Member State, and since the census is notified at the same time as 
programmes, it is not currently possible to inform Member States of the budget that 
they will have available. In order to avoid this, there could be a need to bring forward 
the  publication  of  the  structural  study  on  Member  States  and  the  draft  national 
programme. 

One Member State also criticised the fact that measures eligible for cofinancing must 
have  been  completed  by  31  August  of  the  year  in  question,  and  it  is  therefore 
difficult  to  finance  an  action  during  the  month  of  September.  This  is  because 
payments relating to measures must be made prior to the end of the year in question. 

Some  countries  dispute  the  fact  that  a  measure  cannot  be  the  subject  of  payment, 
under  these  programmes  and  also  under  another  Community  aid  scheme,  although 
they do not dispute the ban on double payments, but feel that two programmes can 
complement  each  other.  The  Commission  therefore  has  no  other  choice  than  to  be 
very  careful  in  order  to  avoid  any  cofinancing  and  therefore  is  not  considering 
removing this limit. 

Others would like to see a more specific description of aid for investments which can 
be accepted. This would run contrary to ensuring flexibility and more straightforward 
implementation  in  recent  years.  It  is  not  possible  to  make  an  exhaustive  list  of 
eligible measures; in principle, the Commission has always indicated its flexibility in 
so far as it can be demonstrated that the equipment in question was only to be used 
for meeting the objectives of the various measures eligible for cofinancing. 

Finally, some Member States are calling for the Commission to make certain changes to the 
Regulation containing implementing measures, particularly in order to include definitions of 
other hive products. Now that these products are listed in an exhaustive manner in the single 
CMO, the Commission will be considering this issue. 

It  has  also  been  requested  that  Commission  activities  (not  necessarily  only  those  of  DG 
AGRI) to support the sector should be publicised to a much greater extent. The Commission 
is currently working on this issue, particularly since the November 2008 European Parliament 
Resolution.  In  order  to  ensure  that  the  efforts  taken  by  the  various  DGs  can  be  coordinated 
more  effectively  and  in  order  to  tackle  the  problem  of  bee  mortality,  an  inter-service  group 
has  been  set  up.  This  group’s  activities  include,  in  particular,  publicising  the  work  of  the 
Commission, which is often not very well known. 

Finally, a range of more  specific  measures were mentioned but do not  justify  amending the 
Regulation. The eligibility of any specific measure would be assessed when the programmes 
are analysed and before they are accepted. 

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4. 

SUGGESTIONS MADE BY THOSE WORKING IN THE SECTOR 

The sector’s comments can be summarised as follows. 

Only  producers,  and  in  particular  COPA-COGECA,  have  sent  certain  comments  to  the 
Commission.  Firstly,  they  stressed  the  importance  of  these  programmes,  the  positive  effect 
that they have had on the sector and ask that the programmes continue in the long term. 

In addition to these general remarks, a number of improvements have been proposed, many of 
which have already been relayed by Member States: 

– 

– 

– 

– 

– 

– 

– 

Better  collaboration  between  Member  States  and  beekeeping  organisations  at  the 
time of preparing programmes. The  organisations  regret,  in particular,  that  in some 
cases the lack of collaboration has resulted in the budget not always being used in the 
most  appropriate  manner.  The  Commission  recognises  the  essential  role  that 
professional  organisations  must  play  in  preparing  these  programmes,  and  reiterates 
that  Member  States  are  even  obliged  to  respect  this  dialogue,  with  the  aim  of 
targeting eligible actions as effectively as possible. 

Technical assistance measures should not be used to promote research activity. 

The introduction of a technical assistance sub-measure to finance the implementation 
of  a  European  platform  for  beekeeping,  in  order  to  encourage  synergy.  The 
Commission encourages dialogue between beekeepers from various Member States, 
but does not feel it necessary to set up a platform of this kind, since this would go 
against  the  very  principle  of  cofinancing  and  simplification.  Technical  assistance 
measures  in  each  Member  State  may  however  include  measures  promoting  such 
intra-Community cooperation. 

More  effective  distribution  of  the  results  of  applied  research  (see  comments  from 
Member States). 

Introduction  of  a  definition  of  other  beekeeping  products  (see  comments  from 
Member States). 

The increase in the budget and the share of Community financing. 

Finally, it is requested that Annex II to the relevant Regulation be amended in order 
to include statistics on bee mortality.  

5. 

CONCLUSION 

As was also the case in 2007, the mechanism for setting up national programmes in order to 
improve  production  and  marketing  in  the  European  Union  has  been  very  beneficial  for  the 
beekeeping  sector,  both  from  the  point  of  view  of  the  Member  States  and  beekeepers 
themselves. 

The priority measures in Regulation (EC) No 797/2004, although being limited from a budget 
point of view, have been valuable in terms of quality for the beekeeping sector. 

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The  simplification  measures  introduced  by  the  Commission  in  2007  have  enabled  Member 
States  to  easily  adapt  currently  existing  programmes  in  order  to  respond  appropriately  to 
difficulties that were not envisaged or which were underestimated when the programmes were 
notified. 

Given the information presented in this report, and in order to avoid a further amendment to 
the Regulation, which would require a period of adaptation on the part of Member States, and 
would risk a less effective usage rate in the short term, the Commission considers that it is not 
appropriate to amend Council Regulation (EC) No 1234/2007. However, it will assess in due 
course whether a positive answer to the requests by Member States and operators vis-à-vis the 
implementing rules is possible. 

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