COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT
Date: 2014-01-30
Institutions: European Commission
Subjects: EU financing, EU programme, State aid, drinking milk, early fruit and vegetables, nursery school, nutrition, tropical fruit

EUROPEAN 
COMMISSION 

Brussels, 30.1.2014  
SWD(2014) 29 final 

COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

amending Regulation (EU) No 1308/2013  and Regulation (EU) No 1306/2013 as regards 
the aid scheme for the supply of fruit and vegetables, bananas and milk in the 
educational establishments 

{COM(2014) 32 final} 
{SWD(2014) 28 final} 

EN 

   EN 

 
 
 
 
  
 
 
 
 
COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

amending Regulation (EU) No 1308/2013  and Regulation (EU) No 1306/2013 as regards 
the aid scheme for the supply of fruit and vegetables, bananas and milk in the 
educational establishments 

1. 

INTRODUCTION 

The  School  Milk  Scheme  (SMS)  and  the  School  Fruit  Scheme  (SFS)  aim  to  sustainably 
increase  the  share  of  fruit  and  vegetables  and  milk  products  in  children's  diets  when  their 
eating habits are being formed. They contribute to the CAP objectives and are in line with the 
public health objectives of shaping healthy eating habits. 

The rationale which led to the establishment of the two school schemes is still relevant in the 
current  context  of  declining  consumption1  of  fruit  and  vegetables  and  milk  products, 
exacerbated  amongst  others  by  the  modern  consumption  trends  towards  highly  processed 
foods which are often high in added sugars, salt and fat. 

2. 

PROBLEM DEFINITION 

Conclusions  from  different  reports2  and  experience  after  years  of  implementation  point  to 
certain weaknesses and inefficiencies in the functioning of current schemes: 

(1) 

Both  schemes  are  pursuing  a  sustainable  change  in  children's  eating  habits  through 
their educational dimension. But there is a gap between the set-up of the schemes 
and  this  objective.  The  educational  dimension  was  built  into  the  SFS  from  the 
beginning, while the SMS does not oblige MS to use specific educational tools and 
the  link  between  the  products  distributed  and  the  scheme  is  low.  Furthermore,  the 
evaluation  systems  of  the  schemes  need  improvements  to  be  able  to  measure  their 
effectiveness. 

1 According to Freshfel data, the consumption of fresh F&V is on the declining trend, falling by an aggregate 
9.4% for fruits and 10.3% for vegetables in the period 2005-2010. It decreased by 3% in 2011 compared to the 
average  for  the  previous  period.  According  to  Eurostat  and  DG  AGRI  data,  in  the  period  2003–2011  the 
estimated consumption of drinking milk in the EU decreased by 5% . The overall per capita consumption of milk 
products, expressed in milk equivalent, also decreased by 5% in 10 years from 302 kg to 286 kg in 2011, even 
though for certain dairy products, such as cheeses, the consumption has been stable or has even increased. 
2 Court of Auditor’s Special report No 10 of 2011 ‘Are the School Milk and School Fruit Schemes effective?’, 
the external evaluations of the SFS (2012) and the SMS (2013), conducted by AFC Consulting Group AG and 
Co Concept.  

2 

 
 
 
 
 
                                                 
(2) 

(3) 

There  is  a  lack  of  coordination  and  consistency  between  them  which  could 
negatively  impact  the  effectiveness  of  the  regime  as  a  whole.  This  problem  stems 
from  the  different  legal  and  financial  frameworks,  market  differences  between  the 
products involved and decisions at MS level how to implement the two schemes. 

The  functioning  of  the  schemes  is  characterised  by  other  deficiencies  that  limit 
their immediate impact, which are either common (such as high administrative and 
organisational burden), or specific for the SFS (most notably the under-execution of 
around 30% of its potential and huge disparities in the costs for products involved in 
the distribution) or for the SMS (potential deadweight effect, low cost-benefit ratio). 

3. 

SUBSIDIARITY 

The  EU  right  to  act  in  this  field  is  set  out  in  Articles  38  –  44  of  the  Treaty  which  make 
provisions for the CAP. A number of elements confirm that action at EU level is appropriate 
and provides an added value: 

An  EU  framework  provides  first  of  all  the  funding  necessary  to  implement  valuable 
initiatives across the EU, as most MS would not be in a position to implement such initiatives 
exclusively  with  their  own  resources.  Furthermore,  the  evaluations  conclude  that  the  EU 
framework has led to greater credibility of programmes in MS, visibility of the schemes, as 
well  as  an  improved  image  and  awareness  of  the  EU.  A  lack  of  EU  action  and  the 
continuation of activities exclusively at the MS level would create a risk of discrimination 
between producers in those countries that do not have an access to the school schemes as a 
market  outlet.  The  EU  regime  produces  additional  added-value  on  top  of  already  existing 
national  schemes  as  it  leads  to  a  continuous  knowledge,  transparency  and  experience 
transfer among participating MS. 

4. 

OBJECTIVES 

In  order  to  meet  the  general  objectives  of  increasing  the  consumption  of  F&V  and  milk 
products  and  contributing  to  shaping  healthier  diets,  the  specific  and  operational  objectives 
aim at adapting the current framework of the schemes to: 

(1) 

Refocus  the  current  set-up  towards  the  long-term  objectives,  with  a  view  of 
equipping both schemes with the educational tools, and contribute to reconnecting 
young citizens with food and its source, thus enhancing perceptions of agriculture 
and  its  products.  These  specific  objectives  translate  into  the  following  operational 
objectives aimed at: 

– 

– 

– 

Boosting  and  consolidating  the  educational  dimension  of  the  current  regimes 
through compulsory educational tools, 

Increasing the link between the products and the scheme (the EU added value), 

Developing a common evaluation methodology for the EU and MS evaluations 
and annual monitoring. 

(2) 

Unify and consolidate the current separate legal and financial frameworks and 
increase the visibility of the EU intervention. The operational objectives aim at: 

3 

 
 
– 

– 

Increasing  synergies  between  the  current  two  schemes  and  their  management 
efficiency, 

Increasing the visibility of the EU schemes. 

(3) 

Increase  the  efficiency  of  the  spending  dedicated  to  the  promotion  of  the 
consumption  of  agricultural  products  in  schools,  with  the  operational  objectives 
aiming at: 

– 

– 

 Improving the conditions affecting the use of the budgetary potential, 

Simplifying  the  legal  framework  and  reduce  the  administrative/organisational 
burden. 

5. 

POLICY OPTIONS 

In  the  process  of  screening  of  different  options,  four  options  were  discarded3,  while  the 
following options were further analysed: 

5.1. 

Option 1: CAP 2020 (status quo) 

The status quo option already integrates the changes brought about by the CAP 2020 reform, 
which  keeps  the  current  separate  legal  and  financial  frameworks,  together  with  the  changes 
agreed for both schemes. The SFS: an increased budget to €150 million per year, higher EU 
co-financing rates (75%, or 90% for less developed regions), and eligibility of accompanying 
measures for EU co-financing. The SMS: obligation for MS to draw up national or regional 
strategies and voluntary accompanying measures. The SMS financing arrangements are kept 
unchanged (EU aid per product €18.15/100kg, no overall ceiling on the EU expenditure). 

5.2. 

Option 2: Adjustment 

This  option  is  set  to  explore  whether  the  objectives  could  be  achieved  by  maintaining  the 
separate  frameworks,  CAP  2020  financing  and  the  choice  of  products  but  introducing 
following adjustments: 

– 

– 

introducing obligatory accompanying measures also for the SMS, 

the  current  frameworks 

approximating 
through  regulatory  adjustments 
(requirements  of  common  strategies,  common  and  administrative  provisions 
related to controls etc), and 

– 

further synergies beyond CAP 2020. 

5.3. 

Option 3: New framework 

This option foresees a common legal and financial framework for the CAP school schemes, 
based on the three “pillars”: 

3  "No  policy",  discarded  based  on  the  analysis  concerning  the  need  for  continued  school  intervention; 
"discontinuation of the SMS only", also not in line with the analysis of the relevance to continue with the milk 
distribution;  "new  framework  with  a  focus  on  socio-economically  disadvantaged  groups  only",  discarded  as 
Member States are better placed to target and prioritise their intervention; and "new framework with a regular 
distribution  of  a  wider  choice  of  agricultural  products",  discarded  based  on  the  public  consultation  outcome, 
proportionality and potentially high implementation burden.  

4 

 
 
                                                 
i)  Common  accompanying  measures,  with  an  educational  focus  on  reconnecting  children 
with agricultural, nutrition/health and environmental issues, that could occasionally include a 
wider choice of agricultural products in thematic measures (to be approved by national health 
authorities). 

ii)  The  limitation  of  the  distribution  to  fresh  fruit  and  vegetables  (including  bananas)  and 
drinking milk only. This would focus the distribution within the limited budget, reflect the 
most  frequent  current  practice,  reduce  organisational  burden  for  schools,  and  is  in  line  with 
the need to help reverse the declining consumption trends for these two groups of products. 

iii) Common financing framework with: 

−  a limited overall EU budget (CAP 2020 neutral, introducing a ceiling also for milk), 
allocated  to  MS  in  separate  “envelopes”  for  F&V  and  milk,  with  a  possible  transfer 
between them (prioritising of intervention through strategies);  
limitation  of  the  EU  contribution  through  aid  per  portion  for  F&V  and  milk  (not 
through the EU co-financing levels as currently under the SFS); 
an  increase  in  the  EU  subsidy  for  milk  in  order  to  reduce  the  deadweight  effect  and 
increase the cost-benefit of distribution. 

− 

6. 

ASSESSMENT OF IMPACTS 

6.1. 

Economic impacts 

•  Direct, indirect and long-term impact on the demand 

Under  option  1,  the  direct  and  indirect  impact  on  the  demand  for  F&V  products  will  likely 
increase for the SFS due to the higher budget and strengthened accompanying measures The 
increased demand could bring more benefits to the local producers (schools as an additional 
"niche"  for  their  products)  if  products  are  sourced  locally  and  encourage  different  forms  of 
cooperation to meet the demands of the institutional markets. 

The impact on the demand for milk products under SMS is likely to be stable, while the long-
term impact depends on MS (if they carry out educational measures). The national strategies 
could  be  perceived  as  administrative  burden,  possibly  decreasing  the  SMS  attractiveness.  If 
projected milk/dairy prices increase, the EU aid towards the cost of the products will further 
drop with unchanged levels of the EU subsidy. 

Under option 2, the direct potential in terms of volumes distributed is expected to be similar 
as  under  option  1,  while  the  indirect  and  long  term  impact  should  increase  with  obligatory 
accompanying  measures  for  SMS.  But  significant reductions in administrative  burden could 
be an incentive for participation and better use of the potential. 

The direct impact on the F&V demand under option 3 is similar as option 1 but channelled 
more to the fresh F&V. The limited overall EU budget for milk will not have an impact on the 
volumes of products distributed, but these should be higher for drinking milk (on account of 
other  dairy  products).  The  higher  EU  subsidy  levels  will  likely  bring  reductions  in  the 
quantities  distributed,  if  national  top-ups  or  private  contributions  remain  unchanged.  Long-
term  impacts  are  expected  to  be  higher  under  this  option  with  improved  accompanying 
measures. 

5 

 
 
•  Consumption 

Under option 1, the direct and indirect consumption of F&V, both short- and long-term, is 
expected to be higher under the SFS. The consumption of milk products under SMS should be 
stable. 

Option  2  is  likely  to  have  a  higher  impact  on  the  consumption  through  the  obligatory 
accompanying measures for both schemes and common strategic planning. 

Option 3 is expected to give greater direct impact on the consumption of drinking milk and 
fresh F&V (for  which the  consumption trends are declining) and an  indirect impact  also on 
the wider variety of products through accompanying measures. 

•  Farmers' income and prices 

The school schemes do not have a significant impact on farmers' income and prices, with 
the exception of a possibility for producers to develop alternative market opportunities outside 
the school (approaching parents and similar). Orientation towards local products increases the 
transparency about how the final price was created (if there is direct sourcing). Option 2 gives 
greater  possibilities  for  the  diversification  of  activities  and  involvement  in  accompanying 
measures also under the SMS. In addition to that, option 3 is expected to bring a more level-
playing  field  as  regards  the  price  of  F&V  products  distributed,  which  could  be  felt  by 
producers if products are directly sourced. 

•  Innovation 

The school schemes have a limited potential to foster innovation and research for the creation 
of child-friendly products, packages and similar.  

•  Trade with third countries 

All options are in line with EU's international trade obligations, even though the impact of the 
schemes on trade is not significant due to limited volumes and mostly local/regional sourcing 
of products. 

6.2. 

Social impacts 

• 

Public health 

The  consumption  of  F&V  and  milk  products  are  beneficial  from  the  public  health  point  of 
view.  The  impact  of  certain  dairy  products  on  weight  management  depends  on  choice  of 
products, portions sizes and frequency. Compulsory strategies under SMS under option 1 will 
result in a better targeting of the scheme. Option 2 will likely bring higher impacts due to the 
obligatory  accompanying  measures  that  comprise  also  nutritional  education.  Option  3  will 
have a greater impact on public health through the limitation of regular distribution to fresh 
F&V  and  drinking  milk  only,  involvement  of  national  health  authorities  in  the  approval  of 
products and better targeting through common strategies. 

• 

Social and territorial balance 

6 

 
 
Option 1 ensures the continued impact of school distribution on social and territorial balance 
(MS  can  focus  and  prioritise  through  their  strategies).  CAP2020  higher  co-financing  levels 
provide for a higher support for less developed regions under the SFS (90%). The low subsidy 
level under SMS often requires significant public or private financial contributions. Option 2 
brings  similar  impacts  as  option  1.  Option  3  is  beneficial  for  regions/MS  in  economic 
difficulties  with  the  abolition  of  obligatory  co-financing  for  F&V,  while  the  flat  rate  per 
portion  would  be  favourable  for  most  of  the  less  developed  regions  where  products  are 
cheaper. 

• 

Employment and job creation 

The school schemes do not have a potential to create significant impact on employment and 
job creation, except through the diversification of activities and cooperation. 

6.3. 

Environmental impacts 

Option 1 encourages local purchasing and environmental considerations for SFS. In many MS 
packages used for the distribution of F&V are reusable or at least recyclable. Accompanying 
measures could integrate also education on environmental matters.  Option 2 strengthens the 
latter elements also for the SMS. Option 3 has potential for further positive impacts through 
the limitation of products featured in the distribution. 

6.4. 

Budgetary impacts 

Under  option  1,  the  impact  on  the  EU  budget  will  remain  as  estimated  for  the  CAP2020 
reform.  The  co-financing  principle  under  SFS  requires  national  contributions,  while  the 
impact  of  the  SMS  on  national  budgets  depends  on  the  involvement  of  MS  (voluntary  top-
ups)  and  private  contributions  (mostly  parents).  Option  2  is  budget  neutral  compared  to  the 
status quo, with limited uncertainty as regards the EU budget, as there is no overall envelope 
that  limits  the  EU  expenditure.  Option  3  is  also  budget  neutral  but  it  limits  the  EU 
contribution  also  for  milk.  The  national  contributions  will  be  needed  if  MS  want  to  enlarge 
the scope and/or intensity of their schemes. 

6.5. 

Administrative burden and simplification 

Under  the  status  quo  (option  1),  the  number  of  quantifiable  obligations  is  estimated  at  54 
information obligations. Total administrative costs for the SFS are estimated at €1.08 million, 
while for the SMS they are around €5.27 million. Option 2  brings considerable reductions in 
the administrative burden, with a possible reduction of quantifiable obligations from 54 to 39 
(30%).  Additional  organisational  burden  could  stem  from  the  obligatory  accompanying 
measures  also  for  the  SMS.  Option  3 is expected to have  similar but certain impacts on the 
administrative burden as option 2, but in addition it is poised to further reduce organisational 
burden with a narrower list of products for the distribution.  

7 

 
 
7. 

COMPARISON OF OPTIONS  

7.1. 

Effectiveness  

Under option 1 there will be a continued gap in the educational dimension and consequently 
long-term  impacts  between  the  two  schemes.  It  addresses  some  of  the  shortcomings  for  the 
SFS but it has no impact on other drivers behind a suboptimal performance of both schemes.  

Option 2 provides a better contribution to the long-term objectives of the schemes through the 
strengthened  educational  dimension  of  the  SMS.  It  is  also  positive  as  regards  the  increased 
synergies but these are limited due to different financial arrangements. It does, however, have 
a limited impact on the other deficiencies limiting the immediate impact of spending and the 
use of potential. 

Option 3 has the greatest potential for achieving the identified objectives within an unchanged 
budget, as it shifts the focus of the current school regimes towards the long-term objectives. 
The  school  regime  would  be  able  to  better  respond  to  the  problems  of  declining  F&V  and 
milk  consumption  and  rising  obesity.  It  enables  the  management  efficiency,  allows  for 
flexibility and prioritizing. It has the potential to increase the efficiency of distribution, as it 
addresses most of the drivers behind the problems (those that could be tackled by this review). 

7.2. 

Efficiency 

Limited changes to the financing arrangements and the level of administrative burden under 
option  1  will  continue  the  low  cost-benefit  ratio  linked  to  the  implementation.  Strong 
variations  in  the  efficiency  of  distribution  under  the  SFS  are  likely  to  continue,  while  the 
issues limiting the SMS efficiency will persist (potential deadweight).  

Option 2 is budgetary neutral but contains small uncertainties as regards the SMS funding (no 
overall EU funds limit). The reduction of the administrative burden increases the cost-benefit 
ratio.  However,  the  SFS  distribution  will  continue  to  be  marked  by  strong  variations  in 
efficiency  (high  disparities  in  costs  of  products)  and  the  SMS  with  continued  potential 
deadweight effect. 

lower 
Option  3  brings  a  greater  cost-effectiveness  with 
administrative  burden  and  changes  in  the  financing  conditions.  The  focused  distribution 
within the limited budget is expected to maximise the impact. Changes to milk subsidy could 
potentially reduce the scope but increase the impact as compared to the higher coverage with 
limited impact. 

the  focused  distribution, 

7.3. 

Coherence  

Option  1  has  a  more  limited  potential  to  tackle  evolving  societal  changes  (consumption 
patterns)  and  provides  limited  contribution  to  the  horizontal  objectives  of  better  regulation 
and  simplification.  But  it  can  make  a  positive  contribution  to  the  public  health  (especially 
health inequalities) through the targeting and prioritizing via national strategies. 

Option  2  brings  an  important  simplification  effect,  so  it  has  greater  contribution  to  better 
regulation  and  simplification.  It  is  also  positive  for  public  health  objectives  through  the 
educational tools for both schemes, contributing to shaping healthier eating habits. 

8 

 
 
Option  3  has  a  higher  economic  impact  on  products  that  need  promotion  (fresh  F&V  and 
drinking milk) but lower impact on other dairy and processed F&V products. It is more in line 
with public health objectives (weight management, health inequalities). It also has the highest 
simplification effect. 

8. 

MONITORING AND EVALUATION 

At  the  moment,  the  SFS  has  a  monitoring  and  evaluation  system  in  place  that  could  be 
upgraded and used as a model for the future system.  

The monitoring would be carried out on the basis of the annual monitoring reports (AMR) to 
measure the immediate outputs and monitor accompanying measures.  

The evaluation would consist of: 

–  MS evaluation reports after 5 years of implementation of the scheme,  

– 

– 

– 

an external EU wide evaluation to assess the overall effectiveness, efficiency, 
coherence and relevance,  

the  EU  Group  of  experts  to  provide  MS  and  the  Commission  with  advice  on 
implementation, monitoring and evaluation, 

a study on long-term impact indicators. 

9