Evaluation of marketing standards (contained in the CMO Regulation, the "breakfast directives" and CMO secondary legislation)
Date: 2019-11-28
Institutions: Directorate-General for Agriculture and Rural Development, European Commission
Subjects: common agricultural policy, rural development



IMMC.Ares%282019%297332619.ENG.xhtml.PART-2019-600393V1.docx









Factual summary report of the public consultation: 


Evaluation of marketing standards [Regulation (EU) No 1308/2013]
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The public consultation for the evaluation of marketing standards [Regulation (EU) No 1308/2013]  was open for feedback from 22 July to 14 October 2019. When the consultation closed, in total 117 contributions were received
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. 



The aim of the public consultation was to receive the opinion (positive, negative, neutral) of stakeholders and the public on the EU marketing standards.  This document should be regarded solely as a summary of the contributions received in response to the public consultation. It cannot in any circumstances be regarded as the official position of the Commission or its Services.



In addition to the public consultation summarized here, the evaluation involved a large number of consultations of stakeholders. These included at the European level interviews of consumer and sector representatives, interviews with national authorities, administrative bodies, producers, representatives of consumer associations, and technical organisations. 








Countries





Country




Total 






Austria




1






Belgium




22






Bulgaria




6






Finland




2






France




37






Germany




8






Hungary




12






Italy




4






Luxembourg




1






Netherlands




6






Poland




1






Spain




16






United Kingdom




1






Grand Total




117






Answers were received from 13 different countries, out of 28 Member States. Most of the responses came from France (37 reactions) and Belgium (22 reactions), then from Spain (16 reactions) and Hungary (12 reactions).





General observation on the closed questions



It should be noted that numerous respondents did not reply to all questions (around 30% of the questions were left blank), therefore –unless otherwise indicated- the analysis has been done taking as a basis the non-blank answers. For each question the number of actual replies (n=) has been provided.



Profile of the respondents


The graph below presents the distribution of the professional respondents. Note that the percentages were done on non-blank answers, representing 62% of the total. (n=72)




 With regard to responding organisations (n=74) the following types can be distinguished:





The respondents had to indicate the sectors they were familiar with. 


The most represented sectors were: Poultry meat (27%), Fruits and vegetables (19%), Eggs (12%), Milk and milk products, beef and wine (3% each), Olive oil and table olives and Honey (2% each). Note that 29 % of respondents did not indicate any product sector. (n=117)



Q18-19-20-21. In your opinion, to what extent have the EU marketing standards, in the product sectors you are familiar with, contributed to:


-supplying the market with products of a standardised and satisfactory quality?  (n=82)


88% of respondents found that they had a positive contribution, 3% found that they had a negative contribution, 4% claimed no effect and 5% had no opinion.



-improving the conditions for production and marketing and creating a level-playing field in these sectors? (n=82)




82% of respondents found that they had a positive contribution, 12% found that they had a negative contribution, 4% claimed no effect and 5% had no opinion.



- providing adequate and transparent information to consumers?  (n=81)


79% of respondents found that they had a positive contribution, 12% found that they had a negative contribution, 8% claimed no effect and 1% had no opinion.



- providing the purchaser with value for money? (n=81)


21% of respondents found that they provided a very good value for money, 47% a good value for money, 12% a limited value for money, 9% no value for money and 11% did not have an opinion.




Q22. In your opinion, to what extent could efficiency be improved by harmonising the control and reporting requirements of the different marketing standards? (n=82)




Q24. In your opinion, to what extent are the EU marketing standards, in the product sectors you are familiar with, consistent to other EU policy interventions in these sectors?: 


EU rules on food safety (n=67)


34% of respondents found that they are very strongly consistent, 21% strongly consistent, 14% moderately consistent, 6% not consistent and 25% did not have an opinion.


Food information to consumers (n=68)


31% of respondents found that they are very strongly consistent, 40% strongly consistent, 18% moderately consistent, 10% not consistent and 1% did not have an opinion.


Geographical indications (n=64)


55% of respondents found that they are very strongly consistent, 14% strongly consistent, 20% moderately consistent, 5% not consistent and 6% did not have an opinion.


Organic products (n=68)




34% of respondents found that they are very strongly consistent, 12% strongly consistent, 17% moderately consistent, 6% not consistent and 31% did not have an opinion.



Q25. In your opinion, to what extent are the EU marketing standards, in the product sectors you are familiar with, consistent with international marketing standards and with private marketing standards?: 


International marketing standards - Codex Alimentarius (CODEX) (n=68)


16% of respondents found that they are very strongly consistent, 19% strongly consistent, 18% moderately consistent, 4% not consistent and 43% did not have an opinion.


International marketing standards - United Nations Economic Commission for Europe (UNECE)(n=66)


21% of respondents found that they are very strongly consistent, 17% strongly consistent, 14% moderately consistent, 4% not consistent and 44% did not have an opinion.


Private marketing standards (n=67)


16% of respondents found that they are very strongly consistent, 15% strongly consistent, 21% moderately consistent, 8% not consistent and 40% did not have an opinion.



Q26-27-28 and 34. In your opinion, has the implementation of the EU marketing standards caused:


-any unexpected or unintended effects in terms of food waste? (n=81)


13% of respondents replied “yes”, 41% “no” and 46% did not have an opinion.


-any unexpected or unintended effects in terms of animal welfare?(n=81)


31% of respondents replied “yes”, 43% “no” and 26% did not have an opinion.


- any unexpected or unintended effects in regard to the sustainability of the food chain? (n=79)


29% of respondents replied “yes”, 36% “no” and 35% did not have an opinion.



Q29. In your opinion, to what extent do the EU marketing standards, in the product sectors you are familiar with, fit with the needs of the supply chain in these sectors (i.e. producers, processors, traders, retailers) ? (n=81)







Q 30. In your opinion, to what extent do the EU marketing standards, in the product sectors you are familiar with, fit with the needs of consumers ? (n=81)





Q 31. In your opinion, to what extent do the EU marketing standards, in the product sectors you are familiar with, fit with the needs of Member States administrations ?


(n=82)









Summary of some open questions:



Q23. In your opinion, what could be simplified, and how, in order to improve the management and implementation of the EU marketing standards?


Following suggestions for simplification or improvement were made : 



Fruits and vegetables: the main qualitative contributions related to:





Digitalisation





Digitalisation and new techniques for labelling use of QR-Code for tracking information 


and to achieve the maximum traceability of the product.






Harmonisation





Harmonisation of marketing standards for different sectors to reduce administrative burden; Alignment of the specific marketing standards for fresh fruit and vegetables with UNECE standards; Harmonisation in the area of authorised packagers; Continue European harmonisation of the rules. 






Recognition





To improve the management and enforcement of the rules, it is necessary to facilitate recognition as authorised economic operators.






Quality





The focus of the EU marketing standards must remain on quality aspects of the products.






Administrative requirements





Simplification of administrative requirements, currency included in the standards.







Compliance





Performance of regular and public reporting on inspections carried out with regard to compliance with EU marketing standards by the various competent authorities. 






Simplification





Simplification of texts; identification with commercial language and consumer; However, simplifying should not be synonymous with eliminating existing marketing standards for different fruit and vegetable products. The removal of common European standards would lead to the proliferation of different private standards: different for each Member State, and for commercial operators.






Sector specificities





The obligation in the EU for citrus to mention of the Preserving agent or other chemical substances used at post-maturity stage is discriminatory as this requirement is not obligatory for any other fruit. 








Eggs: For the Eggs sector, the main qualitative contributions related to:





Simplification





Simpler rules, clear wording, consistency, tighter control. 


However, other stakeholders claim:






Compliance





No simplification is needed. Controls in firm.






Safety, monitoring





Monitoring of products on the food safety website, the raw material being incorporated into a product that has been used, so that the consumer is provided with a clear indication of the source of origin of the product and the quality of the raw material; Effective, frequent monitoring.






Sector specificities





There was no need for simplification, keeping them unchanged, with a few points, in particular concerning the controls on the methods of rearing laying hens in laying hens. 






Poultry meat: For the Poultry meat sector, the main qualitative contributions related to:





Status quo





Many respondents claimed that there is no need for simplification. Keep them unchanged.


And that the management and implementation of the current marketing standards is adequate.






Awareness





Maintaining current standards without simplification and making them known.






Sector specificities





Laboratory analysis procedures could in some cases be simpler and more harmonised. For example, the procedure for checking the water content of poultry is complex and unnecessarily costly for producers.






Olive oil and table olives: the main qualitative contributions related to:





Sector specificities





There is a need to simplify official organoleptic testing for virgin olive oils. In the absence of harmonisation between official control tasting panels established by the International Olive Oil Council, operators marketing virgin olive oils are subject to serious legal uncertainty. 







Documents uploaded and final comments received


The last question of the questionnaire was an open question offering the possibility to add further information.


Out of the 117 answers, 50 uploaded a document/position paper (43%). This shows the interest of the stakeholders in this particular consultation.



Documents uploaded in relation to the sector the respondent is familiar to. (n=50)


When cross-checking the respondents that uploaded a document and the sector the respondent is more familiar to (Q17), 40% of the respondents that uploaded a document did not indicated a particular sector, 38% were familiar to the poultry meat sector, 10% to the eggs sector,  8% to the fruits and vegetables sector and 4% to the dairy products sector.






Feedback received outside the survey portal




There were two contributions received independent from the public consultation. A business association sent feedback regarding the olive oil sector. Besides, a regional public authority sent feedback regarding the important contribution of marketing standards. 


 






(1)


 
https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2017-3244337_it
 




(2)


 This figure does not include contributions received on/after 14 October 2019 outside EU Survey.