REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation and impact of voluntary labelling provisions under Regulation (EC) No 1760/2000 as amended by Regulation (EU) No 653/2014
Date: 2019-12-13
Institutions: Directorate-General for Agriculture and Rural Development, European Commission
Subjects: EU Member State, application of EU law, beef, bovine spongiform encephalopathy, cattle, consumer information, food inspection, food safety, labelling, veterinary inspection

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 13.12.2019  COM(2019) 625 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation and impact of voluntary labelling provisions under Regulation (EC) No 1760/2000 as amended by Regulation (EU) No 653/2014   
 
 
1.  INTRODUCTION 

Pursuant to Article 23a of Regulation (EC) 1760/20001, the Commission shall submit to 
the  European  Parliament  and  the  Council  a  report  dealing  with  the  implementation  and 
impact  of  the  provisions  on  voluntary  beef  labelling,  including  the  possibility  of  their 
review. 

Regulation (EC) No 1760/2000 was adopted in the aftermath of the Bovine Spongiform 
Encephalitis (BSE) crisis, in order to improve transparency and strengthen the confidence 
of consumers in beef. 

The  Regulation  provided  for  strict  rules  concerning  the  approval  and  use  of  voluntary 
information, justified by a serious loss of consumers’ confidence and subsequent serious 
market disturbances. 

Regulation  (EU)  653/20142  amended  Regulation  (EC)  No  1760/2000  and  significantly 
simplified the provisions on voluntary beef labelling, with the main aim of reducing the 
administrative burden for operators and competent authorities, as well as to reduce costs 
borne by operators to provide such voluntary information. 

The  amended  rules  do  not  foresee  the  requirement  for  authorisation  of  voluntary  beef 
labelling  any  more.  Such  voluntary  information  must  comply  with  the  horizontal 
legislation  on  labelling  and  in  particular  Regulation  (EU)  No  1169/20113  on  food 
information to consumers. 

The  objectives  of  this  report  are,  pursuant  to  Article  23a  of  Regulation  (EC) 
No 1760/2000: 

- 

to  assess  the  implementation  and  impact  of  the  current  EU  legislation  on 
voluntary beef labelling along the supply chain, in particular taking into account 

1  Regulation  (EC)  No  1760/2000  of  the  European  Parliament  and  of  the  Council  of  17  July  2000 
establishing a system for the identification and registration of bovine animals and regarding the labelling of 
beef and beef products and repealing Council Regulation (EC) No 820/97, OJ L 204, 11.8.2000 p. 1. 

2 Regulation(EU) No 653/2014 of the European Parliament and of the Council of 15 May 2014 amending 
Regulation (EC) No 1760/2000 as regards electronic identification of bovine animals and labelling of beef, 
OJ L 189, 27.6.2014, p. 33. 

3 Regulation (EU) No 1169/2011 of the European Parliament and 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  repealing  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. 

1 

 
 
                                                           
the  views  expressed  by  competent  authorities,  producers,  processors  and 
consumers; 

- 

to explore the possibility of reviewing provisions on voluntary beef labelling. 

2.  BACKGROUND AND LEGAL FRAMEWORK 

Council Regulation (EC) No 1760/2000 was adopted in the context of a loss of consumer 
confidence after the BSE; it repealed and replaced Council Regulation (EC) No 820/974, 
adopted in response to serious market disturbances caused by the BSE crisis. Regulation 
(EC) No 820/97 introduced the principle of individual traceability of animals and origin 
labelling of beef.  

Regulation (EC) No 1760/2000 established the following elements: 

1.  it reinforced the identification and registration system for bovine animals, Articles 

1 to 10; 

2.  it introduced a compulsory beef labelling system under which operators marketing 
beef  have  to  indicate  on  the  label  information  concerning  origin,  in  particular 
where  the  animals  from  which  the  beef  was  derived  were  born,  fattened  and 
slaughtered, Articles 11 to 15; 

3.  it introduced a voluntary labelling system to allow operators to provide additional 

information to consumers, Articles 16 to 18. 

The provisions referred to in the third point  (voluntary labelling system) were amended 
in  2014  by  Regulation  (EU)  No  653/2014,  essentially  removing  the  requirement  for 
authorisations,  by  competent  authorities,  of  voluntary  labelling  information  and  the 
obligation of controls on operators carried out by an independent body recognised by the 
competent authority. 

 Voluntary  beef  labelling  typically  covers  breed  and  category  of  animals,  region  of 
production, feeding and production systems. 

Regulation (EU) No 653/2014 amended Regulation (EC) No 1760/2000 as follows: 

  a newly introduced Article 15a in particular requires information to be objective, 

verifiable by the competent authorities and comprehensible for consumers; 

4  Council  Regulation  (EC)  No  820/97  of  21  April  1997  establishing  a  system  for  the  identification  and 
registration of bovine animals and regarding the labelling of beef and beef products. OJ L 117, 7.5.1997, 
p. 1. 

2 

 
 
 
                                                           
  Article  15a  moreover  empowers  the  Commission  to  adopt  delegated  acts 
concerning  definitions  and  requirements  applicable  to  terms  and  categories  that 
may be put on the labels of pre-packed fresh and frozen beef and veal. 

  Article  22,  as  amended,  provides  among  other  things  that,  if  an  operator  or 
organisation has labelled beef without complying with the obligations laid down 
for compulsory or voluntary labelling, Member States shall, as appropriate, and in 
accordance with the principle of proportionality, require the removal of the beef 
from  the  market.  Member  States  may  authorise  that  such  beef  be  placed  on  the 
market  after  properly  being  labelled  in  accordance  with  Union  requirements, 
provided that the meat conforms to the relevant veterinary and hygiene rules. 

2.1 VOLUNTARY LABELLING SYSTEM BEFORE ENTRY INTO FORCE OF 

REGULATION (EU) NO 653/2014 

Before  the  entry  into  force  of  Regulation  (EU)  No  653/2014,  the  general  rules  for  the 
authorisation and control of voluntary information on beef, were provided in Articles 16 
and 17 (now repealed) of Regulation (EC) No 1760/2000. 

Briefly: 

 

 

 

the operator was required to send the specification for approval to the competent 
authority of the Member State in which beef production or sale took place; 

the specification had to describe the information to be included on the label; 

the operator had to set up a specific control system to be applied at all stages of 
production, including controls carried out by an independent body recognised by 
the competent authority and designated by the operator; these independent bodies 
had to comply with the criteria set out in European standard EN/45100; 

  operators  using  the  labelling  system  had  to  bear  the  cost  of  controls  by  an 

independent body; 

 

 

the competent authority had to examine the specifications and the measures taken 
to ensure the accuracy of the information provided on the label; 

if the production and/or sale of beef took place in two or more Member States, the 
competent  authorities  of  the  Member  States  concerned  had  to  examine  and 
approve the specifications related to operations within their respective territories; 

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  any  specification  approved  by  a  Member  State  had  to  be  communicated  to  the 
other Member States through the Committee for the Common Organisation of the 
Agricultural Markets; 

 

in  case  the  production  of  beef  took  place  in  a  third  country,  operators  were 
allowed  to  provide  voluntary  information  on  beef  labelling  according  to 
Regulation  (EC)  No 1760/2000  upon  prior  notification  to  the  Commission  from 
the third country concerned containing the following elements: 

 

 

 

the competent authority designated to grant the approval; 

the  procedures  and  criteria  that  the  competent  authority  followed 
when examining the specification; 

the  list  of  operators  and  organisations  allowed  to  use  the 
specifications approved. 

 

 

the Commission had to examine the notifications received from third countries in 
order to evaluate the equivalence of the procedures and criteria applied from the 
third country to the standards set out in Regulation (EC) No 1760/2000; 

the notifications received by third countries had to be transmitted to the Member 
States. 

2.2 VOLUNTARY LABELLING AFTER ENTRY INTO FORCE OF REGULATION (EU) 

NO 653/2014 

Article 15a of Regulation (EU) No 653/2014 provides:  

“Food information other than that specified in Articles 13, 14 and 15 which is added to 
labels  voluntarily  by  operators  or  organisations  marketing  beef  shall  be  objective, 
verifiable by the competent authorities and comprehensible for consumers.  

That  information  shall  comply  with  the  horizontal  legislation  on  labelling  and  in 
particular  Regulation  (EU)  No  1169/2011  of  the  European  Parliament  and  of  the 
Council…”. 

With this  provision, rules on voluntary  beef labelling have been harmonised with  other 
meat types and foodstuffs in general under the horizontal food information to consumers’ 
Regulation3; operators can now provide voluntary information on labels under their own 
responsibility, without the need for a prior approval by competent authorities and without 
third-party controls.  

4 

 
 
 
 
Chapter  V  of  Regulation  (EU)  No  1169/2011  provides  general  rules  on  voluntary  food 
information.  In  particular,  Article  36(2)  of  the  Regulation  lays  down  that  information 
provided on a voluntary basis shall meet the following requirements: 

(a) it shall not mislead consumer as referred to in Article 7 of the Regulation (‘fair 
information practices’), particularly: 

o  as  to  the  characteristics  of  the  food  and,  in  particular,  as  to  its  nature, 
identity, properties, composition, quantity, durability, country of origin or 
place of provenance, method of manufacture or production; 

o  by attributing to the food effects or properties which it does not possess;  

o  by suggesting that the food possesses special characteristics when in fact 
all similar foods possess such characteristics, in particular by specifically 
emphasising the presence or absence of certain ingredients and/or 
nutrients; 

o  by  suggesting,  by  means  of  the  appearance,  the  description  or  pictorial 
representation,  the  presence  of  a  particular  food  or  ingredient  while  in 
reality a component naturally present has been substituted with a different 
component. 

(b) it shall not be ambiguous or confusing for the consumer; and  

(c) it shall, where appropriate, be based on relevant scientific data. 

The reference to Article 7 of the Regulation (EU) No 1169/2011 is particularly important. 
Since  it  states  that  the  information  provided  shall  not  be  misleading  in  relation,  among 
others,  to  the  characteristics  of  food,  to  the  place  of  provenance  and  to  the  method  of 
manufacture  and  production,  it  is  de  facto  covering  all  the  information  previously 
provided as voluntary labelling under Regulation (EC) No 1760/2000. In this sense, fair 
information practices are guaranteed by reference to Article 7. 

3.  METHODOLOGY 

The present report is based on the following information:  

- 

- 

- 

analysis  of  previous  reports  and  evaluations  carried  out  on  voluntary  beef 
labelling;  

consultation  of  Member  States  through  a  specific  questionnaire  and  bilateral 
contacts; 

consultation  of  stakeholders  through  a  specific  questionnaire  and  bilateral 
contacts.  

5 

 
 
3.1 PREVIOUS REPORTS AND EVALUATIONS 

The results of the following studies and reports were used to evaluate the implementation 
of the voluntary beef labelling system: 

a)  Report  from  the  Commission  to  the  Council  and  European  Parliament  on  the 

implementation of Title II of Regulation (EC) No 1760/20005. 

b)  Opinion on agriculture of The High Level Group of Independent Stakeholders on 

Administrative Burdens6.  

c)  Evaluation study for the Commission “Evaluation of EU beef labelling rules”7 

3.2 CONSULTATION WITH MEMBER STATES 

In  order  to  integrate,  update  and  complement  the  analysis  carried  out  within  the 
framework  of  previous  evaluations,  information  was  collected  through  specific 
questionnaires addressed to the competent authorities of all 28 Member States. 

The  questionnaire  was  presented  at  the  meeting  of  the  Committee  for  the  Common 
Organisation of Agricultural Markets on 19 July 2018 and distributed to Member States. 

The aim of the questionnaire was to collect information, opinions and assessments from 
the competent authorities in charge of implementing the system. 

Member States were asked in particular: 

-  whether they kept a national system of notifications and control on voluntary beef 

labelling after the entry into force of Regulation (EU) No 653/2014; 

- 

to  provide  an  estimate  of  the  market  share  of  bovine  meat  voluntarily  labelled 
before and after the entry into force of Regulation (EU) No 653/2014; 

-  which were the main information elements provided under the voluntary labelling 

system; 

5 COM(2004)316 final.  

6  HLG  Opinion  on  the  priority  area  of  Agriculture  /  Agricultural  subsidies  of  5  March  2009, 
https://ec.europa.eu/info/sites/info/files/action-programme-for-reducing-administrative-burdens-in-the-eu-
final-report_dec2012_en.pdf .  

https://ec.europa.eu/agriculture/sites/agriculture/files/evaluation/market-and-income-reports/2015/eu-

7 
beef-labelling-rules/fullrep_en.pdf.

6 

 
 
                                                           
 
- 

- 

- 

- 

- 

the number of controls  carried out  and non-conformity  rates before (2013-2014) 
and  after  (from  2015  onwards)  the  entry  into  force  of  Regulation  (EU)  No 
653/2014; 

the types of non-conformities detected in relation to voluntary beef labelling; 

the  difficulties  encountered  in  implementing  voluntary  beef  labelling  after  the 
entry into force of Regulation (EU) No 653/2014; 

to  assess  the  main  effects  (positive  or  negative)  of  the  simplification  introduced 
by Regulation (EU) No 653/2014; 

to assess (on a scale of 1 to 5) the system of voluntary beef labelling before and 
after  the  entry  into  force  of  Regulation  (EU)  No  653/2014  in  relation  to  the 
following  aspects:  effectiveness  of  the  system,  reliability  of  the  system, 
complexity  for  competent  authorities,  complexity  for  producers,  administrative 
burden for competent authorities to implement and run the system, administrative 
costs for producers, capacity to correctly inform consumers. 

Out of 28 Member States, 12 responded in detail to  the questionnaire (BE-DK-DE-ES-
FR-IT-AT-PT-SI-FI-SE-UK).  5  Member  States  replied  that  they  were  not  applying 
voluntary beef labelling before 2014 (BG-HR-LV-LT-PL). 

11 Member States did not reply or sent a partly completed questionnaire (CZ-EE-IE-EL-
CY-LU-HU-MT-NL-RO-SK). 

A discussion with Member States on the main outcomes of the questionnaire took place 
at the meeting of the Committee for the Common Organisation of Agricultural Markets 
on 8 November 2018. 

3.3 CONSULTATION WITH STAKEHOLDERS 

Similar to the consultation of Member States, the questionnaire addressed to stakeholders 
aimed  to  collect  information,  opinions  and  assessments  in  relation  to  the  following 
aspects: 

-  whether previous rules on beef voluntary labelling (i.e. approval from MS, third-
party controls, notifications etc.) were considered useful in the past to sustain the 
market after the BSE crisis and to correctly inform consumers; 

-  whether there would be valuable reasons to differentiate beef from other types of 

meat and food in relation to voluntary information to consumers; 

7 

 
 
-  how  previous  rules  on  voluntary  beef  labelling  were  perceived  and  the  main 
effects (positive or negative) of the new rules introduced by Regulation (EU) No 
653/2014; 

-  whether  consumers  were  aware  of  the  different  rules  applied  to  voluntary  beef 

labelling before Regulation (EU) No 653/2014 compared to other food; 

- 

- 

any  difficulties  encountered  by  stakeholders  (at  the  relevant  market  stage)  to 
adapt to the new rules introduced by Regulation (EU) No 653/2014 and whether 
the new rules on voluntary beef labelling had an impact (positive or negative) on 
stakeholder's marketing strategies; 

to assess (on a scale of 1 to 5) the system of voluntary beef labelling before and 
after  the  entry  into  force  of  Regulation  (EU)  No  653/2014  in  relation  to  the 
following  aspects:  effectiveness  of  the  system,  reliability  of  the  system, 
complexity  for  competent  authorities,  complexity  for  producers,  administrative 
burden for competent authorities to implement and run the system, administrative 
costs for producers, capacity to correctly inform consumers. 

By  the  end  of  November  2018,  seven  replies  had  been  received  from  the  following 
associations:  European  Livestock  and  meat  trade  unions  (UECBV),  Federación 
Empresarial  de  Carnes  e  Industrias  Cárnicas  (FECIC),  British  Meat  Processor 
Association  (BMPA),  CULTURE  VIANDE,  EUROCOMMERCE  (3  replies  sent  from 
different associated organisations).  

4.  ANALYSIS AND CONSULTATION RESULTS 

4.1 ANALYSIS OF THE PREVIOUS REPORTS AND EVALUATIONS 

A first assessment of the rules on voluntary beef labelling was carried out in 2004 by the 
European  Commission  in  its  “Report  on  the  implementation  of  Title  II  of  Regulation 
(EC) No 1760/2000”. 

In this report, the Commission noted that: 

 

the  voluntary  labelling  system  was  mainly  used  by  operators  in  business  to 
business relations; 

  contractual agreements between commercial partners were in place to ensure the 

transmission of product specific information; 

 

the role of voluntary labelling schemes was perceived by competent authorities in 
a different way, leading to different criteria to authorise the specifications; 

8 

 
 
 

these  different  approaches  led  to  the  fact  that  cases  of  mutual  recognition  of 
approved specifications were rare which risked disturbing intra-EU trade as well 
as  distorting  competition  between  operators  who  were  not  subject  to  the  same 
restrictions in obtaining approval of their specifications. 

A  second  assessment  was  carried  out  by  The  High  Level  Group  of  Independent 
Stakeholders  on  Administrative  Burdens  ('HLG'),  set  up  in  2007  to  advise  the 
the  Action  Programme  for  Reducing 
Commission  on 
Administrative Burdens in the European Union.  

implementation  of 

the 

In its opinion on Agriculture/Agricultural subsidies of 5 March 2009, the HLG identified 
the  procedure  for  approval  of  voluntary  beef  labelling  specifications  and  the  control 
system laid down in Regulation (EC) No 1760/2000 as a source of administrative burden 
for both operators and administrations. 

Therefore,  the  HLG  advised  the  Commission  to  eliminate  the  notification  requirements 
with regard to the use of additional labelling indications other than those compulsory for 
beef. 

According to the HLG report, this would allow a 15% reduction in administrative burden 
(EUR 21 million, out of a total of EUR 139 million for beef labelling) with respect to the 
identification of bovine animals, without compromising the traceability guaranteed by the 
compulsory labelling elements.  

A third detailed evaluation “Evaluation of EU beef labelling rules” was carried out for the 
Commission in 2014, a few months after the adoption of Regulation (EU) No 653/2014. 

In relation to the voluntary labelling system, the main outcomes were: 

- 

- 

- 

the volume of beef subject to voluntary schemes represented an average of 23% 
of all beef sold in the national markets of the six case study Member States (DE, 
FR, IT, ES, UK, IE). 

stakeholders had diverging views on the consequences of the implementation of 
Regulation  (EU)  No  653/2014  simplifying  voluntary  labelling  rules:  some 
appreciated  the  simplified  procedure;  others  saw  the  risk  of  deteriorating  the 
whole system and loss of consumer confidence. 

consumers were generally able to understand indications provided in accordance 
with  voluntary  rules.  However,  some  consumers  interviewed  complained  that 
labels provided in accordance with the voluntary rules often resulted in crowded 
labels. This led to the paradox whereby labels on beef simultaneously provide too 

9 

 
 
much  information  without  sufficient  explanation,  rendering  them  difficult  to 
understand. 

- 

in  general,  voluntary  indications  did  not  feature  as  factors  that  have  a  major 
influence on consumers’ self-described purchasing behaviour.8 

-  most  stakeholders  highlighted  that  Regulation  (EU)  No  653/2014  brought 

voluntary labelling rules for beef in line with general food labelling rules. 

- 

- 

in some cases, voluntary labels were used only in business to business sales.  

some  retailers  feared  that  the  2014  simplification  of  voluntary  labelling  would 
lead to a proliferation of labels with low levels of guarantee that the information 
provided  on  the  voluntary  label  is  objective,  verifiable  and  comprehensive  for 
consumers,  which  could  damage  the  image  of  the  sector.  Others  considered  it  a 
positive  development:  the  simplification  of  procedures  allows  for  economic 
operators to develop new voluntary claims, responding to consumers’ demand. 

4.2 OUTCOME OF CONSULTATION WITH MEMBER STATES 

In  the  2018  consultation,  the  12  Member  States  that  replied  completely  to  the 
questionnaire represented more than 72% of EU bovine meat production. The results can 
thus be considered as significant and representative of the EU situation.  

Two  Member  States  (PT  and  SI)  maintained  their  national  system  of  approval  by  the 
competent  authority  and  third-party  control  for  voluntary  beef  labelling  after  the  entry 
into force of Regulation (EU) No 653/2014.  

One Member State (IT) simplified the system: information that can be retrieved from an 
official register and documents can be put directly on the label by operators, while the use 
of  further  information  has  to  be  communicated  to  the  competent  authority  but  without 
requiring a formal approval. 

One Member State (FR) reported that, despite simplification, many operators continued 
to use the specifications approved before 2014 with controls from an independent body. 
Other operators switched to other national or European labelling and quality schemes or 

8  The  same  conclusions  were  reached  in  the  Consumer  Market  Study  on  Functioning  of  the  meat 
market  for  consumers  in  the  European  Union  (SANCO/2009/B1/010).  This  report  showed  that 
overall more than half of the consumers look at three key aspects when purchasing meat: the use by/best 
before  date  (68%),  the  price  per  kilogram  (67%)  and  the  price  (67%).  48%  and  44%  of  consumers 
respectively look at the country of origin and the producer when buying meat, elements provided in the 
compulsory labelling. https://ec.europa.eu/info/sites/info/files/meat-market-study-final-report_en_0.pdf. 

10 

 
 
                                                           
implemented  private  certification  schemes 
they 
specifications are no longer checked and approved a priori. 

to 

label 

their  products.  New 

In all other Member States that  replied to  the questionnaire, the system  of notifications 
was  completely  repealed,  as  provided  under  the  new  provisions  on  voluntary  beef 
labelling. 

Very few Member States9 were able to provide information on the market share of bovine 
meat  labelled  with  voluntary  information  before  and  after  the  entry  into  force  of 
Regulation (EU) No 653/2014. 

According to  the evaluation  study, the weighted average of the beef sold  in  accordance 
with voluntary labelling schemes for the six studied Member States (DE, FR, IT, ES, UK, 
IE) from 2014 amounted to 23% of the total beef meat marketed. 

Interestingly,  Member  States  with  a  high  share  of  meat  marketed  under  voluntary 
labelling  schemes  did  not  report  significant  changes  in  the  questionnaire.  Austria 
estimates a 5% decrease in the use of voluntary information (from 80-90% to 75-85 % of 
the meat marketed before and after 2014, respectively). In Sweden, this share increased 
from 90 to 95%, while Denmark reported no significant change. 

The main information provided under the voluntary labelling system were the breed and 
category  of  animals,  together  with  the  region  of  production  and  the  feeding  and 
production systems. 

No  Member  State  reported  difficulty  in  the  transition  from  previous  rules  on  voluntary 
beef labelling to the new simplified rules. 

Simplification was considered the main positive effect by Member States who replied to 
the  questionnaire,  with  10  Member  States  out  of  12  recognising  that  the  new  system 
streamlined the rules by avoiding all the administrative steps needed under the previous 
rules  before  getting  the  approval  of  the  specification.  This  caused  an  appreciable 
reduction of the administrative burden for the competent authorities. 

The harmonisation with other types of meat (pig, poultry, sheep and goat meat) was also 
recognised  as  a  positive  effect  because  the  reasons  for  stricter  rules  on  beef  labelling 
(BSE crisis) are no longer relevant. 

Finally, Member States highlighted that simplified rules allow operators to react quickly 
to market demands if new information on labels becomes necessary. 

9 DK, ES, AT, SE. 

11 

 
 
                                                           
As  possible  negative  consequence  of  the  new  system,  an  increased  risk  of  non-
compliances, due to the abolition of controls from an independent body, was identified by 
three Member States (ES, AT, UK). 

This  is,  however, not  confirmed by data provided on controls  and non-conformity rates 
found on voluntary beef labelling before and after the entry into force of Regulation (EU) 
No 653/2014. Many Member States were not able to provide specific data on controls on 
voluntary labelling, since data are collected in an aggregated way together with those on 
compulsory labelling. Four Member States (FR-IT-AT-PL) were able to provide detailed 
disaggregated data. 

In the first three years of application of the new rules (2015-2017) the average percentage 
of  non-compliances  reported  by  these  four  Member  States  indicated  that  the  non-
conformity rate did not vary significantly and that the new simplified system is not more 
risky than the previous one. 

The  analysis  of  the  assessment  submitted  by  Member  States  on  the  previous  and  new 
rules of voluntary beef labelling - using a point system ranging from 1 (lowest value) to 5 
(highest  value)  -  showed  that  overall  Member  States  considered  positively  the 
simplification introduced in 2014. 

In  particular,  Member  States  were  asked  to  provide  an  assessment  on  the  following 
aspects:  

- 

- 

- 

effectiveness of the system - average points scored: 3.7 before 2014 and 3.5 after 
2014; Member States perceived no substantial differences in effectiveness of the 
system;  the  new  rules  are  still  effective  in  ensuring  a  clear  information  on 
labelling to consumers. 

reliability  of  the  system  -  average  points  scored:  4.0  before  2014  and  3.5  after 
2014;  despite  a  small  decrease  in  the  average  points  scored,  the  results  from 
Member States indicate that the new system is almost as reliable as the previous 
one. The controls carried out by the competent authorities ensure and guarantee a 
good level of trustworthiness in the system. 

complexity  for  competent  authorities  -  average  points  scored:  4.2  before  2014 
(complex and burdensome) and 2.3 after 2014;  in  this case the difference in  the 
assessment  before  and  after  the  introduction  of  the  new  rules  was  important. 
Member  States  believed  that  the  previous  system  was  quite  complex  to  manage 
from the administrations side while the new rules reduced the complexity of the 
system. 

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- 

- 

- 

- 

complexity  for  producers  -  average  points  scored:  4.3  before  2014  (time-
consuming and burdensome) and 2.1 after 2014 (less complex and burdensome); 
also in this case there was an appreciable reduction in the points scored. The new 
system is perceived as much less complex. The process of specification approval 
and the management of the whole system were time-consuming and burdensome 
for operators.  

administrative  burden  for  competent  authorities  -  average  points  scored:  4.1 
before 2014 and 2.2 after 2014; the previous system was considered burdensome; 
the new system allowed a sensible burden reduction for competent authorities. 

administrative costs for  producers:  -  average points  scored:  4.0 before 2014 and 
1.9  after  2014;  the  reduction  in  costs  for  producers  after  the  simplification  was 
perceived as very significant. This is related to the abolition of controls. 

capacity to  correctly inform consumers  - average points scored: 4.4 before 2014 
and 3.7 after 2014; while both the previous and the new system scored high value 
on this aspect, the previous system was considered as slightly more informative to 
consumers.  Avoiding  complex  authorisation  procedures,  operators  can 
communicate  more  effectively  on  information  considered  as  important  for 
consumers. 

From Member States’ consultation, it can be concluded that they considered satisfactory 
the implementation of the new system at administrative level. 

4.3 OUTCOME OF CONSULTATION WITH STAKEHOLDERS 

In the 2014 evaluation7 on EU beef labelling rules, neither compulsory nor voluntary beef 
labelling seemed to play a decisive role in accompanying the beef market recovery after 
the BSE crisis, although both contributed to strengthening consumers’ confidence in beef. 

Stakeholders’ opinions diverge on the usefulness of the previous voluntary beef labelling 
system to sustain the market after the BSE crisis.  

While the industry considered the system to play some role in tackling consumers’ loss of 
confidence following the BSE crisis, retailers thought differently. 

Stakeholders’  opinions  converged  on  one  point:  there  are  no  more  valid  reasons  to 
differentiate beef from other types of meat and food in relation to voluntary information 
to be given to consumers. 

Stakeholders  described  the  previous  rules  on  voluntary  beef  labelling  as  burdensome, 
costly  and  disproportionate,  notably  because  of  the  long  and  complex  process  of 
preparation, approval and control of the relevant specification. 

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In stakeholders’ views, consumers were not aware that different rules were applicable to 
beef  compared  to  other  food  in  relation  to  voluntary  labelling  and  therefore  voluntary 
labelling was not a main discriminant in consumers’ purchasing behaviour. 

With regard to possible difficulties encountered by operators to adapt to the 2014 rules, 
stakeholders did not report any difficulty. Rather the contrary: four stakeholders replied 
that  they  had  not  to  adapt  their  marketing  strategies  and  three  that  they  had  positive 
impacts on their business strategies. 

In  particular,  stakeholders  that  reported  a  positive  impact  considered  that  the  new  rules 
allowed more flexibility in the production chain to react quickly to market opportunities 
and demands. 

The  analysis  of  the  assessment  submitted  by  stakeholders  clearly  showed  that  the  new 
system, being equally reliable as the previous one (average points scored on this aspect: 
4.1 before 2014 and 4.0 after 2014), allowed to achieve important results in terms of: 

- 

- 

- 

- 

- 

effectiveness of the system - average points scored: 2.8 before 2014 and 4.5 after 
2014: the system is now perceived as more effective. 

complexity  and  administrative  burden  for  competent  authorities  and  producers  - 
average  points  scored:  4.4  before  2014  and  2.4  after  2014  in  relation  to 
complexity  for  competent  authorities  and  4.3  before  2014  and  2.3  after  2014  in 
relation  to  complexity  for  producers.  In  stakeholders  opinion  an  appreciable 
reduction in complexity was registered for competent authorities and producers. 

administrative  burden  for  competent  authorities  -  average  points  scored:  4.4 
before  2014  and  2.4  after  2014.  Stakeholders  considered  the  administrative 
burden  for  the  competent  authorities  as  high  under  the  previous  rules,  and 
medium with the new system, related mainly to controls. 

administrative  costs  for  producers  -  average  points  scored:  4.1  before  2014  and 
2.5 after 2014. The new system allowed for  a cost  reduction for producers.  It  is 
worth  noting  that  the  extent  of  this  reduction  was  judged  more  important  by 
competent authorities than stakeholders. 

capacity to  correctly inform consumers  - average points scored: 3.1 before 2014 
and 4.1 after 2014. In stakeholders’ opinion, the new system was considered more 
suitable to provide correct information to consumers. 

The analysis of the replies provided to the questionnaire by stakeholders showed clearly 
that the simplification introduced in 2014 had positive effects on the sector. 

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5.  CONCLUSIONS 

The  simplification  introduced  by  Regulation  (EU)  No  653/2014  provides  for  an 
alignment  with  horizontal  rules  laid  down  in  Regulation  (EU)  No  1169/2011  on  food 
information to consumers. 

In  addition  to  voluntary  beef  labelling  now  following  horizontal  rules  in  all  Member 
States,  some  national  specifics  were  maintained  in  four  Member  States.  Portugal  and 
Slovenia  kept  a  full  national  system  of  notification  and  control,  Italy  simplified  the 
national  system  and,  in  France,  many  operators  continued  using  the  specifications 
approved before 2014 with controls from an independent body. 

Overall,  the  effects  of  simplification  were  evaluated  positively  by  Member  States  and 
stakeholders.  Competent  authorities  and  operators  did  not  find  difficulties  to  introduce 
the new rules at administrative and operational levels. 

The  new  rules  were  considered  positively  by  most  respondents,  allowing  to  achieve 
simplification,  harmonization  with  other  sectors,  reduction  of  the  administrative  burden 
and  improved  capacity  of  operators  to  respond  to  consumers’  demand,  without  causing 
problems  at  intra-EU  trade  level  or  undermining  the  effectiveness  and  reliability  of  the 
system. 

A  risk  of  more  frequent  non-conformities  was  mentioned  by  some  respondents  but 
without  supporting  evidence  confirming  it.  The  analysis  of  available  data  on  non-
conformity  rates  before  and  after  the  introduction  of  the  new  rules  showed  comparable 
levels of non-conformity. 

On the basis of the analysis carried out during previous evaluations and of replies to the 
questionnaires received from Member States and stakeholders, the Commission considers 
that the simplification of voluntary beef labelling under Regulation (EU) No 653/2014 is 
functioning satisfactorily and there is no need to review current provisions on voluntary 
beef labelling. 

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