COMMISSION STAFF WORKING DOCUMENT EVALUATION of the mandatory indication of the country of origin or place of provenance for fresh, chilled and frozen meat of swine, sheep, goats and poultry
Date: 2021-08-10
Institutions: Directorate-General for Agriculture and Rural Development, European Commission
Subjects: consumer information, fresh meat, frozen product, goatmeat, labelling, originating product, pigmeat, poultrymeat, refrigerated product, sheepmeat

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 10.8.2021  SWD(2021) 218 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  of the mandatory indication of the country of origin or place of provenance for fresh, chilled and frozen meat of swine, sheep, goats and poultry                               {SWD(2021) 220 final}  
 
 
TABLE OF CONTENTS 

GLOSSARY ....................................................................................................................... 1 

1.  INTRODUCTION ...................................................................................................... 2 

2.  BACKGROUND TO THE INTERVENTION ........................................................ 4 
2.1.  Description of the intervention and its objectives ..................................................... 4 
2.2.  Baseline and points of comparison ............................................................................ 8 

3.  IMPLEMENTATION/STATE OF PLAY ............................................................... 9 

4.  METHOD .................................................................................................................. 10 
4.1.  Short description of methodology ........................................................................... 10 
4.2.  Limitations and robustness of findings ................................................................... 13 

5.  ANSWERS TO THE EVALUATION QUESTIONS ............................................ 13 
5.1.  Effectiveness ........................................................................................................... 13 
5.2.  Efficiency ................................................................................................................ 25 
5.3.  Coherence ................................................................................................................ 28 
5.4.  Relevance ................................................................................................................ 32 
5.5.  EU added value ....................................................................................................... 34 

6.  CONCLUSIONS ....................................................................................................... 35 
6.1.  Conclusions on effectiveness .................................................................................. 35 
6.2.  Conclusions on efficiency ....................................................................................... 36 
6.3.  Conclusions on coherence ....................................................................................... 37 
6.4.  Conclusions on relevance ........................................................................................ 37 
6.5.  Conclusions on EU added value .............................................................................. 38 
6.6.  Lessons learned ....................................................................................................... 38 

ANNEX 1. PROCEDURAL INFORMATION ............................................................. 40 

ANNEX 2. STAKEHOLDER CONSULTATION ....................................................... 42 

ANNEX 3. IMPLEMENTATION OF THE MANDATORY INDICATION OF 
MEAT ORIGIN IN MEMBER STATES……………………………………………. 47 

 
 
 
 
 
 
 
 
GLOSSARY 

Term or acronym 

Meaning or definition 

BSE  

EU 

FIC Regulation 

OJ 

Bovine spongiform encephalopathy 

European Union 

Regulation  (EU)  No  1169/2011  on 
provision of food information to consumers 

the 

The Official Journal of the European Union 

1 

 
 
 
 
 
 
 
 
1. 

INTRODUCTION 

Swine, sheep, goat and poultry meats are widely consumed in the European Union (EU). 
The  Commission’s  impact  assessment  on  general  food  labelling1  confirmed  that  the 
origin  of  those  types  of  meat  has  appeared  to  be  an  important  consumer  concern. 
Moreover, the mandatory indication of origin for beef and beef products, in place since 
20002  following  the  bovine  spongiform  encephalopathy  crisis  (BSE  crisis),  has  raised 
consumer expectations for labelling of the meat they buy. 
In the framework of the 2011 law on food information (the so-called ‘FIC Regulation’3), 
the EU also imposed a mandatory requirement to declare and label the origin4 of fresh, 
chilled or frozen meats of swine, sheep, goats and poultry5.  

The Commission considered several options to prepare its implementing rules on how to 
apply  the  FIC  Regulation’s  mandatory  labelling  requirements  for  the  aforementioned 
types of meats. The challenge was to find an optimal solution for implementing rules that 
would provide consumers with necessary and helpful information on the meat’s origin in 
a way that: (i) met the mandatory legal requirement; (ii) avoided unnecessary burdens for 
the  meat  supply  chain  and  national  administrations;  (iii)  did  not  raise  prices  for 
consumers; and (iv) did not disrupt trade.  
Following the dedicated impact assessment6, the European Commission adopted in 2013 
the implementing regulation laying down rules for the application of the FIC Regulation 
as  regards  the  indication  of  the  country  of  origin  or  place  of  provenance  for  meats  of 
swine,  sheep,  goat  and  poultry7  (‘Regulation  (EU)  No  1337/2013’).  The  Regulation 
started to apply on 1 April 2015. 

In line with its ‘better regulation’ agenda, the Commission is committed to periodically 
evaluate all EU activities intended to  have an impact  on society and the economy. The 
Commission therefore decided to assess Regulation (EU) No 1337/2013 five years after 
its entry into force. This staff working document presents the evaluation  undertaken by 
the Commission. The underlying analysis takes into the account the situation on the EU 

1   European  Commission  staff  working  document  ‘Impact  assessment  report  on  general  food  labelling 

issues’, January 2008.  

2   Introduced  by  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 (OJ L 204, 11.8.2000, p. 1). 

3   Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on 

4  

the provision of food information to consumers, OJ L 304, 22.11.2001, p. 18.  
In the  FIC  Regulation, the concept of  ‘country of origin’ of a  food is determined in accordance  with 
Articles 23 to 26 of Council Regulation (EEC) No 2913/92. Accordingly, the term ‘country of origin’ is 
reserved for meat obtained from animals born, reared and slaughtered in a single Member State or non-
EU country. ‘Place of provenance’ means any place where a food is indicated to come from (according 
to Article 2(g) of the FIC Regulation.  

5   Combined  nomenclature  headings  0203,  0204  and  0207  of  Annex  XI  to  the  FIC  Regulation.  For  the 
sake  of  consistency  with  the  FIC  Regulation  and  Regulation  (EU)  No  1337/2013,  this  staff  working 
document uses mainly the term ‘swine meat’,  which term corresponds to the term "pig meat" used in 
the evaluation support study and other quoted documents. 

6   For  details  see:  European  Commission,  Impact  assessment:  ‘Mandatory  Origin  Indication  for 

Unprocessed Pig, Poultry, Sheep and Goat Meat’, December 2013. 

7   Commission Implementing Regulation (EU) No 1337/2013 of 13 December 2013 laying down rules for 
the  application  of  Regulation  (EU)  No  1169/2011  of  the  European  Parliament  and  of  the  Council  as 
regards the indication of the country of origin or place of provenance for fresh, chilled and frozen meat 
of swine, sheep, goats and poultry, OJ L 335, 14.12.2013, p. 19.  

2 

 
 
                                                      
single market8 from 2015 onwards and in the EU of 28 Member States9, and covers the 
five  main  evaluation  criteria:  (i)  effectiveness;  (ii)  efficiency;  (iii)  relevance;  (iv) 
coherence;  and  (v)  EU  added  value.  The  evaluation  is  mainly  based  on  the  evaluation 
support  study10  and  outcomes  of  the  stakeholder  consultation  activities,  including  an 
online public consultation11.  

In  addition  to  analysing  Regulation  (EU)  No  1337/2013,  this  evaluation  contributes  to 
the broader assessment of the origin-labelling policy and a report from the Commission 
to the European Parliament and the Council12.  

This  evaluation  is  also  relevant  in  light  of  the  new  comprehensive  approach  to  food 
sustainability  outlined  in  the  ‘farm-to-fork’  strategy13,  which  is  at  the  heart  of  the 
European Green Deal14. Mandatory origin labelling and a new food-labelling framework 
aim  to  empower  consumers  to  make  better  food  choices,  thus  facilitating  the  shift  to 
sustainable consumption and healthy diets. The lessons learned from the evaluation could 
therefore  help  to  better  promote  the  consumption  of  food  that  is  healthy  and  
environmentally friendly.  

8   In the EU’s single market (sometimes called the ‘internal market’) people, goods, services, and money 
can  move  around  freely.  More  information  on  the  EU  single  market  can  be  found  on  the  Europa 
website: https://ec.europa.eu/info/policies/single-market_en.  

9   For the purposes of this evaluation, which covers the period from 2015 onwards, the United Kingdom 
has been considered as a member of the European Union (EU-28). The United Kingdom withdrew from 
the EU on 1 February 2020, entering a transition period until 31 December 2020, during which time EU 
law, with a few limited exceptions, continued to be applicable to and in the United Kingdom. 

10   Agra CEAS and Areté, ‘Evaluation study of mandatory country of origin labelling for certain meats’, 

September 2020. 

11   See  the  link  on  Europa:  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1892-

Evaluation-of-mandatory-country-of-origin-labelling-for-certain-meats/public-consultation. 

12   According to the legal obligation stemming from Article 26(4) of the FIC Regulation. 
13   https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/actions-being-taken-

eu/farm-fork_en. 

14   https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal_en. 

3 

 
 
 
 
                                                      
2.  BACKGROUND TO THE INTERVENTION 

2.1. Description of the intervention and its objectives 

One of the main objectives of the common agricultural policy is to ensure the production 
of high-quality food. Although origin labelling cannot be directly linked with a product’s 
intrinsic  quality  characteristics,  consumers  are  increasingly  interested  in  local  food 
systems and in short supply chains. Consumers also have growing concerns about – and 
expectations  for  –  food  safety,  food  quality,  the  environment,  and  animal-welfare. 
Working alongside other EU policies, the common agricultural policy must continue to 
respond to society’s demands and concerns and help farmers to anticipate developments 
in dietary habits and market preferences.  

In this context, food labelling is a powerful market tool that allows consumers to make 
informed choices.  Interest  in  food-origin  labelling has been  growing in  recent  years, in 
particular  for  animal  products.  There  are  several  reasons  for  this.  For  example, 
consumers  may  perceive  domestically  produced  products  as  being  of  higher  quality  or 
more sustainable and safe, or they may want to support local production. Food producers 
also support origin labelling to promote domestically produced food against imports.  

The FIC Regulation of 2011 allowed for setting implementing rules that could vary from 
one type of meat to another, taking into account: (i) the principle of proportionality; and 
(ii)  the  administrative  burden  for  both  food-business  operators  and  enforcement 
authorities.  In  2013,  the  Commission  carried  out  an  impact  assessment15  and 
commissioned a dedicated study16 to examine how best to display the country of origin or 
place of provenance for meats of swine, sheep, goats and poultry. The impact assessment 
looked at how best to collect and make public information on the most important places 
in the life of the animal: its place of birth, its place of rearing, and its place of slaughter. 
The  results  of  the  analytical  work  showed  that  consumers  were  most  interested  in 
knowing  the  place  where  the  animal  was  reared.  The  analytical  work  also  showed  that 
providing mandatory information on the place of birth of the animal required the creation 
of new traceability systems at farm level, which would create new costs. The analytical 
work  showed  that  the  place  of  slaughter  could  be  indicated  on  a  label  at  an  affordable 
cost and gave valuable information to the consumer. On the issue of what geographical 
level  to  present  this  information  (by  country,  by  region  etc.),  the  evidence  from  the 
impact assessment was that indicating the Member State or non-EU country would be the 
most relevant information for consumers. 

Regulation (EU) No 1337/2013 was adopted in 2013 and entered into force in 2015. The 
Regulation focused on three main objectives: 

  providing consumers with the mandatory origin information for meat, as required 

by the legislation;  

  avoiding  unnecessary  burden  for 

the  meat  supply  chain  and  national 
administrations, avoiding trade disruptions, and preventing increases in prices for 
consumers; 

  ensuring that the information provided is accurate, meaningful and verifiable by 

the competent authorities.  

15   See also footnote Error! Bookmark not defined. for full reference. 
16   LEI Agricultural Economics Research Institute, Wageningen UR (NL), Study on mandatory origin 

labelling for pig, poultry and sheep & goat meat, June 2013.  

4 

 
 
                                                      
The mandatory labelling rules of the Regulation covered fresh, chilled and frozen meat in 
any  form  of  cut  (including  minced  meat)  that  was  unprocessed  and  pre-packed.  Meat 
sold  ‘loose’  at  retail  (e.g.  from  a  butcher)  and  packed  on  the  sales  premises  at  the 
consumer’s request was out of scope of the Regulation. For the concerned types of meat, 
the Regulation introduced the following obligations:  
 
 

to indicate the country of rearing, slaughtering or origin on the label;  
to put in place an appropriate identification and registration system which allows at 
each  stage  of  production  and  distribution,  to  (i)  ensure  the  link  between  the  meat 
and  the  animal  from  which  it  is  obtained;  and  (ii)  to  make  it  possible  to  send  the 
information  on  the  country-of-origin  indications  together  with  the  meat.  These 

obligations are implemented through a set of practical measures, as described below. 
  Article  3  of  the  Regulation  requires  food-business  operators  to  have  in  place  a 
traceability system to ensure: (i) the link between the meat and the animal or group 
of animals from which it has been obtained; and (ii) that reliable information is sent 
along the supply chain until the final consumer. 

  Article  4  of  the  Regulation  contains  rules  for  the  formation  of  batches  of  meat17, 
since these batches can greatly affect the normal butchering workflow and sourcing 
practices.  

  Article  5  of  the  Regulation  sets  out  criteria  to  link  the  production  phases with  the 
information  displayed  on  labels,  since  animals  are  often  reared  in  more  than  one 
country. 

  Article 6 of the Regulation allows a derogation for meat from non-EU countries that 
is imported to be placed on the EU market and reared and/or slaughtered in a non-
EU country. 

  Article  7  of  the  Regulation  lays  down  ‘flexibility’  measures  for  minced  meat  or 
trimmings18.  Specific  simplified  apply  for  those  categories  of  products,  since  the 
production  volumes  and  the  processing  chain  make  it  difficult  to  easily  ensure 
physical separation of the different batches. 

  Article 8 of the Regulation allows food-business operators19 to add to the mandatory 
indications on the label other supplementary information referring to the provenance 
of the meat, given that there may be consumer interest in this information. 

The intervention logic is illustrated in Figure 1. It starts with the problems identified, and 
then  moves  to  objectives,  instruments,  expected  outputs  and  possible  impacts. 

17   ‘Batch’  means  meat  obtained  from  a  single  species  (swine,  sheep,  goat  or  poultry)  with  or  without 
bone,  whether  or  not  cut  or  minced,  that  has  been  cut,  minced  or  packed  under  practically  identical 
conditions (as defined in Article 2(b) of Regulation (EU) No 1337/2013). 

18   ‘Trimmings’  means  small  pieces  of  swine,  sheep,  goat  or  poultry  meat,  recognised  as  fit  for  human 
consumption  and  produced  exclusively  during  trimming  operations,  when  boning  carcasses,  or  when 
cutting up meat (as defined in Article 2(a) of Regulation (EU) No 1337/2013). 

19   ‘Food-business  operator’  means  the  natural  or  legal  persons  responsible  for  ensuring  that  the 
requirements of food law are met within the food business under their control, as defined in Article 3(3) 
of Regulation (EC) No 178/2002 of the  European Parliament and of  the  Council of 28  January 2002 
laying  down  the  general  principles  and  requirements  of  food  law,  establishing  the  European  Food 
Safety Authority and laying down procedures in matters of food safety (OJ L 31, 1.2.2002, p. 1). 

5 

 
 
                                                      
 
Figure 1:  Model of intervention logic – summary 

Legend: CAs: national competent authorities; third-country: non EU Country; SANTE F-reports: audits and analysis of DG Health and Food Safety related to the beef sector, see notably: 
https://ec.europa.eu/food/audits-analysis/overview_reports/index.cfm, http://ec.europa.eu/food/fvo/specialreports/rep_details_en.cfm?rep_id=5; https://ec.europa.eu/food/audits-
analysis/audit_reports/details.cfm?rep_id=784&rep_inspection_ref=xxx. 

Source: Evaluation support study. 

6 

 
 
 
 
 
2.2. Baseline and points of comparison 

The mandatory origin provisions developed in the FIC Regulation apply, among others, 
to swine, sheep, goat and poultry meats. These provisions were based on similar existing 
rules adopted in 2000-2010 for other foods i.e. honey, fruit, vegetables, fish, beef, beef 
products, olive oil, bananas, wine, hops, and eggs. 

The underlying motivations for setting the mandatory origin  labelling for various types 
of food were different.  For beef  and beef products,  it was the  BSE crisis.  For all other 
foods, the rationale was instead the close link between the food’s origin and the specific 
characteristics of the food in question. 

Because the rules on beef labelling had been in place for a decade before, the extension 
of compulsory origin labelling to swine, sheep, goat and poultry meats ensured that the 
bulk  of  unprocessed  meat20  consumption  in  the  EU  was  covered  by  the  rules  requiring 
the origin of meat to be clearly labelled.  

Before  Regulation  (EU)  No  1337/2013,  there  was  no  systematic  and  harmonised 
information on the country of origin and place of provenance on labels for swine, sheep, 
goat  and  poultry  meats  available  on  the  EU  single  market.  However,  as  consumers’ 
sensitivity  to  the  origin  of  food  grew  over  the  years,  private  certification  schemes  on 
meat origin were developed. A study from 201221 identified 901 certification schemes in 
the  EU-28  in  total  (including  geographical  indications).  More  than  half  of  those 
certification  schemes  (468  schemes  in  total)  concerned  meats  and  their  origin. 
Information on meats and their origin was covered by 60% of these 468 schemes. A 2012 
study showed that origin information at country or regional level was  already available 
on a voluntary basis for around 86% of meat sold in the EU22. 

In  the  2013  impact  assessment  carried  out  in  preparation  for  the  legislation,  the 
Commission considered the following three policy options:  
 

the simple model with mandatory labelling that indicates only an origin in an EU or 
non-EU country (origin EU/non-EU/mixed);  
the  intermediate  model,  with  mandatory  labelling  of  country  of  rearing  and  of 
slaughter; 
the  beef  model,  including  all  the  information  in  the  intermediate  model,  but  also 
adding the mandatory indication of the country of birth. 

 

 

During  the  2013  impact  assessment,  the  Commission  chose  to  follow  the  intermediate 
model based on mandatory labelling of country of rearing and of slaughtering. The other 
two  policy  options  were  discarded  as  either  not  providing  meaningful  information  to 
final  consumers  (the  option  based  on  the  simple  model),  or  as  too  burdensome  (the 
option based on the beef model). The chosen option was considered optimal to provide 
accurate, clear and useful information on the origin of the meats to consumers, while: (i) 
avoiding  excessive  administrative  burden  for  operators  and  competent  authorities;  and 
(ii) having minimal effects on the standard practice.  

20   According to the Commission impact assessment of 2013, other meats (mainly horse, rabbit and game) 

accounted only for less than 1% of EU meat consumption.  

21   Ipsos and London Economics Consortium, Consumer Market Study on the Functioning of Voluntary 

Food Labelling Schemes for Consumers in the European Union, December 2013. 

22   GfK  EU3C,  EU  Custom  Research  and  Coordination  Centre,  Consumer  Market  Study  on  the 

Functioning of the meat market for consumers in the European Union, December 2012.  

7 

 
 
                                                      
It should also be noted that the existing traceability systems23 were considered already fit 
for purpose, i.e. they provided all the information needed for operators to correctly label 
the meat  for the country of origin  or place of provenance without generating excessive 
new costs or administrative burden. 

Furthermore,  the  risk  of  ‘renationalisation’  of  meat  consumption  (with  consumers  only 
consuming  meat  raised  and  slaughtered  in  their  own  country)  would  have  been  higher 
under  the  model  with  mandatory  indication  of  the  country  of  birth  (beef  model),  thus 
affecting intra-EU trade and hampering the functioning of the EU single market. 

3. 

IMPLEMENTATION/STATE OF PLAY 

Regulation  (EU)  No  1337/2013  was  directly  applicable  in  all  Member  States  from 
1 April 2015.  For some  Member States (Denmark,  Ireland  and  Italy), national law  was 
needed  to  set  up  a  specific  control  regime.  In  other  countries  (Greece,  Poland  and 
Romania),  the  existing  national  rules  were  amended  to  ensure  compliance  with  the 
Regulation.  

In some Member States, national rules and initiatives going beyond the Regulation have 
been  adopted,  or  at  least  have  been  considered.  In  Greece  and  Poland  for  example, 
national  legislation  specified  additional  requirements  to  provide  information  on  the 
country of origin for fresh, chilled and frozen meat of swine, sheep, goat and poultry that 
is sold ‘loose’ (i.e. not pre-packed). Finland and France have issued additional national 
rules  to  extend  the  mandatory  indication  of  origin  or  place  of  provenance  to  two  other 
categories of meat: meat used as an ingredient and meat sold in the catering sector.  

The  evaluation  has  also  identified  private,  voluntary,  quality-assurance  schemes  in 
Member  States:  some  explicitly  focusing  on  origin  (in  Denmark  and  Ireland),  or  only 
implicitly  referring  to  origin  (in  the  Netherlands).  In  Germany  and  Spain,  voluntary 
schemes have also provided information on regional origin, sometimes covering products 
out of the Regulation’s scope.  

For  details  on  the  implementation  approaches  taken  by  the  Member  States  selected  for 
the evaluation and an inventory of their national rules on country of origin, see Annex 3.  

The  surveyed  competent  authorities  of  the  concerned  Member  States    did  not  declare 
systematic  challenges  or  problems  with 
(EU) 
No 1337/2013.  However,  the  information  gathered  during  the  evaluation  process  from 
literature review, desk research and as part of Member-State case studies did reveal some 
potential barriers and new challenges for implementation of the EU rules. These potential 
barriers and new challenges are summarised in the bullet points below. 

implementation  of  Regulation 

  There are potentially misleading practices in the implementation of Regulation 
(EU) No 1337/2013. Some Member States set up national rules and initiatives going 
beyond  the  current  scope  of  the  Regulation  in  response  to  the  concerns  of 
stakeholders  (mainly  consumers)  and  to  meet  stakeholders’  additional  needs. 
Although  the  national  initiatives  and  additional  needs  do  not  raise  problems  of 
implementation  of  the  Regulation  as  such,  they  indicate  consumers’  concerns  that 

23   Systems  set  up  in  compliance  with  EU  legislation  on  food  law  and  food-safety  procedures  and  in 

conjunction with the legislation on the identification and registration of livestock. 

8 

 
 
                                                      
 

they  may  be  misled,  and  pose  challenges  for  ensuring  a  level-playing  field  across 
operators.  
Some  surveyed  national  competent  authorities  have  reported  difficulties  in 
monitoring compliance. The resource constraints they face lead them to prioritise 
their focus by  checking  compliance  with  food-safety  rules only (and not  the other 
aspects of the legislation). Some national competent authorities also face challenges 
in  the  feasibility  and  level  of  monitoring  that  can  be  carried  out  due  to  the 
fragmented structure of the supply chain.  

  There have been difficulties in implementing the batch requirements. This has 
been identified as a problem in a few Member States that rely on imports – mainly 
in  the  swine  meat  and  poultry  meat  sectors.  The  fact  that  meat  of  several  origins 
may be involved posed challenges for operators, slaughterhouses and cutting plants 
that source from multiple origins.  

The three issues listed above, as well as the unintended side effects of the Regulation, are 
analysed further in Section 5 of this staff working document.  

4.  METHOD 

4.1. Short description of methodology  

The  analysis  presented  in  this  staff  working  document  is  mainly  based  on  the 
corresponding  evaluation  support  study10.  The  evaluation  support  study  applied  several 
interlocking  methodologies  to  answer  a  series  of  evaluation  questions  and  therefore 
provides qualitative and quantitative evidence.  

To ensure the completeness, reliability and robustness of the data used in the evaluation, 
a  variety  of  different  methods  and  tools  were  used.  These  included  desk  research, 
stakeholder  surveys  (of  consumers,  supply-chain  operators,  and  national  competent 
authorities)  and  case  studies.  Those  methods,  supplemented  by  the  online  public 
consultation, were also used to collect the views of the main stakeholders. Case studies 
are  briefly  outlined  below,  while  other  tools  are  included  in  the  synopsis  of  the 
stakeholder consultation in Annex 2.  

Twenty-one case studies across 10 Member States were carried out for the purpose of the 
evaluation.  The  case  studies  were  selected  to  ensure  their  representativeness  in 
production, consumption, trade volume and geographical coverage. More concretely, the 
selection  was  based  on  a  qualitative  assessment  of  relevant  quantitative  data  for  the 
following five key criteria:  

 
 
 
 
 

level of per capita consumption; 
self-sufficiency – extent to which domestic production fulfils consumption;  
production level and export; 
balance of trade of live animals;  
farm structure (specialisation and size).  

These  five  criteria  were  relevant  and  useful  for  selecting  case  studies  in  the  swine  and 
poultry sectors, but could not be applied in the sheep and goat meat sectors. This is due 
to the very low levels of consumption of sheep and goat meat in most Member States and 
the  concentration  of  production  in  a  handful  of  Member  States24.  The  case  studies 
selected are summarised in Table 1.  

24   For more info on production, trade and apparent use of meat, see also DG AGRI-JRC dashboard 

https://datam.jrc.ec.europa.eu/datam/mashup/PROD_TRADE_USE/index.html.  

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Table 1. Selected case studies - main characteristics for the swine and poultry meat sectors 
and explanations for the sheep and goat meat sectors.  

Member State 

Swine meat sector 

Poultry meat sector 

Sheep & goat meat sector 

Denmark 

France 

Germany 

Notable consumers 
Net exporters  
Specialised farms  
Generally 
animals  
Moderate  consumption  and 
broadly 
self-sufficient 
(farming systems differ)  

exporting 

live 

Moderate  to  high  consumption 
with  low  production  in  deficit; 
generally small sized farms  

No case study in the sector 

Notable 
exporters; 
sized farms  

producers 

and/or 
moderate-to-small 

Fairly  high  consumption  in 
strong deficit 

Large  consumption  and  net 
exporters  with  more  mixed 
farms;  generally 
importing 
live animals  

Notable producers and (generally) 
net  exporters  generally  reliant  on 
live  animal  imports;  large  farms; 
moderate-low consumption  

No case study in the sector 

Greece 

No case study in the sector 

Low consumption and production 
in broad equilibrium  

Very  high 
with deficit 

consumption 

Ireland 

Italy 

Large consumption and net 
exporters with more mixed 
farms; generally importing 
live animals  

Notable or moderate 
consumption and in deficit 
(farming systems differ) 

Netherlands 

No case study in the sector 

Moderate to high consumption; 
broad equilibrium; large industrial 
farms (live animal flows vary) 

High consumption with 
strong surplus 

No case study in the sector 

No case study in the sector 

Notable producers and (generally) 
net exporters generally reliant on 
live animal imports; large farms; 
moderate-low consumption  

No case study in the sector 

Poland 

Romania 

Spain 

Moderate consumption and 
broadly self-sufficient 
(farming systems differ) 

Notable exporters and producers 
with moderate-to-small sized 
farms  

No case study in the sector 

Moderate-to-small producers 
in deficit with low 
consumption levels; 
generally with smaller, 
mixed farms  

Notable consumption and net 
exporters  with 
industrial 
farms;  generally  exporting 
live animals  

No case study in the sector 

Fairly high consumption in 
very strong deficit 

Moderate to high consumption; 
broad equilibrium; large industrial 
farms (live animal flows vary) 

Fairly  high  consumption  in 
surplus 

Source: own compilation based on the evaluation support study.  

10 

 
 
 
 
 
Figure 2:  Data-collection tools  

Source: IHS Markit & Areté, PowerPoint presentation ‘Evaluation study of mandatory country-of-origin labelling for certain meats’, September 2020.  

11 

 
 
 
 
4.2. Limitations and robustness of findings 

Thanks to  the sound analytical  framework and the methodological  approach (including 
the  quantitative  and  qualitative  approaches),  it  was  possible  to  cover  the  scope  of  the 
evaluation set out in the roadmap25, notably: 

 

 

 

to  assess  whether  the  rules  on  food  information  for  consumers  on  the  mandatory 
origin  labelling  for  certain  meats  as  applied  in  Member  States  are  effective, 
efficient, coherent, relevant, and bring EU added value; 
to  present  an  overview  of  the  implementation  of  the  Regulation  in  every  EU 
Member  State,  in  order  to:  (i)  identify  any  administrative  burden;  (ii)  identify 
existing  barriers/obstacles;  (iii)  identify  best  practices  and/or  new  challenges;  and 
(iv) propose recommendations for adjustments; 
to provide valuable input for the overall assessment of the origin-labelling policy. 

The consistency of the collected data was checked  through cross-variable analysis. The 
sources of evidence described in the methodology were deemed accurate and relatively 
robust for the purposes of the evaluation. Nevertheless, the findings from the evaluation 
support study faced data limitations (limitations of data availability and data reliability26) 
and  led  therefore  to  less  granular  results  and  an  uneven  level  of  detail  for  the  five 
evaluation themes.  

5.  ANSWERS TO THE EVALUATION QUESTIONS 

5.1. Effectiveness  

5.1.1. Effectiveness of mandatory origin-labelling rules 

The evaluation assessed how and to what extent the main objectives of Regulation (EU) 
No  1337/2013  were  achieved.  To  recall,  the  Regulation  laid  down  the  following  main 
objectives: (i) to provide clear, accurate and meaningful information to consumers; (ii) to 
avoid  unnecessary  burden on operators, trade,  administration and the environment; and 
(iii)  to  ensure  that  the  information  provided  is  reliable  and  can  be  checked  by 
enforcement authorities.  

Provide clear, accurate and meaningful information to consumers 

To assess whether the information on meat origin provided to consumers is meaningful, 
the external evaluator conducted a consumer survey.  

Overall,  the  surveyed  consumers  considered  labelling  of  meat  origin  to  be  important 
information at the point of purchase. Most consumers (62%) were either ‘quite’ or ‘very 
satisfied’  with  the  current  level  of  information  provided,  a  third  (32%)  were  ‘neutral’, 
and only 6% were either ‘quite’ unsatisfied or ‘very unsatisfied’. Those respondents who 
were  not  satisfied  with  the  information  on  meat  origin  that  they  receive  gave  the 

25   The  evaluation roadmap can  be  consulted on the  Europa  website:  https://ec.europa.eu/info/law/better-
regulation/have-your-say/initiatives/1892-Evaluation-of-mandatory-country-of-origin-labelling-for-
certain-meats. 

26   Notably:  (i)  incomplete  or  inaccurate  data  on  production;  (ii)  inconsistencies  between  the  various 
sources of trade data (e.g. from Eurostat and the Association of Poultry Processors and Poultry Trade in 
the EU Countries (AVEC)); and (iii) limitations on data availability for intra-EU trade data compared 
for example with extra-EU trade due to the different reporting obligations for operators. 

12 

 
 
                                                      
following main reasons for their dissatisfaction: too little information (46%), information 
not being clear enough (32%), and information that was confusing (15%).  

Consumer satisfaction should be interpreted alongside consumers’ lack of understanding 
of  the  key  terms  and  definitions  used  in  Regulation  (EU)  No  1337/2013.  Only  5%  of 
consumers  correctly  understood  the  main  terms  of  the  Regulation,  i.e.  ‘reared  in’, 
‘slaughtered  in’  and  ‘origin’.  The  consumer  survey  revealed  that  29%  of  consumers 
correctly understood two of the three terms, and that 44% correctly understood only one 
of the terms, while more than a fifth (22%) did not correctly understand any of the terms. 
Consumers  who  correctly  understood  all  three  terms  are  more  likely  to  be  ‘quite 
satisfied’ with the information provided and less likely to have a ‘neutral’ opinion.  

The  understanding  of  consumers  varied  across  Member  States  as  set  out  in  the  bullet 
points below. 
  Consumers in Austria were more likely to correctly understand the term ‘reared in’, 
while those in Bulgaria, Latvia, Portugal, Romania and Hungary were less likely to 
correctly understand this term. 

  Consumers  in  Austria  were  also  more  likely  to  understand  correctly  the  term 
‘slaughtered  in…’  as  were  those  in  Czechia,  Greece,  Lithuania  and  Slovenia. 
Consumers in Belgium, Bulgaria, the Netherlands and Slovakia were the least likely 
to correctly understand this term. 

  Consumers  in  Bulgaria,  Croatia,  Estonia,  Finland,  Greece,  Hungary,  Romania, 
Slovakia  and  Slovenia  were  more  likely  to  understand  correctly  the  term  ‘origin’ 
than consumers in Austria. Consumers in Belgium were more likely to say that they 
did not understand the term than consumers in other Member States. 

The  most  correctly  understood  term  was  ‘slaughtered  in’  (62%),  followed  by  ‘origin’ 
(29%) and then ‘reared in’ (26%). It is also worth noting that the correct understanding 
of the term ‘origin’ appears to have declined between 2012 and 201927.  

The consumer survey has also provided some conclusions on how consumers accept the 
definitions  behind  the  terms  ‘reared  in’,  ‘slaughtered  in’  and  ‘origin’,  as  set  out  in  the 
bullet points below. 
 

Some  consumers  (notably  in  Finland  and  Sweden)  were  likely  to  consider 
themselves  misled  by  the  labelling  on  rearing,  particularly  as  regards  the  rearing 
period (the time spent to rear the animal). 

  Consumers  in  several  Member  States  (notably  Belgium,  Finland,  France,  Italy, 
Latvia,  the  Netherlands,  Slovakia,  Slovenia  and  Sweden)  seemed  to  be  misled  by 
labels indicating the place of slaughter without indicating the place of rearing.  
  On the term ‘origin’, the evidence of potential misunderstanding is rather mixed: the 
main expectation appears to be that the animal should be born in the named country, 
which is consistent with the definition of the term.  

Finally,  consumers  were  asked  how  they  use  the  labelling  information  in  their  meat-
purchasing decisions. According to the consumer survey, only 17% of people considered 
country of origin as the criterion they looked at first when making a purchase decision. 
This  means  that  country  of  origin  is  less  important  for  consumers  than  price  (cited  by 
31% of consumers as the first criterion they looked at) and expiry date (cited by 29% of 

27   In comparison to the survey of the Bureau Européen des Unions de Consommateurs (2013), ‘Consumer 
survey on origin labelling on food’, (2013), https://www.beuc.eu/publications/2013-00043-01-e.pdf. 

13 

 
                                                      
consumers).  Overall,  33%  of  consumers  indicated  origin  either  as  the  first  or  second 
criterion  they  looked  for  in  their  meat  purchases.  The  results  of  the  consumer  survey 
corroborate  those  from  the  supply-chain  survey:  most  consumer  organisations  said  that 
consumers  look  at  origin  information  all  the  time  or  often  in  their  meat-purchasing 
decision.  It  should  be  noted  that  the  2019  Eurobarometer  on  food  safety28  found  that 
origin was the most important purchase criterion, ahead of price. The difference between 
these findings may be due to ‘prompting’ qualities in the Eurobarometer question, which 
makes it more likely that consumers will chose and provide a positive answer.  

On willingness to pay for meat from a preferred origin, a quarter (25%) of the surveyed 
consumers  said  that  they  usually  use  origin  indications  simply  to  choose  between  two 
products of the same price, and 23% of them either did not know or did not pay enough 
attention  to  notice  the  price  difference  between  meat  from  different  countries.  Among 
respondents  who  used  an  origin  indication  to  inform  their  purchasing  decisions,  more 
than half (52%) said that they pay more for meat from their preferred country, but most 
pay only a little bit more.  

This finding should be treated with some caution, since actual consumer behaviour often 
deviates  from  the  consumer  preferences  stated  in  surveys29.  This  is  a  relevant 
consideration  as  origin  labelling  could  imply  higher  prices  for  the  final  products. 
Furthermore, it should also be noted that interviews with EU-level associations suggested 
that  the  fresh-meat  retail  offer  in  most  Member  States  is  largely  restricted  to  domestic 
sources and, in practice, consumers usually do not have any choice to make.  

Ensure that  the information provided is  reliable and can be checked by enforcement 
authorities 

Analysis of the results from the supply-chain survey showed that three quarters (73%) of 
the respondents systematically receive information on the animals or groups of animals 
(batches) from which the received meat is produced. Results of the supply-chain survey 
also  showed  some  simplification  in  information  transmission  across  the  supply  chain: 
41% of operators declared that they had received the full information from the previous 
link in the chain. However, only 30% said that they had passed this full information on to 
the next link in the chain. 

A fifth (20%) of national competent authorities told the survey that full information on 
rearing periods is  passed on through the supply chain.  A further fifth  (20%) stated that 
abbreviated  information  is  passed  on.  Some  27%  of  national  competent  authorities 
indicated  that  a  combination  of  the  two  approaches  is  used.  A  third  (33%)  of  national 
competent authorities said that they did not know what information is provided (N=15). 

28   See: European Food Safety, ‘2019 Eurobarometer on Food Safety in the EU’, 

https://www.efsa.europa.eu/en/corporate/pub/eurobarometer19. 

29   See: European Commission (2015), ‘Study on the mandatory indication of country of origin or place of 
provenance of unprocessed foods, single ingredient products and ingredients that represent more than 
50% of a food’; 
https://ec.europa.eu/food/sites/food/files/safety/docs/labelling_legislation_final_report_ew_02_15_284
_en.pdf. 

14 

 
                                                      
All EU-level organisations agreed that the existing traceability system under Regulation 
(EC)  No  178/200230  setting  out  traceability  requirements  on  food-business  operators 
facilitates compliance with  Regulation  (EU) No  1337/2013  through the transmission of 
reliable  information.  Furthermore,  the  survey  of  national  competent  authorities  showed 
that  the  traceability  systems  currently  in  place  are  ‘fully  effective’  (47%  of  competent 
authority respondents agreed with this) or ‘moderately effective’ (41% agreed). 

On  verifying  the  reliability  of  the  information  on  the  label,  most  national  competent 
authorities  (60%)  reported  that  they  did  not  encounter  any  problem  in  checking  the 
accuracy of the label. The remaining 40% of surveyed authorities reported the following 
problems:  (i)  rearing  periods  not  being  specified;  (ii)  incorrect  construction  of  batches; 
(iii)  intentionally  (and  unintentionally)  incorrect  paperwork  where  systems  are  not 
electronic;  (iv)  lack  of  transmission  of  specific  (and  required)  information;  and  (v)  the 
aggregation  of  batches  of  poultry  meat  with  different  origin  indications  meaning  that 
labels list more than one country of origin. High rates of non-compliance, notably due to 
difficulties encountered by the national competent authority in checking the information, 
were reported in two Member States: the Netherlands and Romania.  

The  following  bullet  points  give  details  on  the  reported  specific  (i.e.  non-systemic) 
problems in each meat sector. 
 
In the swine meat sector: 
-  incorrect  labelling  in  the  period  immediately  after  entry  into  force  of  the 
Regulation,  and  some  initial  inspection  problems  where  the  criteria  used  in  the 
beef sector were applied erroneously (in Spain); 

-  teething problems (in Germany); 
-  non-commercial  holdings  where  traceability  is  unlikely  to  be  documented 

properly (in Ireland, Italy and Romania). 

 

 

In the poultry meat sector: 
-  misleading  practice  of  selling  imported  loose  chicken  fillets  alongside  whole 
birds,  with  the  latter  clearly  labelled  as  being  of  domestic  origin  in  butchers’ 
shops (France, Greece and Ireland);  

-  circumventing the requirements of the Regulation by lightly processing imported 

poultry meat so that it falls outside the Regulation’s scope (Germany).  

In the sheep and goat meat sector: 
-  sheep  meat  and  goat  meat  sold  ‘loose’  at  retail  where  the  display  arrangement 

implies the meat is domestic, when it is in fact imported (e.g. Greece)31; 

-  origin information on imported meat of lambs is much less prominent than other 

indications which suggest a solely domestic provenance (Spain). 

-  Non-commercial flocks of sheep and goats kept in backyard and then slaughtered 
for  local  consumption  (i.e.  not  entering  the  commercial  supply  chain)  are  often 
not identified (Romania). 

30   Regulation  (EC)  No  178/2002  of  the  European  Parliament  and  of  the  Council  of  28  January  2002 
laying  down  the  general  principles  and  requirements  of  food  law,  establishing  the  European  Food 
Safety Authority and laying down procedures in matters of food safety (OJ L 031 1.2.2002, p. 1). 

31   This problem stems from large price differences between domestic and imported meat, coupled with a 
supply deficit during peak demand periods of the  year (such as Easter), and  was sufficient to prompt 
national rules to ensure clarity. 

15 

 
 
 
                                                      
Avoid unnecessary burdens on operators, trade, administration and the environment 

From the outset, Regulation (EU) No 1337/2013 was designed to provide an opportunity 
to reduce burdens on supply-chain actors.  
  Article  4  (on  the  definition  of  a  group  of  animals)  and  Article  6  (allowing  a 
derogation for meat imported from non-EU countries) aimed at reducing the burden 
of monitoring.  

  Definitions  and  derogations  used  under  Article  5  (laying  down  rearing  periods  by 
species) (and more precisely: (i) the exclusion of piglets and day-old chicks from the 
labelling  obligation;  and  (ii)  the  possibility  of  putting  more  than  one  country  of 
rearing and slaughter on a label) aimed at simplifying the labelling and then reducing 
the burden on operators.  

  The  derogations  provided  under  Articles  6  and  7  (i.e.  the  derogation  to  use 
‘EU’/‘non-EU’  designations  on  minced  meat  and 
trimmings)  provided  an 
opportunity  to:  (i)  reduce  the  burden  on  operators  to  segregate  meat  of  different 
origins;  and  (ii)  give  operators  more  flexibility  to  combine  meat  to  achieve  the 
required characteristics.  

The  evidence  gathered  in  the  evaluation  demonstrated  that  definitions  and  derogations 
played  a  central  role  in  limiting  administrative  burden  on  operators  and  national 
competent authorities. Respondents to the supply-chain survey said that they considered 
all  provisions  of  the  Regulation  to  be  useful  for  simplified  compliance  with  the 
requirements, but to differing degrees. At least half the respondents thought that Articles 
4,  6  and  7  simplified  the  provisions  to  a  ‘great  extent’  or  to  a  ‘moderate  extent’.  In 
contrast, 38% of respondents did not feel that Article 5 on rearing periods provided any 
simplification. Overall, Articles 5 and 7 appeared less relevant in the Member States that 
had  national  origin  schemes  that  pre-dated  the  Regulation  (e.g.  France),  because  the 
national rules imposed stricter definitions and rules. 

When  assessing  the  simplifications  by  type  of  species  processed,  the  picture  is  more 
complex, as set out in the following bullet points. 
  The  poultry  meat  sector:  Operators  in  the  poultry  meat  sector  were  more  likely, 
than  operators  in  other  sectors,  to  find  that  Article  4  provided  a  simplification,  and 
that Article 6 did  not  provide a simplification.  In addition, operators in  the poultry 
meat sector said that Article 5 was useful, because it meant that the location of birth 
did not have to appear on a label, thus reducing the burden where poultry were reared 
in different locations (this was the case in Ireland).  

  The  swine  meat32  sector:  The  case  studies  found  little  evidence  that  Articles  4-8 
resulted in  clear reductions in  burden in  the swine meat  sector. However, operators 
said that Article 5 made a significant contribution to reducing the burden (in Poland), 
and  Article  7  was  mentioned  as  having  had  a  small  positive  impact  (in  Germany). 
Article  7  was  also  not  considered  relevant  when  imported  live  pigs  are  used  in  the 
processed meat sector where the product does not carry provenance indications (this 
was the case in Italy). 

32   For  the  sake  of  consistency  with  the  texts  of  the  legal  acts  to  which  the  evaluation  refers  (notably 
Regulation  (EU)  No  1337/2013  and  ‘FIC  Regulation’),  the  term  ‘swine  meat’  is  used  in  this  staff 
working document, and corresponds to the term ‘pig meat’ used in the evaluation support study.  

16 

 
                                                      
  The sheep and goat meat sector: as  with  the other sectors, the  case studies found 
little evidence that Articles 4-8 reduced the burden in the sheep/goat meat sector; it 
was noted in one Member State (Spain) that the overall burden is not substantial in 
any case.  

National competent authorities were also asked to what  extent various provisions of the 
Regulation  simplified their task of checking operators’ compliance with  the Regulation. 
Articles  4  and  6  were  both  seen  by  national  competent  authorities  as  ‘greatly’  (38%  of 
respondents) or ‘moderately’ simplifying checks (46% of respondents). Respondents had 
similar  views  of  Article  5  and  Article  7.  They  saw  Article  8  (allowing  additional 
voluntary information) as creating the least simplification. At least 12 national competent 
authorities found that the implementation of the Regulation had resulted in extra work to 
ensure that operators are complying with the provisions. However, the extra work was not 
generally  considered  substantial  and  was  largely  related  to  training  costs  and  the 
adjustment  of  monitoring  procedures  and  manuals,  while  ongoing  monitoring  costs 
appeared to be minimal.  

the  2013 

impact  assessment, 

the  European  Commission  reported 

In 
the 
environmental  impacts  of  introducing  country-of-origin  labelling  were  expected  to  be 
minimal.  Most  interviewed  EU  organisations  said  that  Regulation  (EU)  No  1337/2013 
had not had any impact on the environment. However, case studies and interviews with 
EU organisations suggested the Regulation had had some impact on emissions (a positive 
or negative impact depending on the emissions and on the nature of the change induced) 
and on waste (a negative impact linked to replacement of the unused existing packaging).  

that 

5.1.2. Effect of mandatory origin labelling on the EU single market 

The Commission’s impact assessment of 2013 raised, as one of the key concerns, linked 
an issue of possible ‘renationalisation’ of trade as a result of the introduction of general 
mandatory rules on labelling of the swine, sheep, goat and poultry meats. The situation 
where consumers only buy meat produced in their own country, might therefore have a 
negative impact on the efficiency and competitiveness of the meat industry. 

The  evaluation  analysis  confirmed  there  were  two  tendencies  that  could  lead  to 
renationalisation:  consumer  ‘nationalism’  (i.e.  consumer  preference  for  meat  seen  as 
produced in their own country); and retailers choosing to reduce the risk of mislabelling 
by limiting the number of meat suppliers they deal with.  
Former surveys33 have already demonstrated that consumers consider products from their 
own  country  as  being  safer  and  of  higher  quality.  These  surveys  also  showed  that 
consumers  are  willing  to  support  their  national  and  local  supply  chain.  The  survey 
carried  out  in  November  and  December  2019  as  part  of  the  evaluation  showed  that 
consumers  tended  to  be  particularly  ‘nationalist’  when  it  came  to  fresh  meat.  The 
national  preference was  stronger in  some Member States than others  and seemed to  be 
related  to  a  lack  of  exposure  to  imported  products.  Consumers  tended  to  be  less 
‘nationalist’ in smaller Member States which are not able to meet domestic demand with 
domestic supply (such as Belgium or Malta) or in Member States that export a lot (like 

33   Notably the consumer survey by the Food Chain Evaluation Consortium (FCEC) as part of the ‘Study 
on the application of rules on voluntary origin labelling of foods and on the  mandatory  indication of 
country of origin or place of provenance of meat used as an ingredient’, carried out for the European 
Commission, July 2013.  

17 

 
                                                      
the Netherlands). The vast majority of consumers who said they used origin indications 
to inform their purchase decisions stated that they had a preference for EU meat and in 
particular  for  meat  from  their  own  country.  This  preference  can  be  seen  in  the  figure 
below.  

Figure 3:  Meat origin sought after to inform a purchase (N=5 927) 

Source: Consumer survey carried out as part of the evaluation support study. 

Consumers  who  said  they  used  origin  labelling  to  inform  their  purchase  decision  were 
mainly motivated by the desire for greater food safety and quality. These consumers also 
considered it important to support the economy of their own country and to protect the 
environment (see also figure 4). 

Figure 4:  Reasons for preferring meat of a certain origin (N=6 250 ) 

2 

11 

25 

33 

34 

32 

48 

50 

51 

0

10

20

30

40

50

60

Percentage of meat purchasers 

I don’t know why I look for origin information / No other reason 

Other (please specify)

Environmental concerns (e.g. food miles, or I believe greenhouse gas emissions are lower if meat comes
from this country / these countries)
I want to support the economy in this country / countries I indicated by buying products from this country /
these countries
Price, e.g. I believe the meat from this country / these countries is normally cheaper

I prefer certain aspects of the methods of production (e.g. the way animals are fed or treated or
sustainability) of this country / these countries
I believe the taste of the meat from this country / these countries is better

I believe the quality of the meat from this country / these countries is better

I believe meat from this/these country / these countries is safer/ that meat from other countries is less safe

Source: Consumer survey carried out as part of the evaluation support study. 

18 

 
 
 
 
Further disruptions in trade might also be linked with other consumer preferences, such 
as  a  preference  for  meat  from  some  countries  over  meat  from  other  countries;  a 
preference for meat from the EU over meat labelled non-EU and a preference for simple 
rather than complex products (i.e. meat from one country of origin over meat reared in 
one country and slaughtered in another).  

On the practices and behaviour of retailers, the literature review suggests that European 
retailers might seek to reduce the risk of mislabelling by simplifying their supply chains, 
notably  by  limiting  the  number  of  suppliers  of  their  meat.  In  particular,  market 
adjustments  in  the  trade  in  live  pigs  observed  in  some  Member  States  (Germany  and 
Poland) were consistent with seeking to avoid labelling swine meat as ‘reared in X’ but 
‘slaughtered  in  Y’.  The  evidence  collected  would  also  suggest  there  has  been  some 
renationalisation in the sheep and goat meat sectors, but not in the poultry sector. 

in 

trade 

The  analysis  of  intra-EU  trade  data  suggested  some  marginal  renationalisation  of  the 
live  animals  and  fresh  meat34.  Although  no  substantial 
market  for 
renationalisation  of  intra-EU  trade  occurred  because  of  the  implementation  of  the 
Regulation,  some  sourcing  consolidation  took  place  for  a  limited  number  of  operators 
and  this  could  have  led  to  a  reduction  in  sourcing  from  other  Member  States  for  the 
operators concerned. 

The  case  studies  highlighted  that  trade  flows  in  the  concerned  meat  sectors  are  mainly 
determined  by  market  forces  (notably  slaughterhouse  availability,  prices,  and  –  for  the 
swine  sector  -  transport  distances),  which  cannot  be  isolated  from  country-of-origin 
labelling.  Assessment  of  the  existing  qualitative  evidence35  does  not  allow  for  clear 
conclusions to be drawn on the magnitude of the impact of origin labelling on intra-EU 
trade. 

5.1.3. Impact of mandatory origin labelling on food-chain actors  

The  supply-chain  survey  organised  in  November  2019  provided  evidence  that 
slaughterhouses in the swine meat sector were those most impacted by mandatory origin 
labelling. The main issue that slaughterhouses had to address was the possible mixing of 
animals  and  products  from  different  Member  States  (this  was 
the  case  for 
slaughterhouses  in  Germany  and  Spain).  Other  issues  reported  by  the  sector  were  the 
need to store and incorporate information from the ‘primary’ sector (i.e. those rearing the 
animals) and transfer this information down the supply chain.  

Impacts  on  poultry  slaughterhouses  were  smaller.  Nevertheless,  operators  processing 
poultry from more than one Member State had to ensure batch segregation (this was the 
case in Germany, Spain and the Netherlands). For Ireland, a small number of supply lines 

34   A confirmation of the marginal renationalisation effect of the mandatory labelling rules is the fact that 
only  3%  of  the  respondents  to  the  supply-chain  survey  said  they  had  significantly  changed  their 
sourcing  practices  after  the  entry  into  force  of  the  Regulation.  66%  of  the  supply-chain-survey 
respondents  did  not  change  their  sourcing  practices,  and  31%  only  changed  their  practices  a  little  or 
moderately. Among operators sourcing from multiple countries, most (58%) kept their initial sourcing 
practices.  

35   In particular: (i) the expectations for intra-EU trade following the implementation of the Regulation and 
based on a review of consumer perceptions of the origin of meat; (ii) evidence from the introduction of 
country-of-origin labelling in  the beef sector; (iii) the  Commission’s impact assessment  of 2013; and 
(iv) intra-EU trade data. 

19 

 
                                                      
had  to  change  to  ensure  correct  labelling  of  production  according  to  the  Regulation’s 
rules.  In  the  sheep  and  goat  meat  sectors,  importing  live  animals  for  slaughter  would 
require  measures  to  keep  the  animals  separate  from  domestic  animals.  This  has  been 
achieved by processing the live animals  on different  days,  and survey respondents  said 
that the impact of this on their operations had not been significant (Spain and Ireland).  

The activities carried out  in  cutting plants (where meat  is  cut  off  animal  carcasses) are 
usually  integrated  into  slaughterhouses.  It  was  therefore  not  possible  to  analyse  these 
cutting activities separately in the supply-chain survey. Nevertheless, the evidence from 
the  case  studies  makes  it  possible  to  draw  some  conclusions.  In  some  Member  States 
(notably  Germany  and  Poland),  the  Regulation  has  made  the  operations  at  the  cutting 
stage  more  complex  in  order  to  guarantee  that  information  on  the  identity  and 
provenance  of  each  animal  could  be  preserved.  As  a  result,  companies  operating  in 
multiple  countries  sometimes  needed  to  increase  batch  segregation  to  comply  with  the 
Regulation. Some operators (in Denmark) reported that this had an impact on economies 
of  scale  that  led  to  an  increase  in  costs.  In  any  case,  these  costs  were  considered  less 
onerous when compared to requirements imposed by retailers or the requirements needed 
to comply with food-safety rules. 

At retail level, the impacts of the Regulation were considered negligible, and related to 
the set up of the operating systems and the labelling requirements. Retailers were already 
sourcing  fresh  swine  meat  and  poultry  meat  mainly  from  domestic  suppliers  before 
Regulation (EU) No 1337/2013 came into force.  

Although farmers were not directly targeted in the survey of supply-chain stakeholders, 
the  case  studies  found  that  the  Regulation  had  no  impact  for  swine,  sheep  and  goat 
farmers.  However,  it  did  have  a  small  impact  on  poultry  farmers  by  making  domestic 
poultry meat more visible at retailers. 

that  consumer  prices  changed  because  of 

No  evidence  could  be  found 
the 
implementation of Regulation (EU) No 1337/2013 in any of the meat sectors. Additional 
costs  were  minimal  and  were  usually  absorbed  in  the  cost  of  implementing  the 
traceability systems. Therefore, three quarters (75%) of respondents to the supply-chain 
survey  indicated  that  the  Regulation  had  either  led  to  no  additional  costs  (60%  of 
respondents),  or  to  only  a  small  additional  cost  (15%)  being  passed  along  the  supply 
chain. 

5.1.4. Impact of mandatory origin-labelling rules  

Impact of the Regulation on traceability systems 

Respondents  to  the  supply-chain  survey  were  asked  whether  their  traceability  systems 
changed specifically because of the entry into force of Regulation (EU) No 1337/2013. A 
slim  majority  (60%,  N=  73)  declared  there  had  been  no  changes  to  their  traceability 
systems. The case studies also confirmed that operators mostly did not need to make any 
changes  to  their  traceability  systems.  Among  the  respondents  who  did  make  changes, 
72%  said  that  their  traceability  systems  had  changed  to  either  a  ‘great  extent’  or  a 
‘moderate extent’, and 28% said their systems had changed to a ‘small extent’. Less than 
half of respondents who made changes to their traceability systems (43%) said that their 
internal  operational  practices  had  changed  to  a  great  extent,  and  more  than  half  (57%) 
declared that their practices had changed to either a moderate extent or a small extent. 

20 

 
The  main  changes  related  to:  (i)  internal  traceability  in  the  supply  chain  (link  between 
incoming and outgoing products); (ii) registration of departures and arrivals of products; 
(iii) product segregation; and to a lesser extent (iv) animal segregation.  

The only additional requirement of the Regulation for traceability systems was that these 
systems  must  be  able  to:  (i)  pass  on  information  relevant  for  the  country-of-origin 
designation to the next stage of the supply chain; and (ii) trace this information back to 
the previous stages in the supply chain. The replies to the supply-chain survey suggested 
that  the  industry  found  this  additional  requirement  straightforward.  The  case  studies 
showed  that  the  information  needed  for  correct  origin  labelling  has  been  already 
communicated  along  all  the  stages  of  the  supply  chain,  as  a  part  of  the  ‘traceability 
system required under Regulation (EC) No 178/2002 and the requirements of Regulation 
(EC) No 853/2004 on the hygiene of foods of animal origin36.  

For  swine  meat  Regulation  (EC)  No  853/2004  (Annex  II,  section  III:  Food  Chain 
Information) states that the documents that must accompany batches of swine meat from 
farm to slaughterhouse and to cutting plant include those that identify the holding from 
which the animals originated. The slaughterhouse then combines the numbered carcasses 
into batches (made up of pigs from one or more suppliers) and assigns each batch a batch 
number. Therefore, it is  known which individual holdings  are  represented in  the batch. 
The batch number accompanies the carcasses into the cutting room where carcasses are 
divided into meat cuts to which the proper origin labelling can be assigned. 

In  the  poultry  industry,  the  high  degree  of  integration  reduces  the  requirement  to  pass 
information 
the  supply  chain.  Typically, 
slaughterhouses receive live birds and send pre-packaged meat directly to the retailer. 

through  different  organisations 

in 

In  the  sheep  and  goat  sector,  animals  are  identified  at  individual  level,  and  the 
information passed along the chain is usually more detailed: it includes full information 
on place of birth, dates spent on specific holdings, and dates of movements. 

This  passing  on  of  information  for  all  the  concerned  species  is  increasingly  done 
automatically  via  electronic  systems.  In  some  cases,  respondents  to  the  supply-chain 
survey  reported  that  their  traceability  system  does  not  allow  the  next  stage  to  proceed 
without the submission of the required information.  

No  respondents  to  the  supply-chain  survey  said  that  they  had  encountered  instances 
where  information  was  missing.  The  respondents  confirmed  that  when  the  information 
was  not  sent  automatically  it  was  always  available  on  request.  Almost  two  thirds  of 
respondents to the supply-chain survey (64%) found that existing traceability systems in 
place for ensuring compliance with the Regulation have been fully effective, while 32% 
considered the systems to be moderately effective. No respondents said that the systems 
are  ineffective,  thus  confirming  previous  evidence  that  only  minimal  changes  to 
traceability  systems  were  required.  In  addition,  81%  of  respondents  said  that  they  had 
never  encountered  –  or  were  not  aware  of  –  any  problems  with  compliance  with  the 
Regulation due to the traceability systems in place. 

36   Regulation (EC) No 853/2004 of the European Parliament and of the Council of 29 April 2004 laying 

down specific hygiene rules for food of animal origin, OJ L139, 30/04/2004, p. 55.  

21 

 
                                                      
Effectiveness and impact of rearing specifications  

The  evaluation  assessed:  (i)  to  what  extent  the  rearing  specifications  laid  down  in 
Article 5(1)(a)  of  Regulation  (EU)  No  1337/2013  for  different  species  have  been 
effective; and (ii) what the impact of these specifications has been on prices, consumer 
information and administrative burden. 

As  mentioned  before,  only  a  quarter  of  consumers  surveyed  were  able  to  correctly 
interpret  the term  ‘reared in’, while most consumers understood the term  ‘reared in’ as 
meaning  that  the  animal  lived  all  its  life  in  the  country  indicated.  However,  42%  of 
consumers understood and accepted the concept behind the term ‘reared in’, i.e. that the 
animal was born and may have spent a short period of time in a country different to that 
indicated on the label as the rearing country. 

Although  overall  consumer  satisfaction  with  the  information  provided  on  the  label  on 
country of origin has been good (only 7% of surveyed consumers considered themselves 
unsatisfied),  poor  or  incomplete  understanding  of  the  terms  related  to  labelling  origin 
could undermine the effectiveness of the Regulation. 

The degree of information on rearing periods passed through the supply chain can vary: 
in some cases, all information is passed on, whereas in others only simplified information 
related to the correct labelling is passed on.  

For the swine meat sector, the level of passing on of information depends on the size of 
trade in live animals. In Member States where there are few or no imports of live pigs, 
time  spent  in  a  country  is  generally  irrelevant  (this  is  the  case  in  France,  Ireland  and 
Spain).  Therefore,  this  information  is  not  needed  for  labelling  purposes,  although  it 
remains  available  to  operators  for  traceability  purposes.  In  Member  States  that  export 
live pigs, such as Denmark, national databases record birth dates, movement dates, and 
places  of  rearing,  and  this  information  is  passed  along  with  the  pig,  ultimately  to  the 
slaughterhouses.  

Information on rearing periods in the poultry meat sector is not generally relevant. This is 
because birds are either slaughtered in the country of rearing or are traded live to another 
country  for  slaughter,  in  which  case  the  exporting  country  is  the  country  of  rearing 
although this  information  still has to  be collected and passed through the supply  chain. 
The high degree of vertical integration means that the slaughterhouse is responsible for 
receiving information from the ‘primary’ sector (i.e. the sector that rears the birds) and 
representing this information on the label of the pre-packed meat that is usually supplied 
straight  to  retailers.  Typically,  flocks  are  sent  to  the  slaughterhouse  along  with 
information  on  country  of  origin,  including:  (i)  the  farm  of  the  parent  flock;  (ii)  the 
hatchery  that  supplied  the  eggs;  (iii)  the  rearing  farm  (including  barn  number,  flock 
number and country); and (iv) dates and locations of movements.  

Information  on  rearing  periods  in  the  sheep  and  goat  meat  sectors  can  be  quite 
sophisticated in Member States where there is an electronic identification system in place 
(this  is  the  case  in  France  and  Ireland).  In  these  cases,  full  information  on  animals’ 
movements can be retrieved with a scanning system at the slaughterhouse. Whether there 
is  an  electronic  system  or  not,  the  slaughterhouse  passes  on  information  to  allow  the 
correct  labelling  to  be  used,  i.e.  abbreviated  information  stating  the  country  of  rearing 
(this occurs in Greece, Ireland and Romania). 

22 

 
Most  (70%)  of  the  national  competent  authorities  responding  to  the  survey  stated  that 
they never had problems in checking the information on rearing periods or that they had 
difficulties  only  on  a  few  occasions.  24%  of  them  reported  having  difficulties 
‘sometimes’,  and  only  one  national  competent  authority  reported  frequent  difficulties. 
The main difficulties reported were: (i) unclear or non-verifiable information for animals 
imported for slaughter; (ii) a lack of information on rearing periods; (iii) the inability to 
pass on information to the next link in the chain; and (iv) incomplete information. There 
were also some stages of the chain where difficulties in verifying information provided 
were apparent. For example, at slaughtering, cutting-plant, packing and farm levels these 
problems occurred frequently or very frequently. Problems were generally less frequent 
the closer one moved to the retail end of the supply chain.  

Impact of batch requirements 

Respondents to the supply chain survey generally did not expect the batch requirements 
in  Regulation  (EU)  No  1337/2013  to  result  in  changes  to  sourcing,  traceability  or 
operational practices. This was confirmed by evidence: most respondents to the supply-
chain survey declared that they did not make changes to their sourcing practices because 
of the batch requirements. The changes that were made tended to be small or moderate, 
and  the  role  the  batch  requirements  played  in  driving  those  changes  was  also  modest. 
There is some evidence to suggest that changes and associated costs were more likely to 
be  incurred  in  slaughterhouses  and  cutting  plants  that  sourced  from  multiple  Member 
States. The minimal costs incurred due to the batch requirements have been absorbed in 
the  processing  stage  of  the  supply  chain  and  have  therefore  not  been  passed  on  to 
consumers. 

5.2. Efficiency 

Impact of the Regulation rules and conditions on costs and administrative burdens of 
the supply chain  

Most respondents  considered the traceability rules of Regulation  (EU) 1337/2013  to  be 
efficient and appropriate to provide the necessary information for proper origin labelling 
for  the  concerned  meats.  This  is  because  these  rules  were  based  on  the  information 
already  available  and  required  under  Regulation  (EC)  No  172/2002.  The  majority  of 
respondents to the supply chain survey (60%, N=73) did not make changes to traceability 
systems.  Among  those  that  did  make  changes,  more  than  three-quarters  noted  one-off 
costs and increased ongoing costs.  

The  supply-chain  survey  showed  no  appreciable  differences  between  an  operator’s 
position  in  the  supply  chain  and  the  costs  they  bore  because  of  changes  in  traceability 
systems. Operators active in processing only and operators carrying out both processing 
and retail activities were more likely to have experienced both one-off and ongoing costs 
to  provide  information  on  rearing  periods.  The  costs  imposed  on  most  operators  have 
been small, and those imposed on operators dealing with imported and domestic animals 
have been affordable. Most of the costs have been incurred in the processing stage, and it 
has been possible to pass these costs through the supply chain.  

On  costs  arising  from  changes  to  internal  practices  by  operators,  these  costs  were  very 
difficult  to  identify  as  they  were  minimal  and  difficult  to  define.  The  expected  cost 
increases  related  to  technical  adjustments  in  the  production  units  and  in  logistics. 
However, the last time these costs were quantified was in 2013 in the impact assessment 

23 

 
carried  out  by  the  European  Commission37.  According  to  that  impact  assessment, 
additional costs were small for each species at 1.5% in the swine meat sector, 1.0% in the 
poultry meat sector and just 0.3% in the sheep and goat meat sectors. The cost increases 
were usually not passed along the supply chain (69% of the cases) or were passed along 
only partially. Only 10% of respondents passed more than one third of the cost increase 
to the next step of the chain. 

One  EU-level  organisation  that  was  interviewed  said  the  total  extent  of  additional 
operating  costs  for  internal  processes  and  sourcing  arrangements  was  in  the  order  of 
1.5%  to  3.0%  of  the  final  product  price  in  the  swine  meat,  sheep  meat  and  goat  meat 
sectors. Around half of these costs were related to technical changes and the other half to 
market changes (loss of flexibility in purchasing). 

On  cost  increases  due  to  changes  in  sourcing  practices,  only  six  respondents  to  the 
supply-chain survey were able to provide information on the magnitude of ongoing cost 
increases  (these  were  national  organisations  mainly  representing  processors).  One 
organisation noted that the cost increase was very small; three respondents indicated that 
it  amounted  to  1.5%;  another  respondent  stated  that  the  increase  in  ongoing  costs  was 
5%;  and  the  final  respondent  stated  that  the  increase  in  costs  was  greater  than  15%. 
Given the small number of quantifications provided by most respondents (among which 
were no operators in the industry), it is reasonable to assume that the additional ongoing 
costs were not considered significant. 

Results  of  the  survey  of  supply-chain  stakeholders  showed  that  the  batch  requirements 
had  an  impact  in  only  a  minority  of  cases:  22%  of  the  respondents  (N=73)  said  they 
made changes to traceability systems, internal-operating practices and sourcing strategies 
as a result of the batch requirements. As regards change in costs, resulting from changes 
made  due  to  the  batch  requirements,  a  fifth  of  all  respondents  reported  one-off  costs 
(estimated at around 2%) and an increase in ongoing costs (19% and 22% respectively).  

Tangible and intangible benefits arising from the Regulation  

The  Regulation  aims  to  have  three  tangible  benefits  for  operators:  (i)  price  benefits 
(stability  or  increase  of  prices  for  the  sold  products)  (ii)  market  growth;  and  (iii) 
reduction of production cost. The survey of supply-chain operators found little evidence 
of  any  of  these  three  benefits:  almost  half  of  respondents  to  the  supply-chain  survey 
(N= 70)  reported  no  tangible  benefits.  A  further  41%  reported  only  low  or  moderate 
tangible  benefits,  and  only  11%  reported  benefits  to  a  ‘great  extent’.  Although  some 
tangible  benefits  can  be  identified,  those  have  been  generally  limited  in  all  concerned 
meat  sectors.  The  replies  to  the  survey  also  seemed  to  be  mainly  influenced  by  the 
respondent’s  position  in  the  supply  chain:  some  operators  considered  the  support  for 
local production over imports to be a benefit, while other operators complained that the 
Regulation  had  resulted  in  a  renationalisation  of  trade  and  therefore  ran  counter  to  the 
objectives of the EU single market. 

Case  studies  make  it  possible  to  identify  some  concrete  examples  of  the  benefits 
perceived  by  suppliers.  A  summary  of  different  case  studies  is  presented  in  the  bullet 
points below.  

37   See footnote 6. 

24 

 
                                                      
 

Swine meat sector:  
-  the fact that there was no appreciable adjustment of trade within the EU, meaning 

that there was no change in the swine meat offering for consumers (Spain); 

-  the fact that consumers can now more easily identify the origin of the meat they 

buy (Denmark);  

-  a  reorientation  towards  domestic  swine  meat  which  more  closely  aligns  with 

consumer demand (Germany).  

 

 

Poultry meat sector:  
-  greater  use  of  domestic  poultry  in  the  food-service  and  catering  sector  to  meet 
increased  consumer  demand  and  thus  an  opportunity  for  market  growth 
(Ireland); 

-  greater market access for domestic producers (Greece).  
Sheep and goat meat sector: 
-  some increased protection for domestic producers (Greece);  
-  better identification of domestic and imported products which compete with 

domestic production (Spain). 

Respondents  to  the  supply  chain  survey  were  more  positive  when  speaking  about 
intangible benefits, such as better information and better product differentiation. Half of 
the  respondents  (N=71)  reported  those  benefits  to  a  ‘great  extent’  and  to  a  ‘moderate 
extent’. A further 20% reported intangible benefits to a ‘small extent’, while 30% did not 
report  any  intangible  benefits.  Respondents  pointed  to  the  following  examples  of 
intangible benefit: (i) a marketing advantage conferred by being able to identify meat as 
national/local rather than simply from the EU; (ii) harmonisation at the EU level, which 
simplifies  trade;  (iii)  meeting  consumer  demand  for  information  on  the  origin  of  the 
meat.  

The  opinion  of  national  competent  authorities  on  the  benefits  for  operators  was  more 
positive  overall:  more  than  half  of  the  surveyed  authorities  identified  tangible  and 
intangible  benefits  for  operators  to  a  ‘great  extent’.  Several  competent  authorities  cited 
increased  sales  and  greater  market  stability  as  tangible  benefits;  as  well  as  increased 
consumer confidence as an intangible benefit.  

Evidence  on  tangible  and  intangible  benefits  for  competent  authorities  is  mixed:  more 
than half of competent authorities perceived tangible and intangible benefits to a great or 
moderate  extent.  However,  at  least  a  third  of  them  identified  no  or  few  benefits.  The 
benefits  cited  by  national  authorities  included:  (i)  greater  traceability,  which  can  be 
helpful  in  the  event  of  food  scandals  or  in  the  prevention  of  epidemic  diseases;  (ii) 
satisfying  consumer  expectations  on  transparency  allows  consumers  to  make  a  more 
informed purchase decision; and (iii) simplified monitoring. 

Some  competent  authorities  that  responded  to  the  survey  also  identified  disadvantages, 
notably a loss of flexibility in supply (since it was no longer possible to switch suppliers 
in times of shortage because labels were already pre-printed). 

Unintended side effects and ‘deadweight’ of the Regulation  

On  the  potential  unintended  side  effects  of  the  Regulation,  some  supply-chain 
stakeholders  hinted  at  changes  in  sourcing  and  operating  practices,  such  as  reinforcing 
country-specific assumptions made by consumers on the quality and safety of meat. The 
mentioned  changes  were  in  any  case  minor  and  restricted  to  certain  types  of  operator 

25 

 
(these cases mainly occurred in the poultry meat sector among processors in Ireland and 
retailers in Spain). Despite the perceptions of some stakeholders, the assessment did not 
reveal  concrete  evidence  of  a  conflict  between  Regulation  (EU)  No  1337/2013  and  the 
objectives and rules of the EU single market. 

Findings from  desk  research lead to  the  conclusion that neither national  provisions  nor 
voluntary schemes could have achieved the same EU-wide objectives of Regulation (EU) 
No 1337/2013. This is especially because: (i) there are no international schemes covering 
origin  indication  for  the  products  of  interest;  (ii)  the  voluntary  schemes  are  present  in 
some Member States only, and often have a regional/local dimension; and (iii) the uptake 
of 
limited.  Interviews  with  EU-level  organisations  (notably 
organisations representing the interests of retailers) also confirmed that a proliferation of 
different voluntary schemes covering origin indication, in the absence of harmonised EU 
legislation, could create barriers to trade and confusion among consumers. In that sense, 
no significant ‘deadweight’ could be related to the Regulation.  

those  schemes 

is 

5.3. Coherence 

Coherence of Regulation (EU) No 1337/2013 with other EU rules and regulations  

The key objectives of Regulation (EU) No 1337/2013 (see also Figure 1) are the same as 
those pursued by Regulation (EC) No 1760/200038 for the beef sector, and relate to the 
objectives laid down by the FIC Regulation. A high degree of perceived consistency was 
also revealed among stakeholders who participated in the surveys. A large proportion of 
respondents to the supply-chain survey (80%, N=73) and national competent authorities 
(93%,  N=15)  identified  no  inconsistencies  or  conflicts  between  the  objectives  of 
Regulation (EU) No 1337/2013 and the objectives of other pieces of EU legislation.  

Very few stakeholders (12% of respondents to the supply-chain survey and one national 
competent  authority)  identified  potential  conflicts  between  the  objectives  of  the 
Regulation and those of other pieces of relevant  EU legislation. There are two types of 
inconsistencies perceived by the stakeholders:  
 

Inconsistency  with  the  rules  in  the  beef  sector:  country-of-origin  labelling  for 
beef  includes  a  requirement  to  state  the  animals  country  of  birth,  a  requirement 
which is missing from Regulation (EU) No 1337/2013 except implicitly where the 
‘origin’ designation is used. The potential conflict related to the different treatment 
of country of birth was also pointed out by the national competent authority.  
Inconsistency between mandatory country-of-origin labelling and the objective 
of  ensuring  the  smooth  functioning  of  the  EU single  market:  this  was  an  issue 
raised  by  the  EU-level  organisation  representing  the  interests  of  traders  of  live 
animals and meat39.  

 

On  the  definitions/specifications  used  in  Regulation  (EU)  No  1337/2013,  these  are  the 
same as – or consistent with – those used in other pieces of relevant EU legislation. Very 

38   OJ L 204, 11.08.2000, p. 1. 
39   However, it should be noted that analysis of the effectiveness criterion under Section 5.1 concluded that 
there is no clear evidence that the Regulation has  had an impact on intra-EU trade  patterns, although 
some  adjustments  to  specific  trade  flows  appear  to  have  occurred.  In  other  words,  there  is  no  clear 
evidence  that  the  Regulation  has  stimulated  or  hindered  the  smooth  functioning  of  the  EU’s  single 
market. 

26 

 
                                                      
few of the consulted stakeholders40 perceived potential conflicts or inconsistencies. The 
few potential conflicts or inconsistencies that were identified related to: (i) definitions in 
Regulation (EC) No 1760/2000 that are different from definitions in Regulation (EU) No 
1337/2013;  (ii)  the  lack  of  an  obligation  in  Regulation  (EU)  No  1337/2013  to  always 
indicate  the  country  of  birth  of  animals  (see  above);  and  (iii)  the  fact  that  Regulation 
(EU) No 1337/2013 does not cover ‘loose’ retail sales in bulk (non-prepacked meat).  

In  general  terms,  the  traceability  requirements  in  Regulation  (EU)  No  1337/2013  are 
non-conflicting  and  coherent  with  those  in  other  pieces  of  relevant  EU  legislation.  It 
should  be  noted  that  the  general  traceability  requirements  for  food  and  feed  set  out  in 
Article  18  of  the  General  Food  Law  (Regulation  (EC)  No  178/200241)  were  already  in 
force at the time of drafting of Regulation (EU) No 1337/2013. The General Food Law 
imposed  an  additional  obligation  to  make  country-of-origin  information  derived  from 
traceability  systems  available  in  such  a  way  as  to  allow  labelling  of  final  products.  A 
large  majority  of  the  stakeholders  consulted  said  there  were  no  inconsistencies  or 
conflicts  between  the  traceability  requirements  of  Regulation  (EU)  No  1337/2013  and 
those  of  other  pieces  of  relevant  EU  legislation  (91%  out  of  N=61  from  supply-chain 
operators, 97% out of N=15 national competent authorities, and all the interviewed EU-
level organisations).  

Very  few  consulted  stakeholders  identified  potential  conflicts  or  inconsistencies.  The 
stakeholders that did identify potential conflicts or inconsistencies were mostly those that 
represented  consumers.  One  consumer  organisation  pointed  out  that  traceability  in  the 
swine and poultry sectors is on a batch basis, rather than on an individual basis, as is the 
case in the beef, sheep  meat  and  goat  meat  sectors. Other inconsistencies perceived by 
stakeholders  related  to  the  two  areas  where  the  specifications  of  Regulation  (EU) 
No 1337/2013  differ  from  those  in  Regulation  (EC)  No  1760/2000:  the  treatment  of 
country  of  birth  and  coverage  of  ‘loose’  retail  sales  in  bulk.  The  provisions  on  rearing 
periods under Regulation (EU) No 1337/2013 lead to more simplified origin labelling for 
swine, poultry and sheep/goat meat than for beef42 where rearing took place in multiple 
Member States and non-EU countries.  

On  the  derogations  provided  by  Regulation  (EU)  No  1337/2013,  the  evidence  from 
stakeholders  identified  no  major  conflicts  or  inconsistencies  between  the  derogations 
provided by Regulation (EU) No 1337/2013 and derogations in other pieces of relevant 
EU  legislation.  However,  it  cannot  be  excluded  that  the  favourable  views  of  industry 
operators  and  representative  organisations  have  been  influenced  by  the  significant 
contribution provided by the derogations in Regulation (EU) No 1337/2013 that simplify 
compliance and reduce burden. A few supply-chain stakeholders43 and the organisations 

40   7%  (N=61)  respondents  from  the  supply-chain  survey,  one  EU-level  organisation,  and  one  national 

competent authority. 
41   OJ L31, 01/02/2002, p.1. 
42   Amended  Regulation  (EC)  No  1760/2000;  amended  Regulation  (EC)  No  1825/2000;  Commission 
Regulation  of  25  August  2000  laying  down  detailed  rules  for  the  application  of  Regulation  (EC) 
No 1760/2000 of the European Parliament and of the Council as regards the labelling of beef and beef 
products, OJ L 216, 26/08/2000, p.8. 

43   A  fifth  of  respondents  to  the  supply-chain  survey  (N=67)  identified  potential  conflicts  between  the 
derogations  provided  in  Regulation  (EU)  No  1337/2013  and  the  derogations  in  other  relevant  EU 
legislation. The highest proportion of respondents identifying potential conflicts  was recorded among 
consumer organisations (64% out of N=11 respondents). 

27 

 
                                                      
representing consumers identified some potential gaps in information to consumers due 
to the derogations for minced meat and trimmings, and the derogations for meat imported 
from non-EU countries (there is a lack of information about which non-EU country non-
EU  meat  comes  from,  especially  if  there  are  country-specific  issues  or  concerns). 
However,  these  arguments  focused  more  on  the  relevance  of  the  derogation  than  its 
coherence. 

On  the  derogation  provided  by  Article  6  of  Regulation  (EU)  No  1337/2013  for  meat 
imported  from  non-EU  countries44,  an  interviewed  EU-level  consumer  organisation 
observed  that  consumers  might  want  to  know  exactly  which  non-EU  country  non-EU 
meat  comes  from,  especially when there are issues with  animal  welfare,  environmental 
impact, or food safety in specific countries. However, this argument has more to do with 
the  relevance  of  the  derogation  than  with  its  consistency  with  similar  derogations  laid 
down by other relevant EU legislation.  
On  the  derogation  provided  by  Article  7  of  Regulation  (EU)  No  1337/201345,  the 
stakeholders’ consultation revealed wide consensus on the coherence of Regulation (EU) 
No 1337/2013 with other pieces of relevant EU legislation introducing mandatory origin 
labelling, notably for beef, honey, fresh fruit and vegetables, extra-virgin olive oils and 
virgin olive oils. As is the case with Regulation (EU) No 1337/2013, those other relevant 
pieces of EU legislation do not provide for the extension of the simplified ‘EU/non-EU’ 
origin indication to the entire range of products that they cover. 

However, consumer organisations disagreed. They voiced their concern that the use of a 
simplified  ‘EU/non-EU’  origin  indication  would  prove  an  obstacle  to  the  possible 
extension  of  mandatory  origin  labelling  to  processed  products  using  minced  meat  and 
trimmings  of  swine,  poultry,  sheep  and  goat  meat  as  an  ingredient.  Although  the 
arguments  made  by  consumer  organisations  on  the  matter  concern  a  hypothetical 
regulatory framework (as there is currently no harmonised EU legislation on mandatory 
origin  labelling  for  processed  food  products),  the  conflict  between  specificities  of 
identification could preclude the use of anything other than an ‘EU/non-EU’ designation 
under the EU legislation applying from April 202046.  

Some  business  stakeholders  and  national  competent  authorities  also  identified  a  partial 
inconsistency  between  the  Article  7  derogation  and  the  analogous  derogation  under 
Article  14  of  Regulation  (EC)  No  1760/2000  for  beef,  since  the  latter  requires  minced 
beef to  be labelled with  the specific Member State or non-EU country of origin,  rather 
than simply ‘EU/non-EU’.  

The  analysis  of  the  coherence  of  Regulation  (EU)  No  1337/2013  has  also  identified  a 
potential  internal  inconsistency  between  the  approach  taken  for  origin  indication  for 

44   This  article  provides  for  a  situation  where  the  non-EU  country  of  rearing  for  imported  meat  is  not 
available. In this case, the label must contain the indication: ‘Reared in: non-EU’ and ‘Slaughtered in: 
(Name of the non-EU country where the animal was slaughtered)’.  

45   Article  7  of  Regulation  (EU)  No  1337/2013  introduced  the  derogation  to  apply  the  ‘EU/non-EU’ 
designation  to  minced  meat  and  trimmings  only  and  not  to  the  meats  covered  by  the  Regulation  in 
general (i.e. fresh, chilled and frozen meat of swine, sheep, goats and poultry). 

46   Reference to Commission Implementing Regulation (EU) 2018/775 of 28 May 2018 laying down rules 
for the application of Article 26(3) of Regulation (EU) No 1169/2011 of the European Parliament and 
of the Council on the provision of food information to consumers, as regards the rules for indicating the 
country of origin or place of provenance of the primary ingredient of a food, OJ L131, 29.05.2018, p.8.  

28 

 
                                                      
minced meat and trimmings on the one hand and the approach taken for packs of several 
pieces  of  meat  of  different  origins  on  the  other  hand.  In  fact,  under  the  Article  7 
derogation, the use of the simplified ‘EU/non-EU’ origin indication for minced meat and 
trimmings is allowed, whereas for packs of meats of different origin under Article 5(3), 
the detailed list of the relevant Member States or non-EU countries must be provided on 
labels.  

Coherence  between  Regulation  (EU)  No  1337/2013  and  national  rules  and 
legislation47 

Regulation  (EU)  No  1337/2013  applied  directly  across  the  EU.  Some  Member  States 
enacted  national  laws  providing  for  a  monitoring  regime  (Denmark,  Ireland  and  Italy), 
and  others  amended  existing  national  laws  to  ensure  compliance  with  the  Regulation 
(France,  Greece,  Poland  and  Romania).  In  one  Member  State  (Spain),  the  pre-existing 
national legislation was repealed to avoid conflicts with the Regulation.  
The evaluation has identified several Member States with additional national rules going 
beyond the scope of Regulation (EU) No 1337/201348. Two Member States (Finland and 
France)  have  issued  additional  national  rules  on  origin  labelling  for  meat  used  as  an 
ingredient  in  processed  products  and  meat  provided  to  mass  caterers.  Although 
mandatory, these rules were set to be limited in time. Two other Member States (Greece 
and  Poland)  extended  the  scope  of  the  Regulation  in  their  national  implementing 
legislation to encompass meat sold ‘loose’ to final consumers. 

The rationale for Member States developing additional national rules was: 
 

to  inform  consumers  about  the  origin  of  meat  used  as  an  ingredient  in  food  to 
increase the market share of domestically produced meat in the catering sector and 
in the processed-meat industry (in Finland and France); 
to  protect  consumers  from  potentially  being  misled  on  the  origin  of  the  meat  sold 
‘loose’  at  retail  given  the  importance  of  this  type  of  meat  in  national  markets  in 
Greece and Poland).  

 

The  case  studies  and  stakeholder  consultation  did  not  identify  any  conflicts  or 
inconsistencies between Regulation (EU) No 1337/2013 and national legislation. Most of 
the  respondents  in  the  online  public  consultation  (79%,  N=115)  were  strongly  or 
moderately  positive  about  the  consistency  between  the  EU  origin-labelling  rules  and 
other EU interventions.  

In addition to national legislation, national voluntary schemes concerning origin (often as 
part  of  wider  quality  schemes)  have  been  developed  in  at  least  eight  Member  States: 
Czechia,  Denmark,  France,  Germany,  Ireland,  Italy,  Poland  and  Spain.  Some  of  those 
schemes  have  been  used  as  an  informal  requirement  for  business-to-business  sales  of 
meat, others were directly linked to national traditional practices (quality schemes such 
as the Label Rouge in France), thus providing an indication of origin even if this was not 
the expressed main  intention. Some other national  initiatives have  also  been developed 

47   For inventory of existing national rules concerning country of origin, see also Annex 3. 
48   Some  possibility  to  set  up  additional,  complying,  and  non-contradictory  rules  on  origin  labelling  is 

allowed in Article 8 of Regulation (EU) 1337/2013, Articles 9 and 45 of the FIC Regulation.  

29 

 
                                                      
that  are  focused  on  quality  or  greater  animal  welfare,  but  without  specific  mention  of 
origin49. 

5.4. Relevance 

The  evaluation  also  analysed  the  relevance  of  EU  Regulation  (EU)  No  1337/2013  and 
more concretely the extent to which the objectives, scope, rules and conditions stated in 
the Regulation: (i) correspond to the current needs and context; (ii) are relevant; and (iii) 
are fit for purpose. 

Extent to which original objectives of the Regulation are still relevant 

The  surveyed  supply-chain  stakeholders,  consumers  and  competent  national  authorities 
reported  that  the  objective  of  ‘providing  clear,  accurate  and  meaningful  information  to 
consumers’  remains  highly  relevant.  Notably,  the  vast  majority  of  consumers  and 
consumer  organisations  (83%,  N=6,250),  as  well  as  two-thirds  (65%,  N=17)  of  the 
surveyed national  competent authorities stated that  the first  objective of the Regulation 
has  remained  ‘fully’  relevant.    There  were  no  stakeholders  who  felt  that  this  objective 
was  no  longer  relevant.  All  interviewed  EU-level  organisations  stated  that  origin 
information  is  increasing  in  importance  for  consumers  of  all  types  of  meat.  The 
stakeholders also found relevant the second objective of the Regulation i.e. ‘ensuring that 
information is reliable and can be checked by enforcement authorities’. The distribution 
of  opinions  about  the  second  objective  was  similar  to  the  first  objective,  i.e.  consumer 
organisations and national competent authorities (69%) were the most likely to find this 
objective to  still be ‘fully’ relevant.  The third objective of the Regulation i.e. ‘to avoid 
unnecessary  burdens  on  operators,  trade,  administration  and  the  environment’  was 
considered  by  survey  respondents  to  be  less  relevant  than  the  other  two  objectives, 
although interviewed EU organisations pointed  out  that unnecessary burdens should be 
avoided. All interviewed EU organisations agreed that it remained relevant to ensure that 
the information provided be reliable and can be checked. No differences in views were 
reported between respondents about how relevant the three objectives were for different 
meat species. 

In the public consultation, the stakeholders were either very or moderately positive about 
the  relevance  of  the  EU  origin-labelling  rules  for  current  stakeholder  needs  (positive 
opinions  ranging  from  55%  of  national  authorities,  66%  of  respondents  to  the  supply-
chain  survey,  and  80%  for  consumers).  Negative  responses  were  rather  low,  between 
10% and 16% in each group of stakeholders.  

Emergence of new needs to cover in the Regulation 

The  evidence  from  the  survey  also  revealed  a  perception  among  all  groups  of 
stakeholders  that  the  scope  of  Regulation  (EU)  No  1337/2013  could  be  extended  to 
encompass:  (i)  meat  sold  ‘loose’  at  retail  (i.e.  not  pre-packed);  (ii)  meat  used  in 
processed products; (iii) meat sold in food-service and catering outlets; and (iv) meat of 
other  species.  Some  supply-chain  organisations  suggested  there  was  a  need  to  allow 
‘EU/non-EU’  labelling  beyond  the  derogation  provided  under  Article  7  of  the 

49   Examples include IKB (Integrale Keten Beheersing/Integrated Quality Control) and Beter Leven in the 
Netherlands; QS in Germany; and, Label Rouge in France. These schemes can be considered to provide 
information on origin by default as they are mainly used nationally. 

30 

 
                                                      
Regulation.  National  competent  authorities  also  felt  that  extending  the  scope  of  the 
derogation  provided  under  Article  7  would  be  relevant,  but  to  a  much  lower  extent. 
Besides,  many  respondents  (86%,  N=99)  in  the  public  consultation  agreed  that  origin 
labelling ought to be extended to processed meat or to meat that was to be exported. 

The case studies also identified several needs, suggesting that the scope of the Regulation 
is not sufficient in the national context, in particular:  
 

the  need  to  indicate  the  country  of  birth  beyond  the  implicit  designation  of  origin 
(identified as a need in Denmark, Greece, Poland and Spain); 
the need to label the origin of non-prepacked meat, i.e. meat sold ‘loose’ at the retail 
stage (identified in Greece, Ireland, Poland and Spain); 
the need to label the origin of meat sold by caterers (an important issue identified in 
several Member States – France and Greece have considered national legislation to 
cover this need); 
the need to label the origin of meat used as an ingredient in processed products with 
relation  to  the  demarcation  between  fresh  and  processed  meat  and  taking  into 
account  Regulation  (EU)  2018/775  (identified  as  a  need  in  Denmark,  France  and 
Germany).  

 

 

 

Extent to which rules of the Regulation are still relevant for the current context 

Most  of  the  national  competent  authorities  and  respondents  to  the  supply  chain  survey 
found  that  the  context  in  which  Regulation  (EU)  No  1337/2013  operates  has  evolved 
since its entry into force in 2015. There have been two main changes: (i) the discussion 
around  labelling;  and  (ii)  consumer  habits  and  interests.  EU-level  organisations  agreed 
with  these  views  by  noting  the  increased  consumer  interest  in  origin  labelling.  This 
greater  consumer  interest  in  origin  labelling  is  also  evidenced  by  the  use  of  temporary 
national  measures  on  origin  under  Regulation  (EU)  No  1169/201150.  Despite  an 
identified  change  in  context,  most  respondents  felt  that  the  Regulation  remained  either 
‘fully’  relevant  or  relevant  to  a  ‘great  extent’.  The  results  of    the  supply  chain  survey 
showed  that  traceability  rules  have  been  ‘fully’  followed  by  more  than  half  of 
respondents  (56%)  and  rules  relating  to  batching/groups  of  animals  by  44%  of 
respondents. The same survey showed also that the rules on labelling/rearing periods and 
derogations  for  minced  meat/trimmings  have  not  been  followed  so  completely.  More 
than a fifth (23%) of respondents said they did not follow the Regulation’s derogations 
for non-EU countries.  

Supply-chain  operators  have tended to  follow a  standard operating procedure to  ensure 
the application of: (i) food-and-feed law; (ii) rules on animal health and welfare; (iii) and 
rules  on  plant  health  and  plant-protection  products.  These  operators  have  typically 
followed this procedure regardless of the final destination of the meat (whether it is sold 
as  fresh/frozen  and  then  subject  to  origin-labelling  obligations  or  used  for  meat 
preparations). 

50   According to Article 39(2) of this Regulation, Member States may introduce measures concerning the 
mandatory  indication  of  the  country  of  origin  or  place  of  provenance  of  foods  only  where  there  is  a 
proven  link  between  certain  qualities  of  the  food  and  its  origin  or  provenance.  When  notifying  such 
measures  to  the  Commission,  Member  States  must  provide  evidence  that  the  majority  of  consumers 
attach significant value to the provision of that information. 

31 

 
                                                      
There is evidence that origin labelling is used on products that fall outside the scope of 
Regulation  (EU)  No  1337/2013,  both  under  mandatory  national  legislation  and  under 
voluntary schemes51. However, there is only mixed evidence on the extent to which there 
are  fully  segregated  supply  chains  serving  markets  other  than  the  EU’s  fresh/frozen 
market52.  Although  it  is  clear  that  there  are  different  market  channels,  there  is  no 
compelling  evidence  of  supply  chains  that  are  entirely  segregated  to  serve  these 
channels53.  According  to  the  supply-chain  survey,  just  over  80%  of  the  other  supply 
chains  are  fully  or  partially  mixed  with  supply  chains  serving  the  EU  fresh/frozen 
market. Only 15% of supply chains are said to be ‘separate’ and 3% are said to not serve 
the EU fresh/frozen market at all. 

5.5. EU added value 

Extent  to  which  Member  States  would  have  acted  to  introduce  national  rules  if 
Regulation (EU) No 1337/2013 did not exist 

The  positions  of  the  Member  States  expressed  in  the  survey  of  the  competent  national 
authorities were balanced between those that would have wished to legislate at national 
level  in  the  absence  of  the  Regulation  and  those  that  would  not.  At  least  6  national 
competent authorities out of 17 considered their introduction of national legislation in the 
absence  of  the  Regulation  to  be  ‘unlikely’.  However,  the  same  proportion  thought  that 
the  introduction  of  national  rules  in  the  absence  of  the  Regulation  would  be  ‘likely’. 
Three  of  the  Member  States  had  a  ‘neutral’  opinion  on  this  eventuality.  None  thought 
that introducing such rules would be ‘entirely feasible’, but a third of Member States felt 
it would be ‘quite feasible’, another third had a ‘neutral’ opinion, and a quarter felt the 
introduction of such rules would be ‘quite unfeasible’. 

The  Member  States  that  introduced  national  rules  before  the  implementation  of 
Regulation (EU) No 1337/2013 said they would have continued to apply these national 
rules in the absence of the EU rules. This includes: (i) the supply chain for swine meat 
and  poultry  meat  in  Poland;  (ii)  the  supply  chain  for  swine  meat  in  Italy;  and  (iii)  the 
supply  chain  for  poultry,  sheep  and  goat  meat  in  Greece.  In  these  three  countries, 
competent authorities, supply-chain organisations and consumer organisations agreed on 
labelling the origin of meat.  

51   It was also noted that origin labelling is often required by end markets on a voluntary basis for products 

that are out of the scope of Regulation (EU) No 1337/2013. 

52   Half of the respondents to the supply-chain survey (53%) said that they or their members are involved 
in supply chains for meat that is not sold as frozen or fresh in the EU (N=73). None of the operators 
processing all three species (poultry, pigmeat, and sheep/goat meat) are involved in frozen or non-fresh 
or EU supply chains (N=8). Two-thirds (68%) of operators processing only poultry meat are also not 
involved  in  frozen  or  non-fresh  supply  chains  (N=19).  However,  two-thirds  (67%)  of  operators 
processing only pigmeat are involved in supply chains for fresh and frozen meat beyond the EU market 
(N=9). A large majority of the national competent authorities (88% out of N=17) indicated that they are 
not aware of supply chains entirely separate from meat sold as fresh or frozen.  

53   There  is a suggestion in the literature  (merger procedure between a Danish and a German processor) 
that the cull sow market is segregated from the general swine meat market, with sow meat used in the 
processing  sector.  However,  some  sow  meat  is  used  in  the  fresh  meat  market  and  sows  are  not 
slaughtered  in  facilities  that  do  not  also  process  standard  finisher  pigs.  There  is  some  evidence  for  a 
segregated supply chain in the poultry sector in France, where whole birds are exported to the Middle 
East, but this has declined in importance over time.  

32 

 
                                                      
Conversely, some of the Member States that do not have national rules said they would 
not  have  introduced  any  rules  specifically  on  origin  labelling  in  the  absence  of  the  EU 
Regulation.  Those  Member  States  (like  Denmark,  Germany  and  the  Netherlands,  have 
nevertheless  developed  national  voluntary  schemes  that  have  addressed  the  origin-
labelling  needs  for  a  large  part  of  the  meat  sold  at  retail  level.  In  some  other  Member 
States (Spain and Romania), the competent authorities did not express any opinion on the 
matter,  but  national  professional  organisations  felt  that  the  introduction  of  such  rules 
would be unlikely in the absence of Regulation (EU) No 1337/2013. 

Potential impact of the non-harmonised system (absence of the EU Regulation)  

Almost half of the surveyed competent authorities were of the opinion that national rules 
could  fulfil  the  objectives  of  the  Regulation  (EU)  No  1337/2013  only  to  a  ‘moderate 
extent’.  More  than  one  third  of  competent  authorities  considered  that  national  rules 
would  not  have  met  the  same  objectives  (notably  Germany,  the  Netherlands,  Romania 
and Spain), while three competent authorities considered that national rules would have 
met the same objectives (Greece, Italy and Poland). 

6.  CONCLUSIONS 

Since 2011, general rules on food information to consumers have been in place in the EU 
that  aim  at  helping  consumers  to  make  informed  decisions.  These  rules  require  certain 
information  to  appear  on  a  food  label,  such  as  the  country  of  origin  or  place  of 
provenance  for  certain  types  of  food.  Through  Regulation  (EU)  No 1337/2013  (‘the 
Regulation’),  in  force  since  2015,  the  fresh,  chilled  and  frozen  meat  of  swine,  sheep, 
goats and poultry are required to indicate their origin (i.e. a place where the animals were 
reared or slaughtered) with a label. The evaluation analysed to what extent the mandatory 
origin-labelling rules for swine, sheep, goat and poultry meats were enabling the EU to 
achieve the objectives set in the legislation. The evaluation also analysed whether these 
rules  have  been  useful  and  sufficient,  and  whether  they  have  remained  relevant  for  the 
concerned stakeholders, i.e. consumers, meat supply-chain operators, and Member-State 
competent authorities.  

6.1. Conclusions on effectiveness 

Consumers consider country-of-origin labelling to be important information at the point 
of  purchase.  There  is  no  doubt  that  the  accuracy  of  the  information  currently  given  on 
labels  is  in  line  with  the  labelling  definitions  set  out  in  the  legislation.  Nevertheless, 
consumer understanding of these definitions is poor and there are therefore doubts over 
consumer interpretation. As a result, it was not possible to conclude that the information 
is fully clear and useful to consumers.  

There  is  evidence  that  the  information  on  the  origin  of  swine,  poultry,  sheep  and  goat 
meats provided to consumers according to the Regulation was considered to be reliable, 
accurate  and  verifiable  by  national  competent  authorities.  Although  no  systemic  issues 
have been reported in the ability of national competent authorities to verify and check the 
information,  differences  in  the  robustness  of  monitoring  have  been  apparent  between 
Member States.  In particular, case studies revealed that monitoring has  been facilitated 
where  live  imports  did  not  take  place,  or  at  least  where  live  imports  were  not  a  major 
feature of the market.  

33 

 
The evidence showed that the existing traceability systems set up in accordance with the 
EU legislation allow all operators to receive systematically the information required for 
compliance  with  the  Regulation  (i.e.  a  link  is  made  and  maintained  between  the  meat 
product  and  the  animal  of  origin).  The  Regulation  specification  on  rearing  periods  did 
not pose challenges to operators and did not create specific costs and burden. The batch 
requirements did not result in changes to sourcing, traceability or operational practices. 
Although the impact was minimal overall, some evidence suggested that the processing 
stage  (in  slaughtering  and  cutting  plants)  was  the  most  affected  by  the  Regulation  in 
several Member States – those operators had to adjust their operational practices.  

Although  the  stakeholder  consultation  and  case  studies  identified  some  limited 
‘renationalisation’.  However,  the  broader  evidence  gathered  in  the  evaluation  did  not 
show significant and clear impacts of the Regulation on intra-EU trade, and so it can be 
concluded  that  Regulation  did  not  hamper  the  development  of  intra-EU  trade  in  live 
animals  and  in  fresh  meat,  and  thus  did  not  disrupt  the  functioning  of  the  EU’s  single 
market. 

Case  studies  pointed  to  some  suggestions/hypotheses  that  the  implementation  of  the 
Regulation  might  have  a  positive  or  negative  environmental  impact,  depending  on  the 
nature of the change induced (e.g. change in trade flows and transport), but no evidence 
for  these  suggestions/hypotheses  could  be  provided.  Overall,  the  evaluation  did  not 
detect a clear and direct relationship between the Regulation and the environment. 

6.2. Conclusions on efficiency 

The  evidence  suggests  that  the  Regulation  achieved  its  main  objective  i.e.  consumers 
have  received  meaningful  and  verifiable  information,  with  a  minimal  negative  impact 
(increase of cost) on operators and national authorities. The evaluation found no evidence 
that  consumer  prices  increased  due  to  implementation  of  the  Regulation.  However,  it 
should be noted that stakeholders were more positive about  the Regulation’s intangible 
benefits  (e.g.  better  information,  product  differentiation)  than  its  tangible  benefits  (e.g. 
higher sales prices for their products, price stability, market growth, and cost reduction).  

The  Regulation  has  been  judged  to  be  efficient  in  limiting  cost  and  administrative 
burdens  on  operators.  Costs  have  been  successfully  minimised  because  it  was  mostly 
possible to meet the Regulation’s provisions using existing traceability systems that were 
already in place. The reported additional cost incurred in passing on information (notably 
on  rearing)  and  in  adapting  the  already  existing  systems  was  minimal,  absorbed  in  the 
supply  chain  (mainly  at  the  processing  stage),  and  not  passed  on  to  consumers.  The 
swine meat sector is more likely to have faced additional costs than other meat sectors. 

Monitoring costs for national competent authorities have been small, as they have been 
integrated  within  the  context  of  the  broader  mandatory  monitoring  under  Regulation 
(EU) 2017/62554. Some Member States raised concerns about the limited resources they 
were able to allocate to monitoring the Regulation’s implementation.  

54   Regulation (EU) 2017/625 of the European Parliament and of the Council of 15 March 2017 on official 
controls and other official activities performed to ensure the application of food and feed law, rules on 
animal health and welfare, plant health and plant-protection products (‘Official Controls Regulation’), 

  OJ L 95, 7/04/2017, p.1. 

34 

 
                                                      
6.3. Conclusions on coherence 

The analysis also made it possible to conclude that the mandatory origin-labelling rules 
for the concerned types of meat were coherent. The collected evidence demonstrated that 
the  objectives,  definitions  and  traceability  requirements  of  the  implementing  EU 
regulation are consistent with those of other pieces of relevant EU legislation. However, 
some stakeholders (mainly supply-chain stakeholders and national competent authorities) 
identified a partial lack of coherence within the approach applied to mixed meat in packs 
(Article 5 of the Regulation) and to minced meat and trimmings (Article 7).  

The  same  groups  of  stakeholders  have  also  suggested  that  there  is  a  possible  lack  of 
consistency  between  the  mandatory  origin-labelling  rules  for  beef  and  those  for  swine, 
sheep, goat and poultry meats. However, it should be highlighted that derogations used in 
the  Regulation  for  swine,  sheep,  goat  and  poultry  meats  remain  consistent  with  the 
approach taken in many other food sectors, notably for blends of honeys and olive oils, 
and mixtures of fresh fruit and vegetables.  

The evaluation did not identify any inconsistencies between the EU rules and the national 
legislation  of  Member  States  (both  the  pre-existing  national  legislation  and  additional 
national rules introduced after entry into force of the Regulation). There is no evidence 
that  the  Regulation  had  significant  unintended  side  effects  or  that  it  was  subject  to 
significant ‘deadweight’.  

6.4. Conclusions on relevance 

All stakeholders (consumers, supply-chain operators, competent national authorities, and 
general public) across the concerned meat sectors said that the three main objectives of 
the Regulation remain ‘fully’ relevant or relevant to a ‘great extent’. This was despite the 
fact that most of the supply-chain operators and national competent authorities found that 
the  context  in  which  the  Regulation  operates  has  changed  since  its  entry  into  force  in 
2015. The three most significant changes pointed out are: (i) an increase in the discussion 
around labelling; (ii) a change in consumer habits and interests; and (iii) increased use of 
temporary national measures on origin indication for certain products.  

Among  the  three  main  objectives  of  the  Regulation,  the  third  objective  i.e.  ‘to  avoid 
unnecessary  burdens  on  operators,  trade,  administration  and  the  environment’  was 
considered  by  stakeholders  to  be  less  relevant  than  the  other  two  objectives.  However, 
stakeholders,  and  interviewed  EU  organisations  in  particular,  stressed  that  unnecessary 
burdens should be avoided.  

Although  many  stakeholders,  including  national  competent  authorities,  did  not  identify 
concrete  new  needs  to  extend  the  scope  of  the  Regulation  with  regard  to  fresh,  chilled 
and  frozen  meat  of  swine,  sheep,  goats  and  poultry,  there  is  substantial  interest  and 
support in the following aspects: country of birth, food service and catering sector, meat 
sold loose at retail  and processed meat products in which meat is  a primary ingredient. 
To some extent, those needs have been addressed in a few Member States. 

6.5. Conclusions on EU added value 

National  competent  authorities,  professional  organisations  and  consumer  organisations 
confirmed that the absence of EU legislation on origin labelling would lead to potentially 
significant  negative  impacts.  Stakeholders  in  the  public  consultation  judged  the  EU 
added value of the Regulation to be good. 

35 

 
In the absence of the Regulation, a significant proportion of Member States would have 
maintained or adopted mandatory national rules to address country origin labelling. It is 
unlikely that national  rules would have been introduced in those Member States which 
have  net  meat  exporting  positions  among  their  supply  chain  and/or  which  have 
developed voluntary national schemes.   

The stakeholder consultation also  revealed wide consensus  on the potential  risks of the 
non-harmonised  approach  at  EU  level  i.e.  widespread  adoption  of  national  rules: 
hampering  smooth  operation  of  the  EU  single  market,  increasing  difficulties  for 
companies to navigate rules, unequal information provided to consumers. 

The existing national compulsory rules on country of origin  going beyond the scope of 
the  Regulation  are  rare  and  form  time-limited  pilot  projects.  Conversely,  voluntary 
quality  schemes  covering  origin  labelling  (implicitly  or  explicitly)  are  widespread  in 
some  Member  States.  Those  schemes  are  designed  to  meet  similar  objectives  as  the 
Regulation (i.e. consumer demand for information on concrete type of product), but were 
further adapted to address specific national needs and extract a competitive advantage. 

6.6. Lessons learned  

Consumers consider country-of-origin labelling to be important at the time of purchase, 
because they also perceive origin as information about quality and safety attributes, that 
are not, however directly linked with origin55. 

Although  the  accuracy  of  the  information  given  on  meat  labels  is  in  line  with  the 
Regulation,  there  are  doubts  over  consumer  interpretation  of  origin-labelling  rules.  For 
this reason, it was not possible to conclude that the information provided when applying 
the Regulation is fully clear and useful to consumers, notably on consumer understanding 
of the concrete specifications (terms and definitions).  

The  evidence  clearly  showed  that  origin-labelling  provisions  for  the  concerned  meats 
were  implemented  without  unnecessary  burdens  on  the  meat  supply  chain  and  on 
national  administrations.  Moreover,  the  derogations  for  minced  meat,  trimmings  and 
imported  meat  have  facilitated  the  implementation  of  the  new  rules.  While  there  is  no 
doubt  about  the  usefulness  of  those  derogations,  their  coherence  and  potential 
harmonisation with other meats and foods could be further analysed. 

Despite proven small changes to trade flows, the Commission assessed the overall effect 
of the origin-labelling provisions for the concerned meats on market dynamics and trade 
dynamics  to  be  marginal.  It  is  nevertheless  important  to  continue  monitoring  the 
Regulation’s policy impact on the EU single market, notably via the different instruments 
currently available, such as:  (i) the meat-market  observatory;  (ii) civil-dialogue groups; 
and (iii) the Committee for the Common organisation of the agricultural markets. 

The increasing societal interest in – and growing environmental case for – food labelling 
make  it  important  for  the  Commission  to  continue  its  efforts  to  better  understand  the 
environmental impact of the origin-labelling provisions. 

55   It should be noted that food-safety rules are fully harmonised in the EU single market. Therefore, food 
business  operators  in  all  Member  States  must  comply  with  the  same  legal  obligations  with  regard  to 
food safety.  

36 

 
                                                      
 
Information on the meat’s origin/provenance (notably on rearing periods) that is passed 
on  according  to  the  EU  regulation  is  sufficient  to  ensure  correct  labelling  and  can  be 
generally  verified  by  Member  States’  competent  authorities.  However,  no  data  are 
available on the number or nature of ‘non-conformities’ (when meat  does not  meet  the 
requirements  of  the  Regulation).  This  is  because  non-conformities  are  addressed  in  the 
broader  context  of  national  food  legislation.  Further  exchanges  and  collection  of  good 
practices on checks in this specific area could help to address gaps in information. 

The objectives of the Regulation have remained relevant, despite the evolving context in 
which it has operated. In particular, there is a perceived increase in consumer interest in 
country-of-origin  information  across  all meat  products  and market  segments,  especially 
for types of meat not covered by the current scope of the Regulation such as meat sold 
loose  at  retail  (i.e.  not  pre-packed),  and  meat  sold  through  food-service/catering. 
Additional mandatory rules and voluntary initiatives in origin labelling set up at national 
level have already partially addressed the emerging needs of consumers. However, these 
national initiatives may negatively influence stakeholders’ perception of the added value 
and  importance  of  the  EU  rules  and  provisions.  The  experience  gained  from  the 
implementation  of  the  Regulation  could  contribute  to  a  broader  assessment  of  origin 
labelling for meats and meat products on the EU single market.  

37 

 
 
 
ANNEX 1.  PROCEDURAL INFORMATION 

Lead DG, Decide Planning/CWP references 

1. 
The evaluation was approved in the European Commission planned programme of legal 
initiatives56  in  2018  as  a  thematic  assessment  of  common  agricultural  policy.  The 
evaluation was organised and conducted by the Directorate-General for Agriculture and 
Rural Development (DG AGRI), according to its evaluation and studies plan.  

2.  Organisation and timing 

The evaluation  was  conducted through an evaluation  support study, in  conformity with 
the  DG  AGRI  procedure  for  organising  and  managing  policy  evaluations  by  external 
contractors. The work was supervised under the technical and contractual management of 
the DG AGRI unit in charge of monitoring and evaluation.  

For the purpose of the evaluation, the Commission set up an inter-services steering group 
to  provide expert opinion on the evaluation  at  all stages:  from  defying the evaluation’s 
scope of the evaluation (its roadmap), by the procurement procedure and delivery of the 
evaluation  support  study,  to  the  dissemination  of  the  evaluation  results  (staff  working 
document).  The  inter-services  steering  group  was  composed  of  DG  AGRI  and  other 
Commission  DGs  with  responsibility  for  this  area:  the  Directorate-General  for 
Competition  (DG  COMP);  the  Directorate-General  for  Internal  Market,  Industry, 
Entrepreneurship and SMEs (DG GROW); the Directorate-General for Health and Food 
Safety  (DG  SANTE);  and  the  Secretariat-General  of  the  Commission  (SG).  The  inter-
services  steering  group  started  its  work  in  June  2018  and  held  several  meetings 
throughout the evaluation process.  
The  overall  evaluation  began  in  September  2018  with  a  roadmap57  setting  out  the 
context,  objective  and  scope  of  the  exercise.  Then,  the  Commission  commissioned  an 
evaluation support study, which was carried out by the external contractor from August 
2019 to August 2020, and published on the Europa website in September 202058. In the 
meantime,  the  Commission  organised  an  online  public  consultation  supporting  the 
evidence gathering under the evaluation.  

Exceptions to the ‘better regulation’ guidelines 

3. 
The  evaluation  followed  the  European  Commission’s  ‘better  regulation’  guidelines59 
without  exceptions.  The  evaluation  was  not  selected  for  scrutiny  by  the  Regulatory 
Scrutiny Board (RSB)60. 

56   Internal reference in Decide: PLAN/2018/3006.  
57   See footnote 25 for link to the evaluation roadmap.  
58   See  footnote  10  for  link  to  the  evaluation  support  study,  its  executive  summary,  leaflet  and 

presentation.  

59   https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why- 

and-how/better-regulation-guidelines-and-toolbox_en 

60   The  RSB  is  an  independent  body  that  advises  the  College  of  Commissioners  and  provides  central 
quality control and support for Commission impact assessments and evaluations at early stages of  the 
legislative  process.  For  more  information  on  its  role,  composition,  rules  and  works  see  the  dedicated 
page on Europa, https://ec.europa.eu/info/law/law-making-process/regulatory-scrutiny-board_en. 

38 

 
 
                                                      
4.  Evidence, sources and quality 

Relevant data and information were gathered in the evaluation support study and in the 
stakeholder-consultation  activities  to  build  an  evidence  base  for  the  staff  working 
document.  The  evaluation  approach  combined  the  following  three  main  types  of 
evidence:  (i)  EU-level  data  and  information  gathering,  review  and  analysis;  (ii)  case 
studies in selected Member States; and (iii) qualitative and quantitative analysis of trade 
data (see also Section 4 METHOD).  

39 

 
 
ANNEX 2. 

STAKEHOLDER CONSULTATION 

The  evaluation  provided  for  a  range  of  consultations  to  collect  information  and  views 
from  relevant  stakeholders  and  the  public,  to  be  used  as  input  for  preparing  the  staff 
working document. 

The  consultations  carried  out  during  the  evaluation  can  be  grouped  as  follows:  (i) 
consultation  activities carried out  by the external  contractor in  charge of  the evaluation 
support study; and (ii) consultation activities carried out by the European Commission.  
Consultation activities carried out by the external evaluator61 

The  external  contractor  carried  out  a  series  of  consultation  activities:  case  studies,  a 
consumer survey, a supply-chain survey, a survey of national competent authorities, and 
interviews with EU-level organisations. The consultation activities targeted the following 
main  stakeholders:  (i)  relevant  public  authorities  in  EU  Member  States;  (ii)  consumer 
organisations; (iii) operators and other actors in the food chain; (iv) farmers and farmers’ 
organisations; (v) academia and experts; and (vi) relevant NGOs.  

Consultation activities carried out by the European Commission 

Roadmap feedback 

In  September  2018,  the  Commission  organised  a  four-week,  an  online  consultation  to 
hear the opinion of the general public on the roadmap of the evaluation. The Commission 
received  some  contributions  from  this  that  have  not  changed  the  initial  scope  of  the 
evaluation.  Nevertheless,  these  contributions  were  taken  into  account  in  designing  the 
evaluation questions. 

Open public consultation 

From  December  2019  to  March  2020,  the  Commission  conducted  an  online  public 
consultation  in  all  official  EU  languages  except  Irish.  The  public  consultation  was 
organised using EUSurvey and published on the Europa website62. Its aim was to gather 
the  views  of  public  authorities,  stakeholders  and  members  of  the  public.  Overall,  the 
public  consultation  provided  a  significant  amount  of  input  on  the  different  sectors, 
especially  through  the  position  papers  that  respondents  to  the  consultation  provided  in 
addition to the EUSurvey questionnaire. Respondents to the public consultation from the 
meat sector came from different backgrounds: the most represented meat categories were 
respondents from the swine meat sector (19% of respondents to the consultation) and the 
poultry meat sector (19%), followed by the sheep meat sector (14%) and goat meat sector 
(11%).  Altogether,  the  meat  industry  represented  63%  of  respondents,  while  37% 
declared their affiliation as ‘none in particular’.  
The  results  of  the  public  consultation  were  summarised  in  the  factual  report63,  which 
provides  an  overview  of  responses  to  the  questions  and  gives  information  about  the 

61   For more details on those activities, see the evaluation support study. 
62   https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1892-Evaluation-of-

mandatory-country-of-origin-labelling-for-certain-meats/public-consultation 

63   The  factual  summary  report  from  the  public  consultation  can  be  consulted  on  Europa  (see  footnote 

above for link). 

40 

 
                                                      
respondents  by  country  of origin  and stakeholder category.  In addition  to  replies to  the 
closed  questions,  some public-consultation  respondents  gave  their  opinions  to  the  open 
questions  on  the  efficiency  and  relevance  of  the  EU  policy.  A  brief  summary  of  those 
opinions  is  presented  in  Table  2.  Finally,  the  public  consultation  was  supplemented  by 
position  papers  provided  by  9%  (N=146)  of  respondents.  A  list  of  respondents  who 
provided position papers (broken down by stakeholder category) is presented in Table 3. 
All position papers can be consulted in the original/source language on the Europa page 
dedicated to the public consultation, and their main subjects are outlined in Table 4. 

Other targeted consultation activities  

The evaluation was presented to DG Agriculture and Rural Development’s civil-dialogue 
groups: the swine meat-sector civil-dialogue group and the quality and promotion civil-
dialogue group64.  

64   Agricultural  civil-dialogue  groups  on  the  Europa  website:  https://ec.europa.eu/info/food-farming-
fisheries/key-policies/committees-and-advisory-councils/civil-dialogue-groups/animal-products_en. 

41 

 
 
                                                      
Table 2. Summary of main opinions to the public-consultation open questions (per stakeholder category) 

Stakeholder  

Academic/research 
institution 

Business associations 

Summary of main positions 

Recommended labelling: within EU-sourced products, ‘sourced from EU’, and for outside countries, ‘sourced outside of EU from country X’. 

- On the EU added value, the labelling rules should be left to EU law. If any company finds it worthwhile to implement an origin-information scheme on a 
voluntary basis, that would be acceptable but the company would have to prove the viability of this scheme on the market. If the consumer does not pay for it, 
then it is not worth providing the information. 
-  Fear  of  a  possible  extension  of  the  scope  of  Regulation  (EU)  No  1337/2013  to  introduce  mandatory  labelling  of  all  products  containing  poultry  meat 
(including processed meat) with the reference ‘EU’ or ‘non-EU’. This would be a discriminatory measure, as it would differentiate between EU products and 
non-EU producers. 
- On Regulation (EU) No 1337/2013, in addition to the place of rearing and slaughtering, support for mandatory indication of the place of birth at Member-
State level. The term ‘origin’ should be reserved for meat obtained from animals born, reared and slaughtered  – and therefore wholly produced – in a single 
Member  State  or  non-EU  country,  as  currently  stated  in  the  legislation.  The  minimum  font  size  of  the  three  places  or  origin,  as  required  by  the  current 
legislation, should be increased to be more easily available to consumers. In addition, there should be a mandatory requirement to show the three places of 
birth, rearing and slaughtering, or the ‘origin’ not only on fresh, chilled and frozen meat, but also on processed products,  minced meat, trimmings, and food 
offered to consumers by catering services and online retailers. Advertisers should not be exempt from displaying such important information.  

Company/business 
organisations 

Inclusion of rabbit meat. Possibility and need to extend the mandatory country-of-origin label to types of meat other than beef, swine meat, sheep meat, goat 
meat and poultry meat. Figures on the size of the rabbit-meat sector and need for transparency to consumers. 

EU citizens 

No inclusion of beef in the survey and the negative environmental impacts of the beef production model. 

NGOs 

Increasing information for consumers on the products, including on the place where animals were born, raised and slaughtered. Origin labelling should also be 
extended  beyond  fresh,  chilled  and  frozen  meat,  to  include  all  preparations  including  meat,  even  meat  served  in  restaurants  or  in  the  catering  sector.  EU 
animal-welfare label. 
- Inclusion of horse meat. Possibility and need to extend the mandatory country-of-origin label to types of meat other than beef, swine meat, sheep meat, goat 
meat and poultry meat. 

Source: European Commission based on the public consultation’s results. 

42 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 3. List of respondents who provided position papers to the public consultation  
(per stakeholder category). 

Country  

Name  

Main subject covered by position paper  

Academic/research institution 

1 

The United 
Kingdom 

Business associations 

University of Southampton 

Labelling, EU/non-EU 

Belgium 

Copa Cogeca 

Place of origin, processed meat 

Brazil 

Germany  

The Brazilian Animal Protein Association 
(ABPA) 

Processed meat, EU/non-EU 

Bundesverband des Deutschen 
Lebensmittelhandels e. V. 

Simplification, minced meat 

Germany  

Verband der Fleischwirtschaft e.V. 

General/EU added value 

2 

3 

4 

5 

Company/business organisation 

6 

7 

Finland 

Finland  

Atria Suomi Oy (slaughterhouse operator 
and processor) 

EU/non-EU labelling 

Snellmans Köttförädling Ab, 
(slaughterhouse operator and processor) 

Origin  labelling  for  processed  and  raw  meat 
products 

8 

France 

Business organisation in rabbit-meat sector 

Rabbit meat 

Citizens (EU) 
Portugal 
9 

EU citizen  

Beef  

NGOs 

10  Austria 

Four Paws  

Place of origin, processed meat 

11  Belgium  

Eurogroup for Animals 

Terminology  of  ‘origin’;  labelling  of  horse 
meat 

12  Belgium  

SAFE – Safe Food Advocacy Europe ASBL  Animal’s place of birth; 

13 

The United 
Kingdom 

World Horse Welfare 

Minced meat and trimmings; 
Origin labelling for meat used as an ingredient 
in pre-packed food; 
Minor types of meat. 
Horse meat 

Source: European Commission based on the public consultation’s results. 

43 

 
 
 
 
 
 
 
 
Table 4. Summary of position papers provided as part of the public consultation (per stakeholder category). 

Academic/research institution 

For trade within the EU, ‘sourced from EU’ labels only. For outside countries, the labelling should be ‘sourced outside of 
EU from COUNTRY X’. 

- Mandatory origin labelling to be extended to rabbit meat. 

Business associations 

- Mandatory origin labelling should be as simple as possible; only unavoidable amendments should be pursued. Maintain 
current  rules  for  minced  meat.  Rules  must  be  set  at  EU  level,  not  Member-State  level.  Only  information  about  the 
fattening/rearing of the animal is relevant; consumers have no interest in the place of slaughtering, the place of birth of 
the animal, or the place the meat was cut. Practice shows that consumers do not actually pay more for meat that carries 
this information. Originally, origin labelling was introduced due to the BSE crises in the beef sector, there is no crisis like 
this currently in other meat sectors, so there is no need to copy the beef-labelling rules for other sectors. 

- The labelling rules should be regulated at EU level not at Member-State level and voluntary rules would be enough. 

- ‘EU’ or ‘non-EU’ labels would be discriminatory labels, as they would mislead European consumers into assuming that 
all  non-EU  products  are  of  lower  quality.  Extending  the  current  rules  to  processed  meat  products  would  imply  high 
economic costs for food-business operators. 

-  Any  mandatory  indication  of  the  place  of  birth  of  the  animal  should  be  decided  at  Member-State  level.  The  term 
‘origin’ should be reserved for meat obtained from animals born, reared and slaughtered – and therefore wholly produced 
–  in  one  single  Member  State  or  non-EU  country.  The  minimum  font  size  of  the  three  places  or  origin  should  be 
increased, and it should be mandatory to indicate the places of birth, rearing and slaughtering (or the ‘origin’) not only on 
fresh, chilled and frozen meat, but also on  processed products (including foie gras), minced meat, trimmings, and food 
offered to consumers by catering services and online retailers. Advertisers (operating physically or digitally) should not 
be exempt from displaying such important information. 

Company/business 
- Origin labelling should be based on individual countries, within and outside of the EU; the labels ‘EU’ and ‘non-EU’ 
are too vague. 

-  There  is  no  need  to  further  complicate  the  rules,  but  indicating  the  country  of  origin  should  be  mandatory;  simply 
indicating that the product came from within or outside of the EU is not enough. All meat products should be regulated in 
the same way, raw and processed products alike. 

- It is vitally important to identify the origin of beef and ensure that this information reaches consumers.  

Citizens (EU) 

NGOs 

- Current EU rules for all types of meat (including horsemeat) should be extended beyond fresh, chilled and frozen meat, 
and should also include all meat preparations. Country-of-origin labels should indicate the places where the animal was 
born, raised and slaughtered. 

-  Place  of  birth  should  be  a  mandatory  indication,  and  the  same  rules  should  be  applied  to  all  types  of  fresh  meat, 
including minced meat and trimmings. All types of meat, including meat used as an ingredient in pre-packed food as well 
as  minor  types  of  meat,  should  be  subject  to  mandatory  origin  labelling  comprising  the  place  of  birth,  the  place  of 
rearing, and the place of slaughter. 

- Include horsemeat. Promote consumer information and help consumers to make better choices based on animal-welfare 
criteria.  Conduct  further  research  on  the  impact  of  mandatory  country-of-origin  labelling  of  equine  meat  on  operating 
costs and the live trade of animals. 

-  Fully  include  horsemeat.  Rebuild  consumer  confidence  in  the  wake  of  the  horse  meat  scandal  and  other  food-fraud 
cases.  Promote  consumer  information  and  help  consumers  to  make  better  choices.  Improve  horsemeat  identification 
systems  across  the  EU,  enable  the  authorities  in  Member  States  to  access  these  systems  across  borders,  and  introduce 
retrospective  microchipping,  so  that  horses  can  be  traced  through  their  passports,  monitoring  the  implementation  and 
enforcement  of  EU  rules.  Ensure  better  communication  between  Member  States’  central  databases.  Conduct  further 
research on the impact of mandatory country-of-origin labelling of equine meat on operating costs and the live trade of 
animals. Promote better transparency and shorter chains of food supply. 

Source: European Commission based on the public consultation’s results. 

44 

 
 
ANNEX 3. 

IMPLEMENTATION OF THE MANDATORY INDICATION OF MEAT ORIGIN IN MEMBER STATES 

  Table 5. Implementation choices in selected Member States 

Member State 

National implementation 

National schemes and specificities covering country of origin 

Denmark  

Regulation (EU) No 1337/2013 and the FIC Regulation are in 
force.  
In addition, a Danish national law is in force.  
There  is  also  a  guidance  document  on  food  labelling  from 
14 June 2014 covering the implementation and enforcement of 
Regulation (EU) No 1337/2013.  

France  

Regulation  (EU)  No  1337/2013  is  in  force.  Monitoring  is 
included  in  the  multiannual  national  monitoring  plan  in 
accordance  with  the  Official  Controls  Regulation  (EU) 
No 2017/625.  

National legislation allows for the voluntary use of the Danish flag to indicate meat reared and 
slaughtered in Denmark. The Danish flag can also be used:  
-  where  an  animal  was  reared  in  Denmark  and  slaughtered  elsewhere  as  long  as  information 
about the place of slaughter is provided;  
-  on  processed  products  as  long  as  most  ingredients  are  Danish  (e.g.  a  sausage  made  with 
Danish meat); 
- and on processed products with imported ingredients, but manufactured in Denmark as long as 
the country of origin of the ingredients is specified. 

Specificities per meat sector  
-  Swine  meat:  one  of  the  main  operators  uses  a  label  ‘100%  Dansk  svinekød’  (‘100%  Danish 
pork’) for cuts destined for the retail market in Denmark. 
- Poultry meat: since 2019, five poultry operators have used the voluntary label ‘Dansk Kylling’ 
(‘Danish chicken’) for poultry of Danish origin, generating a standard that must be followed in 
order to use this label. According to operators in the meat supply chain, the lack of an obligation 
to  provide  information  about  country  of  origin  for  poultry  in  the  food-service  market  is  a 
problem;  it  is  estimated  that  60-80%  of  poultry  meat  used  in  food  services  and  catering  is  of 
non-Danish origin. 
There are extensive national schemes for origin labelling of fresh meat and a pilot scheme for 
meat as an ingredient. 
The country of origin or the place of provenance of a primary ingredient must be given when 
this is not the same as the given country of origin or the given place of provenance of the food 
containing the primary ingredient.  
National schemes covering country of origin; other specificities 
-  Swine  meat:  ‘Le  Porc  Français’  (‘French  swine  meat’)  covers  98%  of  national  pig 
slaughtering.  
-  Poultry  meat:  ‘Volaille  française’  (‘French  poultry’)  is  based  on  an  inter-branch  agreement 
supported by the Association of French Poultry Producers.  
- Sheep/goat  meat: schemes by type of  meat are developed by inter-industry organisations for 
sheep  meat,  lamb,  goat  meat  and  kid  meat  (‘Viande  ovine  française’;  ‘Viande  d’agneau 
française’; ‘Viande de chèvre française’; and ‘Viande de chevreau français’).  
- Processed products: French  Decree No  2016-1137 of 19 August 2016 is a time-limited pilot 
scheme  which  makes  it  mandatory  for  operators  to  indicate  the  origin  of  the  meat  (all  types) 
used  as  an  ingredient  in  a  processed,  pre-packaged  product  containing  more  than  8%  meat 
irrespective of whether it is exported to non-EU countries or sold in the French market. 
- Catering sector: the French government has proposed to require indicating the origin of fresh 

45 

 
 
 
 
 
Germany  

Regulation (EU) No 1337/2013 is in force. There is a national 
food information implementing regulation that lays down the 
sanctions and legal aspects of Regulation (EU) No 1337/2013. 

meat  for  all  species  sold  in  all  restaurants;  this  is  an  extension  to  a  French  decree  that  has 
existed  for  bovine  meat  since  2002.  Since  2017,  all  French  food  products  containing  at  least 
85%  swine  meat  can  indicate  their  origin,  as  may  fresh  swine  meat  products  (including  also 
offal and prepared meats) with at least 94% swine meat content. 

There are more than 300 voluntary schemes that have an origin component for pig and poultry 
meat  in  Germany.  Individual  federal  states  in  Germany  also  have  their  own  origin-labelling 
schemes.  Examples  include  Bavaria,  Schleswig-Holstein  and  North  Rhine  Westphalia. 
Furthermore,  according  to  consumer  organisations,  the  lack  of  an  obligation  to  indicate  the 
country of birth for pigs, or country of origin for caterers and for meat as an ingredient poses 
problems for consumer understanding. For example, the light processing of meat (thus making 
it possible to indicate a German origin  for  mostly  non-German  meat) is said to be a common 
practice by operators to circumvent enforcement of the Regulation. 

Greece  

National  provisions  on  the  labelling  of  country  of  origin  for 
fresh,  chilled,  frozen  and  minced  meat  have  been  in  place 
since  the  2000s  in  Greece,  and  were  consolidated  in  Joint 
Ministerial  Decision  No.  412/8932/2012.  The  latter  was 
replaced  in  March  2018  by  Joint  Ministerial  Decision  No. 
1384/41923/2018 
formally  aligning  national 
legislation  to  Regulation  (EU)  No  1337/2013. There  are  also 
specific  national  rules  for  the  compulsory  labelling  and 
traceability of meat sold at butchers and butchery departments 
of food retailers (Article 9 of Law 4492/2017). 

fully  and 

-  Poultry  meat:  Larger  operators  use  voluntary  labelling  to  guarantee  that  fresh/chilled/frozen 
poultry  meat  comes  from  a  vertically-integrated,  closed  production  system  and  is  therefore  of 
Greek origin, or even originates from a  specific region in  Greece. There are also examples of 
voluntary origin labelling for poultry meat preparations/processed products, sold direct to final 
consumers and destined for the catering sector. 
Given  strong  consumer  demand  in  home-grown  –  and  often  locally  grown  –  meat,  there  is 
concern that consumers may be misled as to the origin of meat destined for catering/processing 
(e.g. meat contained in traditional meat preparations sold in fast-food premises), and as to the 
country of birth of sheep/goats. These gaps also pose problems for ensuring a level-playing field 
across operators. 

Ireland 

Regulation  (EU)  No  1337/2013 
in  force.  National 
legislation provides for enforcement procedures and penalties 
relating to the Regulation.  

is 

Italy 

Regulation  (EU)  No  1337/2013  is  in  force.  The  monitoring 
system  is  set  out  in  Legislative  Decree  No  231  of  15 
December  2017,  which  entered  into  force  on  9  May  2018. 

The Bord Bia Quality Mark, operated by the Irish Food Board, is a voluntary quality-assurance 
scheme which includes requirements on origin labelling. The scheme is applicable to a range of 
food  sectors  including  pig,  poultry  and  sheep/goat  meat.  The  scheme  also  covers  the  food-
manufacturing sector for products where the meat content exceeds a certain threshold.  
Concerns  over  misrepresentation  of  swine  meat  as  Irish,  predominantly  in  the  butchery  and 
processed food sectors, led the Irish Farmers’ Association to introduce a DNA testing system to 
verify Irish swine meat. This system has found high levels of compliance with Bord Bia Quality 
Mark products at retail level. However, products from food-service establishments have shown 
high levels of non-compliance (despite voluntary origin claims made by food-service operators). 
Although this  testing refers to origin labelling that is outside the scope of the  Regulation (i.e. 
non-pre-packed  meat  and  the  catering  sector),  the  potential  for  consumers  to  be  misled  was 
considered  sufficiently  serious  for  the  competent  authority  to  launch  a  consultation  into 
extending country-of-origin labelling to the non-pre-packed-meat market in 2015. However, to 
date no further action has been taken.  
There  is  no  additional  national  legislation  specifically  concerning  origin  labelling  other  than 
Regulation  (EU)  No  1337/2013  for  fresh,  chilled  and  frozen  swine  meat  in  Italy.  There  have 
been  several  attempts  to  set  up  voluntary  labelling  schemes  for  unprocessed  swine  meat,  but 

46 

 
 
 
 
 
Article 13 of the Decree laid down specific sanctions for non-
compliance with the provisions under Article 26 of Regulation 
(EU)  No  1169/2011  and  the  related  implementing  acts 
including Regulation (EU) No 1337/2013.  

Netherlands 

Regulation (EU) No 1337/2013 is in force.  

Poland 

Romania 

Spain 

Regulation (EU) No 1337/2013 is in  force. In addition, there 
is the Law of 7 November 2014, which amended the Law on 
trade  quality  of  agricultural  and  food  commodities  and  on 
food  and  nutrition  safety  and  the  Rule  of  the  Ministry  of 
Agriculture and Rural Development of 23 December 2014 on 
labelling foodstuffs.  

National  law  ref.150/2016  on  retail  amended  the  existing 
legislation to be in line with Regulation (EU) No 1337/2013. 
Government  Decision  106/2002  was  amended  to  include  the 
necessary monitoring framework.  

Regulation (EU) No 1337/2013 is in application. All national 
legislation in force relating to meat labelling was assessed and 
amended  as  necessary 
the 
Regulation.  

to  ensure  consistency  with 

these have not been successful. Ongoing initiatives remain in the developmental stage. 

There are no national schemes covering the origin for poultry meat other than Regulation (EU) 
No 1337/2013 in the Netherlands. There are examples of voluntary quality schemes that cover a 
variety  of  production  concerns  (with  animal  welfare  a  key  component).  These  do  not 
specifically cover origin, although quality is implied in that these are schemes operating in the 
Netherlands. 

There is a voluntary national labelling scheme, ‘Polish product’, which can be used in the swine 
meat and poultry meat sectors (Law of 4 December 2016). ‘Polish Product’ can be used for both 
fresh meat, where it corresponds to the use of the label ‘Origin: Poland’ under Regulation (EU) 
No 1337/2013, and meat products which are beyond the scope of the Regulation. Meat products 
must  also  be  processed  in  Poland  to  carry  the  ‘Polish  product’  label.  Other  ingredients  used 
must also be of Polish origin unless any cannot be replaced for technical reasons; in this case, 
these  ingredients  must  not  exceed  25% of  the  final  product  by  weight.  Non-pre-packed  fresh, 
chilled or frozen meat sold by weight should be origin labelled under national law (Rule of the 
Ministry of Agriculture and Rural Development of 1 April 2018). The rules are complementary 
to Regulation (EU) No 1337/2013. 

There are no additional national schemes in place other than Regulation (EU) No 1337/2013 on 
country-of-origin labelling for pig, poultry or sheep/goat meat. 

‘Alimentos de España’ (‘Food from Spain’) is a voluntary Spanish origin label for pig, poultry 
and sheep/goat meat. Under this initiative, 10 autonomous communities identify products from 
their own region,  using regional labelling. Operators comply  with those  voluntary schemes to 
pursue product-differentiation strategies. According to the industry, excluding processed swine 
meat from the scope of the Regulation poses problems, because a substantial volume of swine 
meat products marketed in Spain are only minimally processed (usually through addition of salt 
or spices). The  incomplete origin labelling of  non-pre-packed meat (sheep/goat  meat) at  retail 
level is also a problem, both for consumer understanding and for ensuring a level-playing field 
for operators. Finally, some labelling practices were identified in which consumers were led to 
believe meat comes from suckling lambs born and reared in Spain, when this is not in fact the 
case.  

Source: Evaluation support study. 

47 

 
 
Table 6. Inventory of existing national rules on country of origin  

Member State 

National regulation 

National quality certification 

National origin certification 

Czechia* 

Denmark 

France 

Finland* 

Germany 

Greece 

Ireland 

Italy 

Netherlands 

Statutory Order on Food Labelling no. 1355 of 27 November 2015 

Danish  Agriculture  &  Food 
Council 

Decree No 2016-1137 on labelling of the origin of meat used as ingredients 
in processed products. 

Label Rouge 

Upcoming  regulation  on  labelling  of  the  origin  of  meat  in  out-of-home 
catering (going beyond Regulation (EU) No 1337/2013). 

Decree of the Ministry of Agriculture and Forestry 218/2017 on indicating 
the origin of meat used as an ingredient in non-pre-packed food delivered 
by  mass  caterers  and  prepacked  foods  intended  for  a  final  consumer  or 
mass caterers and manufactured in Finland (going beyond Regulation (EU) 
No 1337/2013) 

Food Information Implementation Ordinance 

QS 

Voluntary scheme applying to all food to identify Czech origin by 
a Czech food logo (state-owned trademark), 2016. 

Voluntary labelling of  meat  with Danish flag, for  meat of Danish 
origin,  2014.Danish  Crown  ‘100%  Dansk  svinekød’  (‘100% 
Danish pork-meat’); ‘Dansk Kylling’ (‘Danish chicken’), 2019. 

French  origin  for  all  types  of  meat  ‘Viande  de  France’  (English: 
‘Meat from France’), 2014 

More  than  300  origin  and  quality  schemes  for  meat,  e.g. 
‘Regionalfenster’, 2014; or schemes of a federal state 

Joint Ministerial Decision No. 1384/41923/2018 

Statutory Instrument No. 113 of 2015 

Bord Bia Quality Mark 

Bord Bia Quality Mark, 1994 

Legislative Decree No 231 of 15 December 2017 

Food Commodities Act Decree on food labelling 

Beter Leven, IKB (Integrale 
Keten Beheersing/Integrated 
Quality Control) 

Poland 

Rule  of  the  Ministry  of  Agriculture  and  Rural  Development  of  1st  April 
2018 

Romania 

Law 150/2016 on Retail 

Spain 

Different  regional  initiatives  on  pork-meat:  Gran  Suino  Italiano; 
Consorzio di Garazia del Suino Italiano; Italico 

‘Polish product’ (state-owned trademark), 2017 

National label ‘Alimentos de España’ (‘Food of Spain’), 2015 (10 
labels introduced by autonomous communities to identify products 
coming  from  the  region);  voluntary  label  ‘Raza  autóctona’  ( 
Indigenous livestock breeds),  2013 

* Those Member States were not covered by case studies. The information presented here is based on their feedback to the surveys and on findings from desk research. 

Source: Evaluation support study 

48