Evaluation support study of the EU school fruit, vegetables and milk scheme : final report.
Date: 2022-11-23
Institutions: Directorate-General for Agriculture and Rural Development
Subjects: EU Member State, EU programme, United Kingdom, child, consumer survey, eating habits, food consumption, fruit, human nutrition, milk, nutritional needs, school environment, vegetable

Evaluation support study of 
the EU school fruit, vegetables 
and milk scheme 

Final Report 

Written by AGROSYNERGIE 
October 2022    

 Agrosynergie Groupement Européen d’Intérêt Economique  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Agriculture and Rural Development 
Directorate A – Strategy & Policy Analysis 
Unit A.3 – Policy Performance 

Contact:  

AGRI-EVALUATION@ec.europa.eu  

European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Evaluation support study of 
the EU school fruit, vegetables 
and milk scheme 

Final Report 

2022 

Directorate-General for Agriculture and Rural Development   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Evaluation support study of the EU school fruit, vegetables and milk scheme 

ABSTRACT 

The study aims to evaluate the EU school scheme for the supply of fruit and vegetables, 
and  milk  in  educational  establishments  set  out  in  Regulation  (EU)  No°1308/2013  and 
entered into force on 1 August 2017. 

The  analysis  covers  four  school  years  (2017/2018  to  2020/2021)  and  is  based  on 
secondary data and primary data collected through a family survey, a survey of scheme 
managing authorities and case study interviews. The geographical scope is EU-27 and UK 
until 2020.  

Results  show  that  the  school  scheme  is  relevant  in  relation  to  its  main  objectives  of 
“increasing  children's  consumption  of  selected  agricultural  products”  and  “improving 
children's eating habits”. 

The  Covid-19  pandemic  significantly  influenced  the  scheme  implementation  from  March 
2020: the increase of children participation in the fruits and vegetables part of the scheme 
recorded in the first 2 years was interrupted by the pandemic, whereas the milk part saw 
a gradual participation decline starting before the pandemic. Overall, the share of children 
receiving both fruits and vegetables and milk/milk products has increased compared to the 
previous  period  and  a  larger  variety  of  products  are  distributed,  indicating  that  more 
children benefit from a more varied supply of products. 

RESUME 

L'étude  vise  à  évaluer  le  programme  de  l’UE  en  faveur  de  la  distribution  de  fruits,  de 
légumes, et de lait dans les écoles établi par le Règlement (UE)°N 1308/2013 et entré en 
vigueur le 1er août 2017. 

L'analyse  couvre  quatre  années  scolaires  (2017/2018  à  2020/2021)  et  se  base  sur  des 
données secondaires et des données primaires collectées par le biais d'une enquête auprès 
des familles, d'une enquête auprès des autorités chargées de la gestion du programme et 
d'entretiens réalisés dans le cadre d'études de cas. La portée géographique est l'UE-27 et 
le Royaume-Uni jusqu'en 2020.  

Les résultats montrent que le programme à destination des écoles est pertinent par rapport 
à ses principaux objectifs, à savoir "augmenter la consommation des enfants de produits 
agricoles sélectionnés" et "améliorer leurs habitudes alimentaires". 

La pandémie de Covid-19 a considérablement influencé la mise en œuvre du programme 
à partir de mars 2020 : l'augmentation enregistrée de la participation des enfants au volet 
"fruits et légumes" du programme au cours des deux premières années a été interrompue 
par la pandémie, tandis que le volet "lait" a connu une baisse progressive de la participation 
débutée  avant  la  pandémie.  Dans  l'ensemble,  la  part  des  enfants  recevant  à  la  fois  des 
fruits et légumes et du lait/produits laitiers a augmenté par rapport à la période précédente 
et  une  plus  grande  variété  de  produits  est  distribuée,  ce  qui  indique  que  davantage 
d'enfants bénéficient d'un approvisionnement plus varié en produits. 

 
 
 
 
 
 
 
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

TABLE OF CONTENT 

1 
2 

INTRODUCTION ........................................................................................................ 1 
DESCRIPTIVE CHAPTER ............................................................................................ 2 
2.1 BACKGROUND TO THE EU SCHOOL SCHEME ...................................................... 2 
2.1.1  Consumption of F&V and milk/dairy in the EU ...................................... 2 
2.1.2  Healthy diet and good nutrition.......................................................... 4 
2.2 DESCRIPTION OF THE EU SCHOOL SCHEME AND ITS OBJECTIVES ........................... 6 
2.2.1  The regulatory framework ................................................................. 6 
2.2.2  The logic of intervention ................................................................... 9 
2.2.3  EU school scheme national/regional strategies ....................................13 
2.2.4  Implementation of the EU school scheme ...........................................14 
3  METHODOLOGICAL APPROACH TO THE EVALUATION SUPPORT STUDY ................... 19 
3.1 EVALUATION DESIGN ................................................................................ 19 
3.2 BASELINE .............................................................................................. 19 
3.3 CASE STUDY APPROACH ............................................................................. 19 
3.4 DATA COLLECTION ................................................................................... 21 
3.5 MAIN LIMITATIONS OF DATA AND ANALYSIS .................................................. 23 
ANSWERS TO THE EVALUATION QUESTIONS .......................................................... 25 
4.1 CAUSAL ANALYSIS ................................................................................... 25 
4.1.1  ESQ1 - To what extent has the EU school scheme contributed to increase 
children’s consumption of fruit, vegetables, milk and milk products? .....25 

4 

4.1.2  ESQ2 - To what extent has the EU school scheme contributed to healthy 

eating habits? .................................................................................44 

4.1.3  ESQ3 - Which factors influenced, and to what extent, the costs of the 

supply/distribution of products in the Member States implementing the 
scheme? ........................................................................................63 

4.1.4  ESQ4 - To what extent have the following implementation choices 

influenced the achievement of the objectives of the EU school scheme 
with respect to viable food production ...............................................73 
4.2 EFFECTIVENESS ....................................................................................... 85 

4.2.1  ESQ5 - To what extent has the EU school scheme contributed to the 

common agricultural policy general objective of viable food production? 85 
4.3 EFFICIENCY ............................................................................................ 98 
4.3.1  ESQ6 - To what extent has the EU school scheme been implemented in a 

cost-effective way? .........................................................................98 

4.3.2  ESQ7 - To what extent are the rules of the EU school scheme efficient 

with regard to the procedures at EU level? ....................................... 109 
4.4 COHERENCE .......................................................................................... 123 
4.4.1  ESQ 8 - To what extent has the EU school scheme been coherent with 

other measures and instruments of the CAP? ................................... 123 

4.4.2  ESQ 9 - To what extent has the EU school scheme been coherent with 
other relevant EU policies, notably health, education and environment?
 .................................................................................................. 133 

4.4.3  ESQ 10 - To what extent has the EU school scheme been coherent with 

other national policies and intervention in the agricultural, health and 
education sector? .......................................................................... 146 
4.5 RELEVANCE .......................................................................................... 155 
4.5.1  ESQ 11 - To what extent has the EU school scheme corresponded to the 

needs of the EU stakeholders? ........................................................ 155 
4.6 EU ADDED VALUE .................................................................................. 171 

 
 
 
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

4.6.1  ESQ 12 - What is the additional value resulting from the EU school 

scheme compared to what could have been achieved at Member State 
level? .......................................................................................... 171 
5  OVERALL CONCLUSIONS ....................................................................................... 179 
5.1 EFFECTS OF THE EU SCHOOL SCHEME WITH RESPECT TO ITS OBJECTIVES ............ 180 
5.2 COST EFFECTIVENESS OF THE EU SCHOOL SCHEME ......................................... 183 
5.3 COHERENCE OF THE EU SCHOOL SCHEME ..................................................... 185 
5.4 RELEVANCE OF THE EU SCHOOL SCHEME TOWARDS THE NEEDS OF THE EU 

STAKEHOLDERS ..................................................................................... 186 
5.5 EU ADDED VALUE OF THE EU SCHOOL SCHEME .............................................. 188 
RECOMMENDATIONS ............................................................................................. 189 

6 

 
 
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

List of tables 

Table 1: Reasons why products distributed at school are “often” or “sometimes” not 
consumed by children at school ...................................................................................... 37 
Table 2: Evolution of the share of children involved in the different types of educational 
measures on the total number of children participating in the EU school scheme (EU27, 
2017/18-2020/21, %) .................................................................................................... 48 
Table 3: % of MS implementing the different themes of the accompanying educational 
measures 2017/18-2020/21 ........................................................................................... 49 
Table 4:  Effect by age group related to children that ask to eat/eat more willingly than 
before the participation to the scheme the different products (percentage points) ........ 54 
Table 5: Transfers of Union aid between school fruit and vegetables and school milk ..... 81 
Table 6: EU school scheme: calculation of the definitive allocation of Union aid for the 
2020/2021 school year ................................................................................................... 89 
Table 7: EU school scheme – Union aid requested and unrequested ................................ 90 
Table 8: Children participating in the EU school scheme (number)* ............................... 90 
Table 9: Opinion of Public Authorities on whether the EU school scheme has been 
effective in contributing to a viable food production in the respective MS/region ........... 93 
Table 10: Quantities of the products – fruit and vegetables ............................................ 93 
Table 11: Quantities of the products – milk ..................................................................... 94 
Table 12: Budgetary Execution of EAGF (million EUR) ..................................................... 95 
Table 13 : Main EU references for Health, Education and Environment policies ............. 134 
Table 14 : Table of coherence EU school scheme-Health policy documents ................... 136 
Table 15 : Table of coherence EU school scheme-EU Environment policy documents .... 142 
Table 16 : MS implementing the different themes of the accompanying educational 
measures (average 2017-2021 in %) ............................................................................ 144 
Table 17 : Member States implementing initiatives related to EU school scheme and 
viable food production objectives .................................................................................. 147 
Table 18 : Needs expressed in national/regional EU school scheme strategies 2017-2023
 ...................................................................................................................................... 159 
Table 19 : Frequency and duration of product distribution in EU school schemes (*) .... 163 

List of figures 

Figure 1: Contribution of CAP measures to Viable Food Production ................................. 10 
Figure 2: Intervention logic of the EU school fruit, vegetables and milk scheme ............. 12 
Figure 3: Share of expenditure on allocation of Union aid – Total 2017/18-2020/21 (%)
 ........................................................................................................................................ 15 
Figure 4: Evolution of the number of children involved in EU School Scheme (EU27, 
EU27+UK, 2017-2021) .................................................................................................... 30 
Figure 5: Evolution of the number of children benefiting from the F&V and milk part of 
the EU scheme (EU27, 2017/18-2020/21) ...................................................................... 30 
Figure 6: No of children participating in the previous and in current EU Scheme (EU27, 
million)............................................................................................................................ 31 
Figure 7: Ratio No children benefiting from current EU scheme/average previous scheme 
(EU27, %) ....................................................................................................................... 31 
Figure 8: Evolution of the EU scheme coverage rate (EU27, %) ...................................... 32 
Figure 9: Average 2017/18-2020/21 coverage rate by MS (%) ...................................... 32 
Figure 10: % of children participating in the EU school scheme by school level (total 
number of children by year = 100%, EU 27) ................................................................... 33 
Figure 11: Distributed quantities in raw material equivalent ........................................... 34 
Figure 12: Evolution of the consumption per capita of milk and F&V (current and previous 
period (I.N. 2014/15 =100, EU27) .................................................................................. 35 
Figure 13: Evolution of ratio current/previous EU school scheme (EU27) ....................... 35 
Figure 14: Change in the quantities consumed by children outside of school, after the 
participation in the EU school scheme ............................................................................. 38 
Figure 15: Families having received information about the EU scheme and families who 
know that the program is funded by the EU: total and case studies MS (%) ................... 50 
Figure 16: Lessons learned at school by children participating in the EU school scheme 
(% of families) ................................................................................................................ 51 
Figure 17: Net effects by MS: Relation between “eats willingly more than before” and 
“asks for the products more than before” (percentage points) ....................................... 55 

 
 
 
 
 
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

Figure 18: Change in the frequency of children’s consumption outside school, after the 
participation in the EU school scheme (target group) and in the last year (control group)
 ........................................................................................................................................ 56 
Figure 19: Differences between the target group and the control group of the increase % 
of quantity and frequency of consumption of the different categories of products (% 
points) ............................................................................................................................ 57 
Figure 20: Differences between the target group and the control group of children 
consuming at least once a day and not consuming the analysed products (% points) .... 58 
Figure 21: Families stating a frequency of consumption of “3 or more times a day”: 
Difference in % points between the target group and the control group – net effect ...... 59 
Figure 22: Correlation between n. of products chosen and costs of distribution.............. 66 
Figure 23: Link between the EU school scheme design and other national policies and 
interventions in the agricultural, health and education sector ...................................... 149 
Figure 24: Public Authorities’ opinions regarding the “Extent to which the EU school 
scheme has been adequate in addressing needs” ......................................................... 164 
Figure 25 : Opinion of school scheme MA about the benefits of implementing the school 
scheme at EU level rather than at national/regional level alone ................................... 173 
Figure 26 : Opinion of school scheme managing authorities about the extent to which 
national aid has complemented the Union aid ............................................................... 176 

 
 
 
 
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

List of acronyms 

AEM 
AMR 
CAP 
CAWI 
CB 
CEA 
CMEF 
CMO 
CS 
DG EAC 
DG AGRI 
EC 
EDA 
EFSA 
EAGF 
EE 
ESQ 
FAO 
F&V 
ISAMM 
ISSG 
JC 
LA 
MA 
MSA 
MS 
NA 
NPA 
OSC 
PA 
PO 
PDO 
PPP 
SCO 
SIQO 
TFEU 
VFP 
WTO 

Accompanying Educational Measures 
Annual Monitoring Report 
Common Agricultural Policy 
Computer Assisted Web Interviewing 
Cost based 
Cost-Effectiveness Analysis 
Common Monitoring and Evaluation Framework 
Common Market Organisation 
Case Study 
Directorate-General Education, Youth, Sport and Culture 
Directorate-General Agriculture and Rural Development 
European Commission 
European Dairy Association 
European Food Safety Agency 
European Agricultural Guarantee Fund 
Educational establishments 
Evaluation Support Study Question 
Food and Agriculture Organization of the United Nations 
Fruit & Vegetables 
Information System for Agricultural Markets 
Inter-Service Steering Group 
Judgement criterion 
Local Authority 
Managing Authority 
Member State Aggregate 
Member State 
National Authority 
National Payment Agency 
On-the-Spot Checks 
Public Authority 
Producers’ Organisation 
Protected Designation of Origin 
Purchasing Power Parity 
Standard Cost Option 
“Signe official d’identification de la qualité et de l’origine” 
Treaty on the Functioning of the European Union 
Viable Food Production 
Word Health Organisation 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

1 

INTRODUCTION 

The study aims to provide an evaluation of the Union aid scheme for the supply of fruit and 
vegetables,  and  milk  in  educational  establishments  set  out  in  Regulation  (EU) 
No 1308/2013  (hereafter  the  EU  school  scheme),  in  order  to  support  the  review  of  the 
legislative framework for the scheme that the European Commission will propose in 2023, 
as part of the actions under the Farm to Fork Strategy that aims to accelerate the transition 
to a sustainable food system. 

The EU school scheme  unifies under a single common legal and financial framework the 
individual previous schemes operating for fruit and vegetables (from 2009) and for milk 
(from 1977).  

The scheme supports the distribution of selected agricultural products to schoolchildren, 
from  nursery  to  secondary  school  and  educational  measures  with  the  objective  of 
increasing the consumption of the products and shaping healthier diets. 

The  implementation  of  the  EU  school  scheme  is  characterised  by  a  high  degree  of 
subsidiarity,  and  Member  States  (MS)  participating  in  the  scheme  design  a  six-year 
strategy, at national or regional level.  

The  products  eligible  for  distribution  the  scheme  as  defined  by  Regulation°(EU) 
N 1308/2013,  are:  fresh  fruit  and  vegetables;  processed  fruit  and  vegetables  products; 
fresh  products  of  the  banana  sector;  drinking  milk;  cheese,  yoghurt  and  other  milk 
products  without  added  flavourings,  fruit,  nuts  or  cocoa;  milk  products  with  added 
flavourings, fruit, nuts or cocoa. Other agricultural products can be included in educational 
measures. 

The total financial allocation for the EU school scheme was EUR 250 million per school year 
for  the  years  2017/2018  to  2019/2020,  EUR 245.1 million  for  the  year  2020/2021  and 
EUR 220.8 million for the years 2021/2022-2022/2023 after the withdrawal of the UK from 
the EU. The financial allocation is broken down by fruit and vegetables (F&V) and milk and 
by MS that have the possibility of requiring transfers between the F&V part and the milk 
part of the scheme. The financial allocation is assigned to MS according to criteria based 
on the number of six to ten-year old children, the level of regional development and, for 
milk, on the previous scheme utilisation of the budget. 

The evaluation support study provides answers to 12 evaluation questions grouped under 
six criteria: causal analysis, effectiveness, efficiency, coherence, relevance, and EU added 
value. 

The analysis covers the implementation period of the EU school scheme, from its entry into 
force as of 1 August 2017 for four school years (from 2017/2018 to 2020/2021). Longer 
observation periods were taken into account according to the needs of the analysis mainly 
with respect to patterns of consumption of fruits and vegetables (F&V) and milk and milk 
products across the EU since 2010 and to related health and nutrition issues.   

The geographical scope of the analysis is EU-27 and the United Kingdom that implemented 
the scheme until December 2020. 

1 

Evaluation support study of the EU school fruit, vegetables and milk scheme 

2  DESCRIPTIVE CHAPTER  

2.1  Background to the EU school scheme  

2.1.1  Consumption of F&V and milk/dairy in the EU  
This part analyses F&V and milk/dairy consumption trends across the EU and changes in 
patterns  of  consumption  based  on  official  statistics  and  data  from  other  sources,  as 
reported in detail in the following sections. Data generally refer to the whole population, 
only some data report consumption by children and adolescents in some EU MS based on 
national  survey  data  collected  at  different  points  in  time  (the  detail  is  provided  in  the 
sections below).  The presented data overall cover the years 2010 to  2019-20201 across 
the EU-28 (or EU-27 where UK data were not available). 

Apparent consumption of fruit, vegetables and milk/dairy (2010-2019/2020) 

Data on apparent consumption computed from national food balance sheet and trade data 
sourced  from  FAOSTAT,  Food  balance  sheets2,  partly  based  on  Eurostat  data;  European 
Commission,  DG  Agriculture  and  Rural  Development,  Short-term  Outlook3,  Freshfel 
Europe,  F&V  Consumption  Monitoring4,  based  on  Eurostat  and  FAOSTAT  data.  Apparent 
consumption data have some limitations mostly due to lack of official data across the MS 
on stocks/stock variations, waste/losses and domestic use by the processing industry (food 
and feed), but in some cases also due to unexpected year to year variations. Therefore, 
apparent consumption data should be regarded with caution, though they can provide an 
indication of overall trends. 

Data sourced from the FAOSTAT database (2010 to 2019) show that consumption at EU 
28  level  (kg/capita/year)  has  overall  increased  for  fruit  (+10.2%,  for  a  corresponding 
1.09%  average  annual  increase),  but  decreased  for  vegetables  (- 7.4%,  for  a 
corresponding  - 0.83%  average  annual  decrease).  The  overall  increase  in  fruit 
consumption is the result of different and compensating trends across the MS: an increase 
is  shown  across  most  MS,  but  more  noticeable  in  Belgium,  Bulgaria,  Latvia,  Lithuania, 
Romania. The (larger or smaller) decrease in vegetables consumption recorded between 
2010 and 2019 in 16 MS does not appear to be compensated by increase in the remaining 
ones.  

Changes in consumption based on FAOSTAT data are overall confirmed by data sourced 
from Freshfel Europe, which report daily per capita consumption in grams and can therefore 
provide  means  of  comparison  with  recommended  daily 
intake  (i.e.,  400g/day 
approximately)5. Between 2014 and 2019, overall F&V consumption across the EU shows 
a slight decline from 353.1 to 349.2 g/day on average (- 1.1%), resulting from a combined 

1 EFSA data cover also years prior to 2010 depending on MS’ dietary surveys. 
2 https://www.fao.org/faostat/en/#data/FBS. 
3 http://ec.europa.eu/agriculture/markets-and-prices/short-term-outlook/index_en.htm . 
4 Freshfel Europe (European Fresh Produce Association) periodically releases F&V consumption monitoring data 
and reports. The most recent ones for 2014 (EU28) and 2019 (EU27) report apparent consumption data based 
on production from FAOSTAT and trade from EUROSTAT, taking also into account fresh produce volumes destined 
to industrial processing and product loss/waste (on average 20% of gross supply) to arrive at net consumption 
figures  (gram/capita/day).  Population  data  are  sourced  from  EUROSTAT.  https://freshfel.org/what-we-
do/consumption-monitor/ . 
5https://knowledge4policy.ec.europa.eu/health-promotion-knowledge-gateway/food-based-dietary-guidelines-
europe-table-
3_en#:~:text=At%20least%205%20portions%20of%20fruit%20and%20vegetables%20per%20day.,-
%2D&text=5%20servings%20(approximately%20400%20g,contain%20little%20or%20no%20fibre. 

2 

                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

decrease  in  vegetables  consumption  (- 11.3%)  and  a  less  than  proportional  increase  in 
fruit consumption (+ 7.4%). Only a handful of MS consume close to or over 400g of F&V 
per  capita/day,  including  the  Mediterranean  countries  (Italy,  Greece,  Portugal,  Spain, 
Cyprus), but also Belgium, Austria and Poland (Austria, Spain and Cyprus however show a 
decrease  below  the  400g/capita/day  in  2019).  Only  few  MS  show  an  increase  in 
consumption  of  both  fruit  and  vegetables  between  2014  and  2019:  Belgium,  Bulgaria, 
Croatia, Czechia, Luxembourg, Poland and Slovakia. 

Milk  and  dairy  apparent  consumption  data  were  sourced  from  DG  Agriculture  and  Rural 
Development EU fresh dairy products balance sheet6. Consumption figures (i.e., domestic 
use  including  stock  variations)  are  aggregate  for  fresh  dairy  products  including  drinking 
milk, cream, acidified milk and other fresh dairy products7. Apparent consumption of fresh 
dairy products at EU27 level overall decreased by 3.9% between 2010 and 2021 (38 721 
to  37 213  thousand  tonnes).  Correspondingly,  per  capita  consumption  dropped  from 
88.2kg  in  2010  to  83.3kg  in  2021  (- 5.2%).  Conversely,  cheese  apparent  consumption 
shows an upward trend at EU27 level from 2010 to 2021, with an overall 19.4% increase 
(from  7 829  to  9 360  thousand  tonnes).  Correspondingly,  per  capita  consumption 
increased from 17.8kg in 2010 to 21kg in 2021 (17.8%). 

F&V daily consumption patterns  

The  most  recent  EHIS  data  (source:  Eurostat,  European  Health  Interview  Survey 
(EHIS8 2019)  show  that  at  EU  level  about  55%  of  people  >15  years  old  consume  “1-4 
portions” of F&V daily and only 12.4% eat “5 portions or more” of F&V per day, with the 
remaining 33% not consuming F&V on a daily basis.  

Children and adolescents’ consumption of fruit, vegetables and milk/dairy  

Statistics on chronic  and acute food consumption (“all subjects” in g/day) sourced from 
the  European  Food  Safety  Agency  (EFSA)  Comprehensive  Food  Consumption  Database9 
were used to analyse children and adolescents’ consumption of 5 categories of food: Fruit 
and  fruit  products,  Fruit  and  vegetables  juices  and  nectars,  Vegetables  and  vegetable 
products,  Milk  and  dairy  products,  and  also  Sugar  and  similar,  confectionery  and  sweet 
desserts (EFSA uses its own food classification system ‘FoodEx’ developed in 2009). The 
source of EFSA’s consumption statistics are dietary surveys undertaken in a number of EU 
MS  at  different  points  in  time,  some  of  which  include  data  for  the  younger  age  groups: 
infants (up to and including 11 months); toddlers (from 12 up to and including 35 months 

6 Short-term Outlook : http://ec.europa.eu/agriculture/markets-and-prices/short-term-outlook/index_en.htm). 
7 Drinking milk represents nearly two thirds of total fresh dairy products. 
8 The European Health Interview Survey (EHIS) (online data code: hlth_ehis_fv1-2-3) aims at measuring on a 
harmonised  basis  and  with  a  high  degree  of  comparability  among  MS  the  health  status  (including  disability), 
health  determinants  (lifestyle,  including  patterns  of  F&V  consumption)  of  EU  citizens  and  use  of  health  care 
services.  EHIS  wave  1  was  conducted  in  19  European  countries  between  2006  and  2009.  EHIS  wave  2  was 
conducted in all MS, Iceland, Norway and Turkey between 2013 and 2015. Data have been gradually disseminated 
from  the  third  quarter  of  2016.  EHIS  wave  3  was  conducted  in  all  MS,  Iceland,  Norway,  Albania,  Serbia  and 
Turkey,  between  2018  and  2020.  Data  have  been  gradually  disseminated  from  the  third  quarter  of  2021. 
https://ec.europa.eu/eurostat/web/products-eurostat-news/-/ddn-20220104-1  
9 The Comprehensive Food Consumption Database is a source of information on dietary exposure across the EU. 
It contains detailed data for a number of EU countries. In the database, dietary surveys and food consumption 
data for each country are divided by category. These include: age, from infants to adults aged 75 years or older; 
food group  (over 1,500)  and type of  consumption,  covering  both  regular  and  high consumption  thus  allowing 
calculations to be tailored to each category of consumer. The database plays a key role in the evaluation of the 
risks  related  to  possible  hazards  in  food  in  the  EU  and  allows  the  assessment  of  nutrient  intakes  of  the  EU 
population. The statistics on food consumption are reported in grams per day (g/day) and grams per day per kg 
of body weight (g/kg bw per day). The statistics for chronic food consumption are available for the total population 
(‘all subjects’) and for consumers of respective food categories.https://data.europa.eu/data/datasets/the-efsa-
comprehensive-european-food-consumption-database?locale=en. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

of age); other children (from 36 months up to and including 9 years of age) and adolescents 
(from 10 up to and including 17 years of age). Until 2010, MS have used different methods 
to collect food consumption data, which makes it difficult to carry out EU-wide analyses or 
country-to-country comparisons. Since 2011, EFSA provides guidance for the collection of 
more harmonised food consumption data among MS through the EU Menu project "What's 
on  the  Menu  in  Europe?".  Therefore,  the  data  presented  here  should  be  regarded  with 
caution as they only provide an indication of overall consumption patterns and changes. 

The  analysis  covers  those  MS  with  survey  data  available  for  at  least  2  years10  (i.e.,  the 
most recent surveys are comprised between 2012 and 2018 and the previous ones in any 
year  they  were  available,  even  before  2010)11.  The  analysis  was  possible  for  the 
“adolescents” group and for “other children”. Analysis for “other children” aged 36 months 
up to and including 9 years of age (3 MS: France, Spain and Latvia) shows an increase in 
consumption of fruit and fruit products, vegetables and vegetable products and fruit and 
vegetable juices and nectars in all three MS and, conversely, a decrease in consumption of 
sweets and confectionery products. Milk/dairy consumption increased in France and Latvia 
and decreased in Spain. The analysis on adolescents (from 10 up to and including 17 years 
of age) includes a larger number of MS. Adolescents’ consumption of fruit/fruit products 
and vegetables/vegetable products generally increased in all MS (Austria, Belgium, Cyprus, 
France, Latvia, the Netherlands and Spain), with only Cyprus recording a slight decrease 
in fruit/fruit products. Consumption of milk and dairy increased only in Cyprus, France and 
Latvia. Consumption of sweets and confectionery products decreased in all considered MS 
with the exception of Cyprus and Belgium (basically no change in consumption). 

The European Dairy Association (EDA) represents an additional source of information on 
milk/dairy  consumption  by  children  and  adolescents  in  some  MS  through  data  collected 
from  national  sources  at  different  points  in  time  (as  far  back  as  2003  in  Czechia  and 
Hungary and as recently as 2019 in Belgium) and presented in fact-sheet format12. Detail 
of children and/or adolescent consumption is however not available for Croatia, Finland, 
France,  Germany,  Hungary,  Ireland,  Lithuania,  Luxembourg,  Malta,  Poland,  Romania, 
Slovakia, Spain and Sweden. For some MS, the data reported by EDA are from the same 
national  survey  data  collected  in  the  EFSA  Comprehensive  Database  already  presented 
above. 

2.1.2  Healthy diet and good nutrition  
According to the World Health Organization (WHO) “a healthy diet helps to protect against 
malnutrition  in  all  its  forms,  as  well  as  non-communicable  diseases  (NCDs).  Therefore, 
healthy dietary practices start early in life and may have longer term health benefits”13. 

The exact make-up of a healthy diet evolves over time, being influenced by many individual 
characteristics  (e.g.,  age,  gender,  lifestyle  and  degree  of  physical  activity),  social  and 
economic factors (e.g., local availability, income, food prices), individual preferences and 
beliefs, cultural traditions, and geographical and environmental aspects (including climate 

10 Austria (2010,2018); Belgium (2004,2014); Cyprus (2003, 2014); France (2007, 2014); Latvia (2008, 2012); 
the Netherlands (2007, 2012); Spain (2004, 2012); Sweden (2003, 2016). 
11 The data were downloaded from EFSA Comprehensive European Food Consumption Database on 18/3/2022. 
https://www.efsa.europa.eu/en/data-report/food-consumption-data#the-efsa-comprehensive-european-food-
consumption-database. 
12 
https://eda.euromilk.org/fileadmin/user_upload/Public_Documents/EDA_Position_papers_-
_Fact_Sheets/Fact_sheets/EDA_Factsheet_-_Daily_Dairy_Recommendations.pdf. 
13 https://www.who.int/news-room/fact-sheets/detail/healthy-diet . 

Fact-sheet 

published 

following 

available 

2021 

URL: 

the 

at 

in 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

change).  Therefore,  promoting  a  healthy  food  environment  requires  the  involvement  of 
multiple sectors and stakeholders, including public and private sectors. Nevertheless, the 
basic principles of what constitutes a healthy diet remain the same, so that the WHO has 
released 5 key points14: breastfeed babies and young children; eat a variety of food; eat 
plenty of  vegetables and fruit; eat moderate amounts of  fats  and oils; eat less  salt and 
sugars. 

Moreover, the FAO Committee on World Food Security states that “healthy diets are those 
diets that are of adequate quantity and quality to achieve optimal growth and development 
of all individuals and support functioning and physical, mental and social wellbeing at all 
life stages and physiological needs. The exact make-up of healthy diets varies depending 
on  an  individual’s  characteristics  (e.g.,  age,  gender,  lifestyle  and  degree  of  physical 
activity), geographical, demographical, cultural patterns and contexts, food preferences, 
availability of foods from local, regional and international sources, and dietary customs”15. 

When speaking about healthy diet, fruit and vegetables are vital for the proper functioning 
of the human body11,16, while milk and dairy products play a key role in healthy human 
nutrition  and  development  throughout  life,  but  especially  in  childhood11,17.  The 
consumption of fruit and vegetables has been included by the European Commission as a 
determinant  of  health  indicators  within  the  European  Core  Health  Indicators  (ECHI)18. 
Indeed,  good  nutrition,  a  healthy  diet  combined  with  regular  physical  activity,  is  a 
cornerstone for good health19.  

Recommendations  concerning  the  daily  consumption  of  these  food  groups  vary  from 
country  to  country,  with  the  WHO  Regional  Office  for  Europe  committed  to  encouraging 
and  supporting  countries  to  develop  and  implement  their  own  food-based  dietary 
guidelines  (FBDG)20.  Despite  country-specific  dietary  guidelines  for  healthy  diets,  the 
consumption  of  roughly  "5  a  day"  portions  of  fruit  and  vegetable  is  generally 
recommended,  also  for  children21,22  .  As  regards  milk  and  dairy  products,  while  a 
quantification  of  portions  and  sizes  is  unclear  and  often  difficult  to  interpret,  especially 
when referring to children, most of the  MS recommend from 2-3 to 3-4 portions of milk 
and dairy products per day23. 

When specifically considering childhood, as defined by FAO, “good nutrition and access to 
an  adequate  diet  and  health  are  essential  for  child  growth  and  development,  body 
maintenance and protection from both infectious and non-communicable diseases (NCDs) 
in adult life”24. Consuming an unhealthy diet, particularly foods rich in salt, free and added 
sugars  and  fats,  represents  a  major  risk  factor  for  the  development  of  NCDs,  such  as 
cardiovascular  diseases,  and  the  high-calorie  intake  of  such  foods  is  associated  to 
unhealthy weight gain, leading to overweight and obesity. Moreover, children having pre-

14 https://www.who.int/multi-media/details/5-keys-to-a-healthy-diet . 
15 Committee on World Food Security, The CFS Voluntary Guidelines on Food Systems and Nutrition (VGFSyN), 
2021. https://www.fao.org/3/ne982en/ne982en.pdf . 
16 FAO.  2020. Fruit  and  vegetables  – your  dietary essentials.  The International  Year of Fruits  and  Vegetables, 
2021, background paper. Rome. 
17 FAO 2013. Milk and dairy products in human nutrition. https://www.fao.org/documents/card/en/c/5067e4f2-
53f8-5c9a-b709-c5db17d55c20/. 
18 European Commission website. European Core Health Indicators (ECHI). 
19 Eurostat Statistics Explained. Overweight and obesity. 
20 European Commission. Food-Based Dietary Guidelines in Europe (FBDG). 
21 Diet, nutrition and the prevention of chronic diseases. Joint WHO/FAO Expert Consultation 2003. 
22 WHO Regional Office for Europe. Promoting food and vegetable consumption. 
23https://knowledge4policy.ec.europa.eu/health-promotion-knowledge-gateway/food-based-dietary-guidelines-
europe-table-7_en . 
24FAO 2013. Milk and dairy products in human nutrition. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

obesity or obesity are exposed to a higher risk of developing serious health problems, non-
communicable diseases including type 2 diabetes, high blood pressure, asthma and other 
respiratory problems, sleep disorders and liver disease. Children living with obesity may 
also  suffer  from  psychological  effects,  such  as  low  self-esteem,  depression  and  social 
isolation25. In 2012, the  World Health Assembly Resolution specified a set of six “Global 
Nutrition  Targets”  to  be  achieved  by  2025,  recognizing  that  accelerated  global  action  is 
needed  to  address  the  pervasive  and  corrosive  problem  of  the  double  burden  of 
malnutrition,26 with the purpose of not increasing childhood overweight in children under 
5  years  of  age27.  This  target  is  also  part  of  the  “Sustainable  Development  Goals  2030 
Agenda: SDG 2” (to end all forms of malnutrition), (Target 2.2.2b) and SDG 3: to reduce 
by  one-third  pre-mature  mortality  from  non-communicable  diseases  through  prevention 
and  treatment  and  promote  mental  health  and  wellbeing  (Target  3.4)28.  Additionally,  in 
2014,  the  “EU  Action  Plan  on  Childhood  Obesity”  was  launched  to  invite  MS  to  promote 
policies and initiatives aiming at healthy diet throughout the life span, within family and 
school environments (i.e., to reduce the  exposure  of children to foods high in saturated 
fats, trans fatty acids, added sugars or salt)29. Since children spend much of their day at 
school, schools are an essential environment to provide healthy food and to limit access to 
snacks or other less healthy food, to ensure that the healthy option is always the easier 
option and that education on healthy and sustainable diets is improved. As an example, 
the milk part of the EU School Scheme can promote consumption of milk as an alternative 
to  sugar-sweetened  beverages,  while  the  F&V  part  of  the  EU  School  Fruit  Scheme  can 
improve the accessibility of fruit and vegetables, promoting the use of local products30. In 
addition, the EU scheme can contribute to reducing inequalities31. 

Improving access to healthy diets is also an objective of the Europe’s Beating Cancer Plan 
to  improve  health  promotion  and  reduce  risk  factors  for  cancer.  In  line  with  the  Cancer 
Plan  and  the  need  to  address  obesity  and  diabetes  already  in  early  childhood,  the 
Commission will propose a revision of the EU School fruit, vegetables and milk scheme in 
2023 to make healthy products more available to children and improve their understanding 
of the benefits of healthy food.  In addition, the ‘HealthyLifestyle4all’  campaign that was 
launched in 2021 to contribute to the objectives of the Cancer Plan, involves activities and 
sectors  such  as  promoting  sport,  physical  activity  and  healthy  diets,  to  be  channelled 
through key initiatives like the EU School Scheme32. 

2.2  Description of the EU school scheme and its objectives  

2.2.1  The regulatory framework  

The aid scheme for the supply of fruit and vegetables, bananas and milk in the educational 
establishments (hereafter EU school scheme) is set out by the following regulations: 

  Basic act: Regulation (EU) N 1308/2013 of the European Parliament and of the Council 
of 17 December 2013 establishing a common organisation of the markets in agricultural 
products (CMO) and Regulation (EU) N 1306/2013 of the European Parliament and of 
the Council of 17 December 2013 on the financing, management and monitoring of the 

25 WHO Global nutrition targets 2025: childhood overweight policy brief (WHO/NMH/NHD/14.6) 2014. 
26 WHO Global nutrition targets 2025: policy brief series (WHO/NMH/NHD/14.2) 2014. 
27 De Onis M, et al., Global prevalence and trends of overweight and obesity among preschool children. Am J Clin 
Nutr. 2010 Nov; 92(5):1257-64. doi: 10.3945/ajcn.2010.29786. Epub 2010 Sep 22. 
28 SDG indicators, Sustainable development Goals.  
29 WHO European Food and Nutrition Action Plan 2015-2020. 
30 EU Action Plan on Childhood Obesity 2014-2020. 
31 https://data.unicef.org/sdgs/goal-10-reduced-inequalities/. 
32 https://health.ec.europa.eu/system/files/2022-02/eu_cancer-plan_en_0.pdf. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

common  agricultural  policy,  as  amended  by  Regulation (EU) N 2016/791  of  the 
European Parliament and of the Council of 11 May 2016; 

  Financial 

provisions: 

Regulation (EU) N 1308/2013, 

by 
Regulation (EU) 2021/2117  of 
the  European  Parliament  and  of  Council  of 
2 December 2021.  Council  Regulation (EU) N 1370/2013  of  16 December 2013 
determining  measures  on  fixing  certain  aids  and  refunds  related  to  the  common 
organisation  of 
in  agricultural  products,  as  amended  by 
the  markets 
Council Regulation (EU) 2016/795 of 11 April 2016; 

amended 

as 

  Detailed 

and 

technical 

implementing 

rules: 
Commission Delegated Regulation (EU) N 2017/40 of 3 November 2016 supplementing 
Regulation (EU) N 1308/2013 of the European Parliament and of the Council with regard 
to  Union  aid  for  the  supply  of  fruit  and  vegetables,  bananas  and  milk  in  educational 
establishments  and  amending  Commission Delegated Regulation (EU) N 907/2014. 
Commission Implementing Regulation (EU) N 2017/39 of 3 November 2016 on rules for 
the application of Regulation (EU) N 1308/2013 of the European Parliament and of the 
Council with regard to Union aid for the supply of fruit and vegetables,  bananas and 
milk in educational establishments. 

This regulatory  framework unifies under a single  common legal and financial framework 
the  individual  previous  schemes  operating  for  fruit  and  vegetables  (from  2009)  and  for 
milk (from 1977). In particular, Regulation (EU) N 1308/2013 (article 22) establishes that 
the EU school scheme  “intended to improve the distribution of agricultural products and 
improving children's eating habits is aimed at children who regularly attend nurseries, pre-
schools or primary or secondary-level educational establishments which are administered 
or recognised by the competent authorities of Member States”.   

Accordingly,  the  EU  school  scheme  supports  the  distribution  of  selected  agricultural 
products to schoolchildren, from nursery to secondary school33.  MS choose the products 
on  the  basis  of  objective  criteria  which  may  include  health  and  environmental 
considerations,  seasonality,  variety  or  availability  of  produce,  giving  priority,  as  far  as 
practicable, to EU products, and particularly to local purchasing, local markets, short supply 
chains or environmental benefits. 

The  scheme  also  supports  accompanying  educational  measures  (AEM)  that  can  include 
lessons but also farm visits, school gardens, tasting and cooking workshops, theme days 
and games. Their objective is to reconnect children to agriculture and teach them about 
healthy  eating habits  and  issues  such  as  local  food  chains,  organic  farming,  sustainable 
production  and  food  waste.  Funding is  also  available  for  information  activities  to  ensure 
the visibility of the scheme34, as well as monitoring and evaluation to account for the proper 
functioning of the scheme. 

The EU  school scheme is currently funded by the European Agricultural Guarantee Fund 
(EAGF) under the CMO  and the  total financial allocation, was set at  EUR 250 million per 
school year broken down by F&V and milk and by MS (Regulation (EU) No 1370/2013 as 
amended by Regulation (EU) 2016/795, Annex I) for the years 2017/2018 to 2019/2020 
and  EUR 245.1 million  for  the  year  2020/2021.  Following  the  withdrawal  of  the  United 
Kingdom  from  the  Union,  the  total  financial  allocation  under  the  EU  school  scheme  was 
updated at EUR 220.8 million from 1 January 2021 (Regulation (EU) N 2021/2117). 

MS  wishing  to  participate  in  the  EU  school  scheme  are  to  present  to  the  European 
Commission a six-year strategy drawn up at national or regional level, containing specific 

33  The  different  products  groups  covered  by  the  scheme  and  listed  in  articles  (23(3)(4)  and  (5)  of 
Regulation (EU) No  1308/2013  are:  fresh  fruit  and  vegetables;  processed  fruit  and  vegetables  products  and 
banana products; drinking milk; cheese, yoghurt and other milk products without added flavourings, fruit, nuts 
or cocoa; milk products with added flavourings, fruit, nuts or cocoa. Other products can be included in educational 
measures but are not regularly distributed/supplied. 
34 Article 12 of Implementing Regulation (EU) 2017/39. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

elements. MS strategies are notified (i.e., not approved by the European Commission) and 
during the implementation may be amended. 

The  strategies  are  to  include  at  least  the  needs  to  be  met,  the  ranking  of  the  needs  in 
terms  of  priorities,  the  target  group,  the  list  of  products  to  be  distributed,  the  results 
expected to be achieved and, if  available, the  quantified targets to be attained, and lay 
down  the  most  appropriate  instruments  and  actions  for  attaining  those  objectives.  
Furthermore,  MS  are  to  indicate  in  those  strategies  the  objectives  and  content  of  the 
educational measures, the rules about aid applications, the rules on the payment of the 
aid  in  accordance  with  the  strategy  (e.g.,  use  of  standard  scales  of  unit  costs,  flat-rate 
financing  and/or  lump  sums),  and  the  activities  of  information,  communication  and 
publicity to inform the public about the Strategies and the Union's financial contribution to 
the school scheme. See 2.2.3 for details on MS’ current strategies. 

In order to ensure the efficient use of Union aid and to facilitate the implementation of the 
EU  school  scheme,  MS  must  submit  every  year  a  request  for  Union  aid35.  Following  the 
requests, the European Commission each year adopt implementing acts fixing the definitive 
allocation of the aid. 

on  monitoring 

MS  are  also  required  to  monitor  and  evaluate  the  effectiveness  of  their  school  scheme. 
Rules 
regulation 
(Delegated Regulation (EU) N 2017/40 and Implementing Regulation (EU) N 2017/39), and 
in  particular  those  related  to  the  annual  monitoring  reports  by  MS  to  the  Commission, 
which have to include financial data and other information on the actual implementation36.  

evaluation 

down 

and 

laid 

are 

by 

Regarding evaluation, MS are required to submit to the Commission a first report covering 
the results of the first 5 school years (from 1 August 2017 to 31 July 2022) by March 2023. 
To assist MS in their evaluation, the European Commission provided them with non-binding 
Guidelines  (Ares  (2018)5450792  -  24/10/2018).  The  guidelines  provide  definitions  and 
examples, common evaluation questions and indicators, topics for the assessment of the 
functioning  of  the  school  scheme,  as  well  as  an  outline  for  the  evaluation  report  for 
consistent  and  comparable  results  among  MS.  Subsequently,  and  building  on  those 
guidelines, the Commission set out minimum requirements for the format and content of 
the MS' evaluation reports, in annex to Regulation (EU) N 2017/39. 

Finally, the competent authorities of the MS are to draw up a control report on each on-
the-spot check37, describing the different items controlled, and submit to the Commission 
an annual control report on the checks carried out and the related findings. 

35 Information to be provided are related e.g. to the indicative allocation of aid for school fruit and vegetables and 
for school milk, the willingness to transfer part of the indicative allocation up to the maximum percentage referred 
to in Article 23a(4) of Regulation (EU) No 1308/2013, the willingness to use more than the indicative allocation. 
36  Annual  monitoring  reports  by  MS  have  to  include  information  about  the  funds  used  for  the  supply  and 
distribution of each of the product groups listed in Article 23(3), (4) and (5) of Regulation (EU) No 1308/2013 
and  for  the  accompanying  educational  measures,  the  number  of  educational  establishments  and  children 
participating in the school scheme, the average portion size and the average price per portion, the frequency of 
delivery of products,  the  quantities  of products supplied broken  down  by  product  groups  and,  if  applicable, of 
products other than those listed in Article 23(3), (4) and (5) of Regulation (EU) No 1308/2013 that are included 
under  the  accompanying  educational  measures  according  to  Article  23(7)  of  that  Regulation,  the  types  of 
communication and accompanying measures implemented, and the authorities and stakeholders involved in the 
design and implementation of the school scheme.  
37 The total number of on-the-spot checks shall cover at least 5% of the aid claimed at national level and at least 
5% of all aid applicants dealing with the supply and distribution of products and with accompanying educational 
measures in respect of each school year. When the number of aid applicants in a MS is less than five, on-the-
spot checks shall be carried out on the premises of all the applicants. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

2.2.2  The logic of intervention  

The logic of intervention  shows the expected  results and impacts of the activities put in 
place that should contribute to meet the objectives of the EU school scheme. In order to 
better understand how the logic of intervention has been designed, it is important to frame 
the context in which the EU school scheme lies, especially in relation to the objective of 
‘viable food production’38.  

As  explained  in  the  DG  Agri  ‘Technical  Handbook  on  the  monitoring  and  evaluation 
framework  of  the  CAP  2014-2020’39,  the  CAP  has  three  long-term  objectives  and 
‘guaranteeing a viable food production’ (VFP) is one of them.  

The  measures  linked  to  the  VFP  objective  aim  to  address  several  key  challenges  and  in 
particular “guaranteeing food security, averting a slowdown in productivity growth, price/ 
income volatility and facing economic crisis”. The long-term objective is, hence, translated 
into specific objectives: contribute to farm incomes and limit farm income variability in a 
minimally trade distorting manner; maintain market stability; improve competitiveness of 
the  agricultural  sector  and  enhance  share  in  food  chain;  meet  consumer  expectations; 
foster innovation, which is a CAP cross-cutting objective. 

The overall rationale is that the objective of guaranteeing viable food production should be 
met by improving the competitiveness of the EU agricultural sector in a sustainable way. 
Farmers should make their productive choices depending on the market (prices, consumer 
expectations  etc.),  while  respecting  agronomical,  animal  welfare  and  environmental 
requirements set up by policy makers. In turn, the rationale of the CAP is to support farm 
income with instruments that do not disturb market equilibrium and thus favour greater 
market orientation among farmers.  

However, the role of the different measures towards achieving the objective of ‘viable food 
production’  may  differ  significantly  from  one  MS  to  the  other,  depending  on  MS’ 
implementing choices.  

The  logic  of  intervention  showing  the  contribution  of  the  EU  school  scheme  to  such 
objectives is presented in the following page. 

38 https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-policy/cmef/products-and-
markets/impact-cap-measures-towards-general-objective-viable-food-production_en . 
39  https://agriculture.ec.europa.eu/system/files/2018-10/technical-handbook-monitoring-evaluation-
framework_june17_en_0.pdf. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

Figure 1: Contribution of CAP measures to Viable Food Production 

Source: Agrosynergie 

10 

 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

The  EU  school  scheme  has  its  own  specific  objectives  as  stated  in  Regulation (EU) 
N 1308/2013 (as amended by Regulation (EU) N 791/2016): 

 
 

increasing consumption of selected agricultural products; 
improving children's eating habits and shaping healthier diets. 

Based on these assumptions (EU school scheme specific objectives and VFP objectives), a 
specific logic intervention has been designed,  trying to highlight the  pathway that leads 
from those objectives to the longer-term impacts.  Since the national/regional  strategies 
are  structured according to specific needs which differ from  one  context to another, the 
logic of intervention herewith presented does not take them into consideration40. The logic 
of intervention, however, takes into consideration the structure that every strategy must 
be compliant with (Regulation (EU) N 2017/39) by considering all types of activities which 
may be funded by the Union aid and, consequently, implemented at MS level. 

In drafting the logic of intervention, the following reasoning was applied: 

 

  outputs  are  the  immediate  effects  of  the  financial  inputs  of  each  national/regional 
strategy  (as  also  reported  in  the  yearly  monitoring  reporting  to  the  European 
Commission):  namely  children  and  schools  participating  in  the  scheme  (i.e.,  shares 
when  applicable),  quantities  of  products  distributed,  educational  measures  and 
information activities implemented; 
results are the effects of the implementation choices made by MS when setting criteria 
and priorities for the choice of products to be distributed, (i.e., support to short supply 
chain, support to organic food production, support to local markets and to fair trade, 
health  considerations  and/or  environmental  considerations41  such  as  nutritional 
intake, sustainability, waste disposal) and the accompanying educational measures to 
be provided; 
finally, impacts on children’s consumption of the selected products and on promotion 
of  healthy  eating  habits  are  considered  the  longer-term  effects  which  overall  the  EU 
school scheme can generate. In this sense, the logic of intervention tries to give credits 
also  to  external  factors  which  may  contribute  to  the  achievement  of  those  impacts. 
Such external factors  are here intended as any other policy (international, European 
and/or national/regional) that may participate in the achievement of the objectives of 
the  EU  school  scheme.  In  order  to  understand  such  a  contribution,  the  study,  as 
requested  by  the  ESQs  9  and  10,  investigates  to  what  extent  other  EU  and 
national/regional policies are synergic with the EU school scheme; 

 

  moreover,  the  intervention  logic  takes  into  consideration  the  confounding  factors  on 
the EU school scheme which may be generated by external events, such as the COVID-
19 pandemic. 

40 Nevertheless, the specific needs addressed by the MS are considered when answering the relevant ESQs. 
41 Environmental considerations: see Article 23(3) of the basic act. 

11 

 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

Figure 2: Intervention logic of the EU school fruit, vegetables and milk scheme 

Source: Agrosynergie 

12 

 
 
 
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

2.2.3  EU school scheme national/regional strategies  

As previously described, the EU school scheme is based on a high degree of subsidiarity. 
MS  indicate  in  their  strategies,  which  are  notified  to  the  European  Commission,  their 
choices in terms of priorities, children’s target groups, products, educational measures and 
the arrangements for the implementation of the scheme. The most important elements of 
the strategies (as amended up to July 2021) are summarised below.  

In most MS, the school scheme is set up at national level, with only Belgium and Germany 
adopting a regional school scheme format. In total, 19 MS allocate additional national aid 
to complement the Union aid for the distribution of fruit, vegetable, milk and milk products 
and  often  also  in  support  of  accompanying  educational  measures.  MS  not  allocating 
additional  national  resources  are  Denmark,  Greece,  France,  Italy,  Cyprus,  Austria, 
Portugal, Finland, Sweden and two German Laender (i.e., Bremen and Hessen). Only few 
MS have similar national or regional school schemes in place: Ireland, Portugal (only for 
milk), the United Kingdom and the German federal state of Hessen.  

Primary  schools  are  the  educational  establishments  most  targeted  by  the  EU  school 
scheme42. The  choice of  target groups may include special schools that feature in some 
countries (i.e., schools catering for children with special educational needs), as in the case 
of BE-Flanders, Bulgaria, Czechia, Spain, France, Hungary, Ireland, Malta, the Netherlands, 
Slovenia, Slovakia, the United Kingdom and some German Laender, and give preference 
for product distribution in schools with high proportion of children in the more vulnerable 
socio-economic  groups  (i.e.,  Ireland,  France,  BE-Flanders,  DE-Lower  Saxony,  DE-North 
Rhine-Westphalia,  DE-Rhineland-Palatinate  and  DE-Schleswig-Holstein).  With  respect  to 
secondary schools, in few cases only the educational establishments catering for children 
with special needs are eligible (i.e., BE-Flanders, DE-Bavaria, the Netherlands with respect 
to distribution of fruit and vegetables, Slovakia). 

As far as the choice of products to be distributed is concerned, MS and regions could define 
in  their  strategies  specific  priorities,  to  be  applied  when  selecting  the  products  to  be 
distributed.  The  majority  of  MS  give  priority  to  supporting  local/regional  production  and 
organic farming for the choice of products. Only Estonia, Latvia, the Netherlands, Austria, 
Poland  and  Sweden  have  not  indicated  such  priorities.  Environmental  considerations 
regarding  food  miles,  eco-friendly  packaging,  lower  greenhouse  gas  and  other  pollutant 
emissions, appear far less adopted (13 MS and only one Federal State in Germany), and 
even less importance has been given to the distribution of certified quality products (this 
priority was chosen only by Italy and Spain43) and fair-trade products.  

However, it must be taken into account that the selection of one or more priorities is not 
mandatory. National strategies indicate priorities as recommendations for the selection of 
products and suppliers. In any case, the provision of data related to distributed products 
linked to these priorities is not an element required by the monitoring reporting system. 

The choice of eligible schools for participation in the EU school scheme is the responsibility 
of the MS competent authorities, according to choices and objectives set in their strategies. 
In  most  cases,  it  is  for  eligible  schools  (or  school  groupings/associations)  to  apply  to 

42 Some MS/regions do not distinguish nurseries from pre-schools in their school system (e.g., AT, LV, ES, DE-
Bavaria),  therefore,  school  scheme  monitoring  data  are  presented  for  the  aggregate  ”nurseries/pre-schools” 
category. 
43  Concerning  France,  while  no  priorities  are  indicated  in  the  strategy,  EU  and  national  quality  products  are 
specifically  targeted  as  only  such  products  are  eligible  for  distribution  in  conjunction  with  regular  school 
meals. Moreover, some MS indicate in the yearly monitoring reports quality schemes among the priorities used 
to  choose  products;  however,  the  detailed  information  often  refers  to  national  schemes  or  integrated  crop 
management system, i.e., schemes not covered by Regulation (EU) N 1151/2021. 

13 

                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

participate in the school scheme, however in some cases the decision to apply lies with 
regional or local authorities (Romania, Spain). In France and Portugal, both schools and 
local authorities can apply.  

The  selection  of  suppliers  is  generally  done  through  public  tendering  procedures,  with 
potential suppliers having to be approved (i.e., accredited and/or licensed) by the public 
authority.  In  some  MS,  schools  directly  choose  their  suppliers  from  the  list  of 
accredited/licensed  suppliers  (e.g.,  Austria,  BE-Flanders,  Denmark,  DE-Schleswig-
Holstein). Product suppliers usually are the aid applicants. However, in few cases, schools 
or  local  authorities  can  apply  for  aid  directly  (e.g.,  Austria,  BE-Flanders)  or  through 
suppliers (e.g., Bulgaria, Denmark). 

2.2.4  Implementation of the EU school scheme  

All MS implement the EU school scheme, with most MS implementing both the F&V and 
milk  parts.  Sweden,  the  United  Kingdom  and  the  German  federal  states  of  Berlin, 
Brandenburg  (one  joint  school  scheme  strategy)  and  Hessen  opted  for  the  milk  part  of 
scheme  alone,  whereas  the  German  federal  state  of  Saarland  only  implements  the  F&V 
part of the scheme.  

The United Kingdom withdrew from the Union but according to the Withdrawal Agreement 
could continue to participate in the EU school scheme in 2020 and could be reimbursed for 
payments made until 15 October 2020 (i.e., the 2020 financial year for the EAGF). 

Financial execution 

The total indicative allocation of Union aid44 to the EU school scheme for the 2017-2023 
period amounts to EUR 1.5 billion, representing 8.59% of the CMO budget, 0.49% of total 
EAGF budget and 0.37% of total CAP budget for the same period. In terms of expenditure, 
considering  the  latest  available  data  for  2020,  the  EU  school  scheme  expenditure 
(EUR 162 million) represents 6% of CMO, 0.37% and 0.36% of EAGF and CAP expenditure, 
respectively45. 

The  definitive  allocated  Union  aid  for  the  first  4  school  years  (2017/2018,  2018/2019, 
2019/2020 and 2020/2021) under analysis amounts to EUR 995.1 million46. 

The financial execution of the school scheme for the whole EU over this period amounts to 
EUR 693.5 million  (close  to  70  %  of  allocated  Union  aid).  Financial  execution  varies 
considerably across MS, ranging between a minimum of 7.4% in France and a maximum 
of 100% in Estonia and Latvia. Within this broad range, in most MS the level of execution 
is above EU average, whereas in 10  MS (including the United Kingdom that participated 
until 2020) execution is below EU average and in the case of Belgium,  Portugal, Greece 
and especially France, well below the average. 

44 Union aid means the financial support funded by the EU general budget granted to a specific action intended 
to help achieve one or more policy objectives. 
45 Annex to the 14th Financial Report from the Commission to the European Parliament and the Council on the 
European Agricultural Guarantee Fund - 2020 financial year. 
46 
Commission Implementing Decision C(2019)2249 
decision (EU) 2020/467 of 25/3/2020. Commission implementing decision (EU) 2021/462 of 15/3/2021. 

C(2018)1762 
of 

27/3/2018. 
implementing 

final 
of 
Commission 

Implementing 

Commission 

27/3/2019. 

Decision 

final 

14 

                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

Figure 3: Share of expenditure on allocation of Union aid – Total 2017/18-2020/21 (%) 

Sources: Allocation Union aid: Commission Implementing Decision C(2018)1762 final of 27/3/2018. 
Commission Implementing Decision C(2019)2249 final of 27/3/2019. Commission implementing decision 
(EU)2020/467 of 25/3/2020 - OJ L 98 of 31/3/2020. Commission implementing decision (EU)2021/462 of 
15/3/2021 - OJ L 92 of 17/3/2021. Expenditure: Commission’s overview based on the MS' declarations of 
expenditure up to December 2021 sent to the Commission according to Article 10 of Regulation (EU) No 
908/2014 - preliminary figures: corrections are possible and payments may still be made. 

The reasons for varied financial execution are different in the MS, e.g., in BE-Wallonia the 
number of participating schools dropped remarkably between the school years 2017/2018 
and 2020/2021, due to difficulties linked to procurement procedures and reimbursement 
delays. This complaint was raised by a large number of schools over  the period (source: 
PA survey). 

In  Portugal,  low  school  scheme  uptake  appears  to  be  linked  to  a  large  extent  to  the 
complexity of administrative procedures the municipalities have to face to apply for scheme 
participation. In spite of adjustments and simplification being introduced by the Managing 
Authority  together  with  the  Paying  Agency,  the  municipalities  still  consider  the 
administrative burden as excessive. For this reason, the Autonomous Region of Madeira is 
not  participating  in  the  EU  school  scheme,  nor  the  Municipality  of  Lisbon,  having  an 
important  impact  on  the  total  number  of  children  participating  in  the  school  scheme 
(source: case study interviews). 

Greece  did  not  participate  in  the  2017/2018  school  year  due  to  delays  in  the  tendering 
procedures to select suppliers and again in 2020/2021 for the same reason, aggravated 
by the uncertainty linked to the Covid-19 pandemic and restrictive measures taken by the 
government in 2020 and 2021 such as school closures (source: annual monitoring reports 
and communications to the European Commission). 

France  has  experienced  a  series  of  difficulties  having  a  significant  impact  on  the  school 
scheme uptake. The main issue appears to be related to the administrative burden, which 
discourage  schools  and  municipalities  from  applying  to  participate.  Administrative 
procedures have been simplified in February 2020, but the results might not yet be visible 
due  to  the  COVID  crisis.  Additional  issues  are  linked  to  overlapping  between  products 
delivered by the EU scheme and products already delivered with lunches; to restrictions 
on distribution times; to the school scheme being perceived as adding complexity to the 
well-structured collective school catering already in place (source: case study interviews). 

15 

 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

In Italy, in the school year 2019/2020 the milk tender was revoked. Due to delays in the 
public procurement procedures for the milk part of the  scheme, the tender was still not 
finalised in March 2020, when the Covid-19 pandemic forced school closures.  

Overall,  the  F&V  part  of  the  scheme  shows  a  better  spending  performance  (73%), 
compared  to  the  Milk  part  of  the  scheme  (65%).  It  must  be  said  however,  that  better 
financial execution rate is recorded for the Milk part of the scheme in Bulgaria, Denmark, 
Ireland, Lithuania, Malta, Poland, Romania and Finland.  

Expenditure of Union aid for accompanying educational measures, information, monitoring 
and evaluation activities47  is also variable across the MS, with 4.3% and 1.9% of Union 
aid  being  utilised  respectively  (total  EU  for  school  years  2017/18-2018/19-2019/20-
2020/21).  For  both  accompanying  educational  measures  and 
information  and 
monitoring/evaluation activities, the expenditure share ranges between 0% to appx. 14% 
across the MS. The highest expenditure ratios for accompanying educational measures are 
recorded for Czechia (12.5%), Ireland (14.9%), Italy (13.8 %) and Finland (13.6%). 

In order to gain a complete picture of the EU school scheme, the level of expenditure of 
additional  national  funds  is  also  considered  (2017/2018,  2018/2019,  2019/2020  and 
2020/2021). Most MS allocate additional national resources (public and/or private) to the 
distribution of fruit, vegetables and milk/milk products to school children and in some cases 
also to educational measures. Greece, France, Italy, Cyprus, Portugal, Finland and Sweden 
do not allocate any additional national funds to the EU scheme. Conversely, in some MS, 
national  funds  represent  a  considerable  share  (well  over  50%)  of  the  total  EU  school 
scheme  expenditure  (i.e.,  the  sum  of  Union  aid  and  national  funds),  namely,  Bulgaria, 
Czechia, Latvia, Hungary, Austria and Slovakia. 

Distribution  of  the  selected  products  in  schools  and  accompanying  educational 
measures 

Out  of  all  MS,  only  Greece  did  not  activate  the  EU  school  scheme  on  the  first  year  but 
started it in the school year 2018/1948. Over the four examined years, at EU27 level, the 
yearly average number of children participating in the EU school scheme is around 17.5 
million pupils (EU-28, average 2017/18-2019/2020, EUR 19.6 million pupils) and around 
133 000 educational establishments are involved (EU-28, 152 600 schools). 

Children  participation  in  the  EU  school  scheme  is  generally  fairly  equally  distributed 
between  F&V  and  milk  at  EU  level.  In  Belgium,  Croatia,  Italy,  France,  Germany,  the 
Netherlands and Slovenia, participation in the F&V part of the scheme is higher compared 
to  the  milk  part  (and  to  a  smaller  extent  also  in  Hungary  and  Slovakia),  whereas  in 
Denmark, Estonia, Finland, Portugal and Romania participation is relatively higher for milk. 

Overall,  primary  schools  are  the  most  targeted  by  MS,  while  nurseries/pre-schools  and 
secondary schools are more marginally targeted and by few MS (for the former in particular 
Germany,  Lithuania,  Bulgaria,  Portugal,  Spain,  and  Sweden  and  for  the  latter  Romania, 
Austria, Sweden and France). This may be related to the fact that the age 6 to 10 years 
old is regarded as the age bracket when eating habits are formed, as it is also explicitly 
reported in some MS strategies (i.e., Spain, Poland). 

47  The  EU  school  scheme  also  finances  information  activities  to ensure  the visibility  of  the  scheme,  as  well  as 
monitoring and evaluation to account for the proper functioning of the scheme. 
48 Greece requested Union aid for school fruit and vegetables and for school milk but did not participate in the 
scheme for delays linked to tendering procedures (information can be found in its annual monitoring report). 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

Finally,  for  accompanying  educational  measures,  the  highest  children’s  participation  can 
be observed in Poland (3.5M children in 2017/18 and 4.1M in 2018/19)49, Germany (3M 
children in 2017/18 and 3.8M in 2018/19), Czechia (1.9M children in 2017/18 and 2.6M in 
2018/19), Italy (3.2M children in 2017/18 and 2.2 in 2018/19) and Hungary (1.1M children 
in 2017/18 and 2.1M in 2018/19). In particular, when it comes to the types of educational 
activities,  lessons,  lectures  and  workshops  appear  to  be  the  most  widely  implemented, 
followed by tasting classes and cooking workshops. Few MS have implemented most types 
of  educational  activities,  namely  France,  Germany,  Hungary,  the  Netherlands,  Poland, 
Portugal  and  Spain.  A  comparison  between  2018/19  (highest  number  of  schoolchildren 
participating in AEMs over the 4 school years) and 2020/21 (lowest number of participating 
children over the 4 school years) shows that the number of children participating in “other 
activities”  such  as  competitions,  games,  etc.  has  increased,  vis-à-vis  decreased 
participation in all other types of AEMs. This suggests some “repositioning” of AEMs perhaps 
to  accommodate  more  online  activities  in  response  to  social  distancing  restrictions  and 
school closures linked to the Covid-19 pandemic (Italy, France, Ireland). 

Influence of the Covid-19 pandemic on the EU school scheme implementation 

The  temporal  scope  of  the  evaluation  support  study  that  spans  from  the  school  year 
2017/2018  to  the  school  year  2020/2021  has  been  strongly  affected  by  the  Covid-19 
pandemic’s outbreak since March 2020. According to the World Bank50 “at the peak of the 
pandemic, 45 countries in the Europe and Central Asia region closed their schools, affecting 
185 million students”. School closures due to Covid-19 have necessarily brought significant 
disruptions in the EU school scheme implementation that have to be taken into account 
when  analysing  the  role  of  the  scheme  in  reaching  its  objectives.  The  most  severe 
disruptions took place in the first months after the pandemic’s outbreak and over time, the 
schools gradually adjusted to the new reality. 

According  to  managing  authorities  responding  to  the  PA  survey  (see  chapter  3),  school 
scheme  implementation  was  mostly  affected  with  respect  to  products’  distribution, 
participation of educational establishments and the provision of accompanying educational 
measures.  This  is  not  surprising  as  these  aspects  are  related  to  school  closures  (as  a 
consequence  of  lockdowns)  and  social  distancing  measures  taken  by  many  EU 
governments in response to the pandemic from March 2020 onwards.   

Moreover, interviews carried out in case study MS (see chapter 3) provided some further 
insights: product distribution was surely hampered in Italy, Lithuania, Bavaria, North-Rhine 
Westphalia, Poland, Portugal and Romania, with cases of suppliers being unable to find a 
market destination for already planned stocks.  

MS found different solutions to cope with the emergency, for example in Lithuania home 
delivery  of  fruit,  vegetables  and  dairy  packages  to  children  in  distance  learning  was 
organised during lockdown. In Italy product distribution was extended for the 2019/2020 
school  year  to  September  2020  and  for  the  2020/2021  to  September  2021.  In  these 
prolonged distribution occasions in Italy, F&V and milk/dairy products were distributed in 
baskets or refrigerated bags for the children to take home51.  

Covid-19 has also changed the way in which products are distributed. In order to respect 
hygiene  and  safety  measures  imposed  by  national  governments,  products  have  to  be 
packaged in single portions and  schools and product suppliers report that the pandemic 

49 Total number of children participating in AEM sourced from annual monitoring report data is likely to double-
count  participating  in  more  than  one  type  of  educational activity.  Numbers  are  reported  only for  the first  two 
school years under analysis because in the two following years (2019/20 and 2020/21) the number of children 
participating in educational measures drops dramatically in certain MS due to Covid-related restrictive measures 
such as school closures put in place by some MS governments. For these two years it is not possible to compare 
across MS. 
50 World Bank, “The Impact of COVID-19 on Education” OPINION, APRIL 2, 2021. 
51 Some product suppliers think that at least this has been a good way for information about the school scheme 
to reach the families. 

17 

                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

has made even simple product distribution in schools quite a challenge in terms of hygiene 
and product handling. As a result of the pandemic, in the last 2 years schools in Italy have 
been far less willing to register their classes for the school scheme.  

Interviewees  in  the  case  study  MS  also  mentioned  that  the  provision  of  accompanying 
educational  measures  was  surely  affected  in  Italy,  Poland  and  Portugal,  where  some 
contracts with providers had to be cancelled or put on hold. In Italy changes were made 
to  “turn  things  around”  and  convert  at  least  some  educational  activities,  which  were 
previously  mostly  carried  out  in  presence,  in  an  online  format  and,  where  possible,  in 
interactive format (e.g., a virtual interactive farm visit for milk/dairy and through social 
networks  and  YouTube  for  F&V).  The  positive  side  of  this  is  that  more  schools/children 
could be involved.  

18 

 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

3  METHODOLOGICAL APPROACH TO THE EVALUATION SUPPORT STUDY 

3.1  Evaluation design 

The evaluation design draws on a range of methods and tools for collecting and analysing 
quantitative and qualitative data necessary to answer the 12 evaluation questions and to 
provide a robust assessment of the effects of the EU school scheme.  

The analysis covers the implementation period of the EU school scheme from its entry into 
force as of 1 August 2017 for four school years (from 2017/2018 to 2020/2021), for which 
annual monitoring report (AMR) data are available. A longer observation period was taken 
into account according to the needs of the analysis, mainly with respect to consumption 
data for fruits and vegetables (F&V), milk and milk products across the EU since 2010 (or 
earlier).   

The geographical scope of the analysis is EU-27 and the United Kingdom that implemented 
the scheme until December 2020. In addition, a case study approach was chosen, in order 
to support and complement the evaluation of the EU school scheme with respect to causal 
analysis, effectiveness, efficiency, coherence, relevance and EU value added criteria.  

Overall, the evaluation of the EU school scheme uses quantitative analysis complemented, 
where appropriate, by qualitative analysis of information from different sources (i.e., desk 
review  of  school  scheme  strategies  and  scientific  literature,  in-depth  interviews  with 
European  Commission  officials,  structured  interviews  with  public  authorities  and  school 
scheme stakeholders at case study level).  

3.2  Baseline 

EU legislation requires that school scheme strategies at least identify the needs to be met 
and the expected results and, if available, the quantified targets to be achieved in relation 
to the initial situation (Reg. EU no. 1308/2013, art 23(8)). It also requires that the initial 
situation (i.e., baseline), in relation to which progress towards results will be measured, 
be based on available data (Reg. EU no. 2017/39, art. 1(2)(d)). However, national/regional 
strategies do not report in a systematic and homogeneous manner quantified baseline nor 
target indicators that could be used for comparison analysis.  

Therefore, the analysis has utilised, where appropriate, data from the previous F&V and 
milk  schemes  (period  2014/2015  to  2016/2017)  to  calculate  baseline  indicators  for 
comparison with the current EU scheme (see paragraph about limitations). 

3.3  Case study approach 

Selection of case studies 

The analysis for the selection of case study MS/regions was carried out in two subsequent 
steps.  

The first step consisted in mapping the MS according to the size of scheme participation in 
conjunction with F&V and milk consumption levels. The analysis was carried out separately 
for F&V and for milk. The mapping exercise allowed to assess the position of each MS with 
respect to level of scheme participation measured as the proportion of children taking part 

19 

Evaluation support study of the EU school fruit, vegetables and milk scheme 

in the F&V and milk parts of the school scheme in the school year 2018/201952  in relation 
to the target children population in 2018 (source: EUROSTAT - School enrolment statistics 
– online data code: educ_uoe_enra02) distinguishing for education levels (early childhood, 
primary and secondary education) and to consumption. Fruit and vegetables consumption 
data was sourced from the European Health Interview Survey, Wave2 2013-2015 (source: 
Eurostat53 ). Due to lack of available per capita milk consumption data across the EU-27 
and the UK, “production of drinking milk” data (source: CLAL.it, after Eurostat, BLE, ISTAT, 
average  l/capita  2017-2020)  was  used  as  a  proxy  of  milk  consumption54.  The  mapping 
exercise was supplemented with cluster analysis55, to identify groups of MS sharing similar 
characteristics with respect to the mapping variables used.  

The  second  step  consisted  in  characterising  each  national  and  regional  school  scheme 
according  to  the  following  variables:  Coverage  of  school  schemes  in  terms  of  share  of 
children participating in relation to the target population; Budget execution: share of school 
scheme  expenditure  in  relation  to  allocated  budget;  Implementation  of  accompanying 
educational  measures;  Type  of  scheme  set-up  (national  or  regional);  Type  of  scheme 
administration (schools, municipalities, etc.); Presence of national/regional aid in addition 
to Union aid; Implementation of similar scheme(s) at national or regional level; Product 
choice priorities indicated by MS/regions in their strategies (in particular, priority given to 
locally sourced product and organic products); Product distribution with meals in addition 
to morning and/or afternoon distribution56. In addition, the selection of case studies has 
taken into account the budget size per MS, so that case study MS/regions account for a 
significant share of total Union aid allocation.  

The  analysis  allowed  to  select  12  case  studies  (10  national  and  2  regional):  Czechia, 
France, Italy, Lithuania, the Netherlands, Poland, Portugal, Romania, Spain, Sweden and 
the  German  federal  states  of  Bavaria  and  North-Rhine  Westphalia.  The  selected  case 
studies represent about 80% of Union aid expenditure57 for each part of the scheme (F&V 
and  milk)  and  cover  different  EU  geographical  areas  (Mediterranean,  eastern  Europe, 
northern Europe, Scandinavia and Baltic). 

Execution of case studies 

The  information  needed  to  support  the  analysis  to  answer  all  evaluation  questions  was 
collected  through  a  family  survey  at  national  level  (10  case  studies)  using  a 
questionnaire-based online survey, structured interviews at national and regional level 
(12 case studies) and documentary research.  

52  This  school  year  was  selected  as  it  recorded  the  highest  children  participation  across  MS  over  the  period 
2017/18 to 2019/20 (at the time of selecting case studies, annual monitoring report data were not available for 
the school year 2020/21). 
53 European Health Interview Survey – EHIS - online data code: hlth_ehis_fv3. 
54 Eurostat definition of "drinking milk": “Raw milk, whole milk, semi-skimmed and skimmed milk containing no 
additives.  Relates  only  to  milk  directly  intended  for  consumption,  normally  in  containers  of  2lt  or  less.  Also 
includes milk with vitamin additives”. 
55 Cluster  analysis  is  a  statistical  classification  technique  in which  a set of  observations  or objects  with  similar 
characteristics  are  grouped  together  in  groups.  This  method  is  typically  used  when  it  is  not  possible  to  make 
assumptions  about  the  likely  relationships  within  the  data.  Different  algorithms  and  methods  can  be  used  for 
grouping objects with similar characteristics into respective categories. Cluster analysis was applied here using 
both the hierarchical method and the k-means approach allowing for different possible solutions (4 to 6 clusters). 
The 4-cluster solution was chosen. 
56 The latter two variables were included at the request of the ISSG. 
57 Average Union aid expenditure for school years 2017/18, 2018/19 and 2019/20. At the time of selecting case 
studies, expenditure data for the school year 2020/21 was not available. 

20 

 
 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

3.4  Data collection 

Primary data 

Primary data was collected using the four tools described in the following paragraphs.  

a.  Family survey in case study Member States 

An online questionnaire-based family survey was used in order to collect primary data to 
analyse patterns of consumption of products interested by distribution under the EU school 
scheme, as well as children’s attitudes and knowledge. The questionnaire was administered 
in  10  case  study  MS:  Czechia,  Germany,  Italy,  Lithuania,  the  Netherlands,  Poland, 
Portugal, Romania, Spain and Sweden. The survey could not be carried out in France as 
the very low school scheme participation would not guarantee collecting responses from a 
statistically representative sample (see below explanation of sample size determination).  

Computer Assisted Web Interview (CAWI) was used to collect the survey data for a Target 
Group of families with children participating in the EU school scheme and a Control Group 
of families with children not participating in the scheme.  

Sample  size  was  statistically  determined  on  the  basis  of  the  reference  population  (i.e., 
number of children participating in the EU school scheme in each case study MS on average 
over  the  first  3  years  of  the  scheme:  2017/18,  2018/19  and  2019/20).  A  statistically 
representative  sample  of  approximately  385  families  with  children  participating  in  the 
school scheme in each country was defined (for an associated 5% margin of error and 95% 
confidence  level).  Therefore,  the  sample  size  for  the  family  survey  was  set  to  400 
questionnaires  to  be  collected  from  the  target  sample  and  400  questionnaires  from  the 
control sample (800 respondents in each case study MS).  

The  survey  was  carried  out  in  December  2021.  The  response  was  very  satisfactory  and 
allowed to collect the planned number of questionnaires for both target and control samples 
in all case study MS, with the only exception of Sweden, for which 285 questionnaires were 
collected58.  However,  the  overall  achievement  rate  was  >100%  in  both  samples  (4 009 
responses for Target Group and 4 217 for Control Group). 

b.  Public Authorities survey at EU 27 level and the UK 

This survey was directed to 27 national (including the UK) and 17 regional (14 in Germany 
and  3  in  Belgium)  EU  school  scheme  managing  authorities.  The  appropriate  national 
contact  points  were  identified  with  the  support  of  the  Commission  services.  For  the  14 
regional school schemes of Germany, the questionnaire was sent to contacts indicated in 
the annual monitoring reports. 

On 3rd January 2022, a total of 44 questionnaires were sent out by email to all relevant 
national and regional Public Authorities.  

In total, 37 questionnaires have been returned, for a corresponding 84.1% overall response 
rate. However, 100% response rate was achieved at EU-27 level considering that the UK 
was  the  only  (former)  MS  not  participating  in  the  survey.  The  remaining  missing 
questionnaires are from 7 federal states of Germany.  

The  survey  data  collection  was  completed  at  the  end  of  February  2022,  however  some 
additional data related to administrative costs was requested in May. 

58 The smaller sample for Sweden is still statistically representative for a corresponding 5% margin of error and 
90% confidence level (i.e., the sample size needed would be no. 271 respondents), thus still acceptable for this 
type of survey usually characterised by very variable response rates. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

The collected survey data (Family survey and PA survey), have been treated, to the extent 
possible, in a quantitative manner through statistical analysis, so as to highlight strengths 
and weaknesses of the EU school scheme implementation and compare results across MS.  

c.  Structured interviews in case study Member States and regions 

The  collection  of  information  through  structured  interviews  with  EU  school  scheme 
managing  authorities,  other  public  authorities  in  Agriculture,  Environment,  Health  and 
Education and the different categories of stakeholders involved in the EU school scheme 
(national  paying  agencies,  F&V  and  dairy  sector  representatives,  product  suppliers, 
educational establishments and local authorities, providers  of accompanying educational 
measures, civil society representatives) relied on experienced country experts, who were 
provided with synthetic school scheme strategies’ information, interview guidelines and the 
template for restitution of interview results.  

In total, 151 interviews have been carried out in the 12 case study MS and regions between 
mid-December 2021 to mid-March 2022. 

d.  In-depth interviews with European Commission officials 

On the basis of the brief description of the internal procedures for managing the EU school 
scheme  provided  by  the  European  Commission  services  at  the  onset  of  the  evaluation 
support  study,  a  total  of  seven  interviews  were  carried  out  with  officials  of  Directorate 
General for Agriculture and Rural Development, policy unit and audit unit during December 
2021 and January 2022. One additional interview was carried out with the Web master of 
the EU school scheme Web site in the same Directorate General.  

The  interviews  served  the  purpose  of  gaining  in-depth  knowledge  of  different  EC 
procedures,  interpretation  of  key  points  of  the  relevant  EU  legislation  and  details  about 
different expenditure items. 

Secondary data 

The  main  secondary  data  feeding  the  analysis  required  to  answering  ESQs  are  the  EU 
school  scheme  annual  monitoring  report  data  (AMR)  for  each  national/regional  school 
scheme.  

EU school scheme data used in the evaluation: 

 

ISAMM  annual  monitoring  reports  for  the  school  years  2017/2018–2018/2019–
2019/2020–2020/2021; 

  Monitoring  data  of  the  previous  F&V  scheme  and  milk  scheme  for  the  school  years 

2014/2015–2015/2016-2016/2017; 

  Complete financial execution data up to the 2020/2021 school year; 
  MS’ transfers between the school F&V and milk envelopes, 2017-2018-2019-2020. 

Substantial work has been carried out on all data received or otherwise collected, which 
have been organised and checked for quality and reliability. In particular:  

  A  unique  monitoring  database  for  the  current  school  scheme  has  been  compiled 

including ISAMM data for all MS and all years (from 2017/18 to 2020/21);  

  The data from the previous EU F&V and milk schemes have been transferred from PDF 
into Excel files and adequately organised for computing relevant baseline indicators; 
  Some  ISAMM  monitoring  data  have  been  treated  to  make  them  directly  comparable 
across the MS: quantities of distributed dairy products have been transformed into milk 
equivalents;  quantities  of  F&V  (processed)  have  been  transformed  into  raw  material 
equivalents; cost data (where available) have been transformed from euro to Purchase 
Power Parities (PPP). 

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Further secondary data concerning F&V and milk/dairy consumption were sourced from: 

  FAOSTAT Food Balances (2010-)59: Data on apparent consumption of F&V, milk and 
milk products at EU level calculated from national balance sheets and trade data, 2010-
2019; 

  DG  Agriculture  and  Rural  Development  -  EU  fresh  dairy  products  balance  sheet60: 
apparent  consumption  data  for  milk  and  milk  products  at  EU  level  calculated  from 
national balance sheets and trade data; 

  EUROSTAT-European  Health 

(online  data  code: 
Interview  Survey 
hlth_ehis_fv3)61  Wave  2  (2014)  and  Wave  3  (2019)  data  at  EU  level  on  F&V 
consumption patterns with respect to the population >15 years old; 

(EHIS) 

  FRESHFEL  -  Consumption  Monitor  (F&V  consumption  based  on  EUROSTAT  and 

FAOSTAT data up to 201962; 

  EFSA - Comprehensive European Food Consumption Database63: dietary survey data 
collected for children and/or adolescents and/or adults from national surveys in 18 MS;  
  EDA (European dairy Association)64: Dairy consumption data and factsheets compiled 

from national data (different years) for some 27 MS. 

3.5  Main limitations of data and analysis  
One  of  the  main  limitations  concerns  the  completeness  of  the  information  included  in 
ISAMM annual monitoring reports. Bearing in mind that the provision of separate data on 
the number of children participating in the F&V part of the scheme and in milk part is non-
mandatory for MS, data gaps for some MS in some school years represented a limit to the 
calculation of indicators at EU28 level, in particular those computed as ratios between two 
variables.  

To overcome this limit, indicators were calculated for groups of MS (MS aggregates – MSA), 
for which data was available for all considered years and for the relevant variables. This 
means the aggregate  of MS (MSA) can differ  for each calculated indicator  and is clearly 
indicated in each piece of analysis. 

Comparative analysis between current and previous school schemes indicators (i.e., used 
as baselines) was not always possible. Comparison of the number of products distributed 
per pupil per year under the current scheme with the number of products distributed under 
the previous EU school schemes, was possible only for F&V. For milk and dairy, the product 
categories of the previous scheme (defined in Regulation (EU) No 657/2008, Annex I) are 
not comparable with the product categories of the current EU school scheme (Regulation 
(EU)  No 1308/2013,  art. 23(3)(4)(5)).  Moreover,  the  current  EU  scheme  presents  a 
defined list of products, the previous F&V scheme monitoring system did not. Therefore, 
caution was necessary when reporting results of the comparative analysis. 

Concerning the family survey, answers obtained from children's families rather than from 
the  children  themselves  can  represent  a  limitation  because  information  is  not  collected 
directly  from  the  children  involved  in  the  EU  school  scheme.  Although,  there  is  a  clear 
advantage  in  the  possibility  of  collecting  answers  from  family  adults  who  are  directly 
concerned  with  their  children's  health  and  education  (including  nutritional  aspects)  and 
directly  responsible  for  food  purchase  decisions  and,  therefore,  for  any  changes  in  their 
children's  diet.  Indeed,  any  change  in  children's  eating  habits  is  not  spontaneous,  but 

59 https://www.fao.org/faostat/en/#data/FBS. 
60 Short-term Outlook http://ec.europa.eu/agriculture/markets-and-prices/short-term-outlook/index_en.htm) . 
61 https://ec.europa.eu/eurostat/databrowser/view/hlth_ehis_fv3e/default/table?lang=en. 
62 https://freshfel.org/what-we-do/consumption-monitor/. 
63https://data.europa.eu/data/datasets/the-efsa-comprehensive-european-food-consumption-
database?locale=en. 
64 https://eda.euromilk.org/home.html. 

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mediated by parents’ decisions. Furthermore, it should be borne in mind that survey results 
depend on the degree of awareness existing within the participating families. 

Further limitations that are more specific to different parts  of the analysis, are  reported 
within the answers to ESQs. 

24 

Evaluation support study of the EU school fruit, vegetables and milk scheme 

4  ANSWERS TO THE EVALUATION QUESTIONS  

4.1  Causal analysis 

4.1.1  ESQ1  -  To  what  extent  has  the  EU  school  scheme  contributed  to 
increase children’s consumption of fruit, vegetables, milk and milk 
products?  

4.1.1.1  Background and methodological approach  

Understanding 

Article 168 of the TFEU establishes that EU policies should ensure, in their definition and 
implementation, a high level of human health protection. Good nutrition is one of the key 
factors  for  good  health,  in  general,  and  in  particular  for  children  (see  2.1.2).  Children 
having (pre-) obesity are exposed to a higher risk of serious health problems and incidence 
of non-communicable diseases. In a context of increasing overweight and obesity among 
children, the EU school fruit, vegetables and milk scheme aims at promoting: 

1.  a durable increase of the consumption of selected agricultural products (namely fruit, 
vegetables  and  milk  and  milk  products),  preferably  replacing  the  consumption  of 
energy dense, processed foods high in added/free sugars, fat, saturated fat and sodium 
(salt).  The  EU  school  scheme  should  contribute  to  increasing  the  number  of  regular 
consumers  of  these  products,  with  also  positive  repercussions  on  internal  market 
stability (and therefore ensuring the availability of both current and future supplies of 
the concerned agricultural products); 

2.  children’s healthy eating habits: the  EU  school scheme  should contribute to improve 

nutrition and to shape healthier diets65. This objective is addressed in ESQ 2. 

Hence the evaluation question is related to the first objective of the EU school scheme and 
asks to assess66:  

 

 

the consumption of fruit and vegetables, milk and milk products distributed under the 
EU school scheme and actually consumed at school: direct consumption; 
the  consumption  of  fruit  and  vegetables,  milk  and  milk  products  outside  the  school: 
indirect consumption (i.e., outside the period of distribution under the EU scheme at 
school as well as at home).  

The implementation of the EU scheme is based on a high degree of subsidiarity, including 
the choice of the products to be distributed to schoolchildren. Therefore, ESQ1 requires to 
evaluate the effects on the consumption of the different products groups covered by the 
scheme (see 2.2.1). 

Judgement criteria, indicators and sources 

In  order  to  reply  to  the  evaluation  question,  our  judgement  is  based  on  the  following 
judgement criteria (JC) and indicators.  

Judgement criteria 

Indicators 

Sources 

time 

the 
JC1.1:  Over 
number of children involved 
in  the  distribution  of  fruit 
and  vegetables,  milk  and 

1.1.1 Evolution 2017/18-2020/21, change (in 
%)  of  the  No  of  children  participating  in  the 
EU school scheme and by school level 

65 i.e., recital (5) of Regulation (EU) 2016/791. 
66 as requested in the terms of reference. 

-  EU school scheme monitoring 
2018/19; 

2017/18; 

data 
2019/20; 2020/21 

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Judgement criteria 

Indicators 

Sources 

milk products  under  the  EU 
school scheme has (has not) 
increased 

1.1.2  Evolution  of  the ratio  No  of children  in 
the current EU school scheme by year / No of 
children  in  the  previous  EU  school  schemes 
(average 2014/15-2016/17) 
in  the  period  2017/18-
1.1.3  Evolution 
2020/21  of  the  ratio  (in  %)  No  of  children 
participating in the EU school scheme / No of 
children  in  the  target  group  set  out  in  the 
strategy (coverage rate) 
1.1.4  %  of  children  participating  in  the  EU 
school scheme by school level 

JC1.2:  The  quantity  of  fruit 
and  vegetables,  milk  and 
milk  products  consumed by 
children  in  school  (direct 
consumption)  and  outside 
school 
(indirect 
consumption) has (has not) 
increased over time 

to 

school 
JC1.3:  The  EU 
(has  not) 
scheme  has 
increase 
contributed 
knowledge  of 
children’s 
F&V, milk and milk products 
through  the  provision  of  a 
greater variety of products 

- 

the 

ratio 

(Index 

number 

1.2.1 Evolution of distributed quantities in raw 
I.N. 
equivalent 
2017/18=100) 
1.2.2  Evolution  2017/18-2020/21  of  the 
average distribution per child of F&V and milk 
and  milk products  at  school  (in  raw  material 
equivalent) 
1.2.2 Evolution of the distributed quantities of 
F&V  and  milk  per  capita  in  raw  material 
equivalent  (previous  period  and  current 
period) (I.N. 2014/15 =100)  
(average 
1.2.3  Evolution  of 
distribution  per  child  per  year  of  the  current 
school  scheme  /  distribution  per  child  in  the 
previous  EU  school  schemes 
(average 
2014/15-2016/17) 
1.2.3  Products  distributed  at  school  are/are 
not actually consumed and why 
1.2.4 % of families of children participating to 
the  EU 
the 
maintenance and/or the increase of the child’s 
consumption outside the school 
1.2.5 Informed opinions of EU school scheme 
administrators  and  stakeholders  concerning 
the  effects  of  the  implementation  of  the 
scheme on the products (qualitative indicator) 
1.3.1  Evolution  2017/18-2020/21  of  the 
composition  of  products  delivered 
to 
schoolchildren  
1.3.2  Evolution  of  the  ratio  number  of 
products  distributed  to  schoolchildren  per 
year  /  number  of  products  delivered  of  the 
previous  EU  school  schemes 
(average 
2014/15-2016/17) 

scheme 

stating 

school 

-  School  Milk  reports  (Annual 
Statistics)  2014/15;2015/16; 
2016/17 

-  School  Fruit  scheme  -  Annex 
V  of  DG  AGRI  Working 
Document (Guidelines)  
2014/15; 

2015/16; 

-  AMR 

2016/17 
-  Findings 
review 

from 

literature 

-  EU school scheme monitoring 
2017/18;2018/19; 

data 
2019/20; 2020/21 

-  School  Milk  reports  (Annual 
Statistics) 2014/15; 2015/16; 
2016/17 

-  School Fruit  Scheme  -  Annex 
V  of  DG  AGRI  Working 
Document (Guidelines) - AMR 
2014/15; 2015/16; 2016/17 
-  Structured  interviews  in  CS 
(schools/ 

countries/regions 
municipalities) 

-  Family survey in CS countries 
-  Findings 
literature 
from 
review 

-  EU school scheme monitoring 
2017/18;2018/19; 

data 
2019/20;2020/21 

-  School  Milk  reports  (Annual 
Statistics) 2014/15; 2015/16; 
2016/17 

-  School Fruit  Scheme  -  Annex 
V  of  DG  AGRI  Working 
Document (Guidelines) - AMR 
2014/15; 2015/16; 2016/17 
from 

literature 

-  Findings 
review 

Methodological approach and its limitations 

Tools, method and sources used 

The  analysis  is  carried  out  at  EU  level  EU-27+UK  and  at  MS  level  over  the  period  of 
implementation  of  the  scheme  2017/18-2020/21.  The  analysis  relies  on  secondary  data 
from the EU school scheme monitoring database and on family survey results. Monitoring 
data of the schoolyear 2020/21 do not include UK, as of 1 February 2020, UK is no longer 
an EU member.  

Triangulation  of  quantitative  and  qualitative  data  from  the  different  sources  was  used 
wherever possible.  

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

With regard to the EU school scheme direct consumption (in schools) the analysis focuses 
on the main elements that may contribute to any increase in consumption. In particular:  

 

increase  of  the  number  of  children  participating  to  the  EU  scheme,  and  the  scheme 
coverage67; 

  growth of per capita distribution in schools (per child);  
 

increase  of  the  number  of  products  distributed  (which  is  expected  to  increase  and 
improve children’s knowledge of a wider number/variety of fruit and vegetables and or 
milk and milk products that can be consumed)68. 

Furthermore,  the  effect  of  the  scheme  in  increasing  direct  consumption  of  the  products 
under analysis is also assessed by comparing the results of the current EU school scheme 
with the average of the period 2014/2015-2016/2017 of the two previous schemes (School 
fruit and vegetable scheme and School milk scheme) used as a baseline69.   

As regards the direct consumption per child of the different products, the analysis had to 
consider: 

 

 

the  differences  between  fresh  products  and  products  subject  to  different  levels  of 
processing, and the different proportions of fresh/processed products distributed at MS 
level and in each schoolyear;  
the fact that the number of children to whom each category of product is delivered is 
not  available,  which  prevents  a  correct  calculation  of  the  actual  per  capita 
distribution70.  

To overcome these issues, and also in order to have a comparable reading of per capita 
distribution  (consumption)  among  different  MS  and  among  years,  we  considered  it 
appropriate to reduce all quantities of the different products distributed under one common 
denominator. Therefore, the quantities distributed of each type of product were calculated 
in  terms  of  "raw  material  equivalent".  Raw  material  equivalents  express  a  unit  of  a 
processed product into the amount of raw material needed to produce the product (e.g., 
cheese  expressed  in  lt.  of  milk).  Quantities  in equivalent  raw  material  are  computed  by 
multiplying  the  quantities  of  the  processed  products  distributed  under  the  EU  school 
scheme by (average) processing coefficients. 

Moreover, in order to verify the robustness of this methodology, the results concerning per 
capita distribution in raw material equivalent of the schoolyears 2019/20 and 2020/21 (and 
the  difference  between  the  two  years)  were  compared  with  the  number  of  portions 
distributed per capita available in the monitoring data (this information is available only 
for  the  last  two  years  of  the  period  analysed).  Taking  into  account  that  the  notion  of 
"portion" does not correspond to a fixed quantity, the analysis at MS level showed overall 
comparable results concerning the sign of the difference between the two years, positive 
and negative (i.e., increase and/or a decrease over the two years)71. 

Qualitative information collected through the family survey and interviews in case studies 
MS were used to verify whether the quantities distributed to children are actually consumed 

67 Number of children benefiting from the scheme relative to the total number of children of the target school 
population. 
68  In some MS the range of known products and usually consumed is more limited than in others. 
69 Milk data: "School Milk reports (Annual Statistics)”. F&V data: "School Fruit Scheme  - Annex V of DG AGRI 
Working Document (Guidelines) - Annual Monitoring Report". 
70 E.g., in Bulgaria in 2017/18, were distributed 116 000 litres of drinking milk, 320 000 kg of cheese and curd 
and 1 806 000 kg of plain yoghurt. The total number of children involved in the EU scheme distribution that year 
was 471 000, but the number of children to whom each category of product was distributed is not known. 
71 The few discrepancies observed are related to a change in the size and/or composition of the portions over the 
two years. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

at  school  or  not  (and  why  children  not  always  consume  the  distributed  products).  The 
family survey data is treated quantitatively. 

With regard to the effects of the EU scheme on indirect consumption (outside the period 
of distribution under the scheme and at home) the analysis relies on data gathered through 
the family survey. The net effects of the scheme on indirect consumption are  calculated  
by the difference between the percentage of answers to the survey given by families with 
children  participating  in  the  EU  school  scheme  (target  group)  and  the  percentage  of 
answers given by families with children not participating to the scheme (control group) 72: 
NE (net effect) = % Answerstg - % Answerscg (for example: if the percentage of answers of 
the target group to a specific question is 30% and the percentage of answers of the control 
group to the same question is 25%, the net effect is 5 percentage points). 

Factors influencing children’s consumption and its changes are numerous and diverse (73). 
However, these factors should affect to the same extent the consumption of both children 
participating in the EU school scheme (target group) and children not participating in the 
scheme (control group, considered as counterfactual). Therefore, the difference between 
the results obtained for the two groups represent the role played by the implementation of 
the EU school scheme (net effect74). 

The analysis is complemented with findings from relevant academic research and studies 
addressing the subjects. 

The results of the analysis concerning the level and the stability of consumption (direct and 
indirect)  was  enriched  by  the  opinions  of  EU  school  scheme  administrators  and 
stakeholders concerning the effects of the implementation of the scheme on the products 
(case studies). 

Limitations of methods and sources 

When reading the results of the analysis, it is important to bear in mind that the school 
year 2019/2020 coincides with the beginning of the COVID-19 pandemic that forced, since 
March 2020, MS to adopt strict restrictive measures. These measures influenced the size 
of the school population (and therefore volumes of products distributed) at least in the four 
last months of the schoolyear 2019/2020 and in the schoolyear 2020/2021.  

When comparing the results of the previous schemes with the current scheme, it  should 
be taken into account that: 

 

 

 

the previous two schemes were fully operational while the current scheme may have 
had initial delays in its launch across the different MS; 
the current scheme introduced changes in eligible products (in particular the milk part 
of the scheme) and in reimbursement rules; 
changes have been introduced also in monitoring requirements and guidelines. 

72 Two different questionnaires were used in the survey: one for the target group and one for the control group. 
The two questionnaires and the ten case study’s MS where the survey has been carried out (Czechia, Germany, 
Italy, Lithuania, Netherlands, Poland, Portugal, Romania, Spain, Sweden) have been agreed with the Steering 
Group. 
73 Scaglioni S., De Cosmi V., Ciappolino V., Parazzini F., Brambilla P., Agostoni C., Factors Influencing Children’s 
Eating Behaviours. Nutrients. 2018; 10(6):706. https://doi.org/10.3390/nu10060706  
74  The  method  for  the  comparison  between  a  target  group  and  a  control  group  (DID:  difference-in-difference 
model)  in  order  to  assess  the  net  effect  of  policy  implementation  is  provided  in  “Guidelines-  Assessing  RDP 
achievements  and  impacts  in  2019  -  European  Evaluation  Helpdesk  for  Rural  Development”,  European 
Commission, August 2018. 

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Therefore, results should be taken with caution. 

Some factual errors identified in the monitoring data of the current EU scheme and in the 
data of the previous schemes have been, when possible, corrected. In addition, data gaps 
for some MS in some years and UK withdrawal since 2020/2021 represent a limitation in 
the  calculation  of  indicators  at  EU28  level,  in  particular  those  derived  from  the  ratio 
between two variables75.   

Therefore,  it  was  necessary  to  apply  different  aggregations  of  MS  for  the  different 
indicators,  so  as  to  obtain  a  robust  and  effective  comparability  of  the  results  across 
schoolyears under analysis.  In particular, for  each indicator, an aggregate of  MS (called 
MSA) was identified for which: 

  data is available for all the years (these aggregates allow a correct assessment of the 

evolution during the analysed period);  

  data is available for both variables of the indicators used to answer the ESQ76. 

thus, excluding from the aggregates, when necessary, MS for which data is missing in one 
or more years. Hence the aggregate of MS (MSA) differs for each indicator (MS composing 
the aggregate are always indicated). 

It is important to bear in mind that the provision of separate data on the number of children 
participating in the F&V part of the scheme and in milk part is non-mandatory for MS. 

As regards the direct consumption per child of the different products, the lack of precise 
knowledge about the actual types of processed product (each having its own processing 
coefficient)77 is a limitation of the analysis and thus the results have inevitable inaccuracies 
and should be taken with caution.  

The comparison of the number of products distributed per pupil per year under the current 
scheme with the number of products distributed under the previous EU school schemes, 
was possible only for F&V78. Moreover, in contrast to the monitoring system of the current 
EU scheme which presents a defined list of products, the previous F&V scheme monitoring 
system did not. Therefore, the results of the analysis should be taken with caution. 

4.1.1.2  Analysis 

Judgement  criterion  1.1:  Over  time  the  number  of  children  involved  in  the 
distribution  of  fruit  and  vegetables,  milk  and  milk  products  under  the  EU 
school scheme has (has not) increased 

Evolution of the number of children involved in the current EU school scheme 

The  analysis  of  the  number  of  children  involved  in  the  EU  school  scheme  in  the  period 
2017/18-2020/21,  based  on  monitoring  data,  shows  that  between  the  schoolyear 
2017/2018 and the schoolyear 2020/2021 the number of children decreased by -14.2%, 
(from 18.6 million to 16.0 million children, EU27), as a result of a gradual decrease over 

75 e.g., the indicator “evolution 2017/18-2019/20 of the average consumption per child of F&V” is the result of 
the ratio between “distributed quantities” and “number of children”. If for one of the two variables used in the 
computation of the ratio, data of some MS and in different years are not available, the results of the indicator at 
aggregated EU-28 level are biased, and therefore not comparable across years.  
76 e.g., in the case of the indicator “evolution 2017/18-2019/20 of the average consumption per child of F&V”, 
the  MS  group  consists  of  all  MS  that  have,  for  all  the  considered  years,  both  data  concerning  the  distributed 
quantities of F&V in schools and data concerning the number of children who received F&V in schools. 
77  This  limitation  concerns  mainly  cheeses.  This  category  has  a  large  number  of very different  products  (soft, 
semi-hard, hard cheese), with correspondingly different processing coefficients. 
78 Milk and milk products data of the previous scheme are too aggregated to be compared. 

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time. The COVID-19 emergency, started in March 2020, has dramatically accentuated this 
ongoing phenomenon. 

Figure 4: Evolution of the number of children involved in EU School Scheme (EU-27, 
EU27+UK, 2017-2021) 

Children (1 000 000) 

Change % 

Source: own elaboration based on the EU School Scheme monitoring data 

The decrease of the overall number of pupils involved in the school scheme at EU27 level 
is the effect of differentiated patterns at MS level. Albeit, we observe a decrease in 17 MS, 
the  decrease  observed  in  Poland  (- 32.5%)  Romania  (- 13.5%)  Spain  (- 15.9%)  Italy 
(- 25.6%)  and  France  (- 48.3%)  has  a  significant  incidence  on  the  EU27  result,  as  the 
initial  number  of  children  of  these  MS  is  (relatively)  high.  Conversely,  Cyprus,  Czech 
Republic,  Estonia,  Latvia,  Luxembourg  and  Slovenia  show  an  increase  of  the  number  of 
children  involved  in  the  scheme,  while  in  Germany  and  Sweden  the  number  of  children 
remained stable. 

The size of the % changes of each MS is to a large extent (although not exclusively) linked 
the control measures and public health policies deployed by national governments in order 
to limit the spread of COVID-19 pandemic since March 2020: some MS (i.e., Italy, France) 
imposed  severe  lockdowns  and  distance  learning  for  long  and/or  short  periods  of  time; 
other MS (i.e., Sweden) kept schools open. 

In contrast to the decrease in the total number of children, the evolution of the number of 
children benefiting from the F&V part of the scheme shows a fluctuating development with 
an increase between the first and the second year and a return to its initial level in 2020/21 
as a result of the COVID pandemic (overall in the period 2017/18-2020/21 the number of 
children benefiting from the F&V part decreased by 2.5%). On the other hand, the number 
of children benefiting from the milk part shows a constant decrease since 2017/18. 

Figure 5: Evolution of the number of children benefiting from the F&V and milk part of 
the EU scheme (EU27, 2017/18-2020/21) 

Number children (1 000 000) 

Change % 

MSA: EU27 – (DE+EL+NL+ES) 
Source: own elaboration based on the EU School Scheme monitoring data 

30 

15.016.017.018.019.020.021.02017/182018/192019/202020/21Children (1 000 000)EU 27EU27+UKCovid-19-4.4-1.2-9.1-4.6-1.6-16.1-18.0-16.0-14.0-12.0-10.0-8.0-6.0-4.0-2.00.02018-19/ 2017-182019-20/ 2018-192020-21/ 2019-20% ChangeEU 27EU27+UKCovid-19 7.0 7.5 8.0 8.5 9.0 9.5 10.0 10.5 11.0 11.52017/182018/192019/202020/21F&VMilk12.6-3.6-10.1-4.1-4.6-5.0-15.0-10.0-5.00.05.010.015.02018-19/ 2017-182019-20/ 2018-192020-21/ 2019-20F&VMilk 
 
 
 
 
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

Comparison of the number of children involved in the current EU school scheme with 
the previous schemes 

The  comparison  of  the  results  of  the  current  EU  school  scheme  with  the  results  of  the 
previous schemes (average 2014/15-2016/17), further reinforces these findings:  

 

 

concerning  fruit  and  vegetables,  the  current  scheme  engendered  an  increase  in  the 
number  of  children  compared  to  the  previous  period,  interrupted  by  the  COVID-19 
pandemic. However, the ratio between the number of children participating in the F&V 
part  of  the  current  scheme  and  the  three-year  average  number  of  children  of  the 
previous  scheme  (used  as  a  baseline)  is  always  greater  than  1  even  during  the 
schoolyears affected by the pandemic79;   
concerning milk and milk products, a significant decrease is observed in the number of 
children compared to the previous scheme: the ratio is sharply below 1, and tends to 
slightly decrease (from 0.72 to 0.63 between 2017/18 and 2020/21), However, this is 
mostly attributable to France, Italy and Poland, which have considerably reduced the 
number  of  children  compared  to  the  previous  period80.  Besides,  France,  Italy  and 
Poland,  other  MS  (Cyprus,  Denmark,  Belgium,  Romania,  Sweden  and  Finland)  show 
ratios <1, but their incidence on the total MSA is more limited81. 

Figure 6: No of children participating in 
the previous and in current EU Scheme 
(EU-27, million) 

Figure 7: Ratio No children benefiting 
from current EU scheme/average 
previous scheme (EU-27, %) 

MSA Milk: EU27 -(DE+ EL+ NL+ ES) 

MSA F&V= MSA= EU27-(FI+DE+EL+NL+ES) 

Sources: Own elaboration based on EU school scheme monitoring data 2017/18-2020/21; School Milk reports 
(Annual Statistics) 2014/15-2016/17; School Fruit Scheme - Annex V of DG AGRI Working Document 
(Guidelines) 

The results of the analysis highlights that, in general, there is simultaneously an increase 
of children participating in the F&V part of the scheme and a decrease (in relative terms) 
of  the  number  of  children  that  participates  in  the  milk  part  of  the  EU  scheme.  This  is 
common to most MS for which data are available. 

Finally, the results of the analysis show that, under the current scheme, the percentage of 
children  benefiting  only  from  F&V  or  only  from  milk  and  milk  products  has  significantly 
decreased  (over  30%),  while  the  percentage  of  children  receiving  both  categories  of 
products has  significantly increased (over 12%). Therefore,  at  school and over time,  an 
increasing number of children are benefiting from a more varied supply of products. 

79 Most MS with available data show a ratio >1, except Belgium, France, Italy, Hungary, Croatia, Ireland, Malta 
and Poland.  
80 Since these MS have a large school population, the % changes have an important effect on the EU aggregate.   
81 All other MS have ratios >1, and Czech Republic, Bulgaria and Austria show particularly high values. 

31 

6.08.010.012.014.016.018.02014/152015/162016/172017/182018/192019/202020/21Children (1 000 000)MSA F&VMSA MilkPrevious periodCovid-191.071.201.161.030.720.690.660.630.400.500.600.700.800.901.001.101.201.302017/18/Av prev2018/19/Av prev2019/20/Av prev2020/21/Av prevF&VMilk 
 
 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

Evolution of the coverage rate of the current EU school scheme 

As regards the coverage rate, the ratio (%) between the number of children participating 
in the EU scheme and the number of children in the target group set out in the national 
strategies  for  the  school  scheme  was  calculated.  The  coverage  rate  reflects  the  results 
actually achieved (children involved in the scheme) respect the expected results.  

The results show an average coverage rate82 of 35.1% with a maximum of 46.7% in the 
case of children attending primary school and a minimum of 15.1% for children attending 
secondary school. The same hierarchy among the different school categories is observed 
for children participating to the F&V and to the milk parts of the scheme. This confirms MS 
strategic  choices  of  concentrating  the  distribution  of  the  selected  products  in  primary 
schools. 

However, at MS level, important differences are observed. Namely, the very low degree of 
coverage achieved in France (3.5% out of a target of 12 000 000 children)83, which has a 
significant effect on the coverage rate at general level: without France, the MSA ratio rises 
from 35.1% to 53.5% (average of the four years).  

Furthermore,  the  coverage  rate  of  the  milk  part  of  the  scheme  is  higher  (on  average 
25.7%) than the F&V part rate (20.5%) in all MS with available data for both variables84. 
Taking  into  account  the  increasing  trend  of  the  F&V  part  of  the  EU  scheme,  this  result 
would  confirm  further  future  potential  of  growth  of  the  number  of  children  that  could 
participate to the F&V part of the scheme. 

Figure 8: Evolution of the EU scheme 
coverage rate (EU27, %) 

Figure 9: Average 2017/18-2020/21 
coverage rate by MS (%) 

MSA=EU-27- (FI, DE, EL, MT, NL, PT, ES) 
Source: own elaboration based on the EU School Scheme monitoring data 

Evolution of pupils participating in the EU school scheme by school level 

Concerning  the  distribution  of  the  number  of  pupils  by  school  level,  MS  choices  are 
particularly concentrated on primary schools representing 71% of the children involved in 
the scheme at EU-27 level (average 2017/18-2020/21), while secondary schools are less 
involved (on average 10.5% of children).  

82MSA = EU27 - (FI, DE, EL, MT, PT, ES). 

83France has experienced a series of difficulties that have hampered the implementation of the  scheme. Based 
on  information  collected  in  case  study  MS  and  regions,  main  issues  are  related  to:  administrative  burden 
(administrative procedures have been simplified in February 2020 but the results might not yet be visible due to  
the  COVID  crisis),  overlapping  between  products  delivered  by  the  EU  scheme  and  products  already  delivered 
during lunchbreaks; restrictions on distribution times; collective catering already well-structured and the school 
scheme is perceived as adding complexity to the existing organisation of schools. 

84 MSA = EU-27 - (FI, DE, EL, MT, NL, PT, ES) for F&V and for milk (this data is not mandatory for MS). 

32 

15.020.025.030.035.040.045.050.055.060.065.02017/182018/192019/202020/21MSA TotalMSA F&VMSA MilkMSA without FR0.010.020.030.040.050.060.070.080.090.0100.0FRIEDKBEITCYATHUHRPLLTSKSEBGSLROLVCZEEPTLUMSA 
 
 
 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

Figure 10: % of children participating in the EU school scheme by school level (total 
number of children by year = 100%, EU-27) 

Source: own elaboration based on the EU School Scheme monitoring data 

Therefore,  in  general,  MS  implementation  choices  focus  on  children  belonging  to  age 
groups potentially more perceptive in adopting the consumption patterns envisaged by the 
policy. Yet, it should be pointed out that the age classes indicated under the primary school 
level in the EU school scheme MS strategies are rather differentiated: e.g.in France primary 
school comprises children aged 6-11 years old; in Denmark 5-15 years old; Finland 6-16 
years old. 

Even if evidence in the literature points to the difficulty of identifying the most adequate 
target  group/s  by  children  age  due  to  limited  evidence  (85),  it  also  indicates  that  eating 
behaviour is shaped early in life and can show long-term stability. Therefore, nutritional 
education should be targeted at children and adolescents in particular, and could thus have 
a  potential  role  in  the  prevention  of  many  diet-related  diseases  (Mikkila  et  al.,  2005; 
Issanchou, 2017) (86).  

Judgement criterion 1.2: The quantity of fruit and vegetables, milk and milk 
products  consumed  by  children  in  school  (direct  consumption)  and  outside 
school (indirect consumption) has (has not) increased over time 

A.  Direct consumption 

The  analysis  of  direct  consumption  (linked  to  the  distribution  of  the  products  under  the 
scheme)  is  based  on  the  analysis  of  the  monitoring  data  concerning  the  distributed 
quantities of the selected products. It is important to bear in mind that, in order to have 
comparable  data  among  MS,  the  distributed  quantities  of  the  different  products  are 
expressed in raw material equivalents. 

85 Department of Nutrition, University of Oslo, “Feedback on the Combined evaluation Roadmap/Inception Impact 
Assessment: Review of the EU school fruit, vegetables and milk scheme”, 2022. Ongoing research as part of the 
JPI HDHL Policy Evaluation network (PEN) project (https://www.jpi.pen.eu/). 
86 Mikkila V., Räsänen L., Raitakari O.T., Pietinen P. and Viikari J., “Consistent dietary patterns identified from 
childhood to adulthood: The Cardiovascular Risk in Young Finns Study”, British Journal of Nutrition, 2005, No 93, 
pp. 923–931. Issanchou S., “Determining factors and critical periods in the formation of eating habits: Results 
from the Habeat project”, Ann Nutr Metab, 2017, No 70, pp. 251–256. 

33 

18.071.110.916.174.19.817.173.89.119.570.89.70.010.020.030.040.050.060.070.080.0Nurseries/Pre-schoolsPrimary schoolsSecondary schools2020/212019/202018/192017/18 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

The  analysis  shows  that  total  distributed  quantities  of  F&V  decreased  by  about  22% 
between 2017/18 and 2020/21 (after an increase of 3.7% between the first and the second 
year)87, while total milk quantities decreased by about 38% and constantly throughout the 
analysed period88. 

Figure  11:  Distributed 
quantities in raw material 
equivalent 
(I.N. 
EU27) 

2017/18=100, 

Source: own elaboration based 
on  the  EU  School  Scheme 
monitoring data  

These developments are partly related to the evolution of the number of children over the 
period  (see  3.2.1)89,  but  also  related  to  national  decisions  regarding  the  increase  or 
decrease of i) the frequency of distribution (number of portions per week), ii) the duration 
of the distribution (number of days/weeks per schoolyear), iii) the average portion size, 
iv)  the  composition  of  the  products  distributed90.  These  elements,  as  well,  have  been 
influenced by the difficulties in the supply of the selected products for distribution caused 
by the COVID-19 crisis91.  

Therefore,  the  evolution  of  the  quantities  distributed  per  capita  (in  raw  material 
equivalent),  at  EU  level  and  at  MS  level,  is  the  result  of  the  combination  of  the  two 
dynamics:  

 

 

concerning fruit and vegetables, the average amount distributed per capita92 fell from 
7.3 kg  in  2017/18  to  6.2 kg  in  2020/21,  showing  a  21%  decrease  (- 9.6%  between 
2017/18  and  2018/19).  The  decrease  is  the  result  of  the  reduction  of  the  overall 
distributed  quantities  (- 22.7%  between  2017/18  and  2020/21)  and  of  a  lower 
reduction of the number of participating children (- 2.5%); 
concerning  milk  and  milk  products,  the  average  quantities  distributed  per  capita93 
passed from 17.1 litres in 2017/18 to 12.2 litres in 2020/21, showing a 28.9% decrease 
(- 9.7% between 2017/18 and 2018/19). The result is the consequence of the reduction 

87 Between 2017/18 and 2020/21 all MS decreased the distribution of F&V, except CZ, EE, ES, NL, PT, RO, FI.  
The distribution in Poland decreased by 51% (from 21.1 to 10.4 million Kg); in Germany by 34% (from 9.9 to 
6.5 million Kg); in Italy by 25% (from 6.4 to 4.8 million Kg). Approximately half of the decrease in the EU-27 is 
a consequence of the Polish decrease. 
88 Between 2017-18 and 2020-21 all MS decreased the distribution of milk and milk products, except BG, ES, FR, 
CY, LU, MT. The distribution in Romania decreased by 76% (from 43.6 to 10.4 million lt.); Poland by 48% (from 
44.4 to 23.0 million lt.): Germany by 54% (from 14.6 to 6.7 million lt.). 
89 The regression analysis confirms a correlation between the number of children and the quantities distributed: 
a) very high in the case of milk (R2= 94.8%); b) lower in the case of F&V (R2= 21.9%). 
90 For example, in the milk part change in the quantity of cheese and in F&V part a change in the quantity of juice 
(products with a high processing coefficient). 
91 For example, in Poland, a decrease of 36% of the number of children was associated with a decrease of 50% 
of  F&V  quantities.  Similarly,  in  Romania,  13%  decrease  of  the  number  of  children  was  associated  with  76% 
decrease of milk quantities. 
92 Distribution per child participating in the F&V part of the EU school scheme. 
93 Distribution per child participating in the milk part of the EU school scheme. MSA = 27 - (DE, EL, ES, NL). 

34 

50607080901001102017/182018/192019/202020/21Milk (N.I)F&V (N.I) 
 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

in the overall quantities distributed (- 38,2% between 2017/18 and 2020/21) and of a 
lower reduction of the number of participating children (- 3.1%). 

This average result is the effect of diversified patterns among MS, in both sectors: in the 
case of F&V, there are large differences in the distribution per child in the first schoolyear 
(2017/18) (i.e., from a minimum of 0.3 Kg in Malta to a maximum of 26 Kg in Denmark) 
and  also  significant  differences  in  the  variations  between  2017/18  and  2020/21 
(particularly negative for Denmark, Romania, Italy and Poland, and particularly positive for 
Ireland,  Finland,  Malta,  Belgium  and  Czech  Republic).  Similarly,  in  the  case  of  milk  and 
milk products, we can observe large differences in the initial situation (from a minimum of 
0.9 kg per child in France to a maximum of 26 kg in Hungary), and large diversity in the 
size of the variations between 2017/18 and 2020/21 (particularly negative for Romania, 
Austria,  Italy,  Slovakia,  Poland  and  particularly  positive  in  Malta,  France,  Belgium, 
Denmark and Cyprus). 

The comparison with the schemes  of the previous  period (2014/15 to 2016/17), further 
reinforces the results already emerged concerning the milk part of the scheme, for which 
a decrease in the distribution per capita is part of a process already ongoing in the previous 
period. 

Figure 12: Evolution of the consumption 
per capita of milk and F&V (current and 
previous period (I.N. 2014/15 =100,  
EU-27) 

Figure 13: Evolution of ratio 
current/previous EU school scheme 
 (EU-27) 

F&V: MSA = EU27-(DE, EL, ES, NL, PT) - Milk: MSA = EU27-(DE, EL, ES, HR, NL) 

Source: own elaboration based on the EU School Scheme monitoring data; School Fruit Scheme - Annex V of 
DG AGRI Working Document (Guidelines); School Milk reports; Reg. (EC) no 657/2008 

Furthermore, the analysis of the ratio between the quantities distributed each year of the 
current scheme with the three-year average of the previous two schemes, shows that in 
the case of F&V, the ratio is above 1 in the first year of the current scheme (1,02), but it 
becomes progressively less than 1 in the following three years, with a slight recovery in 
2020/202194. Concerning milk and milk products, the ratio value is always below 1 showing 
a decreasing development95. 

94  At  MS  level,  only  Bulgaria  and  Latvia record ratio values above 1  in  all  four  years  of  the  current  EU  school 
scheme,  while some  MS  (Denmark,  Hungary  and Romania)  show  ratio  values  above  1  in  the first  and  second 
year, but below 1 in the last two years. Finally, Ireland, Austria and France show an uneven development, with 
values above or below 1 depending on the years. 

95At MS level, only Bulgaria, Denmark and Croatia record ratio values above or near 1 in all the four years of the 
current scheme, while Czechia and Poland show ratio values above one in the first two years, but always below 
1 in the last two year. 

35 

50.060.070.080.090.0100.0110.02014/152015/162016/172017/182018/192019/202020/21F&L (N.I)Milk (N.I)1.02 0.93 0.78 0.81 0.86 0.77 0.62 0.62 0.000.200.400.600.801.001.202017/182018/192019/202020/21F&VMilk 
 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

It is important to bear in mind that these results refer to the quantities distributed per child 
under the EU scheme and do not give information on whether these are actually consumed 
by children.  

In order to have a more realistic picture, specific questions were asked in the framework 
of  the  family  survey96  on  the  topic  "products  distributed  at  school  are/are  not  actually 
consumed and why". 

Regarding  F&V,  66%  of  the  3  306  families  having  answered  to  the  question  “Does  it 
happens that your child does not eat the F&V distributed at school?” stated that their child 
often  or  sometimes  does  not  eat  the  products  distributed  at  school97.  The  percentage 
exceeds 50% in all MS, with a maximum in Romania (76%) and a minimum in Portugal 
(52%). The percentage of families that state that their children do not eat the distributed 
fruit  and  vegetables  at  school  is  higher  in  families  with  a lower  level  of  education  (over 
70%) and in families living in rural areas98.  

Regarding  milk  and  milk  products,  52%  of  the  2  914  families  having  answered  to  the 
question  “Does  it  happens  that  your  child  does  not  eat  the  milk  and/or  milk  products 
distributed  at  school?”  indicate  that  their  child  often  or  sometimes  does  not  eat  the 
products distributed at school99. In this case, the percentage exceeds 50% in DE, LT, RO, 
SE (with a maximum of 67% in Romania), while in the other MS it is below 50% (with a 
minimum in PT and ES, 36-38%). Also in this case, the percentage appears to be inversely 
correlated with the educational level of the families (no major differences are observed in 
terms of families place of living).  

These results highlight that per capita quantities distributed in schools do not necessarily 
coincide  with  the  quantities  actually  directly  consumed  by  children  at  school  (direct 
consumption). This seems particularly true in the case of F&V (although it is not possible 
to establish the extent).  

The results of the family survey on the reasons why both fruit and vegetables and milk and 
milk products distributed at school are often or sometimes not consumed, highlighted three 
main aspects: taste, snacks brought from home, lack of time. Only for F&V, the difficulty 
in handling them (peeling) is also an important reason100. 

Table 1: Reasons why products distributed at school are “often” or “sometimes” not 
consumed by children at school 

He/she does not like them 
He/she  had  already  a  snack  when  fruit  and/or  vegetables/  milk  are 
distributed  

29% 

27% 

26% 

30% 

F&V (*)  Milk (*) 

96  The  survey  has  been  carried  out  in  the  following  MS:  Czech  Rep.,  Germany,  Italy,  Lithuania,  Netherlands, 
Poland, Portugal, Romania, Spain, Sweden.  
97 14% of the families answered “often” and 52% answered “sometimes”. 
98 It was asked to families to indicate the place of living with the following options: rural area or village/small or 
middle town/large town. 
99 12% of the families answered “often” and 40% answered “sometimes”.  
100  At  MS  level,  the  importance  of  the  different  reasons  is  quite  articulated.  For  example,  for  milk,  the  most 
important reason in Spain, Romania, Portugal and the Czech Republic is the availability of snacks brought from 
home. In Poland and Germany, it is the lack of time. In Italy, Lithuania, Netherlands and Sweden it is the taste. 
For F&V, the most important reason in Spain, Romania, Portugal, Poland and the Czech Republic is the availability 
of snacks from home. In Germany, Lithuania and Netherlands it is the lack of time. In Italy it is the difficulty of 
handle it. For both parts of the scheme, taste and snacks brought from home are the two main reasons also if 
we  analyse  the  answers  by  age  groups,  by  educational  qualification  level  and  by  place  of  living.  The  answers 
obtained  from  the  interviewed  local  authorities  and  civil  society  in  the  case  studies  MS  largely  confirm  the 
indications that emerged from the family survey. However, other reasons were mentioned regarding the quality 
of  the  distributed  products:  unripe  fruits  (FR),  not  fresh  F&V  (DE-Bavaria,  LT,  ES),  low  quality  and  bad 
presentation of the products (PT). Finally, to organisational causes (non-distribution of spoons to eat yoghurt in 
PL). 

36 

 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

The portions are too big 
He/she suffers from food intolerance/allergy 
There is no time to eat / to drink them in class  
It is difficult to eat the F&V in class because they need to be peeled/cut 
He/she follows a specific diet (e.g., vegetarian, vegan, etc.) 
Other reasons 
I don’t know 

12% 
7% 
20% 
24% 
- 
7% 
3% 

11% 
9% 
25% 
- 
8% 
9% 
3% 

(*) % of the total number of surveyed families stating that their children often or sometimes does not eat the 
products distributed at school 

Source: own elaboration based on the family survey data 

Based on the information gathered through the interviews in the case studies MS the “non-
consumption” phenomenon concerns almost all products, but in a differentiated way among 
MS: vegetables are more  often not  consumed  in North Rhine Westphalia (DE-NRW) and 
exotic fruits in NL. Milk products are more often not consumed in FR and LT (soft and hard 
cheeses) and milk in RO and ES. F&V processed products are also frequently refused in ES. 

It is interesting to discover what happens to products distributed but not immediately 
consumed by pupils at school. Interviewees in the case studies MS indicate that, in most 
cases,  products  are  taken  home  (DE,  IT,  LT,  PL,  ES,  RO),  and  therefore  (probably) 
consumed within the family. In less frequent cases, i.e., in three case studies’ MS (FR, 
DE-NRW; ES), they are thrown away and recycled as compost. In other MS (FR, PT and 
ES) products are kept and redistributed to pupils the day after and/or given to teachers 
(ES). 

Concerning products not consumed, some studies (Ismail et al., 2021) (101) point out that 
“…the amount of waste frequently dependents on the popularity of F&Vs served:  e.g., 
fruit  is  purchased  more  frequently  than  vegetables  to  avoid  waste  and  maintain 
children’s interest”. 

Confirming the attention given by MS to the issues related to food waste, the analysis of 
the themes addressed by the accompanying measures shows that the theme food waste 
is the third most addressed at EU level (see 4.2.1). 

B.  Indirect consumption 

The analysis of indirect consumption (i.e., outside the period of distribution under the EU 
scheme as well as at home) is based on the results of the family survey. In order to verify 
whether  the  distribution  of  the  products  in  schools  has  stimulated  indirect  consumption 
(outside school) of the selected products, % of the surveyed families stating a change of 
their  child's  consumption  outside  school  compared  to  the  situation  before  the  child's 
participation in the EU school scheme (target group of the family survey) was calculated. 
In addition, the % of families with children not participating to the scheme (control group) 
stating a change of the child's consumption outside school during the last year was also 
calculated for the same products. The net effects of the EU school scheme are calculated 

101  Ismail  M.  R.,  Seabrook  J.  A.  &  Gilliland  J.  A..  Process  evaluation  of  fruit  and  vegetables  distribution 
interventions  in  school-based  settings:  A  systematic  review.  December  2020,  Preventive  Medicine  Reports 
21(146):101281, DOI:10.1016/j.pmedr.2020.101281. 

37 

 
 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

as the difference between the percentages of the answers of the two groups (see 4.1.1.1). 

The analysis focuses on two aspects: the net effect on the increase in consumption (families 
stating “has increased”) and the net effect on the preservation of consumption (“remained 
the  same”).  The  latter  aspect  cannot  be  ignored  as  a  significant  proportion  of  children 
decreases the consumption of the products (“has decreased”). Therefore, it is possible that 
the EU scheme contributes not only to the increase of consumption, but also to slow down 
the decline102 (i.e., maintenance of consumption levels). 

Moreover, families were asked to express an opinion concerning all the products distributed 
under the EU school scheme and not only on those actually distributed in their MS schools. 
This methodological choice was done in order to capture changes in consumption also on 
products that may benefit from a halo effect103. 

Figure 14: Change in the quantities consumed by children outside of school, after the 
participation in the EU school scheme 

The results of the family survey highlight that: 

Source: own elaboration based on the family survey data 

  most families of the target group (over 50%) stated that children did not change the 
consumption  of  the  products  distributed  under  the  scheme  outside  the  school.  This 
result  concerns  all  products  and  is  common  to  all  MS104.    The  differences  with  the 
control group, however, are very small, ranging from a minimum of 1% (fresh fruit and 
processed  fruit)  to  a  maximum  of  3.5%  (milk  with  added  sugar  or  flavouring  and 
yoghurt with added sugar, fruit, nuts, flavours). Thus, the EU school scheme helped to 
maintain  previous  levels  of  consumption  (and thus  helped  to  limit  the  decline  of  the 
consumption), albeit to a limited extent; 

102 The family survey results show that for children having decreased consumption, the net effect between the 
target group and the control group ranges from a minimum of -2.6 percentage points for fresh fruit to a maximum 
of -6.9 percentage points for milk, i.e., the decrease is significantly less accentuated in the case of the children 
of the target group. 
103 The 'halo effect' is a type of cognitive bias in which the perception of an element is positively or negatively 
influenced by the perception of one or more other positive or negative elements of the object. In marketing, the 
'halo effect' is the effect by which the (positive) impression of a certain product tends to be extended to other 
different products belonging to the same sector. Therefore, the increase in consumption of one product can trigger 
the increase in the consumption of similar products. 
104 Only exception, fresh fruits in Czech Republic where the share of families stating that children did not change 
the consumption outside the school is 46.5%. 

38 

-10.0%0.0%10.0%20.0%30.0%40.0%50.0%60.0%70.0%Has increasedRemained thesameHas decreasedHas increasedRemained thesameHas decreasedHas increasedRemained thesameHas decreasedTARGET GROUPCONTROL GROUPDIFFERENCEFresh fruitsFresh vegetablesProcessed F&VMilkMilk with added sugar or flavouringYoghurt with no added sugar, fruit, nuts, flavoursYoghurt with added sugar, fruit, nuts, flavoursCheese 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

  a  significant  proportion  of  families  of  the  target  group  (ranging  from  19%  to  39%, 
depending on the products) stated that children increased their consumption outside 
the school of the selected products, while a smaller proportion responded that children 
decreased their consumption. In general, the most significant increases concern: fresh 
fruit  (50%  in  Czech  Republic,  between  40%  and  45%  in  Portugal,  Romania,  Spain). 
The least significant increase concerns all products in Lithuania;   

  however, although all positive, the differences with the control group are rather small. 
Regarding the increase in consumption, the lowest differences (and thus the size of the 
net  effects)  include  all  products  of  the  F&V  sector  (from  3%  to  5%  points),  while 
somewhat higher differences are found for all products in the milk sector (from 6% to 
8% points); 

  At MS level, the size of the differences is quite diversified according to the products. In 
Italy the net effects are higher for all products, as well as in Spain for fresh fruit; in 
Czech Republic, Netherlands and Spain for processed F&V; in Czech Republic, Germany, 
Poland, Spain for milk; in Czech Republic for milk with added sugar or flavouring; in 
Czech  Republic  and  Spain  for  yoghurt  with  no  added  sugar,  fruit,  nuts,  flavours;  in 
Czech Republic for yoghurt with added sugar, fruit, nuts, flavours; in Spain for cheese; 
conversely,  in  some  MS  the  net  effects  are  near  to  zero  (fresh  fruits  in  Lithuania; 
processed F&V in Poland and Romania; yoghurt with added sugar, fruit, nuts, flavours 
in Germany and Lithuania; cheese in Portugal) or even negative (milk in Lithuania and 
Romania; cheese in Netherlands). 

 

For almost all product categories the highest net effects are related to families with lower 
level  of  educational  qualification  and  mainly  living  in  rural  areas  (with  the  exception  of 
fresh fruits and vegetables and yoghurt with no added sugar, fruit, nuts, flavours). On the 
contrary,  the  lowest  net  effects  concern  families  with  higher  educational  qualification 
(tertiary education and upper secondary education), with the exception of milk and yoghurt 
with no added sugar, fruit, nuts, flavours). 

Finally, information collected through structured interviews in case study MS and regions 
provided some further insights:  

 

 

for  some  interviewees,  the  EU  scheme  played  a  positive  role  on  the  consumption  of 
F&V (Italy, Czech Republic DE-Bavaria, Netherlands, Poland) and milk (Italy, Lithuania, 
Poland),  also  due  to  the  existence  of  an  emulation  effect105  among  pupils.  In 
particular,  concerning  the  role  of  the  scheme  on  indirect  consumption,  interviewees 
stated that: children like the products and ask their families to include them in their 
diet  (Czech  Republic,  Poland);  some  children  bring  changes  home,  and  the  products 
are  bought  more  often  (France,  DE-NRW,  Netherlands);  parents  give  F&V  to  their 
children more often than before (DE-Bavaria, Netherlands) and pupils demand outside 
the school has also increased (Romania, Spain); 
for others, the impact on consumption was minimal for vegetables (Lithuania), because 
children are used to eat vegetables at home or as snacks (Italy) and for milk because 
its consumption is already a consolidated habit (Portugal) or because products are not 
very  tasty  (Romania).  For  some  interviewees,  there  is  no  evidence  of  an 
increase/consolidation  of  the  consumption  (Lithuania,  Spain,  Portugal).  Moreover, 
concerning  indirect  consumption,  children  eating  habits  are  very  difficult  to  change, 
even more at home (Czech Republic), and for some families it is not possible to buy 
expensive products distributed at school (Italy). 

105 Emulation effect is the generation of an impulse to imitate the actions or behaviour of others, taking them as 
a model so as not to appear inferior to them. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

Concerning children’s indirect consumption (at home), based on the family survey, we can 
therefore conclude that:  
 

in general, the EU school scheme has favoured an increase and/or the preservation of 
consumption, but for a rather limited proportion of participating children (in particular 
for F&V products); 

  more positive results have been achieved in some MS and among families with lower 

levels of education, mainly located in rural areas. 

Judgement criterion 1.3: The EU school scheme has (has not) contributed to 
increase  children’s  knowledge  of  F&V,  milk  and  milk  products  through  the 
provision of a greater variety of products 

The analysis under this judgement criterion is based on the scheme monitoring data and 
focuses on the evolution between the schoolyears 2017/18 and 2020/21 of the number of 
products distributed to pupils.  

The underlying hypothesis is that delivering to children a wide variety of products increases 
the likelihood of finding (more) popular products, which can then generate a halo effect on 
other products of the same category. Hence, the large range of products offered at school 
can encourage an increase of consumption and consequently broaden children's diets. 

Evidence in the literature points out that variety of products (F&V) delivered to  children 
should increase the likelihood of increasing intake of fruits and vegetables in general, as 
all  children  will  find  something  they  like  (Ismail  et  al.,  2021).  Moreover,  the  need  for  a 
greater  variety  of  fruit  and  vegetables  provided  to  children  through  distribution 
interventions  is  highlighted  (Ismail  et  al.,  2021).  Other  researches  mention  that  quality 
and  variety  of  products,  in  particular  F&V,  appear  to  be  factors  that  may  impact  the 
products consumption in middle and secondary schools (Meshkovska et al., 2022(106)). 

The results of the analysis carried out show that, on average at EU level, the number of 
different  varieties  of  fruit  and  vegetables  products  distributed  at  school  (fresh  and 
processed)  decreased  from  around  24  in  2017/18  to  around  20  in  2020/21107.  This 
decrease concerns all segments, both fresh fruits, fresh vegetables and processed fruit and 
vegetables108. At  MS level, considering  the whole set of products  of the  F&V part of the 
scheme, we can highlight that: 

 

the decrease is observed in 14 out of 26 MS having implemented the F&V part of the 
scheme109. The higher decreases concern Romania (from 25 in 2017/18 to 5 products 
in 2020/21: - 80%), Denmark (from 28 to 15: - 46%), Italy (from 26 to 16: - 30%), 
Germany (from 52 to 38: - 27%) and Spain (from 28 to 21: - 25%); 

  different situations are observed among MS. In the last year the number of different 
types  of  fruit  and  vegetables  products  is:  less  than  10  in  5  MS  (Ireland,  Latvia, 
Lithuania,  Luxembourg,  Romania);  between  10  and  19  in  10  MS  (Bulgaria,  Croatia, 
Denmark, Finland, Italy, Malta, Netherlands, Poland, Portugal, Slovakia); between 20 

106 Meshkovska B., Scheller D.A., Wendt J., Jilani H., Scheidmeir M., Stratil J.M., Lien N. and on behalf of the PEN 
Consortium, 2022. Barriers and facilitators to implementation of direct fruit and vegetables provision interventions 
in  kindergartens  and  schools:  a  qualitative  systematic  review  applying  the  consolidated  framework  for 
implementation research (CFIR). 
107 In 2020/21 there is a small improvement (from 19 to 20) after the continuous decrease of the previous years. 
108 Among MS the varieties that have mostly decrease are: fresh fruits: mangoes, nuts, quinces and aromatic 
herbs; fresh vegetables: artichokes, cabbages, cauliflowers, fennels, garlic, onions, mushrooms; processed F&V 
(vegetable juices; vegetable soups). 
109 AT, BE, CZ, DK, ES, FR, DE, HU, IE, IT, PL, RO, SK, SI. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

and 49 in 8 MS (Austria, Cyprus, Czech Republic, Estonia, Germany, Hungary, Slovenia, 
Spain); higher than 50 in 2 MS (Belgium and France). 

Concerning milk and milk products, products are grouped into categories and therefore the 
analysis  can  only  refer  to  these  categories110.  On  average  at  EU  level,  the  number  of 
product categories (fresh and processed) shows a fluctuating development during the four 
years under analysis (3.3 categories in 2017/18; 3.4 in 2018/19; 3.1 in 2019/20; 3.2 in 
2020/21)111. At MS level, only 6 show a decrease between 2017/18 and 2020/21 (Belgium, 
Czech Republic, Denmark, Estonia, France, Romania). Additionally, the situation is rather 
diversified among MS as in the last year the number of product categories is: 

 

less  than  3  in  8  MS  (Denmark,  Ireland,  Latvia,  Malta,  Portugal,  Romania,  Spain 
Sweden); 

  between 3 and 5 in 14 MS (Belgium, Bulgaria, Croatia, Cyprus, Estonia, Finland, France, 

Germany, Italy, Lithuania, Luxembourg, Netherlands, Poland, Slovenia); 

  higher than 5 in 4 MS (Austria, Czech Republic, Hungary, Slovakia). 

These  dynamics  seem  to  have  been  influenced  by  the  COVID-19  crisis,  which  has likely 
played  a  more  important  role  in  the  case  of  F&V  products  than  in  the  in  case  of  milk 
products.  In  fact,  supplies  of  fresh  products  from  agricultural  origin  seem  to  have  been 
hampered  by  greater  difficulties  (production  and  distribution)  than  products  mainly 
processed by the food industry (i.e., milk products). 

This evidence is confirmed by the results of the comparison between the current and the 
previous period (possible only for the F&V part of the EU scheme, see 3.1.3). In general, 
the value of the ratio between the number of products distributed to schoolchildren under 
the current and the previous scheme is higher than 1 in all the four analysed years of the 
current  scheme,  although  decreasing  (from  1.6  in  2017/18  to  1.3  in  2019/20  and 
2020/21).  

However, a fair number of MS, for which data are available, show values below 1 in the 
entire analysed period (Bulgaria, Croatia, Lithuania, Spain) or in the last three years (Italy 
and  Poland).  Conversely,  other  MS  show  values  above  1  in  the  four  schoolyears  under 
analysis  (Austria,  Czech  Republic,  Estonia,  Germany,  Hungary,  Luxembourg,  Malta,  the 
Netherlands, Romania, Slovenia). 

In conclusion, the evidences suggest that:  
  over the period 2017/18-2020/21, the number of products offered to schoolchildren is 

 

decreasing (F&V) or fluctuating (milk); 
in  the  case  of  F&V,  in  the  first  year  of  implementation  of  the  EU  scheme  school, 
2017/18, there  was an  increase of 60%  of the number of products compared to the 
previous  scheme.  Although  this  increase  has  gradually  diminished  in  the  following 
years, the number of products delivered to children has always remained higher when 
compared  to  the  previous  scheme.  Therefore,  despite  the  COVID  pandemic  and 
referring to F&V, the EU scheme has been effective in providing a wide variety of F&V 
products  to  schoolchildren,  potentially  increasing  their  knowledge  and  stimulating 
consumption of the products; 

110  Categories  are:  Drinking  milk  and  lactose-free  versions;  Cheese  and  curd;  Plain  yoghurt;  Fermented  or 
acidified milk products without added sugar, flavouring, fruit, nuts or cocoa; Fermented milk products without 
fruit  juice,  naturally flavoured;  Fermented  milk products with  fruit  juice,  naturally  flavoured or  non-flavoured; 
Milk-based drinks with cocoa, with fruit juice or naturally flavoured; Fermented or non-fermented milk products 
with fruit, naturally flavoured or non-flavoured. 
111 The categories most affected by the decrease are: fermented or acidified milk products without added sugar 
and Milk-based drinks with cocoa, with fruit juice or naturally flavoured. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

  however, the high disparity in the number of products offered to schoolchildren noticed 
among MS, shows that this objective is pursued with uneven intensity across MS. 

4.1.1.3  Conclusions 

Evaluation question 1 is related to the first objective of the EU school scheme and asks to 
assess whether and to what extent the EU school scheme, as implemented by  MS in the 
period  2017/2018-  2020/21,  had  an  effect  on  the  consumption  of  fruit  and  vegetables, 
milk and milk products distributed under the EU school scheme (listed in articles (23(3)(4) 
and  (5)  of  Regulation (EU) N 1308/2013)  and  actually  consumed  at  school  (direct 
consumption) and outside the school (indirect consumption112).  

Concerning the role played by the EU school scheme on children’s direct consumption, and 
taking into account some limitations mainly related to the availability of data at MS level113, 
the results show that, in the first years of implementation, the current scheme engendered 
an increase in the number of children participating in the F&V part of the scheme compared 
to  the  previous  period  and  that  this  increase  has  been  interrupted  by  the  COVID-19 
pandemic. 

In  general,  in  the  period  2017/18-2020/21  the  significant  decrease  in  the  number  of 
children overall involved in the EU school scheme is greatly linked with the beginning of 
the pandemic since March 2020. The differences observed among MS are mainly the result 
of  the  control  measures  and  public  health  policies  deployed  by  national  governments  to 
face the pandemic.  

However, while for the F&V part of the EU school scheme, the decrease of the number of 
children involved in the scheme is the consequence of the Covid-19 crisis, for the milk part 
the decrease generated by Covid-19 is part of a process already ongoing in the previous 
years. Besides Covid emergency, this would confirm a progressively decreasing interest of 
some MS (namely France, Italy and Poland) towards the milk part of the EU school scheme. 

Accordingly, it emerges that there is, simultaneously, an increase of the participation of 
children in the F&V part of the scheme and a decrease (in relative terms) of the number of 
children  participating  in  the  milk  part.  This  evolution  is  common  to  most  of  the  MS  for 
which data are available.   

Moreover, the evidence shows that the percentage of children receiving only F&V or only 
milk  and  milk  products  has  significantly  decreased  over  time,  while  the  percentage  of 
children receiving both categories of products has significantly increased (more than 12%). 
Therefore, at school and over time, an increasing number of children are benefiting from 
a more varied supply of products. 

Finally, the coverage rate (i.e., number of children involved in the scheme relative to the 
target fixed in the national strategies) of the milk part of the scheme is higher (on average 
25.7%) than the F&V part rate (20.5%) in all MS with available data. Taking into account 
the increasing trend of the F&V part of the EU scheme, this result would confirm a further 
future potential of growth of the number of children that could participate in the F&V part 
of the scheme. 

The results of the analysis show that the evolution of the quantities distributed at school 
(increase/decrease) is linked to the evolution of the number of children: the correlation is 
strong in the case of milk and smaller in the case of F&V. For the latter, the supply of the 
products to schools could have been influenced by food provision difficulties during the first 
period of the Covid-19 pandemic. In general, the decrease in the distributed quantities114 

112 i.e., outside the period of distribution under the EU scheme at school as well as at home. 
113 e.g., in the monitoring system data related to the number of children involved distinguished for each part of 
the scheme is not mandatory. Therefore, not all MS provide it and/or provide it occasionally. 
114 Calculated in terms of raw material equivalent. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

is higher than the decrease in the number of children involved in the scheme. Hence, the 
quantities distributed per child show a decline. In the case of milk and milk products, the 
pandemic crisis intensified, but did not cause, this decrease. These overall results are the 
combined effect of different situations at MS level. 

The analysis based on the family survey carried out in 10  MS showed that the products 
delivered  at  school  are  not  always  consumed  by  children  (especially  F&V)115.  Taste, 
availability of snacks brought from home and lack of time are the  main reasons for this 
phenomenon. Usually, unconsumed products are taken home or stored and redistributed 
the next day at school. In less frequent cases, they are thrown way or recycled as compost.  

Concerning the role played by the EU school scheme on children’s indirect consumption (at 
home),  the  analysis  based  on  the  family  survey,  show  that,  in  general,  the  EU  school 
scheme  have  favoured  an  increase  and/or  the  maintenance  of  consumption  of  a  limited 
proportion of participating children (in particular for F&V products). This result is consistent 
with  the  evidence  that  children  benefiting  from  the  scheme  do  not  always  consume  the 
products distributed at school. The results also highlight that more positive results would 
have  been  achieved  in  some  MS116.  Moreover,  more  positive  results  would  have  been 
achieved among families with lower levels of education and living in rural areas. 

Finally, the contribution of the EU scheme to the increase of children’s knowledge of the 
selected  products  through  the  provision  of  a  greater  variety  of  products,  has  been 
analysed.  Delivering  to  children  a  wide  variety  of  products  increases  the  likelihood  of 
finding  (more)  popular  products,  which  can  stimulate  the  consumption  of  other  similar 
products belonging to the same  sector (halo effect).  Hence, the large  range of products 
offered  at  school  can  encourage  an  increase  of  consumption  and  consequently  broaden 
children's diets as all children will find something they like. 

The  evidence  suggests  that  over  the  period  2017/18-2020/21,  the  number  of  products 
offered to schoolchildren is decreasing (F&V) or fluctuating (milk) but that in the case of 
F&V, in the first year of implementation of the EU scheme school, 2017/18, there was an 
increase of 60% of the number of products compared to the previous scheme. Although 
this  increase  has  gradually  diminished  in  the  following  years,  the  number  of  products 
delivered to children has always remained higher when compared to the previous scheme.  
Therefore,  despite  the  COVID  pandemic  and  referring  to  F&V,  the  EU  scheme  has  been 
effective  in  providing  a  wide  variety  of  F&V  products  to  schoolchildren,  potentially 
increasing  their  knowledge  and  stimulating  consumption  of  the  products.  However,  the 
high  disparity  in  the  number  of  products  offered  to  schoolchildren  noticed  among  MS, 
shows that this objective is pursued with uneven intensity across MS. 

115 Children “often” or “sometimes” do not eat the products distributed at school: for 66% of the 3 306 families 
having  answered  to  the  question  in  the  case  of  F&V;  for  52%  of  the  2  914  families  having  answered  to  the 
question for milk/milk products. 
116 In Italy for all products; in Spain for fresh fruit; in Czech Republic, Netherlands and Spain for processed F&V; 
in Czech Republic, Germany, Poland, Spain for milk; in Czech Republic for milk with added sugar or flavouring; 
in Czech Republic and Spain for yoghurt with no added sugar, fruit, nuts, flavours; in Czech Republic for yoghurt 
with added sugar, fruit, nuts, flavours; in Spain for cheese. Conversely, in some MS the net effects are near to 
zero  (fresh  fruits  in  Lithuania;  processed  F&V  in  Poland  and  Romania;  yoghurt  with  added  sugar,  fruit,  nuts, 
flavours in Germany and Lithuania; cheese in Portugal) or even negative (milk in Lithuania and Romania; cheese 
in Netherlands). 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

4.1.2  ESQ2 - To what extent has the EU school scheme contributed to healthy 

eating habits?  

4.1.2.1  Background and methodological approach  

Understanding 

The ESQ 2 is closely linked to ESQ1 and addresses the second objective of the EU school 
scheme  related  to  the  promotion  of  children’s  healthy  eating  habits  and  the  shaping  of 
healthier diets. 

Nutrition education is a critical component in the development of healthy eating practices 
and  behaviours.  The  results  of  several  studies117  show  that  the  combination  of  nutrition 
education  with  additional  provision  of  products  might  be  significantly  beneficial  in 
improving dietary habits, daily nutrient intake, body composition, and quality of life. 

Therefore,  the  question  asks  to  assess  if  and  to  what  extent  the  notions118  learned  by 
children participating to the EU school scheme (in particular with accompanying educational 
measures) generate a virtuous process that, through the change of attitude and behaviour 
towards  the  distributed  products,  are  translated  into  an  improvement  of  children’s 
consumption habits, according to the following process: 

learning of 
notions

change in 
attitude

change in 
consumption 
behaviour

healthier 

eating habits 

Therefore, the evaluation question investigates the following aspects: 

  pupils’ learning level of the notions and recommendations related to the link between 
health and the consumption of the products distributed through the EU scheme (mainly 
but not exclusively related to the prevention of obesity and overweight); 

  how the notions learned by children have influenced their attitude and (consequently) 
their behaviour towards the consumption of the products distributed with the EU school 
scheme:  in  particular,  whether  and  to  what  extent  the  scheme  contributed  to  the 
transfer of the notions learned into: 

-  a  positive  attitude  towards  the  products  distributed  with  the  EU  school 
scheme such as to generate a demand of the products within the family (i.e., 
if children eat the products more willingly and ask for it outside the school); 

-  a  coherent  and  subsequent  behaviour  in  the  daily  consumption  of  the 
products distributed with the EU school scheme, not only in terms of quantity 
consumed  at  school  (see  ESQ1),  but  also  in  terms  of  consumption  habits 
(frequency  of  consumption  of  fruit  and  vegetables  and/or  of  milk/milk 
products per day, etc.); 

 

if and to what extent the changes in behaviour 119 resulted in a change of children’s 
consumption  patterns  into  healthy  eating  habits:  in  particular,  if  quantities  and 
consumption patterns of the products distributed in schools resulted in a corresponding 

117 Murimi M.W., Moyeda-Carabaza A.F., Nguyen B., Saha S., Amin R., Njike V., Factors that contribute to effective 
nutrition education interventions in children: a systematic review, Nutrition Reviews, 2018.  
Murimi M.W., Kanyi M., Mupfudze T., Amin R., Mbogori T., Aldubayan K., Factors Influencing Efficacy of Nutrition 
Education Interventions: A Systematic Review, Journal of Nutrition Education and Behavior, 2017. 
118 i.e.: fruits and vegetables and milk and milk products are healthy; importance of eating fruits and vegetables 
daily; importance of drinking milk and/or eating milk products regularly; variety of fruits and vegetables, milk 
and  milk  products,  and  other  agricultural  products;  learn  about  organic  farming;  eat  seasonal  fruits  and 
vegetables. 
119  The  child  asks  to  eat/drink  outside  the  school  the  products  distributed  with  the  EU  school  scheme  and/or 
eats/drinks the products more willingly. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

reduction of the consumption of products that are harmful to health (specially energy 
dense, processed foods with added/free sugars, fat, saturated fat and sodium). 

Dealing mainly with educational and behavioural aspects, ESQ2 asks to focus on the role 
played by the EU  school scheme (namely through accompanying educational measures) 
directly on children and indirectly on their families. The level of family’s awareness about 
the  scheme  and  the  degree  to  which  children  share  the  notions/knowledge  learned  at 
school within the family is crucial to translate notions/knowledge into changes in attitude 
and  behaviour,  and  hence  into  changes  in  children's  consumption  patterns.  In  fact, 
regarding consumption at home, such changes are closely linked to the family purchasing 
decisions. 

Finally, healthy eating habits are part of a broader  context of "good health", but not an 
exhaustive part. Hence, although not directly required by the evaluation question, it seems 
appropriate to investigate whether the results concerning children's healthy eating habits 
are also accompanied by habits related to physical activity: i.e., the existence of the latter 
is an indicator of a broader (family) focus on good health (of children). 

Definition of key terms 

Healthy eating habits – According to the WHO “a healthy diet helps to protect against 
malnutrition in all its forms, as well as non-communicable diseases (NCDs). Therefore, 
healthy dietary practices start early in life and may have longer term health benefits”. 
Moreover,  the  FAO  Committee  on  World  Food  Security states  that  “healthy  diets  are 
those  diets  that  are  of  adequate  quantity  and  quality  to  achieve  optimal  growth  and 
development of all individuals and support functioning and physical, mental and social 
wellbeing at all life stages and physiological needs”. (see 2.1.2 for more details) 

Learning of notions - are the set of notions learned by children at school through the 
activities foreseen in the regulatory framework of the EU school scheme: distribution of 
products and accompanying educational measures linked directly and/or indirectly to the 
objective of promotion of children’s healthy eating habits and the shaping of healthier 
diets. 

Attitude (positive) - is defined as the (positive) psychological disposition of children to 
produce emotional responses that are consistent with the cognitive aspects induced by 
educational actions (knowledge enhancement), and that influence their behaviour. 

Behaviour - way of acting that is coherent and consequential to the change in attitude. 

Consumption patterns - are long-term consumption habits, with those desirable giving 
priority to the consumption of the products distributed in schools with the EU scheme 
rather  than  products  that  are  harmful  to  health  (e.g.,  energy  dense,  processed  foods 
with added/free sugars, trans-fatty acids, high in saturated fat and sodium). 

45 

 
 
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

Judgement criteria, indicators and sources 

In order to reply to the evaluation question, our judgement is based on the following criteria 
and indicators.  

Judgement criteria 

Indicators 

Sources 

JC2.1: Over time, the number of 
children  involved  in  educational 
measures 
not) 
increased 

(has 

has 

JC2.2:  Parents  of 
children 
participating  to  the  EU  school 
scheme  are  (are  not)  informed 
and aware about the purposes of 
the scheme 

their 

JC2.3:  Children  participating  to 
the  EU  school  scheme  have 
(have not) improved and shared 
with 
their 
knowledge about healthy eating 
habits  and  the  importance  of 
consuming 
and 
vegetables,  milk  and  milk 
products 

parents 

fruits 

JC2.4:  The  EU  school  scheme 
has  (has  not)  contributed  to 
increase  the  quantity  and  the 
children’s 
of 
frequency 
consumption 
and 
of 
vegetables,  milk  and  milk 
products 

fruit 

JC2.5:  Children  participating  to 
the  EU  school  scheme  have 
(have  not)  decreased 
their 
foods/drinks 
consumption  of 
with high content in fat, sodium 
and added sugar 

JC2.6: Healthy eating habits are 
(are  not)  accompanied  by 
activities 
to 
children's well-being and health 

that  contribute 

2.1.1  Change  2017/2018-2020/2021  in  the  No 
of  children  involved  in  the  different  types  of 
educational measures  
2.1.2  Evolution  of  the  ratio  No  of  children 
involved  in  the  different  types  of  educational 
measures/ No of children participating in the EU 
school scheme (2017/18-2020/21) 
2.1.3 % families stating that their child has been 
involved  in  educational  activities  under  the  EU 
school scheme 
2.1.4  Themes  of  the  educational  measures  per 
MS per year 
2.2.1%  of  families  stating  to  have  received 
information  about  the  EU  school  scheme,  to 
know  what  it  is  about  and  to  know  the  main 
purposes. 
2.2.2%  of  families  stating  to  know  that  the 
programme  to  which  the  child  participates  is 
supported by the EU school scheme 

2.3.1  %  of  families  stating  that  their  children 
participating  to  the  scheme  have  learned  rules 
concerning healthy eating habits  
2.3.2  %  of  families  stating  that  their  children 
participating to the scheme ask that the healthy 
eating rules learned through the school scheme 
are also adopted at home 
2.3.3  Main  determinants  of  success  of  the  EU 
school scheme in relation to increasing children’s 
awareness/ knowledge on healthy eating habits 
and on food products origin and agriculture  
2.4.1  %  of  families  of  children  participating  to 
the  EU  school  scheme  stating  that  the  child 
changed its attitudes and behaviour towards the 
consumption  of  fruit  and  vegetables,  milk  and 
milk products  
2.4.2  %  of  families  of  children  participating  to 
the EU school scheme stating an increase of the 
child’s consumption of fruit and vegetables, milk 
and milk products outside the school  
2.4.3  %  of  families  of  children  participating  to 
the EU school scheme stating an increase of the 
child’s  frequency  of  consumption  outside  the 
school  of  fruit  and  vegetables,  milk  and  milk 
products  
2.4.4 Current frequency of consumption of fruit 
and  vegetables,  milk  and  milk  products  of 
children  
2.5.1  %  of  families  stating  that  their  children 
have  decreased/maintained/increased 
their 
consumption  of  fast  food,  soft  drinks,  other 
snacks high in fat, sodium and added sugar  

-  EU 

school 

scheme 
data 
2018/19; 

monitoring 
2017/18; 
2019/20; 2020/21 

-  Family  survey  in  CS 

countries 

-  Family  survey  in  CS 

countries  

-  Findings 

literature review 

from 

-  Family  survey  in  CS 

countries  

-  Findings 

from 

literature review 

-  Structured  interviews 
CS 

in 
countries/regions 

-  Family  survey  in  CS 

countries 

-  Family  survey  in  CS 

countries  

2.6.1 % of families stating that their children do 
physical activities.  

-  Family  survey  in  CS 

countries  

46 

 
 
 
 
 
 
 
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

Methodological approach and its limitations 

Tools, method and sources used 

The methodology is based on three main steps of analysis and uses various tools: 

 

 

 

the first step focuses on the educational measures implemented by schools under the 
EU  scheme  and  on  the  coverage  degree  of  these  measures  relative  to  children 
participating in the EU school scheme. This part (completing the quantitative analysis 
already carried out in ESQ1) is based on the EU school scheme monitoring data; 
the second step is based on the results of the family survey carried out in 10 case study 
MS and focuses on the aspects related to the notions learned through the educational 
measures of the school scheme, on their knowledge by families and on the changes of 
attitude/behaviour and of children’s consumption patterns. The analysis is completed 
with  information  gathered  in  the  case  studies  MS,  through  structured  interviews  to 
relevant  stakeholders,  on  the  EU  school  scheme  success  determinants  regarding 
children’s awareness/knowledge of healthy eating habits; 
the third step investigates whether the compliance with healthy eating habits is also 
accompanied by a virtuous change of habits (reduction of the consumption of products 
that are harmful to health) and by sport activities that contribute to the overall children 
well-being and health. This analysis is also based on the results of the family survey.  

The analysis is complemented with findings from relevant scientific research, recent official 
reports, academic papers and studies addressing the subjects. 

As in ESQ1, the effects of the EU school scheme on knowledge, behaviour, and change in 
consumption patterns, based on the family survey, are identified through a counterfactual 
approach.  

Limitations of methods and sources 

When reading the results of the analysis some limitations should be considered. 

Concerning accompanying educational measures, in some MS (Belgium, Czechia, Ireland, 
Spain,  Italy,  Hungary)  and  for  some  types  of  measures,  monitoring  data  include  also 
educational  measures  funded  with  national  resources.  In  these  cases,  the  number  of 
children  involved  is  higher  than  the  number  of  children  participating  in  the  EU  school 
scheme as it may include double or multiple counting of children across the different types 
of  activities.  In  addition,  in  MS  that  implement  two  or  more  measures,  these  measures 
often involved the same children. Therefore, the share of children involved in educational 
measures on the total number of children participating in the EU school scheme has been 
calculated for each measure and not overall.  

Concerning the family survey, it is important to bear in mind that: 

 

the results are qualitative and based on the degree of awareness existing within the 
families. The use of a  survey addressed to  children's families rather than to children 
themselves  represents  a  limitation  because  the  information  obtained  does  not  stem 
directly from the parties (children) involved in the EU school scheme. This choice is, 
however,  linked  to  the  existence  of  legal  constraints  concerning  the  protection  of 
minors. Conversely, addressing the survey to families has also advantages such as the 
possibility of receiving answers from (adults) persons: 

-  directly  interested  in  their  children's  education,  in  general  and  from  the 

nutritional point of view;  

-  directly  concerned  by  the  purchasing  decisions  of  food  products,  and 
therefore  with  a  direct  and  more  precise  knowledge  of  any  changes  in 
children's  diet.  It  is  also  important  to  bear  in  mind  that  any  change  in 

47 

Evaluation support study of the EU school fruit, vegetables and milk scheme 

children's  eating  habits  is  not  spontaneous,  but  mediated  by  parents’ 
decisions. 

 

 

it has been asked to the families of the target group to indicate any  change in their 
children’s consumption and behaviour as a result of the participation in the EU scheme 
compared to the period before the participation. To the families of the control group, it 
was  asked  if  any  change  occurred  during  the  last  year.  In  case  of  children  that 
participated  in  the  scheme  for  more  than  one  year  the  change  stated  by  the  family 
could be the overall effect of the participation; 
the results by age group have to be taken with caution since among the 10 MS in which 
the family survey was carried out, only 3 MS (and in Germany, 9 out of 14 strategies) 
targeted secondary schools (15-18 years old). In the remaining MS a high presence of 
children in the age class 15-18 years old could be due to the difference between the 
age of the children at the time of the survey and the age of the children at the time of 
the participation in the scheme (the questionnaire asked for the age of the children at 
the time of the survey). 

Finally,  Portugal  family  survey  results  should  be  considered  with  caution,  as  there  is  an 
overlap between EU and national activities (national milk scheme). Furthermore, it should 
be  noted  that:  in  Sweden,  the  fruit  and  vegetable’s  part  the  EU  scheme  has  not  been 
implemented and so the sample of the target  group is  smaller; in Germany 2  of the  14 
German school schemes strategies120 have implemented only the milk part of the scheme, 
and 1 Federal State only the F&V part. 

4.1.2.2  Analysis 

Judgement  criterion  2.1:  Over  time,  the  number  of  children  involved  in 
educational measures has (has not) increased 

The analysis of the EU school scheme monitoring data, shows that in the period 2017/18-
2020/21, all MS have implemented one or more educational measures (see table below). 
Furthermore, the analysis shows that the highest share of children involved in each EAM 
on the total number of children participating in the scheme has been reached by tasting 
classes, cooking workshops in 2018/2019 (47.6%).  Indeed,  some educational measures 
are  less  implemented  than  others,  in  particular  "school  gardens"  and  "visits  to  farms, 
dairies, farmers' markets and similar activities". 

Table 2: Evolution of the share of children involved in the different types of educational 
measures on the total number of children participating in the EU school scheme 
 (EU-27121, 2017/18-2020/21, %) 

Type of measure 

School gardens 
Visits to farms, dairies, famers' markets and similar activities 
Tasting classes, cooking workshop 
Lessons, lectures, workshops 
Other activities: competitions, games, themed periods, other 

2017/
2018 
5.6 
6.2 
34.3 
37.7 
36.0 

2018/ 
2019 
8.4 
7.8 
47.6 
41.5 
34.2 

2019/ 
2020 
8.0 
7.0 
35.1 
36.2 
33.4 

2020/
2021 
7.6 
7.3 
30.3 
33.9 
38.2 

Source: EU School Scheme monitoring data 

However, the scenario is quite diversified both at MS level and over time for each MS. In 
particular  regarding  the  two  last  schoolyears  (2019/2020  -  2020/2021),  the  level  of 
implementation of the  different types  of measures is the  result not only of MS strategic 

120 Hamburg does not participate to the EU School Scheme and Berlin and Brandenburg have a joint scheme. 
121 Excluding United Kingdom. In some MS and for some types of measures the ratio is >100 (Belgium, Czechia, 
Ireland, Spain, Italy, Hungary). Thus, the EU-27 total is slightly overestimated. 

48 

                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

choices, but also of restrictions resulting from the different national approaches to manage 
the COVID-19 pandemic.  

In addition, the results of the family survey highlight that not all the children have been 
involved  in  educational  measures:  in  general,  only  68%  of  the  families  with  children 
participating  in  the  EU  school  scheme  declares  that  their  child  participated  in  these 
activities, with a minimum in Sweden (59%) and a maximum in Spain (84%)122. 

Concerning the themes of the accompanying educational measures, according to the EU 
scheme monitoring data, we can observe that the theme "healthy eating habits" (the one 
that  should  have  the  strongest  influence  on  the  virtuous  pathway  leading  to  change  in 
eating  habits)  was  addressed  by  more  than  95%  of  the  MS  having  implemented  the 
educational  measures  (average  2017/18-2020/21).  Moreover,  the  theme  “organic”  was 
addressed by around 57% of MS and the theme “sustainable production” by slightly less 
than 50% of MS (the latter is however, the theme showing the highest increase in the last 
year). 

Table 3: % of MS implementing the different themes of the accompanying educational 
measures 2017/18-2020/21 

Reconnection of children to agriculture 
Healthy eating habits 
Local food chains 
Organic 
Sustainable production 
Food waste 
Other 

2017/18  2018/19  2019/20  2020/21 

100.0 
91.3 
60.9 
56.5 
47.8 
69.6 
8.7 

92.3 
96.2 
65.4 
57.7 
42.3 
69.2 
23.1 

96.2 
96.2 
57.7 
53.8 
46.2 
65.4 
34.6 

100.0 
95.8 
66.7 
58.3 
58.3 
70.8 
33.3 

Source: EU School Scheme monitoring data 

Judgement  criterion  2.2:  Parents  of  children  participating  to  the  EU  school 
scheme are (are not) informed and aware about the purposes of the scheme 

The answer to this judgement criterion is based on the  results of the family survey. The 
level  of  information  and  awareness  of  the  family  is  an  important  aspect,  as  the  notions 
learned by pupils at school can find a favourable ground within the family concerning habits 
and levels of indirect consumption (at home). This is confirmed by scientific literature: a 
recent systematic review of fruit and vegetables distribution interventions in school-based 
settings  (Ismail  et  al.,  2021)  indicated  parental  engagement  as  one  of  the  aspects  that 
contribute  to  the  success  of  distribution  interventions.  The  review  confirms  that  family 
involvement ensures availability and accessibility of fruits and vegetables at home which 
is  associated  with  increased  children’s  consumption  of  the  products.  Literature  also 
confirms  that  inadequate  awareness  is  a  challenge  to  distribution  intervention’s 
implementation (Jamelske and Bica, 2014(123), Bai et al., 2011(124)). 

The results of the family survey show that: 

  about  83%  of  the  families  know  that  the  programme  is  supported  by  the  EU  school 

scheme, with a minimum in Sweden (73%) and a maximum in Czechia (92%); 

122 However, in general, about 21% declares that they were not involved and 12% that they do not know. The 
lower  %  compared  to  the  monitoring  data  is  explained  by  the  fact  that  in  this  case  it  is  the  total  number  of 
children involved, and not the number of children per measure (as already mentioned, a child can be involved in 
more than one measure). 
123  Jamelske  E.,  Bica  L.,  The  USDA  Fresh  Fruit  and  Vegetable  Program:  A  case  study  of  implementation  and 
consumption in Wisconsin, Journal of Child Nutrition & Management, v38 n2 Fall 2014. 
124 Bai Y., Feldman C., Wunderlich S.M., Aletras S., Process evaluation of the Fresh Fruit and Vegetable Program 
implementation in a New Jersey elementary school, Journal of the American Dietetic Association, 2011 Vol. 111; 
Iss. 9-supp-S. 

49 

 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

  about 76% of the families have received information about the EU school scheme, know 
what  it  is  about  and  its  main  purposes,  with  a  minimum  in  Romania  (66%)  and  a 
maximum in Spain (84%); 
in  all  MS  the  percentage  of  families  knowing  that  the  scheme  is  financed  by  the  EU 
(first  aspect)  is  higher  than  the  percentage  of  families  having  received  information 
about the scheme (second aspect). 

 

Figure 15: Families having received information about the EU scheme and families who 
know that the program is funded by the EU: total and case studies MS (%) 

Source: Family survey in CS countries 

Despite the good level of awareness, a certain degree of lack of knowledge related to the 
contents  of  the  school  scheme  remains  for  a  limited  percentage  of  families  who  are, 
however, aware that the scheme is funded by the EU. 

Judgement criterion 2.3: Children participating to the EU school scheme have 
(have  not)  improved  and  shared  with  their  parents  their  knowledge  about 
healthy eating habits and the importance of consuming fruit and vegetables, 
milk and milk products  

Lessons learned at school 

The  results  of  the  family  survey  concerning  the  children’s  learning  of  notions  in  the 
framework  of  the  scheme  are  very  positive.  In  particular,  according  to  the  families  the 
lessons  “fruit  and  vegetables  are  healthy”,  “importance  of  eating  fruit  and  vegetables 
daily”, “milk and milk products are healthy” have been learned (and families are aware of 
this)  by  more  than  80%  of  the  children125.  Moreover,  all  the  other  lessons  (see  figure 
below)  exceed  70%  of  the  children,  with  the  sole  exception  of  "about  organic  farming" 
(62%)126. It is also remarkable that percentages above 70% are reached for all lessons in 
most MS, again with the exception of "about organic farming" in all MS (except Spain) and 
"discovered a wider range of milk and milk products and other agricultural products" in six 
MS127. 

125 In particular, “fruit and vegetables are healthy” by more than 90% of the children in Portugal, Romania, Spain, 
Italy and the “importance of eating fruits and vegetables daily” by more than 90% in Portugal and Spain.  
126 The result concerning organic farming is consistent with the fact that this theme was addressed in educational 
measures by about 57% of MS. (see 4.2.1). 
127 Czechia, Italy, Lithuania, Netherlands, Poland, Sweden. 

50 

CZDEITLTNLPLPTROESSETotal65%70%75%80%85%90%95%100%65%70%75%80%85%90%95%100%% of families having received information % families who know that the program is supported by the EU school scheme 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

Figure 16: Lessons learned at school by children participating in the EU school scheme (% 
of families) 

Source: Family survey in CS countries 

The results of the survey show also that the implementation of the EU school scheme has 
contributed to children discovering a wider range of products (overall, 74% for F&V and 
70% for milk and milk products), and, thus, it has probably contributed to a more varied 
diet.  In  fact,  the  variety  of  the  products  distributed  under  the  current  EU  scheme  has 
increased  compared  to  the  previous  EU  schemes,  although  the  number  of  products 
distributed during the current EU school scheme has, overall, decreased over the  three-
year implementation period: see ESQ1.  

The results based on families’ answers, however, show higher learning success in some MS 
(Spain, Portugal, Romania) and lower in others (Sweden and Lithuania). 

Adoption at home of the lessons learned at school 

The  family  survey  also  investigated  whether  the  children  participating  in  the  EU  school 
scheme ask that the healthy eating rules learned at school are also adopted at home. It 
should be highlighted that sharing the lessons learned with the families is an indicator of 
the probability that the effects  on children's behaviour are also reflected in other  family 
members. Evidence in the literature points to the role of the family as a secondary target 
group  (Meshkovska  et  al.,  2022)  which  can  potentially  improve  its  own  eating  practices 
and those of the family as a whole (Chen Q et al., 2014(128)). Other studies indicate that 
distribution  programs  extended  their  benefits  to  parents  by  potentially  improving  the 
products  consumption,  by  influencing  purchasing  practices  and  by  reinforcing  healthy 
dietary messages at home (Ismail et al., 2021). 

In general, only 46% of the surveyed families stated that the healthy eating rules learned 
by their child at school are also adopted at home, with higher values in Germany (56%), 
Spain (55%) and Romania (50%), and lower values in Lithuania (35%) and Italy (38%). 
However, a proportion of respondents (37%) stated that the lessons learned were already 
part of the family’s cultural background (were already adopted at home before). Thus, in 
these cases, the scheme may have contributed to underpin already embedded behaviours 
within families. Scientific studies reveal that parents play a direct role in children’s eating 

128  Chen  Q,  Goto  K,  Wolff  C,  Bianco-Simeral  S,  Gruneisen  K,  Gray  K.,  Cooking  up  diversity.  Impact  of  a 
multicomponent, multicultural, experiential intervention on food and cooking behaviors among elementary school 
students from low-income ethnically diverse families. 2014, Appetite. 

51 

0%10%20%30%40%50%60%70%80%90%Fruits and vegetables  arehealthyImportance of eating fruitsand vegetables dailyDiscovered a wider range offruits and vegetables andother agricultural productsEating more seasonal fruitsand vegetablesMilk and milk products arehealthyImportance of drinking milkand/or eating milk productsregularlyDiscovered a wider range ofmilk and milk products andother agricultural productsAbout organic farming 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

patterns  through  their  behaviours,  attitudes  and  that  their  knowledge  affects  the 
availability and accessibility of the products at home (Patrick and Nicklas, 2005(129)). Other  
researches  (Rasmussen  et  al.,  2006(130), Ovrum  and  Bere,  2014(131)),  pointed  out  that 
children’s consumption at home is positively associated with their parents’ consumption. 

Main  determinants  of  success  of  the  EU  scheme  in  relation  to  increasing  children's 
awareness/knowledge of healthy eating habits, food origin and agriculture 

The analysis of the opinions gathered through the interviews in the case study MS allowed 
to  identify  the  main  determinants  of  success  of  the  EU  school  scheme  in  relation  to  1) 
increasing children's awareness/knowledge of healthy eating habits and 2) food origin and 
agriculture. 

Accompanying  educational  measures,  in  particular  practical  activities  (i.e.,  games  and 
competitions, school gardens, hands-on activities, videos, teaching materials, etc.) are the 
key  tool  used  in  almost  all  MS132  (Czechia,  France,  DE-Bavaria,  Italy,  Lithuania, 
Netherlands,  Poland,  Portugal,  Spain)  for  increasing  children’s  awareness  concerning 
healthy  eating  habits133.  Additionally,  the  active  involvement  of  teachers134  (Czechia, 
France, DE-Bavaria, Lithuania, Netherlands, Poland, Portugal) and/or the use of targeted 
interventions  of  external  influencers/nutritionists  (Italy,  Lithuania)  is  also  considered  a 
success factor. Other success factors are the presence of emulation effects among pupils 
(Italy,  Poland,  Spain)  and  the  dissemination  of  educational  material  among  children’s 
parents (Italy, Portugal). 

However, some elements of criticism emerged from the interviews. For some interviewees, 
educational  measures  are  not  effective  enough  and  should  be  strengthened  and/or 
replaced/complemented  by  more  manual  activities135  (France,  Romania).  Moreover, 
distributed  materials  are  indicated  as  being  insufficiently  informative  and  not  very 
attractive to children (Portugal). For others, nutrition education is already part of the school 
curriculum,  and  therefore  the  EU  school  scheme  does  not  provide  much  added  value 
(Sweden)136. 

Concerning  the  second  topic,  the  key  tool  remains  the  accompanying  educational 
measures,  in  this  case  articulated  in  the  various  initiatives  (visits  to  farms,  visits  to 
specialised research centres, visits to factories, markets; handy activities, etc.), also with 
the  interventions  of  experts  (Czechia,  France,  DE-North  Rhine  Westphalia,  DE-Bavaria, 
Italy,  Lithuania,  Netherlands,  Poland,  Portugal,  Spain)137  and  possibly  complemented  by 
an active involvement  of teachers (Lithuania, Netherlands, Portugal) and/or  suppliers  of 

129 Patrick H., Nicklas T., A review of family and social determinants of children’s eating patterns and diet quality, 
J Am Coll Nutr. 2005 Apr; 24(2):83-92. 
130 Rasmussen  M.,   Krolner R.,  Klepp  K.I.,   Lytle  L.,  Brug  J.,  Bere  E., et  al., 2006.  Determinants  of fruit  and 
vegetable consumption among children and adolescents: a review of the literature. Part I: Quantitative studies. 
131  Ovrum  A.,  Bere  E.,  Evaluating  free  school  fruit:  results  from  a  natural  experiment  in  Norway  with 
representative data. 2013, Public Health Nutrition, 17(06):1-8. 
132 According to some interviewees (in Italy), games, competitions and practical workshops definitely work 
better than lessons that teach children what to do and what to eat. 
133 Trainings, workshops, materials provided as well as support staff for implementation of the intervention in the 
school setting are considered important facilitators (Meshkovska et al., 2022). 
134 To this regard, an additional helpful element could be the implementation of training courses and seminars to 
improve teachers’ skills/involvement (Lithuania). 
135  However,  this  criticism  seems  to  be  more  related  to  the  implementation  methods  chosen  at  national  level 
rather than to the instrument as such. 
136 An element of criticism found in the literature concerns the fact that there are no minimal standards set for 
the design or implementation of the educational measures: even if flexibility is positive some guidance would be 
needed as the quality of design and implementation of the educational measures greatly differs even within the 
same country (Meshkovska et al., 2022). 
137 Obviously, in the last period visits were limited due to the Covid-19 pandemic. 

52 

                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

products  (DE-North  Rhine  Westphalia,  DE-Bavaria).  The  importance  of  teacher’s 
engagement  is  confirmed  by  the  scientific  literature  that  identifies  teachers  as  opinion 
leaders and important facilitators (Carbone et al., 2016(138), Bouck MS et al., 2011(139)). 

Judgement criterion 2.4: The EU school scheme has (has not) contributed to 
increase the quantity and the frequency of children’s consumption of fruit and 
vegetables, milk and milk products 

The analysis, based on the results of the family survey, comprises two parts: the first one 
investigates  the  role  of  the  EU  school  scheme  (distribution  of  products  at  school  and 
educational measures) on children’s change in attitude towards the consumption of fruit 
and  vegetables,  milk  and  milk  products;  and  the  second  part  investigates  whether  this 
change  influenced  the  consumption  behaviour,  expressed  in  terms  of  frequency  and 
quantity consumed140 .  

Children’s change in attitudes  

The  families  of  the  target  group  participating  in  the  survey  have  been  questioned  on 
whether their children ask to eat/drink the selected products at home more than before 
the participation in the scheme and if children eat the products more willingly than before. 
The same question has been asked to the families of the control group relative to the last 
year. 

The role played by the scheme is given by the difference between the results obtained for 
the target group and the results of the control group. In general, the analysis highlights 
that the majority of children of both groups (well over 50%) did not change their attitude 
towards fruits, vegetables, milk and milk products, and a minority (but not insignificant) 
show a worsening of their attitude (particularly towards vegetables). These overall results 
can  be  observed,  roughly  to  the  same  extent,  in  all  MS  (with  the  exception  of  Czechia, 
where  the  percentage  of  children  not  changing  their  attitude  of  the  target  group  is  less 
than 50% for all products). 

Moreover,  according  to  the  answers  provided  by  the  families  surveyed  a  significant 
proportion of children of the target group asks more and eats more willingly the products 
in comparison to the period before the participation to the school scheme (comprised in 
range  between  24%  and  36%  depending  on  the  products  and  on  the  two  considered 
aspects).  The most noticeable improvements concern fruit (36% eats  willingly and 33% 
asks), and the least important concern vegetables (28% eats willingly and 24% asks). Milk 
and milk products are in an intermediate situation (30% eats willingly and 29% asks). The 
differences with the control group141 and, thus, the sizes of the net effect are all positive 
for both aspects, but slightly higher for "eats more willingly" (max 11.3 percentage points 
and min 9.2 percentage points) than for "asks more" (max 9.9 percentage points and min 
9.1 percentage points). Furthermore, the net effects are higher for fruit142 and vegetables 
relative to milk and milk products.  

On the contrary, the % of children asking less than before and or eating less willingly than 
before is higher in the control group than in the target group for all product categories. 

138 Carbone ET., DiFulvio GT., Susi T., Nelson-Peterman J., Lowbridge-Sisley J., Collins J., Evaluation of an urban 
farm-to-preschool and families program. Int Q Community Health Educ. 2016 Apr; 36(3):177-87. 
139 Bouck M.S., St Onge R., He M, Beynon C., Lemieux S., Khoshaba L., Stewart S., Northern fruit and vegetable 
pilot program: a process evaluation. Can J Diet Pract Res. 2011 Spring; 72(1):14-22. 
140 Consumption changes in terms of quantity have already been addressed in ESQ1. 
141 Families of the control group were asked to indicate whether there has been any change over the last year.   
142  For  fruits,  the  net  effect  is  11.3  percentage  points  for  “eats  willingly”  and  9.9  point  for  “asks  more”;  for 
vegetables is 10.2 points and 9.7 points; for milk & milk products is 9.2 and 9.1 points. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

Hence, children's participation in the EU school scheme should have had a double effect:  
  generating  an improvement  in  children’s  attitude  towards  the  products  (children  ask 

 

more and eat more willingly than before); 
curbing  the  decrease  of  children’s  attitude  towards  the  products  that  would  have 
in  the  EU  school  scheme  (and  thus 
occurred 
maintaining/consolidating the attitude). 

in  absence  of  participation 

The analysis by age143 show that the age group 6-10 years old is the one for which the 
percentage of families stating non change, for both aspects (asks to eat and eats willingly), 
relative to the period before participation to the EU school scheme, is the highest (it varies 
from 61% for eats willingly fruits to 69 % for asks to eat vegetables).  

The effect of the scheme is positive in all age groups. However, with some differences, the 
results obtained show that the size of the effect increases as the  children age increases 
(i.e.,  the  effect  is  lower  in  age  group  0-5  years  old  and  higher  in  age  group  15-18). 
Therefore, it could be deduced that the ability to translate lessons learned into coherent 
changes in attitude could be also linked to the level of "maturity" of the children. 

Table 4:  Effect by age group related to children that ask to eat/eat more willingly than 
before the participation to the scheme the different products (percentage points) 

The child asks to eat… 

The child eats willingly… 

15-18  11-14  6-10 

0-5 

15-18  11-14  6-10  0-5 

Fruits 
Vegetables 
Milk and milk products 

18.7 
13.6 
12.3 

14.8 
12.3 
15.4 

11.4 
9.1 
11.4 

9.2 
9.0 
3.2 

19.0 
14.6 
13.1 

16.1 
11.5 
12.5 

12.9 
13.4 
12.5 

6.1 
7.7 
5.6 

Source: Family survey in CS countries 

The analysis also  shows that the percentage  of families of the target  group  stating that 
their  children  did  not  change  their  attitude  compared  to  before  the  participation  in  the 
scheme is lower in families with a lower level of educational qualification (“no qualification”) 
and it progressively increases in families with a higher level of qualification. 

Concerning children “asking more” than before or “eating more willingly” than before, the 
differences between the target group and the control group are positive for all educational 
qualification levels of the families (for both aspects and all product categories): 

 

 

in the case of milk and milk products the highest net effects are registered in families 
with  the  lowest  levels  of  educational  qualification  (no  qualification  and  primary 
education, more than 10 percentage points for both aspects); 
in the case of fruit and vegetables, the results are less clear-cut: regarding 'asks for 
more' the higher net effects of the scheme are observed in the families with the lowest 
level of qualification (no qualification), but also in the families with the highest level of 
qualification (tertiary education); regarding 'eats more willingly' the highest effects are 
observed in families with the highest level of qualification, but not in the families with 
the lowest educational qualification. 

On the contrary, the results do not show significant differences according to the place of 
living of the families. 

Finally, as shown in the figures below, there is a strong correlation (in particular for fruits 
and milk/milk products, less for vegetables) between the two aspects: the increase of “asks 
to eat/drink” in comparison to the period before the distribution of the products at school, 
is quite consistent with the increase of “eats willingly”144.  

143 Regarding the results of the survey by age group, limitations described in § 4.1.3 must be taken into account. 
144 For F&V an important exception is observed for families with a low level of educational qualification, where a 
large net effect concerning the aspect “ask more” corresponds to a much smaller net effect concerning the aspect 
“eats more willingly”. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

Figure 17: Net effects by MS: Relation between “eats willingly more than before” and 
“asks for the products more than before” (percentage points) 

Changes in the consumption behaviour of children 

Source: Family survey in CS countries 

In  order  to  verify  whether  the  changes  in  attitudes  influenced  the  indirect  consumption 
(out-of-school) of the products distributed with the EU school scheme, the percentage of 
families stating that their children changed their consumption, both in terms of quantity 
and frequency, was measured. Again, the role played by the EU school scheme is given by 
the difference between the results of the target group and those of the control group. 

Concerning the consumption in terms of quantity, the results presented in ESQ1, show that 
in general the EU school scheme had positive effects, even though extremely limited, on 
the indirect consumption (outside the school) of F&V products (results are higher for milk 
products). However, a limited number of MS show more positive results. 

With  regard  to  the  frequency  of  consumption,  the  results  are  similar:  in  general,  about 
60% of the families of the target group stated that, for all products analysed, the frequency 
of consumption has not changed after the participation in the EU school scheme.  

Moreover,  the  difference  between  the  share  of  the  families  of  the  target  group  and  the 
share  of  the  families  of  the  control  group  having  stated  an  increase  of  frequency  of 
consumption  of  the  concerned  products  is  just  over  8  percentage  points  for  milk  and 
flavoured  milk  and  lower  effects  for  cheese  and  fresh  vegetables,  between  5  and  6 
percentage points. Thus, the role played by the scheme is, in general, positive but limited 
and these results are in line with the net effect concerning the increase of the quantities 
consumed. 

55 

CZDEITLTNLPLPTROESTotaly = 1.1305x -0.023R² = 0.621100%05%10%15%20%00%05%10%15%20%The child asks to eat/drink productsThe child eats willinglyFruitsCZDEITLTNLPLPTROESTotaly = 0.4556x + 0.0501R² = 0.270200%05%10%15%20%00%05%10%15%20%The child asks to eat/drink productsThe child eats willinglyVegetablesCZDELTNLPLPTROESSETotaly = 1.114x -0.0099R² = 0.866500%05%10%15%20%00%05%10%15%20%The child asks to eat/drink productsThe child eats willinglyMilk & milk products 
 
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

Figure 18: Change in the frequency of children’s consumption outside school, after the 
participation in the EU school scheme (target group) and in the last year (control group) 

Source: own elaboration based on the family survey data 

In the case of the families stating a decrease of the frequency of consumption in general 
the  %  of  children  who  decreased  the  frequency  of  consumption  is  higher  in  the  control 
group  than  in  the  target  group.  This  result  is  in  line  with  the  net  effect  concerning  the 
decrease in quantity consumed.  

Therefore, the school scheme seems to have affected children behaviour with a two-fold 
effect on the consumption:   

  encouraging a (limited) increase in consumption in terms of quantity and frequency; 
 

limiting  the  decline  of  consumption  that  would  have  occurred  in  the  absence  of 
participation in the EU school scheme (and thus consolidating existing quantities and 
frequency levels). 

Furthermore, results by age groups145 suggest that the EU school scheme played the most 
important  role  (increased  quantities  and  frequency)  in  the  case  of  children  aged  15-18 
years old for all products of the F&V sector (between 13 and 16  percentage points). For 
milk  products,  the  effects  of  the  scheme  are  roughly  the  same  for  the  15-18  years  old 
group  and  the  11-14  years  old  group  (between  a  minimum  of  8  percentage  points  for 
cheese and a maximum of 13 points for milk and milk with added sugar or flavouring). On 
the  other  hand,  for  all  products  (with  the  sole  exception  of  milk  with  added  sugar  or 
flavouring),  the  scheme  seems  to  have  a  lower  effect  in  the  0-5  years  old  age  group 
(between a minimum of -6 percentage points for quantity of fresh fruits and a maximum 
of 8 points for quantity of yoghurt with no added sugar, fruit, nuts, flavours). 

The results by level of educational qualification of the families show that, in general (but 
with some exceptions)  the EU school scheme  had a higher effect (increase  of quantities 
and frequency of consumption) in families with a lower level of qualification, and mainly 
located in rural areas (and therefore among families that are, probably, the least aware). 
In these families, the increased awareness generated by the children's participation in the 
scheme (see 4.2.2) should also have generated a larger effect of the EU scheme also on 
children’s change of behaviour. 

145 The analysis by age group has to be taken with caution (see “Limitations of methods and sources”). 

56 

-10.0%0.0%10.0%20.0%30.0%40.0%50.0%60.0%70.0%HasdecreasedHasincreasedRemainedthe sameHasdecreasedHasincreasedRemainedthe sameHasdecreasedHasincreasedRemainedthe sameTARGET GROUPCONTROL GROUPDIFFERENCEFresh fruitsFresh vegetablesProcessed F&VMilkMilk with added sugar or flavouringYoghurt with no added sugar, fruit, nuts, flavoursYoghurt with added sugar, fruit, nuts, flavoursCheese 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

Indeed,  the  lowest  differences  between  the  target  group  and  the  control  group  are 
observed  (with  some  exceptions)  among  families  with  higher  levels  of  educational 
qualification  (upper  secondary  education  and  tertiary  education).  Presumably,  these 
families  are  more  aware  and  therefore  the  consumption  at  home  (in  quantity  and 
frequency) of the selected products was already relatively high (some studies confirm that 
one of the reasons why a proportion of children in disadvantaged areas would not receive 
fruits and vegetables is the lack of parent’s awareness, Ismail et al., 2021).  

The  results  also  show  a  positive  relationship  between  the  net  effects  of  the  scheme  on 
quantities and on frequency of consumption (see figure below)146. 

Figure 19: Differences between the target group and the control group of the increase % 
of quantity and frequency of consumption of the different categories of products (% 
points) 

Legend: FF - fresh fruits; FV - fresh vegetables; M –milk; PF&V - processed F&V; MF - milk with added sugar or 
flavouring; Y - yoghurt; YF - yoghurt with added sugar, fruit, nuts, flavours; c: cheese 

Source: Family survey in CS countries 

The analysis of the correlation between the two variables shows that: 

 

 

 

the percentage of families stating an increase of the quantities consumed is correlated 
with the percentage of families stating an increase in frequency.  It can therefore be 
deduced  that  the  (stated)  growth  in  consumption  is  largely  due  to  the  increase  in 
frequency (number of portions). This is in line with the daily recommended quantities; 
for fresh fruits, fresh vegetables, processed fruits and milk, the percentage of families 
stating  an  increase  of  quantities  consumed  is  lower  than  the  percentage  of  families 
stating an increase in frequency. It can therefore be deduced that the (stated) increase 
in  consumption  is  (mostly)  due  to  an  increased  frequency  of  consumption,  but  with 
smaller portions; 
for all products of the milk sector (with the exception of drinking milk), the percentage 
of  families  stating  an  increase  of  the  quantities  consumed  is  almost  equal  to  the 
percentage  of families  stating an increase in frequency.  It can therefore be deduced 
that the (stated) increase in consumption is (mainly) due to an increased frequency of 
consumption, with portions with quantities more or less constant147;  

The analysis of the changes in attitude and behaviour was concluded with the analysis of 
the frequency of the present consumption148 outside the school (i.e., the existing situation 
after the effects of the implementation of the scheme). 

146 The regression of the differences shows a R2 = 49,8%. 
147 This result is reasonable, since most milk products are delivered in single packages (yoghurt without and with 
additives). 
148 At the date of the survey (December 2021). 

57 

FFFVPF&VMMFYYFC3%4%5%6%7%8%9%3%4%5%6%7%8%9%QuantityFrequency 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

The share of children participating in the EU school scheme who consume the products at 
least once a day is very high for fruit (85%), vegetables (72,4%) and milk (74%), whereas 
it  appears  significantly  lower  for  the  other  products  (57%  for  processed  F&V;  50%  for 
cheese; 45% for  yoghurt; 39%  for flavoured  milk and flavoured yoghurt). On the  other 
hand, the share of children who never consume outside of the school is low for F&V and 
milk (between 1% and 4%), but higher for yoghurt and flavoured milk (between 12% and 
17%). Cheese is around 6%. 

The comparison with the control group provides an interesting picture: the differences are 
very small for fruit, vegetables and milk (comprised between 5 and 9 percentage points), 
whereas differences are higher for milk products (between 14 and 16 percentage points). 
Therefore,  it  seems  that  for  an  important  share  of  children,  the  EU  school  scheme 
stimulated the "regular" (at least once a day) consumption of the products that in absence 
of the  scheme would have continued not to be  consumed149. However,  the  effect of the 
scheme  on "core" products (fresh  fruit and vegetables, milk) is limited, since their daily 
consumption is already a generally consolidated behaviour. 

Figure 20: Differences between the target group and the control group of children 
consuming at least once a day and not consuming the analysed products (% points) 

Legend: FF - fresh fruits; FV - fresh vegetables; M –milk; PF&V - processed F&V; MF - milk with added sugar or 
flavouring; Y - yoghurt; YF - yoghurt with added sugar, fruit, nuts, flavours; c: cheese 

Source: Family survey in CS countries 

The  results  by  age  group  concerning  the  consumption  “at  least  daily”  show  that,  for  all 
products, the scheme has the highest effect in the case of children aged 15-18 years old 
(between a maximum of 23 percentage points for milk with added sugar or flavouring and 
a minimum of 11 points for milk and fresh fruits) and the lowest effect is recorded, for all 
products, in the 6-10 years old age group (between a maximum of 11 percentage points 
for cheese and a minimum of 2 points for fresh fruits). 

Concerning the analysis by level of educational qualification of the families, the effect of 
the EU school scheme on the consumption 'at least daily' is rather uneven: the role played 
by  the  scheme  is  more  important  in  families  with  lower  levels  of  qualification  (no 
educational qualification and/or primary education and/or lower secondary education) in 
the case of processed fruit and vegetables, milk with added sugar or flavouring, yoghurt 
with no added sugar, fruit, nuts, flavours, yoghurt with added sugar, fruit, nuts, flavours 
and cheese. On the contrary, in the case of milk, the scheme shows the lowest effect in 
the case of families with lower levels of educational qualification (even negative for families 

149 We consider that milk with added sugar or flavouring is not consumed by 35% of the control group, and only 
16% of the target group. 

58 

FFFVPF&VMMFYYFC-20%-15%-10%-05%00%00%05%10%15%20%NeverAt least once a day 
                                                      
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

with no qualification). According to the place of living, the  role played  by the EU  school 
scheme  intervention  is  higher  in  families  living  in  rural  areas  or  villages  for  almost  all 
product categories, with the only exception of fresh fruits and vegetables. 

Finally, the share of families of the target group stating a frequency of consumption of “3 
or  more  times  a  day”  is  comprised  only  between  a  maximum  of  16%  (for  fruit)  and  a 
minimum  of  5.7%  (for  yoghurt).  Concerning  the  role  of  the  EU  school  scheme,  the  net 
effect (difference in percentage points between the answers of the target group and of the 
control group) is limited and comprised between a maximum of 3.4 percentage points for 
cheese and - 1.8 percentage points for milk150, 0.7 percentage points for fresh fruit 151 and 
2.2 percentage points for fresh vegetables 152.  

Figure 21: Families stating a frequency of consumption of “3 or more times a day”: 
Difference in % points between the target group and the control group – net effect 

Cheese

Yoghurt with added sugar, fruit, nuts,…

Yoghurt with no added sugar, fruit, nuts,…

Milk with added sugar or flavouring

3,4%

3,0%

3,0%

3,9%

Milk

-1,8%

Processed F&V

Fresh vegetables

Fresh fruits

2,3%

2,2%

0,7%

-2,0% -1,0% 0,0% 1,0% 2,0% 3,0% 4,0%

Source: Family survey in CS countries 

Judgement criterion 2.5: Children participating to the EU school scheme have 
(have not) decreased their consumption of foods/drinks with high content in 
fat, salt and added sugar 

The results of the family survey are rather uneven: more than 40% of the families with 
children  participating  in  the  EU  school  scheme  stated  that  their  children  did  not  change 
their consumption of fast food, soft drinks and snacks high in fat, salt and added sugar, a 
little more than 30% affirmed that their children decreased the consumption (a lot or fairly 
decreased) of these foodstuffs, and more than 20% stated to have increased it (a lot or 
fairly increased).  

Besides, the results of the counterfactual analysis are not clear-cut: the difference between 
the  target  group  and  the  control  group  is  quite  positive  in  the  case  of  children  having 

150  The  general  result  derives  from  a  high  negative  difference  in  Romania  (-11  points),  but  also  in  Czechia, 
Germany, Lithuania, Poland and Portugal, although to a lesser extent. However, it should be considered that milk 
products  (except  cheese)  compete  with  each other  and  are  interchangeable.  This  is  not  the  case  for fruit  and 
vegetables. 
151 The overall outcome is the result of opposing effects: positive differences of more than 4 points in Czechia and 
Germany;  negative  differences of  more  than 4 points  in  Portugal  and Romania,  but  also  negative  in  Italy  and 
Poland. 
152 The result derives from differences generally positive, with a maximum in Netherlands and Germany (7 and 
6% points), but accompanied by negative differences in Lithuania and Poland and tending to zero in Romania. 

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decreased the consumption of the products153 (8 percentage points for soft drinks and 10 
percentage  points  for  the  other  two  products),  but  also  (slightly)  positive  for  children 
having  increased  their  consumption  (1  percentage  point  for  fast  food  and  2  percentage 
points for the other products)154. 

Finally, the effect related to the decreasing of consumption is the highest for the 6-10 years 
age  group  concerning  “fast  food”  and  “snacks  high  in  fat,  salt  and  added  sugar”  (14 
percentage  points  and  12  percentage  points).  In  the  case  of  soft  drinks,  all  age  groups 
show  a  positive  role  of  the  scheme  in  decreasing  their  consumption  (between  9  and  10 
percentage points) except the 15-18 age group (only 1 percentage point). This last group 
shows the lowest effect for all three product categories. 

Therefore,  the  implementation  of  the  EU  school  scheme  seems  to  have  favoured  (to  a 
limited  and  non-univocal  extent)  the  reduction  of  the  consumption  of  foods/drinks  with 
high content in fat, salt and added sugar, although in a more limited way in adolescents 
aged 15-18 years old. 

The  analysis  shows  also  a  correlation  between  the  decrease  of  consumption  (for  all 
products) and: 

 

 

the  increasing  educational  qualification  level  (in  the  case  of  the  families  with  no 
qualification, the net effect is even negative for all product categories); 
the increasing size of the place of living (lower in the rural areas or villages, higher in 
the large towns).  

Judgement criterion 2.6: Healthy eating habits are (are not) accompanied by 
activities that contribute to children's well-being and health 

The results of the family survey show that physical activities, with different modalities and 
frequencies, concern almost all children participating in the EU school scheme (only 2% of 
the families stated that their children do not practice any kind of physical activities). It is 
also  significant  that  almost  50%  of  the  children  practices  sport  regularly155  (with  a 
maximum in Italy and Spain and a minimum in Sweden) and 57% play outdoors (with a 
maximum in Poland and a minimum in Italy).  

In this case, the differences between the children of the families of the target group and 
the children of the families of the control group are rather important: in general, more than 
14 percentage points for regularly practised sport, and 10 points for outdoor games.  

Obviously,  there  is  no  direct  causal  link  between  the  implementation  of  the  EU  school 
scheme and physical activities. However, it does not seem to be incidental that the notions 
learned  at  school  concerning  dietary  well-being  are  consistently  reflected  in  a  broader 
sphere of total well-being, albeit in a differentiated way between different age groups. 

4.1.2.3  Conclusions 

The ESQ 2, closely linked to ESQ1, addresses the second objective of the EU school scheme 
related to the promotion of children’s healthy eating habits and the shaping of healthier 
diets. 

The  analysis  of  the  implementation  of  the  educational  measures  that  complement  and 
accompany the distribution of the selected products at school, based on monitoring data, 
showed  that  the  Covid-19  pandemic,  since  March  2020,  limited  the  potential  of  these 

153 Spain, Portugal and Italy are the MS with the higher difference. On the other hand, in Czechia the difference 
is almost zero. 
154 However, it has to be taken into account that the families affirming “I don't know” are about 1-2% in target 
group and about 8-9% in the control group. 
155 At least once a week. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

measures  of  positively  influencing  schoolchildren  healthy  eating  habits.  Indeed,  data  on 
the  number  of  children  participating  to  the  different  educational  measures  show  a 
significant increase between the first and the second year of implementation of the scheme 
followed by a decrease in the last two years. 

Nevertheless, the results of the family survey concerning the notions learned by children 
through  the  EU  school  scheme  are  very  positive,  in  particular  those  related  to  the 
importance  of  the  consumption  of  fruit  and  vegetables  and  milk  (and  milk  products)  on 
health. 

Further  to  this,  case  study  interviews  indicate  that  practical  activities  (i.e.,  games  and 
competitions,  school  gardens,  hands-on  activities,  videos,  teaching  materials,  etc.),  are 
the key tool for increasing children’s awareness concerning healthy eating habits. 

Concerning  the  role  of  the  EU  school  scheme  (distribution  of  products  at  school  and 
educational measures) on children’s change in attitude towards the consumption of fruit 
and vegetables, milk and milk products, a significant proportion of the families participating 
to  the  family  survey156  stated  that  these  notions  belonged  already  to  the  family’s 
background, and therefore already adopted at home. In these cases, the EU school scheme 
may have contributed to consolidate already embedded behaviours within the families157.  

These findings may explain the role played by the EU school scheme on children's attitude 
towards the distributed products: indeed, although with differences at MS level, among the 
different age groups and among families with different educational qualification levels, the 
school scheme should have:  

  generated a net improvement in children’s attitude towards the products (children ask 

 

more and eat more willingly than before); 
curbed  the  net  decline  of  children’s  attitude  towards  the  products  that  would  have 
in  the  EU  school  scheme  (and  thus 
occurred 
maintaining/consolidating the already existing attitude). 

in  absence  of  participation 

Therefore, the EU school scheme seems to have had an impact on children behaviour by 
encouraging a (limited) increase in consumption in terms of quantity and frequency158 and 
limiting the decline of consumption that would have occurred in the absence of participation 
in the EU school scheme (and thus consolidating existing quantities and frequency levels). 
This  effect  of  the  scheme  is  positive  in  all  age  groups.  However,  in  general,  the  effect 
increases as the children age increases (i.e., the effect is lower in age group 0-5 years old 
and higher in age group 15-18). Therefore, it could be deduced that the ability to translate 
lessons  learned  into  coherent  changes  in  attitude  could  be  also  linked  to  the  level  of 
"maturity" of the children. 

Moreover, the highest effects of the EU scheme are observed among families with a lower 
level  of  educational  qualification  and  those  mainly  living  in  rural  areas  (and  the  lowest 
effects among families with higher levels of educational qualification that, presumably, are 
more aware and with an already relatively high consumption at home, in terms of quantity 
and frequency). 

156 37% of the total number of the interviewed families. 
157 Even if it has contributed to the discovery of a wider range of the products concerned by the EU school scheme. 
158 Under 10 percentage points, in particular for F&V products (slightly higher results are observed for milk and 
milk products). 

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For the share of children showing positive changes of behaviour, the increase in consumed 
quantities is mainly due to an increase in the frequency of consumption (increase of the 
number of portions) 159. 

Regarding the change  of children's  consumption patterns into healthy eating habits, the 
family survey show that the results are quite uneven. Therefore, the implementation of the 
EU  school  scheme  seems  to  have  favoured  to  a  limited  and  non-univocal  extent  the 
reduction of the consumption of foods/drinks with high content in fat, salt and added sugar. 
The EU school scheme should have played a major role in children of the age group 6 -10 
years old. Moreover, the results of the analysis showed a correlation between the decrease 
of consumption (for all unhealthy foods) and the increasing educational qualification level 
as  well  as  the increasing  size  of  the  place  of  living  (lower  in  the  rural  areas  or  villages, 
higher in the large towns).  

Finally, with regard to physical activity that contributes to children's well-being and health, 
the results show that differences between children participating in the EU school scheme 
and  the  children  not  participating  are  quite  important160.  However,  differences  are 
significantly higher for children of the 0-5 years old group, and more limited for the 6-10 
years old group. Although there is no direct causal link, it does not seem to be incidental 
that  the  notions  learned  at  school  concerning  healthy  eating  habits  are  consistently 
reflected in a broader sphere of good health. 

159 However, for all the products of the fruit and vegetables sector and for milk, the quantity of the single portions 
decreases with the increasing of the frequency (more portions, but smaller size), while for other milk products 
the quantity of the single portions remains roughly the same with the increasing of the frequency. 
160 In general, more than 14 percentage points for regularly practised sport, and 10 points for outdoor games. 

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4.1.3  ESQ3  -  Which  factors  influenced,  and  to  what  extent,  the  costs  of 
in  the  Member  States 

the  supply/distribution  of  products 
implementing the scheme? 

4.1.3.1  Background and methodological approach  

Understanding 

This ESQ asks to identify and assess the factors influencing the costs of supply/distribution 
of  products  within  the  EU  school  scheme161.  This  ESQ  is  closely  related  with  ESQ6  that 
analyses if the EU scheme has been implemented in a cost-effective way (i.e., efficiency 
of the scheme). 

In order to identify and understand how different factors influence the distribution/supply 
costs of the scheme, the analysis focuses on MS implementation choices concerning: 

 

 
 

the choice of products according to type of products and requirements from the legal 
basis; 
the approach chosen for the reimbursement of eligible costs; 
the choice of procedures for the selection of suppliers. 

Definition of key terms 

Supply/Distribution  costs.  Refer  to  all  the  costs  related  to  the  distribution  of  the 
products in the schools including the price of the product, transport, storage, processing, 
and other administrative costs occurring. 

Products. Are those referred to in Article 23(9) of the basic act and Article 2(1)g of the 
implementing  regulation,  namely  Fresh  fruit  and  vegetables  (Article  23(3)a  of 
Regulation (EU) N 1308/2013),  Processed  fruit  and  vegetables  (Article  23(4)a  of 
Regulation (EU) N 1308/2013),  Milk  (Article  23(3)b  of  Regulation (EU) N 1308/2013), 
and Milk products (Article 23(4)b and Annex V to Regulation (EU) N 1308/2013). 

Criteria for the choice of products  distributed. According to Article 23(11) of the 
basic  act  and  Article  2(2)a  of  the  implementing  regulation  these  are  health 
considerations,  environmental  considerations,  seasonality,  variety  of  products  and 
availability of local or regional produce. MS choose the products on the basis of objective 
criteria most relevant to their context. 

Priorities for the choice of those products. The priorities refer to local or regional 
purchasing,  organic  products,  short  supply  chains,  environmental  benefits,  products 
recognised  under  the  quality  schemes  established  by  Regulation  (EU)  No  1151/2012, 
fair-trade. 

Selection of suppliers. Regulated by Article 23(8) of the basic act and Article 2(1)l of 
the  implementing  regulation,  procurement  procedures  (when  applicable)  can  be 
managed  by  the  national  authority  at  central  level,  or  by  municipalities/educational 
establishments at local level. 

161 The food public procurement market has been estimated at EUR 82 billion, representing a significant part of 
the  procurement  of  any  national  food  economy  and  a  large  portion  of  food  people  eat  every  day.  Given  this 
volume, as stated in the Technical Report on the School setting - Public Procurement of Food for Health, published 
in 2017 by the Maltese Presidency and the European Commission, public institutions have the potential to drive 
innovation towards more nutritionally balanced foods and healthier diets in a fair and transparent way, possibly 
also reinforcing common EU goals such as: the protection of the environment; combating climate change; higher 
resource and energy efficiency. 

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Reimbursement rules. As from Article 23(8) of the basic act and Article 2(1)i of the 
implementing regulation two approaches for the reimbursement of the eligible costs to 
suppliers can be used:  

  a cost-based approach: a form  of  reimbursement occurring after the service 
has been provided/the product has been delivered, by which the amount to be 
paid to the supplier is determined on the basis of actual costs;  

  a  standard  cost  option:  a  system  which  allows  reimbursing  expenditure 
according  to  predefined  methods  based  on  process,  outputs  and  results.  SCOs 
can take the form of flat rate financing, scales of unit costs, and lump sums. 

Judgement criteria, indicators and sources 

In order to reply to the evaluation question, we base our judgement on the following criteria 
and indicators.  

Judgement criteria 

Indicators 

Sources 

JC3.1: Total supply/distribution 
costs  of  products  in  the  MS 
been 
have 
the 
influenced 
products chosen 
the 
strategies 

not) 
by 

(have 

in 

3.1.1 Number products distributed 
3.1.2 Number of criteria applied 
3.1.3 Correlation between products and costs of 
distribution (based on aid efficiency index) 
3.1.4 Informed opinions of stakeholders: national 
authorities, producers’ organisations, educational 
establishments, 
authorities 
administering the scheme 

local 

and 

-  Desk research on EU school 
scheme  strategies  2017-
2023 

-  Annual  monitoring  reports 

2017/18 to 2020/21 

-  Results of ESQ6 
-  Desk 

research 

on 
documents 
at 

additional 
available 
national/regional level 
-  Public Authorities Survey 
-  Structured interviews in CS 

(have 

JC3.2: Total supply/distribution 
costs  of  products  in  the  MS 
have 
been 
influenced by the requirements 
for the selection of products for 
distribution 
the 
set 
strategies 

not) 

by 

JC3.3:  The  approach  for  costs 
reimbursement  affected  (did 
not affect) the distribution costs 
of products in the MS 

JC3.4:  The  use  of  specific 
criteria  for  the  selection  of 
suppliers  (including  the  model 
of  distribution)  influenced  (did 
not  influence)  the  distribution 
costs of products in the MS 

3.2.1 Quality Requirements applied 
3.2.2 Informed opinions of stakeholders: national 
authorities, producers’ organisations, educational 
establishments, 
authorities 
administering the scheme 

local 

and 

countries/regions 

-  Desk research on EU school 
scheme  strategies  2017-
2023 

-  Annual  monitoring  reports 

2017/18 to 2020/21 

-  Desk 

research 

on 
documents 
at 

additional 
available 
national/regional level 
-  Public Authorities Survey 
-  Structured interviews in CS 

and 

local 

3.3.1 Reimbursement approach applied by MS 
3.3.2 Informed opinions of stakeholders: national 
authorities, producers’ organisations, educational 
authorities 
establishments, 
administering the scheme 
3.4.1  Use  of  specific  criteria  for  suppliers’ 
selection 
3.4.2 Informed opinions of stakeholders: national 
authorities, producers’ organisations, educational 
establishments, 
authorities 
administering the scheme 

local 

and 

countries/regions 

-  Public Authorities Survey 
-  Structured interviews in CS 

countries/regions 

-  Desk  research  at  Case 

study level 

-  Public Authorities Survey                                                                          
-  Structured interviews in CS 

countries/regions 

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Methodological approach and its limitation 

Tools, method and sources used  

The analysis is carried out at EU-28 level (EU-27+UK) and at case study level and it takes 
the in-depth analysis of the national/regional strategies as the starting point. The analysis 
is also based on primary data and information collected through: 

 

 

the PA survey: national and regional managing authorities responsible for the school 
scheme implementation participating in the survey were asked to provide a judgement 
about the influence of different factors on the distribution of products; 
structured interviews in case study MS and regions. 

Finally,  a  quantitative  analysis  (regression)  was  used  to  verify  the  possible  correlation 
between the choice of products distributed within the EU school scheme and distribution 
costs. This analysis uses the results of ESQ 6 and is based on the synthetic efficiency index 
defined as the ratio between the coverage rate of the EU school scheme at MS level and 
the cost per child in that MS.  

Limitations of methods and sources 

Limits  of  the  analysis  to  answer  this  ESQ  are  mainly  related  to  the  lack  of  detailed 
monitoring  data  on  the  different  dimensions  here  assessed  (e.g.,  costs  for  logistics, 
storage, packaging, etc.). This, of course, is also closely connected to the high number of 
variables (e.g., types of products, criteria for selection, distribution model, reimbursement 
approach, etc.) involved in the implementation of the strategies. In this respect, therefore, 
the  analyses  have  been  carried  out  with  the  aim  of  reporting  the  main  findings  about 
relevant common evidence. 

4.1.3.2  Analysis 

Judgement criterion 3.1: Total supply/distribution costs of products in the MS 
have (have not) been influenced by the products chosen in the strategies 

The analysis of the national strategies shows that the choice of the types of products to be 
distributed varies across MS162: a high share of MS has chosen to distribute fresh F&V (91% 
of  MS)  and  plain  milk  (98%).  The  distribution of  milk  products  ex  Art.  23  of  Regulation 
(EU) No 1308/2013163 (63%) appears also relevant, whereas processed F&V (35%), milk 
products ex Annex 5164 (19%) and other products (26%) are chosen less.  

The combination of product groups distributed varies greatly across MS165. It is important 
to clarify, however, that the supply/distribution of fresh fruit and vegetables and milk is a 
prerequisite  (art.  23)  for  the  distribution  of  processed  fruit  and  vegetables  and  of  milk 
products. This explains the high share of MS distributing, respectively, fresh F&V and milk. 
Moreover,  'other  products'  are  not  regularly  distributed/supplied,  but  only  included  in 
educational measures (e.g., tasting during workshops, farm visits, theme days). 

162categories  of  products  that  can  be  chosen  are:  Fresh  fruit  and  vegetables;  Processed  fruit  and  vegetables; 
Milk; Milk products; Milk products. Each of these categories includes more than one type of products. For example, 
concerning fresh F&V 17 types of products can be chosen. 
163Milk products falling within CN codes 0401, 0403, 0404 90 and 0406 or CN code 2202 90. 
164Products with added sugar, added fat, added salt, added sweeteners. 
1659% of the National Strategies choose to distribute all products (Austria, Czech Republic, Italy and Lithuania) 
and 9% distribute 5 categories of products (Spain, Hungary, Slovenia and Slovakia); 26% distribute 4 out of 6 
(BE Wallonia and Brussels, Bulgaria, Estonia, Greece, France, Croatia, Luxembourg, Poland, Romania and Finland) 
or  2  out  of  six  products  (BE  Flanders;  DE  Bremen,  Hessen,  Mecklenburg  Western  Pomerania,  Lower  Saxony, 
Rhineland-Palatinate, Saxony Anhalt, Schleswig-Holstein and Thuringia; Latvia and Portugal) were chosen in the 
strategies; in 23% of cases 3 types of products were chosen (Cyprus, Denmark, Ireland, DE Baden Wurttemberg, 
Bavaria, North Rhine Westphalia and Saxony, Malta, the Netherlands and UK; finally, in 7% of the strategies only 
one type of product was chosen (DE Berlin and Brandenburg and Saarland; Sweden). 

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Concerning the criteria applied for the choice of products (Article 2(2)a of the implementing 
Regulation),  almost  all  strategies  take  into  account  health  considerations  (93%  of  all 
strategies),  local  or  regional  products  are  also  often  considered  (74%),  together  with 
seasonality  and  variety  of  products  (63%).  Environmental  considerations  have  been 
included in 51% of the cases. 

Given the lack of structured monitoring data on the costs of distribution, in order to test a 
possible correlation between the choice (number) of type of products distributed (and the 
costs of distribution of the products, a regression analysis was carried out.  

Figure 22: Correlation between n. of products chosen and costs of distribution 

Source: our elaboration on info from EU school scheme strategies and monitoring data 

Using  the  number  of  types  of  F&V  products  selected166  in  the  different  strategies  as 
independent  variable  (x)  a  first  regression  was  carried  out,  assuming  that  the  level  of 
expenditure  for  the  distribution  of  the  products  per  MS  (dependent  variable;  y)  is  a 
reasonable  proxy  of  the  costs  of  distribution.  A  second  regression  was  carried  out 
considering  the  F&V  synthetic  efficiency  index  calculated  in  ESQ6  for  each  MS  as  the 
dependent variable (y).  

The  results  of  the  first  regression  show  no  correlation  between  the  number  of  types  of 
products and distribution costs: the strategies having chosen few types of fresh F&V (e.g. 
Luxembourg, Lithuania, Latvia, Portugal, Romania, Slovakia), in spite of presumably being 
more vulnerable to price fluctuations, seem to perform better than MS/strategies having 
chosen  a  larger  number  of  fresh  products  (e.g.  France,  Czech  Republic,  Austria,  Spain, 
Italy, Hungary, Greece, and the Netherlands).  

The results of the  second regression analysis confirm that there is no strong  correlation 
between the products to be distributed and the values of the aid-efficiency index (R2 value 
is in  all  cases  very  low),  thus  it  appears  that  the  costs  of  the  products  are  not  a  major 
influencing factor of the costs of distribution.  

According  to  the  results  of  the  PA  survey167,  63%  of  the  respondents  consider  that,  in 
general,  the  choice  of  the  types  of  products  affects  the  costs  of  distribution  (for  39% 
“somewhat”  and  for  24%  “to  a  great  extent”).  In  this  sense,  the  answers  to  the  PA 
survey168  further  clarify  that  for  several  MS/regions169  the  choice  of  the  products  to  be 

166 The analysis was carried out only for F&V. For the other categories data available do not allow this type of 
analysis. 
167 Participants to the survey have been asked to indicate to what extent the chosen types of products influenced 
the costs of supply/distribution foreseen in procurement procedures. 
168 Participants to the survey have been asked to indicate to what extent product price influenced the choice of 
products to distribute in schools. 
169 Belgium, DE Bavaria, Estonia, Latvia, the Netherlands, Poland. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

distributed was influenced by their price (especially milk products’ and fresh and processed 
fruits’).  

Judgement criterion 3.2: Total supply/distribution costs of products in the MS 
have  (have  not)  been  influenced  by  the  requirements  for  the  selection  of 
products for distribution set by the strategies 

The analysis of the strategies shows that, among the priorities for choosing products  as 
established in Article 2(2)a of the implementing regulation170, the one related to “local or 
regional purchasing” has been  selected in 67% of cases, followed by “organic products” 
(56%)  and  “short  supply  chain”  (44%).  The  criteria  related  to  environmental  benefits 
(33%), to products recognized by Regulation (EU) No 1151/2012171 (5%), and fair trade 
(19%)  seem  to  be  less  relevant.  It  seems  also  appropriate  to  underline  that  only  one 
strategy (Spain) has selected all the priorities, whereas six strategies have foreseen none 
of them (e.g., Sweden, Poland, Austria, the Netherlands, Latvia, Estonia). The MS report, 
on  a  yearly  basis,  on  the  priorities  actually  applied  to  choose  the  products172.  However, 
when  reading  the  results  of  the  analysis  it  is  important  to  consider  that  some  of  these 
priorities may have been perceived by the authorities designing the strategies as strongly 
related to each other and to some extent possibly overlapping (e.g., organic products and 
environmental benefits, or local/regional purchasing and short supply chain), hence leading 
to the selection of only a few of them.  

According to the results of the PA survey concerning the extent to which requirements for 
distribution  influenced  the  costs  of  supply/distribution  foreseen  in  the  procurement 
procedures, 6 respondents (18%) consider that product quality requirements have, overall, 
influenced  to  a  great  extent  the  costs  of  distribution173,  whereas  most  MS  (37%  of 
respondents) consider the selected quality requirements “somewhat” affecting the costs of 
distribution. The analysis of the different quality requirements investigated in the PA survey 
also  show  that  variety  and  seasonality  of  products  (which  applies  also  to  large  MS)  are 
deemed  to  have  the  largest  effect  on  the  costs  of  distribution,  followed  by  healthy  food 
choices and organic production (which mostly applies to small MS)174. Finally, 6 national 
authorities answered that selected quality requirements have little influence on distribution 
costs. 

Information collected through structured interviews in case study MS and regions provide 
some detailed insights on the issue. The  effect of organic products (and products under 
quality schemes) on distribution costs has been largely reported by interviewees: indeed, 
organic products are more expensive than conventional products and their production costs 
are not always fully reimbursed. Additionally, organic products are more difficult to find in 
the local market. In particular, interviewees stated that: 

170 Article 23(11) of Regulation (EU) N 1308/2013. 
171 EU Regulation on quality schemes for agricultural products and foodstuffs. 
172  According  to  the  monitoring  data,  in  the  four  years  under  analysis  the  priority  related  to  “local/regional 
purchasing”  has  been  selected  on  average  by  60.1%  of  the  MS;  “organic  products”  by  48.5%;  “short  supply 
chain” by 47.2%; “quality schemes” by 43.5%, and “fair trade” by 12%. Some MS indicate in the AMR quality 
schemes  among  the  priorities  used  to  choose  products,  but  the  detailed  information  often  refers  to  national 
schemes or integrated crop management system (i.e., schemes not covered by Regulation (EU) N 1151/2021). 
173 However, among these, 3 MS (the Netherlands, Latvia and Estonia) have not selected such priorities in their 
strategies, therefore the results could be biased. 
174 On the contrary, the less affecting quality requirements seem to be those related to GI and TSG products and 
to fair trade. 

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 

 

concerning insufficient reimbursement, the use of a flat rate appears to discourage the 
distribution of organic products (DE Bavaria175 and France176). However, in Spain an 
additional  budget  is  dedicated  to  organic  products  (+20%  on  the  price)  in  order  to 
promote their distribution and the public procurement established an awarding criterion 
based on additional % of organic production (on top of the minimum 25% of organic 
products distributed; 
concerning  the  limited  organic  production  at  local  level,  in  two  MS  (Lithuania  and 
Portugal)  it  has  been  (sometimes)  necessary  to  find  alternative  market  sources  of 
supply in order to avoid delivery delays and consequent difficulties by municipalities to 
be compliant and, eventually, engaged. 

Moreover,  according  to  interviewees,  quality  requirements  can  also  affect  the  costs  of 
distribution  when  considering  minimum  standard  required  (e.g.,  size  and  shape  of  the 
portion, storage/cooling capacity, extra sorting, etc.):  

 

 

 

In  Czech  Republic  and  in  Poland,  portion  size  affects  the  distribution  of  certain 
products  (e.g.,  apples),  hampering  the  quality:  e.g.,  during  storage  and 
transportation  fruits  may  lose  moisture,  which  reflects  into  loss  of  weight  and 
eventually to a raise in the breakeven costs. In Poland, such occurrences doubled 
the costs of supply/distribution (where SCO based reimbursement is applied); 

In  France,  suppliers  of  products  distributed  under  the  EU  school  scheme  have  to 
fulfill additional requirements in relation to those already in place for the products 
distributed under the national financed scheme177; 

In Italy, the distribution of dairy products foresees additional requirements affecting 
costs,  such  as  the  provision  of  isothermal  boxes  to  school  to  keep  the  products 
refrigerated for 2 days178.  

Finally,  logistics  costs  have  been  also  pointed  out.  Some  MS,  in  fact,  specified  that 
transportation  in  disadvantageous  geographical  conditions  (e.g.,  Spain)  or  under  the 
selected  product  quality  requirements  (e.g.,  Italy,  Lithuania,  Poland)  lead  to  a  raise  in 
distribution costs. However, in Spain some adjustments to address these costs have been 
applied (e.g., additional payments  can compensate the  costs linked to the length of the 
transport and distribution and to refrigerated transport)179.  

Judgement criterion 3.3: The approach for reimbursement of costs affected 
(did not affect) the distribution costs 

The  analysis  of  the  implementation  choices  concerning  the  two  options  for  cost 
reimbursement set by Article 2(1)i of the implementing regulation180, shows that 44% of 

175Product suppliers interviewed reported that the significantly higher purchase prices for organic goods are not 
reflected in the reimbursement (EUR 4.20 per kg compared to  EUR 3.20 for conventional goods). Especially in 
the summer, regional organic fruit (berries or cherries) is not available at prices that would be covered by the 
refund. 
176According  to  stakeholders  interviewed  (local  authorities,  product  suppliers  and  Paying  Agency),  organic 
products are more expensive and the lump sum set only accounts for the price difference between conventional 
and quality products, i.e., not price difference between conventional and organic products. 
177The National Programme for Nutrition and Health (Programme National Nutrition Santé – PNNS). 
178In general, however, it was also clarified that, according to their model of implementation, costs have to be 
interpreted as costs of the service provided, therefore, the value of the products represents between 45% and 
60% of the overall distribution costs. 
179  Complementary  aid  for  transport  expenses  EUR/kilogram  350 km  <  X  <  500 km  0.0726;  500 km  <  X  < 
750 km 0,0953; > 750 km 0.1083. Supplement for refrigerated transport EUR 0.0085. 
180 If standard scales of unit costs, flat-rate financing and/or lump sums are authorised, the fair, equitable and 
verifiable calculation method used for their establishment; if a cost-based system is used, the arrangements to 
assess the reasonableness of the costs submitted by aid applicants. 

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the  national/regional  strategies  applied  a  cost  based  (CB)  system181,  whereas  the  rest 
applies a standard costs option (SCO) system182. Greece seems to apply a mixed method, 
whereas  France  reimburses  additional  delivery  costs  on  top  of  SCO.  If  we  look  at  the 
performance based on the aid-efficiency index (see ESQ 6), we observe that MS applying 
a CB reimbursement system seem to perform better than those using a SCO approach 183. 
It must be, however, outlined that MS adopting the CB approach show Union aid average 
unitary cost of EUR 3 345 (see ESQ6), which is more than double the Union aid average 
unitary cost experienced in MS adopting the SCO (EUR 1 529). 

The results of the PA survey184 show that 79% of the respondents consider effective the 
approach chosen for the distribution of products (41% considered it very effective, whereas 
38% considered it somewhat effective)185. On the contrary, 22% of respondents deemed 
the reimbursement approach chosen as very little effective or not effective at all for the 
distribution of products186. 

Moreover, according to the information collected through case study interviews, although 
the  SCO  approach  limits  the  administrative  burden,  the  applied  rate  is  considered 
sometimes insufficient: 

 

 

 

In DE Bavaria, product suppliers reported that the school scheme has increasingly 
been associated with insufficient earnings by the suppliers, leading to many small 
suppliers  not  participating  anymore,  also  due  to  the  high  bureaucratic  effort  and 
the interim financing required until the reimbursement is paid; 

In  France,  one  product  supplier  outlined  that  if  the  lump  sum  remains  the  same 
over time and is not adjusted to changes in the market price of the products, this 
leads  to  variations  of  the  percentage  of  real  cost  actually  reimbursed  by  the 
scheme187; 

In the Netherlands, the flat rate is supposed to encompass the cost of products and 
their distribution, but distribution is difficult to organise and costly, given the way 
schools are allocated to suppliers188. 

The  administrative  burden  of  the  approach  chosen,  often  leading  to  a  delay  in 
reimbursement, has been highlighted by product suppliers in Czech Republic, DE NRW, and 
educational establishments in Lithuania and Portugal. In the latter MS, the procedures for 
reimbursement are challenging for municipalities and educational establishments that have 
low  administrative  and/or  financial  capacity,  which  hampers  the  participation  in  the 
scheme.  Finally,  the  cost  reimbursement  approach  chosen  has  been  questioned  by 
stakeholders in Poland, where the system does not take into account transport and product 
transformation costs: in order to make the system more fitting the reality of the market, 
a  new  methodology  for  calculating  the  reimbursement,  on  the  basis  of  wholesale  prices 

181 The strategies foresee CB including all expenses (e.g., Italy, Slovenia, Slovakia, UK) or only some of them 
(e.g.,  LU)  and  sometimes  setting  a  maximum  amount  based  on  statistics  (e.g.,  Belgium,  Bulgaria, 
Czech Republic). 
182 Among MS applying this option France, Spain, Poland, Portugal, Sweden. 
183 Among 10 MS that perform better, 6 apply a CB reimbursement system; on the contrary, among the 7 MS 
that perform worse, 5 use a SCO approach. 
184  To  what  extent  has  the  approach  chosen  for  the  reimbursement  of  eligible  costs  (including  Standard  Cost 
Options - SCO) guaranteed an efficient product supply/distribution? 
185 Among both categories there is an equilibrium between the use of CB and SCO approach. 
186  it  is  interesting  to  note  that  among  the  latter  Authorities,  the  vast  majority  (5  out  of  6  –  Italy,  Lithuania, 
Luxembourg, Slovenia, Slovakia) apply a CB approach for reimbursement. 
187 Lump sums are defined for each category of products, with different amount for conventional products and 
products under SIQO (Signe official d’identification de la qualité et de l’origine). For SIQO products distributed on 
lunch break, only the price difference between the SIQO product and a conventional equivalent is reimbursed by 
lump sums. 
188 Suppliers were allocated with equivalent numbers of small and big schools, isolated schools, etc. 

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plus the costs  of preparations to the delivery  (peeling, cutting, packing, etc.), has been 
proposed by the National Authority. 

Judgement  criterion  3.4:  The  use  of  specific  criteria  for  the  selection  of 
suppliers (including the model of distribution) influenced (did not influence) 
the distribution costs 

The procedure for the selection of suppliers, although complying with the EU provisions for 
public  procurement  rules,  has  been  designed  differently  among  MS  according  to  Article 
2(1)(l)  of  the  implementing  regulation:  although  most  apply  procurement  procedures 
managed  by  the  national  authority  at  central  level,  there  are  several  cases189  where 
municipalities/educational establishments are in charge of tendering procedures related to 
the distribution, sometimes making reference to a list of suppliers previously defined190. 

The  results  of  the  PA  survey191  show  that  only  in  few  cases192  the  use  of  Green  Public 
Procurement, social and/or innovation criteria for the selection of the suppliers have been 
reported.  In  these  cases,  furthermore,  the  above-mentioned  criteria  seem  to  have  little 
influence on the costs of distribution. However, these results must be taken with caution 
as in several MS public procurement procedures (and their specific criteria) are carried out 
at local level. Hence the above reported information, collected at National Authority level, 
may show some inconsistency. The results of the PA survey193 additionally show that the 
model for product distribution (frequency and number of portions) also plays a key role: 
66% of respondents reported that the model influenced the distribution costs (21% “to a 
great  extent”,  whereas  45%  “somewhat”).  Only  18%  of  respondents  reported  that  the 
model has not influenced at all the costs194. 

Moreover, the information gathered through the case studies, highlights a spread opinion195 
regarding the fact that the selection of suppliers seems to reward more easily specialised 
companies with a strong market position, and, therefore, with higher capacity of meeting 
quality, quantity and assortment requirements. To this respect, it is worth mentioning that: 

 

 

 

requirements,  data  protection 

in  the  Netherlands,  there  is  only  one  milk  supplier  which  has  long-established 
experience  in  the  scheme.  According  to  interviewed  product  suppliers  and  sector 
representatives, the low reimbursement rate together with other factors such as logistic 
capacity,  packaging 
traceability 
requirements make it difficult for small suppliers to participate;  
in  Spain,  the  price  is  the  main  awarding  criterion  (as  in  Romania),  not  encouraging 
small  suppliers  to  participate  because  it  requires  significant  logistics  capacity.  The 
logistics issue has been raised also in Portugal, where small suppliers are not willing to 
set up such an organisation for short term contracts; 
in  France,  collective  catering  excludes  small  suppliers  that  have  not  the  sufficient 
organisation capacity or are not able to provide the requested product quantity. The 
organisational  conditions  were  highlighted  also  in  Italy,  where  interviewees  clarified 
that suppliers often had to outsource the distribution to POs in order to participate in 

issues,  and 

189 Austria, Sweden, Slovenia, Portugal, Hungary, Cyprus, Croatia, Denmark. 
190 BE – Brussels, DE – Baden Württemberg, Bavaria and Schleswig-Holstein. 
191 Have specific criteria been applied for the selection of suppliers? 
192 Croatia, Spain, Malta, and the Netherlands. 
193 To what extent has the model for distribution of products influenced the costs of distribution? 
194 France, Malta, Austria, Romania, Slovenia and Sweden. 
195 Sector representatives in Czech Republic, France, DE Bavaria, the Netherlands and Spain; product suppliers 
in Lithuania, DE Bavaria, the Netherlands, Poland and Spain and local authorities/educational establishments in 
France and DE NRW. 

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 

the scheme196. However, in Italy, based on the assumption that a unique supplier for 
more  regions  allows  to  contain  costs,  a  framework  contract  in  regional  lots  was 
launched; 
In  Poland,  the  Managing  Authority  clarified  that  the  criteria  want  to  ensure  the 
participation  of  experienced  companies  able  to  ensure  the  delivery  of  products  on  a 
large scale for the entire period  of deliveries, hence  ensuring constant availability of 
labour force to this end197. 

Finally,  the  administrative  effort  required  for  participating  in  the  scheme198  and  the 
financial  capacity  of  the  suppliers,  in  order  to  prefinance  the  distribution199  were  also 
highlighted as hindrances to the participation of small businesses in the EU school scheme 
and to the fairness of competition (e.g., producers’ organizations and product suppliers in 
France and Poland, product suppliers in DE NRW and Bavaria, producers’ organization in 
the Netherlands). However, according to Spanish representatives, these difficulties could 
be overcome by encouraging small companies to group together, supply to intermediaries 
who  manage  the  logistics  aspects,  or  establishing  multi-annual  contracts  which  could 
guarantee  the  investment  in  terms  of  organization  made  by  smaller  producers  to 
participate in the scheme. 

4.1.3.3  Conclusions  

The overall objective of this ESQ is to understand  which factors influenced, and to what 
extent,  the  total  costs  of  the  supply/distribution  of  products  (including  the  price  of  the 
products,  transport,  storage,  processing,  and  other  administrative  costs  occurring).  The 
analysis  is  based  on  regulatory  framework  related  to  implementation  choices  and  the 
consequent information reported in MS strategies. 

The analysis is completed with empirical analysis based on primary data collected through 
the  survey  of  Public  Authorities  and  structured  interviews  with  EU  stakeholders  in  case 
study MS and regions. 

Overall,  the  type  of  products  (including  the  quality  requirements  on  which  the  choice  is 
based), seems to have no particular impact on the costs of distribution, with the exception 
of  organic  production.  In  fact,  organic  products  affect  the  costs  (and  possibly  even  the 
participation of small businesses to the EU school scheme). Additionally, the distribution of 
these products is limited where local or regional production is not sufficient. However, in 
few  cases  for  the  distribution  of  such  products  an  additional  amount  is  awarded  to  the 
suppliers.  Finally,  even  if  to  a  lesser  extent,  the  low  reimbursement  price  of  organic 
products and of products under quality schemes has been also mentioned as a constraint 
for the participation of small suppliers (DE Bavaria, the Netherlands, Spain). 

Certain product requirements such as size, sorting and packaging of the portion may also 
have a strong influence on the costs of distribution as they may require additional work 

196In Italy products distributed in schools through the EU school scheme are the same as the products delivered 
to the market, therefore, POs that can offer organic products and PDO/PGI products have an advantage. As an 
example, usually 20% to 30% of POs production is organic. 
197The suppliers are selected by the school participating from a list of approved suppliers published by the National 
Support Centre for Agriculture on the website www.programdlaszkol.org. An approved supplier delivers products 
under the program upon contract with the school. In order to obtain approval, in addition to the conditions set 
out  in  EC  Regulation  2017/40  art.  5  and  6,  suppliers  must  have  the  necessary  equipment  to  ensure  proper 
conduction of activities related to the purchase, preparation of deliveries and delivery of fruit and vegetables or 
milk, respectively, and demonstrate at least 6 months of experience in the production or processing of fruit and 
vegetables or milk, respectively, or marketing of fruit and vegetables or milk, respectively (the requirement of 6 
months  of  experience  does  not  apply  to  cooperatives  and  associations  of  farmers'  cooperatives,  groups  and 
associations  of  agricultural  producer  groups,  organizations  and  associations  of  fruit  and  vegetable  producer 
organizations, milk producer organizations and associations of milk producer organizations). 
198DE NRW, France, Italy, and Lithuania. 
199DE Bavaria, DE NRW. 

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from  the  suppliers  along  the  logistics  and  distribution  chain.  This  is  particularly  true  in 
cases  where  a  reimbursement  approach  based  on  SCO  is  applied,  as  prices  of  products 
(and costs related to labour) may vary over the years of implementation of the scheme. It 
can be noted that the model of distribution (frequency and number of portions) also affects 
the costs of distribution. Logistics, in this sense, seem to be a key factor in certain areas 
as  they  may  increase  the  costs  of  distribution,  if  not  well  considered  and  planned 
beforehand. 

Finally,  as  regards  fair  competition  among  suppliers,  according  to  the  results  of  the  PA 
survey, public authorities believe to have set all necessary procedures at national level to 
safeguard it. However, suppliers/producers interviewed in case study MS clarified that the 
selection  of  suppliers  seems  rewarding  more  easily  specialized  companies  with  a  strong 
market position. In this sense some of the reasons mentioned by interviewees are related 
to  the  organisational  capacity  needed  to  meet  quality,  quantity  and  assortment 
requirements (Czech Republic, the Netherlands, Poland, Spain), the overall administrative 
costs  related  to  participation  to  the  scheme  (France,  Lithuania,  Romania),  the  financial 
capacity to prefinance some expenses (DE NRW), given the delay in the reimbursement, 
the (usually) short term contracts awarded not encouraging small companies to invest in 
the participation, the lowest price as  key criterion for awarding the contract to suppliers 
(Romania, Spain), which is detrimental for small local companies.  

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4.1.4  ESQ4 - To what extent have the following implementation choices 
influenced  the  achievement  of  the  objectives  of  the  EU  school 
scheme with respect to viable food production  

a) application of the criteria for the allocation of Union aid to the Member 
States, and 

b) the possible transfers of Union aid between school fruit and vegetables 
and school milk? 

4.1.4.1  Background and methodological approach  

Understanding 

While the overall framework and basic principles and rules are set at the EU level, in the 
light of the principle of subsidiarity, the Commission has provided for a degree of flexibility 
allowing  MS  to  integrate  different  features  in  designing  and  implementing  their  school 
scheme strategies, depending on national or regional specific needs. 

In this ESQ, the focus of the analysis is the extent to which the criteria set out in the EU 
school scheme regarding allocation of Union aid to each MS, and the possibility of making 
further adjustments on the allocation of Union aid between school fruit and vegetables and 
school  milk  and  milk  products,  influenced  the  achievement  of  the  EU  school  scheme  in 
relation to the CAP general objective of enhancing viable food production, particularly by 
its specific objectives of: 

  maintaining market stability; 
  ensuring  availability  of  both  current  and  future  supplies  while  meeting  consumer’s 

expectations; 
increasing farm income and limiting its variability; and 
improving competitiveness of the agricultural sector. 

 
 

The answer to this ESQ was conducted by the following sub-questions: 

  ESQ 4a) To what extent have the application of the criteria for the allocation of Union 
aid to the MS ‘number of six to ten-year-old children’ and ‘level of regional development’ 
influenced the achievement of the objectives of the EU school scheme with respect to 
viable food production? 

Regulation (EU) N 1308/ 2013 states that the encouragement to the consumption of fruit 
and vegetables, as well as of milk and milk products by school children should be made 
“with a view to durably increasing the share of those products in the diets of children at 
the  stage  when  their  eating  habits  are  being  formed,  thereby  contributing  to  the 
achievement of the objectives of the CAP in particular stabilising markets and ensuring the 
availability of both current and future supplies” (cf. recital 24). 

The criterion ‘level of regional development’, aims to ensure the possibility that higher aid 
can be allocated to the less developed regions, to the smaller Aegean Islands and to the 
outermost  regions,  as  these  regions  often  show  low  levels  of  productivity,  market 
integration and farm income and, therefore, the agricultural sector is more susceptible to 
price  volatility  and  market  instability.  Additionally,  the  geographic  setting  of  the  islands 
can also show a lower diversification and agricultural markets where transport and storage 
costs might make it more difficult to find products at a reasonable cost.  

These  two  criteria  are  directly  reflected  in  the  indicative  allocation  for  each  EU  school 
scheme national strategies, both for fruit and vegetables and milk and milk products parts 
&V and milk parts of the school scheme. 

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Definition of key terms 

Less  developed  regions  are  areas  at  NUTS  3  level  whose  Gross  Domestic  Product 
(GDP) per capita is less than 75 % of the average GDP of the EU 27 (in accordance with 
point (a) of the first subparagraph of Article 90(2) of Regulation (EU) No 1303/2013 of 
the European Parliament and of the Council. 

Outermost regions are part of the MS territories located in areas that are remote from 
Europe  (Guadeloupe,  French  Guiana,  Réunion,  Martinique,  Mayotte,  Saint-Martin 
(France), the Autonomous regions Azores and Madeira (Portugal) and the Canary Islands 
(Spain). 

Smaller Aegean Islands are the Greek islands in the Aegean Sea, except Crete and 
Evia (Article 1(2) of Regulation (EU) No 229/2013 of 13 March).  

  ESQ 4b) To what extent have the possible transfers of Union aid between school fruit 
and vegetables and school milk influenced the achievement of the objectives of the EU 
school scheme with respect to viable food production? 

This  sub-question  looks  at  the  influence  that  the  possibility  given  to  MS  to  make 
adjustments between the indicative allocations defined for fruit and vegetables and milk 
and products parts of the school scheme of the transfers of Union aid between school fruit 
and vegetables and school milk envelopes in the achievement of the objectives of the EU 
school scheme with respect to viable food production and, more generally, to understand 
the use and under-use of the Union aid allocated per MS. 

Judgement criteria, indicators and sources 

In order to reply to the evaluation question, our judgement is based on the following criteria 
and indicators.  

Judgement Criteria 

Indicators 

Sources 

school 

JC4.1:  EU 
scheme 
implementation 
choices 
concerning 
target 
(age  groups)  have 
groups 
contributed to an increased and 
durable consumption 

children 

4.1.1. Main target groups (age groups) 
chosen by the MS to benefit from the EU 
school scheme 

JC4.2:  The  higher  allocation  of 
Union  aid  to  less  developed 
regions has led to more schools 
and  children  to  be  covered  by 
the EU school scheme 

4.2.1.  Number  of  MS  that  applied  a 
higher allocation aid to less developed 
regions. 

JC4.3:  The  transfers  between 
milk and F&V envelopes used by 
some  MS  have  contributed  to 
improving  the  implementation 
the  school  scheme 
towards 
objectives related to viable food 
production 

4.3.1  Transfers  made  by  MS from  the 
F&V  part  to  the  milk  part  and  vice 
versa. Rate of use of the transfers. 
4.3.2. Motivations for the transfers 

-  Findings 

from 

desk 
research/  literature  review: 
analysis  of  EC  legislative 
acts,  existing  literature  on 
the 
evaluation 
studies    

subject, 

-  EU 

school 
strategies 2017-2023 
-  Public Authorities Survey 
-  Structured  interviews  in CS 

scheme 

MS/regions 

-  EU 

school 
strategies 2017-2023 
-  Public Authorities Survey 
-  Structured  interviews  in CS 

scheme 

MS/regions 

-  Working  documents  for  the 
Committee  for  the  CMO  of 
the  agricultural  markets, 
animal products 

-  Implementing acts on fixing 
indicative  and  definitive 
Union aid allocations  
-  Public Authorities Survey 

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Methodological approach and its limitations 

Tools, method and sources used 

The methodology adopts an approach based on ‘Contribution analysis’, meaning that the 
exercise  of  constructing  the  theory  of  change  was  based  on  a  contributory  relationship. 
Taking  as  the  starting  point  the  EU  school  scheme  intervention  logic  (see  2.2.2)  the 
analysis focuses on how implementation choices using the criteria ‘number of six to ten-
year-old children’ and ‘level of regional development’ and the recourse to transfers affected 
the contribution of the EU  school scheme to the CAP objective of ensuring a viable food 
production.  

The analyses rely mainly on collected qualitative data and to a lesser extent on quantitative 
data.  The  data  was  collected  through  desk  research  (e.g.,  EU  school  scheme 
national/regional  strategies  and  annual  monitoring  data),  through  the  Public  Authorities 
survey and Case Study interviews. 

Limitations of methods and sources 

Only  two  school  scheme  strategies  identified  needs  related  to  viable  food  production: 
Hungary identified the need to stabilize producers’ incomes through increasing the level of 
milk  and  milk  product  consumption;  and  Czechia  identified  the  need  to  support  the 
production and processing of fruit, vegetables and milk. This led the evaluation team to 
assume that no special attention was attributed to the contribution for enhancing viable 
food  production  in  the  designing  of  the  school  scheme  strategies  and,  therefore,  the 
implementation  choices  are  not  driven  by  the  aim  of  contributing  to  this  objective.  The 
results of the interviews carried out in the scope of the case studies have confirmed it.  

As  the  assumptions  of  the  implementation  choices  regarding  the  age  groups  benefiting 
from the EU school scheme took in consideration, to a large extent, health related needs 
(where  eating  habits  are  most  influenced  in  order  to  promote  health),  the  information 
collected in this regard has a qualitative nature and a limited perspective on the subject of 
analysis, e.g., the information gathered from the stakeholders contains limited reflection 
on how these choices contribute to the overall objective of viable food production. 

Regarding  the  criterion  ‘level  of  regional  development’,  only  two  MS  mentioned  to  have 
applied it  (France  and  Spain).  Therefore,  it  is  considered  that,  from  a  technical  point  of 
view,  the  evidence  is  limited  and  does  not  provide  a  solid  basis  for  conclusions  and 
recommendations.  

4.1.4.2 

Analysis 

Judgement  criterion  4.1:  EU  school  scheme 
implementation  choices 
concerning  children  target  groups  (age  groups)  have  contributed  to  an 
increased and durable consumption 

In  order  to  promote  the  healthy  eating  habits  of  children  and  to  ensure  that  the  aid  is 
targeted at children at the stage when their eating habits are being formed, the EU school 
scheme  regulation  defined  a  criterion  related  to  the  targeting  of  aid  by  MS  taking  into 
account the number of six- to ten-year-old children in the MS concerned. 

In respect to ensuring future demand, the assumption is that it depends on the change of 
attitudes and behavior towards the consumption of fruit and vegetables and milk and milk 
products in the future beyond the targeted age group. 

With the allocation of Union aid according to the number of children in the target group 
six- to ten-year-old children it is expected that the share of those products in children diets 
increase in a durable way and, thereby, contribute to the achievement of the CAP general 

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objective  of  enhancing  viable  food  production  in  particular  by  stabilising  markets  and 
ensuring the availability of both current and future supplies. 

The strategies for the implementation of the EU school scheme are led, to a large extent, 
by  health-related  needs,  such  as  reducing  obesity  and  overweight  rates  among 
children/adolescents and increasing consumption of fruit/vegetable products and milk/milk 
products amongst children, therefore, the main objectives are linked to changing children’s 
habits/dietary patterns  towards healthier  eating habits by including fruit and vegetables 
and milk and milk products in their diets in a long-lasting manner. 

The  decisions  regarding  the  selection  of  target  groups  for  participation  in  the  EU  school 
scheme were taken by the competent Authorities and stakeholders (e.g., in Czechia, the 
selection of age groups of children took place in cooperation with the Ministry of Education, 
Youth and Sports, the Ministry of Agriculture and the Ministry of Health) and / or in a basis 
of  relevant  scientific  literature  (e.g.,  in  the  main  information  for  the  selection  of  target 
groups comes from the annual survey of 9-10 years old children organised by the Health 
authority  (Istituto  Superiore  di  Sanità)  within  a  programme  called  “Okkio  alla  salute” 
(“Keep an eye on your health”). 

The  decisions  on  the  target  groups  are  largely  substantiated  by  the  overall  basis  that 
children  don’t  meet  the  recommended  daily  consumption  of  fruit  and  vegetables  and  of 
milk  and  milk  products  (e.g.  Greece,  Austria),  with  strategies  having  a  more  complete 
justification for target groups’ selection based on the effects of the school scheme in terms 
of changing children’s eating habits and making sure that they increase the proportion of 
fruit and vegetables and milk and milk products in their diets in both the short and long 
term (e.g., Croatia, Portugal, Denmark, Poland, Bulgaria, Latvia), which was reinforced by 
information collected in the Case Studies.  

In the period under analysis, most of the children participating in the EU school scheme is 
in  the  six  to  ten-year-old  age  group  (average  of  71%  over  the  first  4  school  years). 
Nonetheless, the need to extend the age groups benefiting from the EU school scheme was 
mentioned  in  the  case  studies  (e.g.,  several  stakeholders  in  the  Netherlands,  such  as 
educational  establishments  and  civil  society,  consider  important  to  include  secondary 
schools in the EU school scheme, as the students tend to replace fruit and vegetables with 
lesser healthy food. Moreover, to guarantee a more durable increase of consumption, there 
should be a continuity from primary to secondary schools). This need is supported by the 
consideration that the sooner the children have regular access to healthier products, the 
better the results in integrating them in a constant and long-lasting way in their diets. This 
consideration is put forward by a number of systematic reviews of research evidence which 
emphasizes that early childhood intervention regarding good nutrition is essential to assure 
health  benefits  and  that  eating  habits  are  learnt  in  early  childhood  and  likely  to  be 
transferred into adulthood (Matwiejczyk  et al., 2018) (200). 

On the other hand, the importance of extending the distribution of this type of products to 
children  aged  over  10  years  was  also  mentioned  (i.e.,  Netherlands,  Croatia,  Czech 
Republic) , considering that after this age there may be a greater propensity to exclude 
these products from their diet, as there is more freedom of choice and there is an increased 
attractiveness of 'easy' products with higher levels of sugar, fat and carbohydrates.  

Nevertheless, it’s also at the age over 10 years that individual perceptions and awareness 

200  Matwiejczyk,  L.,  Mehta,  K.,  Scott,  J.,  Tonkin,  E.,  &  Coveney,  J.,  Characteristics  of  Effective  Interventions 
Promoting Healthy Eating for Pre-Schoolers in Childcare Settings: An Umbrella Review, Nutrients, 2018, 10(3), 
293. https://doi.org/10.3390/nu10030293.  

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start to gain shape, and it is important to cultivate the relevance of healthy eating habits 
(Appleton et al., 2016)(201) (e.g., the implementation of the school scheme in Croatia covers 
primary and secondary schoolchildren because a survey as shown that consumption of fruit 
and vegetables and milk and milk products decreases as students get older; in the Czech 
Republic, the school milk scheme applies only to primary school, and it was considered by 
the product  suppliers that it would be beneficial to include kindergartens and secondary 
schools, as all these age groups need dairy nutrition and instil healthy eating habits. It was 
also mentioned that secondary school students are relatively oriented towards “fast food”, 
which also leads to milk and dairy products being excluded from the diet. With the use of 
dairy products in secondary schools, it could still successfully educate this age group). 

No concrete assessment on the influence of these target groups on viable food production 
was given by any of the stakeholders consulted in the Case Studies, however, the collected 
information generally points out that younger children are more likely to assimilate eating 
habits,  and  older  children  are  more  likely  to  value  objectives  of  meeting  consumer 
expectations  as  they  are  more  potentially  more  attentive  to  social,  economic  and 
environmental aspects.  

Moreover, it is understood that, even if there exists a positive increase in the consumption 
of fruit and vegetables  and milk and milk products,  the potential to be  sustainable over 
time could increase if there would be a continuity from pre-schools to secondary schools. 
However, the MS considering that expanded target group in the school scheme is the best 
way to achieve long-term objectives experience limited budgetary allocation and the need 
to provide national aid (e.g., Slovenia). 

Besides, there is a combination of motivations behind eating habits, from individual taste 
and  pleasure  and  awareness  of  health  principles,  to  collective  aspects  including  school 
environment  and  family  attitudes  towards  eating  and  dietary  habits.  Factors  related  to 
childhood  experiences,  such  as  relation  with  the  school  scheme,  eating  habits  within 
families and recognition by the parents of the benefits of consuming these products, are 
crucial factors to determine a durable consumption.  

Between  the  factors  influencing  food  intake,  good  experiences  with  the  school  scheme 
(e.g.,  individual  preferences),  and  a  school  environment  effectively  promoting  healthy 
products (e.g.,  knowledge and  experiences gained from AEM) may influence greatly the 
eating habits in a durable way. In this sense, it can be stated that school is a privileged 
space for adjusting eating behaviors.  

Moreover,  the  ‘six  to  ten-year-old  children’  are  more  independent  and  going  through  a 
socialization process associated with the structuring of behaviors coming from learning and 
seeing  (interaction  with  others)  and,  so,  represent  adequate  recipients  for  educational 
measures. 

In this sense, and as the primary school stage constitutes a stable period of growth and 
physical  and intellectual  development,  these  school  years  represent  the  crucial  moment 
for the consolidation of healthy eating habits, which, if established at this early stage are 
difficult  to  change  in  adulthood  (Menor-Rodriguez  MJ  et  al.,  2022)  (202).  Also,  given  the 
importance  of  eating habits within  the family, a great deal of  encouragement should be 
expected from the family environment, and often this is not happening. 

201Appleton, K., Hemingway, A., Saulais, L., Dinnella, C., Monteleone, E., Depezay, L., Morizet, D., Perez-Cueto, 
F.,  Bevan,  A.,  Hartwell,  H.  Increasing  vegetable  intakes:  rationale  and  systematic  review  of  published 
interventions. European Journal of Nutrition. 55. 2016. 10.1007/s00394-015-1130-8. 
202Menor-Rodriguez  M.J.,  Cortés-Martín  J.,  Rodríguez-Blanque  R.,  Tovar-Gálvez  M.I.,  Aguilar-Cordero  M.J., 
Sánchez-García J.C., Influence of an Educational Intervention on Eating Habits in School-Aged Children. Children. 
2022; 9(4):574. https://doi.org/10.3390/children9040574. 

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In this regard, the overall perception collected in the case studies is that a longer and more 
consistent implementation of the EU school scheme, for example, with the increase in the 
frequency  supply  and  the  development  accompanying  educational  measures  not  only 
aiming  school  children,  but  also  aiming  teachers,  other  educational  professionals  and 
parents/families, could, eventually, amplify the contribution towards the desired objective 
of increased durable consumption. 

About the relevance attributed by the MS to accompanying educational measures, reflected 
by their expenditure level, in the period under analysis, the average Union aid spent with 
the accompanying educational measures was about 4.3% of the total expenditure of the 
EU school scheme. Ireland has the highest expenditure (15.0%), followed by Italy, Czechia, 
Finland with an expenditure between 12% - 14% range, but there were also MS that didn’t 
declare  any  expenditure.  It  should  however  be  taken  into  account  that  some  MS  use 
national  funds  for  these  measures  and  /  or  already  provide  activities  dedicated  to  this 
theme in regular school curricula (e.g., Netherlands and Sweden). 

The  supply  of  fruit  and  vegetables  and  of  milk  and  milk  products  by  itself  does  not 
contribute to raising awareness and increase knowledge about healthy eating habits and 
their benefits. The accompanying educational measures are considered a critical factor for 
increasing consumption and for durable consumption.  

Currently, school curricula include components dedicated to promote healthy eating habits. 
However, food education is considered to be dependent on the habits that prevail within 
the  family  and,  therefore,  a  wider  intervention  is  needed,  as  there  are  parents  not 
particularly well informed about the importance of introducing/increasing healthy habits in 
the children’s diet.  

Judgement criterion 4.2: The higher allocation of Union aid to less developed 
regions has led to more schools and children to be covered by the EU school 
scheme 

The criterion ‘level of regional development’, aims to ensure the possibility that higher aid 
can be allocated to the less developed regions, to the smaller Aegean Islands and to the 
outermost regions. Among the MS that could possibly apply this criterion, only two replied 
affirmatively to the PA survey (France and Spain).  

In the context  of the implementation of the Portuguese  EU  school scheme  strategy, the 
decision not to apply a higher allocation of Union aid to the outermost regions is due to 
two main reasons:  

  Autonomous Region of Azores would have capacity to respond to demand based on the 
regional production. For the milk part  of the EU  school scheme this is, in fact, more 
than  obvious  since  Azores  account  for  about  30%  of  the  total  milk  production  in 
Portugal.  For  the  F&V  part,  there  has  been  low  participation  of  educational 
establishments on some islands due to the difficulties in the supplying of fresh fruit and 
vegetables on the local market. 
In  the  Autonomous  Region  of  Madeira,  although  the  participation  in  the  EU  school 
scheme was discussed, the decision was made not to participate.  

 

In respect to France, according to the results of the PA survey, the amounts of the Standard 
Cost  Options (SCOs) for the overseas territories are based on the amounts of the  same 
costs calculated for metropolitan areas, adjusted by an indicator which takes into account 
the  difference  in  prices  to  import  products  (in  these  regions  eligible  products  are  often 
more expensive due to transportation costs).  

The establishment of flat rates by product in the French outermost regions is set out in the 
« Mise en œuvre du dispositif d’aide de l’Union européenne pour la distribution de fruits et 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

de  légumes,  de  bananes,  de  lait  et  de  produits  laitiers  dans  les  établissements 
scolaires »203. The method consists of taking into account an indicator used by the Office 
de développement de l’économie agricole d’outre-mer (ODEADOM)204, which is published 
each  year  in  the  annual implementation  report  of  the  Programme  of  options  specifically 
relating to remoteness and insularity (POSEI) France.  

In  the  information  collected  under  the  PA  survey,  the  estimate  of  the  difference  in  aid 
granted on average was approximately +11% in 2021/2022 for each SCO in the French 
overseas  territories  (corresponding  to  the  same  average  difference  for  the  products 
distributed under the school scheme - per kg of milk and milk products and per kg of fruit 
and vegetables).  

Still according to the PA survey, the main reasons which influenced the allocation of higher 
Union aid to those regions was to contribute to meet consumer expectations (e.g., organic 
products),  to  contribute  to  wider  implementation  of  the  school  scheme  and  to  increase 
consumption  of  agricultural  products  by  school  children.  The  strategy  for  the 
implementation  of  the  EU  school  scheme  in  France  also  mentions  the  objective  of 
diversifying  children's  dietary  habits  by  introducing  them  to  products  that  are  rarely  or 
never consumed, including changing regional habits (e.g., in the French outermost regions 
dairy products are rarely consumed). 

Moreover, lack of data  at regional level does not allow  to assess the contribution  of the 
higher  Union  aid  to  the  increase  of  the  coverage  of  the  EU  school  scheme  in  terms  of 
number of schools / children participating or to the viable food production objectives and 
interviewees  did  not  express  a  qualitative  assessment  on  this issue.  The  school  scheme 
managing authority however outlined that in Martinique local suppliers took part in the EU 
School Scheme, contributing to organising local distribution channels. 

Regarding Spain, the EU school scheme strategy mentions an increase by 20% of the price 
per kg of products distributed to schools in regions considered to be less developed (e.g. 
Extremadura),  and  a  complementary  aid  for  transport  expenses  in  the  case  of  products 
that are transported for more than 350 Km (e.g. for outermost regions as Canary Islands) 
(the complementary aid depends on the distance covered by the product distribution route: 
EUR 0.0726 /Kg  for  products  that  travel  more  than  350  Km  and  less  than  500  km; 
EUR 0.0953 /Kg for products that travel between 500 and 750 Km; and EUR 0.1083 /Kg 
for products that travel more than 750 Km)205. 

According to the primary information collected (Public Authorities survey and Case Study 
interviews) this supplementary Union aid made it possible compensate transportation costs 
of the products towards the outermost regions (maritime transport is much more expensive 
than  road  transport)  and,  this  way,  keep  the  attractiveness  for  the  operators  to  get 
involved  and  to  guarantee  that  all  regions  can  participate  in  the  EU  school  scheme. 
Nonetheless, the information collected on the field was not sufficient to assess the extent 
to which a higher Union aid contributed to increase the coverage of the EU school scheme 
in  terms  of  number  of  schools  /  children  participating  and,  therefore,  the  viable  food 
production  specific  objectives  by  the  increase  of  the  consumption  of  the  products 
distributed in the scope of the EU school scheme. 

203https://www.franceagrimer.fr/fam/content/download/64129/document/FAM%20décision%20LFE%20%20con
solidée%202020.pdf?version=3 . 
204 Indicator 2b): calculates the difference in import prices of products subsidized by the Specific Supply Scheme 
between the French overseas departments and France. 
205 Real Decreto 511/2017, de 22 de mayo, por el que se desarrolla la aplicación en España de la normativa de 
la Unión Europea en relación con el programa escolar de consumo de frutas, hortalizas y leche. 

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Judgement criteria 4.3: The transfers between milk and F&V budgets used by 
some  MS  have  contributed  to  improving  the  implementation  towards  the 
school scheme objectives related to viable food production  

With a view to ensuring the effective implementation of the school scheme, the Union aid 
for school fruit and vegetables and for school milk and milk products is allocated having as 
a basis the amounts required annually by each of the MS. Moreover, there is the possibility 
of transferring part of the budget for fruit and vegetables to milk, or vice versa206 to better 
adjust to the priorities and needs of the MS in implementing the EU school scheme.  

The possibility of transferring the Union aid between the two parts of the EU scheme was 
used by 14 MS over the four years of implementation of the school scheme (2017/18 to 
2020/21). 

The possibility of transfer of Union aid was mainly used from milk to fruit and vegetables 
in terms of number of transfers. This appear to be consistent with the already mentioned 
upward trend in the number of children participating in the fruit and vegetable’s part, in 
parallel with a significant decrease of the number of children participating in the milk part 
of the EU school scheme.  However, a significant part of the transfers is not used, whereas 
the amount of the transfers is not executed, mainly, in the case of the transfers made from 
fruit and vegetables to milk and milk products.  

There is no evidence that the transfers affected the supply/distribution in either part of the 
school  scheme.  Indeed,  it  should  be  noted  that,  only  around  15%  of  the  total  amount 
transferred from the milk part to the F&V part of the school scheme in the period under 
analysis, was used. In the case of transfers from the F&V to the milk part, to be noted the 
transfers made by France of almost EUR 4.5 million each year. The information collected 
in the PA survey mentions a decision for the reallocation of Union aid based on the need 
to establish equivalency in the budgets available for F&V and milk in view of achieving an 
equal  contribution  to  increase  consumption  of  agricultural  products  by  school  children. 
However, the amount of these transfers was not used.  

206 In case the transfer of more than 20% and up to 25%, MS have to motivate it. Only Malta asked for a transfer 
of more than 20% in the first school year. Malta justification was related to the need of more time for a successful 
transition from the previous school milk scheme to the current scheme and that part of the resources foreseen 
for milk would have been better utilised under the F&V part of the current scheme. 

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Table 5: Transfers of Union aid between school fruit and vegetables and school milk 

MS 

2017/2018 

2018/2019 

2019/2020 

2020/2021 

Euro 

Euro 

Euro 

Euro 

Main reason for the 
transfers 
(source: PA survey) 

Belgium 

22 450 

37 529 

37 529 

37 529 

Denmark 

2 987 

Germany 

451 361 

177 929 

384 706 

162 902 

Ireland 

117 052 

Spain 

1 575 696 

1 114 961 

165 874 

Higher demand for F&V than 
for  milk  at  the  schools  in 
proportion to the allocation. 

Underutilisation 
budget 
and 
funds in F&V. 

of  milk 
insufficient 

National/regional 
authority restrictions. 

health 

Use or non-use for the 
transferred amounts 

The  amount  of  the  transfers 
made  from  the  milk  part  to 
the F&V part was not used. 

The  amount  of  the  transfers 
made  from  the  milk  part  to 
the F&V part was not used. 

The amount of the transfers, 
reinforcing  the  Union  aid  for 
F&V  part  of  the  scheme  was 
used  in  2018/2019  but  not 
in 
used 
2017/2018,2019/2020  and 
2020/2021 

The  amount  of  the  transfer 
made  from  the  milk  part  to 
the  F&V  part  was  used  at 
60%. 

The amount transferred from 
the milk part to the F&V part 
of  the  scheme  was  used  at 
30%  in  2017/2018  but  not 
used 
in  2018/2019  and 
2019/2020 

France 

4 497 617 

4 497 617 

4 497 617 

4 497 617 

Cyprus 

100 044 

100 044 

100 044 

100 044 

Establish equivalency in the 
budgets for F&V and milk in 
view  of  achieving  equal 
contribution to consumption 
of agricultural products. 

The  amount  of  the  transfers 
made  from  the  F&V  part  to 
the milk part was not used. 

The  amount 
transferred 
from  the  milk  part  to  the 
F&V part of the scheme was 
used  at  82%  in  2018/2019 
and at 60% in 2020/2021. 

The amount transferred from 
the milk part to the F&V part 
of  the  scheme  was  not  used 
in  2017/2018,  used  at  82% 
in  2018/2019,  not  used  in 
2019/2020 and used at 60% 
in 2020/2021. 

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Luxembourg 

4 000 

30 000 

35 000 

40 950 

A slower uptake for milk and 
milk product than expected.  

Malta 

48 250 

- 

Netherlands 

480 212 

480 212 

480 212 

480 212 

- 

Austria 

112 546 

130 000 

150 000 

Higher demand for fruit and 
vegetables than milk. 

Portugal 

426 842 

- 

The amount transferred from 
the milk part to the F&V part 
of  the  scheme  was  totally 
used. 

The amount transferred from 
the milk part to the F&V part 
of the scheme was not used. 

The amount transferred from 
the milk part to the F&V part 
of  the  scheme  was  used  at 
27%  in  2017/2018,  70%  in 
2018/2019 and in 2019/2020 
and 2020/2021not used. 

The  amount  of  the  transfers 
made  from  the  milk  part  to 
the F&V part was not used. 

The  amount  of  the  transfers 
made  from  the  F&V  part  to 
the milk part was not used. 

Romania 

1 373 370 

1 373 370 

Sweden 

570 994 

570 994 

570 994 

570 994 

Transfers M to FV 

(9) = 2 911 611 

(7) = 2 070 675 

(7) = 1 353 365 

(6) = 824 354 

Transfers FV to M 

(4) = 6 868 823 

(3) = 6 441 981 

(2) = 5 068 611 

(2) = 5 068 611 

many 
were 
There 
Contracting authorities (City 
councils)  which  opted  for  a 
milk  distribution  of  5  days 
per/ week.  

The  amount  of  the  transfers 
made  from  the  F&V  part  to 
the  milk  part  was  totally 
used. 

Sweden  does  not  apply  the 
fruit  and  vegetable  part  of 
the school scheme. 

The  amount  of  the  transfers 
made  from  the  F&V  part  to 
the milk part was not used. 

Source: Working documents presented to the MS’ delegates in the Committee for the common organisation of the agricultural markets, animal products 

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4.1.4.3  Conclusions  

ESQ4 asks to assess to what extent the achievement of the EU school scheme in relation 
to the CAP general objective of enhancing viable food production was influenced by: 

a)  the criteria set out in the EU school scheme regarding the allocation of the Union aid to 
each  MS:  the  number  of  six  to  ten-year-old  children  and  the  level  of  regional 
development; 

b)  the possibility given to MS of making adjustments on the allocation of the Union aid 

between the F&V part of the EU school scheme and the milk part.  

In relation to ESQ4a), the EU school scheme regulation defined a criterion related to the 
targeting of aid by MS taking into account the number of six- to ten-year-old children in 
the MS concerned. This is to ensure the consumption of fruit and vegetables and of milk 
and milk products at the stage when children eating habits are being formed, with a view 
to durably increasing the share of those products in their diets. 

The results of the analysis highlight that, in the period under analysis, most of the children 
participating in the EU school scheme belong to the six to ten-year-old age group (average 
of 71% over the first 4 school years).  

Although not focusing on objectives related to viable food production, it can be considered 
that the target group “six to ten-year-old children” is the one with the higher potential to 
contribute to an increased and durable consumption, therefore, contributing to the viable 
food production objectives, particularly by stabilising markets and ensuring the availability 
of both current and future supplies, therefore positively influencing the agricultural sector 
(in general, to maintain the demand of the agricultural products, at least, those distributed 
by the EU school scheme).  

Notwithstanding, the establishment of a share of fruit and vegetables  and milk and milk 
products  in  diets  corresponding  to  daily  needs  demands  a  long-term  ‘involvement’ of 
children  and  a  more  prolonged  and  systematic  distribution  of  such  products  across  age 
groups.   

Also,  the  overall  perception  collected  in  the  case  studies  is  that  the  accompanying 
educational  measures  are  a  critical  factor  for  increasing  consumption  and  for  durable 
consumption. Concerning the relevance given by MS to these measures, reflected by the 
expenditure level, it is noted that, in the period under analysis, the average Union aid spent 
was about 4.3% of the total expenditure of the EU school scheme. The analysis suggests 
that better results might be attained with enhanced accompanying measures adapted to 
age  groups  and  involving  not  only  school  children  but  also  teachers,  other  educational 
professionals and also families. 

Indeed,  it  is  believed  that  maintaining/increasing  fruit  and  vegetables  and  milk 
consumption  depends  also  on  food  education  provided  by  parents/families  and  on  more 
consistent  and  frequent  use  of  accompanying  educational  measures,  not  only  aimed  at 
target  groups  benefitting  from  EU  school  scheme,  but  in  a  broader  manner  covering  all 
target groups.  

The second criterion, ‘level of regional development’ gives the possibility that higher aid 
can be allocated to the less developed regions, to the smaller Aegean Islands and to the 
outermost regions. Among the MS that could possibly apply this criterion, two (France and 
Spain) actually did so. The results of the evaluation do not allow to draw a clear conclusion 
of the effectiveness of this criterion, as there is not enough detailed information to allow 
an  assessment  of  whether  the  option  for  higher  allocation  of  Union  aid  has  led  to  the 
increase  of  the  consumption  of  the  products  distributed  by  the  EU  school  scheme  and, 
therefore, to contribute to the specific objectives related to viable food production.  

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In relation to ESQ4b), the possibility of transfers of Union aid was mainly used from the 
milk part to the F&V part of the EU school scheme to cope, presumably, with the increase 
in the number  of children participating in the fruit and vegetables part of the  EU school 
scheme that goes in parallel with a decrease of the number of children participating in the 
milk part. Transfers from the F&V part to the milk part have been used by a limited number 
of MS but the amounts transferred are higher.  

Nevertheless, in almost all cases the amounts transferred, have been used only partially 
or not used at all and therefore have not contributed to the objectives of the  EU school 
scheme of increasing the distribution of F&V and milk and milk products to children. 

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4.2  Effectiveness 

4.2.1  ESQ5 - To what extent has the EU school scheme contributed to the 
common  agricultural  policy  general  objective  of  viable  food 
production? 

4.2.1.1  Background and methodological approach  

Understanding 

The  Union  aid  provided  under  the  EU  school  scheme  should  originate  positive  results  in 
terms  of  increasing  the  share  of  fruit  and  vegetables  and  milk  and  milk  products  in 
children’s diets, and maintain it over time. A sustained increase in consumption/demand 
of the products concerned can act as an important factor to stimulate and, thus, to leverage 
the stability of the relative markets, also taking into account consumers’ expectations. 

Because there are so many and varied factors influencing the effectiveness of the EU school 
scheme in contributing to the CAP general objective of viable food production, the current 
analysis embraces also a recapping nature, benefiting from the outcomes of previous ESQs 
which, notwithstanding the constraints described, are the result of a team effort that was 
able to honor the importance of the EU school scheme as well as the commitments assumed 
with this Report. 

Definition of key terms 

Viable food production is one of the three general objectives of the CAP focusing in 
particular  on  the  specific  objectives  of  increasing  and  stabilising  agricultural  income, 
increasing  the  competitiveness  of  the  agricultural  sector  and  maintaining  market 
stability.  It  is  understood  as  the  context  where  market  conditions  increase  the  value 
share of agricultural production in the food chain, enhance farm income and limit farm 
income variability, improve competitiveness of the agricultural sector. 

Market  stability  means  when  markets  operate  without  concern  about  unpredictable 
fluctuations  (e.g.,  variability  of  supply  and  demand),  this  context  promotes  efficiency 
and long-term growth by allowing more reliable economic decisions. 

Farm  income  means  the  total  output  (total  production  value),  plus  direct  payments 
minus intermediate consumption in farms. 

Regulatory background for indicative and definitive allocations and reallocation 
of Union aid for school scheme:  art. 23(a) of Regulation (EU)  No 1308/2013, 
art.  5  of  Regulation (EU) N 1370/2013;  Art.  3  and  Art.  7  of 
Regulation (EU) 2017/39 

From 1 August 2017 until 31 July 2023207, the indicative allocations of the aid for each 
MS  are  those  set  out  in  Annex  I  of  Regulation (EU) N 2016/795  amending 
Regulation (EU) N 1370/2013.  using  the  criteria  laid  down  in  Article  23a(2)  of 
Regulation (EU) N 1308/2013 (number of six to ten-year old children, level of regional 
development and, for milk, historical use of the aid).  

MS submit by 31 January each year their request for Union aid relating to the next school 
year (indicative allocation) and, if applicable, update the request for Union aid relating 
to the ongoing school year.  

207From 1 August 2023, the Commission shall fix, on the basis of the same criteria, the indicative allocations to 
each MS of the aid. The Commission shall subsequently assess at least every 3 years whether those indicative 
allocations remain consistent with the criteria and, where necessary, shall fix new indicative allocations. 

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The Commission shall reallocate that indicative allocation or the unrequested part thereof 
to those MS who have notified it of their willingness to use more than their indicative 
allocation.  The  reallocation  is  based  on  the  criteria  referred  to  in  Article  23a(2)  of 
Regulation (EU) N 1308/2013  (number  of  six  to  ten-year  old  children,  the  level  of 
regional development and, for milk, the historical use of the aid) and limited according 
to the level of use of the definitive allocation of Union aid by the MS concerned for the 
school year that ended prior to the annual request for Union aid. 

Following  the  requests  submitted  by  the  MS,  the  Commission  each  year  adopt 
implementing acts fixing the definitive allocation of aid for school fruit and vegetables 
and for school milk among participating MS. 

Judgement criteria, indicators and sources 

The answer to this ESQ is based on the judgement criteria and indicators systematized in 
the following table. 

Criteria 

Indicators 

Sources 

JC5.1:  EU  school  scheme 
implementation  contributed 
to increase the consumption 
of  agricultural  products  by 
schoolchildren 

5.1.1  Financial  execution  of  the  EU 
school scheme (%) 
5.1.2  Coverage  of  the  EU  school 
scheme (number of schoolchildren) 
5.1.3  Coverage  of  the  EU  school 
scheme  in  relation  to  the  target 
groups set out in the Regulation (%) 

-  EU school scheme strategies 2017-2023 
-  Financial  data  Commission’s  overview 
based  on 
the  MS'  declarations  of 
expenditure  sent  to  the  Commission 
of 
to 
according 
Regulation (EU) N 908/2014 

Article 

10 

-  EU school scheme monitoring data 
-  Public Authorities Survey 
-  Structured interviews in CS MS/regions 
-  Results of ESQ1 

JC5.2:  EU  school  scheme 
choices 
implementation 
have  contributed 
to  an 
increase  of  consumption  of 
agricultural  products  by 
children,  ensuring 
future 
demand 

JC5.3:  EU  school  scheme 
implementation  choices  led 
to  a  positive  influence  in 
relation 
specific 
to 
objectives  related  to  the 
CAP  general  objective  of 
viable food production 

5.2.1  Direct  consumption  of  the 
selected products by children 
5.2.2  Indirect  consumption  of  the 
selected products by children   

-  EU school scheme strategies 2017-2023 
-  Public Authorities Survey 
-  Structured interviews in CS MS/regions 
-  EU school scheme monitoring data 
-  Results of ESQ1 and ESQ2 

5.3.1  Evolution  of  the  quantities  of 
the supplied products under the EU 
school scheme  
5.3.2 Total market volume / share of 
the products supplied under the EU 
school scheme  
5.3.3  Change  in  the  farms’  income 
levels 
5.3.4 Change in the diversification of 
the agricultural market 

-  EU school scheme strategies 2017-2023 
-  EU school scheme monitoring data 
-  Public Authorities Survey 
-  Structured interviews in CS MS/regions 
-  Statistics 

and 
Agriculture  Organization  of  the  United 
Nations (FAOSTAT) 

division 

Food 

of 

Methodological approach and its limitations 

Tools, method and sources used 

The  first  step  of  the  analysis  verified  whether  the  national/regional  strategies  for  the 
implementation of the EU School Scheme 2017–2023 targeted the CAP general objective 
of enhancing viable food production. 

Moreover,  the  analysis  revealed  not  only  the  absence  of  specific  objectives,  but  also,  a 
general lack of information and data (e.g., indicators and measurable targets) to support 
an effective assessment of the contribution of the EU School Scheme towards achieving 
the CAP general objective of enhancing viable food production. 

With  this  background,  for  answering  ESQ  5,  was  deemed  necessary  to  explore  which 
aspects of the implementation of the EU School Scheme that, in light of the intervention 

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logic, may have contributed, both directly or indirectly, to achieving the specific objectives 
of viable food production. 

The interpretation of the most appropriate way to ensure the robustness of the answer to 
this  ESQ,  led  to  an  approach  based  on  the  integration  of  qualitative  information  and 
quantitative data from different data sources.  

Besides making use of EU School Scheme monitoring and statistical data and other relevant 
available  information,  the  evaluation  entailed an  extensive  process  of  data  collection  by 
means  of  different  tools,  of  which  the  PA  survey  and  the  CS  countries/regions  are 
particularly noteworthy. These data collection tools contained concrete questions regarding 
the effectiveness of the EU School Scheme towards achieving CAP’s key-policy objective of 
enhancing viable food production (e.g., the informed opinion of the respondents on the EU 
School Scheme effectiveness in increasing children’s consumption of fruit, vegetables, milk 
and milk products and enhancing viable food production in the respective country/region 
in relation to the products distributed in schools). 

Furthermore, the many and varied factors that influence the effectiveness of the EU School 
Scheme's contribution to the CAP overall objective of viable food production, required the 
integration  of  several  elements  of  analysis.  In  this  sense,  the  answer  to  this  ESQ  also 
benefits from the outcomes of previous ESQs, namely, to assess: 

  whether  and  the  extent  to  which  the  EU  school  scheme  contributed  to  increase  the 
direct  and  indirect  consumption  of  fruit  and  vegetables  and  milk  and  milk  products, 
furthering, this way, a long-lasting increase of their consumption / demand; 
factors that may have leveraged or limited the implementation of the EU school scheme 
and  respective  contribution  to  achieving  the  CAP  general  objective  of  viable  food 
production. 

 

The  answer  to  this  ESQ  was  largely  based  on  the  analysis  of  qualitative  information 
collected  from  various  sources.  Triangulation  and  cross-verification  of  the  collected 
information  were  assured  throughout  the  analysis.  Quantitative  information  was 
incorporated whenever available, ensuring the robustness of the results. 

Limitations of methods and sources 

Despite  the  great  efforts  made  in  exploring  and  collecting  information  from  different 
sources, it became apparent the insufficiency of supporting quantitative elements to carry 
out a robust  evidence-based  evaluation. In respect to the structured  interviews  with EU 
school scheme stakeholders in the scope of case studies, the consultation provided relevant 
information, however, it was revealing of the difficulty in contributing with concrete data 
and information based on previous reflections. 

In addition, the difficulty in complementing the analysis with findings from other studies of 
from  literature.  Although  recognizing  the  importance  of  this  exercise  to  deepen  and 
substantiate the evaluation viewpoints, no recent material was found. 

Moreover, the EU School Scheme represents a limited share both in terms of market share 
(quantity of products distributed compared to the quantity of products produced in the MS) 
and in terms of financial support (volume of financial support compared with other policy 
interventions  contributing  to  the  same  objective  of  viable  food  production,  in  particular, 
direct payments).  

With regard to the EU school scheme monitoring data that can be used as support for this 
purpose,  one  important  limitation  is  the  absence  of  information  concerning  quantities 
distributed and effectively consumed by children, per type of fresh fruit and vegetables. 
Although the list of products supplied / distributed is provided in the monitoring reports 
(cf. Section 4.1), their quantities are not specified (cf. Section 4.6) since the information 

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is  not  requested  with  such  a  detail.  The  structure  /  template  defined  for  the  Monitoring 
reports, only requires the disaggregation between fresh and processed, and between fruit 
and vegetables. Peculiarly, more itemized information is required about processed fruit and 
vegetables, which do not have a relevant weight in the products distributed / supplied. 

4.2.1.2  Analysis 

Judgement  criterion  5.1:  EU  school  scheme  implementation  contributed  to 
increase the consumption of agricultural products by schoolchildren  

Financial execution of the EU school scheme (%)208 

The EU school scheme operates within the same legal and financial framework; however, 
the respective budget is maintained separately, although, with the possibility of transfers 
from  the  fruit  and  vegetables  part  of  the  EU  scheme  to  the  milk  part,  or  vice  versa, 
depending on the priorities and needs. The overall total financial allocation for the EU school 
scheme  was  EUR 250 million  per  school  year  for  the  years  2017/2018  to  2019/2020, 
EUR 245.1 million for the year 2020/2021 and EUR 220.8 million for the years 2021/2022-
2022/2023 after the withdrawal of the UK from the EU. The financial allocation is broken 
down  by  fruit  and  vegetables  (F&V)  and  milk209.  The  definitive  allocation  per  MS  is 
calculated on the basis of the criteria mentioned in the previous ESQ4.  

The milk part of the EU School is applied in all MS and the United Kingdom (with the only 
exception  of  Germany-Saarland  that  implements  only  the  F&V  part  of  the  scheme), 
whereas the F&V part is not applied in Sweden, the United Kingdom and in Germany-Berlin 
and Brandenburg and Hessen.  

The main beneficiaries in terms of Union aid allocation were Germany, Italy, France and 
Poland,  which  together  make  up  51.5%  of  the  total  Union  aid,  while  Estonia,  Ireland, 
Croatia, Cyprus, Latvia, Lithuania, Luxembourg, Malta and Slovenia, altogether represent 
just 5.5%.  

The average financial execution of the EU School Scheme for the four school years under 
analysis in terms of total Union aid allocation and expenditure is of 69.7%, and consistently 
under-utilised over the years in analysis. The financial execution varies significantly across 
the  27  MS  plus  United  Kingdom  (considered  for  all  implementation  years,  except  for 
20/21),  from  a  minimum  of  7.4%  in  France  and  a  maximum  of  100.0%  in  Latvia  and 
Estonia.  

Within this range, most  MS are positioned with a financial execution above EU average, 
while eight are below the average, with France, Greece and Portugal well below the average 
(7.4%, 33.7% and 43.3%, respectively), and with only a small number of MS using 90% 
or  more  of  the  allocated  Union  aid  (Bulgaria,  Czechia,  Estonia,  Latvia,  Lithuania, 
Luxembourg, Hungary and Slovakia). The main reasons for the different financial execution 
are described in 2.2.4. of this Report.  

Besides Union aid, most of the MS added also National aid for the implementation of the 
EU  School  Scheme.  Nine  MS  do  not  allocate  additional  national  aid  (Denmark,  Greece, 
France,  Italy,  Cyprus,  Austria,  Portugal,  Finland  and  Sweden).  The 
level  of 
representativeness of this amount in the total aid expended (Union and national) differs 
among  MS,  accounting for  a  maximum  of  around  65%  in  Czechia,  Hungary  and  Austria 
and  around  50%  in  Bulgaria,  Latvia,  Malta,  Poland,  Romania,  Slovakia  and  the  United 

208(Expenditure for the supply/distribution of products + Expenditure for the educational measures + Expenditure 
for information, monitoring and evaluation) in relation to the total Union aid for the school scheme. 
209Following the withdrawal of the United Kingdom from the EU, the total EU budget for the scheme amounts to 
EUR 220.8 million  per  school  year,  consisting  of  up  to  EUR 130.6 million  for  fruit  and  vegetables  and  up  to 
EUR 90.1 million for milk, as established in Regulation EU N 2021/2117 (in force from 1st January 2021). 

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Kingdom.    Generally,  the  MS  with  Union  aid  expenditure  above  90%  also  use  higher 
national aid.   

In order to maximize the use of available funds, besides the pursuit of a more targeted 
use  of  Union  aid  given  by  the  possibility  of  making  transfers  between  the  financial 
allocations for school fruit and vegetables and for school milk in accordance to MS specific 
contexts, the Commission adopts measures to reallocate unrequested Union aid between 
the MS participating in the school scheme that have notified their willingness to use more 
than their available allocation.  

Regarding  this  issue,  it  should  be  noted  that  there  is  a  set  of  MS  with  a  relatively  low 
financial execution, but most of them are not usually in the condition of "unrequested union 
aid",  and  there  is  a  set  of  MS  that,  on  the  contrary,  demonstrate  systematically  their 
willingness  to  use  more  than  their  indicative  allocation  (closer  to  the  amount  those  MS 
initially requested). 

Focusing  the  analysis  on  the  MS  which,  in  the  period  under  analysis,  had  a  financial 
execution above 90% (Bulgaria, Czechia, Estonia, Latvia, Lithuania, Luxembourg, Hungary, 
Slovakia), the pattern is as follows: 

  a definitive allocation well below the requested allocation; 
  willingness to use more than their indicative allocation; 
  unrequested amounts much lower than the reality of financial execution for a number 

of MS; 

  definitive allocation to continue lower than the allocation requested. 

In  all  the  MS  with  financial  execution  above  90%,  in  addition  to  Union  aid,  they  grant 
national aid for the financing of the school scheme. The evaluation traced the path of two 
of these countries (with dissimilar number of children participating in the school scheme): 
Estonia with about 200 thousand children and Czechia with about 900 thousand children. 

Table 6: EU school scheme: calculation of the definitive allocation of Union aid for the 
2020/2021 school year 

Czechia 

Total allocation requested 
Indicative allocation 
Request additional amount 
Reallocation 
Definitive allocation  
Union aid execution 
National aid 

Estonia 

Total allocation requested 
Indicative allocation 
Request additional amount 
Reallocation 
Definitive allocation  
Union aid execution 
National aid 

2017/2018  2018/2019  2019/2020  2020/2021 
Euros 

4 989 013 
4 082 903 
906 110 
23 895 
4 106 798 
100 
7 155 937 

5 934 264 
3 956 176 
1 978 088 
150 315 
4 106 491 
100 
7 465 052 

5 830 940 
3 974 570 
1 856 370 
188 690 
4 163 260 
100 
6 252 714 

7 856 164 
3 123 230 
4 732 934 
13 996 
4 480 135 
100 
6 796 753 

2018/2019 

2019/2020 
Euros 

2020/2021 

912 777 
547 336 
365 441 
19 521 
566 857 
100 
424 363 

980 356 
549 208 
431 148 
24 390 
573 599 
100 
242 559 

947 290 
439 163 
508 127 
1 812 
542 176 
100 
315 629 

Source: Working documents presented to the MS’ delegates in the Committee for the common 
organisation of the agricultural markets, animal products; Annual Monitoring reports. 

If  an  analysis is  made  using the  totals  of  requested  and  unrequested  amounts  of  Union 
aid, and links this to the total of the EU school scheme Union aid that was not used in each 

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year,  it  is  possible  to  understand  that  the  financial  execution  of  the  EU  school  scheme 
would be more effective if the amounts not used by some MS were used by others which 
demonstrate willingness to use more than their indicative allocation. 

Table 7: EU school scheme – Union aid requested and unrequested 

Union aid – EU school scheme 

2017/2018  2018/2019  2019/2020  2020/2021 
Euros 

Request additional amount 

14 179 928 

24 922 356 

21 297 496  90 321 230* 

Unrequested amount (reallocated) 

425 000 

2 230 727 

2 628 485 

2 283 977 

Union aid not used 

32 329 056 

25 681 905 

52 054 194 

47 717 422 

* Before capping as relevant. 
Source: Working documents presented to the MS’ delegates in the Committee for the common organisation of 
the agricultural markets, animal products. 

Coverage of the EU School Scheme (number of children and in relation to the target 
group set out in the Regulation) 

The EU school scheme covers a significant number of children. The summary monitoring 
reports indicate that, in the period under analysis, the EU school scheme promoted healthy 
eating  habits  and  the  consumption  of  local  products,  supplying  selected  agricultural 
products to approximately 19 million children in educational establishments across the MS 
(less in 2020/2021 due to the COVID-19 pandemic). 

Table 8: Children participating in the EU school scheme (number)* 

Type of educational establishment  2017/2018  2018/2019  2019/2020  2020/2021 

Nurseries/Pre-schools  

3 648 747 

3 125 274 

3 264 560 

3 048 342 

Primary schools  

Secondary schools  

Total  

14 423 978  14 382 892  14 097 264  11 347 566 

2 210 625 

1 905 143 

1 734 072 

1 561 238 

20 283 350  19 413 309  19 095 896  15 957 146 

* In some countries, estimate as the exact number is not/not easily available 
Source: School scheme monitoring report summaries 

Notwithstanding the significant number of children benefited by the EU school scheme, the 
most recent available official data210 show that, altogether, there were around 74.8 million 
pupils and students enrolled in the education levels established as target group in the EU 
school  scheme.  This  means  that  the  EU  school  scheme  covers  only  about  25%  of  the 
children who regularly attend educational establishments of MS (21% nurseries and pre-
schools, 60% of primary schools and 5% of secondary-level schools).   

However, at MS level, important differences are observed. Namely, the very low degree of 
coverage achieved in France (3.5% out of a target of 12 000 000 children)211, which has a 
significant effect on the coverage rate at general level: without France, the MSA ratio rises 
from 35.1 to 53.5 % (average of the four years).  

Based  on  annual  monitoring  data,  from  2017/18  to  2020/21,  the  number  of  children 
participating in the EU School Scheme at EU-27 level has decreased by 14.2%: -14.9% in 
nurseries/pre-schools; -11.4% in primary schools; -29.2% in secondary schools.  

210Pupils and students enrolled by education level (EUROSTAT, 2022). 
211France has experienced a series of difficulties that have hampered the implementation of the scheme. Based 
on  information  collected  in  case  study  MS  and  regions,  main  issues  are  related  to:  administrative  burden 
(administrative procedures have been simplified in February 2020 but the results might not yet be visible due to  
the  COVID  crisis),  overlapping  between  products  delivered  by  the  EU  scheme  and  products  already  delivered 
during lunchbreaks; restrictions on distribution times; collective catering already well-structured and the school 
scheme is perceived as adding complexity to the existing organisation of schools. 

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In terms of number of children in the two parts of the school scheme, it should be noted a 
slight increase of the average number of children participating in the fruit and vegetables 
(3,6%) and a decrease participating in the milk part of the EU school scheme (10,4%). 
This gives notice of a shift shared by most MS from the milk and milk products to the fruit 
and vegetables part of the school scheme.  

Furthermore,  the  analysis  also  considers  the  frequency  of  the  supply  of  agricultural 
products in the schools, as the habits are driven by repetition. Research on habit formation 
has shown that behaviour is likely to become habitual when it is frequently and consistently 
performed in the same context212. In the school year 2020/2021 only 3 MS distributed fruit 
and vegetables on a daily basis, and 5 MS supplied milk every day.  

Nevertheless,  there  would  not  be  sufficient  resources  in  the  current  EU  school  scheme 
budget to extend it in a way to achieve the supply of school fruit and vegetables and of 
school milk, accompanying educational measures and related costs, i.e., to cover all the 
children in educational establishments of MS. 

Judgement  criterion  5.2:  The  consumption  of  agricultural  products  by 
children under the EU school scheme has increased, ensuring future demand  

Direct consumption of the selected products by children 

Although most Public Authorities that replied to the questionnaire stated that the EU school 
scheme has been effective in attaining the objective of increasing children’s consumption 
of fruit, vegetables, milk and milk products, the analysis carried out within the scope of 
the present evaluation (e.g., under ESQ 1) has revealed a rather different perspective. 

In what regards the results of the PA survey, the perception on the effectiveness of the EU 
school  scheme  in  attaining  the  objective  of  increasing  children’s  consumption  varied 
according to the type of products distributed, as follows: 

 

 

 

 

consumption of fresh fruit and vegetables (26 responses): considered very effective by 
30.8%,  somewhat  effective  by  61.5%  and  very  little  effective  by  7.7%  of  the 
respondents; 
consumption  of  processed  fruit  and  vegetables  (12  responses):  considered  very 
effective by 25%, somewhat effective by 41.7% and very little effective by 33.3% of 
the respondents; 
consumption of milk (28 responses): considered very effective by 21.4%, somewhat 
effective by 64.3% and very little effective by 14.3% of the respondents; 
consumption  of  milk  products  (20  responses):  considered  very  effective  by  20.0%, 
somewhat effective by 60.0% and very little effective by 20.0% of the respondents. 

According to the answer provided in ESQ 1 (see 4.1.1, Judgement criterion 1.2), there has 
been a decreasing quantity of products distributed per child. Taking into account that not 
all  the  quantities  distributed  are  actually  consumed,  it  can,  therefore,  be  reasonably 
assumed that children are consuming a lower quantity of agricultural products under the 
school scheme (direct consumption).  

Nonetheless, the results of the family survey revealed a positive, although slight, difference 
in consumption between children participating and not participating in EU School Scheme 
(see 4.1.1). 

212Van der Weiden A., Benjamins J., Gillebaart M., Ybema J.F. and de Ridder D. ( How to Form Good Habits? A 
Longitudinal  Field  Study  on  the  Role  of  Self-Control  in  Habit  Formation. Front.  Psychol. 11:560,  2020.  doi: 
10.3389/fpsyg.2020.00560. 

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Indirect consumption of the selected products by children 

In respect to ensuring future demand, the assumption is that this depends on the change 
of attitudes and behavior towards the consumption of fruit and vegetables and milk and 
milk products outside the school scheme (indirect consumption).  

In general, the analysis shows a positive but extremely limited effect. Overall, the results 
show  a  maintenance  of  the  attitude  of  children  participating  in  the  EU  school  scheme 
towards fruits, vegetables, milk and milk products (see  4.1.2, JC 2.4). Moreover, it was 
also  found  a  relative  inability  of  the  stakeholders  involved  in  the  evaluation  process  to 
specifically and concretely assess the influence of the school scheme on the level of intake 
of milk and milk products and fruit and vegetables by children. Indeed, the stakeholders 
consulted in the Case Studies stated the difficulty in assessing the contribution of the EU 
school  scheme  to  increase  the  consumption  of  agricultural  products  by  children,  and 
greater  difficulty  when  it  comes  to  assessing  future  demand  by  changing  children’s 
attitudes towards fruits, vegetables, milk and milk products.  

Nonetheless, the overall perception is that a wider and more effective implementation of 
the  EU  school  scheme  could,  eventually,  amplify  the  contribution  towards  the  desired 
objective. It is understood that regular consumption of agricultural products within families 
and the recognition by children of the benefits of consuming these products, are  crucial 
factors.  

This  reinforces  the  importance  of  developing  accompanying  educational  measures  in  a 
more frequent and coherent manner, not only aiming at children benefiting from the EU 
school  scheme,  but  also  aiming  at  teachers  and  other  educational  professionals  and 
parents/families. In fact, one of the factors considered critical for achieving an increased 
long-lasting consumption of agricultural products is the awareness and knowledge about 
healthy eating habits. 

An additional perspective reflects on what would happen in the absence of the EU school 
scheme. The results of the PA survey show that MS / regions: 

  would not be able to distribute fresh fruit and vegetables, milk and milk products in 

schools (just over 60% of the responses); 

  would  not  be  able  to  distribute  processed  fruit  and  vegetables  (nearly  80%  of  the 

responses). 

Judgement  criterion  5.3:  The  EU  school  scheme  implementation  led  to  a 
positive influence in relation to specific objectives related to the CAP general 
objective of viable food production 

The analysis comprised under this JC was based on the mechanism through which national 
strategies may ensure the contribution to viable food production, this is, in what way the 
implementation of the school scheme encourage in particular local or regional purchasing, 
organic products, short supply chains, or consider prioritizing sustainability and fair-trade 
considerations, among other criteria. 

In addition, the perspective of market share will also be included, having in account the 
weight of the quantities of the products supplied compared to the total market quantities, 
and the significance of this market measure in relation to other interventions contributing 
to the same objective.  

The analysis carried out on the results of the Public Authorities survey and of Case Study 
interviews converge on the overall perspective that the implementation of the EU school 
scheme  has  no  significant  influence  in  relation  to  specific  objectives  related  to  the  CAP 
general  objective  of  viable  food  production.  In  fact,  when  asked  to  classify  the  level  of 
effectiveness  of  the  EU  school  scheme  in  contributing  to  a  viable  food  production, 

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considering the products distributed in schools, most of the respondents stated ‘very little 
effective’ and, in a lesser but still relevant proportion, ‘not at all effective’. 

Table 9: Opinion of Public Authorities on whether the EU school scheme has been 
effective in contributing to a viable food production in the respective MS/region 

Specific objectives 
related to CAP general 
objective of VFP 
Contribution to 
Maintain market stability 
Meet consumer 
expectations 
Farmers’ income 
Stability of farm incomes 
Improve competitiveness 
of agricultural sector 

Fruit and vegetables 

Milk and milk products 

Very and 
somewhat 
effective 
28.0% 

Very little and 
not effective at 
all 
72.0% 

Very and 
somewhat 
effective 
22.2% 

Very little and 
not effective at 
all 
77.8% 

36.0% 

44.0% 
32.0% 

32.0% 

64.0% 

56.0% 
68.0% 

68.0% 

37.0% 

44.4% 
33.3% 

29.6% 

63.0% 

55.6% 
66.7% 

70.4% 

Note: opinion asked in relation to the products distributed in schools. 
Source: own elaboration based on the survey to Public Authorities. 

Evolution of the quantities of the supplied products under the EU school scheme and 
their total market volume / share  

In the case of fruit and vegetables, since there is no data about the quantities distributed 
per individual types of fruit and per vegetables, the analysis considered total distributed 
quantities  in  one  year  as  an  example:  total  quantity  for  fresh  fruit  and  vegetables 
distributed in the school year 2018/19 (cf. report “Implementation in the 2018/2019 school 
year” refers a total quantity of 71 210 015 Kg). 

To calculate the total production, the analysis considered the products which have a higher 
representativeness  in  the  distribution  under  the  EU  school  scheme,  and  the  quantities 
produced in those MS. The analysis used FAOSTAT production statistics for the year 2019. 
An exception was made for France, that was not considered in the production quantities, 
as it is a great producer but has a very low school scheme implementation rate. 

Table 10: Quantities of the products – fruit and vegetables 

Fruits  and  number  of  MS  distributing 
under EU school scheme 

MS producing within those 
distributing under EU school scheme 
(no.) 

Apples (26 MS) 

Citrus (19 MS) 

Peaches/Nectarines (15 MS) 

Pears (23 MS) 

25 

7 

10 

22 

Total quantity of the products produced in the MS that are also distributed in 
2020 

Quantity 
(tonnes) 

10 184 230 

9 487 740 

2 266 940 

2 348 840 

24 287 750 

Total quantity of fresh fruit and vegetables distributed under the EU school 
scheme in 2019/2020  

71 210 

Source: FAOSTAT, Statistics division of Food and Agriculture Organization of the United Nations; Annual 
monitoring data on the implementation of the EU School Scheme. 

The  ratio  between  the  quantities  distributed  under  the  EU  school  scheme  and  the  total 
quantities produced in the MS which also distribute them is equal to 0.29%.  

In relation to milk and milk products, the analysis considered the quantity of drinking milk 
and  lactose-free  versions  distributed  in  the  school  year  2018/2019  (cf.  report 
“Implementation 
total  quantity  of 
168 051 358 liters), and the quantity of skimmed milk produced in the EU. 

the  2018/2019  school  year” 

refers  a 

in 

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Table 11: Quantities of the products – milk 

Quantity of drinking milk and lactose-free versions distributed in the 
school year 2018/2019 
Quantity of skimmed milk produced in EU-27 
% ratio (approx.) between milk distributed under EU school scheme 
and total milk produced EU-27 

163 009.8 tonnes 

54 814 451 tonnes 

0.30% 

Source: FAOSTAT, Statistics division of Food and Agriculture Organization of the United Nations; Annual 
monitoring data on the implementation of the EU School Scheme. 

Similarly, to F&V, the share of milk distributed under the school scheme compared to total 
EU27 production is very small. 

As  mentioned  before,  the  EU  school  scheme  has  a  negligible  level  of  effectiveness  in 
contributing to the CAP general objective of enhancing viable food production. Among the 
factors that led to this understanding is the representativeness of the products distributed 
under the EU school scheme when compared to total production (and share of the market), 
which  is  too  small  to  have  a  perceptible  contribution  to  the  specific  objectives  towards 
enhancing viable food production. This perspective is supported by the results of the Case 
Studies carried out. 

Nonetheless, while the school scheme contribution can be considered to be insignificant at 
EU level, it might possibly be of some significance at regional and local levels, namely, to 
maintain agricultural production. For instance: 

 

 

in Portugal, it was mentioned that, given the age-group, the fruit distributed at schools 
is  usually  smaller  in  size  than  those  most  valued  on  the  market  and  producer 
organizations  may  have  the  opportunity  to  market  smaller  fruit  at  a  higher  price 
compared to that practiced by the processing industry;  
in Poland, product suppliers co-operate with local companies in most cases, therefore, 
regardless of the little effect due to the low quantities demanded, the school scheme 
promote local agri-food chain and may affect the income of farmers delivering products 
within the scheme.  

Farms’ income levels 

The price paid to suppliers should be adequate otherwise they would not participate in the 
tenders of the scheme. The prices for purchasing fruit and vegetables and milk and milk 
products  are  defined  in  the  procurement  procedures.  The  determination  of  prices  has 
different approaches within the MS213. 

Then, in the procurement procedures the pursuit of the lowest prices is not unusual:  

 

 

 

in Romania and Portugal, the public procurement procedures apply the lowest price as 
the most important criterion for the selection of suppliers;  
in Spain it was considered that too much weight is given to the price, as a consequence, 
the price is the main driver while it does not reward the quality of the products and of 
the service;  
in The Netherlands the suppliers look for the cheapest products to fit in the amount of 
the eligible costs, which were considered very low;  

213 e.g., in Italy prices are determined on the basis of different costs: the cost of raw materials and wholesale 
prices for F&V and for milk and dairy prices are based on market data published by ISMEA - Istituto di Servizi per 
il Mercato Agricolo Alimentare, and take into account cost of packaging and distribution. The unit cost is included 
in  the  tender;  in Germany  there  is  a fixed price for  delivery  of  fruit  and vegetables  in the  EU  school  scheme, 
which  calculation  is  based  on  a  mixed  basket  of  goods,  including  logistics  and  personnel  costs  and  regularly 
checked by an independent institution; in Poland the eligible costs are estimated on the basis of average retail 
price  of  the  products  concerned  calculated  for  proceeding  5  years;  in  Hungary,  the  cost  of  the  products  is 
determined on the basis of price data collected by the Research Institute of Agricultural Economics (HUF/kg) and 
price information from the FruitVeB Hungarian Interprofessional Organization for Fruit and Vegetable, taking into 
account data from five years. 

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 

in Poland product suppliers consider the level of eligible costs to be low and not in line 
with actual market conditions. 

These conditions, together with the current relatively small volumes of fruit and vegetables 
and of milk and milk products, explain the general opinion of stockholders on the marginal 
role played by the scheme on farms' income level. 

As for income stability, the role of the EU school scheme in reducing farm income variability 
varies across MS (source: PAs survey and case studies). Although there is no data to assess 
any  of  these  aspects,  it  is  believed  that,  where  there  are  closer  relationships  between 
producers and distributors (e.g., Producers’ Organisations  - POs), the EU school scheme 
may provide income stability by ensuring regular procurement of products throughout the 
school year.  

However,  as  the  contracts  are  established  usually  for  a  given  school  year,  the  relative 
stability is only short-term (e.g., in Poland, milk processors sign contracts for the supply 
of  products  to  schools  for  a  period  of  one  year,  such  an  agreement  somehow  ensures 
stability and guarantees that the raw material will be collected by processing plants). 

Other  interventions  supported  by  the  European  Agricultural  Guarantee  Fund  (EAGF) 
concurring to the same CAP objective of viable food production also make the contribution 
of the EU school scheme seem very small. 

According to the Evaluation of the impact of the CAP measures on the general objective 
'viable food production'214, although it is considered that the measures comprised in the 
CMO of agricultural products “serve a crucial role in the specific objective of maintaining 
market  stability  and  help  to  improve  agricultural  competitiveness  and  increase  farm 
income”,  the  core  instrument  of  the  CAP  contributing  to  the  objective  of  viable  food 
production are the direct payments. The table below shows the relative importance of the 
support under the EU school scheme in face of other market measures under the CMO and 
in face of direct payments. 

Table 12: Budgetary Execution of EAGF (EUR milion) 

 Total EAFG 
 Direct Payments  
 Interventions in agricultural markets, of which 
 School Scheme 

EU School Scheme in relation to the total expenditure in 
Interventions in agricultural markets 
EU School Scheme in relation to the total expenditure in 
Direct Payments 

2018 
43 188.7 
40 668.7 
2 296.9 
250.0 

2019 
43 116.4 
40 544.7 
2 442.5 
250.0 

2020 
43 380.0 
40 621.0 
2 504.1 
250.0 

10.9% 

10.2% 

10.0% 

0.6% 

0.6% 

0.6% 

Source: Financial Reports from the Commission to the European Parliament and the Council on the European 
Agricultural Guarantee Fund – financial years 2018, 2019, 2020 

Therefore, regarding the specific objective of increasing the income of farms involved in 
the supply of the products distributed under the EU school scheme, an eventual effect will 
be  mostly  (or  totally)  indirect,  as  the  procurement  of  products  usually  does  not  involve 
direct contracts and payments to producers, but retailers / distributors. 

In relation to stability of farm incomes, it is considered that the implementation of the EU 
school  scheme  has  not  contributed  in  a  relevant  manner  towards  this  objective,  as  the 
commercial relationship is usually established with distributors, which, in turn, buy from 
several producers in order to respond to the supply needs. 

214 Commission Staff Working Document, final version, May 2021. 

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Change in the diversification of the agricultural market  

Although the EU school scheme allows for the distribution of a varied range of products, 
and,  in  most  strategies,  such  variety  is  provided  for,  the  information  collected  through 
Case Study interviews revealed that actual implementation of the school scheme supply a 
much narrower selection of products in schools.  

Whilst  it  is  important  to  know  the  type  and  quantity  of  products  effectively  distributed 
under the EU school scheme in order to provide an accurate evaluation for this indicator, 
as  the  MS  may  not  distribute  all  the  products  foreseen  in  the  respective  strategy,  the 
monitoring data lacks information concerning quantities of individual products distributed 
(and also the quantity of the products effectively consumed by children). 

The  analysis  of  the  national  strategies  and  information  collected  through  Case  Study 
interviews  indicate  a  prioritization  to  distributing  products  in  their  most  natural  state. 
Nearly all national strategies prioritize the supply of fresh fruit and vegetables and of plain 
milk (see 4.1.3, JC 3.1.). 

According to the school scheme monitoring report summaries, for the fruit and vegetables 
part  of  the  EU  school  scheme,  fresh  products  are  supplied  in  all  MS.  Considering  the 
evidence gathered in the interviews with relevant stakeholders in the scope of the Case 
Studies the diversification is influenced by the following factors:  

 

seasonality of agricultural production: during the school year, there is a shorter variety 
of fruits and vegetables produced;  

  maximum cost (€/kg, €/child or €/portion): lower maximum costs make it impracticable 
to  provide  certain  fruits  and  vegetables  also  provided  for  in  the  list  of  products 
contained in the school scheme strategies due to their higher market price; 

  practicability of distribution: the schools privilege products 'grab and go', this is, that 
require no additional support to children (e.g., to peel), no special care and have lower 
perishability. 

Taking into account these factors, it comes as no surprise that the most significant fruits 
distributed by the school scheme are also of the most common in the market: apples and 
pears.  As for the milk and milk products, the diversification is relatively circumscribed to 
plain drinking milk or lactose-free versions and to plain yoghurt.  

However, some of the products that are not regularly supplied/distributed to schoolchildren 
may occasionally be tasted under the accompanying educational measures (tasting classes, 
cooking workshops, theme days, among others) as part of the educational approach.  

4.2.1.3  Conclusions  

ESQ5 asks to asses to what extent the EU school scheme contributed to the to the common 
agricultural  policy  general  objective  of  viable  food  production,  i.e.:  maintaining  market 
stability, increasing farm income and improving agricultural competitiveness. The analysis 
is based on quantitative data and qualitative information collected from various sources.  

The overall representativeness of the EU school scheme on the market (i.e., the volume of 
the  products  supplied/distributed  under  scheme)  is  limited  when  compared  to  the  total 
production  of  fruit  and  vegetables  and  milk  and  milk  products.  In  addition,  when 
considering other support under EAFG concurring to the same objective, it is possible to 
see that the EU School Scheme represents on average less than one percent of the total 
EAFG expenditure.  

Notwithstanding, and while the overall dimension of the EU School Schemes is narrow, it 
has not yet been able to fully meet its potential. The under implementation is considered 

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to  be  mainly  due  to  the  low  execution  rate  of  a  few  countries,  limiting  the  effective 
contribution of the EU School Scheme to the viable food production objectives. 

In particular, information collected in the framework of the case studies highlighted that 
the general opinion of stockholders is that the EU school scheme has a marginal role on 
farms' income level, due to the relatively small volumes of fruit and vegetables and of milk 
and  milk  products  and  the  procurement  conditions.  Although,  it  is  believed  that,  where 
there  are  closer  relationships  between  producers  and  distributors  (e.g.,  Producers’ 
Organisations  -  POs),  the  EU  school  scheme  may  provide  income  stability  by  ensuring 
regular procurement of products throughout the school year. 

The accompanying educational measures are critical for achieving an increased long-lasting 
consumption  of  agricultural  products  by  schoolchildren  and  for  bonding  them  to  the 
agricultural  sector.  Also,  important  to  reach  these  objectives,  is  the  visibility  and 
acknowledgement of the EU school scheme among parents/families as the most important 
tool to promote healthy eating habits and the consumption of agricultural products. 

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4.3  Efficiency 

4.3.1  ESQ6 - To what extent has the EU school scheme been implemented in a 

cost-effective way? 

4.3.1.1  Background and methodological approach  

Understanding 

We  considered  “Cost-effective  way”  as  the  way  for  implementing  and  managing  the  EU 
school scheme achieving its expected objectives/benefits that saves on the use of every 
resource used (monetary, human, etc). We defined a series of measurable benefits and of 
costs, that were analysed and compared in order to assess the school scheme efficiency. 
The  type  and  size  of  the  benefits  have  been  analysed  in  ESQ  1,  2,  4  and  5.  This  ESQ 
assesses costs incurred for the distribution of products and for the provision of AEMs. The 
ESQ asks to analyse both direct costs and indirect costs, such as: 

Definition of key terms 

fulfil 

the  obligations  set  by  Regulation (EU) 2017/39  and 

Compliance costs: actual costs undertaken by key beneficiaries (schools and suppliers) 
to 
implementing 
Regulation (EU) N 1308/2013.  These  costs  mainly  focus  on  applying,  implementing, 
controlling, publicizing and reporting on the scheme. These include costs for providing 
products and services like AEMs: such costs can be analysed in unitary terms (e.g., per 
quantity unit of delivered products, per child participating in the EU scheme). 

Administrative and enforcement costs: costs undertaken to manage the scheme in 
relation with all the actors involved (e.g., public authorities, schools, suppliers). These 
costs  usually  consist  of  planning,  selecting  suppliers  and  schools,  paying  suppliers  of 
goods and services, monitoring and inspecting cases of non-compliances to the current 
rules.  

In  the  case  of  the  EU  school  scheme,  assessing  cost  efficiency  is  nevertheless  severely 
complicated by the wide array of technical and organisational solutions adopted by each 
MS and/or regional authority. 

Judgement criteria, indicators and sources 

In order to reply to the ESQ, our judgement is based on the following criteria and indicators. 

Judgement criteria 

Indicators 

Sources 

Basic 

JC6.1: 
efficiency 
goods and services  

cost-
of  provided 

JC6.2: Identification of the 
most 
cost  demanding 
tasks (Compliance costs)  

JC6.3: Identification of the 
cost  demanding 
most 
tasks 
(Administrative 
costs) 

6.1.1  Analysis  of  unitary  costs  (adjusted  for 
PPP)  for  providing  the  foreseen  goods  (F&V, 
Milk)  and  services  (accompanying  educational 
measures  
6.1.2 Extent (frequency and relevance) of non-
compliance cases   

6.2.1(a) Outcome of the qualitative assessment 
of  the  relations  with  other  stakeholders  (NAs, 
Schools, Suppliers, Families, etc)  
6.2.1(b)  Analysis  of  the  task:  publicity  of  EU 
support  
6.2.2(a) Outcome of the qualitative assessment 
of procurement of goods / services  
6.2.2(b) Outcome of the qualitative assessment 
of  distribution  of  goods  and  organization  of 
accompanying measures  
6.3.1(a) Outcome of the qualitative assessment 
of  the  EU  school  scheme  promotion  and 
selection of applicants  

-  EU  school  scheme  annual 

monitoring data  

-  Structured  interviews  in  CS 

countries/regions   

-  DG  AGRI:  Annexes  to  the 

yearly Activity reports  
-  Public Authority Survey   
-  Structured  interviews  in  CS 

countries/regions  

-  Structured  interviews  in  CS 

countries/regions  

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Judgement criteria 

Indicators 

Sources 

JC6.4: 
potential improvements  

Identification  of 

6.3.1(b) Outcome of the qualitative assessment 
of the payments management process 
6.3.2 Outcome of the qualitative assessment of 
monitoring activities  
technical  solutions  already 
6.4.1  Specific 
adopted  for  increasing  the  scheme  benefits  or 
decreasing  its  costs  (able  to  be  replicated 
and/or scaled up)  
6.4.2  Specific organizational  solutions  adopted 
the  scheme  benefits  or 
increasing 
for 
decreasing its costs   

-  Interviews to DG AGRI staff  
-  Structured  interviews  in  CS 

countries/regions  

Methodological approach and its limitations 

Tools, method and sources used 

The evaluation assessment is based on the analysis of two categories of cost:  

 

 

direct costs, actual cost for providing AEMs and distributing goods (F&V and milk); 

indirect  costs:  include  administrative  and  enforcement  costs  linked  to  the  overall 
scheme’s management and implementation. 

Concerning direct costs, the analysis is based on the EU school scheme monitoring data 
complemented by the results of the Public Authorities survey; the analysis was carried out 
only  on  EU  expenditure.  Data  were  adjusted  according  to  Eurostat  Comparative  Price 
levels215  in  order  to  better  compare  values  amongst  MS  and  over  the  four  school  years 
under analysis216 . 

The analysis of indirect costs of the scheme relies mainly on results of the interviews carried 
out in case study MS and regions. The coverage rate of children participation was calculated 
with respect the targets set by MS. Whenever possible we tried to compare the obtained 
indicators  with  the  values  recorded  in  previous  evaluations;  this  could  be  only  achieved 
partially. This analysis enabled us to outline an overall view of cost efficiency, and to define 
at a reasonable extent which MS could be considered the “best” and “worst” performers in 
terms of use of funds for the scheme’s success, providing a series of reasons concurring to 
explain such outcome. 

For the assessment of indirect costs, information regarding the organisation of the scheme 
included in the national strategies was analysed. Moreover, a set of approx. 25 questions 
have been addressed in the framework of the case studies to public authorities active at 
various levels in the school scheme’s implementation, and also to other key stakeholders. 
In addition, information and data were gathered trough the PA survey in order to estimate 
in more detail the amount of time allocated to every key task related to the management 
of the EU scheme (see ESQ7).  

We based the assessment on recorded unitary costs (per quantity and per child), bearing 
in mind that: the current format of the AMRs does not ease the detailed tracking of the 
scheme’s  implementation,  lacking  detailed  information  on  key  aspects  of  many 
expenditures (in particular for AEMs); attribution of the number of children participating to 
the two parts of the EU scheme is difficult to be performed and reported. We based the 
calculation of unitary values on the records of quantities and participants outlined for ESQ 
1 and ESQ2 (see relevant tables).  

215 Eurostat: https://ec.europa.eu/eurostat/databrowser/view/tec00120/default/table?lang=en . 
216 It is important to note that, due to the re-balancing impact among MS of the revised monetary values, total 
figures and averages tend to be approx.12-14% higher than the actual costs reported in AMRs.  

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Concerning  the  frequency  of  distribution  of  the  products,  precise  data  are  often  not 
available  (especially  for  school  year  2020/21).  The  fact  that  the  current  format  of  AMR 
includes an “Other” as an answer option where additional information about this issue is 
sometimes  provided,  but  clear  explanations  are  rarely  available;  as  a  consequence  the 
precise distribution frequency of products cannot be known217 . 

Finally,  we  used  the  “synthetic  efficiency  indicator”  (of  Union  aid),  defined  as  the  ratio 
between  the  share  of  participating  children  in  a  MS/target  children  population  and  the 
cost/child per MS. The same indicator was used in the evaluation of the Milk scheme for 
the years 2004/2012. It directly expresses the capacity of each MS to extend the share of 
children  involved  in  the  scheme  with  every  additional  euro  spent:  the  higher  the  index 
value,  the  stronger  the  MS  capacity.  As  a  drawback  it  tends  to  amplify  the  relative 
difference  between  MS;  but  in  this  way  it  helps  to  identify  groups  of  MS  performing 
better/worse than the EU average.  

Limitations of methods and sources 

For both cost categories we recorded some limitations (besides ones already outlined): 

  Direct  costs:  some  data  deriving  from  the  AMRs  appear  either  incomplete,  partially 
unreliable  and/or  unbalanced  compared  to  the  specific  MS  and  issue  at  stake218. 
Therefore,  we  decided  not  to  take  them  into  account  in  calculating  the  selected 
indicators; these cases are always highlighted. For what concerns data about quantities 
of  distributed  products  (both  F&V  and  products  based  on  milk  content),  they  were 
standardized in terms of “raw equivalents” (see also ESQ1 for details). Monitoring data 
do not allow to clearly distinguish if the same pupil attended more than one AEM: that 
is why we labelled the table for summarising unitary cost “cost per child units” meaning 
that it was not possible to distinguish students attending only one AEM type and not 
others, but that it was possible to record how many students in total attended a certain 
activity (therefore involving a cost for its provision). 
Indirect  costs:  although  we  aimed  at  constructing  an  average  “cost-profile”  for  the 
scheme’s  implementation,  outlining  the  relative  importance  of  every  type  of  indirect 
costs, this did not prove possible for the lack of reliable replies in the framework of the 
CS  interviews:  reliable  quantitative  data  collected  (regarding  the  time  and/or  costs 
employed on distinct tasks) have been provided only in very few cases, and for different 
issues219. This did not allow us to carry out any clear comparison. 

 

217In order to better clarify the reported data it could be possible to ask MS how many total days/school year the 
products (F&V and milk) were actually distributed to children, not with-standing the specific periods of distribution 
chosen along the year. 
218A few examples of data that do not appear fully clear or are missing regarding AMRs: in some cases the number 
of children included in the target group and the total of children participating in the scheme is missing; in other 
cases the number of participating schools is not divided between the FV and the Milk parts, and no data is provided 
regarding the average cost for apples and for drinking milk,  no priority for the choice f FV & Milky products is 
indicated, and no data is provided regarding the average cost for apples and for drinking milk. Concerning the 
frequency of product distribution: one MS indicates that F&V distribution in 2018/19 and 2019/20 is "daily", but 
the respective comments found in the MR specify that this happened only during a 16-day period along the year; 
-another MS reports a daily distribution, while the comments outline that this happens only in primary schools, 
while in other schools there is a different frequency. In both cases the reported data are confusing and difficult 
to assess. Expenditure for supply distribution of milk in one MS (2017/18): in the AMR a figure of 587078€ is 
reported, but the related comment states that they were going to pay an additional EUR 8.5 milion in early 2019. 
Only when this additional comment is taken into account the overall expenditure appears more  comparable to 
what has been spent in the following two school years. 
219In most cases NAs were not able to quantify the time usually devoted to scheme tasks. In some other cases 
they provided replies that included only a gross estimate (not comparable due to the use of different time units) 
of the time used. In three cases NAs simply did not answer. 

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4.3.1.2  Analysis  

Judgement criterion 6.1: Basic cost-efficiency of provided goods and services  

Analysis  of  unitary  costs  (adjusted  to  PPP)  of  the  accompanying  educational 
measures and of the distribution of the products (F&V, Milk) 

A.  ACCOMPANYING EDUCATIONAL MEASURES (AEM) 

The analysis is based on the EU school scheme AMR data and on data collected through 
CS  interviews.  Accompanying  educational  measures  absorb  only  3%  of  the  total  school 
scheme’s expenditure, and expenditure is reported separately for the F&V and Milk section, 
but not for each type of measure. Educational measures have some distinct features that 
make the cost efficiency assessment more difficult because AEM show greatest variation 
in  terms  of  organisational  format  or  implementation  and  of  intrinsic  quality,  when 
compared to the distribution of F&V and milk, for which some standards (related to quality 
and  quantity)  are  instead  defined  and  common  to  every  MS.  In  addition,  some  MS  use 
national funds to support the provision of AEMs.  

The results of the analysis of the participation rates to each type and to the total set of 
AEMs and their unitary cost for every MS, show some trends and clusters can be identified:  

 

 

the evolution of unitary costs along the four years shows a significant decrease in the 
two  last  school  years.  This  is  likely  to  be  determined  by  the  arise  of  the  Covid-19 
pandemic, that greatly changed the extent and way AEMs were provided in most EU 
MS, due to various restrictions put in place; 
“best  performers”  in  terms  of  overall  efficiency  in  implementing  the  educational 
measures are:  Czechia, Germany,  Hungary, Latvia and Poland. These  MS show both 
best  records  in  involving  children  (compared  to  their  overall  population)  and  lower 
unitary  costs  compared  to  the  EU  average,  equal  to  2.04  €/child).  The  “worst 
performers” are Austria, Croatia, Estonia, Ireland, Romania: all of them show exactly 
the  opposite  values  compared  to  the  previous  group  of  MS.  Italy,  Spain  and  The 
Netherlands lie somewhere  in the middle of this ranking, with mid-range attendance 
and costs;  

  apart  from  Estonia,  that  shows  the  highest  unitary  costs220  (EUR 14.36/child),  the 

 

 

overall variation of costs among MS is fairly limited221;  
the tendency to a decrease in unitary costs may mainly depend on the shift from live 
activities (in presence) to online ones due to the pandemic restrictions, although the 
number  of  children  attending  farm  visits  and  cooking  workshops  (usually  the  most 
expensive AEMs) remained quite stable along the three school years in most MS. Next 
to  this  stands  the  likely,  more  intense  use  of  local  teachers  to  replace  previously 
outsourced (and therefore more expensive) activities; 
the cost decrease may also partially depend on the fact that between the first and the 
fourth  year  there  was  a  13%  increase  in  the  number  of  children  participating  in 
activities like school gardens (the only recorded increase amongst all AEMs). Gardens 
are fairly inexpensive to set-up, and involvement of children is usually managed by the 
teachers, with no extra-costs for external personnel and for transport costs. 

When  analysing  in  detail  the  mix  of  different  AEM  activities  performed  by  the  best  and 
worst  performers  no  clear  pattern  can  be  outlined:  other  reasons  for  explaining  the 

220 This happens mainly for two reasons: -Estonia involves only a tiny % of children in its AEM (approx.5% of 
the overall target), so their unitary cost is higher; -the composition of its AEM includes a strong part of visits to 
farms and other outdoor activities, usually more costly that other types of AEMs.  
221 It is intuitive that best performing MS associated higher participation with lower unitary costs, yet France is, 
to  this  regard,  an  outlier:  it  shows  low  costs  but  also  a  low  attendance,  similarly  to  the  poor  coverage  rate 
recorded in distribution of products.  

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variation in success and unitary costs could be found in the accuracy for  reporting their 
costs and in the organizational model of each MS. To note that the average EU cost/child 
is  only  EUR 2.04/child,  slightly  higher  than  the  average  cost/quantity  for  milk 
(EUR 1.11 /child).  This  is  not  necessarily  a  positive  sign,  confirming  the  overall  low 
investment of resources on this key scheme’s activity.  

B.  DISTRIBUTION OF PRODUCTS 

The analysis of the cost efficiency of the scheme was based on EU expenditure and was 
carried out separately for each of its parts, for which expenditure is reported; it also relied 
on the results of the PA survey. National/regional authorities have been asked to express 
their opinion about the reasonableness of the reported costs that we found in the AMRs222. 
A few overall notes about the products’ distribution sector are outlined as follows: 

  The large majority of MS show different cost patterns for F&V and for Milk parts: a MS 
which records higher unitary costs for F&V does not tend to show  a similar trend for 
Milk. This may mean that at national scale the two value chains have quite different 
structures, and that the MS size does not apparently affect it. Only Austria, Hungary 
and Italy always record higher costs than the EU average for both scheme’s parts223. 
  On the opposite side stand Belgium, Denmark, Estonia, Latvia, Luxembourg, Portugal 
and Slovakia, recording lower than EU average unitary costs for both scheme’s parts. 
They are all small MS, all of them, with the exception of Denmark, with a low frequency 
in products distribution.  

F&V part of the scheme  

The F&V part of the scheme is responsible for spending approximately 67% of the overall 
scheme’s budget at EU level. Main remarks are as follows: 

 

 

the total expenditure for distributing F&V (including their purchase) increased between 
the first and second year, and decreased in the 3rd and in the 4th school years. The 
average  unitary  costs  per  quantity  and  per  child  served  show  a  decreasing  trend, 
stronger in the last school year (similarly to the trend recorded for the Milk part). This 
can be explained by two main reasons: following the Covid-19 pandemic logistic chains 
needed  to  improve  and  therefore  be  able  to  distribute  goods  at  a  lower  cost;  the 
average quantity/child slightly decreased in the last two years (as well as the variety 
of distributed goods), increasing the burden on suppliers; 
the  average  unitary  cost/quantity  of  distributed  F&V  in  the  four  years  was  equal  to 
EUR 2.39/kg  equivalent.  This  is  44%  higher  than  the  EUR 1.66/kg  estimated  in  the 
evaluation of the Fruit scheme for the years between 2009 and 2011224, and higher 
than the variation of the average cost of living index in the EU during the same period 
(approx. 12%). These comparisons must be taken cautiously though: the range and 
quality of products available within the school scheme between 2017/2021 were higher 
than 10 years before, and vegetables tend to cost more than fruit, as the CS confirmed. 

22235 PAs answered, with 19 respondents stating that costs looked quite adherent to reality, while 14 said that 
they were “somewhat” reasonable; only two NAs (FR and SI) had strong doubts about them, saying that reported 
costs were low compared to actual ones. 
223In  the  Italian  case  this  may  depend  on  the  choice  for  prioritising  PDOs  (Protected  Designation  of  Origin 
products)  for  F&V,  while  in  Austria  it  may  be  due  to  the  very  wide  choice  of  different  F&V  products  being 
distributed, although its distribution patterns (frequency of distribution and quantity served for F&V and milk) are 
below the EU average, and the population is concentrated in Vienna and in plain areas of the country, therefore 
non requiring heavy transport costs. 
224AFC, CO CONCEPT Marketing Consulting, Directorate-General for Agriculture and Rural Development (European 
Commission), Evaluation of the EU Fruit school scheme, 2012. 
https://agriculture.ec.europa.eu/common-agricultural-policy/cap-overview/cmef/products-and-markets/school-
fruit-scheme_en . 

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 

CS information also shows that organic F&V tend to have an average price premium of 
approx. 30% compared to conventional farm products; 
the best performing MS include: Latvia, Belgium, Croatia, Estonia, Finland, Lithuania, 
Luxembourg,  Portugal  and  Slovenia225.  Ireland  shows  a  high  number  of  involved 
children,  but  a  far  lower  unitary  cost  compared  to  the  EU  average  (and  not  having 
prioritized  organic  products).  The  group  of  worst  performing  MS  include  Denmark, 
Germany, Greece (although we have data only for 2018/19), Italy, and to a large extent 
Spain: all of them show high costs/kg and per child, jointly with a limited success in 
reaching children compared to their target population. For Italy and Spain, it must be 
noted that both MS prioritized PDOs and organic products in their distribution.  

The two main factors explaining this ranking are the respective frequency of distribution 
(times/week)  and  the  average  size  of  distributed  portions:  the  majority  of  MS  showing 
higher unitary costs show also higher frequency of distribution, and a bigger served portion 
of F&V226. These conclusions are substantially confirmed by the figures of the “synthetic 
efficiency  indicator  of  Union  aid”:  Belgium,  Czechia,  Denmark,  Luxembourg,  Latvia, 
Croatia, Cyprus, Slovakia and Slovenia.  

MILK part of the scheme 

The Milk part of the EU school scheme recorded a constant decrease in terms of children 
participation,  as  well  as  a  decrease  in  the  average  quantity  of  milk  and  milk  products 
distributed per child. The main remarks deriving from our analysis are as follows: 

 

 

similarly, to the F&V part of the EU school scheme, the absolute amount of expenditure 
increased  between  the  1st  and  the  2nd  year,  and  decreased  in  the  third  and  in  the 
fourth school year, according to the participation rates; the average unitary costs per 
quantity  and  per  child  show  a  decreasing  trend,  stronger  in  the  last  school  year.  To 
note that the ratio cost decrease/quantity between 2020/21 and 2017/18 is the same 
as for the F&V part (-20%), while the cost decrease/child is bigger: -17% (compared 
to -6%)227; 
the variation of the average unitary cost of milk across MS is lower than for the F&V 
part (as expected, being all packaged goods) and the average price of milk is equal to 
EUR 1.11/lt  equivalent.  Information  collected  in  CS  show  that  organic  milk  has  an 
average price premium of approx. 20% compared to ordinary milk; 

  we  cannot  compare  these  figures  to  the  results  of  the  previous  milk  scheme 
evaluation228  carried  out  for  the  years  2002/2003  to  2011/2022  because  the 
evaluation did not use the same indicator regarding cost/lt equivalent. However, the 
average  price  of  EUR 1.11  appears  in  line  with  market  retail  prices  recorded  for  the 
corresponding years in Europe; 
the group of “best performers”, with both low unitary costs (per lt and per child) and 
high  distribution  frequency  or  portion  size,  includes:  Belgium,  Denmark,  Estonia, 
Luxembourg,  Slovakia,  Poland,  Sweden  and  UK.  France  and  Finland  show  very  low 
unitary  costs,  but  also  share  the  smallest  portion  size,  while  Finland  ensures  a  high 
distribution frequency. The group of “worst performers” include Czechia and Romania, 

 

225 Interesting to note the gap between the two island MS, with Cyprus always ahead of Malta in showing lower 
unitary costs. 
226 One positive exception to the rule is Luxembourg, with a low unitary cost associated with a good frequency 
and portion size bigger than average. Bulgaria and Finland could have represented some very positive examples 
in terms of overall cost efficiency, but they did not provide data for assessing the % of children participating to 
the scheme compared to their target groups, so a better assessment is hampered. 
227 This intuitively depends on the different features of the two logistic chains, with the Milk one more centred on 
processed products that are easier to handle, and more constantly available compared to F&V ones.  
228 AFC Consulting Group AG, Directorate-General for Agriculture and Rural Development (European Commission), 
Evaluation of the EU Milk school scheme, 2014. 
https://op.europa.eu/en/publication-detail/-/publication/591f5107-9264-4bf5-bd94-7f2788e6074c  

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with  high  unitary  costs  and  minimum  distribution  frequency,  followed  by  Hungary, 
Bulgaria and Ireland. To note that the two island MS (Cyprus and Malta) do not seem 
disadvantaged in this ranking compared to what was recorded for the F&V part. This 
can  be  reasonably  explained  by  the  fact  that  imports  of  milk  products  tend  to  be 
cheaper and easier to handle than F&V. 

The majority of MS that show higher unitary costs are motivated by a higher frequency of 
distribution, and by a bigger served portion of milk, while the opposite holds for the MS 
recording lower unitary costs: this means that basic dynamics of costs setting are again 
regularly at work.  

The  calculation  of  the  synthetic  efficiency  indicator  confirms  what  we  stated  above, 
highlighting the best cases of Estonia, Latvia, Luxembourg, Portugal, Slovenia, Slovakia, 
and Sweden. 

Extent (frequency and relevance)  of  non-compliance cases  (from  the  reports  about 
on-the-spot checks229 (OSC), and from data on recovery of undue payments  

Non-compliance cases represent a cost and an indirect indicator of (possible) inefficiency 
of  the  scheme.  The  results  of  the  analysis  based  on  the  information  available  in  the 
Annexes  to  the  Annual  activity  reports  2018-2019-2020  of  DG  AGRI,  show  that  the 
adjusted error rate (the total amount of expenditure at risk, based on the errors reported 
by MS authorities and EC audits) ranged from 1.95% of the overall  aid paid in 2018, to 
2.64% in 2019 and to 4.76% in 2020, with several MS involved230. 

In  addition,  one  should  take  note  of  the  amount  of  the  requested  budget  that  was  not 
disbursed  by  the  European  Commission  after  due  checks  in  the  three  years  considered: 
EUR 12 229 000,  representing  2.4%  of  the  actual  spending  in  the  same  period.  A  more 
detailed outlook of the areas where audits identified control deficiencies is reported in ESQ 
7. Non-compliance regarding checks leads also to a part of the scheme’s budget not being 
spent. 

Judgement  criterion  6.2:  Identification  of  the  most  cost  demanding  tasks 
(Compliance costs) 

In overall terms we noted that most stakeholders involved in the scheme at various scale 
do  not  seem  able  to  properly  take  into  account  the  costs  associated  with  the  scheme’s 
implementation,  and  this  prompted  several  missing  and/or  incomplete  replies  in  all  the 
surveys carried out. This contributes to explain why the quantity/quality of received replies 
in  the  PAs  survey  and  in  CS  interviews  was  quite  poor.  According  to  interviews, 
procurement  procedures  of  products  and  provision  of  AEMs  represent  the  key  areas  for 
expenditure  measured  in  terms  of  complexity  of  procedures  and  in  terms  of  required 
time/work.  

Based on PA survey and CS interviews, some procurement procedures handled centrally 
and/or regionally (e.g., Italy, Spain) work better than those managed by local bodies in 
terms of costs monitoring and of time saved for implementing the scheme, albeit they shift 
the burden onto national authorities. There is no clear evidence that these MS achieve an 
overall  reduction  of  unitary  costs  for  distributing  goods  and  of  the  time  needed  to 
implement the scheme. Centralised procurement procedures tend to show a clear trade-
off in most CS for two issues: quality of products (that tends to be lower in order to bid at 

229On-the-spot  check  is  a  check  carried  out  by  the  first  level  controller  on  partners’  premises  (whereas  desk 
checks are carried out on the first level controller’s premises). In accordance with Regulation (EU) No 1308/2013, 
the first level controller has to go on-the-spot in order to verify that the reported activities have taken place, the 
delivery of sub-contracted supplies, work and goods is in progress or has been completed. At the same time, the 
means invested in going on-the-spot should remain proportional to the costs to be verified. Consequently, it may 
be legitimate to use sampling unless Partner State rules indicate differently for their first level control system. 
230 Recently (May 2022) the figures for 2021 was also released, with an error rate of 1.62%. 

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a cheaper price for the tender) and service to more remote areas (that tends to be reduced 
due to higher transport costs involved).  

Similar findings have been observed for AEMs: there is no common agreement about the 
best approach to this activity in the CS interviews. In some cases, stakeholders prefer it 
when they are provided by national authorities, in other cases by suppliers, in other ones 
by  independent  local  organizations.  To  note  that  many  AEMs  are  provided  by  school 
teachers (e.g., in the Netherlands and Germany). 

Monitoring & Reporting to the competent body in each MS seems to be tasks that require 
only a short time to most surveyed stakeholder (approx. 1 hour/week), but a higher one 
to schools and suppliers, according to national arrangements. 

Educational establishments usually formulate their application for the participation to the 
EU school scheme via online platforms, requiring on average 1-2 hours. The extremes are 
represented by the NL (where a school takes 30 minutes) and by Lithuania (where the time 
needed can reach one day).  

Outcome  of  the  qualitative  assessment  of  the  relations  with  other  stakeholders 
(national authorities, schools, suppliers, families, etc)  

Being  able  to  adequately  deal  with  every  stakeholder  involved  in  the  scheme 
implementation represents a basic requirement for its efficient management. CS interviews 
suggest that the stakeholders requiring more time to deal with are product suppliers; the 
higher the number of different suppliers and delivered products, the higher the amount of 
time  involved.  In  second  place  comes  the  task  of  dealing  with  providers  of  AEMs. 
Relationships with national or regional authorities and also with families apparently need 
only very few hours/week or per month (with the lowest time allocation occurring in  the 
Netherlands). The fact that most respondents among EEs to the CS survey indicated only 
a short  amount  of time usually devoted to their  relationship with families  could actually 
represent a worrying sign, because families play a key role in influencing children behaviour 
for what concerns their usual diet.  

Analysis of the task: publicity of EU support  

According to our CS, this task is mostly implemented via the placement of a small poster 
on the desk where products are distributed. This requires a minimum amount of time, and 
the needed materials are usually produced and delivered by NAs or regional authorities. 
We anyway noted that some schools never received some of the foreseen materials, while 
others  added  their  own  produced  materials  to  make  the  scheme  more  visible  (without 
receiving any reimbursement). In Sweden, from the last school year, additional publicity 
measures were introduced (a specific website notice). The amount of money that every MS 
devotes to this activity tends to greatly vary over the  years (most MS in the CS survey 
could not provide a precise figure).  

Most CS highlighted the notion that children and families perceive F&V products as arriving 
from  other  EU  MS  (e.g.,  Spain,  Greece)  and  do  not  yet  have  sufficiently  clear  that  the 
school scheme is implemented at EU-wide scale and with EU support (see also answer to 
ESQ 11 for the problems to the scheme’s overall credibility arising from poor publicity of 
EU support to the school scheme). 

Outcome of qualitative assessment of products distribution and organization of AEM  

One of the main engaging tasks is the time devoted by school staff to prepare and distribute 
the products after they arrive at school. In this case the information collected through the 
CS  interviews  range  from  4  to  30  hours/week,  depending  on  the  specific  distribution 
patterns: the higher the number of different suppliers, the frequency of distribution and 
the number of classes, the higher the amount of time needed by school staff.  

Timing of products distribution is a relevant issue in the overall scheme’s efficiency. If at 
national scale (e.g., Italy, Spain, Romania), procurement procedures take a long time to 
be  performed.  This  delays  the  actual  start  of  products  delivery,  compressing  the  time 
available for their distribution, and increasing the burden to schools, that are always very 

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busy  when  approaching  the  last  months  of  the  school  year.  Moreover,  schools  can  find 
themselves overflooded with products (i.e., F&V) to the point that children are provided 
with bags to bring the products home in order to avoid waste (IT, ES); the lack of proper 
storage  facilities,  more  frequent  in  rural  areas,  can  also  lead  to  additional  waste  of 
products. A similar “time compression” problem can apply for the provision of AEMs, risking 
to render them less effective for the stated scheme’s objectives. Only Slovakia approached 
the distribution of milk using also automatic vending machines at school premises.  

Another area where teachers’ work plays a significant role in the scheme’s implementation 
is in providing AEMs: this occurs in almost every country we checked, but appears stronger 
in the two German Laender. In CS where also the procurement of AEMs is centralised and 
they are assigned to specialised bodies, the time needed for contacts with them is reduced 
compared to the time that a single school might need. 

In a few CS, the issue of plastic packaging (to be reduced or avoided) was raised (Italy, 
the Netherlands, Germany). 

Judgement  criterion  6.3:  Identification  of  the  most  cost  demanding  tasks 
(Administrative costs) 

Outcome  of  the  qualitative  assessment  of  the  EU  school  scheme  promotion  and 
selection of applicants  

According to the outcome of most CS interviews, there are usually limited efforts to inform 
about the  EU  scheme.  Only NL appears to invest on a weekly newsletter sent to all the 
schools and families involved. Various materials are produced and distributed to schools 
by central and regional authorities managing the scheme, but with uneven frequency. 

Opinions  about  the  selection  of  applicants  to  participate  in  the  scheme  (schools,  local 
authorities) tend to vary. In general terms, this procedure does not prove time-consuming, 
because almost all MS adopt simple systems for applicants to register. In other MS (e.g., 
Romania) this procedure may require many working days. An extreme case was found in 
Italy, where a school applied for the scheme in July, but (as of late December) it had not 
yet received a confirmation of its entry in the system231. Registering for the first time in 
the  school  scheme  proves  always  more  complex,  due  to  the  need  of  learning  which 
documents are required.  

Outcome of the qualitative assessment of the payments management process  

Our evaluation found that payment procedures can be extremely time-consuming, even in 
MS  that  adopt  a  centralised  tender  procedure  (e.g.,  Italy,  Spain).  Nearly  every 
representative  of  the  suppliers’  category  that  we  interviewed  complained  about  the 
excessive length of time needed to receive due payments. This can be explained mainly by 
MS rules/procedures (not by the EU scheme itself) and it tends to affect more heavily small 
and  medium  suppliers,  that  are  usually  more  exposed  to  financial  stress.  It  must  be 
underlined that the long chain governing the flow of payments (distribution of products by 
supplier  Supplier  receives  payment  from  the  aid  applicant  (EE/LA)  /aid  applicant 
submits aid application to NA  NA sends aid application to EU EU paying application 
to NA  MS paying application to EE/LA) tends to delay them compared to the moment 
the  actual  expenditure  for  purchasing  products  was  undertaken,  and  this  creates  a 
disincentive for many suppliers in participating to the EU scheme.  

On  the  positive  side,  several  MS  are  currently  shifting  to  innovative  systems  for 
accelerating  payments,  usually  based  on  various  electronic  platforms,  some  of  them 
smartphone based (e.g., France, Lithuania). When payment requests are still received on 
printed paper public bodies need up to a total of 1 500 working days to process them (e.g., 
Bavaria, with 28 000 schools involved- and Romania). A common complaint refers to the 
poor cost-for-value of the payment received by the EU: the amount of reimbursement per 

231  This  occurs  because  Ministry  of  Agriculture  does  not  confirm  schools’  participation  until  the  selection  of 
suppliers is completed, which is often delayed.  

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distributed portion appears small compared to the work needed to distribute it. This issue 
is likely to become more relevant due to the current rise of inflation in EU. 

Outcome of the qualitative assessment of monitoring  

From the CS experience, monitoring of routine administrative activities by schools requires 
a modest amount of work (2 to 4 hours/week depending on the number of classes in the 
school and on the number of different suppliers).  

Among  case  study  MS,  Netherlands  is  the  only  one  that  performs  a  routine  (monthly) 
evaluation of the satisfaction of children and teachers about the scheme’s implementation. 
We found that most MS tend to wait for the deadline set by the EU scheme to invest more 
in evaluation efforts. This may represent a risk for the overall scheme’s success, as it would 
be helpful to gather some assessment at an earlier stage to introduce improvements to 
the  scheme’s  implementation.  Italy  releases  on  a  yearly  basis  a  detailed  “monitoring 
report”  on  the  F&V  part  of  the  scheme  that  actually  represent  an  interesting  evaluation 
effort. 

Judgement criterion 6.4:  Identification of potential improvements  

Specific  technical  solutions  already  adopted  for  increasing  the  scheme  benefits  or 
decreasing its costs (able to be replicated and/or scaled up)  

The main results of the analysis can be summarised as follows: 

 

 

  online  systems  for  applying  to  the  scheme  appear  spread  and  able  to  ease  the 
participation to the scheme by educational establishments. Each country should be able 
to rely on them;  
the  adoption  of  automatic  distributors  for  vending  fruit,  juices,  milk  (with  proper 
visibility of EU support) could improve both children participation and cost efficiency; 
the spreading of digital processing of applications by suppliers has enabled to reduce 
overall administrative costs, although national norms may still require a large number 
of different documents to applicants; 
the  adoption  of  smartphone-based  apps  may  greatly  assist  schools  in  checking  the 
actual  distribution  of  goods  and  in  checking  how  many  children  are  involved  in  the 
distinct  parts  of  the  EU  scheme.  These  apps  could  be  conveniently  matched  with 
monitoring  and  billing  phases  of  the  scheme,  shortening  monitoring  and  payment 
tasks; 

 

  using the same formats for gathering data in all involved MS and schools might greatly 
facilitate  the  collection  of  more  reliable  data  for  the  EC  (most  national  authorities 
complained about the lack of collaboration by schools to this regard). 

Specific  organizational  solutions  adopted  for  increasing  the  scheme  benefits  or 
decreasing its costs (able to be replicated and/or scaled up) 

The main results of the analysis can be summarised as follows: 

 

  harmonising rules regarding the structure, the indicators and the quality requirements 
of tenders could foster competition and improve access to the scheme by suppliers; 
increasing the proportion of processed F&V could ease storage and delivery to schools, 
therefore facilitating overall consumption by students; 
reducing the number of distributed products (e.g., only PDOs and organic ones) could 
ease the overall administrative burden for every stakeholder involved in the scheme; 

 

  paying  suppliers  by  kg  of  distributed  goods  instead  than  by  portion  might  simplify 
calculations and ensure a fairer treatment to suppliers. Paying the Union aid directly to 
suppliers might reduce time needed and the administrative burden to schools; 
indexing Union aid on a yearly basis may contribute to solve most suppliers’ problems, 
because the rate of reimbursement hardly covers actual costs for distributing products. 

 

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4.3.1.3  Conclusions 

The results of the analysis show that unitary costs of products recorded for both parts of 
the scheme appear comparable to market prices in the corresponding years, and linked to 
clear features of the scheme’s implementation (e.g., frequency of distribution, portion size, 
proportion of organic products). Between 2017/18 and 2020/21 unitary costs decreased, 
presumably to the increased adoption of IT systems to manage most scheme’s procedures 
in many MS, and to the reduced variety of delivered products. 

Less  information  is  available  about  the  cost  efficiency  related  to  the  provision  of  AEMs, 
whose potential beneficial role within the scheme must be stressed; most CS interviewees 
stated the importance of fostering active and outdoor AEMs.  

MS adopting centralised procurement procedures do not perform better in terms of cost 
efficiency compared to other MS with decentralised systems. No clear pattern influencing 
the  variation  of  unitary  costs  can  be  recognised.  Procurement  procedures  of 
products/services  and  selection  of  suppliers  (and  their  related  payment)  are  the  most 
demanding tasks. Application by the schools is usually fairly simple and quick. Procurement 
is often hampered by procedures that still rely on the use  of paper documents, by very 
long delays in managing the full cycle of tendering procedures, and by national/regional 
regulations that require a huge number of documents. Different MS place quite different 
importance to the technical and economic aspects of an offer for a tender, and this may 
affect the overall quality of the EU scheme implementation.  

Distribution of products is often based on the unpaid work of school personnel, and this 
may prove quite time-consuming, and detrimental to the overall scheme’s success. 

Timing of distribution is extremely important: in some CS we  found that due to various 
delays  this  starts  only  in  late  Spring,  causing  a  “time  compression”  that  is  negative  for 
both goods distribution (at higher risk of being wasted) and for properly carrying out AEMs. 

Non-compliance cases and related sum recovery are of limited amount compared to the 
overall scheme budget, but of significant importance for underlining the need to improve 
capacities  at  MS  and  regional  level,  in  particular  concerning  the  need  to  improve  the 
capacities related to OSCs implementation. 

Analysis of the most cost-demanding tasks (Administrative costs) showed that promotion 
and  publicity  of  the  EU  scheme  usually  receive  low  and/or  uneven  attention,  and  this 
contributes to limit the awareness of the EU scheme among schools and families (see ESQ 
2 and ESQ 11). 

Concerning the potential improvements of the EU scheme, a series of technical solutions 
have  already  been  adopted:  online  systems  for  applications  by  the  schools;  vending 
machines for milk; digital processing of payments; smartphone apps recording deliveries 
of products. 

No innovative organizational solution has been tested so far in case study MS and regions, 
but  several  suggestions  were  provided:  harmonisation  of  tender  structure  and  rules; 
increased  flexibility  in  the  number  of  processed  products  to  be  provided,  payment  by 
quantity of delivered products rather than by portions. 

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4.3.2  ESQ7 - To what extent are the rules of the EU school scheme efficient with 

regard to the procedures at EU level? 

4.3.2.1  Background and methodological approach  

Understanding 

Regulatory  policy  and  internal  operational  rules  should  contribute  to  improved  decision-
making and positive policy outcomes, serving the public interest. We considered part of an 
efficient implementation of the EU norms the reasonableness of administrative costs (costs 
incurred  for  fulfilling  the  tasks  described  in  the  EU  regulatory  framework  of  the  school 
scheme)  placed  at  the  interface  between  the  EC  and  the  work  carried  out  by  NAs  and 
regional authorities.  

Definition of key terms 

Rules  and  procedures  are  EU  provisions  and  internal  administrative  tools  affecting 
the way the scheme is implemented by the  EC, from the analysis of the pluri-annual 
MS strategies to the payment of Union aid (reimbursement of expenditure incurred by 
a  MS).  The  focus  of  this  evaluation  question  is  on  the  relationship  between  the 
procedures  adopted  at  EU 
to 
Regulation (EU) N 1308/2013  and  Regulation (EU) N 1370/2017,  and  the  overall 
efficient implementation of the scheme on the ground.  

the  scheme  according 

to  manage 

level 

Resources are the internal human resources that work on the various tasks regulating 
the scheme’s implementation, and the tools (IT, etc.) used to that purpose. We also 
linked  such  resources  to  the  human  resources  used  by  NAs  and/or  regional  public 
authorities to manage the scheme according to the subsidiarity principle. 

Efficient  is  the  ability  to  provide  a  positive  ratio  between  benefits  and  costs  of  the 
scheme’s implementation; in this evaluation benefits are assessed mainly in ESQ1-2-4 
and 5, while costs are assessed mainly in ESQ 4 and 6.  

Regulatory background and description of current EU procedures for managing 
the EU school scheme 

Envoy of Strategies – Art. 23(8) of Regulation (EU) N 1308/2013, Art. 2(3) of 
Regulation (EU) N 2017/40 and Art. 2 of Regulation (EU) 2017/39 

Frequency  of  notifications:  every  6  years.  The  first  round  of  strategies  was  due  by 
1 August 2017, the next round is due by 30 April 2023. MS notify their strategies, at 
national  or  regional  level,  to  the  EC  via  as  an  enclosed  document  based  on  a  EC 
template. 

The school scheme legislation sets out that strategies are notified to (and not approved 
by) the EC. Their “acceptance” in ISAMM is a ISAMM form 708 technical feature in the 
IT system – ISAMM manual specifies this.  

The EC services may make comments to the MS strategies, in view of the completeness 
and clarity of information. The strategies are posted in the Europa EU school scheme 
page 

Member  States’  amendments 
Regulation (EU) N 1308/2013 and 2(4) of Regulation (EU) N 2017/40 

the  strategies  –  Art.  23(8)  of 

to 

Frequency of notifications: not determined or limited in number by the legislation, which 
only  requires  notification  within  two  months  from  the  amendment(s).  MS  notify 
amendments to their strategies for the period from 2017 to 2023 via ISAMM form 709, 
as an enclosed document showing in track changes the amendment(s) and illustrating 
their reason. Amendments are notified to, and not approved by, the EC. The EC services 
may make comments, in view of the completeness or clarity of information. 

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The amended strategies 2017 2023 are posted in the Europa EU school scheme page 
and replace the original version. 

States’ 

Member 
of 
for  Union 
Regulation (EU) N 1308/2013 and Art. (3) of Regulation (EU) N2017/39 – and 
Commission  decision  on  the  definitive  allocation  of  Union  aid  –  Art.  5(6)  of 
Regulation (EU) N 1370/2013 and Art. 7 of Regulation (EU) N 2017/39  

–  Art. 

request 

23a(3) 

aid 

Frequency of notifications: once a year, by 31 January.  

MS notify their annual request for  Union aid via ISAMM form 704 for the next school 
year and via ISAMM form No 751 for the ongoing school year. A working document with 
the amount of Union aid requested by each MS, and the calculation by the EC to fix the 
definitive allocation of Union aid based on MS’ requests, is presented to the Committee, 
together  with  the  working  document  with  the  draft  Commission  decision,  before  the 
Committee’s opinion on the draft decision.  

The decision adopted by the EC is posted in the Europa EU school scheme webpage. 

Member  States’  annual  monitoring  report  –  Article  9(3)  of  Commission 
Delegated  Regulation (EU) N 2017/40,  Articles  8(1)  and  (3  of  Commission 
Implementing Regulation (EU) N 2017/39 

Frequency of notifications: once a year, by 31 January.  

MS  notify  their  annual  monitoring  report  via  ISAMM  form  No  777  based  on  a  EC 
template.  MS’  monitoring  reports  are  not  approved  by  the  EC.  Their  acceptance  in 
ISAMM  is  only  a  technical  feature  of  the  IT  system.  The  EC  services  may  make 
comments for the completeness, consistency and clarity of information.   

The  MS’  annual  monitoring  reports,  and  the  overview  of  results,  are  posted  in  the 
Europa EU school scheme webpage; some key data are in the agri-data portal. 

Annual control reports on the on-the-spot checks (OSCs) carried out and the 
Delegated 
related 
Regulation   (EU) N 2017/40  and  Article  10(7)  of  Commission  Implementing 
Regulation (EU) N 2017/39 

Commission 

findings 

Article 

9(4) 

of 

– 

Frequency of notifications: once a year, by 31 October of the calendar year subsequent 
to the school year. 

Member  States’  evaluation  reports  –  Article  9(2)  and  (5)  of  Commission 
Delegated  Regulation (EU) N 2017/40,  Article  8(2)  and  (3)  of  Commission 
Implementing Regulation (EU) N 2017/39  

Frequency of notifications: every five school years, by 1 March232. MS shall notify via 
ISAMM their evaluation reports that the EC will make public. Minimum requirements for 
the  format  and  content  of  the  evaluation  reports  have  been  developed  (Annex  to 
Regulation (EU) N 2017/39). The ISAMM form will be made available in due time. 

Our methodological approach is also framed by the “Better Regulation” Toolbox, that helps 
policy makers to assess the  efficiency and effectiveness of their instruments  following a 
“behavioural compliance” with a set of quality criteria. The underlying rationale is that, if 
the  outputs  (policy  choices,  adopted  internal  procedures  and  tools,  actions  performed, 
results achieved in terms of data collection and use) meet the set guiding quality criteria, 
the  administrative  system  can  be  considered  efficient233.  For  what  concerns  internal  EU 
procedures, we widen the assessment to their compliance with some key quality standards 

232 The first evaluation report, for school years 2017/2018 to 2021/2022, is due by 1 March 2023. 
233 EU “Better regulation” Toolbox-chapter 1, Tool #1- versions 2017 and 2021. We also highlight the fact that the “Better 
Regulation” Toolbox recommends “to use the toolbox selectively and with common sense” (p.11- ch.1- version 
2021). 

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(principles)  highlighted  in  the  Better  Regulation  Toolbox,  that  we  identified  as  the  most 
relevant  also  for  the  potential  improvement  of  the  EU  school  scheme  in  the  future,  as 
follows:  

  Transparency,  to  be  assessed  by  checking  openness  to  stakeholders’  views  and 

unbiased (evidence-based) data handling and decision-making. 

  Learning, to be assessed by checking high quality of adopted procedures and tools and 

their comprehensiveness. 

  Accountability, to be assessed by checking that evidence from the scheme is embedded 
in the planning/policy cycle and that decision-making is based on evidence-based data 
handling. 

Judgement criteria, indicators and sources 

In order to reply to the evaluation question, our judgement is based on the following criteria 
and indicators.  

Judgement criteria 

Indicators 

Sources 

JC  7.1:  Reasonableness  of 
administrative costs incurred by 
the EU and by NAs 

7.1.1  The  cost  (time)  devoted 
the 
management of the school scheme by the  EC 
and  by  the  NAs  is  reasonable,  and  the 
administrative 
that  prove  more 
demanding for NAs are identified   

tasks 

to 

- 

reliable 

JC7.2:  Transparency 
the 
adopted  procedures  are  based 
relevant 
on 
information,  and  enable  useful 
feedback  by  key  actors  (Public 
Authorities)  involved  in  the  EU 
school scheme  

and 

represent 

JC7.3:  Learning  -  the  adopted 
procedures 
an 
opportunity  for  learning  by  all 
the 
(Public 
Authorities)  involved  in  the  EU 
school scheme management  

actors 

key 

- 

reliable 

JC7.4.  Accountability 
the 
adopted  procedures  are  based 
on 
relevant 
information,  and  their  outcome 
supports  both  the  policy  cycle, 
as  well  as  internal  and  external 
accountability duties  

and 

of 

High 

scheme 

continuous 

improvement 

7.2.1.  Unbiased  (evidence-based)  -  the  EC 
properly  gathers,  assesses  and  conveys  best 
available evidence deriving from the EU school 
scheme implementation in order to foster the 
achievement of the scheme’s original goals and 
the 
its 
implementation  
to  stakeholders’  views: 
7.2.2.  Openness 
relevant data/information  and  outcomes from 
the 
implementation  are  easily 
accessible  to  key  stakeholders  (MS/regions, 
Local  Authorities,  etc).  Procedures  and 
responsibilities  are  clear  and  the  EC  provides 
feedback  and  inputs  potentially  useful  for 
improving the overall scheme performance 
7.3.1. 
clarity, 
comprehensiveness  and  conciseness  drive  all 
of  the  administrative  norms  and  procedures 
being adopted.  
7.3.2.  Comprehensiveness:  the  current  EU 
norms  allow  to  concentrate  on  the  most 
important 
scheme 
implementation  (financial,  technical,  social, 
environmental, etc)  
7.4.1. Embedded in the planning/policy cycle: 
evidence  from  the  scheme’s  implementation 
and monitoring is made available to feed into 
the  ongoing,  overall  policy  development 
process.  
7.4.1.  Comprehensiveness:  the  current  EU 
norms  allow  to  concentrate  on  the  most 
important 
scheme 
implementation  (financial,  technical,  social, 
environmental, etc) 

quality: 

aspects 

aspects 

the 

the 

of 

of 

-  Interviews  with  selected 

DG AGRI staff  

-  Structured  interviews  in 
CS 
countries/regions 
(National  and  regional 
public authorities) 

-  PA survey (two phases) 
-  Interviews  with  selected 
DG AGRI staff - Unit G3  
-  Structured  interviews  in 
CS countries/regions  
-  Public Authority Survey   

-  Interviews  with  selected 
DG  AGRI  staff  and  other 
relevant  DGs  involved  in 
the EU school scheme  

-  Interviews  with  selected 
DG  AGRI  staff  and  other 
relevant  DGs  involved  in 
the EU school scheme  
-  Structured  interviews  in 
CS 
countries/regions 
(National  and  regional 
public authorities)  

Methodological approach and its limitations 

Tools, method and sources used 

We started with the analysis of every key task foreseen at the EC level, for managing the 
EU  school  scheme,  as  prescribed  by  implementing  Regulation (EU) N 2017/39.  Such 

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analysis was carried out by interviewing the staff involved in the scheme’s management in 
DG  AGRI  AGRI.E.3  “Animal  products”  and  AGRI.H.2  “Assurance  and  Audit-Market 
measures”.  Additional  information  was  collected  through  interviews  in  case  study 
MS/regions with PAs and other subjects in charge of the scheme implementation also at 
local  scale.  Finally,  we  carried  out  a  specific  survey  on  PAs  focused  on  the  time  they 
devoted to the key tasks outlined in the regulatory background. The collected quantitative 
and  qualitative  information  was  complemented  by  other  quantitative  data  regarding 
important aspects of the overall scheme’s management (e.g., cases of non-compliance for 
OSCs,  number  of  budget  re-allocation  requests  by  MS,  number  of  amendments  to 
strategies, etc.).  

The overall aim of this analysis was to gather an analysis of administrative costs accruing 
to different stakeholders (in particular public bodies like NAs and regional authorities). 

In addition, we analysed the internal procedures  of the  EC framing them according to a 
selection of three Judgement Criteria, that is to say overall quality principles set out in the 
“Better Regulation” Toolbox. This comparison  was meant to provide an assessment that 
may be useful for operational improvements to the current scheme’s management for what 
concerns the link between the EU and NAs.  

Limitations of methods and sources 

For what concerns the analysis of administrative costs deriving from the application of EU 
rules, the main limits are linked to the lack of availability of  structured and  comparable 
data at national level on the amount of time allocated to every task of the EU scheme’s 
implementation;  this  hampered  the  possibility  to  precisely  assess  the  net  costs  of 
information obligations imposed by EU legislation. This problem, particularly important in 
the CS survey, was partially solved in the PA survey, where a more precise set of questions 
was asked to the NAs. In overall terms, the PA survey and the CS clearly highlighted some 
areas that are most time-consuming and improvements seem possible.  

In regard to the three quality criteria selected from the Better Regulation Toolbox the main 
difficulty  proved  to  apply  the  compliance  with  qualitative  principles  to  the  information 
available for the EU procedures at stake. It is often difficult to assess how broad principles 
can be properly transferred into detailed provisions and procedures. We tried to stick to a 
“common sense” approach, asking ourselves if and how the current procedures could be 
enhanced in order to improve the overall scheme’s success in achieving its stated goals. 

4.3.2.2  Analysis 

The  analysis  is  based  on  the  outcome  of  the  interviews  carried  out  with  DG  AGRI  staff, 
complemented  by  the  replies  to  selected  questions  included  in  the  PA  survey  and  by 
interviews in CS MS and regions. 

Judgement criterion 7.1: Reasonableness of administrative costs incurred by 
the EU and by NAs 

The  time  devoted  to  the  management  of  the  school  scheme  has  been  analysed  at  two 
levels: at the level of the national authorities and at the level of the EC services.  

For what concerns the time devoted to the management of the school scheme at the 
level of the EC services. 

The costs allocated to the staff involved in administering the scheme at EU level represent 
a  broad  indicator  of  its  management  cost-efficiency.  We  deemed  appropriate  to  assess 
these costs in terms of workload expressed in FTE/year (full time equivalents)234. As  stated 
in the paragraph of “Limitations of methods and sources” above the reported figures must 

234 This is coherent with the approach undertaken in the DG REGIO study “New assessment of ESIF administrative 
costs and burden”, 2018 (p. 9). 

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be taken with caution, because they represent a subjective perception by the person who 
was  interviewed,  not  the  result  of  a  systematic  and  detailed  measurement  of  his/her 
allocated  time  to  various  tasks235.  However,  they  point  to  conclusions  that  appear  fairly 
coherent, and that may prompt an action for improvement in the use of human resources 
at several levels. 

For what concerns the time devoted to specific tasks we focused on the following ones: 

  AMRs: guidelines for filling the ISAMM form in order to send the AMRs on a yearly basis, 
and the strategies every six years, have been prepared by DG AGRI to facilitate such 
procedures. Regarding these tools we noted that: 

- 

the  software  managing  the  compilation  of  ISAAM  forms  includes  useful 
automatic checks able to quickly detect inconsistencies in the provision of 
every relevant data (tested for the 1st time in 2020 with MS representatives), 
but must still be improved in order to prevent as much as possible DG AGRI 
from dedicating additional efforts in order to achieve full completeness and 
clarity  of  the  requested  information.  Unfortunately,  apart  from  the  time 
needed  to  process  the  files  once  they  are  considered  ready  (a  total  of  27 
working  days/year)  it  is  very  difficult  to  estimate  the  amount  of  time 
required to the  EU  staff in order to receive clarifications from the over 35 
MS/regions involved: the experience so far shows that it may request from 
0,2 working day to 1 week to properly clarify the content of just one AMR. 
The total amount of time/year allocated to this procedure is indeed relevant: 
our estimate (based on 2 working days/AMR) is that it can reach on average 
up  to  95  working  days/year,  including  the  27  working  days  mentioned 
above- 0,43 FTE/year); 

-  a high number of  MS and regions presented amendments to their original 
strategies:  a  total  of  41,  submitted  by  14  MS  and  9  regions  (three  from 
Belgium and 6 from Germany); 25 of these amendments were sent after the 
Covid-19 outbreak (after April 2020, although the results of the PA survey 
show  that  only  a  minor  part  of  them  was  caused  by  problems  due  to  the 
pandemic)236.  The  data  show  an  increasing  number  of  strategies’ 
amendments  being  presented  by  the  MS  over  the  considered  years.  This 
requires an additional amount of time for DG AGRI to properly analyse them: 
estimating an average of 2 working days/amendment, this leads to approx. 
(2 x 12) = 24 working days/year. 

  A modest amount of time (5 working days/year) is needed to receive and process the 
requests from MS wishing to amend the original budget allocated for implementing the 
scheme: the provisional data that we could access show that from 2017/18 to 2019/20 
school years, a total of 99 re-allocations of their initial budget were requested by MS, 
with a slight predominance (53 out of 99) affecting the Fruit & vegetables part of the 
scheme. In almost every case MS request additional budget compared to the initially 
allocated one.  

EC audits performed every year in some MS provide another useful source of information 
for this judgement criterion. The more detailed information available in the Annexes to the 
Annual  activity  reports  2018-2019-2020  of  DG  AGRI  shows  that  the  adjusted  error  rate 
(the total amount of expenditure at risk, based on errors reported by MS authorities and 
EC  audits)  ranged  from  1.95%  of  the  total  aid  paid  in  2018  (equal  to  EUR 3 034 497 
milion), to 2.64% in 2019 (EUR 5 005 123 milion) and to 4.76% in 2020 (EUR 7 334 892 
milion), with several MS involved. This indirectly confirms that MS keep having problems 

235 No monitoring data available. 
236 The 11 MS that did not submit amendments so far are: Cyprus, Estonia, Finland, Greece, Italy, Luxembourg, 
Poland, Portugal, Romania, Spain, Sweden, and United Kingdom. 

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in properly reporting their financial data and in complying with the EU scheme rules and 
provisions.  

Moreover, according to the results of the PA survey, one of the tasks for which PAs would 
like to see a simplification are OSCs, that currently absorb a major part of the time needed 
to manage the EU scheme. 

The interviews carried out with competent EU staff indicate that EC audits usually tend to 
identify  drawbacks  and/or  inconsistent  information  regarding  three  important  areas  of 
interest:  

 

lack of sufficient quality in carrying out proper OSC (On-the spot-checks), in particular 
concerning accompanying educational measures; 

  procedures for the selection of applicants and compliance with EU public procurement 

 

rules; 
control of reasonableness of cost-based systems or fairness, equity and verifiability of 
simplified costs. 

For what concerns the overall amount of time devoted to manage the scheme at the EU 
level by DG AGRI, we estimated that approximately 5 full-time equivalent (FTE) officers 
are engaged in this effort: 

two FTE237 officers in unit AGRI.E.3; 
two FTE officers in unit AGRI.H.2; 

 
 
  one  FTE  summing  the  Director/Deputy  involved,  the  legal  affairs  officer,  the  web 

master. 

Taking  as  a  base  cost  the  annual  initial  gross  stipend  of  an  AD9  administrator 238 
(EUR 98 532 /year) we obtain a total cost of EUR 492 660 . Comparing this cost with the 
average  yearly  amount  of  disbursed  Union  aid  in  the  four  years  period  under  analysis 
(approx. EUR 164 million) we find a ratio of 2.8%. To note that, if the EU school scheme 
had been operating at 100% of its planned capacity (EUR 250 million per year), the ratio 
between managing cost/ Union aid would have been 2%. 

These  values  appear  comparable  with  the  managing  costs  assessed  for  most  other  EU 
funded grants and aid programmes239. In our opinion, this percentage would significantly 
decrease should the scheme’s overall uptake or budget increase, because managing cost 
at EU level would remain quite stable (they mainly depend on the number of MS/Regions 
involved  in  the  EU  school  scheme,  linked  to  submitting  strategies,  AMRs  and  payment 
requests to the EC). To note that a significant amount of time is currently allocated every 
year to process: 

  95 working days to receive due clarification on AMRs; 
  24 working days for processing amendments to strategies. 

If  we  add  to  these  119  working  days/year  (equivalent  to  0.54  FTE/year)  the  two  FTEs 
devoted to audits and to the long checks usually needed after such audits, we can see that 
approx. half of the time currently devoted from the EC to the scheme’s management goes 
to activities that may benefit from an improvement of the existing guidelines and of other 
provisions available to the affected stakeholders, and from actions aiming at raising their 

237We  defined  a  FTE  (Full  Time  Equivalent)  position  as  a  person  who  is  employed  for  2.080  hours/year  (8 
hours/day- 5 days/week). That is to say some 260 days/year including paid vacations and holidays, that leaves 
approx. 220 of actual working days/year. All calculations shown in this chapter are based on these baseline data. 
238  https://www.eca.europa.eu/it/Pages/Transparency-staff.aspx.  Taking  as  a  reference  a  higher 
administrator role should reasonably compensate for not taking into account the cost of mission per diems and 
other benefits. 
239see ch.4 of “European Parliament, DG for Internal Policies- The cost of each EUR of the EU budget to implement 
EU policies in MS: mastering implementation costs of European grants”, 2016. In this chapter, as an example, 
the  cost  for  managing  the  Horizon2020  programme  at  EU  level  is  estimated  at  2%  of  the  value  of  signed 
agreements. The average value found in the DG REGIO study of 2018 for ESIF was approx. 4%. 

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capacity to handle some specific implementation issues that we have already outlined in 
this evaluation. 

For what concerns the time devoted to the management of the school scheme at the 
level of MS and/or regional authorities.  

The  analysis  of  the  information  collected  in  the  PA  survey  and  in  the  CS  provided  the 
following  results  for  what  concerns  the  administrative  tasks  that  are  proving  more 
demanding: 

 

the number of PAs that answered the questions regarding time needed to implement 
the different scheme's tasks was 6 out of 12 in the framework of the CS and 15 out of 
30 in the framework of the PAs survey, with a total response rate of 21 out of 42 (50%). 
In some cases, their answers could not be duly compared, either because they were 
expressed with different time units, and/or providing only a qualitative reply instead of 
a precise amount of time. This probably depends also on the limited attitude to estimate 
the actual time devoted to specific tasks needed to manage the EU scheme240; 

 

  when looking at the overall ranking in term of time spent for the six main tasks assessed 
(Application  for  EU  reimbursement-  Amendments  to  strategy-Budget  changes-
Preparation  of  AMRs-Contact  with  stakeholders-OSCs  &  other  controls-  Other  tasks) 
the PAs  survey  shows that the 15  respondents placed  OSCs  & other controls at first 
place,  with  34%  of  total  time  devoted  to  the  scheme’s  implementation,  followed  by 
Application  to  the  EU  for  costs  reimbursement  (19%),  and  by  Contacts  with 
stakeholders  (9.8%).  The  “Other  tasks”  category  (representing  some  24%  of  total 
reported time) is usually represented by checking of the received aid applications; 
in both surveys the variation in the amount of time stated by the different MS is quite 
high for some tasks (e.g., contacts with stakeholders and carrying out of OSCs). This 
does not find an apparent explanation neither in the model adopted for the suppliers’ 
selection at MS scale, nor in the number of schools participating to the EU scheme in a 
given  MS/region241.  On  the  other  hand,  the  tasks  concerning  requests  for  budget 
reallocation,  delivery  of  the  AMR,  and  monitoring  &  evaluation  activities  show  less 
variation among MS, and apparently require a very limited amount of time/year (each 
representing less than 1% of total time needed to manage the scheme); 
the  strong  variation  recorded  among  MS  presumably  means  that  some  of  them  are 
better  internally  organized  for  these  tasks  than  others.  This  conclusion  is  indirectly 
confirmed  when  looking  at  the  system  adopted  for  suppliers’  selection  and  product 
distribution  (centralized  or  local)  and  to  the  number  of  schools  reached  by  the  EU 
scheme: there is no apparent link between a type of distribution system and the time 
needed  to  manage  the  scheme  at  MS  level.  What  makes  a  major  difference  in  the 
relative efficiency of every MS (in terms of human resources allocated to manage the 
EU  scheme)  is  the  recorded  outreach  of  the  scheme,  measured  by  the  number  of 

 

240This is indirectly confirmed when comparing for example the figures stated in two MS in the two distinct surveys. 
In  the  CS  survey  (01/2022)  the  interviewed  representative  of  one  MS  NA  estimated  in  2  FTE  (full-time 
equivalents)/year the total time needed to manage the scheme at national scale. In the PA survey (06/2022) the 
interviewed representative declared that 100 working days (equivalent to approx. 0.4 FTE/year) were needed. A 
similar,  strong  difference  can  be  found  in  the  case  of  another  MS:  0.1 FTE/year  in  the  CS  survey,  and  over 
6 FTE/year in the PA survey.  
241Intuitively, one could have expected that in MS adopting a decentralised system for choosing suppliers (where 
the main responsibility is on every EE’s) the burden on NA would have been lighter. Yet the figures show that 
Croatia records a high amount of working days/year compared to the approx. 800 schools involved in the scheme, 
whereas Poland, with a similar distribution system, is recording a much lower number of working days compared 
to the approx. 11 800 schools participating to the EU scheme. In essence, the internal organization of NAs seems 
to play an important role in determining the administrative costs at stake in every MS. 

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 

schools involved242: the more schools involved, the more efficient the related use of 
human resources; 
in more details, according to the CS survey, carrying out OSCs by NAs tends to need 
from  1  working  day  (Romania)  to  2.5  (Bavaria,  Poland)  and  up  to  5  working  days 
(France,  Czech  Republic)  for  NAs.  Another  2-3  working  days  are  needed  for  their 
planning.  The  main  issue  here  is  uneven  quality:  apart  from  the  areas  where  more 
assistance  and  clarifications  might  prove  helpful  (see  also  8.2.1),  another  complaint 
raised in one case referred to the fact that OSCs concern only budget issues, not other 
relevant outcomes  of the scheme’s implementation (e.g., perception by children and 
their families, change in dietary habits, visibility of EU support, policy regarding farming 
and health)243; 

 

  given  this  picture,  it  could  be  advisable  to  revise  the  Key  and  Ancillary  Controls 
concerning the EU scheme (released on 01/08/2017). Adding to this improvement, the 
organisation of capacity building activities might presumably led to a simplification of 
the  current  work  for  implementing  the  OSC  task  of  the  scheme  at  MS  level,  and  to 
facilitate  an  improvement  in  the  carrying  out  of  next  EC  audits  (where  the  proper 
carrying out of OSCs has been highlighted as a recurring problem-see previous section 
of this paragraph); 
the data also show that a wide internal variation is present when analysing the  total 
time devoted for managing the scheme by NAs and by regional authorities (from the 
107  working  days/year  of  Lower  Saxony  in  DE  to  the  1535  working  days/year  in 
Wallonia; from the 581 working days/year of Croatia to the 1974 working days/year in 
Poland; 
this wide variation in some data provided is confirmed by the high variation in the total 
amount of working days/year needed to manage the EU scheme: we pass from some 
600 working days/year (equivalent to approx.3 FTE, as in the case of Sweden, which 
records the lowest amount of time for managing the scheme-in this case limited to the 
Milk part) to 1 500/1900 (equivalent to 5-6 FTE/year, as in most MS and regions); 
  7 out of 15 answering MS/regions highlighted procedures and/or administrative areas 
where a simplification would be desirable. Such areas are underlined with almost equal 
strength: - preparation of the AMR, - carrying out of the OSCs, - application procedure 
to receive reimbursement from EU and the “Other tasks” area (usually the time needed 
to perform checks on applications received by schools and suppliers).  

 

In  conclusion,  our  evaluation  did  not  find  any  particular  and/or  relevant  administrative 
costs directly caused by the implementation of the EU school scheme. The main concerns 
expressed  by  the  interviewed  MS  and  regional  authorities  referred  to  national  and/or 
regional  norms  regulating  its  implementation  at  local  scale.  In  several  cases  various 
stakeholders  complained  about  the  lack  of  clarity  and  shifting  responsibility  amongst 
separate public national and regional authority units responsible for the implementation of 
the EU scheme.  

The  only  remark  commonly  mentioned  in  most  CS  regarded  the  difficulty  in  precisely 
reporting  the  number  of  children  participating  in  each  part  of  the  EU  scheme,  and  the 
variable accuracy in reporting data, that greatly depends on the willingness of teachers to 
properly collect them. Another remark raised (e.g., Sweden, Spain) concerned the option 
for simplifying the request for payments, making them dependent on the total amount of 
milk (litres), and of F&V (kg) distributed, rather than on the number of distributed portions. 

242This  appears  coherent  with  the  key  conclusions  found  in  the  DG  REGIO  study  “New  assessment  of  ESIF 
administrative costs and burden”, 2018 (p. 10). 
243 The fact that the OSCs and audits are often the only opportunity to get directly in touch with representatives 
of the NAs and of EU amplifies their importance and potential role. In our view this recorded complaint wished to 
raise the issue that, next to budget concerns, other issues ought to be duly monitored and discussed with the 
ultimate beneficiaries of the EU scheme. 

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Judgement criterion 7.2: Transparency  -  the adopted procedures  are based 
on  reliable  and  relevant  information,  and  enable  useful  feedback  by  key 
actors (public authorities) involved in the EU school scheme 

Collection of relevant and unbiased evidence about the scheme’s implementation 

The main sources of evidence about the EU school scheme implementation at MS/regional 
scale are: 

  MS/regional strategies  notified every 6  years to the  EC and are published on the  EU 
school  scheme  web  site  (Art.  23(8)  of  Regulation (EU) N 1308/2013,  Art.  2(3)  of 
Regulation (EU) N 2017/40 and Art. 2 of Regulation (EU) N 2017/39. 

  Annual  Monitoring  Reports  (AMR):  they  are  sent  by  MS  once  a  year,  by  the  31st  of 
(Article  9(3)  of  Commission  Delegated  Regulation (EU) N 2017/40, 

January 
Articles 8(1) and (3 of Commission Implementing Regulation (EU) N 2017/39. 

Other  important  documents  are  MS  amendments  to  strategies  (Art.  23(8)  of 
Regulation (EU) N 1308/2013 and 2(4) of Regulation (EU) N 2017/40), and MS requests for 
(3)  of 
Union  aid 
Regulation (EU) N 2017/39). 

(3)  of  Regulation (EU) N 1308/2013  and  Art. 

(Art.  23a 

The  evaluation  shows  that  collection  of  relevant  evidence  is  in  some  cases  affected  by 
omissions  and/or  less  than  optimal  quality  of  data  provided  by  MS  and/or  regional 
authorities (e.g., some German Landers), mainly in the compilation of the AMRs via ISAMM 
forms.  This  problem  affected  several  MS  in  different  years,  with  no  identification  of  a 
particular  common  pattern.  As  a  result,  completeness  and  comparability  of  provided 
information  about  the  scheme’s  implementation  is  not  always  ensured.  More  complete 
information could be of relevant importance for assessing the cost efficiency of the scheme 
(e.g.,  precise  number  of  children  participating  in  each  part  of  the  scheme;  expenditure 
recorded for providing each type of educational measures and/or for products’ distribution, 
etc). 

Two  factors  may  have  contributed  to  this  problem:  the  initial  phase  for  implementing 
Regulation (EU) N 1308/2013 from August 2017, that required more detailed information 
compared to the previous two schemes in place until 2017, especially for the milk part of 
the scheme; and the outbreak of the Covid-19 pandemic, that has hampered most phases 
of the scheme implementation from the spring 2020 (especially provision of AEMs)244.  

Taking  into  account  that  the  procedure  for  the  collection  of  relevant  information  is 
regulated by art. 25 (4) of Regulation (EU) N 1308/2013 for what concerns the F&V part of 
the scheme, where it states that, “The Commission may adopt implementing acts laying 
down the measures necessary  for the application of this subcomponent, including … the 
submission, format, and content of monitoring and evaluation reports by MS participating 
in  the  Union  school  fruit  and  vegetables  scheme”,  and  that  the  relevant  reference  for 
monitoring  is  article  9(3)  of  delegated  Regulation (EU) N 2017/40,  it  looks  possible  to 
request MS to provide more precise and complete data about the scheme’s implementation.  

Relevant data  regarding the scheme are open to stakeholders’ view, and they have 
the opportunity to provide  feedback and inputs potentially useful for improving the 
scheme’s performance  

Sharing of the scheme’s key outcomes with the possibility of providing feedback fulfilling 
the Transparency criterion has been carried out so far mainly through: 

  presentations of short summaries based on the AMRs to the Civil dialogues group for 
Horticulture and to the one for Milk; in both cases this happens once or twice/year; 

244  Another  factor  that  may  have  hampered  the correct provision of  data  is  the  inertia  with  which  PAs  usually 
react to a change in the mandatory norms they need to comply with-see to this regard also the result of the DG 
REGIO study “New assessment of ESIF administrative costs and burden”, 2018 (p. 13).  

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 

  meetings of the Expert Group for Agricultural Markets concerning aspects falling under 
the CMO regulation, Animal Products, which acts as a forum for discussion with experts 
of MS, and enables exchange of experience; this group tends to meet on average twice 
a year; 
the section of the main DG AGRI web site devoted to the EU school scheme245. The 
web site mainly presents statistical data (a fairly complete database/research engine) 
and  materials  (strategies  and  monitoring  reports),  jointly  with  a  dissemination 
factsheet. It does not include any relevant policy and/or evaluation document, nor any 
tool  to  receive  requests  and/or  suggestions  from  relevant  stakeholders  involved  or 
interested in the scheme’s design and implementation. 

We checked the data regarding the visits to the pages of the web site from 2018 to 2021, 
and we found that: 

  no  data  are  available  for  2018,  because  in  that  year  the  DG  AGRI  web  site  was 
transitioning to a new web site and content was split between the old and the current 
web site; 

  data available from 2019 to 2021 show a stark increase in the number of pageviews 
(performed both via direct access to specific pages and after a google search): the total 
number of page visits passed from 10 033 in 2019 to 26 079 in 2020, to reach 30 479 
in  2021  (with  a  303%  increase  compared  to  2019).  A  similar  increase  apparently 
affected also other parts of the DG AGRI web site, and the fact that most people were 
forced to stay at home for a longer time due to the Covid-19 pandemic surely played a 
role, but the recorded figures represent indeed a remarkable and positive change.  

The evaluation shows that the main and regular opportunity for stakeholders to provide 
inputs potentially useful for the scheme’s performance happens on a yearly basis via the 
AMRs. Taking into account the limited success of the scheme compared to its planned goals 
(both  in  terms  of  budget  spent  and  for  what  concerns  its  contribution  to  healthy  eating 
habits), increasing the opportunities offered to stakeholders in order to provide feedback 
and  inputs  potentially  useful  for  improving  the  scheme’s  performance  could  prove  very 
helpful.  

The information gathered through interviews in the case study MS shows the appreciation 
by the large majority of public authorities for the easy and prompt support provided by DG 
AGRI whenever needed. A sensitive issue remains the state of the communication chain 
between  the  local/regional  scale  and  the  national  one  (e.g.,  uneven  opportunities  to 
exchange relevant comments and feedback). A similar problem, raised in one CS, referred 
to  the  fact  that  representatives  of  schools  and  of  regional  governments  considered  the 
chances available for providing feedback to NAs about the EU school scheme quite limited.  

Another  relevant  issue  concerns  networking  by  the  EU  with  and  among  the  EU  scheme 
participants. We noted that, although networking activities are foreseen to be supported 
in art. 27 (9) of Regulation (EU) N 1306/2013, no clear evidence of such potentially useful 
activity has been so far recorded:  only the Dutch NA appears to have  contacts  with the 
French one in order to exchange experience about the scheme’s implementation.  

This situation limits both the chances to gather useful feedback from and to ensure proper 
participation of those who implement the scheme on the ground, facilitating learning from 
others’ experience. As a matter of fact, this need was expressed in several CS interviews 
with NAs (e.g., Czechia, Spain, Italy, Lithuania, Poland). This suggestion regarded either 
the  overall  scheme’s  implementation  or  specific  aspects  that  are  considered  more 
important  by  some  MS  (e.g.,  AEM  delivery,  communication  methods  and  tools  between 
across different administrative levels within the same MS, etc). 

245https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-policy/market-
measures/school-fruit-vegetables-and-milk-scheme/country_en ). 

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Judgement  criterion  7.3:  Learning  -  the  adopted  procedures  represent  an 
opportunity for learning by all the key actors (Public Authorities) involved in 
the EU school scheme management  

Use of high-quality internal norms and procedures  

The results of the analysis show that: 

 

 

 

 

 

the guidelines available to MS to send their AMRs are considered by the large majority 
of CS MS/regions clear and concise. However, they mention 22 times in their 12 pages 
instructions  for  “not  mandatory”  information,  and  in  three  cases  some  of  them  are 
anyway “encouraged” to be delivered to the EC. Although understanding that some MS 
may  have  in  the  past  found  problems  in  gathering  the  relevant  information,  this 
approach may prove confusing (as confirmed by one Case Study); 
the guidelines prepared to assist the delivery of the Strategies appear quite short, and 
more extensive explanatory comments and examples could help their use; 
there  are  currently  no  guidelines  to  guide  MS  in  the  submission  of  amendments  to 
Strategies, apart from the clarifications listed at page 4 of the Questions and Answers 
to assist MS in the implementation of the  EU school scheme”, issued  by the “Expert 
Group  for  Agricultural  Markets  concerning  aspects  falling  under  the  CMO  regulation, 
Animal Products”, issued on 15/9/2017; 
there  are  no  apparent  tools  to  facilitate  monitoring  and  evaluation  of  accompanying 
educational  measures  by  MS  and  regional  authorities,  apart  from  the  clarifications 
included  in  the  already  mentioned  “Questions  and  Answers  to  assist  MS  in  the 
implementation of the EU school scheme” (pages 7 to 10); 
the set of norms concerning the carrying out of EU financial and administrative audits 
is  contained  in  the  document  “Key  and  ancillary  controls  concerning  the  school 
scheme”, issued by DG AGRI in 1/8/2017. 

As  a  consequence,  every  stakeholder  at  MS  level  involved  in  the  EU  school  scheme 
management  must  currently  check  a  total  of  at  least  six  distinct  sources  of  rules  and 
guidelines: two EU regulations, two guidelines, a set of “Q&A”, and a document regarding 
EC  audits.  This  may  prove  time-consuming,  and  may  create  difficulty  in  correctly 
interpreting some relevant elements of the scheme’s implementation.  

Current norms/procedures are comprehensive and enable to concentrate on the most 
critical aspects of the scheme’s implementation  

In  this  regard  we  noted  that  the  procedures  currently  adopted  comply  with  the 
requirements set in the implementing Regulation (EU) N 2017/39, covering every relevant 
task foreseen in such act to properly manage the scheme’s implementation at EU level.  

The  monitoring  tools  used  focus  on  basic  data:  budget  expenditure  and  number  of 
participants to the two  parts  of the scheme. Other potentially useful information can be 
retrieved  under  the  “non-mandatory”  data  (e.g.,  themes  and  types  of  the  educational 
measures, communication activities carried out). Knowledge of other economic, social and 
environmental  aspects  of  the  scheme’s  implementation  that  play  an  important  role  for 
achieving its planned goals are paid less attention (e.g., information about food wasted, 
consumption of organic products, actual involvement in AEMs). 

Moreover, little attention is devoted to better understand how distinct administrative levels 
of PAs exchange data regarding the scheme’s implementation, and to facilitate the adoption 
of appropriate monitoring and communication tools at MS, regional, local and school scale, 
in  accordance 
implementing 
Regulation (EU) N 2017/39.  For  instance,  a  CS  interview  showed  that,  while  cooperation 
tends to be more established at Ministry level, communication between national authorities 
and lower administrative levels can prove less than optimal. Every MS retains the flexibility 
to implement the EU school scheme according to their specific cultural and socio-economic 

stated  at  art.  2(2)(g)  of 

to  what 

the 

is 

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context  (subsidiarity  principle),  yet  fostering  the  sharing  of  best  practices  in  monitoring 
and reporting more precise data regarding the scheme’s implementation appears a priority.  

For example, this could be carried out by facilitating the adoption of common templates 
among schools within every MS, and of digital tools for recording and analysing data at MS 
level, and/or among different MS. To this regard, some MS (e.g., Lithuania) are currently 
introducing apps available on smartphones to better track the precise number of children 
attending different parts of the scheme, and that may greatly ease their proper reporting, 
especially if such apps are tested, improved and shared among several MS.  

From the CS we carried out, we can report that several NAs would like to have the chance 
to share the outcomes of EC audits and of AMRs delivery with other MS. From this overview 
derives the conclusion that the understanding of EU norms/procedures at MS level can be 
improved  in  order  to  implement  the  scheme  at  a  high-quality  level,  and  that  current 
opportunities for learning from other MS experience is rather limited. 

Judgement criterion 7.4: Accountability  -  Adopted procedures are based on 
reliable and relevant information, and their outcome supports both the policy 
cycle and the accountability duty  

Evidence from the scheme’s implementation and monitoring is made available to feed 
into the ongoing, overall policy development process  

The evidence deriving from the scheme’s implementation is that its outcomes are so far 
embedded  in  the  overall  EU  policy  cycle  via  the  interservice  group  composed  by 
representatives  of  several  DGs,  and  via  the  ongoing  work  on  the  impact  assessment 
process for reviewing the scheme’s structure246.More recently (from 5 May to 28 July 2022) 
the EC launched a public consultation for the review of the EU school scheme. 

Taking into account the growing interest testified by the rising number of visits to the web 
site, and the many potential impacts of the scheme (most of them in line with the “Farm 
to Fork “strategy), this may prove not sufficient to use the lessons learnt from the scheme 
for  improving  the  overall  policy  development  process.  It  is  not  clear  to  what  extent  the 
work  of  the  “Expert  Group  for  Agricultural  Markets  concerning  aspects  falling  the  CMO 
regulation, Animal Products” can play a role in this regard, given the limited duration of 
such meetings and the fact that their agenda usually includes several other points to be 
discussed.  

The  findings  of  the  case  study  interviews  confirm  that  the  legal  basis  of  the  EU  school 
scheme is fully understood by the school scheme managing authorities. Also, the key policy 
outcomes of the scheme’s implementation (i.e., its potential impact on EU policy regarding 
food,  health  and  farming)  could  be  made  more  visible  and  understandable  to  key 
stakeholders. 

For instance, an option that could be considered entails the issue, on a yearly basis, of a 
“policy brief” outlining what the main outcomes of the EU school scheme are (e.g., social 
and economic results, and/or a special focus on some specific and relevant areas-organic 
products,  consumption  trends,  etc),  and  how  they  fit  into  the  key  EU  policy  regarding 
health, food and farming (e.g., compared to the milestones and targets set in the “F2F” 
strategy). This tool could be discussed with the key DGs affected by the scheme results 
(as  a  policy  tool),  but  also  distributed  to  the  stakeholders  involved  in  the  scheme’s 
implementation, as a EU dissemination tool. 

246 The Better Regulation Toolbox (p.10- version 2021) defines “Embedded in the planning and policy cycle” as 
“Evidence from all preparatory and analytical work, including stakeholder consultation, should feed into the policy 
development process”. An interesting debate is nevertheless ongoing about this issue- see for instance “Towards 
an  Evidence-Based  and  Integrated  Policy  Cycle  in  the  EU:  A  Review  of  the  Debate  on  the  Better  Regulation 
Agenda”, by G.Listorti and others, JRC- JCMS 2020 Volume 58. Number 6. pp. 1558–1577. 

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Gathering,  assessing  and  conveying  best  available  evidence  in  order  to  foster  the 
achievement  of  the  scheme’s  original  goals  and  the  continuous  improvement  of  its 
implementation  

From  the  analysis  portrayed  in  the  previous  parts  we  can  conclude  that  the  procedures 
adopted at  EU level appear more  focused  on  monitoring and evaluating the objective  of 
increasing  the  consumption  of  some  agricultural  products  among  children  than  on  the 
overall improvement of their eating habits. The majority of the monitored data concerns 
the first topic (e.g., number of participating children and of distributed quantities), and the 
budget  spent  on  its  implementation,  although  with  the  limits  already  highlighted  in 
previous paragraphs (e.g., some data are missing or cannot be considered fully reliable). 
Given this picture, and the fact that other relevant elements to assess cost efficiency and 
the scheme’s impacts are not present in the current format of AMRs (e.g., budget spent 
on each AEMs type, more precise accounting of students participating to the two parts of 
the  scheme  in  order  to  prevent  as  much  as  possible  double-counting  risks,  etc)  new 
opportunities for the continuous improvement of the EU scheme implementation should be 
identified.  

The need for such constant improvement led us to check one additional aspect that share 
a horizontal relevance for this judgement criterion, and in particular for the Accountability 
criteria: the type of information available on the EU web site (that affects the access to the 
scheme’s content). 

From the analysis of the EU web site and of the national web sites that can be accessed 
via the EU site we noted that: 

  MS  strategies  and  AMRs  are  regularly  displayed  (after  due  clarifications  have  been 

received by MS- this may take a long time); 

  no MS is displaying evaluation reports on the main EU web site, that routinely shows 
only  strategies  and  monitoring  reports  (a  few  MS  display  evaluation  reports  in  their 
national web sites: Austria, Germany, Italy, The Netherlands); 
some MS still show two separate web sites for the two parts of the scheme (e.g., Italy, 
Slovenia); 

 

  no FAQ section is included. 

4.3.2.3  Conclusions  

The ESQ7 asks to assess to what extent the rules of the EU school scheme are  efficient 
with regard to the procedures at EU level. 

On the basis of the results of the analysis under each judgment criterion, we can highlight 
the following key conclusions: 

  Human  resources  allocated  to  manage  the  scheme  at  EU  level  (estimated  in  5  FTE 
units) appear adequate, and their total cost in line with other EU funding programmes, 
yet approx. half of the time of the current internal procedures is allocated to budget 
and financial controls (including the carrying out of EC audits) and to the clarification 
of  AMRs  content.  Devoting  more  time  to  the  gathering  and  analysing  important 
information regarding other critical economic, social and environmental aspects of the 
scheme’s implementation might help to improve the scheme’s overall success. 

  Human resources allocated to manage the scheme at MS/regional scale appear quite 
variable, apparently depending on the internal organization of these MS rather than on 
the number of EEs participating in the scheme. The tasks that are  reported as more 
time-consuming  are  the  carrying  out  of  OSCs,  application  for  EU  reimbursement, 
contacts with stakeholders, and check of aid application received at sub-national scale. 
Several stakeholders complained in the CS survey that the amount of work needed to 
properly implement the EU scheme is very high compared to the limited amount of aid 
received;  this  complaint  is  more  often  raised  in  MS  where  the  use  of  paper  work  is 
higher. 

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  Available guidelines are considered clear and concise by public authorities interviewed 
in CS MS/regions, yet such bodies could benefit from merging the many documents at 
stake  in  a  unitary  set  of  common  provisions,  enhanced  by  more  practical  examples; 
this  would  probably  ease  the  administrative  costs  for  the  MS.  In  practice  this  would 
require the EC to bundle the text of all relevant EU documents (e.g., EU regulations, 
existing  or  new  guidelines  to  fill  reports,  note  to  the  Permanent  Representations 
regarding submission of the Strategies, the Key and Ancillary controls concerning the 
school scheme - 2017, etc.) into an harmonized and more user-friendly text.  

  The  AMR  could  comprise  more  detailed  and  disaggregated  information,  able  to  be 
analysed  in  order  to  provide  useful  insights  about  several  cost  efficiency  issues, 
although some CS interviews reported that PAs would prefer to simplify the amount of 
data to be sent to the EU. This latter opinion was confirmed by four respondents to the 
PA survey. 

  More frequent or focused exchanges between DG AGRI, other relevant DGs and school 
scheme managing authorities focused on specific issues to analyse and discuss feasible 
improvements and most likely policy impacts (that could prompt the issue of a yearly 
policy  brief  to  key  stakeholders)  of  the  EU  scheme  implementation  might  support  a 
better implementation of the scheme.   

  Some  areas  where  MS  need  more  support  and/or  guidance  have  been  identified: 
carrying out of OSCs and of EC financial audits, adopting digital solutions to deal with 
suppliers  and  for  reporting  student  participation  to  the  distinct  parts  of  the  scheme, 
preparation  of  the  AMRs).  Appropriate  tools  could  be  put  in  place  to  ease  MS  work: 
revision  of  the  current  EU  guidelines,  organization  of  capacity  building  workshops, 
sharing of identified best practices, etc. 
In  overall  terms,  monitoring,  evaluation  and  networking  activities  with  national 
stakeholders (especially in order to share lessons learnt and best practices) might be 
better promoted and supported. In short, a more pro-active and strategic approach is 
advisable, and it looks feasible within the mandate assigned and the rules governing 
the work of the EC. 

 

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4.4  Coherence 

4.4.1  ESQ 8 - To what extent has the EU school scheme been coherent with other 

measures and instruments of the CAP?  

4.4.1.1  Background and methodological approach  

Understanding 

The  evaluation  question  asks  to  assess  the  internal  coherence  of  the  EU  school  scheme 
with respect to other relevant CAP measures and instruments (1st and 2nd Pillar). To this 
end,  the  Better  Regulation  Guidelines  indicates  that  coherence  with  other  related  policy 
instruments  must  be  considered  to  exploit  synergies  and  to  avoid  undermining  the 
effectiveness  of  existing  instruments  or  raising  compliance  costs.  Different  policy 
instruments or different EU policies, in fact, may compete (albeit to different extents) in 
the achievement of some of the EU priorities identified by the Commission for the 2014-
2019 and 2019-2024 years247. 

Definition of key terms 

Coherence is defined as the extent to which the various components of a policy operate 
together to achieve the policy objectives. Therefore, the judgement on the coherence is 
expressed according to whether: 

 

 

 

the school scheme contributes with other relevant CAP measures to the achievement 
of the same policy objective (coherent); 

the  school  scheme  does  not  have  any  relationship  with  the  other  CAP  measures 
addressing the same policy objective (neutral); 

the school scheme runs in the opposite direction relative to the other CAP measures 
addressing the same policy objective (non-coherent).   

Judgement criteria, indicators and sources 

In order to reply to the evaluation question, our judgement is based on the following criteria 
and indicators.  

Judgement criteria 

Indicators 

Sources 

JC8.1:  The  EU 
school 
scheme  is  coherent  with 
other 
and 
relevant 
appropriate  measures  and 
instruments  of 
the  CAP 
working in the same area 

-  Legal framework for other 
and 
policies 
implementing 

CAP 
measures, 
instruments 

-  Logics of intervention 
school 
-  EU 
strategies 2017-2023 

scheme 

-  Literature review 
-  Public Authorities Survey 
-  Results of ESQs 1, 3, 5, 6  
-  Structured  interviews  in 

CS MS/regions 

8.1.1 Judgement on the coherence of the school 
scheme  with  the  other  CMO  measures  acting  in 
the F&V and milk  
8.1.2 Judgement on the coherence of the school 
scheme with direct payments  
8.1.3 Judgement on the coherence of the school 
scheme with relevant RDP measures, in particular 
RDP measures encouraging short food chains and 
local markets 
8.1.4 Judgement on the coherence of the school 
scheme  with  CAP  measures  enhancing  the 
organic sector 
8.1.5 Judgement on the coherence of the school 
scheme  with  EU  quality  policy  (Regulation  (EU) 
No 1151/2012) 
8.1.6 Judgement on the coherence of the school 
scheme  with  relevant  and  appropriate  CAP 
measures  supporting  promotion  and  information 
on agriculture products  

247https://www.europarl.europa.eu/EPRS/EPRS-Briefing-538963-Setting-EU-Priorities-2014-19-FINAL.pdf, 
https://ec.europa.eu/info/strategy/priorities-2019-2024_en  

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Methodological approach and its limitations 

Tools, method and sources used 

To  answer  this  question,  the  objectives  of  the  EU  school  scheme  illustrated  in  the 
intervention  logic  (see  2.2.2:  increase  consumption  of  selected  F&V  and  milk  products, 
promote healthy eating habits and shape healthier diets and the objectives of viable food 
production to which the scheme should contribute: maintain market stability, enhance farm 
income, improve competitiveness of farm sector, meet consumer expectations) have been 
compared to the objectives of other relevant CAP measures and instruments.  

The sets of measures considered are: 

  Common  Market  Organisation:  Regulation (EU) N 1308/2013  establishing  a  common 

organisation of the markets for agricultural products.  

  Direct Payments: Regulation (EU) N 1307/2013 establishing rules for direct payments 

to farmers. 

  Rural  Development  Measures:  Regulation (EU) N 1305/2013  on  support  for  rural 
development by the European Agricultural Fund for Rural Development (EAFRD). 
  Organics:  Council  Regulation (EC) N 834/2007  on  organic  production  and  labelling  of 

organic products.  

  Regulation (EU) N 1151/2012  on  quality  schemes  for  agricultural  products  and 

foodstuffs 

  Promotion  Policy:  Regulation (EU) N 1144/2014  on 

information  provision  and 
promotion  measures  concerning  agricultural  products  implemented  on  the  internal 
market and in third countries.  
Information  Policy  on  the  CAP:  Regulation (EU) N 1306/2013  on  the  financing, 
management and monitoring of the common agricultural policy. 

 

In addressing this question, the following tools have been used:  

  desk  research:  analysis  of  the  EU  legislation,  DG  AGRI  Strategic  Plan  2016-2020, 
analysis  of  national  and  regional  school  scheme  strategies,  staff  working  documents 
published  by  the  Commission,  evaluations  of  the  CAP  measures  carried  out  by 
independent external contractors, recent official reports, academic papers and studies 
addressing the subject; 

indicators and results relating to other ESQs; 

  analysis of the logics of intervention; 
 
  primary  data  collected  through  the  survey  of  Public  Authorities  at  EU-27  level  and 
through structured interviews with EU stakeholders in case study MS and regions. 

Limitations of methods and sources 

One  limitation  lies  in  the  possible  response  bias  of  school  scheme  managing  authorities 
answering the PA survey. Surveyed PAs are responsible for the planning the of the school 
scheme  strategies  notified  to  the  Commission  and  for  scheme  implementation,  thus  it 
cannot be excluded that “desirable” answers were provided to some extent (e.g., “yes, the 
scheme is relevant with respect to the needs of EU stakeholders”). However, the overall 
results are clear and confirmed by interviews carried out in case study MS. 

As  already  mentioned,  the  lack  of  monitoring  data  on  distributed  organics  products 
prevented  quantitative  analysis.  This  limitation  was  only  partially  overcome  using 
information from case studies. 

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4.4.1.2  Analysis 

Judgement  criterion  8.1:  The  EU  school  scheme  is  coherent  with  other 
relevant  and  appropriate  measures  and  instruments  of  the  CAP  working  in 
the same area 

Coherence with other CMO measures acting in the F&V and milk  

The EU scheme is part of the common organisation of the markets (CMO) in agricultural 
products, which regulates and supports the marketing of agricultural products.  

The  CMO  is  a  key  component  of  the  CAP,  providing  rules  and  measures  to  achieve  the 
policy objectives set out in Article 39 of the TFEU248, in particular with regulation of prices, 
aids  for  the  production  and  marketing  of  the  various  products,  storage  and  carryover 
arrangements  and  common  machinery  for  stabilising  imports  or  exports  (Article 40 
TFEU).The  CMO  has  an  internal  heading,  covering  market  intervention  and  rules  on 
marketing and producer organisations, and an external heading covering trade with third 
countries.  

Measures  under  the  CMO  serve  a  crucial  role  in  the  objective  of  maintaining  market 
stability, and help to improve agricultural competitiveness and increase farm income.   

The EU school scheme aims to increase the direct and indirect consumption249 of selected 
agricultural  products,  in  terms  of  quantity  and  variety,  and  to  boost  demand  of  fruit, 
vegetables, milk and milk products in the future.  Acting on market demand, the scheme 
contributes  to  market  stability  together  with  other  sector-targeted  CMO  measures250 
aiming at the same objective on the supply side. 

In  particular,  the  school  scheme  is  linked  to  marketing  standards  (quality  and  labelling 
rules  for  fresh  and  processed  F&V  and  bananas  and  labelling  rules  for  milk  and  milk 
products),  guaranteeing  a  standardised  quality  to  EU  consumers.  Marketing  standards 
provide  technical  requirements  for  products’  attributes  (such  as  size,  shape  etc),  and 
represent the baseline for many agricultural products placed on the EU internal market. 

The school scheme is linked to the CMO measures251 regulating and fostering producers’ 
organisations  (POs)  and  inter-branch  organisations  (IBOs),  POs  and  IBOs  play  a  role  in 
concentrating supply and reducing transaction costs, and can be suppliers within the school 
scheme252. POs and IBOs operate to a large extent in the F&V and milk sector: in the EU, 
52% of all recognised POs operate in the F&V and 9% in the milk and dairy sector; 23% 
of IBOs operate in these two sectors253. 

In particular for F&V, the school scheme is linked to the PO’s supported activities carried 
out  within  their  operational  programmes.  Such  activities  are  mainly  aimed  at  improving 

248Article 39 TFEU: The objectives of the CAP shall be (a) to increase agricultural productivity; (b) to ensure a fair 
standard of living for the agricultural community; (c) to stabilise markets; (d) to assure the availability of supplies; 
(e) to ensure that supplies reach consumers at reasonable prices. 
249Direct consumption: the consumption of F&V, milk and milk products distributed under the school scheme and 
consumed at school. Indirect consumption: the consumption of F&V, milk and milk products outside the school 
(outside the period of distribution under the school scheme as well as at home). 
250European  Commission,  Evaluation  of  Marketing  Standards  contained  in  the  CMO  Regulation,  the  “Breakfast 
Directives” and CMO secondary legislation: final report, 2020. Commission Staff Working Document: Evaluation 
of the impact of the CAP measures on the general objective 'viable food production' {SWD (2021) 106 final}. 
European  Commission,  DG  AGRI,  Evaluation  study  of  the  impact  of  the  CAP  measures  towards  the  general 
objective “viable food production”: final report, 2020.  
251The setting up of new POs and organisation is supported under the rural development policy . 
252For example, in Italy 6 of the 9 suppliers selected for the F&V distribution (2021/2022) are POs.  
253Source:  DG  AGRI,  2018  https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-
policy/market-measures/agri-food-supply-chain/producer-and-interbranch-organisations_en . 

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the planning of production (25,5% of total EU expenditure, 2019)254 and product quality 
(24.4%), and also refer to promotion and communication (2.5%) and organic production 
(1.2%). 

Aiming at market stability, the school scheme is also coherent with other CMO measures 
targeting at market balance and limiting the internal volatility, used in cases of necessity: 
public  intervention  (butter  and  skimmed  milk  powder),  private  storage  (butter,  cheese, 
skimmed milk powder), and exceptional measures255.  

These  findings  are  confirmed  by  the  surveyed  PAs,  responsible  at  national  level  of  the 
scheme planning and implementation. Most of them (56%) consider the school scheme to 
be  coherent  with  market  measures  and  40%  consider  it  coherent  with  POs  supported 
activities.  Synergies  with  PO’s  promotion  activities  and  private  storage  schemes  were 
confirmed by interviewed economic operators in Italy, Poland, Germany.  

However, more in general, the results of the survey show that, in the opinion of the PAs, 
the  link  between  the  school  scheme  and  other  CAP  measures  is  not  strong  (with  the 
exception of market measures and, to a lesser extent, organics and promotion policy). In 
about 43% of cases256, it was indicated that the scheme has no relationship with other CAP 
measures  (neutrality).  Furthermore,  during  the  CS  interviews  (public  authorities  and 
economic  operators)  it  has  often  been  emphasised  that  agricultural  aspects  are  not  the 
main focus of the scheme, but rather the area of healthy eating, and this aspect played a 
decisive role in the planning of the scheme. See also ESQs 5 and 9. 

Coherence with direct payments  

Direct  payments  are  the  CAP  core  instrument  to  support  farmers  income,  provided  that 
farmers  comply  with  standards  relating  to  food  safety,  environmental  protection  and 
animal  health  and  welfare.  Direct  payments  aim  at  support  farmers’  income  level:  the 
policy  aims  at  achieving  a  level  of  income  for  farmers  comparable  to  non-agricultural 
incomes in order to ensure a fair standard of living to the agricultural community.  Direct 
payments  also  aim  at  stabilise  farmers’  income  in  time,  given  the  volatile  nature  of 
agricultural income. 

The EU school scheme funds the purchase of F&V, milk and milk products to be distributed 
to  schoolchildren,  with  a  direct  effect  on  the  income  of  the  farmers  involved.  Also,  the 
scheme  aims  to  induce  a  long-lasting  increase  of  the  demand  of  these  products,  thus 
impacting present and future farmers’ revenues.   

Since the rationale of the CAP is to consider that farmers’ income should be composed of 
market  revenues  supplemented  with  direct  payments257,  it  can  be  concluded  that  the 
school  scheme  objectives  contribute  to  direct  payments  vis-à-vis  the  CAP  income 
objective.   

However, given the relatively small distributed quantities (ESQs 1 and 5) it is evident that 
the  scheme  can  only  have  a  marginal  effect  on  farm  income  level  (ESQ5).  Accordingly, 
60%  of  surveyed  PAs  considered  that  the  EU  school  scheme  has  no  relationship  with 
income supports or did not answer. 

254 Source: DG AGRI, https://agriculture.ec.europa.eu/farming/crop-productions-and-plant-based-products/fruit-
and-vegetables/sector-reports_en. 
255 In the period 2014-2021, the Commission used such measures to address crises in the milk and F&V sectors. 
256  32 PAs, 18 CAP measures, 4 options of answers (neutral, not-coherent, somewhat coherent or coherent).  In 
31% of cases the option chosen was “not-coherent” and in 26% of cases “somewhat coherent” or “coherent”. 
257 European Commission, DG AGRI, Evaluation study of the impact of the CAP measures towards the general 
objective “viable food production”: final report, 2020. 

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Coherence with relevant rural development measures 

EU rural development policy aims at the sustainable development of  rural areas through 
three  overarching  objectives:  improving  the  competitiveness  of  agriculture,  ensuring 
sustainable management of natural resources and climate action, and fostering a balanced 
territorial development of rural areas.  

One  of  the  approaches  pursued  with  the  rural  development  policy  to  improve  the 
competitiveness of agriculture is the development of short supply chains and local 
markets258.  

The  rationale  behind  policy  support  is  that  local  markets  and  short  supply  chains  offer 
advantages for producers and consumers in economic, social and environmental terms259.   

The  two  concepts,  short  supply  chains  and  local  markets  or  local  food  systems,  are 
different.  Commission  Delegated  Regulation  (EU)  No  807/2014  define  a  “short  supply 
chain” [article 11(1)] as a supply chain involving no more than one intermediary between 
farmer and consumer. RDPs are expected to specify the maximum radius of km between 
the place from which the product originates and the place where the activities of processing 
and sales to the final consumer take place [article 11(2)] or set out a convincing alternative 
definition. As found in the literature, in local food systems “foods are produced, processed 
and retailed within a defined geographical area” where “the local is understood in relation 
to geographical scales, such as the regional, national or global … depending on context and 
purpose” (Kneafsey et al., 2013) (260). 

Therefore,  the  two  concepts  are  different  in  the  sense  that  consumers  can  buy  local 
products  via  long  supply  chains  (several  intermediaries)  or  they  can  buy  products  from 
afar via short chains (e.g., online from the producer). Nevertheless, there are intersections 
in the sense that local food systems can rely on short supply chains. 

The  EU  school  scheme  shares  the  objective  of  enhancing  short  supply  chains  and  local 
markets, including them among the priorities for choosing products and suppliers, and local 
food chains among the themes to be explained to children with the educational measures. 

The analysis shows that 18 out of 43 strategies adopt both priorities - short supply chains 
and  local/regional  products  -  among  the  criteria  for  selecting  suppliers  and  no  strategy 
prioritise short supply chains only.  However, the absence of a clear distinction as for rural 
development support may have led to  some confusion/overlap (from an interview: “The 
strategy  does  not  include  “short  supply  chains”  as  preference  given  to  locally/regionally 
sourced products already includes this aspect”).  

Many PAs and economic operators interviewed during case studies agree on the importance 
of  favouring  locally/regionally  grown  products  and  products  from  short  supply  chains. 
However, one issue seems to be related to the costs of the supply/distribution of products 
(ESQ3): moreover, some operators noted that since prices remained unchanged for years 
(SCO  approach),  it  is  becoming  difficult  to  supply  regional  products  ("the  smaller  our 
margin,  the  less  we  can  consider  regional  producers  and  we  have  to  give  preference  to 
cheap international products").  

258 The EU school scheme objectives are also directly linked to other RD measures: information and promotion 
activities on quality products and new participation in quality schemes, up of producer groups, support to organic 
production. See respective paragraphs. 
259 European Parliament, Short food supply chains and local food systems in the EU, 2016.  Strength2food: Food 
quality for sustainability and health. Strategic guide: Short Food Supply Chains (SFSCs), 2021. 
260 Kneafsey, M., Venn, L., Schmutz, U., Balázs, B., Trenchard, L., Eyden-Wood, T., Bos, E., Sutton, G., & Blackett, 
M. (2013). Short food supply chains and local food systems in the EU (JRC Scientific and Policy Reports). 

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Coherence with CAP measures supporting the organic sector  

The EU recognizes the essential role of the organic sector as an asset for both the land and 
for  consumers,  in  particular  for  environmental  care,  preserving  landscapes  and 
biodiversity, responding to the growing societal demands for quality food produced 
with high environmental, biodiversity and animal welfare standards.  

A sustainable food system is also at the heart of the Green Deal’s Farm to Fork strategy: 
the Commission has set a target of at least 25% of the EU’s agricultural land under organic 
farming and, to achieve this target, is putting forward an Action plan 2021-2027 for the 
development  of  organic  production261.  The  Action  plan  is  divided  into  3  axes  and 
strengthening  the  EU  school  scheme  is  one  of  the  actions  envisaged  within  axis  1  - 
stimulating demand and ensuring consumer confidence.  

The EU school scheme objective (meeting consumer expectations) is coherent with the 
other CAP measures addressing the organic sector262. Indeed, the legislation allows MS to 
give priority to organic products through selection criteria in procurement procedures or 
other  arrangements  and  the  organic  sector  is  one  of  the  themes  of  accompanying 
educational measures. Based on the survey to PAs, the coherence of the scheme with the 
organic  policy  is  perceived  to  be  very  high  at  national  level  (53.1%  of  respondents). 
However, even if half of the MS used the possibility of prioritising organic when selecting 
products  to  be  distributed  in  schools,  the  monitoring  system  does  not  allow  quantifying 
how much of the distributed products are organics.  

Based on the results of the interviews, there is a main issue related to the procurement 
costs  of  organic products (see  ESQ3): these products are, in fact, more  expensive than 
conventional ones and their production costs are not always fully reimbursed; moreover, 
organic products (sometimes) cannot be easily acquired on the local market. Higher costs 
have had an effect on the coverage of the scheme. These considerations are addressed in 
the Action plan 2021-2027, which proposes mitigation measures (e.g., tax measures).  

Furthermore, the findings of the family survey concerning the children’s learning of notions 
in  the  framework  of  the  scheme  highlight  the  need  of  stimulate  the  learning  of  notions 
regarding organic farming. Indeed, the results  show the lowest result for "notions about 
organic farming": all the other lessons exceed 70% of the children, with the sole exception 
of  "about  organic  farming"  (62%).  This  result  is  consistent  also  with  the  fact  that  this 
theme was one of the less addressed by the accompanying educational measures (about 
57 % of MS). 

Coherence with EU quality schemes in the agrifood sector 

The EU quality schemes cover a wide range of products. However, the scope of this ESQ is 
the 
products 
limited 
Regulation (EU) N 1151/2012263  covered  by  the  aid  scheme  for  the  supply  of  fruit  and 
vegetables,  bananas  and  milk  in  the  educational  establishment,  in  accordance  with  the 

agricultural 

Annex 

those 

listed 

to 

to 

in 

I 

261Communication from  the  Commission  to  the  European  Parliament,  the Council,  the  European  Economic  and 
Social Committee and the Committee of the Regions on an action plan for the development of organic production 
COM/2021/141 Final/2. 
262 Under the CAP 2014-2020, organic farmers benefit from several support measures, in particular under rural 
development policy (support for maintenance and conversion to organic farming, investments in organic farming 
practices and aid for marketing and promotion of organic products); also, organic producers qualify for greening 
direct payments and POs of organic F&V benefit from increased co-financing rates. 
263 See also the recent Commission proposal for a Regulation repealing Regulation (EU) No 1151/2012,  Food & 
drink – EU geographical indications scheme (revision) (europa.eu). 

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Regulation (EU) N 1307/2013  (articles  23  to  27),  as  amended  by  Regulation  (EU) 
2016/791, and with the Regulation (EU) N 2017/40 (article 11)264. 

The EU implements a quality policy linking products and their quality characteristics with 
their geographical origin and the specific and traditional know-how linked to the product. 
By  protecting  the  names  of  these  products  as  Geographical  Indications  (GIs)  or  as 
Traditional  Speciality  Guaranteed  (TSG)265,  their  origin,  quality  and  authenticity  is 
guaranteed and it helps producers in informing consumers about the product specificities. 

44%  of  the  GIs/TSGs  in  the  agrifood  sector  belong  to  the  class  “Fruit,  vegetables  and 
cereals fresh or processed” (399 out of 1 464 EU registered names) and “Cheese” (244); 
some  dairy  products  are  also  registered  under  the  Class  1.4.  Other  products  of  animal 
origin (source: the EU geographical indications register, Stand: 2 September 2022). 

The  EU  quality  schemes  under  Regulation (EU) N 1151/2021  (GIs/TSGs  in  the  agrifood 
sector) and the school scheme are coherent with respect to the objective of enhancing the 
competitiveness of the agricultural sector: 

 

 

the  EU  quality  schemes  objectives  are  (among  other  266)  securing  a  fair  return  for 
farmers and producers for the qualities and characteristics of a given product, or of its 
mode of production, helping farmers to improve their competitiveness and position in 
the  food  chain,  and  providing  information  on  products  with  specific  characteristics 
linked  to  geographical  origin,  thereby  enabling  consumers  to  make  more  informed 
purchasing choices; 
the EU school scheme legislation allows to prioritize, where appropriate, the distribution 
of F&V, milk and milk products with GIs/TSGs (Regulation (EU) N 1151/2012) and their 
inclusion in the accompanying educational measures.  Therefore, the scheme aims to 
support  the  direct  consumption  of  GIs/TSGs  products  and  to  increase  awareness  of 
these products. 

Concerning  healthy  diets,  it  must  be  stressed  that  GIs/TSGs  have  no  objective  of  the 
health policy since the concept of quality conveyed is linked to origin, specificities of the 
product and their production methods/know-how, and not with the nutritional properties 
of the concerned products. Therefore, there is no link between quality schemes and healthy 
diets  (neutrality).  For  further  analysis  on  the  coherence  between  GIs/TSGs  and  health 
policies, please refer to the above-mentioned Commission’s evaluation (SWD/2021/0427 
final) the Evaluation support study on GIs and TSGs protected in the EU and the ensuing 
impact assessment 267. 

264 Therefore, alcoholic beverages are out of the scope. In addition, analysis of the nutritional composition of the 
products covered by the two schemes was not required in this evaluation. 
265 According to the Regulation (EU) N 1151/2012, for agricultural products and foodstuffs two types of GIs can 
be registered: protected designation of origin (PDO) for which the raw ingredients must come from the region of 
origin where all steps of production must take place, and geographical indication (PGI) for which at least one of 
the stages of production or processing must take place in the region. TSGs aim to register traditional recipes and 
are not linked to a specific geographical area. 
266  Commission  staff  working  document,  Evaluation  of  geographical  indications  and  traditional  specialities 
guaranteed protected in the EU (SWD/2021/0427 final). 
267  European  Commission,  DG  AGRI,  Evaluation  support  study  on  geographical  indications  and  traditional 
specialities 
2021. 
EU: 
https://data.europa.eu/doi/10.2762/891024.  Commission staff working document SWD (2022) 135 final: Impact 
assessment report accompanying the document Proposal for a Regulation of the European Parliament and of the 
Council on European Union geographical indications for wine, spirit drinks and agricultural products, and quality 
schemes 
for  agricultural  products,  amending  Regulations (EU) N 1308/2013,  (EU) N 2017/1001  and 
(EU) N 2019/787 and repealing Regulation (EU) N 1151/2012. The Evaluation support study concluded that “In 
principle,  no  inconsistencies  were  found  between  the  EU  quality  and  health  policy,  as  the  two  policies  pursue 
theoretically different objectives (…) Provided that it is clear to consumers which angle of “quality” the EU quality 

Publications  Office, 

guaranteed 

protected 

report, 

final 

the 

in 

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The  possibility  to  give  priority  to  products  covered  by  Regulation (EU) N 1151/2012  was 
chosen by Italy and Spain268. Furthermore, the list of eligible products for France (National 
strategy, point 5) mainly refers to products covered by Regulation (EU) N 1151/2021269. 

These implementation choices reflect the distribution of GIs in Europe: 61% of GIs in the 
F&V sector is Italian, Spanish or French (243 out of 399: 120 in Italy, 63 in Spain and 60 
in France) and 141 out of 244 for cheeses (56 in Italy, 55 in France and 30 in Spain).  

Monitoring  data  do  not  provide  data  on  the  quantity  of  GI  products  purchased  and 
distributed under the school scheme. In France the list is binding and, from the information 
gathered through CS, the prioritization was used in the procurement procedures both in 
Italy  and  Spain  (in  Andalusia  products  distributed  for  breakfast  under  educational 
measures must be PDO products). As suggested by previous analysis (ESQ6), this choice 
may have had an effect on procurements costs, explaining higher costs/kg and per child 
than the EU average and limited coverage.  

Coherence with other CAP measures supporting promotion and information  

This part of the analysis investigates the coherence between the  school scheme and EU 
promotion policy of agriculture products and EU information policy on the CAP. 

Based on Regulation (EU) N 1144/2014, the EU Commission co-finances, and also directly 
organises,  information  and  promotion  campaigns  and  events  to  promote  EU  agriculture 
products.  As  stated  in  the  Regulation,  the  EU  promotion  policy270  aims  to  increase 
awareness  of  the  merits  of  EU  products  and  standards;  increase  consumption, 
competitiveness, profile, market share of EU products; increase awareness and recognition 
of quality schemes; restore market conditions in case of problems.  

The  budget  is  set  by  the  Commission  through  Annual  Work  Programmes  (AWPs),  which 
define actions, priorities, objectives and expected results for proposal for simple and multi 
programmes, in the internal market and in third countries. The calls are open to trade or 
inter-trade organisations, producer organisations and agri-food groups.  

The message of promotion activities in the internal market (see AWPs from 2017 to 2022) 
goes to stress the high safety and quality standards of EU agri-food products, their diversity 
and traditional aspects and to increase knowledge about the EU’s quality schemes.  

From 2019 onwards, the promotion of F&V to encourage a balanced and proper diet is a 
specific topic of the policy and receives a dedicated budget allocation (EUR 20 million, 22% 
of  the  budget  for  the  internal  market),  in  line  with  the  Communication  of  the  Future  of 
Food  and  Farming  and  the  Tartu  call  for  healthy  lifestyles271.  Proposals  on  F&V  for  the 
internal market are also eligible under other topics. 

schemes  tackle,  there  is  no  contradiction  between  the  two  policy  areas.  Results  from  the  consumers  survey 
conducted in 7 MS suggest that, overall, consumers do not perceive the products belonging to quality schemes 
as  “healthier”.  However,  consumers  could  still  associate  the  “quality”  message  of  GI  products  to  “healthy” 
properties,  potentially  influencing  their  preference  for  these  products.  Given  the  broad  scope  of  the”  term 
“quality”,  clarifying  the  message  that  the  quality  schemes  convey  could  be  beneficial  could  be  beneficial  and 
would align with the objective of providing reliable information to consumers. These considerations are relevant 
in the context of this evaluation. 
268 Moreover, some MS indicate in the yearly monitoring reports quality schemes among the priorities used to 
choose  products;  however,  the  detailed  information  often  refers  to  national  schemes  or  integrated  crop 
management system, i.e., schemes not covered by Regulation (EU) N 1151/2021. 
269 At lunchtime, only products with official identification sign of quality and origin (PDO, PGI, TSG, Label Rouge, 
Agriculture Biologique ) and products from the outermost regions are eligible. 
270https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-policy/market-
measures/promotion-eu-farm-products_en . 
271 https://sport.ec.europa.eu/sites/default/files/ewos-tartu-call_en.pdf . 

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Before 2019 (2016-2018), the largest share of the budget for internal market was absorbed 
by projects promoting F&V, in third place the programmes promoting dairy products272. 

Based  on  the  logics  of  intervention,  AWPs  analysis  and  confirmed  by  other  evaluation 
studies273,  it  can  be  concluded  that  the  EU  school  scheme  interacts  in  synergy  with  the 
AWPs  towards  the  same  objective  of  promoting  the  consumption  of  F&V  in  the 
context of healthy  diets.  In terms  of measures implemented, activities in schools are 
also eligible under the promotion activities: in this case the target group being the same, 
a risk of overlap with the EU school scheme accompanying educational measures could be 
possible, although very few promotion programmes targeted schools and there are main 
differences between the two schemes (duration, topics).  The information policy on the 
CAP  is  implemented  by  the  Commission  on  the  basis  of  art.  6  and  art.  45  of 
Regulation (EU) N 1306/2013274, with the aim of illustrating how the CAP is a policy for all 
European  citizens  and  influences  their  lifestyles  contributing  to  the  achievement  of  the 
Commission's political priorities, particularly the European Green Deal.  

Part of the budgetary envelope for information actions relating to the CAP goes to the co-
financing  of  information  and  communication  measures  (IMCAP)275.  Every  five  years,  DG 
AGRI  develops  an  external  communication  strategy,  defining  its  specific  communication 
objectives, target groups, main messages and communication tools.  

The  2016-2020  strategy  identifies  five  audience  segments  with  tailored  messages  and 
tools:  schoolchildren,  teachers,  citizens,  young  people;  beneficiaries  of  the  CAP  and 
multipliers as stakeholders.  

The message  of the projects should attract the interest  of  the general public (especially 
young urban dwellers) in relation to food quality and specificity, and healthy eating276. 
The projects can include: TV features, farm visits, information campaigns, audio-visuals, 
apps 
designed 
to educate through entertainment) are used to target schoolchildren and teachers. 

and  media 

Edutainment 

activities. 

packages 

(media 

There is a clear complementary nature and coherence between the EU school scheme, in 
particular the accompanying educational measures, and these projects financed through 
the information policy and using separate funding (EAGF, Operational technical assistance). 
In fact, the 2022 call for proposals explicitly refers to synergies between these instruments: 
“For schoolchildren, teachers and university students: novel approaches should be used to 
engage with young people and raise their awareness of the new CAP and the contribution 
that it makes in many areas such as the climate change challenge, food, healthy and high-
quality eating as a lifestyle choice, in relation also with the EU school scheme for Milk, Fruit 
and Vegetables and the Tartu Call for healthy lifestyles”.  

of 

list 

selected  programmes 

for  2016,  2017,  2018 

272  Source:  European  Commission, 
https://ec.europa.eu/chafea/agri/content/previous-programmes . 
273  See  also:  Commission  Staff  Working  Document,  Evaluation  of  the  impact  of  the  EU  agricultural  promotion 
policy  in  internal  and  third  countries  markets  {SWD  (2020)  401  final}.  European  Commission,  DG  AGRI, 
Evaluation support study of the EU agricultural promotion policy, internal and third country markets: final report, 
2020. Freshfel Europe: response to the public consultation on the EU promotion policy review, 2021. 
274  The objectives of  this  policy  are:  help  to  explain,  implement  and  develop  the  CAP, raise public  awareness, 
through information campaigns, of the CAP’s content and objectives and reinstate consumer confidence following 
crises, inform farmers and other parties active in rural areas; promote the European model of agriculture and 
contribute to the corporate communication on EU political priorities. 
275  https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-policy/financing-cap/cap-
funds/grants-information_en . 
276 Commission Staff Working Document, Evaluation on the information policy on the CAP {SWD/2021/0980 final} 
European Commission, DG AGRI, Evaluation study on the information policy on the CAP: final report, 2021. 

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4.4.1.3  Conclusions 

The EU school scheme is coherent with a number of CAP measures as it shares with them 
the objectives of market stability, fair income for farmers, meeting consumers expectations 
and agricultural competitiveness and promoting healthy eating habits. 

However, according to stakeholders (survey to public authorities involved in the planning 
and  implementation  of  the  scheme,  in-depth  interviews  with  public  authorities  and 
economic operators in the case study regions) the scheme does not seem to be so much 
linked to other agricultural measures but rather to the area of healthy nutrition. 

The scheme is implemented within the CMO concurring to the CAP objective regarding the 
stabilisation of the market.  Within this regulatory framework, by acting on the demand 
side, the school scheme is coherent with market measures and other instruments of the 
CMO acting on the internal market on the supply of F&V, milk and milk products.  

The school scheme addresses two crucial objectives of the CAP: farm income support and 
development of organic production to meet the increasing societal demand for quality food 
produced  with  high  environmental  standards  and  is  coherent  with  the  CAP  specific 
measures  covering  these  areas.  Links  are  however  limited,  given  the  overall  volumes 
assured by distribution through the scheme and a less interest in addressing the topic of 
organic production compared to other topics within the educational measures. 

Concerning the objective of enhancing the competitiveness of the agricultural sector, 
the school scheme is coherent with the rural development measures aiming at developing 
short supply chains and local markets. In order to avoid overlap and to be fully consistent 
with the action of rural development policy, it might be useful to adopt in the framework 
of the school scheme legislation the same definitions currently given by Regulation (EU) 
No 807/2014 concerning the two concepts.  Aiming at enhancing the competitiveness of 
the sector, the school scheme supports (also) the direct consumption of products covered 
by  EU  quality  schemes,  i.e.,  products  with  geographical  indication  (PDO/PGI)  and 
traditional products (TSG). The concept of quality conveyed by GIs/TSGs is not linked with 
the nutritional properties of the distributed products: therefore, there is no link between 
quality schemes and healthy diets (neutrality).  

Within the CAP and concerning the promotion of healthy diets, the EU school scheme is 
coherent with the topics and messages of the actions of promotion and information on EU 
agri-food products and on the CAP, co-funded or implemented directly by the Commission. 
The  analysis  of  legislation,  official  reports  and  studies  highlighted  the  complementary 
nature of these interventions, in particular for the promotion of healthy eating habits and 
of the consumption of F&V in the context of healthy diets.  

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4.4.2  ESQ 9 - To what extent has the EU school scheme been coherent with other 

relevant EU policies, notably health, education and environment? 

4.4.2.1  Background and methodological approach  

Understanding 

The evaluation question asks to assess the external coherence of the EU school scheme 
objectives  with  other  EU  policies,  other  than  the  CAP,  notably  health,  education  and 
environment. For references and definitions please see ESQ8. 

Judgement criteria, indicators and sources  

In order to reply to the evaluation question, our judgement is based on the following criteria 
and indicators.  

Judgement criteria 

Indicators 

Sources 

JC 9.1: 
school 
the  EU 
scheme is coherent with the 
objectives  of  the  EU  Health 
and Food Safety policy  

on 

Judgement 

9.1.1 
coherence 
(coherent/neutral/not coherent) of the EU school 
scheme  objectives  with  the  objectives  of  the 
Strategic  Plan  2016-2020  for  Health  and  Food 
Safety and related EU policies/initiatives 

the 

school 
the  EU 
JC 9.2: 
scheme is coherent with the 
objectives 
EU 
of 
Education and Culture policy  

the 

9.2.1  Judgement  on  the  coherence  of  the  EU 
school  scheme  objectives  (coherent/neutral/not 
coherent) with specific objectives of the Strategic 
Plan  2016-2020  for  Education  and  Culture  and 
related the Strategic Plan 2016-2020 and related 
EU policies/initiatives 

JC 9.3: 
school 
the  EU 
scheme is coherent with the 
EU 
of 
objectives 
Environment policy  

the 

9.3.1  Judgement  on  the  coherence  of  the  EU 
school  scheme  objectives  (coherent/neutral/not 
coherent) with specific objectives of the Strategic 
Plan 2016-2020 for the Environment and related 
EU policies/initiatives   

Methodological approach and its limitations 

Tools, method and sources used 

-  Intervention  logic  and  EU 
school  scheme  strategies 
2017-2023 

-  Legal  framework  of  EU 
policies  related  to  health, 
education 
and 
environment 

-  Public Authorities Survey 
-  Structured  interviews  in 

CS MS/regions 

-  Results of ESQ2, ESQ8 

The analysis of external coherence has been carried on the basis of a two-step approach:  

 

 

the  first  has  been  carried  out  analysing  the  coherence  of  the  EU  school  scheme 
objectives  illustrated  in  the  intervention  logic  (see  2.2.2:  increase  consumption  of 
selected  F&V  and  milk  products,  promote  healthy  eating  habits  and  shape  healthier 
diets  and  the  objectives  of  viable  food  production  to  which  the  scheme  should 
contribute: maintain market stability, enhance farm income, improve competitiveness 
of  farm  sector,  meet  consumer  expectations  for  products  that  are  of  high  quality, 
healthy, climate and environmental-friendly) with general and specific objectives of the 
Strategic  Plans  2016-2020  for  Health  and  Food  Safety,  Education  and  Culture, 
Environment277; 
the second has taken into account the coherence of the EU school scheme objectives 
illustrated  in  the  intervention  logic  and  of  the  objectives  stated  in  the  national  and 
regional  strategies  (as  they  fit  into  the  objectives  of  the  intervention  logic)  in  their 
relation  to  the  most  relevant  (for  the  purposes  of  the  present  evaluation)  policy 

277https://ec.europa.eu/info/sites/default/files/strategic-plan-2016-2020-dg-sante_en_0.pdf; 
https://ec.europa.eu/info/publications/strategic-plan-2016-2020-education-and-culture_en; 
https://ec.europa.eu/info/publications/strategic-plan-2016-2020-environment_en . 

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orientations stated in the EU Health, Education and Environment regulatory and policy 
framework, namely documents, actions and instruments. 

Table 13 : Main EU references for Health, Education and Environment policies 

EU policy 

Reference 

EU Health policy 

EU Education policy278 

Strategic Plan 2016-2020 
EU Action Plan on Childhood Obesity 2014-2020  
Regulation (EC) No 1924/2006 of the European parliament and of the council of 20 
December 2006 on nutrition and health claims made on foods  
EU White Paper, Together for health - A strategic approach for the EU 2008 – 2013 
Commission staff working document accompanying the white paper 
EU  white  paper  on  A  Strategy  for  Europe  on  Nutrition,  Overweight  and  Obesity 
related health issues 2007 
EU  Green  Paper  "Promoting  healthy  diets  and  physical  activity:  a  European 
dimension for the prevention of overweight, obesity and chronic diseases" 2005 
EU Framework for national initiatives on selected nutrients 
Technical Report on Public Procurement of food for health 
Europe’s Beating Cancer Plan  

Strategic Plan 2016-2020 
Council Recommendation on Pathways to School Success  
Commission Staff Working Document accompanying the Document Communication 
on  School  Development  And  Excellent  Teaching  For  A  Great  Start  In  Life 
{Com(2017) 248 Final}  
Communication From the Commission to the EP, the European Council, the Council, 
the EESC and the Committee of the Regions Building A Stronger Europe: The Role 
of Youth, Education And Culture Policies Com/2018/268 Final  
Council Recommendation on blended learning for high quality and inclusive primary 
and secondary education  
Proposal for a Council Recommendation on learning for environmental sustainability. 

EU Environment policy  Strategic Plan 2016-2020 

Directive (EU) 2019/904 on the reduction of the impact of certain plastic products 
on the environment 
Decision  1386/2013/EU  of  the  European  Parliament  and  of  the  Council  of  20 
November 2013 on a General Union Environment Action Programme to 2020 ‘Living 
well, within the limits of our planet’ 
Biodiversity Strategy 
Circular Economy action plan 
EU Food Losses and Food Waste 
Climate and Energy Package 
Climate Adaptation Strategy 
Resource Efficiency Roadmap 

The analysis of external coherence focuses on the current frame of the EU policy (i.e. the 
frame in place at the time of the launch of the EU school scheme - 2017), but also makes 
reference  to  the  Farm  to  Fork  strategy  within  the  European  Green  Deal 279,  and  to  the 
Europe’s Beating Cancer Plan280. The Directive  on the  reduction of the impact of certain 
plastic  products  on  the  environment281  promulgated  in  2019  (MS  are  required  to  take 
measures from July 2021) has also been taken into account in the analysis. 

The following tools have been used: 

  desk research: analysis of the relevant Strategic Plans 2016-2020, analysis of the main 

EU legislation, official acts and policy documents on the three EU policies; 

  analysis of Public Authority survey data; 

  analysis  of  information  gathered  through  structured  interviews  in  case  study 

MS/regions; 

 

indicators and results relating to other ESQs. 

278 Article 165 of the TFEU. 
279 https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal_en . 
280 https://ec.europa.eu/health/system/files/2022-02/eu_cancer-plan_en_0.pdf . 
281 https://eur-lex.europa.eu/eli/dir/2019/904/oj . 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

Limitations of methods and sources 

As regards the structured interviews in CS MS/regions, a major limitation is related to the 
limited  number  of  Authorities  (i.e.,  public  bodies  in  charge  of  implementing  Health, 
Environment  and  Education  policies),  involved  at  least  in  the  planning  of  the  school 
scheme,  even  if  not  participating  in  its  implementation,  and  available  to  answer.  Most 
interviews only provided partial elements and generally insufficient explanations to be used 
meaningfully for coherence analysis. 

4.4.2.2  Analysis  

Judgement criterion 9.1: The EU school scheme is coherent with the objectives of 
the EU policy on Health  

DG  Health  and  Food  Safety’s  strategy  for  2016-2020  addresses  three  priorities  of  the 
Commission:  a new boost for jobs, growth and investment in the EU, a deeper and fairer 
internal  market  with  a  strengthened  industrial  base,  a  balanced  trade  policy  to  harness 
globalisation. These priorities are in turn broken down into specific objectives.   

Given the economic importance and potential of the health and food sectors, the policy’s 
primary  objective  is  to  contribute  to  jobs,  growth  and  investment  by  supporting  health 
system reforms to make them more efficient, resilient and accessible, and by creating the 
right environment for growth and investment in the food and feed sector.   

Concerning  this  important  policy  area,  the  EU  school  scheme,  aiming  at  promoting 
healthy  eating  habits  and  increasing  the  consumption  of  fresh  fruit  and 
vegetables and of milk, is coherent with the specific objectives of EU policy on Health of 
ensuring  more  cost-effective  and  sustainable  healthcare  systems  and  safe  and 
sustainable  food  and  food  production  systems.  Also,  the  two  policies  share  the 
objective  of  helping  the  agricultural  sector  to  remain  competitive282,  contributing  to 
innovation in the food sector and ensuring a sustainable food production.  

Moreover, there is a coherence between the school scheme, concurring also at meeting 
consumers expectations concerning health, the environment and the climate, and two 
other  specific  objectives  foreseen  by  the  Health  strategic  plan,  aimed  at  strengthening 
consumer information on food and reducing food waste. 

The EU school scheme is rather neutral towards the remaining objectives of the DG Health 
and Food Safety’s strategy for 2016-2020.  

The analysis of the legislation and of policy orientations stated in the EU Health documents 
confirms  the  interaction  between  the  school  scheme  and  EU  health  policy.  Case  study 
interviews  provided  some  additional  information  on  the  relation  between  the  EU  school 
scheme and EU policies/objectives/actions related to health. 

First of all, it should be noted that promoting healthy and sustainable diets is one of the 
key issues of the Farm to Fork Strategy283. At present, the Commission is working on a 
new  legislative  proposal  for  a  framework  for  a  sustainable  food  system  (expected  for 
2023284)  that  should  lead  to  a  review  of  the  EU  school  scheme  strengthening,  among 
others, educational messages on the importance of healthy nutrition.  

282 Heath Strategic Plan 2016-2020: Given that high standards of safety and quality are integral to the EU “brand,” 
it is essential that safety and competitiveness are delivered together and not in opposition to one another…. all 
these approvals contribute to innovation and are needed to help the food industry and agricultural sector remain 
competitive. 
283 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52020DC0381 . 
284https://ec.europa.eu/food/horizontal-topics/farm-fork-strategy/legislative-
framework_en#:~:text=The%20proposal%20for%20a%20legislative,to%20sustainable%20food%20systems%
20easier.  

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

Moreover,  it  must  be  underlined  that  EU  has  launched  in  November  2020,  for  the 
forthcoming years, the Beating Cancer Plan structured around four key action areas and 
aiming  at  tackling  the  entire  disease  pathway:  to  this  end  relevant  for  the  EU  school 
scheme will be the actions related to cancer prevention, and in particular those aiming at 
improving health promotion through access to healthy diets and physical activity (3.4) and 
reducing environmental pollution (3.5).  

However, the analysis here focuses on the frame of the EU policy on health in place at the 
time  of  the  development  of  the  EU  school  scheme  (2017).  The  table  below  shows  the 
coherence of the EU school scheme objectives, including those specified at national level 
by MS, with relevant EU Health policy documents. Please note that the objectives reported 
in the second column refer to the  exact wording of  the national and regional strategies 
2017-2023, section 2.2 Objectives and indicators, notified to the European Commission.  

Table 14 : Table of coherence EU school scheme-Health policy documents 

school 

EU 
scheme 
objectives  as  set 
up  by  the  EU 
regulations 
(intervention 
logic) 

Increase 
consumption of 
selected 
agricultural 
products (F&V 
and milk 
products) 

Promote healthy 
eating habits  

Contribute to 
farmer income 

Maintain market 
stability 

EU school scheme objectives as 
detailed  in  the  national  and 
regional strategies 

Greater demand and consumption 
of fruit, vegetables, milk and milk 
products among children and 
teenagers, in terms of quantity and 
variety. Slow down declining trend 
of milk consumption.  Boost 
demand for fruit, vegetables, milk 
and milk products in the future. 
Greater consumption of F&V by 
schoolchildren attending 
disadvantaged schools 
Help children and teenagers have a 
healthy diet and balanced eating 
habits.  Increase knowledge of 
schoolchildren on health, nutrition 
and balanced diet 
Greater popularity, positive 
attitude and acceptance towards 
F&V, milk. Developing a taste for 
F&V and a taste for unprocessed or 
minimally processed products and 
for unsweetened and non-flavored 
milk and milk products.  
Raise awareness among parents as 
a major influencer of children’s 
habits. 
Ensuring that a fair price is paid to 
farmers. Diversify farm income 
sources. 
Greater demand and consumption 
of fruit, vegetables, milk and milk 
products among children and 
teenagers, in terms of quantity and 
variety. Slow down declining trend 
of milk consumption.  Boost 
demand for fruit, vegetables, milk 
and milk products in the future. 

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136 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

school 

EU 
scheme 
objectives  as  set 
up  by  the  EU 
regulations 
(intervention 
logic) 

EU school scheme objectives as 
detailed  in  the  national  and 
regional strategies 

Increase knowledge of 
schoolchildren on agriculture 
production: variety of agriculture 
products, F&V species and varieties 
growth, seasonality, food chain 
Greater awareness of 
schoolchildren on the importance 
of food quality and knowledge of 
quality systems.  Increase 
knowledge of schoolchildren about 
the origin of agriculture products 
and the local food chains, including 
typical products 
Further improve existing 
partnerships to better integrate 
local food chains in their regions 
Promote the organic product 
Increase knowledge of 
schoolchildren about food and 
environment, including the combat 
against food waste 
Making a contribution to a healthy 
school life 

Improve 
competitiveness 

Meet consumer 
expectations 

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Legend: C=Coherent; N=Neutral; NC= Non-Coherent 
Source: own assessment on Health policy documents, EU school scheme intervention logic, national and 
regional school scheme strategies 2017-2023 

High degree of interaction is found between the scheme objectives and the EU Action Plan 
on  Childhood  Obesity  2014-2020  and  the  EU  Framework  for  National  Initiatives  on 
Selected  Nutrients.  Also  relevant  are  the  less  recent  EU  White  Paper  on  A  Strategy  for 
Europe on Nutrition, Overweight and Obesity,  2007 and the EU  Green Paper Promoting 
healthy  diets  and  physical  activity:  a  EU  dimension  for  the  prevention  of  overweight, 
obesity and chronic diseases, 2005. 

The  Action  Plan  on  Childhood  Obesity  2014-2020  (released  in  2014)  recognizes  8  key 
areas  for  action  in  counteracting  childhood  obesity.  Among  them,  the  following  are 
particularly relevant to the EU school scheme: 

  promote  healthier  environments,  especially  in  schools  and  pre-schools.  The  school 
scheme is expressly mentioned as a policy measure helping to provide healthy option 
and  increase  daily  consumption  of  fresh  fruit  and  vegetables  and  healthy  food  in 
schools, provide access to healthy meals and snacks and limit other supplementary less 
healthy  food  options,  improve  the  education  on  healthier  food  choices  and  physical 
activity at schools and making the school environment attractive to eat in. Furthermore, 
the importance of accompanying the school scheme with education on healthy eating 
habits and combating food waste is pointed out; 

137 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

  make the healthy option the easier option, again with explicit reference to the school 

 

scheme285;  
inform and empower families: promote healthy family meals (around a schedule and 
table) and pay closer attention to children and young people's diet; 

  establish harmonised monitoring of school nutrition. 

The EU framework for National Salt Initiatives and National Initiatives on Selected nutrients 
were adopted in 2008 and 2011 by the High-Level Group286, with two annexes on saturated 
fat and added sugars developed in 2012 and 2015287, where the Commission coordinated 
the development of concrete benchmarks and identified areas for action for reformulation 
of food in terms of target variables that may vary nationally (salt reduction, saturated fat, 
trans  fat,  energy,  total  fat  content,  added  sugars).  The  school  scheme  objectives  are 
coherent  with  the  strategy  outlined  in  the  document,  which  states  that  raising  public 
awareness of an overall healthy eating pattern and behaviour on consumption frequency 
of  certain  food  categories  is  central  to  reduce  population  intake  levels  of  those  food 
component  towards  recommended  levels.  Furthermore,  also  raising  awareness  about 
healthier  options  within  product  categories  that  are  present  on  the  market  already  and 
promoting their consumption is claimed to be crucial288.  

The Green Paper "Promoting healthy diets and physical activity ...," (COM(2005) 637 final) 
raises the concern that unhealthy diets and lack of physical activity are the leading causes 
of  avoidable  illness  and  premature  death  in  Europe,  becoming  a  major  public  health 
priority. The strategy for promoting healthy lifestyles within the EU include: to not mislead 
consumers, and in particular children, by advertising for foods high in fat, salt and sugars, 
such as energy-dense snacks and sugar-sweetened soft drinks, and the marketing of such 
products in schools; to promote home and school environments supporting healthy food 
choices for children, by also improving the nutritional value of school meals. All the above-
mentioned objectives are relevant to the two main objectives of the EU school scheme, 
and neutral for the other objectives. Finally, the White Paper on A Strategy for Europe on 
Nutrition,  Overweight  and  Obesity  sets  out  an  integrated  EU  approach  to  contribute  in 
reducing  ill  health  due  to  poor  nutrition,  overweight  and  obesity.  The  strategy  requires 
action  from  a  wide  range  of  actors,  including schools.  Specifically,  the  paper  recalls  for 
approach to better informing consumers on how to make healthy options, including low 
socio-economic  groups;  improve  the  access  to  healthy  foods  provide  healthy  options in 
schools  (which  are  priority  settings);  ensure  a  good  or  greater  affordability  of  F&V  to 
encourage  their  consumption  especially  among  young  people;  promote  children's 
consumption  of  fruit  and  vegetables  and  allow  surplus  production  to  be  distributed  to 
educational institutions.  

The interaction between school scheme and EU policy on health is confirmed by the results 
of the PA survey. By asking “to what extent EU policies/objectives/actions related to health 
have been taken into account when drafting the EU school scheme in your country/region”, 
all respondents reported to have taken into account EU health policy in the design of their 
EU  school  scheme  strategy.  In  particular,  39%  affirm  that  those  policies  have  been 

285 Make healthy options more affordable and attractive by subsidising products such as fruit and vegetables (e.g., 
EU School Fruit Scheme); promote substitute for sugar-sweetened beverages such as consumption of milk in the 
EU School Milk Scheme; develop or improve schemes that limit marketing of energy-dense foods to children (also 
beyond the school environment). 
286 The high-level group on nutrition and physical activity is a group of EU government representatives dealing 
with this issue, led by the EU Commission. 
287 https://ec.europa.eu/health/system/files/2016-11/added_sugars_en_0.pdf . 
288 However, it should be noted that the analysis of the nutritional composition of the products and subproducts 
distributed with the scheme (e.g. fruit juices) according to the provisions of Regulation (EU) N 1308/2013 (as 
amended) was not required was not required in this evaluation. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

considered to a great extent (i.e., Belgium Flanders, Bulgaria, Greece, Luxembourg, Malta, 
Austria, Poland, Romania, Slovenia, Slovakia, Sweden and 2 German Laender). 

CS interviews further deepen the issue. In Portugal the Health Authority clarified that the 
EU  school  scheme  is  one  of  the  only  ‘initiatives’  that  combines  health,  education  and 
agricultural policies and, thus, it is crucial to strengthen and deepen  this link in order to 
follow  a  greater  contribution  for  the  achievement  of  the  priorities  identified  by  the 
Commission  (2014-2020  and  2020-2024).  In  particular,  if  properly  implemented  and 
reaching out a high number of school children, the EU school scheme is considered to have 
a strong potential to address the major challenge of reduction of poor nutrition, overweight 
and obesity, consequently improving current and future children’s health status. In Poland, 
the Health Authority stressed that the issue of tackling overweight and obesity, due to its 
scale, must be addressed holistically, ensuring coherence between policies. 

However, sometimes it was considered that achieving coherence between the EU school 
scheme  and  national  priorities  was  more  challenging,  as  national  objectives  are  more 
ambitious than EU priorities in terms of health.  In France,  for  instance, the objective of 
increasing fibre consumption, notably through the consumption of pulses, was highlighted. 
In Sweden, the government decided in 2013 that public health issues were best addressed 
through national policies289 , therefore the EU school scheme strategy was drafted within 
the framework of the CAP, though aiming at the best possible outcome in terms of public 
health aspect and simplification of rules. 

As regards actions already in place in order to strengthen coherence with EU health policy, 
in France a Steering Committee of the EU school scheme including the representatives of 
the  ministry  of  health  is  in  place,  Poland  ensures  consistency  with  national  and  EU 
strategies  through  inter-ministerial  cooperation  in  the  development  of  the  scheme 
implementation concept and in Spain meetings and working groups have enabled to involve 
relevant  stakeholders  in  the  health  sector.  In  Lithuania,  the  same  criteria  for  the 
composition  of  dairy  products  were  set  both  within  school  scheme  distribution  and  for 
children school meals.   

Judgement  criterion  9.2:  The  EU  school  scheme  is  coherent  with  the 
objectives of the EU policy on Education 

In a first step, an analysis was carried out for gauging the coherence of the objectives of 
the  EU  school  programme  with  the  Strategic  Plan  of  DG  Education  and  Culture,  which 
defines  the  policy  objectives  for  the  period  2016-2020.  All  policy  areas  in  the  sphere  of 
activity of DG Education and Culture contribute to the two objectives related to Jobs and 
Growth: competitiveness and social inclusiveness, through education, innovation, youth, 
culture and sport. 

The analysis did not reveal many shared issues between the Education Strategic Plan and 
the  EU  school  scheme.  The  EU  school  scheme,  in  particular  its  objectives  related  to 
promoting healthy eating habits and meeting consumer expectations, is in some way linked 
with two specific objectives of the EU Education Strategic Plan related to competitiveness, 
i.e., to improve the level of key competences and skills and to foster quality improvements, 
innovation excellence and internationalisation. 

Deepening  the  analysis  on  policy  documents,  the  EU  school  scheme  appears  to  have  a 
relationship  with  the  indications  stated  in  the  Commission  Staff  Working  Document 

289 Government Office Memorandum of facts 2013/14:FPM61 – EU school fruit, vegetables and milk scheme. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

accompanying  the  Document  Communication  on  School  Development  And  Excellent 
Teaching For A Great Start In Life {Com(2017) 248 Final}290. 

The staff working document takes a systemic view on school education policies, addressing 
the need for inclusive education as a guiding principle for the future development of school 
education policies.  The  document underlines the importance to support young people  in 
developing key competences for personal fulfilment and development, active citizenship, 
social inclusion and employment. The competences young people need are not necessarily 
equivalent  to  the  subjects  taught  in  school,  therefore,  schools  must  enhance  cross-
disciplinary teaching and learning, project- and problem-based learning, team teaching or 
involving  external  stakeholders.  Curricula  that  connect  with  real  life  have  proven  to  be 
more  engaging:  project-  and  problem-based  learning,  on-the-job  experiences  or 
community-service learning increase the motivation of learners, put subject content into 
context and offer opportunities for the development of social, civic and entrepreneurship 
competences.  Moreover,  extracurricular  and  out-of-school  educational  opportunities, 
including wider community projects, can provide opportunities for learners to show their 
talents and increase their motivation and sense of belonging at school. 

The  overall  approach  recommended  in  these  documents  is  in  line  with  the  underlying 
principles of the EU school scheme of actively promoting new knowledge in participating 
schools and applying innovative teaching methods to children through the accompanying 
educational measures (AEMs).  Regarding this, the school scheme objectives specified in 
the  national  strategies  (e.g.,  increase  knowledge  of  schoolchildren  about  food  and 
environment,  including  the  combat  against  food  waste,  increase  knowledge  of 
schoolchildren on agriculture production and greater awareness  of schoolchildren on the 
importance of food quality) are coherent with the EU educational policy. Also, the analysis 
of AEM themes (ESQ 2) to confirms what here observed: in fact, the theme “reconnecting 
children  to  agriculture”  was  addressed  by  97%  of  the  MS  implementing  AEMs  (average 
2017/18-2020/21) and "healthy eating habits" by over 95%291. 

Results  of  the  PA  survey292  appear  to  validate  such  an  interpretation,  showing  that  the 
large majority of respondents report to have taken into account the EU policy related to 
education  (82%).  However,  some  MS  (Austria,  Denmark,  France,  Lithuania,  Latvia  and 
Hungary)  reported  to  have  taken  into  account  EU  education  policy  only  to  a  very  little 
extent or not at all, when designing their national school scheme strategies. 

Additionally, case study interviews have provided some further details regarding how EU 
education policies/objectives/actions and the EU school scheme complement each other. 
In particular: 

 

in  Poland  activities  carried  out  within  the  scheme  support  the  regular  educational 
activities performed at schools293; 

290  Even  if  to  a  lesser  extent,  the  scheme  interacts  also  with  the  objectives  and  actions  set  out  in  the 
Communication from the Commission to the EP, the European Council, the Council, the EESC and the Committee 
of  the  Regions  Building  A  Stronger  Europe:  The  Role  of  Youth,  Education  And  Culture  Policies 
(Com/2018/268 Final), the Council Recommendation on blended learning for high quality and inclusive primary 
and  secondary  education  and  the  Proposal  for  a  Council  Recommendation  on  learning  for  environmental 
sustainability. 
291  It should be remembered, however, that the analysis of the coverage rate of AEMs (ESQ2) highlighted that 
the  share  of  children  involved  in  each  type  of  measure  is  only  a  small  part  of  the  total  number  of  children 
participating in the EU school scheme. 
292 “To what extent EU policies/objectives/actions related to education have been taken into account when drafting 
the EU school scheme in your country/region?”. 
293 The provision of more prophylactic related contents supplements and strengthens the educational activities, 
in particular the ones directed to the youngest part of the target group. 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

 

 

in  Italy  the  school  scheme  strategy  contributes,  within  the  European  education  and 
training  policies,  to  the  pursuit  of  the  common  goal  of  improving  the  quality  and 
effectiveness of education;  
finally, in Czech Republic the goals of education are complemented by the EU school 
scheme  through  compulsory  education  within  the  field  of  Health  Education,  which 
guides  pupils  to  learn  the  principles  of  a  healthy  lifestyle  and  to  apply  them  in  their 
lives.  

Furthermore, as regards the practical actions to reinforce coherence between the EU school 
scheme and EU educational policy some suggestions were given by interviewees: 

  mutual exchange of information on the implementation of AEMs between the  central 
level  (Ministry  of  Education)  and  the  organisational  level  in  the  schools  (Poland, 
Lithuania, Spain294); 
combining formal and non-formal education (Lithuania). 

 

DG Environment’s strategy for 2016-2020 contributes primarily to the achievement of the 
general  objective  of  boosting  jobs,  growth  and  investment  through  six  specific 
objectives295. Particularly important for DG Environment is the objective of greening the 
economy,  which  entails  getting  more  added  value  from  materials  and  other  natural 
resources,  reducing  waste  and  environmental  harm  through  more  efficient  use  of 
resources, thus contributing to growth, competitiveness and job creation.  

No links were found between the two main objectives of the EU school scheme, increase 
consumption  of  selected  F&V  and  milk  products  and  promote  healthy  eating  habits  and 
shape healthier diets, and the DG Environment’s Strategic Plan for 2016-2020. However, 
the analysis shows that the school scheme objectives related to consumer expectations 
for products that are of high quality, healthy, climate and environmental-friendly and to 
ensuring  a  viable  food  production  are  coherent  with  the  objective  “EU  economy  is 
resource-efficient, green and competitive” and to a lesser extent with “Enabling framework 
for  environmental  policy,  based  on  smart  implementation,  a  strong  knowledge  and 
evidence  base,  investment,  and  improved  environmental  integration  and  policy 
coherence”.  

As regards the EU environmental policy it is important to recall that within the European 
Green  Deal,  the  Farm  to  Fork  strategy296  aims,  among  other  environmental  issues,  at 
promoting more sustainable food systems and sustainable food consumption. In particular, 
in the Strategy (2.4.Promoting sustainable food consumption and facilitating the shift to 
healthy,  sustainable  diets)  it  is  specified  that  the  Commission  will  make  a  legislative 
proposal  for  a  framework  for  a  sustainable  food  system  before  the  end  of  2023, 
accompanied by a review of EU school scheme to enhance its contribution to sustainable 
food consumption and in particular to strengthen educational messages on the importance 
of healthy nutrition, sustainable food production and reducing food waste. 

294  There  are  many  exchanges with  other regional  ministries  to  share experiences  and  at the  EU  level,  and  in 
Andalusia, there are many educational centres, with various programs. A regional network is organised with a 
referent centre, coordinated by a referent teacher. The referent centre, the IES Guadalquivir won the EU Health 
Awards in 2019, for its project ‘Be active’ dedicated to improving eating habits. 
295  The  EU  economy  is  resource-efficient,  green  and  competitive;  The  Union’s  natural  capital  is  protected, 
conserved and enhanced;  The Union's citizens are safeguarded from environment-related pressures and risks to 
health and well-being; There is an enabling framework for environmental policy, based on smart implementation, 
a  strong  knowledge  and  evidence  base,  investment,  and  improved  environmental  integration  and  policy 
coherence:  The  Union's  cities  are  more  sustainable;  The  Union  is  more  effective  in  addressing  international 
environmental challenges. 
296 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social  Committee  and  the  Committee  of  the  Regions:  “A  Farm  to  Fork  Strategy  for  a  fair,  healthy  and 
environmentally-friendly food system” (COM/2020/381 final). 

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Table 15 : Table of coherence EU school scheme-EU Environment policy documents 

EU school scheme 
objectives as set up 
by the EU regulations 
(intervention logic) 

EU school scheme objectives as 
detailed in the national and 
regional strategies 

Increase 
consumption of 
selected agricultural 
products  (F&V and 
milk products) 

Promote healthy 
eating habits 

Contribute to farmer 
income 

Maintain market 
stability 

Improve 
competitiveness 

Meet consumer 
expectations 

Greater demand and consumption 
of fruit, vegetables, milk and milk 
products among children and 
teenagers, in terms of quantity and 
variety. Slow down declining trend 
of milk consumption.  Boost 
demand for fruit, vegetables, milk 
and milk products in the future. 
Greater consumption of F&V by 
schoolchildren attending 
disadvantaged schools 
Help children and teenagers have a 
healthy diet and balanced eating 
habits.  Increase knowledge of 
schoolchildren on health, nutrition 
and balanced diet 
Greater popularity, positive 
attitude and acceptance towards 
F&V, milk. Developing a taste for 
F&V and a taste for unprocessed or 
minimally processed products and 
for unsweetened and non-flavored 
milk and milk products.  
Raise awareness among parents as 
a major influencer of children’s 
habits. 
Ensuring that a fair price is paid to 
farmers. Diversify farm income 
sources. 
Greater demand and consumption 
of fruit, vegetables, milk and milk 
products among children and 
teenagers, in terms of quantity and 
variety. Slow down declining trend 
of milk consumption.  Boost 
demand for fruit, vegetables, milk 
and milk products in the future. 
Increase knowledge of 
schoolchildren on agriculture 
production: variety of agriculture 
products, F&V species and varieties 
growth, seasonality, food chain 
Greater awareness of 
schoolchildren on the importance 
of food quality and knowledge of 
quality systems.  Increase 
knowledge of schoolchildren about 
the origin of agriculture products 
and the local food chains, including 
typical products 
Further improve existing 
partnerships to better integrate 
local food chains in their regions 
Increase knowledge of 
schoolchildren about food and 
environment, including the combat 
against food waste 
Promote the organic product 

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142 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation support study of the EU school fruit, vegetables and milk scheme 

Making a contribution to a healthy 
school life 

N 

N 

N 

N 

N 

N 

N 

Legend: C=Coherent; N=Neutral; NC= Non-Coherent 
Source: own assessment on Environment policy documents, EU school scheme intervention logic, national and 
regional school scheme strategies 2017-2023 

Additionally, in 2019, the EU has promulgated the Directive on the reduction of the impact 
of  certain  plastic  products  on  the  environment  which  promotes  circular  approaches  that 
give  priority  to  sustainable  and  non-toxic  re-usable  products  and  re-use  systems  rather 
than  to  single-use  products,  aiming  first  and  foremost  to  reduce  the  quantity  of  waste 
generated.  Such  an  aspect,  although  to  be  further  developed  in  the  future,  has  been 
highlighted in two MS: 

 

 

in  Italy  the  yearly  monitoring  report  for  2019/2020  highlights  that  school  managers 
stress the fact that the excess of packaging is difficult to dispose of and at the same 
time contradicts the commitment to increase attention to the environment; 
in  Sweden  the  sector  representative  has  worked  for  many  years  to  reduce  the 
environmental impact and increase the renewability of milk packages, and to promote 
collection and recycling297. 

Thus, the analysis of coherence is developed onto this evolving framework and focus on 
ongoing EU actions on environment.  

Among these, particularly relevant to the school scheme is the EU Food Losses and Food 
Waste.  In  2016,  the  EU  Council  has  adopted  conclusions  (10730/16)298,  inviting  the 
European  Commission  to  develop  a  common  methodology  to  measure  food  waste,  to 
facilitate  food  donation,  to  support  education  and  awareness  among  the  population  on 
sustainable  food  production  processes,  consumption,  food  losses  and  waste.  Finally,  it 
should  be  noted  that  one  of  the  Farm  to  Fork  Strategy’s  targets  also  concerns  the 
strengthening of the fight against food waste.  

According to the Recommendations for Action in Food Waste Prevention (2019), developed 
by the EU Platform on Food Losses and Food Waste, schools can promote lifelong learning 
opportunities on how to prevent food loss and waste. The analysis (ESQ2) shows that the 
EU  school  scheme  reinforces  this  action:  among  the  themes  that  can  be  addressed  by 
accompanying measures, we can observe the importance given by MS to the issue of food 
waste. Indeed, in the four years of implementation of the scheme, on average almost 70% 
of  the  MS  and  regions  carrying  out  accompanying  educational  measures  address  food 
waste among the themes taught to pupils. 

Table 16 : MS implementing the different themes of the accompanying educational measures 
(average 2017-2021 in %) 

Reconnection of children to agriculture 

Healthy eating habits 

Food waste 

Local food chains 

Organic 

2017/2021 (avg %) 

97.1 

94.9 

68.8 

62.7 

56.6 

297https://www.tetrapak.com/content/dam/tetrapak/publicweb/gb/en/sustainability/documents/sustainability-
report2020.pdf . 
298 https://ec.europa.eu/food/system/files/2017-08/fw_lib_council_food-losses-food-waste_2016.pdf . 

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Sustainable production 

Other 

48.7 

24.9 

Source: EU School Scheme annual monitoring report data 

Conversely,  the  other  two  topics  related  to  the  environment:  organic  production  and 
sustainable production seem to be yet less appealing. The topic “organic” was addressed 
by around 57% of MS and “sustainable production” by slightly less than 50% of the MS. 
However,  sustainable  production  shows  in  the  highest  increase  in  the  last  year 
(2020/2021). 

Furthermore, regarding the coherence between the EU action on organic and the EU school 
scheme  (distribution  of  organic  products  under  the  scheme),  it  has  already  been 
highlighted (ESQ8) that the school scheme monitoring system does not allow to quantify 
the quantities of organic products distributed.  

Finally,  the  EU  school  scheme  appears  to  interact,  though  to  a  lesser  extent,  also  with 
other  EU  actions/initiatives  (Resource  Efficiency  Roadmap,  Climate  and  Energy  Package 
and  Climate  Adaptation  Strategy).  Although,  the  importance  of  these  policies  is  not 
neglectable, they appear neutral with the main objectives of the EU school scheme (i.e., 
increase F&V and milk consumption, promote healthy eating habits). 

It is worth mentioning that EU policies related to environment have been less taken into 
account when designing the national/regional strategies compared to health and education 
policies  (PA  survey:  100%  health,  82%  education,  68%  environment  -  to  a  great 
extent/somewhat).  Indeed,  the  results  of  the  analysis  of  information  gathered  through 
interviews (CS) showed a marginal role played by environmental issues in the definition of 
the  strategies  and  implementation  of  the  scheme.  Among  case  study  MS,  in  fact,  only 
Lithuania, Spain, Italy and France have mentioned some elements related to environmental 
issues (e.g., in Lithuania, the strategy has only defined that the products must be supplied 
within a maximum distance of 350 km, whereas in Spain, there are high synergies with 
environmental education: e.g., recycling, carbon footprint - for instance to reduce transport 
and  favour  local  products,  and  integrated  production).  Such  an  outcome  suggests  that 
coherence between EU school scheme and EU Environment policy should be reinforced, as 
the  strategies  (objectives)  seems  to  look  more  at  the  health-related  issues,  leaving  the 
environmental issues to be eventually addressed only at procurement/distribution level. 

4.4.2.3  Conclusions 

The ESQ9 asks to assess the external coherence of the EU school scheme with other EU 
policies, other than the CAP, notably health, education and environment. 

The analysis of coherence has been developed onto an evolving framework where a central 
role  is  played  by  the  EU  Green  Deal  and  the  Farm  to  Fork  strategy  which,  aiming  at  a 
sustainable food consumption, will bring to a review of the EU school scheme to strengthen 
educational messages on the importance of healthy nutrition, sustainable food production 
and reducing food waste. However, the analysis focuses on ongoing EU actions. 

Coherence with the EU policy on Health. The analysis of the EU Health Strategic Plan 2016-
2020  shows  that  the  EU  school  scheme,  with  its  main  objectives  of  promoting  healthy 
eating habits and increasing the consumption of fresh fruit and vegetables and of milk, is 
coherent  with  the  specific  objectives  of  ensuring  a more  cost-effective  and  sustainable 
healthcare systems and safe and sustainable food and food. Moreover, there is a coherence 
between 
consumers 
expectations concerning  their  health,  the  environment  and  the  climate,  and  two  other 
Health strategy’s  specific objectives, aimed at  developing consumer information on food 
and reducing food waste. 

at meeting 

concurring 

scheme, 

school 

also 

the 

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The analysis of the legislation and official acts suggests that the scheme objectives relating 
to developing healthy eating habits in children and promoting consumption of fresh fruit 
and vegetables, low-fat, unsweetened and unflavoured dairy product are coherent with the 
policy objectives of some significant actions of the EU concerning health: EU Action Plan 
on  Childhood  Obesity  2014-2020,  EU  Framework  for  National  Initiatives  on  Selected 
Nutrients  with  its  annexes299,  EU  White  Paper  on  A  Strategy  for  Europe  on  Nutrition, 
Overweight  and  Obesity,  EU  Green  Paper  Promoting  healthy  diets  and  physical  activity.  
Moreover,  the  analysis  shows  that  in  all  analysed  national/regional  strategies  of  the  EU 
school scheme (updated to 2021), health objectives are central. 

Coherence with the EU policy on Education. The analysis for gauging the coherence of the 
EU school scheme with the EU Education Strategic Plan did not reveal many shared issues. 
Nevertheless,  the  overall  approach  recommended  in  the  EU  Education  related  policy 
documents  is  in  line  with  the  underlying  principles  of  the  EU  school  scheme  of  actively 
promoting  new  knowledge  in  participating  schools  and  applying  innovative  teaching 
methods to children through the accompanying educational measures (i.e., AEMs). This is 
particularly  evident  with  regards  to  the  positive  effects  on  improving  youngest  citizens’ 
knowledge and awareness on the interconnection of all healthy habits leading elements, 
especially  applying  innovative  teaching  methods  to  children.  Mutual  exchange  of 
information between relevant actors appears to be the more suitable course of action for 
improving this coherence. 

Coherence with the EU policy on Environment. Finally, the analysis conducted on the EU 
Environment  Strategic  Plan  shows  that  no  links  were  found  between  the  two  main 
objectives  of  the  EU  school  scheme  (increase  consumption  of  selected  F&V  and  milk 
products  and  promote  healthy  eating  habits  and  shape  healthier  diets)  and  the  DG 
Environment’s Strategic Plan for 2016-2020.  However, the EU school scheme  objectives 
related  to  consumer  expectations  for  products  that  are  of  high  quality,  healthy,  climate 
and environmental-friendly and to ensuring a viable food production are coherent with the 
objective “EU economy is resource-efficient, green and competitive”. 

Besides the EU policy action on organic production (see ESQ 8), particularly relevant to the 
school scheme is the EU Food Losses and Food Waste. According to the Recommendations 
for Action in Food Waste Prevention (2019), developed by the EU Platform on Food Losses 
and  Food  Waste,  schools  can  promote  lifelong  learning  opportunities  on how  to prevent 
food loss and waste. Through AEMs, the EU school scheme reinforces the EU action and its 
objective and a great importance was given to the issue of food waste and recycling. 

299 However, it should be noted that the analysis of the nutritional composition of the products and subproducts 
distributed with the scheme (e.g., fruit juices) according to the provisions of Regulation (EU) No 1308/2013 (as 
amended) was not required in this evaluation. 

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4.4.3  ESQ  10  -  To  what  extent  has  the  EU  school  scheme  been  coherent  with 
other  national  policies  and  intervention  in  the  agricultural,  health  and 
education sector?  

4.4.3.1  Background and methodological approach  

Understanding 

The question asks to assess whether the EU school scheme is coherent with other national 
policies and interventions related to the agriculture, health and education sectors financed 
by national funds, and in particular, policies and interventions respectively related to: 

improving consumption of healthy food; 

 
  developing healthy eating habits; 
 
  VFP  objectives  (i.e.,  farmer  income,  maintaining  market  stability,  improving 

improving awareness around healthy consumption issues. 

competitiveness of the farm sector, meeting consumers’ expectations). 

Judgement criteria, indicators and sources 

In order to reply to the evaluation question, our judgement is based on the following criteria 
and indicators.  

Judgement criteria 

Indicators 

Sources 

JC10.1: The EU scheme is coherent (is 
not  coherent)  with  other  national 
policies  and  interventions  related  to 
viable food production objectives  

JC10.2:  There  is  (there  is  not)  a 
relationship  between  relevant  national 
policies  and 
the 
educational  sector  and  the  EU  school 
scheme strategy 

interventions 

in 

JC10.3:  There  is  (there  is  not)  a 
relationship  between  relevant  national 
policies and interventions in the health 
sector  and  the  EU  school  scheme 
strategy  

- 

with 

national 

strategy 

10.1.1  -  Coherence  of  the  EU  school 
relevant 
scheme 
policies 
agricultural 
/interventions in the MS 
10.1.2 
Informed 
stakeholders and operators 
10.2.1  -  Coherence  of  the  EU  school 
relevant 
scheme 
educational 
policies 
/interventions in the MS 
10.2.2 
Informed 
stakeholders and operators 

opinions 

opinions 

strategy 

national 

with 

of 

of 

- 

10.3.1  -  Coherence  of  the  EU  school 
scheme  strategy  with  relevant  health 
national policies/interventions in the MS 
10.3.2 
Informed 
stakeholders and operators 

opinions 

of 

- 

- 

- 

- 

Authorities 

Public 
Survey 
Desk research at case 
study level 
Structured  interviews 
in CS countries  

Methodological approach and its limitations 

Tools, method and sources used  

The analysis is carried out at EU-28 level (EU 27 + UK) and at Case Study (CS) level and 
it takes the intervention logic of the EU school scheme and in-depth analysis of the national 
and regional strategies as the starting point.  

The analysis is based on primary data and other information collected through: 

 

survey of Public Authorities at EU-27300 level. Respondents were asked to provide their 
opinion about the extent to which other policies/interventions related to agriculture / 
education / health were taken into account when drafting the school scheme, using a 
scale  “To  a  great  extent”,  “Somewhat”,  “Very  little”  and  “Not  at  all”). Responses  for 
each other national policy/intervention were assigned a score ranging from +3 (“To a 
great  extent”) to 0 (“Not at all”) and a synthetic indicator (average)  was calculated, 
based on these scores, across all respondents for each item; 

300 The UK did not answer the survey. 

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 

structured  interviews  in  case  study  MS/regions  and  desk  research  (i.e.,  information 
gathered again at CS level). 

Limitations of methods and sources 

Limitation related to CS highlighted for ESQ9 could be applied also in the case of ESQ10. 

4.4.3.2  Analysis  

Judgement  criterion  10.1:  The  school  scheme  is  coherent  (is  not  coherent) 
with  other  national  policies  and  interventions  related  to  viable  food 
production objectives 

The results of the PA survey show that only 7 MS indicated to implement national initiatives 
(funded  with  national  resources)  aiming  at  the  distribution  of  agricultural  products  in 
schools,  somehow  related  to  viable  food  production  objectives  (i.e.,  improve  market 
stability,  support  farmers’  income  and  meet  consumer  expectations).  In  general,  these 
initiatives are coherent with the general objectives of the EU school scheme, and to a lesser 
extent with the objectives of VFP. 

Table 17 : Member States implementing initiatives related to EU school scheme and 
viable food production objectives 

National initiatives 

EU school scheme 
objectives 

VFP objectives 

MS 

National 
intervention 

Main 
objective 

relevant 

BE-W 

EE 

FR 

LT 

LV 

Eat Tomorrow 
Strategy 
Organic catering 
label 
National Food 
Programme 
School Meals 
Programme 
Green Public 
Procurement 

LU 

Food4Future 

SI 

Traditional 
Slovenian breakfast 

Sustainable food 
system 
Support organic 
products‘ consumption 
Food security and 
sustainability  
Support organic 
products‘ consumption 
Distribution of local 
products 
Enhancing Regional 
production 
Raise awareness on 
eating habits 

n
o
i
t
p
m
u
s
n
o
c

e
s
a
e
r
c
n
I

d
e
t
c
e
e
s

l

f
o

s
t
c
u
d
o
r
p

l

a
r
u
t
l
u
c
i
r
g
a

N 

C 

C 

C 

C 

C 

N 

k

l
i

m
d
n
a

V
&
F
(

)
s
t
c
u
d
o
r
p

y
h
t
l
a
e
h

e
t
o
m
o
r
P

d
n
a

s
t
i
b
a
h

g
n
i
t
a
e

s
t
e
d

i

i

r
e
h
t
l
a
e
h

e
p
a
h
s

r
e
m
r
a
f

o
t

e
t
u
b
i
r
t
n
o
C

e
m
o
c
n

i

t
e
k
r
a
m
n
a
t
n
a
M

i

i

y
t
i
l
i

b
a
t
s

e
v
o
r
p
m

I

s
s
e
n
e
v
i
t
i
t
e
p
m
o
c

r
e
m
u
s
n
o
c

t
e
e
M

s
n
o
i
t
a
t
c
e
p
x
e

C 

N 

C 

N 

N 

N 

C 

N 

N 

N 

N 

C 

C 

N 

N 

N 

N 

N 

C 

C 

N 

C 

N 

C 

N 

C 

C 

N 

C 

C 

C 

C 

C 

C 

C 

Source: own elaboration on PA survey 

For a better understanding of the coherence between the above analysed initiatives and 
the EU school scheme and VFP’s objectives a synthetic review has been performed. 

In Belgium Wallonia the Government adopted in 2018 the Eat Tomorrow Strategy, which 
identified sustainable food in canteens as the main work topic for the period 2019-2021, 
to  encourage  canteens  in  a  transition  to  a  sustainable  food  system  through  the 
implementation of a Green Deal Canteens Durables. The Sustainable Canteens action plan, 
developed  in  2019  and  launched  in  2020,  has  made  it  possible  to  set  up  a  voluntary 
labelling system. 

Estonia and Lithuania support organic products’ consumption in schools: the former by a 
support initiative which issues a recognized certification to educational establishments that 

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reached  20%  of  organic  products  used;  the  latter  by  promoting  organic  food  produced 
under  the  national  agri-food  quality  scheme  in  pre-school  educational  institutions  by 
covering the price difference between quality products and conventional food.  

In France, the National Food Programme (PNA)301 wants to ensure that the population has 
access to safe, healthy, diversified food of good quality and sufficient quantity, produced 
under  conditions  that  are  economically  and  socially  acceptable  to  all,  that  promote 
employment,  that  protect  the  environment  and  landscapes,  and  that  contribute  to 
mitigating and adapting to the effects of climate change.  

In order to address these needs, collective catering has a major role, as it aims at: 

improving the quality of food; 

 
  updating nutritional recommendations in canteens; 
  enhancing  the  evolution  of  consumption  practices  for  a  sustainable  diet  (with  the 

generalization of the weekly vegetarian menu in the canteens); 
favouring the substitution of plastics; 

 
  enabling the fight against food waste.  

With the implementation of the option of a distribution of products under quality labels at 
lunchtime,  the  program  contributes  to  the  guidelines  of  up-quality/high-end  school 
catering, with sustainable and quality products. It also contributes to the accessibility of 
these products for as many people as possible. Finally, it contributes to the challenges of 
structuring the quality chain for a transition in both agriculture and food. 

In Latvia instead, “Green Public Procurement” (GPP)  conditions have been promoted for 
securing a certain share of local products in school meals.  

In Luxembourg the initiative aims to ensure that 50% of the products in collective catering 
subsidised  by  the  State  come  from  Luxembourg  agriculture.  A  preferential  short  circuit 
also, but also an increased fight to reduce waste and to abandon unsustainable products, 
introducing a new range of meals. 

In Slovenia, the project “Traditional Slovenian breakfast”302 aims to educate, inform and 
raise awareness of  schoolchildren and, to a  certain extent, the general public about the 
importance of breakfast in eating habits, the importance and benefits of locally produced 
food, the importance of agriculture and beekeeping for production, environment, economic 
activities and the proper management of waste generated in everyday activities. 

This limited result concerning the few number of national initiatives (funded with national 
resources)  aiming  at  the  distribution  of  agricultural  products  in  schools  seems  to  be 
confirmed by other results of the PA survey: in fact, only 10% of MS/regions reported to 
have taken into account “to a great extent” other national policies/interventions related to 
agriculture when planning the EU school scheme strategy. A further 40% of MS stated to 
have “somewhat” taken into account other agriculture initiatives. The remaining 50% of 
respondents declare that national initiatives have been only “little” or “not at all” taken into 
account  in  planning  the  strategy  (possibly  due  to  the  absence  of  national  initiatives  in 
place). 

Indeed, the synthetic indicator measuring the link between the EU school scheme design 
and  other  national  policies  and  interventions  shows  its  lowest  value  for  agriculture 

301 The National Programme for Food has 5 axes: social justice, fight against food waste, food education, catering 
and regional food projects. 
302 https://www.nasasuperhrana.si/tradicionalni-slovenski-zajtrk/o-projektu/projekt/ . 

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interventions, whereas national health policy actions have played a more decisive role at 
the time of planning the school scheme strategy. 

Figure 23: Link between the EU school scheme design and other national policies and 
interventions in the agricultural, health and education sector303 

Source: own elaboration of PA survey data 

Interaction  of  the  different  policy  instruments  was  used  in  several  MS  (e.g.,  Czechia, 
Lithuania,  Spain,  Poland,  France)  through  a  process  of  public  consultations,  stakeholder 
meetings and working groups in order to discuss and define issues such as needs, budget 
allocation, choice of providers, etc. 

The  information  gathered  through  interviews  in  the  case  study  MS  confirm  the  limited 
number  of  other  agriculture  related  initiatives  linked  to  the  EU  school  scheme:  the 
development  of  the  EU  school  scheme  strategy  seems,  in  fact,  to  be  ultimately  led  by 
health related issues. Therefore, no complementary measures in the agriculture sector and 
the EU school scheme emerged, with the notable exception of organic farming: 

 

 

In France, stakeholders and operators agreed that EU school scheme contributed to the 
national objective of developing sustainable food production, notably through organic 
farming  -  promoted  by  the  2023  “climate  law”  -  or  other  labels304,  while  the 
representatives  of  the  dairy  sector  further  outlined  that  the  EU  school  scheme  was 
directly in line  with  art.  24  of  the  law  for  the  balance  of  commercial relations in  the 
agricultural and food sector and healthy, sustainable and accessible food for all, which 
aims  at  promoting  signes  d'identification  de  qualité  et  d'origine  (SIQO)  in  mass 
catering.   According  to  the  French  representatives  of  the  fruit  and  vegetables  sector 
however, the list of eligible quality labels could be revised to include more labels such 
as HEV3305, or transition to organic farming, in order to fit the objectives of the new 
climate law.  
In the Netherlands, although the agricultural policy focuses on sustainable agriculture, 
the introduction of organic products in the EU school scheme has not been easily carried 
out,  showing  lack  of  consistency  with  certification  requirements  of  certain  products 
(i.e., milk products). 

303  The  question  asked  was:  To  what  extent  the  other  national  policies/interventions  related  to  agriculture  / 
education / health have been taken into account when drafting the school scheme in your country/region? 
304 In France the EU school scheme mainly promotes products under quality labels, as these are the only eligible 
products on lunchbreaks. 
305 High environmental value (HEV) corresponds to the highest level of a more general scheme of environmental 
certification for farms. The farm environmental certification is a voluntary approach which aims to identify and 
promote  particularly  environmentally-friendly  practices  applied  by  farmers.   In  order  to  engage  the  whole 
agricultural sector in an approach focused on environmental progress, it is designed on the basis of certification 
of the whole farm at three levels. The third or "high environmental value" level is based on performance indicators.  

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Judgement  criterion  10.2:  There  is  (there  is  not)  a  relationship  between 
national  policies/interventions  and  the  EU  school  scheme  strategy  in  the 
educational sector  

More than half (60%) of the authorities responding to the PA survey reported about the 
implementation  of  national  policies  and/or  interventions  aiming  at  raising  awareness  on 
the positive effects of healthy eating habits. Among those authorities, 12 (Denmark, DE 
Bremen, DE Lower Saxony, DE Mecklenburg-Western Pomerania, DE Schleswig-Holstein, 
Estonia, France, Cyprus, Lithuania, Poland, Portugal and Sweden) answered that nutrition 
and  healthy  eating  habits  are  part  of  the  regular  curricula  taught  in  schools.  In  the 
remaining cases, specific projects or initiatives have been reported (e.g., Czechia, Ireland, 
Luxembourg, Malta, The Netherlands, Slovenia). 

Furthermore, according to the PA survey, 23% of the authorities responding indicated that 
they  have  taken  into  account  the  existing  national  policies/interventions  “to  a  great 
extent”: among these Germany, France, Malta, The Netherlands and Sweden. The share 
of strategies which took into account “very little” or “did not” take into account national 
policies related to education in healthy consumption appears lower (35%) than the share 
observed  in  the  previous  criterion  (JC1)  in  relation  to  agriculture  initiatives  (50%). 
Accordingly, the score of the synthetic indicator measuring the link between the EU school 
scheme and other national policies and interventions is higher. 

Information  from  CS  supports  the  results  of  the  PA  survey  and  clarifies  if/how  national 
initiatives on education were taken into account when the EU school scheme was drafted: 

 

 

 

 

In the Czech Republic, the Ministry of Agriculture actively cooperated with the Ministry 
of Education, Youth and Sports in designing the strategy of the school scheme.  
Italy  specified  that  the  main  actions  implemented  by  the  Ministry  of  Education, 
University and Research (MIUR) in the field of food education were taken into account 
when planning the national strategy306.  
In Spain, the Ministry of Education reported a high level of coherence of the various 
programmes regarding education, and strong synergies with environmental education 
(e.g., on the topics of recycling, carbon footprint, integrated production).  
In Portugal, the role of schools as a privileged context for reaching a large number of 
children  in  early  stage  of  development  is  considered  a  determining  factor  to  reach 
families and to influence attitudes and behaviours of future generations. In this sense, 
the Ministry of Education has been progressively investing in children food health and 
has  been  working  at  different  levels  so  that  the  school  population  acquires  better 
literacy in nutrition, better understanding of the scope of food health issues and finds 
a  coherent  food  offer  in  the  school  space,  following  the  guidelines  of  the  health 
authorities.  

306  MIUR document  "Guidelines for Food  Education,  2015"  provides  the framework  in  which  Food  Education  is 
placed  within  Italian  education  and  training  system,  also  in  light  of  educational  and  cultural  heritage.  The 
Guidelines are directed not only to the school system, but also to all subjects direct and indirect involved, external 
to schools. Through the Guidelines and thanks to teachers, families can participate in information and training 
courses on food and on food culture as only through extensive and up-to-date knowledge of the food system, it 
is  possible  to  make  correct  choices,  for  themselves  and  for  the  society.  Young  people  learn  about  positive 
changes: less waste of food and water, search for global quality, fight against illegality, choice of local products 
and product seasonality, enhancement of excellence of Made in Italy and local productions, respect for food habits 
and  customs  from  other  countries,  intercultural  dialogue,  sensitivity  to  global  citizenship  and  to  sustainable 
development according to ecological, social and economic criteria.  
MIUR  –  “Extension  of  the  Educational  Offer  -  Funds  pursuant  to  Law  440”  dedicated  to  the  development  of 
educational  projects  aimed  at  promoting  health  education,  food  education  and  healthy  lifestyles.  In  2016  the 
“National  plan  for  promotion  of  health  education,  nutrition  education  and  healthy  lifestyles”  was  launched,  to 
which 702 educational establishments have participated with original projects.  

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  Finally,  in  Bavaria  the  Managing  Authority  highlighted  that  in  the  implementation 
regulation for the Bavarian Child Education and Care Act (AVBayKiBiG), the educational 
and  upbringing  goals  that  are  binding  for  all  state-funded  day-care  centers  are  laid 
down307.  

One  exception  is  represented  by  Romania  where,  although  the  national  pilot  scheme 
activated in 2017 to provide food support for pre-schoolers and students in 50 schools308 
(now 150) was considered when planning the school scheme, interviewed public authorities 
reported that national policies related to education were not considered, as in many cases 
products are distributed to pupils by auxiliary school personnel (i.e., school maids) without 
accompanying distribution with appropriate educative information provided by specialized 
personnel.  

If in general, local authorities and/or educational establishments were not involved in the 
planning of the strategies, coherence was ensured through different means:  

 

 

 

In the Czech Republic the Interdepartmental Coordination Group on the School Fruit, 
Vegetables  and  Milk  School  Project,  which  involved  representatives  of  relevant 
ministries,  other  state  bodies  and  experts,  worked  for  ensuring  coherence  and 
cooperation309,  while  another  Interdepartmental  Consultative  Group  worked  to 
approve accompanying measures. 
In  France, a  steering  committee  of  the  EU  school  scheme  was  established,  which 
includes representatives of the Ministry of Education.  
In Italy, the national strategy ensures its coherence with nutrition education initiatives 
developed  at  regional/local  level  by  encouraging  the  development  of  additional 
accompanying  programs  and  measures.  Communication  activities  developed  by  the 
Ministry  of  Agriculture  also  try  to  ensure  that  activities  carried  out  at  local  level  are 
adequately disseminated.  

  Poland issued a binding catalogue of accompanying educational measures to be put in 

 

place. 
In Spain, meetings and working groups with all relevant stakeholders were organised 
before planning the strategy (a referent teacher in a referent educational centre was 
designated).  

  Finally, in DE Bavaria the involvement of nutrition experts and discussion with other 

stakeholders (e.g., civil society associations) were the main tools used. 

Judgement  criterion  10.3:  There  is  (there  is  not)  a  relationship  between 
national  policies/interventions  and  the  EU  school  scheme  strategy  in  the 
health sector  

The  analysis  aims  at  exploring  the  relationship  between  national  health  policies  and 
initiatives and the EU school scheme. In this regard, 85% of respondents to the PA survey 
report about existing initiatives aiming at promoting healthy eating habits in their national 
context. Some of those initiatives are directly linked to national legislation or programme 
implementation  (e.g.,  BE  Flanders,  Bulgaria,  Denmark,  DE  Schleswig-Holstein,  Spain310, 

307 In the Bavarian Education and Training Plan (BayBEP), these educational and training goals, as well as the 
key  processes  for  the  quality  of  education  and  training,  are  presented  in  detail  and  form  the  basis  for  the 
pedagogical  work  in  the  state-funded  Bavarian  day-care  centers.  In  particular,  a  few  projects  aiming  to  raise 
awareness on healthy nutrition and deepen the topic of origin and production of food were highlighted (e.g., “Full 
in shape”, "Countrywomen go to school", "Farm experience", "Know how it grows and tastes good", "Food lovers", 
"Healthy and fit in children's everyday life”). 
308 Pilot program to provide food support for pre-schoolers and students in 50 public pre-university schools. 
309 This working group met several times a year and worked on an agenda related to the European agenda. 
310National Plan for fighting child obesity. 

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Croatia,  Latvia311,  Portugal,  Slovenia  and  Sweden312)  and  often  produce  manuals  or 
guidelines of these initiatives aiming at promoting healthy habits.  

The case of France is of particular interest where, as previously mentioned (JC 10.1), the 
EU school scheme aims at deploying all the actions of education on food and taste planned 
within the framework of the PNA and the handbook of the Ministry of Education “education 
on food and taste” intended for teachers and school managers. Adaptive and easy to use 
tools (e.g., videos) have been developed in interdepartmental cooperation, in particular to 
disseminate public health messages targeting children and adolescents, in connection with 
the food distributed313.  

Other authorities have also reported on the implementation of nationally funded projects 
(e.g.,  Slovenia314  and  Slovakia315),  beside  the  measures  executed  via  the  EU  school 
scheme.  

The  relationship  between  national  health  initiatives  and  the  EU  school  scheme  appears 
strong,  also  supported  by  the  extent  to  which  national  policies/interventions  related  to 
health have been taken into account when designing the EU school scheme strategy. As 
reported  under  JC  10.1,  this  is  the  policy  area  where  the  greatest  interaction  has  been 
reported (highest value of the PA survey synthetic indicator). In particular, 83% of survey 
respondents in fact report to have considered the existing national health initiatives when 
planning the strategy either to “a great extent” (e.g., BE Flanders, Denmark, France, Latvia 
and Portugal) or “somewhat”. Only 18% of authorities reported a weak interaction between 
the drafting of the EU school scheme and local initiatives: among those, only 2 (Romania 
and DE Saarland) deem this interaction non existing at all.    

Coherence between national initiatives and the EU school scheme seems well supported by 
the interviews in case study MS: 

 

 

in  the  Netherlands,  the  Ministry  of  Health  coordinates  and  finances  the  “Healthy 
Schools” (Gezonde Scholen) Programme, which mainly targets prevention, obesity and 
exercise (with national targets set by the Cabinet) and which liaises with the EU school 
scheme316.  Another  national  Programme  acting  in  coherence  with  the  EU  school 
scheme  is  the  "Learn  to  eat  healthy"  (Smaaklessen)  Programme  of  the  Ministry  of 
Agriculture, which focuses on interactions between farmers and schools and teachers, 
for example, on how to grow vegetables;  
in  France,  the  National  Programme  for  Nutrition  and  Health  (Programme  National 
Nutrition  Santé  -  PNNS)  provided  guidance  for  the  design  of  the  French  EU  school 
scheme.  This  policy  has  cross-cutting  objectives  and 
includes  scientists’ 
recommendations for school catering and food education as well as nutritional goals;  

https://www.aesan.gob.es/AECOSAN/web/nutricion/subseccion/vigilancia_obesidad_infantil.html . 
311 https://www.vm.gov.lv/lv/veseligs-uzturs . 
312 Government Office Memorandum of facts 2013/14:FPM61 – EU school fruit, vegetables and milk scheme.  
313  The  deployment  of  these  tools  also  contributes  to  the  implementation  of  the  law's  obligations,  since  food 
education and the fight against food waste are included in the national education code. It is indeed planned that 
information and education on food and the fight against food waste, consistent with the guidelines of the national 
program of nutrition and health and the national program for food, are provided in schools, as part of the teaching 
or the territorial educational project. 
314Kids 
meal! 
prepare 
(https://www.kuhnapato.si/KUHNAPATO,,predstavitev,english.htm);  Water  schools  -  project  Voda  zmaga 
(http://www.waterschools.eu/si/primeri-dobre-prakse/voda-zmaga-slovenija). 
315 “Let´s talk about the food”; “I know what I´m eating” 
316 However, the Ministry of Health was not involved in drafting the national strategy for the EU School Scheme. 
Providing fruits, vegetables or dairy products is not a primary national objective for the Ministry of Health, but it 
is coherent with their programme. Similarly, youth is always focus point, because it is useful to start early to set 
healthy habits, but it is not a specific policy for them to increase children’s consumption of F&V.  

traditional 

healthy 

Let’s 

Kids 

to 

– 

a 

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 

in  Italy,  the  national  health  policy  initiatives  taken  into  account  when  preparing  the 
school scheme strategy are indicated in the national strategy document: in particular, 
the  Programme  "Gaining  health:  making  healthy  choices  easy"  promoted  by  the 
Ministry of Health, to combat the four main risk factors of chronic non-communicable 
diseases (smoking, alcohol abuse, improper diet and physical inactivity) according to 
the lines of action prepared by the WHO317 and “Okkio alla salute” (“Keep an eye on 
your health”), a national health surveillance system, financed by the Ministry of Health 
and  coordinated  by  the  Higher  Institute  of  Health  (Istituto  Superiore  di  Sanità)318. 
According  to  providers  of  educational  measures,  although  the  latter  initiative  can 
indicate where it is more needed to bring educational messages with respect to healthy 
diet and correct nutrition, since in certain areas obesity rates are higher than in other 
areas, no real sharing of project results among stakeholders took place.  

According to interviewed health authorities (Portugal, France and Spain319), coherence has 
been ensured mostly through cooperation among the different public authorities (e.g., in 
Monitoring  Committee,  meetings)  and  it  is  mainly  aimed  at  meeting  nutritional 
recommendations,  hence  relating  to  the  choice  of  products  to  be  distributed,  choice  of 
target  groups  and  frequency  of  distribution.  In  other  MS  (Poland  and  the  Netherlands), 
cooperation between different public authorities is mainly aimed at reaching out to target 
groups and other beneficiaries, also by taking advantage of existing national programmes.  

4.4.3.3  Conclusions  

The analysis based on desk research and information gathered through the PA survey and 
through  interviews  in  the  MS  case  studies  suggests  that  the  national  policy  initiatives 
indicated by the surveyed national authorities related to education and health have a good 
level  of  coherence  with  the  EU  school  scheme  objectives.  Coherence  with the  education 
initiatives  is  mainly  established  by  the  use  of  school  curricula  on  relevant  topics  (e.g., 
environmental effects) and the involvement of the different stakeholders both in the design 
and in the implementation of the policy, while coherence with health initiatives is grounded 
in the implementation of national programmes and projects aiming at promoting healthy 
eating habits among children. 

Such a positive outcome seems very much correlated to the fact that existing legislative 
framework or policy actions were operational, in the given MS, before the 2017-2023 EU 
school scheme strategy was planned, favouring, therefore, the implementation of the EU 
school scheme. Sometimes, ad hoc projects have also given way to piloting actions which 
were  later  further  implemented  within  the  strategy  (e.g.,  through  accompanying 
measures). Moreover, integration between the EU school scheme and national initiatives 
is  granted  through  more  or  less  structured  cooperation  between  the  different  public 
authorities involved, both before planning the strategy and during its implementation (e.g., 
Monitoring Committees). 

However,  cooperation  seems  to  be  well  established  at  central  level  (between  public 
authorities),  while  it  is  not  actively  including  actors  at  local  level  (schools  and  local 

317  Within  the  "Gaining  health"  programme,  the  Ministry  of  Health,  together  with  the  Ministry  of  Education, 
University and Research (MIUR), the Higher Institute of Health (ISS) and the Council for Research in Agriculture 
and  Agricultural  Economics  (CREA),  has  produced  information  materials  for  education  and  health  promotion 
initiatives, both for schools and families. In this context, a multimedia educational kit was developed, divided into 
five specific teaching units (plus a manual for teachers) addressing issues of healthy eating and physical exercise.  
318 The sample survey of 9-10 years old children conducted every 2-3 years constitutes an important source of 
data  on  lifestyles  of  primary  school  children  and  represents  the  Italian  institutional  response  to  the  need  of 
addressing the problem of overweight and obesity in the child population. 
319 There is a collaboration with the national health authorities and meetings are organised with the authorities 
at regional level. The decision about target age groups, frequency of the distribution and its duration was decided 
in each Autonomous Community (apparently, highly driven by budget limitations). 

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authorities),  although  their  importance  for  the  success  of  the  policy  is  overall  well 
acknowledged.  

As far as agriculture policy initiatives are concerned, the results of the analysis point out 
the coherence between the national initiatives implemented, although limited in number 
and implemented by a limited number of MS, and the EU school scheme. 

Only few national initiatives foresee objectives linked to agricultural issues and these are 
specific  objectives  such  as:  support  to  organic  farming  (e.g.,  certificates  awarded  to 
schools  reaching  a  certain  share  of  organic  products  distributed);  promotion  of  quality 
products produced under environmentally, economically and socially adequate conditions; 
support to local production, also through the application of specific procurement criteria as 
the “Green Public Procurement”. 

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4.5  Relevance 

4.5.1  ESQ  11  -  To  what  extent  has  the  EU  school  scheme  corresponded  to  the 

needs of the EU stakeholders?  

4.5.1.1  Background and methodological approach  

Understanding 

The evaluation question asks to assess to what extent the EU school scheme is relevant in 
relation to the needs of EU stakeholders.  

Definition of key terms 

Relevance is defined as the extent to which a policy intervention is a pertinent tool to 
address the existing needs and problems. In other words, the evaluation question asks 
to formulate a judgement on the ability of the EU school scheme to satisfy the current 
needs  of  EU  stakeholders.  It  is  also  important  to  assess  whether  the  original  needs 
reported in the strategies are still relevant. 

Our understanding is that “EU stakeholders” include the institutions and other subjects 
responsible  for  the  scheme  planning  and  implementation,  educational  establishments 
and  other  subjects  administering  the  school  scheme,  product  suppliers/distributors, 
providers  of  accompanying  educational  measures  and  the  end  beneficiaries  (i.e., 
children,  their  families  and  the  wider  civil  society  including  consumer  associations, 
parent/teacher associations, health NGOs).  

Needs  are  laid  out  in  the  national/regional  strategies  and  they  generally  are  closely 
linked to the main objectives of the EU school scheme of increasing children consumption 
of selected agricultural products (F&V, milk and dairy), promoting healthy eating habits 
and shape healthier diets (please refer to the intervention logic). Needs identified in the 
strategies  such  as  increasing  children’s  consumption  of  F&V,  milk  and  milk  products, 
increasing the variety of distributed products, promoting the distribution of local/regional 
products,  connecting  children  to  food  production  systems  are  more  closely  connected 
with  viable  food  production  objectives  of  the  CAP  included  in  the  intervention  logic: 
contribute to farmer income, contribute to market stability, improve competitiveness and 
meet consumer expectations. Few needs included only in some school scheme strategies 
more  closely  relate  to  objectives  of  other  policies,  such  as  environment  (reduce  food 
waste)  and  socio-economic  (increase  F&V  and  milk  consumption  in  disadvantaged 
children’s groups).  

Judgement criteria, indicators and sources 

The answer to the evaluation question is based on the following criteria and indicators.  

Judgement criteria 

Indicators 

Sources 

involvement 

JC11.1:  The 
of  public 
authorities  and  private  stakeholders  in  the 
design  and  implementation  of  the  school 
scheme  strategy  has  (has  not)  been 
adequate  to  ensure  that  the  needs  of  the 
different EU stakeholders are met 

JC11.2: The EU school scheme has (has not) 
been relevant with respect to addressing the 
needs expressed in the strategies: Increase 
children consumption of F&V, milk and dairy 
products in the long run 

11.1.1 Judgement of relevance based 
on  theoretical  analysis  of  school 
scheme  strategies  and  on  informed 
opinions  of  EU  stakeholders  in  CS 
MS/regions 

-  EU 

school 

scheme 

strategies 2017-2023 
-  Structured  interviews 

in CS MS/regions 

11.2.1 Judgement of relevance based 
on  analysis  of  school  scheme 
strategies in relation to chosen target 
groups, criteria for products’ choice, 
model  of  product  distribution  and 
AEM themes 

-  EU 

school 

scheme 

strategies 2017-2023 

-  Annual 

monitoring 
to 

reports  2017/18 
2020/21 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

Judgement criteria 

Indicators 

Sources 

Judgement  of  PAs  on 

11.2.2 
relevance of the school scheme  
11.2.3  Informed  opinions  of  EU 
stakeholders  in  CS  MS/regions  on 
relevance of the school scheme  
11.2.4 Results of other ESQs 

-  Public 
survey 

Authorities 

-  Structured  interviews 

in CS MS/regions 

-  Answers 

to  ESQ1-

ESQ2-ESQ3 

1 

2 

3 

4 

5 

6 

7 

8 

9 

Increase  the  number  of  children  / 
schools involved in the school scheme 
Contribute to attaining recommended 
daily consumption of F&V, milk/dairy 
Promote  children  healthy  eating 
behaviour/Develop  healthy  eating 
habits  
Contribute to reducing overweight and 
obesity rates in children 
Raise  children  awareness  of  the 
benefits  of  consuming  F&V,  milk  and 
milk products 
Improve  children  knowledge  of  food 
systems, 
production 
ecological/organic 
farming, 
sustainable production  
Educate children to reduce food waste 
distributed 
variety 
Increase 
children 
/ 
products 
consumption  
Promote  distribution  of  local/regional 
products 

Diversify 

of 

to 

10  Contribute 

F&V, 
milk/dairy  consumption  in  socially 
disadvantaged children’s groups 
11  Encourage  parents’  participation  in 

increasing 

the school scheme 

JC11.3: The needs originally identified in the 
national/regional  school  scheme  strategies 
are still (are no longer) relevant 

11.3.1 Informed opinions of PAs and 
EU stakeholders on current relevance 
of the EU school scheme 

-  Public 
survey 

Authorities 

-  Structured  interviews 

in CS MS/regions 

Methodological approach and its limitations 

Tools, method and sources used 

The analysis is carried out at EU-28 level (EU-27 + UK) and at Case Study (CS) level. The 
answer  to  this  evaluation  question  is  based  on  desk  analysis  and  empirical  analysis. 
Triangulation of data from different sources (i.e., school scheme strategies; primary data 
collected through PA survey and interviews in Case Study MS/regions; AMR data; results 
of other ESQs; evidence from relevant scientific literature) was used wherever possible. 

The first step of the analysis consisted in a desk review of school scheme strategies aimed 
at  identifying  the  expressed  needs  and  at  assessing  whether  the  choices  made  by  the 
MS/regions adequately address such needs. The analysis focused in particular on: 

 

 

choice of target groups and model of product distribution including criteria and priorities 
for product choice; frequency/duration/timing of distribution; 
themes of accompanying educational measures. 

Empirical analysis was based on the primary data collected through the survey of Public 
Authorities  and  through  structured  interviews  with  EU  stakeholders  in  case  study 
MS/regions and on AMR data. Results of the PA survey are presented through calculated 
synthetic  indicators  (see  following  analysis  under  Judgement  Criterion  11.2).  Where 
appropriate, the analysis has taken into account the results of other evaluation questions: 
results of ESQ1 and ESQ2 based on family survey data provide information about families’ 
(i.e., end beneficiaries) perceived influence of the school scheme on consumption of F&V 
and milk/dairy and other relevant elements; ESQ3. 

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Limitations of methods and sources 

One  limitation  lies  in  the  possible  response  bias  of  school  scheme  managing  authorities 
answering the PA survey. Surveyed PAs are responsible for the planning the school scheme 
strategies  notified  to  the  Commission  and  for  scheme  implementation  and  it  cannot  be 
excluded that “desirable” answers were provided to some extent (e.g., yes, the scheme is 
relevant  with  respect  to  the  needs  of  EU  stakeholders).  However,  the  overall  PA  survey 
results are clear and confirmed by interviews carried out in case study MS and regions. 

4.5.1.2  Analysis 

Judgement criterion 11.1: The involvement of public authorities and private 
stakeholders  in  the  planning  and  implementation  of  the  school  scheme 
strategy has (has not) been adequate to ensure that the needs of the different 
EU stakeholders are met 

The  answer  is  based  on  desk  analysis  of  the  MS/regions’  school  scheme  strategies, 
supplemented by analysis of information collected in CS MS/regions through interviews. 

The analysis is developed on the assumption that the larger the number of actors including 
public  authorities  representing  different  policy  interests  such  as  agriculture,  health, 
education, environment, economic and social affairs and other public/private stakeholders, 
including  market  agencies,  national  paying  agencies,  agricultural  sector  organisations, 
product  suppliers/distributors,  providers  of  accompanying  educational  measures, 
representatives  of  educational  establishments,  research 
institutes,  civil  society 
representatives320,    involved  in  planning  and  implementation  of  the  scheme,  the  more 
adequate the strategy should be in addressing the needs of the various EU stakeholders.  

The analysis of national/regional school scheme strategies complemented with information 
from  annual  monitoring  reports  indicates  that  different  approaches  were  used  at  the 
planning stage321. Most strategies (36 out of 43) were designed by joint effort of different 
public authorities with responsibilities in agriculture, health/nutrition, education and also 
social  affairs.  Of  these,  18  strategies  also  involved  one  or  more  stakeholders  (F&V  and 
dairy sector representatives, market development agencies, chambers of commerce in BE-
Flanders,  DE-Baden-W.,  DE-Saxony,  DE-Saxony-Anhalt,  Denmark,  Estonia,  Ireland, 
France,  Lithuania,  Luxembourg,  Hungary,  the  Netherlands,  Austria  and  Slovenia;  public 
health and/or nutrition institutes/organisations in BE-Flanders, Czechia, DE-Hessen, DE-
Saxony-Anhalt,  Lithuania,  the  Netherlands,  Slovenia  and  Slovakia;  representatives  of 
schools/municipalities in Denmark, DE-Baden-W., DE-Schleswig-H., Latvia and Slovenia; 
consumer association in Austria) in the design of the school scheme. These latter strategies 
should  have  ensured  the  identification  of  the  needs  relevant  to  different  groups  of 
stakeholders. 

The information collected through structured interviews in the selected case study MS and 
regions  confirms  that  for  planning  the  strategy,  most  MS/regions  had  either  set  up  a 
steering committee and/or used a consultation approach with various public authorities at 
national  and  sometimes  also  at  regional/local  level  (Spain,  France,  Italy,  Portugal)  and 
other  stakeholders  to  cover  agriculture  and  environment,  health  and  nutrition,  and 
education aspects322.  

At the implementation stage, the involvement of different public authorities (in particular, 
within the scope of health and education) appears to slightly decrease and the number of 

320 Including consumer associations, teacher/school associations, parent associations and NGOs. 
321 Planning here refers also to subsequent re-planning as a number of strategies have been amended post 2017. 
322 Scientific research in health, nutrition and food habits of children and adolescents was also consulted at the 
planning stage (Czechia, Spain, France, Italy, Lithuania, Poland, Portugal and Bavaria). 

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school scheme strategies being centrally managed by one public authority alone (often the 
Ministry  of  Agriculture)  increases.  However,  many  strategies  involve  agriculture,  health 
and  education  public  authorities  as  well  as  the  paying  agencies  in  the  scheme 
implementation, usually allocating specific responsibilities to different actors.  

Health authorities are generally in charge of suggesting and/or approving the products to 
be distributed in schools and related nutritional aspects323. Public authorities in education 
are  called  upon  in  matters  relating  to  schools’  selection  and  design  and  provision  of 
accompanying educational measures. National paying agencies are responsible for on-the-
spot checks and generally also for administrative checks; in some cases, the paying agency 
is in charge of selection of suppliers of products and AEMs to schools (Bulgaria, Croatia) 
and  for  scheme  monitoring  and  evaluation  (Czechia,  Estonia,  Greece).  In  few  cases, 
national  paying  agencies  are  responsible  for  overseeing  the  whole  school  scheme 
implementation (Bulgaria, Czechia, France, Malta, Poland, Slovakia).  

The degree to which different public authorities and other stakeholders are involved in the 
implementation of the EU school scheme appears to vary across MS/regions according to 
different institutional set up and rules. The strategies involving to a larger extent different 
groups  of  stakeholders  (i.e.,  sectors’  representatives,  product  suppliers,  health  and 
education  organisations  and  other  civil  society  representatives)  in  the  scheme 
implementation are those of the Netherlands, France, Lithuania, Estonia, Latvia, Finland, 
Ireland,  Hungary,  Cyprus,  Belgium,  Germany  (federal  states  of  Baden-W.,  Berlin  & 
Brandenburg,  Bremen,  Hessen,  Lower  Saxony,  North-Rhine  Westphalia,  Schleswig-
Holstein,  Thuringia).  In  most  of  these  MS/regions  various  authorities  and  other 
stakeholders  share  responsibilities in implementing different elements  of the scheme, in 
monitoring and evaluation activities and communication. 

The importance of cooperation between agriculture, health and education public authorities 
is  highlighted  in  a  study  reviewing  the  F&V  school  scheme324.  The  wish  for  increased 
involvement of different public authorities and stakeholders emerges to some extent from 
the PA survey in Slovakia and Estonia (see for details the analysis under JC 11.3) and from 
case study interviews. F&V and dairy sector representatives interviewed in France wish to 
be  more  involved  at  the  planning  stage.  In  Bavaria,  separate  public  authority 
responsibilities  for  different  aspects,  such  as  planning,  implementation  and  control,  are 
perceived as making the coordination of scheme activities less effective. 

The analysis of school scheme strategies shows that, depending on institutional set up and 
rules,  different  MS/regions  have  adopted  different  planning  and  implementation 
approaches more or less involving of public authorities in agriculture/environment, health 
and  education  and  of  different  categories  of  stakeholders.  About  half  of  the  43  school 
scheme strategies involve various public authorities and different groups of stakeholders 
at both planning and implementation stages, thus overall ensuring that the needs of the 
different EU stakeholders are addressed. Information collected on the field through the PA 
survey  and  case  study  interviews  suggests  that  in  some  MSs  a  more  structured  and 
systematic involvement of health and education public authorities and other stakeholders 
(in  the  fields  of  agriculture,  environment,  health  and  education)  at  the  planning  and 
implementation stages may be desirable. 

323Some MS do not indicate in their strategies which body/institution is responsible for selecting and/or approving 
the products to be distributed in schools (i.e., Estonia, France, the Netherlands). Other MS adopt a participative 
approach by which agriculture, health and education public authorities are involved in the design of the strategy, 
including product selection, through committees/working groups or by consultation (i.e., Cyprus, Denmark, Italy, 
Luxembourg, Poland, Portugal). 
324Department of Nutrition, University of Oslo, “Feedback on the Combined evaluation Roadmap/Inception Impact 
Assessment: Review of the EU school fruit, vegetables and milk scheme”, 2022. Ongoing research as part of the 
JPI HDHL Policy Evaluation network (PEN) project (https://www.jpi.pen.eu/ ). 

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Judgement criterion 11.2: The EU school scheme has (has not) been adequate 
in addressing the needs of the EU stakeholders 

The answer to this judgement criterion is based on desk analysis of the MS/regions’ school 
scheme  strategies,  with  particular  reference  to  the  influence  of  certain  implementation 
choices on the ability of school schemes to adequately address the expressed needs, and 
empirical  analysis  based  on  PA  survey  data  (EU-27),  on  information  collected  through 
interviews in case study MS and regions and on results of other evaluation questions. 

The analysis of the strategies has allowed to identify the main needs expressed by MS and 
regions  at  the  time  of  designing  the  school  scheme.  The  following  table  associates  the 
needs expressed in the strategies325 to the EU school scheme objectives as established by 
EU regulations (intervention logic) and to the different EU stakeholders. 

Table 18 : Needs expressed in national/regional EU school scheme strategies 2017-2023 

EU school scheme 
objectives as 
established by EU 
regulations 
(Intervention 
logic) 

-  Increase 

consumption of 
selected 
agricultural 
products (F&V 
and 
milk/products) 
-  Maintain market 

stability 

Needs expressed in 
national/regional 
strategies 

1.  Increase children 
consumption of 
F&V, milk and 
dairy products in 
the long run 

2.  Increase the 
number of 
children / schools 
involved in the 
school scheme 

3.  Contribute to 
attaining 
recommended 
daily consumption 
of F&V, milk/dairy 

4.  Promote children 
healthy eating 
behaviour/Develop 
healthy eating 
habits 

-  Promote healthy 
eating habits and 
shape healthier 
diets 

5.  Contribute to 
reducing 
overweight and 
obesity rates in 
children 

6.  Raise children 

awareness of the 
benefits of 
consuming F&V, 

MS/regions 

EU stakeholders 

BE-Wallonia; BG; CZ; DK; 
DE-Bavaria; DE-Saxony; 
DE-Saxony-Anhalt; EE; 
IE; EL; ES; FR; HR; IT; 
CY; LV; LT; LU; HU; MT; 
AT; PL; PT; RO; SK; SE; 
UK 

IE; ES; IT; LU 

BE-Flanders; BE-Brussels; 
BG; DE-Berlin & 
Brandenburg; DE-
Bremen; DE-Mecklenburg 
West Pomerania; DE-
Lower Saxony; DE-NRW; 
DE-Schleswig Holstein; 
IE; FR; PT; SI; FI 

BG; CZ; DE-Bavaria; DE-
Berlin & Brandenburg; DE-
Bremen; DE-Hessen; DE-
Mecklenburg West 
Pomerania; DE-Lower 
Saxony; DE-Saxony-
Anhalt; DE-Thuringia; ES; 
CY; LV; LU; HU; NL; AT; 
PT; SI; SK; FI; UK 

BE-Wallonia; BE-Flanders; 
HU; NL; PL; PT; SK 

-  Public authorities/Public 
and private stakeholders 
involved in design and 
implementation of the 
school scheme 

-  Educational establishments 
and other school scheme 
administrators 

-  Product suppliers/Sector 

organisations 

-  Children and families 
-  Civil society 

-  Public authorities/ Public 
and private stakeholders 
involved in design and 
implementation of the 
school scheme 

-  Educational establishments 
and other school scheme 
administrators 

-  Providers of educational 

measures 

-  Children and families 
-  Civil society 

BE-Flanders; BG; DK; DE-
Baden-W.; DE-Bavaria; 
DE-Rhineland-Palatinate; 
DE-Saxony; DE-Saxony-
Anhalt; DE-Thuringia; ES; 

-  Public authorities/ Public 
and private stakeholders 
involved in design and 
implementation of the 
school scheme 

325 Additional needs are expressed in only few strategies: “improve communication about the scheme” (Spain, 
Austria);  “support  production  of  F&V  and  milk”  (BE-Wallonia,  Czechia);  “help  stabilise  producers’  income” 
(Hungary). 

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Needs expressed in 
national/regional 
strategies 

milk and milk 
products 

7.  Improve children 

knowledge of food 
production 
systems, 
ecological/organic 
farming, 
sustainable 
production 

8.  Educate children 
to reduce food 
waste 

9.  Increase variety of 

distributed 
products / 
Diversify children 
consumption 

10. Promote 

distribution of 
local/regional 
products 

11. Contribute to 

increasing F&V, 
milk/dairy 
consumption in 
socially 
disadvantaged 
children’s groups

Evaluation support study of the EU school fruit, vegetables and milk scheme 

EU school scheme 
objectives as 
established by EU 
regulations 
(Intervention 
logic) 

-  Increase 

consumption of 
selected 
agricultural 
products (F&V 
and milk 
products) 

-  Improve 

competitiveness 
-  Meet consumer 
expectations 

MS/regions 

EU stakeholders 

-  Educational establishments 
and other school scheme 
administrators 

-  Product suppliers/Sector 

organisations 

-  Providers of educational 

measures 

-  Children and families 
-  Civil society 

HR; IT; LV; LT; HU; NL; 
AT; PL; PT; RO; SI; SK; 
FI; SE 

BE-Wallonia; BG; DE-
Baden-W.; DE-Bavaria; 
DE-Hessen; DE-
Mecklenburg West 
Pomerania; DE-
Rhineland-Palatinate; DE-
Saarland; DE-Saxony; 
DE-Thuringia; EE; FR; IT; 
LV; NL; AT; SI; SK; FI 

-  Meet consumer 
expectations 

DE-Hessen; HR; LV; NL; 
SI 

-  Increase 

consumption of 
selected 
agricultural 
products (F&V 
and milk 
products) 

-  Improve 

competitiveness 

-  Increase 

consumption of 
selected 
agricultural 
products (F&V 
and milk 
products) 

BE-Flanders; BG; DE-
Rhineland-Palatinate; ES; 
FR; IT; PT; FI 

BE-Flanders; DE-Hessen; 
DE-Mecklenburg West 
Pomerania; DE-Saarland; 
LV; AT; SI 

IE (and FR, BE-Flanders, 
DE-Lower Saxony, DE-
North Rhine-Westphalia, 
DE-Rhineland-Palatinate 
and DE-Schleswig-Holstein 
as indicated in choice of 
Target Groups within the 
scheme strategy 
documents) 

-  Public authorities/ Public 
and private stakeholders 
involved in design and 
implementation of the 
school scheme 

-  Educational establishments 
and other school scheme 
administrators 

-  Children and families 
-  Civil society 

-  Public authorities/ Public 
and private stakeholders 
involved in design and 
implementation of the 
school scheme 

-  Educational establishments 
and other school scheme 
administrators 

-  Providers of educational 

measures 

-  Children and families 
-  Civil society 

12. Encourage 
parents’ 
participation in the 
school scheme  

-  Promote healthy 
eating habits and 
shape healthier 
diets 

ES; FR; IT 

Source: own elaboration based on analysis of EU school scheme strategies 

Not surprisingly, the needs that are more closely related to the two main objectives of the 
scheme  are  expressed  in  most  MS/regional  strategies.  Indeed,  the  needs  pertaining  to 
increasing F&V and milk/dairy consumption, are indicated in 37 school scheme strategies 
(out of 43) and the needs relating to the  objective of improving children healthy eating 
habits, are included in 33 strategies. Promoting children’s knowledge  of food production 
and of ecological/organic and sustainable production systems is the next most frequently 
expressed  need  (24  strategies).  The  remaining  reported  needs  are  relevant  for  smaller 
numbers of school scheme strategies.  

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It  seems  worth  highlighting  that in  most  strategies  the  needs  to  be  addressed  are  very 
often  expressed  in  a  way  that  makes  them  very  similar  to  objectives  (e.g.,  increase 
consumption  of  F&V)  rather  than  needs  (e.g.,  address  stagnating  or  declining  F&V 
consumption). Only few strategies appear to express “needs” more appropriately as needs, 
in particular BE-Flanders, Malta, the Netherlands, Poland, Portugal and Slovenia. 

In terms of priority ranking of needs to be reported by MS and regions in their strategies 
according to what established in Reg. EU No. 1308/2013, art. 23(8), again the majority of 
EU  school  scheme  strategies  rank  the  needs  relating  to  increasing  F&V  and  milk/dairy 
consumption and to improving children healthy eating habits as first, second or third. This 
appears to  confirm the  overall relevance  of the designed strategies in  addressing needs 
that are closely linked to the two main objectives of the EU school scheme. 

Influence of implementation choices on the relevance of the EU school scheme  

This  part  of  the  analysis  examines  the  influence  of  implementation  choices  made  in  the 
strategies on the ability of school schemes to satisfy the expressed needs. Where relevant, 
theoretical  analysis  is  complemented  with  information  found  in  the  literature  and  data 
collected through the PA survey and case study interviews, and results of other ESQs. 

Choice of target groups by children age and school level is expected to influence to some 
extent  the  ability  of  the  school  scheme  to  address  the  needs.  Research  shows  that 
identifying  the  most  adequate  target  group/s  by  children  age  is  difficult  due  to  limited 
evidence326. The scientific literature also shows that although eating behaviour is shaped 
early  in  life,  it  can  show  long-term  stability  (Mikkila  et  al.,  2005;  Issanchou,  2017327), 
therefore  education  in  nutrition  should  be  targeted  both  to  children  and  adolescents. 
Therefore, high coverage of the scheme across age brackets / school levels together with 
high  intensity  (i.e.,  high  share  of  children  participating  in  the  scheme  in  relation  to  the 
eligible school children population) should positively impact the ability of the school scheme 
to  address  needs  such  as  “increase  the  number  of  children  and  schools  involved  in  the 
school scheme” and “increase children consumption of F&V and milk/dairy in the long run”. 
All strategies have selected the primary school children group328, which is often deemed 
by  the  public  authorities  who  prepared  the  school  scheme  strategies  as  the  most 
appropriate target group. This is explicitly expressed in some strategies and supported to 
an extent by stakeholders’ opinions collected through CS interviews (Czechia, Italy, Poland, 
Spain). In Italy the choice of the 6-10 age group is based on the scientific literature, as 
children obesity rates are the highest in that age group, therefore linked to the need of 
reducing overweight and obesity in children. It should also be considered that the ability 
of school schemes to target with adequate coverage and intensity the different age groups 
is influenced by available financial resources as well. 

The EU school scheme is inclusive and it aims to improve the distribution of agricultural 
products  to  and  improving  children's  eating  habits  for  all  children  who  regularly  attend 
nurseries, pre-schools or primary or secondary-level educational establishments which are 
administered or recognised by the competent authorities of MS (Reg. EU No. 1308/2013, 

326  See  reference  in  previous  section  6.2.1  to  the  ongoing  Review  of  the  EU  school  fruit,  vegetables  and  milk 
scheme carried out at University of Oslo. 
327 Mikkila V., Räsänen L., Raitakari O.T., Pietinen P. and Viikari J., “Consistent dietary patterns identified from 
childhood to adulthood: The Cardiovascular Risk in Young Finns Study”, British Journal of Nutrition, 2005, No 93, 
pp. 923–931. Issanchou S., “Determining factors and critical periods in the formation of eating habits: Results 
from the Habeat project”, Ann Nutr Metab, 2017, No 70, pp. 251–256. 
328 Over half of school schemes (23 out of 43) include all school levels, 11 schemes cover the younger age brackets 
(nursery/pre-school and primary school levels) and further 3 school schemes cater for primary and secondary 
school  children  (HR,  NL  and  SI).  The  remaining  6  schemes  (CZ,  EL,  IT,  PL  and  the  German  federal  states  of 
Mecklenburg-Western Pomerania and Schleswig-Holstein) focus only on primary school children. 

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art.22).  However,  some  MS’  strategies  consider  it  important  to  also  ensure  product 
distribution to those children who are more in need. The need of “increasing F&V, milk/dairy 
consumption  in  socially  disadvantaged  children’s  groups”,  explicitly  reported  among  the 
needs of the strategy329only by Ireland330, is actually addressed also by the strategies of 
France,  Belgium  (Flanders)  and  Germany  (Lower-Saxony,  North  Rhine-Westphalia, 
in  the  choice  of  target  groups331. 
Rhineland-Palatinate  and  Schleswig-Holstein) 
Furthermore, 20 strategies include special schools (i.e., schools for children with special 
educational needs that feature in some MS) in their target groups. This suggests that the 
EU school scheme is relevant with respect to addressing the needs of more vulnerable or 
socially  disadvantaged  children  across  a  larger  number  of  strategies  compared  to  those 
having originally included this need. 

Criteria and priorities for product choice are also expected to influence the extent to which 
the school scheme is able to address the needs identified in the strategies. Analysis carried 
out to answer ESQ3 already informed that most strategies include among product choice 
criteria health considerations, local and regional products, variety and seasonality and, to 
a lesser extent, environmental consideration. Overall, these criteria appear to adequately 
address, respectively, the needs of improving healthy eating behaviour (expressed in 33 
strategies),  increasing  the  variety  of  products  distributed  to  children  (in  8  strategies), 
promoting  the  distribution  of  local/regional  products  (in  7  strategies)  and  improving 
children  knowledge  of  food  production  systems  including  organic  and  sustainable 
production (in 19 strategies)332. 

Evidence  in  the  literature  points  to  a  positive  influence  of  frequency  and  duration  of 
distribution on children consumption of fruit and vegetables (Roseman et al., 2020; Silveira 
et al., 2011; Haß et al., 2018)333. Moreover, a positive change in consumption is likely to 
be  maintained  over  time  to  some  extent  (Bere  et  al.,  2007;  Bere  et  al.,  2015)334.  We 
therefore  base  the  analysis  on  the  hypothesis  that  school  schemes  providing  for  higher 
frequency and longer duration of product distribution may be more adequate to address 
the need of increasing children consumption of F&V and milk/dairy in the long run. 

Examination  of  school  strategies  (planning)  and  annual  monitoring  report  data 
(implementation) shows, first of all, that implementation choices with respect to frequency 
and  duration  of  product  distribution  are  rather  diversified  across  national  and  regional 
schemes  and  in  some  cases,  also  between  the  F&V  and  the  milk  parts  of  the  scheme. 
Relatively homogeneous groups  of MS/regions were identified on the  basis of frequency 
and duration of product distribution. 

Table 19 : Frequency and duration of product distribution in EU school schemes (*) 

329 I.e., in the dedicated section 2 of the EU school scheme strategy template. 
330 An amendment to the strategy was made for the year 2020/21 to aim the programme more specifically at 
disadvantaged schools. 
331 I.e., in the dedicated section 4 of the EU school scheme strategy template. 
332 The priority “Fair-trade” is chosen by 7 MS/regions, but it does not address any of the needs identified in the 
strategies. 
333 Roseman M.G., Riddell M.C and McGee J.J, “Kindergarten to 12th grade school-based nutrition interventions: 
Putting past recommendations into practice”, Journal of Nutrition Education and Behavior”, 2020, No 52, pp.808-
820. 
Silveira J.A.C, Taddei J.A.A.C, Guerra O.H. and Nobre M.R., “Effectiveness of school-based nutrition education 
interventions  to  prevent  and reduce  excessive  weight gain  in  children  and  adolescents:  A  systematic review”, 
Jornal de Pediatria, 2011, No.87, pp.382-392. 
Haß J., Lischetzke T. and Hartmann M., “Does the distribution frequency matter? A subgroup specific analysis of 
the  effectiveness  of  the  EU  school  fruit  and vegetable  scheme  in Germany  comparing  twice  and  thrice weekly 
deliveries”, Public Health Nutrition, 2018, No.21, pp.1375-1387. 
334  Bere  E., Veierød  M.B., Skare  Ø.  and  Klepp  K.I., “Free school  fruit-sustained  effect  three years  later”,  Int J 
Behav Nutr Phys Act, 2007, No 4, pp.1-6. 
Bere E., Te Velde S.J., Småstuen M.C., Twisk J. and Klepp K.I., “One year of free school fruit in Norway – 7 years 
follow-up”, Int J Behav Nutr Phys Act, 2015, No 12, pp.1-7. 

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High frequency 

Medium frequency 

Low frequency 

High exposure 

DK;  DE-Berlin  &  Brand.;  DE-
Bremen;  DE-Hessen;  DE-Lower 
Saxony;  DE-NRW;  DE-Saarland; 
DE-Saxony-Anhalt;  IE(milk);  LT; 
HU;  NL(milk);  SK(milk);  FI,  SE; 
UK 

BG;  DE-Saxony;  DE-
DE-
Schleswig-H.; 
Thuringia; 
PT(F&V); 
SK(F&V) 

Medium exposure 

LT; NL (F&V) 

Low exposure 

IE (F&V); CY 

RO 

IT 

DE-Baden-W.; 

DE-
DE-Mecklenburg-

CZ; 
Bavaria; 
Western Pom.; 
DE-Rhineland-Palatinate;  EL; 
HR(F&V); LU; MT; PT(milk); SI 

BE-Wallonia, 
Flanders; ES; HR (milk) 

Brussels, 

High frequency: Daily distribution or 3-4 times/week; Medium frequency: Twice/week; Low frequency: 
Once/week. High exposure: Entire school year or 24-36 weeks; Medium exposure: 12 to 24 weeks; Low 
exposure: 2 to 12 weeks. 

(*) Three MS are not included in the table: in Estonia, France and Austria distribution covers the entire school 
year with frequency of distribution either being decided by product suppliers or by schools. 

Source: own elaboration of annual monitoring report data 

Based on the above hypothesis, MS and regions characterised by lower levels of frequency 
and duration of product distribution may be more at risk of not adequately addressing the 
need of increasing children’s consumption. Most school schemes show high and/or medium 
frequency/duration of distribution, and no school scheme falls into the Low exposure/Low 
frequency group, as shown in the table above. This suggests that, overall, the EU school 
scheme  adequately  addresses  the  need  of  increasing  children’s  consumption.  Only  few 
schemes are characterised by lower frequency/duration: Italy (medium frequency and low 
exposure), and the three Belgian regions, Spain and Croatia for milk (low frequency with 
medium  exposure).  Product  distribution  is  foreseen  at  morning  and/or  afternoon  snack 
breaks and, in addition, also with school meals.  It should be highlighted that most school 
schemes distributing F&V and milk/dairy with high frequency and duration, also distribute 
products with school meals (i.e., in addition to morning and/or afternoon snack times). By 
increasing  the  number  of  occasions  for  children  to  consume  F&V  and  milk/dairy  such 
schemes  may  be  regarded  as  more  adequately  addressing  the  need  of  increasing 
consumption.  

According  to  an  ongoing  study  by  the  University  of  Oslo  assessing  the  F&V  part  of  the 
scheme  (see  6.2.1),  the  importance  of  accompanying  educational  measure  has  grown 
compared to the previous scheme. In order to ensure the relevance of the school scheme, 
accompanying  educational  measures  (AEM)  should  be  designed  around  themes  that  are 
adequate to meet the needs identified in the strategies. Every year the monitoring system 
collects from MS and regions data about the main themes of such activities: Healthy eating 
habits; reconnection of children to agriculture; organic; sustainable production; local food 
chains; food waste. We consider such themes as respectively linked to the following needs: 
Promote  children  healthy  eating  behaviour  and  develop  healthy  eating  habits;  Improve 
children  knowledge  of  food  production  systems,  organic  and  sustainable  production; 
Promote distribution of local/regional products; Educate children to reduce food waste. 

Cross  analysis  of  AEM  themes  and  needs  indicates  that  in  most  cases  the  number  of 
strategies using a theme specifically connected to a particular need is either equal or larger 
than  the  number  of  strategies  explicitly  expressing  the  same  need.  Thus,  the  themes 
chosen for AEM appear to overall adequately address the needs of EU stakeholders. Only 
the  need  related  to  “Improving  children  knowledge  of  food  production  systems,  organic 
farming  and  sustainable  production”  expressed  in  19  strategies  is  not  fully  taken  into 
account through the “organic” and the “sustainable production” themes of AEMs, chosen 
by respectively 18 and 15 strategies. This slight inconsistency between AEM themes and 
corresponding needs is found in Bulgaria, Austria, Slovakia and the German federal state 
of Mecklenburg-W. Pomerania.  

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The results are consistent with the findings of ESQ2. In fact, the themes “reconnection of 
children to agriculture” and “healthy eating habits” are employed by nearly all strategies 
(97%  on  average  over  the  school  years  2017/18  to  2020/21).  At  the  other  end  of  the 
spectrum, “organic” and “sustainable production” are themes used by respectively 56.6% 
and 48.7% of the strategies (on average over the years 2017/18 to 2020/21  – see also 
ESQ9). 

Analysis  of  relevance  of  the  EU  school  scheme  based  on  PA  survey  and  case  study 
interviews 

National  and  regional  managing  authorities  responsible  for  the  school  scheme 
implementation  participating  in  the  survey  were  asked  to  provide  an  opinion  about  the 
extent to which the school scheme has adequately addressed the needs expressed in their 
strategies. For each identified need335, responses were collected on a scale ranging from 
“0=not  adequate  at  all”  to  “3=very  adequate”.  A  synthetic  indicator  (average)  for  each 
need was calculated based on these scores across all respondents336.   

Figure 24: Public Authorities’ opinions regarding the “Extent to which the EU school 
scheme has been adequate in addressing needs” 

Values: 0=not adequate at all; 1=not very adequate; 2=somewhat adequate; 3=very adequate 
Source: own elaboration of PA survey data 

PA survey results show that the school scheme is perceived as most relevant in relation to 
addressing the needs of increasing the number of schools/children involved in the school 
scheme, increasing children consumption of F&V, milk and dairy products in the long run 
and raising children awareness of the positive effects of consumption of F&V and milk/milk 
products (scores ranging from 2.40 to 2.51 on a 0-3 scale), thus indicating a good level of 
relevance  also  in  relation  to  the  main  school  scheme  objectives.  The  school  scheme  is 
thought to be overall sufficiently adequate to address most of the needs expressed in the 
strategies  (i.e.,  scores  >2),  but  less  adequate  with  respect  to  encouraging  parents’ 
participation,  to  addressing  the  needs  of  disadvantaged  or  vulnerable  children’s  groups 
(which is however expressed only by few strategies), to educating children to reduce food 
waste,  to  reducing  overweight  and  obesity  rates  in  children  and  to  promoting  the 
distribution of local and regional agricultural products.  

335 Respondents had the possibility to indicate whether needs are pertinent or not to their school scheme strategy. 
336 The number of respondents to each item of the question may vary according to which needs are reported in 
the respective strategies, as not all needs are indicated in all strategies. The number of responses to this question 
items therefore varies between 26 and 35 vis à vis the 37 completed questionnaires collected in total. 

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Informed opinions collected through interviews in case study MS and regions allow further 
insights in relation to the results of the survey.  

The  EU  school  scheme  is  generally  perceived  as  adequate  in  addressing  the  need  of 
increasing  F&V  and  milk  consumption  in  the  long-term  (thus  contributing  also  towards 
recommended intake), promoting healthy eating behaviour and raising awareness of the 
healthy  benefits  of  F&V  and  milk  consumption.  In  many  cases,  interviewees  (to  include 
most  public  authorities  and  other  stakeholders  such  as  product  suppliers,  F&V  and 
milk/dairy sector  representatives,  schools and  providers  of AEM)  stressed the important 
role played by educational measures (Italy, Czechia, Lithuania, Poland) and in some cases 
it was pointed out that the school scheme is adequate in addressing these needs in the 
long-term  (Bavaria,  North-Rhine  Westphalia,  Czechia).  However,  public  authorities  and 
representatives  of  civil  society  in  Portugal  and  in  Romania  consider  the  scheme  as  still 
inadequate,  largely  in  reason  of  insufficiently  developed  accompanying  educational 
activities. In Bavaria, one school representative argues that it is not possible to increase 
children consumption when only 100g of fruit (a small apple) are distributed per week per 
child. In France, F&V and dairy sector representatives consider the scheme as relevant to 
increase  children’s  daily  consumption  of  fruits  and  vegetables,  however  this  is  seriously 
limited  by  the  very  poor  uptake  of  the  scheme.  French  educational  establishments  also 
point  to  the  fact  that  product  distribution  cannot  be  done  any  longer  at  morning  and 
afternoon breaks, which seems to have reduced the quantities that can be distributed in 
schools337. 

Family  survey  results  (see  ESQ1,  JC  1.2)  show  that  a  large  proportion  of  children 
participating in the scheme (about 66% of the respondents for F&V and 52% for milk/dairy) 
do not consume the products distributed at school often or sometimes for various reasons 
such as lack of time at school breaks, difficulties with peeling fruit, etc. Similarly, the EU 
school  scheme  seems  to  have  contributed  to  increasing  or  at  least  maintaining 
consumption outside the school scheme only for a small part of participating children (in 
particular for F&V). 

With  respect  to  the  relevance  of  the  EU  school  scheme  in  addressing  the  needs  of 
“promoting  healthy  eating  behaviour”  and  “raising  awareness  of  the  healthy  benefits  of 
F&V and milk consumption”, the information collected through CS interviews and the PA 
survey are consistent with the results of the family survey: the conveyed messages that 
“fruit and vegetables are healthy”, “importance of eating fruit and vegetables daily”, “milk 
and  milk  products  are  healthy”  have  been  in  fact  learned  by  over  80%  of  the  children 
whose families responded to the survey (see ESQ2 – JC 2.3). 

In terms of contributing to reduce overweight and obesity rates in children, by promoting 
healthy eating and by distributing healthy products the school scheme is at least to some 
extent  relevant  in  contributing  to  reduce  obesity  (Poland).  However,  some  public 
authorities and educational establishments share the opinion that families are or should be 
mostly responsible for establishing consistent eating habits towards avoiding overweight 
(Czechia, Italy, Lithuania, Portugal, North-Rhine Westphalia, Bavaria) and that the school 
scheme can provide a limited contribution to reducing overweight and obesity.  

In  Italy,  Lithuania,  Poland  and  to  some  extent  Spain  and  the  Netherlands,  the  school 
scheme  is  perceived  by  educational  establishments  and  providers  of  AEM  as  fairly 
adequately  addressing  the  need  to  promote  children’s  knowledge  of  food  production 

337 The French strategy was modified in 2020 on the basis of recommendations made by the national agency for 
food safety, health, environment and labour (ANSES) to limit the daily number of distributions to avoid double 
breakfast and double teatime, which was deemed as wrongly encouraging extra food intake. 

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systems,  organic  farming  and  sustainable  production  through  targeted  educational 
measures  such  as  special  days  when  lectures  are  delivered  jointly  with  product  tasting, 
trips to local markets, farm visits338 and interactive computer games. In most other case 
study MS and regions, the general opinion from different stakeholders (schools, product 
suppliers  and  sector  representatives)  is  that  the  school  scheme  is  not  very  adequate  in 
addressing  this  need,  the  main  reason  residing  in  poor  design  and  lack  of  systematic 
delivery  of  accompanying  educational  measures.  Whether  the  judgement  is  positive  or 
negative, some further elements emerging from CS interviews seem worth reporting: 
  even if educational activities are regarded as adequate to address the need of improving 
children’s knowledge about production systems, organic agriculture and sustainability, 
such activities are carried out infrequently (once or twice a year for each F&V and milk 
part of the scheme) and they involve only part of the children participating in the EU 
school scheme, making it difficult to assess how adequate such activities actually are 
in  relation  to  this  need  (product  suppliers  and  providers  of  AEM  in  Italy,  Romania, 
Spain);  

  much  of  the  responsibility  of  providing  information  to  children  is  left  with  individual 
schools  and  teachers,  therefore  the  relevance  of  the  scheme  in  improving  children’s 
knowledge  can  vary  quite  a  lot  within  the  same  MS  or  region  (Bavaria,  North-Rhine 
Westphalia); 
improving  children’s  knowledge  of  sustainable  food  production  should  rather  be 
included in the ordinary school curriculum (sector representatives in Czechia, Sweden). 

 

The ability of the scheme to provide a variety of products to school children, linked to the 
need  “Increase  variety  of  distributed  products  /  Diversify  children  consumption”,  in  the 
opinions  of  interviewed  stakeholders,  mostly  applies  to  F&V.  Again,  the  views  of 
stakeholders across case studies differ. In some cases, product suppliers highlighted that, 
in spite of the possibility of distributing various different fruit and vegetables as foreseen 
in the respective scheme strategies, the number of products given to children is actually 
rather  limited  to  only  few  products  (Italy  and  Portugal).  In  Italy  in  particular,  the  short 
calendar of distribution, which appears to be compressed in the last weeks of the school 
year  (mainly  due  to  inefficiencies  in  managing  tendering  procedures  and  contracting  of 
suppliers,  as  indicated  in  case  study  interviews  by  F&V  sector  representatives,  product 
suppliers,  providers  of  AEM  and  confirmed  by  the  school  scheme  managing  authority), 
clearly limits the variety of products that can distributed and also the possibility for children 
to  taste  products  in  different  seasons.  Other  strategies  chose  to  limit  the  number  of 
products  to  be  distributed  (Bavaria,  Lithuania,  Romania),  which  is  seen  in  Bavaria  as  a 
limit of the scheme.  

Promoting the distribution of local and/or  regional products is not included as a need in 
any  of  the  case  study  MS/region  school  scheme  strategies.  A  question  regarding  the 
relevance of the school scheme in this respect was nevertheless asked in CS interviews. 
The  generally  shared  opinion  of  product  suppliers  and  sector  representatives  is  that  it 
would  be  desirable  to  promote  distribution  of  local  F&V,  however  the  higher  costs  of 
products  and  logistics  and  sometimes  also  limited  product  availability  prevent  local 
producers’  participation,  as  they  often  are  small-sized  companies  (Czechia,  France, 
Portugal).  In  Romania  as  well,  the  scheme  is  thought  of  not  sufficiently  addressing  the 
need  to  promote  local  and  regional  products.  French  F&V  sector  representatives  also 
pointed out that it is sometimes difficult to provide local fruits while ensuring the diversity 
of  the  products  distributed.  Other  school  schemes  by  choice  provide  both  local/regional 
products and products of other national or EU origin (Lithuania, Italy). Italy has chosen a 

338 However, as reported in ESQ2, farm visits are the type of educational measures involving a smaller number 
of children participating in the school scheme compared to most other AEM. 

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different  approach  for  F&V  and  milk,  where  priority  for  “local”  is  given  to  milk/dairy 
products but not so much to F&V because “children should come to know and appreciate a 
variety of F&V products typically produced in different regions”.  

Among case study MS and regions, the need of ensuring F&V and milk/dairy consumption 
in  socially  disadvantaged  children’s  groups  is  addressed  only  in  the  strategies  of  France 
and North-Rhine Westphalia. In both cases, interviews confirm that the school scheme is 
seen as fairly adequate to address the social issue. The relevance of the school scheme in 
relation to this need is also recognized in Romania and Bavaria.  

In terms of encouraging parents’ participation in the school scheme, explicitly expressed 
as a need in the strategies of Spain, France and Italy, the general perception is that parents 
are not much involved in the school scheme and often they do not have much information 
either,  in  spite  of  communication  being  directed  to  families  by  most  school  schemes 
through dedicated websites, newsletters, informative flyers given to children to take home, 
social  networks  and  others,  as  shown  also  by  family  survey  results  (see  ESQ2).  The 
perceived lack of parental involvement emerges from the opinions of different stakeholders 
in Italy, Spain, Poland, Portugal, Romania, Sweden, Bavaria and North-Rhine Westphalia. 
In most cases, interviewees report that greater involvement of parents and families would 
be  desirable,  in  particular  to  reinforce  the  health  messages  (i.e.,  importance  of  eating 
healthily)  transmitted  to  children,  for  example  through  parents’  participation  in  some 
accompanying educational measures.  Only in France and Czechia different stakeholders 
agree that the school scheme is adequately involving parents. 

the 
Judgement  criterion  11.3:  The  needs  originally 
national/regional school scheme strategies are still (are no longer) relevant 

identified 

in 

This  part  aims  at  assessing  the  extent  to  which  the  needs  originally  included  in  school 
scheme strategies are still relevant today, as a way also to collect possible suggestions for 
future improvements. 

The analysis is based on the data collected through the Public Authorities survey across 
the EU 27 and on informed opinions of EU stakeholders collected through interviews in case 
study MS and regions. 

According to surveyed Public Authorities, the needs identified when planning the strategies 
are with no doubt still highly relevant today. The question “In your opinion, are the original 
needs of the EU school scheme still relevant today?” was indeed answered affirmatively by 
all respondents. In order to gather better insight, PA survey respondents were given the 
possibility  to  add  their  comments.  Only  Denmark,  Estonia  and  Slovakia  took  the 
opportunity. One interesting element emerges in the answers of Estonian and Slovak public 
authorities,  as  both  judge  the  involvement  of  different  public  authorities  and  other 
stakeholders in the school scheme as insufficient. If more feedback and involvement from 
the  wider  society  is  needed,  then  “most  important  is  planning  the  involvement  process, 
targeted to reach broad-based and meaningful results” (Estonia) and also “education and 
public health authorities in individual MS should cooperate more on the programs in order 
to implement them more effectively and achieve the objectives, especially in relation to 
the education of children” (Slovakia). 

According  to  the  opinions  of  EU  stakeholders  collected  through  interviews  in  case  study 
MS/regions, the needs originally identified in the strategies are still highly relevant as they 
are not yet completely satisfied. In particular, consumption of F&V and milk/dairy is still 
low and overweight and obesity rates are still a problem (Czechia, the Netherlands, Poland, 
Romania and Bavaria). The only possible exception appears to be in relation to the need 
of  raising  children  awareness  of  the  benefits  of  eating  healthily  and  the  importance  of 
consuming F&V and milk/dairy on a regular basis, towards which the EU school scheme is 

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perceived to have so far performed reasonably well, at least in some MS (Czechia, Spain, 
Italy). 

Some further elements and suggestions emerge in some case study MS and regions: 

 

 

stronger focus should be put on vegetables, which are still less accepted than fruit (civil 
society representatives in the Netherlands); 
increasing attention is being paid to the use of animal products and their impact on the 
environment.  Animal  products  are  criticised  and  it  has  become  more  difficult  to 
implement the milk part of the scheme (health public authority in Spain and dairy sector 
representatives in Spain and Bavaria); 

  greater attention should be given to environmental aspects and sustainability issues: 
reduce unnecessary plastic, use eco-friendly packaging and recyclable glass bottles for 
milk,  increase  support  for  organic  products,  short  supply  chains,  seasonal  products 
(civil society representatives in North-Rhine Westphalia, F&V sector representatives in 
the Netherlands, providers of AEM in Italy); 
through  the  years,  increasing  focus  has  been  put  on  distributing  certified  quality 
products, whereas the real interest in terms of nutrition lies in the diversity of fruit and 
vegetables consumed (F&V sector representative in France); 
continue  to  simplify  the  administration,  managing  and  control  of  the  scheme  (civil 
society representatives in Lithuania, Slovakia). 

 

 

4.5.1.3  Conclusions  

The evaluation question asks to evaluate whether and to what extent the EU school scheme 
adequately addresses the needs of EU stakeholders. The analysis was carried out at EU28 
level (EU-27 + UK) and at Case Study (CS) level, based on desk review of school scheme 
strategies  and  relevant  scientific  literature,  and  on  empirical  analysis  of  various  data: 
primary data collected through PA survey and Case Study interviews; AMR data; results of 
other ESQs. 

The analysis of school scheme strategies shows that, depending on institutional set up and 
rules,  different  MS/regions  have  adopted  different  planning  and  implementation 
approaches  more  or  less  involving  of  public  authorities  in  agriculture/environment, 
health/nutrition, education and also social affairs and of different categories of stakeholders 
including market agencies, national paying agencies, agricultural sector organisations (i.e., 
F&V and milk/dairy), product suppliers/distributors, providers of AEMs, representatives of 
educational  establishments,  research  institutes  and  civil  society  representatives  (i.e., 
consumer/parent/teacher  associations,  NGOs).  About  half  of  the  43  school  scheme 
strategies involve various public authorities and different groups of stakeholders at both 
planning and implementation stages, thus overall ensuring that the needs of the different 
EU stakeholders can be addressed.  

Information  collected  through  the  PA  survey  and  case  study  interviews  confirms  the 
importance  of  cooperation  between  agriculture,  health  and  education  public  authorities 
highlighted in a study currently reviewing the F&V school scheme. Indeed, in some MSs 
(Estonia, France, Slovakia) a more structured and systematic involvement of health and 
education  public  authorities  and  of  other  stakeholders  (in  the  fields  of  agriculture, 
environment,  health  and  education)  at  the  planning  and implementation  stages  may  be 
desirable. 

Analysis of school scheme strategies and monitoring data shows that the needs related to 
the two main objectives of the EU school scheme (i.e., increase consumption of selected 
agricultural  products,  promote  healthy  eating  habits  and  shape  healthier  diets)  are 
expressed in the vast majority of strategies and in most strategies, they are priority ranked 
as first, second or third. Results of the PA survey and case study interviews show that the 

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school  scheme  is  perceived  as  most  relevant  in  relation  to  addressing  the  needs  of 
“increasing  the  number  of  schools/children  involved  in  the  school  scheme”,  “increasing 
children consumption of F&V, milk and dairy products in the long run” (thus contributing 
also  towards  recommended  intake),  “promoting  healthy  eating  behaviour”  and  “raising 
awareness of the healthy benefits of F&V and milk consumption, thus suggesting a good 
level of relevance also in relation to the two main school scheme objectives. 

It  should  nevertheless  be  recalled  that  results  of  the  family  survey  presented  in  ESQ2 
suggest that the role played by the scheme in addressing the need to increase F&V and 
milk/dairy consumption is likely to be positive but rather limited. In various instances, CS 
interviews stressed that relevance of the school scheme towards increasing consumption 
of the interested products should indeed be assessed in the long-term. 

Furthermore, it should be pointed out that the school scheme relevance in relation to the 
needs of “increasing children consumption of F&V, milk and dairy products in the long run” 
and of “increasing the number of schools/children involved in the school scheme” can be 
seriously  hindered  by  poor  uptake  in  certain  MS  (e.g.,  France,  Greece,  Portugal  and 
Belgium). 

Based  on the hypothesis that school schemes  providing for higher frequency and longer 
duration of product distribution may be more adequate to address the need of “increasing 
children  consumption  of  F&V  and  milk/dairy  in  the  long  run”,  the  analysis  of  AMR  data 
suggests that the majority of school schemes are adequately addressing this need through 
distribution frequency and exposure. Few MS and regions, characterised by low levels of 
frequency  and  duration  of  product  distribution,  in  particular,  Italy,  the  three  Belgian 
regions, Spain and Croatia for milk, are more at risk of not adequately addressing the need 
of  increasing  children’s  consumption.  Most  school  schemes  that  distribute  F&V  and 
milk/dairy  with  high  frequency  and  duration,  also  distribute  products  with  school  meals 
(i.e., in addition to morning and/or afternoon snack times). By increasing the number of 
occasions for children to consume F&V and milk/dairy such schemes may be regarded as 
more adequately addressing the need of increasing consumption. 

The scheme is perceived by Public Authorities across the EU-27 to be sufficiently adequate 
to  address  the  need  to  “promote  children’s  knowledge  of  food  production  systems  and 
sustainability”, but less adequate with respect to “reducing overweight and obesity rates 
in  children”,  “addressing  the  needs  of  disadvantaged  or  vulnerable  children’s  groups” 
(which is however expressed only by few strategies), “educating children to reduce food 
waste”, “encouraging parents’ participation” and  “promoting the distribution of local and 
regional  agricultural  products”.  Informed  opinions  of  different  stakeholders  (educational 
establishments, providers of AEMs, product suppliers, F&V and milk sector representatives 
and civil society) collected through CS interviews overall confirm these findings.   

One element clearly emerging from interviews in various case study MS and regions (i.e., 
answers  of  various  stakeholders  such  as  product  suppliers,  F&V  and  milk/dairy  sector 
representatives, schools and providers of AEM in Italy, Czechia, Lithuania, Poland, Bavaria, 
North-Rhine  Westphalia)  is  the  important  role  played  by  accompanying  educational 
measures, in particular in relation to the needs of “promoting healthy eating habits” and 
“improving children’s knowledge of food production systems”. 

Further  to  this,  both  PA  survey  and  CS  interviews  very  clearly  indicate  that  the  needs 
identified when planning the strategies are still highly relevant today and suggest that the 
relevance of the EU school scheme may be improved by giving more attention, in particular, 
to environmental and sustainability aspects such as reducing unnecessary plastic, use more 
eco-friendly packaging and recyclable glass bottles for milk, increase support for organic 
products,  short  supply  chains  and  seasonal  products.  Furthermore,  according  to  some 
stakeholders  (health  public  authority  in  Spain  and  dairy  sector  representatives  in  Spain 

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and Bavaria) another issue to be addressed concerns the increased attention to the impact 
of  consumption  of  animal  products  on  the  environment,  which  has  made  it  increasingly 
difficult to implement the milk part of the scheme. 

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4.6  EU added value 

4.6.1  ESQ 12 - What is the additional value resulting from the EU school scheme 
compared to what could have been achieved at Member State level? 

4.6.1.1  Background and methodological approach  

Understanding 

EU added value is defined in the Better Regulation Guidelines as the value resulting from 
an EU intervention which is additional to the value that would have been otherwise created 
by MS action alone. 

Indeed,  the  evaluation  question  asks  to  assess  whether  and  to  what  extent  the  school 
scheme undertaken within the EU framework has contributed to achieving the established 
objectives339 in ways that national or regional schemes alone would not have been able to. 

The assessment of the possible added benefits resulting from the implementation of the 
school scheme at EU level rather than at MS level entails providing answers to the following 
questions: 

  Would the MS be able to implement a similar school fruit, vegetables and milk scheme 
without EU funding? Does EU funding allow for larger-scale national/regional schemes 
involving  more  schools/children/distributed  products  and  including  educational 
measures, which would not be possible with national/regional funding alone? 

  Does  EU  level  implementation  of  the  scheme  provide  an  additional  contribution  to 

reconnecting children to agriculture? 

  Does  EU  level  implementation  translate  into  greater  visibility  and  credibility  of  the 

scheme, also at MS/regional level? 

  Does  EU  level  implementation  promote  exchange  of  knowledge  and  best  practices 
between MS/regions, which would not be possible with school schemes implemented 
at national level? 

  Does  the  scheme  implementation  at  EU  level  provide  an  additional  contribution  to 

stabilising the markets for F&V and milk/dairy? 

  Does  the  scheme  implementation  at  EU  level  provide  an  additional  contribution  to 

meeting consumer expectations? 

It is also important to assess whether the flexibility given to the  MS to adapt the school 
schemes  to  their  own  reality  (in  terms  of  choice  of  children  target  groups,  choice  of 
products and models of distribution, etc.) supports the creation of EU added value. 

Most national and regional school scheme strategies allocate national financial resources 
in addition to Union aid340 and three MS implement national school schemes in addition to 
their participation in the EU school scheme: Ireland, Finland and Portugal (and the UK until 
2020). Finland refers to the provision of free school meals as a national school scheme. 
Free school meals are also provided in Sweden but they are not considered as a national 
school scheme.  At regional level, only the German federal state of Hessen has a regional 
school scheme in place. For these MS/regions, an additional issue relevant for the analysis 

339 Including the two main objectives set out in Regulation EU No 1308/2013, art.22 (improve the distribution of 
agricultural  products  and  improve  children's  eating  habits)  and  the  objectives  mostly  shared  by  national  and 
regional school scheme strategies, such as promoting greater consumption of F&V, milk and dairy by children 
and  adolescents,  encouraging  healthy  eating  habits,  increasing  children’s  awareness  of  the  benefits  of  eating 
healthily,  improving  children’s  knowledge  of  agricultural  production  including  variety,  seasonality,  quality 
products, sustainable production for the environment and the importance of reducing food waste, etc. (see  3.2.1). 

340 Greece, France, Italy, Cyprus, Portugal, Finland, Sweden and the German Laender of Bremen and Hessen do 
not include national payments. 

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concerns  the  existence  of  complementarity,  and/or  perhaps  synergies,  between  the  EU 
school scheme and national/regional initiatives. 

Judgement criteria, indicators and sources 

The  answer  to  the  evaluation  question  is  based  on  the  following  judgement  criteria  and 
indicators.  

Judgement criteria 

Indicators 

Sources 

121.1  Judgement  of  PAs  on  the 
school scheme EU added value  

12.1.2 Informed opinions of public 
authorities  and  EU  stakeholders 
on  the  school  scheme  EU  added 
value  

-  Public 
survey 

Authorities 

-  Structured  interviews 

in CS MS/regions 

- 

JC12.1:  The  implementation  of  the  school 
scheme  at  EU  level  has  (has  not)  allowed  to 
create additional value compared to the value 
that would have been otherwise created by MS 
action alone, by: 

-  Reaching a larger number of children and 
the  school 

from 

schools  benefitting 
scheme 
-  Distributing 

larger  product  quantities, 
more frequently and with longer duration 
Increasing 
the  variety  of  products 
distributed 

- 

-  Financing  a  larger  number  of  educational 

activities 

-  Ensuring  better  visibility  of  the  school 

scheme 
-  Generating 

a  better 

of 
knowledge  and  best  practices  among  the 
MS/regions 

exchange 

-  Providing 

-  Providing 

additional 

contribution 

to 
stabilising the F&V and milk/dairy markets 
to 
meeting consumer expectations by raising 
consumer  awareness  of  the  benefits  of  a 
healthy diet 

contribution 

additional 

-  Providing 

additional 
reconnecting children to agriculture 

contribution 

to 

JC12.2:  The  implementation  of  national  or 
regional school schemes in addition to the EU 
school  scheme  and/or  inclusion  of  additional 
national  payments  in  the  EU  scheme,  have 
(have  not)  favoured  complementarity  and/or 
synergies with the EU school scheme 

12.2.1  Share  of  national  aid/ 
Union  aid  expenditure  across  MS 
in  the  school  years  2017/18  to 
2020/21 
12.2.2  Judgement  of  PAs  on 
complementarity/synergies 
between  EU  school  scheme  and 
national schemes and national aid  

-  EU 

school 

scheme 
monitoring 
annual 
reports 
2017/18, 
2018/19, 2019/20 and 
2020/21 

-  Public 
survey 

Authorities 

Methodological approach and its limitations  

Tools, method and sources used 

The analysis is carried out at two levels mostly based on primary data collected through: 

 
 

survey of Public Authorities at EU-27 level; 
structured  interviews  to  public  authorities  and  other  stakeholders  in  12  case  study 
MS/regions. 

Results of the PA survey are presented through statistical indicators (see following analysis 
under  Judgement  Criteria  12.1  and  12.2).  Case  studies  provided  an  opportunity  to 
investigate in more depth the views of different groups of stakeholders.  

The  analysis  under  the  second  Judgement  Criterion  also  uses  annual  monitoring  report 
data on national aid and Union aid expenditure over the time interval under analysis.  

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Limitations of methods and sources 

One  limitation  lies  in  the  possible  response  bias  of  school  scheme  managing  authorities 
answering the PA survey. Surveyed PAs are responsible for the planning the school scheme 
strategies  notified  to  the  Commission  and  for  scheme  implementation  and  it  cannot  be 
excluded that “desirable” answers were provided to some extent.  

Judgement  Criterion  12.1:  The  implementation  of  the  school  scheme  at  EU 
level has (has not) allowed to create additional value compared to the value 
that would have been otherwise created by Member State action alone 

PA survey respondents were asked to indicate the extent to which they agree with a series 
of statements describing different added benefits of applying the school scheme at EU level 
rather than at national or regional level. For each given statement responses were collected 
on  a  scale  ranging  from  “-2=completely  disagree”  to  “2=completely  agree”.  A  synthetic 
indicator (average) was calculated for each statement across all respondents341. 

Figure 25 : Opinion of school scheme MA about the benefits of implementing the school 
scheme at EU level rather than at national/regional level alone 

Values: -2=completely disagree: -1=somewhat disagree; 0=neither agree nor disagree/No answer; 1=somewhat 
agree; 2=completely agree 

Source: own elaboration of PA survey data 

According to survey respondents, a school scheme implemented at EU level creates added 
value mostly (i.e., highest scores recorded) in terms of allowing to include a larger number 
of  schools/children  and  to  distribute  larger  product  quantities  than  it  would  have  been 
possible  with  a  national  or  regional  scheme  alone.  This  suggests  that  implementing  the 
school scheme at EU level should be more effective in attaining the objective of increasing 
children consumption of selected agricultural products. Respondents also agree to a slightly 
smaller extent that the school scheme implemented at EU level rather than at national or 
regional  level  provides  additional  value  in  terms  of  better  visibility  of  the  scheme,  of 
contributing to reconnect children with the agricultural sector, of financing a larger number 
of  educational  measures  and  of  generating  a  better  exchange  of  knowledge  and  best 

341 37 respondents out of 37 answered all items of this question in the PA survey. 

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practices  between  MS/regions  and  also  meeting  consumer  expectations  by  raising 
awareness of the benefits of eating healthily. 

On  the  other  hand,  again  according  to  PA  survey  responses,  EU  implementation  of  the 
school  scheme  is  perceived  as  adding  value  only  to  a  very  limited  extent  in  terms  of 
“increasing the range of products than can be distributed to school children” and in terms 
of “providing additional contribution to F&V and milk/dairy markets’ stability”. As shown in 
the previous graph, the average score across all survey respondents for these two items 
(respectively  0.41  and  0.76)  is  between  “0=neither  agree  nor  disagree/No  answer”  and 
“1=somewhat agree”.   

Further insights emerge from interviews in case study MS and regions. First of all, there is 
wide consensus among public authorities involved in the school scheme implementation, 
sector representatives and national paying agencies that the main added value of the EU 
school scheme is in the possibility of reaching more schools and children than it would be 
possible with national programmes alone. Most interviewees across case study MS/regions 
agree in fact that EU financial support is key to having a school scheme in place (Czechia, 
Italy, Lithuania, the Netherlands, Poland, Romania and North-Rhine Westphalia).  

It is also recognised by interviewed public authorities that a common system of objectives, 
rules,  procedures  and  controls  at  EU  level  improves  the  effectiveness  of  the  scheme 
implementation (Czechia, Italy, France, Poland) and also makes monitoring and evaluation 
activities  more  robust  and  reliable  (Poland).  On  the  other  hand,  some  stakeholders 
perceive  that  a  scheme  implemented  at  national  level  would  reduce  the  administrative 
burden for the involved educational establishments (Lithuania, Portugal and Romania342). 
The flexibility given to the MS to adapt the school scheme to their needs is generally seen 
as a positive element. Only the managing authorities of the scheme in France and Lithuania 
feel  that  even  more  flexibility  could  be  given  to  the  individual  MS  to  improve  the 
performance of their schemes. For instance, in Lithuania, the scheme managing authority 
as well as schools’ and civil society representatives believe that greater flexibility given to 
the MS may allow to simplify procedures at the local level for schools and suppliers, thus 
reducing the administrative burden. The Netherlands complained about the lengthy process 
involved when making changes to the EU scheme strategy343. 

EU  level  implementation  of  the  school  scheme  is  perceived  in  most  case  study  MS  and 
regions as creating synergies  with respect to the possibility of  communicating the same 
health and nutrition messages to children across the EU MS. In France, Italy, Bavaria and 
Poland, it is opinion of different stakeholders that the EU school scheme is very important 
because it is one of the few common health and nutrition policy instruments applied in the 
same way across all MS that can reach beyond what is done at national level. 

Implementation at EU level is thought as having the potential to achieve better visibility 
for the school scheme compared to implementation at national or regional level. However, 
in  most  cases  better  visibility  has  not  been  achieved  due  to  poor  communication,  in 
particular  towards  schools  and  families  (Czechia,  France,  the  Netherlands,  Portugal, 
Romania,  Bavaria,  North-Rhine  Westphalia)  and  sometimes  also  towards  the  interested 
agricultural  sectors  and  the  potential  product  suppliers  (France).  In  Italy,  the  school 
scheme is regarded as having good visibility at the national level, but more could be done 
to  create  a  collective  public  image  for  it,  which  could  also  bring  citizens  closer  to  EU 
institutions. Some interviewees report that, being an initiative organised at EU level, the 
school scheme acquires in the eyes of many a certain official status and legitimacy (Italy, 

342  However,  in  Portugal  and  Romania  sector  and  school  representatives  indicate  that  it  is  not  clear  to  them 
whether administrative burden is due to the EU scheme or rather to legislative requirements at national level. 
343  The  comment  by  Steunpunt  representative  refers  to  the  long  time  it  took  to  introduce  in  the  strategy  the 
possibility to distribute organic F&V in the Dutch school scheme. 

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France).  Opinion  is  that  this  aspect  deserves  more  attention  as  it  goes  beyond  the 
credibility of the school scheme and that a policy instrument developed and implemented 
at European level has a different appeal and significance “as it can makes us feel European 
citizens”. In the opinion of a Lithuanian sector representative, the scheme at EU level holds 
higher credibility than a national one and could consequently have an impact also on the 
interested  F&V  and  dairy  markets,  in  terms  of  increasing  consumption  of  selected 
agricultural products (F&V and milk/products) and contributing to maintain market stability 
for the same products (see logic of intervention in 2.2.2). 

In terms of exchange of knowledge and best practices, most interviewed stakeholders feel 
that there is not enough space provided at EU level for exchange among the MS, in spite 
of the recognised usefulness of the regular meetings organised by the Commission. Such 
meetings mostly focus on budget, the legal framework and monitoring, but could be used 
more effectively to share experiences, practices and lessons learned (public authorities and 
providers of AEMs in Czechia and Italy, school representatives in Lithuania). This view is 
indeed supported by the findings of the ongoing “Review of the EU school fruit, vegetables 
and milk scheme” conducted by the Department of Nutrition at the University of Oslo344. 
Sharing of experience and practices is done to some extent among schools within national 
boundaries (Germany, Lithuania), but only the Dutch school scheme managing authority 
reported  that  they  had  specific  collaboration  with  France  to  exchange  respective 
experiences.  

The  managing  authority  of  the  French  scheme  carried  out  a  benchmark  analysis  (upon 
suggestion of a F&V sector union) on the implementation of the school scheme in other 
MS, aimed at understanding why the school scheme in France does not work as well as it 
should and what could be done to improve it. The main recommendations emerging from 
this analysis indicate that 1) communication should be improved, 2) the schools should be 
put  at  the  centre  of  the  scheme  and,  at  the  same  time,  3)  the  administrative  burden 
associated  with  admin  procedures  required  to  apply  to  participate  in  the  school  scheme 
should be taken off the schools and shifted more to product suppliers. 

The managing authority of the Italian school scheme reported that it would be very useful 
to  organise  “Info  days”  or  similar  initiatives  in  Brussels  in  which  also  stakeholder 
representatives  can  participate,  beyond  the  Committees  focussing  on  the  legislation 
framework and on monitoring activities, in order to learn from other countries.  

Judgement Criterion 12.2: The implementation of national or regional school 
schemes in addition to the EU school scheme and/or inclusion of additional 
national  payments 
favoured 
complementarity and/or synergies with the EU school scheme  

in  the  EU  scheme,  have  (have  not) 

The  analysis  under  this  judgement  criterion  is  based  on  data  collected  through  the  PA 
survey (please see 4.5.1.1 for an overview of the MS/regions that allocate national financial 
resources in addition to Union aid and of the MS implementing national school schemes).  

Survey  respondents  were  asked  to  indicate  the  extent  to  which  additional  national 
payments  (in  the  MS/regions  where  they  are  foreseen  in  the  school  schemes)  have 
complemented Union aid with respect to different aspects of the school scheme (product 
distribution, provision of educational measures, provision of information, etc.). Responses 
were collected on a scale ranging from “0=not at all” to “3=to a great extent”. A synthetic 
indicator (average) for each statement was calculated across all respondents. 

As  shown  in  the  graph  below,  the  results  of  the  survey  suggest  that  national  payments 
have complemented Union aid only to a limited extent, albeit slightly better with respect 

344 See reference in previous section 6.2.1. 

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to providing additional educational activities for school children, to distributing products to 
a larger number of schools and to distributing additional products.  

Figure 26 : Opinion of school scheme managing authorities about the extent to which 
national aid has complemented the Union aid 

Values: 0= not at all; 1= very little; 2= somewhat; 3= to a great extent 
Source: own elaboration of PA survey data 

Annual  monitoring  data  show  that  over  the  first  four  years  of  the  scheme  (2017/18  to 
2020/21), national aid expenditure accounted for an overall 69.2% of Union aid across the 
EU  28  (including  the  UK  until  end  2020).  This  share  increases  to  93.4%  if  only  the 
MS/regions using additional national resources are considered (see 7.1.1). Therefore, the 
judgement  given  by  survey  respondents  about  the  extent  to  which  national  aid 
complements Union aid does not appear to reflect the reality. One possible explanation of 
this result is in the fact that not all MS participating in the survey answered this particular 
question345 and that responses are missing, in particular, from some of the MS that make 
substantial use of national aid to finance product distribution and/or educational measures, 
namely Denmark, Latvia, Hungary, Austria, Slovakia, Slovenia and also Spain (in addition 
to the UK that did not answer the survey at all, as already reported). 

The questionnaire to Public Authorities included also a question for those MS and regions 
implementing a national school scheme in addition to the  EU scheme: Ireland, Portugal, 
Finland, the UK346 and the German federal state of Hessen, aimed at assessing the extent 
to which there are complementarity and/or synergies between national and EU schemes. 

Only Ireland, Finland and Portugal provided a response to this question347. The managing 
authority of the Irish school scheme completely agrees that the national and the EU scheme 
are  complementary,  as  “the  EU  school  scheme  has  enabled  us  to  expand  our  existing 
National Schemes to reach a greater number of pupils and develop a more comprehensive 
programme” and there is also synergy in that Ireland has purposely adapted the national 

345 The number of responses for the six items of this question varies from 13 to 20, which is low if considering 
that 37 completed questionnaires were returned. 
346  As previously  indicated,  it  was  not  possible  to  collect  data  for  the  UK  as  they  did  not participate  in  the PA 
survey.  However,  the  national  school  schemes  continue  to  be  implemented  after  Brexit.  The  School  Fruit  and 
Vegetables Scheme (SFVS) established since 2000 and targeted to 4 to 6 years old children has been resumed 
pandemic 
after 
(https://www.schoolfoodmatters.org/news-views/news/school-fruit-and-vegetable-scheme-resume). 
The 
national  School  Milk Scheme will  be funded  until  at  least  2022 despite  the  UK’s  departure from  the  European 
Union (https://www.cypnow.co.uk/news/article/school-milk-scheme-funded-until-2022). 
347 No response was given to this question by the managing authority of Hessen’s school scheme and the UK did 
not participate in the survey, as previously mentioned. 

suspended 

Covid-19 

briefly 

March 

being 

2020 

due 

the 

to 

in 

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scheme  to  fit  within  the  objectives  of  the  EU  school  scheme348.  A  certain  degree  of 
complementarity  is  also  reported  by  Finland,  where  the  EU  scheme  has  allowed  wider 
distribution of organic milk and F&V and added product variety to the national scheme (it 
should be recalled that what Finland refers to as a national school scheme, actually is the 
distribution of free school lunches). No conclusions can be drawn for Portugal as comments 
were  not  provided  by  the  managing  authority  of  the  scheme,  who  only  gave  a  neutral 
response  regarding  existing  complementarity  or  synergies  with  the  national  scheme 
(which, in any case, includes only milk distribution). 

4.6.1.2  Conclusions  

The  evaluation  question  asks  to  evaluate  to  what  extent  the  school  scheme  undertaken 
within  the  EU  framework  has  contributed  to  achieving  the  set  objectives  in  ways  that 
national or regional schemes alone would not have been able to. 

According to PA survey respondents, school scheme implementation at EU level generates 
added  value  mostly  in  terms  of  allowing  MS/regions  to  reach  a  larger  number  of 
schools/children and to distribute larger product quantities than it would be possible with 
national or regional schemes alone. This suggests that EU implementation should be more 
effective  in  attaining  the  objective  of  increasing  children  consumption  of  selected 
agricultural  products.  To  a  smaller  extent,  EU  implementation  provides  additional  value 
also in terms of better visibility, of contributing to reconnect children with the agricultural 
sector,  of  financing  a  larger  number  of  educational  measures,  of  generating  a  better 
exchange of knowledge and best practices between MS/regions and in meeting consumer 
expectations by raising awareness of the benefits of eating healthily. 

Information collected through case study interviews partly supports survey results. There 
certainly is overall agreement that the main added value of the EU school scheme is in the 
opportunity of reaching more schools and children. EU level implementation of the scheme 
is  perceived  in  most  case  study  MS/regions  as  creating  synergies  with  respect  to  the 
opportunity of communicating the same health and nutrition messages to children across 
MS. 

Opinions  of  interviewed  public  authorities  and  stakeholders  somewhat  diverge  from  PA 
survey  results  in  respect  of  the  EU  school  scheme  allowing  better  visibility  and  better 
exchange of knowledge and practices. In spite of EU implementation having the potential 
to  achieve  better  visibility  for  the  school  scheme,  in  most  cases  better  visibility  has  not 
been  accomplished  due  to  poor  communication,  in  particular  at  national  level  towards 
schools and families (Czechia, France, the Netherlands, Portugal, Romania, Bavaria, North-
Rhine  Westphalia)  and  sometimes  also  towards  the  interested  agricultural  sectors  and 
potential product suppliers (France). At EU level, better visibility of the scheme could be 
achieved  by  providing  more  opportunities  for  the  different  stakeholders  to  exchange 
experiences, lessons learned and best practices. In the eyes of public authorities, school 
representatives  and  providers  of  accompanying  educational  measures  in  some  MS 
(Czechia, Italy, Lithuania) meetings or “info days” organised by the European Commission 
could  be  effectively  used  to  this  purpose.  Public  authorities  recognise  that  a  common 
system of objectives, rules, procedures and controls at EU level improves the effectiveness 

348 In Ireland, funding under the EU F&V part of the scheme has been used to extend the scope of the National 
Food Dudes Programme. The EU school milk scheme also partly supports two national schemes: the statutory 
Urban School Meals Scheme for primary schools (around 330 schools) operated by Local Authorities and part-
financed by the Department of Social Protection; a non-statutory School Meals Local Projects Scheme under which 
the Department of Social Protection provides funding directly to primary and secondary schools, local groups and 
voluntary organisations which operate their own school meals projects. Priority is currently given to schools which 
are  part  of  the  Department  of  Education  &  Skills’  initiative  for  disadvantaged  schools,  ‘Delivering  Equality  of 
Opportunity in Schools’ (DEIS). 

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of the scheme implementation (Czechia, Italy, France, Poland). The flexibility given to the 
MS to adapt the school scheme to their needs is also generally seen as a positive element.  

Results of the PA survey suggest that national payments have complemented  Union aid 
but  only  to  a  limited  extent,  albeit  slightly  better  with  respect  to  providing  additional 
educational  activities  for  school  children,  to  distributing  products  to  a  larger  number  of 
schools and to distributing additional products. However, PA opinions collected through the 
survey  do  not  seem  to  be  consistent  with  expenditure  figures,  which  show  high  overall 
share of national payments over Union aid in the first four years of the school scheme. 

As  far  as  national  schemes  are  concerned,  the  results  of  the  PA  survey  indicate  that 
certainly in Ireland and to some extent in Finland, national and EU schemes complement 
each other. 

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5  OVERALL CONCLUSIONS 

The aim of this evaluation was to assess the EU school fruit, vegetables and milk scheme 
set  out  in  Regulation (EU) N 1308/2013.  The  current  EU  school  scheme  unifies  under  a 
single common legal and financial framework the two previous schemes operating for fruit 
and vegetables (from 2009) and for milk (from 1977).  

Article 168 of the TFEU establishes that EU policies should ensure, in their definition and 
implementation, a high level of human health protection. Good nutrition is one of the key 
factors  for good health, in general, and in  particular for  children. Children having (pre-) 
obesity  are  exposed  to  a  higher  risk  of  serious  health  problems  and  incidence  of  non-
communicable  diseases.  In  a  context  of  increasing  overweight  and  obesity  rates  among 
children, the EU school scheme has its own specific objectives: 

  promote a durable increase of the consumption of fruit, vegetables and milk and milk 
products, that should replace the consumption of energy dense, processed foods high 
in added/free sugars, fat, saturated fat and sodium (salt); 
improve children’s healthy eating habits: the  EU school scheme should contribute to 
improve nutrition and to shape healthier diets.  

 

The scheme supports the distribution of selected agricultural products to schoolchildren, 
from nursery to secondary school and accompanying educational measures on agriculture 
and good nutrition. The implementation of the EU school scheme is characterised by a high 
degree of subsidiarity and MS wishing to participate in the scheme, design and notify to 
the European Commission a six-years strategy, at national or regional level.  

The  evaluation  support  study  answers  12  evaluation  questions  grouped  under  six 
evaluation criteria: causal analysis, effectiveness, efficiency, coherence, relevance, and EU 
added value. 

The geographical scope of the analysis is EU27 and the United Kingdom that implemented 
the  scheme  until  December  2020.  The  evaluation  covers  the  period  from  August  2017, 
date  of  entry  into  force  of  the  scheme,  for  four  school  years  (from  2017/2018  to 
2020/2021). Longer observation periods were taken into account according to the needs 
of the analysis.  

Before illustrating the main findings, it is important to recall the following elements: 

 

the  period  of  analysis  of  the  effects  of  the  scheme  is  rather  short  and  it  has  been 
strongly affected by the onset of the Covid-19 pandemic since spring 2020; 

  besides  this  exceptional  event,  the  execution  of  the  definitive  financial  allocation  for 
the  whole  EU  over  the  four  years  of  implementation  of  the  scheme  is  around  70% 
(EUR 693.5 million out of EUR 995.1 million, which entails EUR 301.6 million budgeted 
in  the  EU  budget  but  lost)  and  it  varies  considerably  across  MS  ranging  between  a 
minimum of 7.4% in France and a maximum of 100% in Estonia and Latvia. 

In the following sections the overall conclusions and recommendations of the evaluation 
support study are presented.  

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5.1  Effects of the EU school scheme with respect to its objectives 

Effects of the scheme on children’s consumption and on children’s healthy eating 
habits 

THE  EFFECTS  OF  THE  EU  SCHOOL  SCHEME  ON  CHILDREN’S  CONSUMPTION  AT  SCHOOL  OF  THE 
DISTRIBUTED  PRODUCTS  IN  THE  FOUR  YEARS  OF  IMPLEMENTATION  HAVE  BEEN  SEVERELY 
INFLUENCED  BY  THE  COVID-19  PANDEMIC’S  OUTBREAK  IN  MARCH  2020.  THE  DIFFERENCES 
OBSERVED AMONG MS ARE MAINLY THE RESULT OF THE CONTROL MEASURES AND PUBLIC HEALTH 
POLICIES DEPLOYED BY NATIONAL GOVERNMENTS TO FACE THE PANDEMIC.  

The decrease of the overall number of pupils involved in the school scheme at EU-27 level 
(dropped  from 18.6 to  16.0 million between  2017/2018 and 2020/2021,  -14.2%) is the 
effect of differentiated patterns at MS level. The size of the changes (in %) of each MS is 
to a large extent (although not exclusively) linked the control measures and public health 
policies  deployed  by  national  governments  in  order  to  limit  the  spread  of  COVID-19 
pandemic: some MS (i.e., Italy, France) imposed severe lockdowns and distance learning 
for long and/or short periods of time; other MS (i.e., Sweden) kept schools open. 

IN GENERAL, OVER TIME, THERE IS AN INCREASE OF THE IMPORTANCE OF THE F&V PART OF THE 
SCHEME COMPARED TO THE MILK PART. 

Taking into account some limitations mainly related to the availability of data at MS level 349, 
differences were observed between the two parts of the EU school scheme: concerning the 
milk part, Covid-19 accentuated an already ongoing decline in the number of schoolchildren 
participating in the scheme that had stated in the previous years. Concerning the F&V part, 
data show an increase of the number of pupils in the first years of implementation of the 
current scheme compared to the previous F&V scheme. However, this increase has been 
interrupted  by  the  onset  of  Covid-19  pandemic  that  caused,  in  the  following  years,  a 
decrease of the number of children participating in the F&V part of the scheme. 

Moreover, if we consider the whole period (2017/18-2020/21), the decrease in the number 
of  children involved in the milk part of the scheme is stronger than the decrease in the 
number of children involved in the F&V part. Besides Covid emergency, the analysis of the 
monitoring  data  shows  a  progressively  decreasing interest  of  some  MS  (namely  France, 
Italy and Poland) towards the milk part of the EU school scheme. 

AN  INCREASING  NUMBER  OF  CHILDREN  THAT  PARTICIPATE  IN  THE  EU  SCHOOL  SCHEME  IS 
BENEFITING FROM A MORE VARIED SUPPLY OF PRODUCTS. 

The share  of  children receiving only  fruit and vegetables or only milk and milk products 
has  significantly  decreased  over  time,  while  the  percentage  of  children  receiving  both 
categories  of  products  has  increased  (more  than  12%).  Thus,  an  increasing  number  of 
children is benefiting from a more varied and complete range of products. 

Moreover,  the  variety  of  the  products  distributed  under  the  current  EU  scheme  has 
increased  compared  to  the  previous  EU  schemes,  although  the  number  of  products 
distributed during the current EU school scheme has, overall, decreased over the four-year 
implementation period. 

DISTRIBUTED  QUANTITIES  OF  THE  SELECTED  PRODUCTS  ARE  LINKED  TO  THE  DECREASE  IN  THE 
NUMBER OF CHILDREN INVOLVED IN THE EU SCHOOL SCHEME, IN PARTICULAR FOR THE MILK PART 
OF THE SCHEME. 

Total  distributed  quantities  of  fruit  and  vegetables  decreased  by  about  22%  between 
2017/18 and 2020/21 (after an increase of 3.7% between the first and the second year of 
the current scheme), while total milk quantities decreased by about 38% and constantly 
throughout  the  analysed  period.  The  evolution  of  quantities  distributed  in  schools  is 

349 E.g., In the monitoring system data related to the number of children involved distinguished for each part of 
the scheme is not mandatory. Therefore, not all MS provide it and/or provide it occasionally. 

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strongly  explained  by  the  evolution  of  the  number  of  children  involved  in  the  scheme, 
especially in the case of milk (less for F&V). Other causes that  contribute to explain the 
decrease are the national decisions regarding the increase or decrease of i) the frequency 
of distribution (number of portions per week), ii) the duration of the distribution (number 
of  days/weeks  per  schoolyear),  iii)  the  average  portion  size,  iv)  the  composition  of  the 
products distributed. These elements, as well, have been influenced by the difficulties in 
the supply of the selected products for distribution caused by the COVID-19 crisis.  

HOWEVER, THE DECREASE OF DISTRIBUTED QUANTITIES IS HIGHER THAN THE DECREASE OF THE 
NUMBER  OF  CHILDREN.  ACCORDINGLY,  THE  DISTRIBUTED  QUANTITIES  PER  CHILD  DECREASED 
DURING THE PERIOD 2017/2018-2020/2021. 

Concerning fruit and vegetables, the average amount distributed per child350 passed from 
7.3 kg in 2017/18 to 6.2 kg in 2020/21, showing a 21% decrease (-9.6% between 2017/18 
and 2018/2019). In the case of F&V, the amount distributed per capita in the first year of 
implementation of the scheme is higher than the average amount distributed per capita in 
the  previous  period  (the  current  scheme  had  a  positive  impact  compared  to  the  old 
scheme), but in the following years it has been affected by the pandemic. 

Concerning  milk  and  milk  products,  the  average  quantities  distributed  per  capita351  fell 
from 17.1 litres in 2017/2018 to 12.2 litres in 2020/21, showing a 28.9% decrease (-9.7% 
between  2017/2018  and  2018/2019).  In  the  case  of  milk,  this  decrease  is  part  of  an 
ongoing evolution started in previous period. 

IN  ADDITION,  CHILDREN’S  ACTUAL  DIRECT  CONSUMPTION  OF  THE  PRODUCTS  DISTRIBUTED  AT 
SCHOOL IS LOWER RELATIVE TO DISTRIBUTED QUANTITIES.  

The results of the family survey, confirmed by interviews carried out in case studies MS, 
showed  that  the  products  delivered  at  school  are  not  always  consumed  by  children 
(especially fruits and vegetables)352. Taste, availability of snacks brought from home and 
lack of time are the main reasons for this phenomenon. Usually, unconsumed products are 
taken home or stored and redistributed the next day at school. In less frequent cases, they 
are recycled as compost. 

THE EU SCHOOL SCHEME HAS HAD A LIMITED EFFECT  ON POSITIVELY INFLUENCING CHILDREN'S 
ATTITUDE TOWARDS FRUITS, VEGETABLES AND MILK PRODUCTS. 

The analysis based on the family survey highlights that as result of the lessons learnt at 
school, a limited share of around 10% (on average) of the children involved in the scheme 
show a more positive attitude towards fruit and vegetables and milk/milk products (i.e., 
children  ask  to  eat  F&V/  to  drink  milk  and  children  eat/drink  fruit  and  vegetables  and 
milk/milk products more willingly). 

Moreover, the analysis shows that the notions learnt at school (especially those related to 
“importance of eating fruit and vegetables daily” and “fruit and vegetables and milk/milk 
products are healthy”) are judged very positively by the majority of the surveyed families 
of the children participating in the scheme.  Besides, according to the  surveyed  families, 
children ask that the rules learnt at school are also adopted at home. However, for 37% of 
the surveyed families (mostly with higher levels of education) the notions taught at school 
were already part of the cultural background, and therefore already adopted at home. For 
these families, the scheme may have helped to consolidate attitudes and behaviour that 
were already usual within the family.  

350 In raw material equivalent. 
351 In raw material equivalent. 
352 Children “often” or “sometimes” do not eat the products distributed at school: for 66% of the 3 306 families 
having  answered  to  the  question  in  the  case  of  F&V;  for  52%  of  the  2  914  families  having  answered  to  the 
question for milk/milk products. 

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THE CHANGE IN ATTITUDE CAUSED BY THE SCHEME SEEMS TO HAVE HAD AN IMPACT ON CHILDREN’S’ 
BEHAVIOUR BY ENCOURAGING AN INCREASE IN INDIRECT CONSUMPTION IN TERMS OF QUANTITY 

AND FREQUENCY AND BY LIMITING THE DECLINE OF CONSUMPTION THAT WOULD HAVE OCCURRED 
IN THE ABSENCE OF PARTICIPATION IN THE EU SCHOOL SCHEME. HOWEVER, THESE EFFECTS HAVE 
BEEN OBSERVED FOR A LIMITED SHARE OF CHILDREN.  

The analysis based on the family survey shows that the increase in consumption outside 
school (indirect consumption) concerns a limited share of the children participating in the 
scheme,  both  in  terms  of  quantity  and  in  terms  of  frequency:  between  3%  and  5%  for 
F&V, depending on the products; between 6% and 8% for milk, depending on the products. 
Moreover,  for  a  further  1%  to  3%  of  children  the  change  in  attitude  favoured  the 
preservation of habitual consumption (preventing its decline). The best results are obtained 
in  the  case  of  families  with  a  lower  level  of  education  and  predominantly  living  in  rural 
areas. 

The family survey results also highlight that the increase of consumed quantities is mainly 
due to an increase in the frequency of consumption (increase of the number of portions). 
However,  for  all  F&V  products  and  for  drinking  milk,  the  quantity  of  single  portions 
decreases  with  increasing  frequency  (more  portions,  but  smaller),  while  for  other  milk 
products the quantity of the single portions remains roughly the same with the increase of 
frequency. 

THE IMPLEMENTATION OF THE EU SCHOOL SCHEME SEEMS TO HAVE FAVOURED TO A LIMITED AND 
DIFFERENTIATED  EXTENT  THE  REDUCTION  OF  CONSUMPTION  OF  FOODS/DRINKS  WITH  HIGH 
CONTENT IN FAT, SALT AND ADDED SUGAR. 

Regarding  the  change  of  children's  consumption  patterns  into  healthy  eating  habits 
(reduction  of  the  consumption  of  foods/drinks  with  high  content  in  fat,  salt  and  added 
sugar) the results are uneven: the difference between the results obtained by the children 
participating in the school scheme and by the children not participating in the scheme is 
positive both in the case of a decrease of the consumption of foods/drinks with high content 
in fat, salt and added sugar (10%) and in the case of an increase of the consumption of 
these products (2%)353. 

Effects of the implementation choices related to the allocation of Union aid to the 
MS  and  transfers  of  Union  aid  between  school  fruit  and  vegetables  and  school 
milk  

THE  AGE  TARGET  OF  THE  EU  SCHOOL  SCHEME CAN  ENSURE THE  CONSUMPTION  OF  FRUIT  AND 
VEGETABLES  AND  OF  MILK  AND  MILK  PRODUCTS,  WITH  A  VIEW  TO  DURABLY  INCREASING  THE 
SHARE OF THOSE PRODUCTS. 

The results of the analysis highlight that in the period under analysis, most of the children 
participating in the EU school scheme belong to the six to ten-year-old age group (average 
of 71% over the first 4 school years). Although not focusing on objectives related to viable 
food production, it can be considered that the target group “six to ten-year-old children” 
is the one with the higher potential to contribute to an increased and durable consumption, 
therefore, contributing to the viable food production objectives, particularly, by stabilising 
markets  and  ensuring  the  availability  of  both  current  and  future  supplies,  therefore, 
positively  influencing  the  agricultural  sector  (in  general,  to  maintain  the  demand  of  the 
agricultural products, at least, those distributed by the EU school scheme). 

Notwithstanding, the establishment of a share of fruit and vegetables and milk and milk 
products  in  diets  corresponding  to  daily  needs,  demands  a  long-term  ‘involvement’ of 

353 In other words, for 2% of the cases, the number of children participating in the scheme  that increased the 
consumption of foods/drinks with high content in fat, salt and added sugar is higher than the number of children 
not participating in the scheme and having increased the consumption of these products. Therefore, the results 
indicate an unintended effect. 

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children  and  a  more  prolonged  and  systematic  distribution  of  such  products  across  age 
groups.  

ACCOMPANYING  EDUCATIONAL  MEASURES PLAY  A  CRUCIAL  ROLE  IN  MAINTAINING/INCREASING 
FRUIT AND VEGETABLES AND MILK CONSUMPTION. 

However,  better  results  might  be  attained  with accompanying  educational  measures 
adapted  to  age  groups  and  involving  not  only  schoolchildren  but  also  teachers,  other 
educational professionals and parents/families. In this respect, the analysis suggests that, 
in fact, maintaining/increasing fruit and vegetables and milk consumption depends, mostly, 
on food education provided by parents / families and also on more consistent and frequent 
use of accompanying educational measures covering all age groups.   

THE POSSIBILITY OF TRANSFERS OF UNION AID BETWEEN THE F&V PART OF THE EU SCHEME AND 
THE  MILK  PART  WAS  USED  BY  A  LIMITED  NUMBER  OF  MS  OVER  THE  FOUR  YEARS  OF 
IMPLEMENTATION  OF  THE  SCHOOL  SCHEME  (IN  TOTAL  14  MS).  HOWEVER,  IN  MOST  CASES 
AMOUNTS TRANSFERRED ARE NOT FULLY USED. 

Most of the MS having used the possibility of transfers, transferred amounts from the milk 
part to the F&V part of the EU school scheme to cope, presumably, with the increase in the 
number of children participating in the fruit and vegetables part of the EU school scheme 
that  goes  in  parallel  with  a  decrease  of  the  number  of  children  participating  in  the  milk 
part. The transfers from the F&V part to the milk part have been made only by four MS but 
the amounts transferred are higher. Nevertheless, in almost all cases amounts transferred, 
have been used only partially or not used at all and therefore have not contributed to the 
objectives of the EU school scheme of increasing the distribution of F&V and milk and milk 
products to children 

5.2  Cost effectiveness of the EU school scheme  

RECORDED UNITARY COSTS OF THE DISTRIBUTED PRODUCTS APPEAR FAIR. 

Unitary costs based on annual monitoring report data (per quantity of distributed products 
and per child served) are in broad terms comparable to market prices recorded in the years 
under analysis. Much less information is available for the costs regarding provision of AEMs. 

SPECIFIC REQUIREMENTS AFFECT ACTUAL DISTRIBUTION COSTS. 

In  particular,  costs  of  organic  products  affect  total  distribution  costs.  Additionally,  the 
distribution of these products is limited in cases where local or regional production is not 
sufficient  to  cover  the  demand.  Moreover,  requirements  such  as  size,  sorting  and 
packaging of the portions also influence distribution costs because they require additional 
work along the logistics and distribution chain. In general, there is a trade-off between the 
objective  of  serving  special  areas  and/or  groups  (e.g.,  schools  located  in  remote  areas, 
children with specific needs, etc), and the objective of reducing distribution costs.  

HIDDEN COSTS (I.E. ADMINISTRATIVE COSTS) MAY HAMPER THE PARTICIPATION IN THE SCHEME 
BY SUPPLIERS. 

Our analysis shows that among suppliers there is a growing concern about the capacity of 
the  EU  school  scheme  to  cover  their  actual  costs  and  therefore,  in  some  cases,  an 
increasing difficulty in ensuring the participation of suppliers to the EU scheme’s tenders. 
This depends on two main factors: delays on payments to suppliers due to a long series of 
vetting  steps  needed  between  the  many  subjects  involved  (educational  establishments, 
local-regional-national authorities, EU); time devoted to fill applications to the scheme and 
to  stand  various  controls  within  the  scheme’s  implementation.  Finally,  the  approach  for 
reimbursement of distribution costs chosen by MS (i.e., cost based or standard cost option) 
can  prove  to  be  inefficient  in  case  the  rate  applied  does  not  encompass  all  expenses  or 

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remains fixed over time, not taking into account market changes (e.g., high inflationary 
periods).  

SPECIALISED  COMPANIES  MEET  MORE  EASILY  THE  REQUIREMENTS  FOR  THE  SELECTION  OF 
SUPPLIERS. 

According to product suppliers interviewed in the case studies MS, specialised companies 
have higher capacity for meeting quality, quantity and assortment requirements asked in 
the framework of the national/regional procurements for the purchase of the products to 
be distributed under the EU school scheme, as well as the capacity to develop economies 
of  scale  regarding  transport  facilities.  Small  suppliers,  generally,  do  not  have  the 
organisational and financial capacity to provide the distribution of products or to comply 
with the administrative paperwork needed.  

EACH  MS  MODEL  FOR  MANAGING  THE  EU  SCHOOL  SCHEME  AFFECTS  THE  DISTRIBUTION  OF 
COMPLIANCE 354AND ADMINISTRATIVE355 COSTS AMONG DISTINCT STAKEHOLDERS.  

The  selection  of  suppliers,  handling  of  aid  applications  and  carrying  out  of  on-the-spot 
checks  represent  the  implementation  tasks  for  which  most  time  is  actually  spent. 
Depending on how the EU scheme is managed by MS/regions the administrative burden 
tends to shift from national authorities to regional authorities (centralized systems), or to 
educational establishments (locally managed systems). National and regional rules play a 
major role in this sense (in some cases still relying on paper documents). 

Efficiency of the rules of the EU school scheme at EU level 

THE  AMOUNT  OF  HUMAN  RESOURCES  AT  EUROPEAN  COMMISSION  LEVEL  FOR  MANAGING  THE 
SCHEME  APPEARS  REASONABLE  WHEREAS  THE  AMOUNT  ALLOCATED  AT  MS  LEVEL  TENDS  TO 
GREATLY VARY. 

The  total  amount  of  human  resources  allocated  at  the  EC  services  level  to  manage  the 
school  scheme  seems  adequate  to  the  tasks  foreseen  by  the  relevant  regulatory 
framework.  At  the  EC  services  level  significant  part  of  the  time  is  devoted  to  request 
clarifications  to  MS/Regions  (either  concerning  the  annual  monitoring  reports  or  the  EC 
financial  audits).  National  Authorities  allocate  to  the  management  of  the  scheme  an 
amount of human resources varying significantly that apparently does not depend nor on 
the number of the involved educational establishments, neither on the adopted system for 
selecting suppliers, but rather on the national/regional authority internal organisation. The 
implementation tasks that prove to be more time consuming at MS and regional level are: 
carrying  out  of  OSCs,  application  for  Union  aid,  checking  of  applications  at  sub-national 
level. The first two tasks are also those for which the results of the surveys show that a 
simplification would be desirable.   

THE  SET  OF  EU  INSTRUMENTS  GUIDING  ADMINISTRATIVE  PROCEDURES  MIGHT  BE  BETTER 
STRUCTURED TO FACILITATE THE WORK AT MS AND REGIONAL LEVEL. 

The analysis showed that national Public Authorities are usually satisfied with the support 
received  from  the  European  Commission  services  but  also  that  simplifying  the  EU 
procedures regarding on-the-spot checks and submission of aid applications (that currently 
absorb  the  main  part  of  the  national  authorities  work  related  to  the  EU  school  scheme) 
might  improve  their  operations.  The  set  of  different  instruments  related  to  the  actual 
implementation of the EU scheme is wide, and could be better integrated in a fully readable 

354 i.e., actual costs undertaken to implement the EU scheme (e.g., for buying and distributing products and for 
providing AEMs). 
355  i.e.,  costs  linked  mainly  to  human  work  for  managing  the  various  scheme’s  tasks  in  relation  with  other 
stakeholders (e.g., payments, monitoring, reporting). 

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and user-friendly manner, e.g., including operational examples of best (bad) practises, and 
merging them into a unified document.  

ENHANCED  OPPORTUNITIES  FOR  STAKEHOLDERS  TO  PROVIDE  THEIR  OPINION  ABOUT  THE  EU 
SCHEME SHOULD BE PURSUED. 

National Public Authorities and other relevant stakeholders have  regular opportunities to 
share their opinions about the EU school scheme with the EU. Some areas where MS need 
more support and/or guidance have been identified: carrying out OSCs and EC financial 
audits, adopting digital solutions to deal with suppliers and reporting pupils participation in 
the two parts of the scheme, preparation of the AMRs. Appropriate tools could be put in 
place  to  ease  MS  work:  revision  of  the  current  EU  guidelines,  organisation  of  capacity 
building workshops, identification of best practices,  etc.  In overall terms visibility of the 
scheme,  monitoring,  evaluation  and  networking  activities  with/among  national 
stakeholders (especially in order to share lessons learnt and best practices) might be better 
promoted and supported. 

5.3  Coherence of the EU school scheme 

Coherence with other measures and instruments of the CAP 

THERE  IS  A  CLEAR  COMPLEMENTARY  NATURE  BETWEEN  THE  EU  SCHOOL  SCHEME,  THE  EU 
PROMOTION  POLICY  ON  AGRICULTURE  PRODUCTS  AND  THE  EU  INFORMATION  POLICY  AND  CAP 
WITH REGARD TO THE OBJECTIVE OF PROMOTING HEALTHY DIETS.  

The analysis highlighted the complementary between these CAP instruments, sharing the 
objective of promoting healthy eating habits and enhancing the consumption of F&V in the 
context of healthy diets.  

IN  ADDITION,  THE  OBJECTIVES  OF  THE EU  SCHOOL  SCHEME  ARE  COHERENT WITH A  NUMBER  OF 
CAP MEASURES, THE CMO, DIRECT PAYMENTS, RURAL DEVELOPMENT POLICY, QUALITY SCHEMES, 
ORGANIC  POLICY,  WITH  REGARD  TO  ENSURING  A  VIABLE  FOOD  PRODUCTION  AND  MEETING 
CONSUMERS EXPECTATIONS.  

These  CAP  instruments  and  measures  share  with  the  school  scheme  the  objectives  of 
market stability (in particular CMO), fair income for farmers (direct payments), agricultural 
competitiveness  (rural  development  measures  supporting  cooperation  and  quality 
schemes)  and  meeting  consumers  expectations  (organic  policy).  The  school  scheme 
addresses these crucial objectives of the CAP and is coherent with the relevant CAP specific 
measures, in particular for the F&V and milk sectors. However, the analysis cannot rely on 
detailed  data  on  quantities  actually  distributed  concerning  organic  products,  quality 
schemes products, local markets and short chains since the monitoring system does not 
foresee the collection on data related to product choice criteria. 

HOWEVER, ACCORDING TO THE STAKEHOLDERS, THE SCHEME IS MORE LINKED TO HEALTH-RELATED 
ISSUES. 

According to the majority of stakeholders that were consulted (survey to public authorities 
involved  in  the  planning  and  implementation  of  the  scheme,  structured  interviews  with 
public authorities and operators in case study regions) the scheme does not seem to be so 
much linked to other agricultural measures but rather to the area of healthy eating. 

Coherence with other EU policies 

The study assesses the external coherence of the EU school scheme with other EU policies, 
notably health, education and environment. 

IN  THE  FRAME  OF  A  DEVELOPING  STRATEGIC  POLICY  FRAMEWORK,  THE  EU  SCHOOL  SCHEME 
PROVES TO BE COHERENT ESPECIALLY WITH THE EU HEALTH POLICY.  

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Coherence  with  the  EU  Health  Policy  seems  to  be  proved  both  at  general  objectives 
(healthy eating habits and consumer expectations) and at policy objectives (EU Action Plan 
on  Childhood  Obesity  2014-2020,  EU  Framework  for  National  Initiatives  on  Selected 
Nutrients and its Annexes) level. Coherence with EU Education Policy and, especially, with 
EU Environment Policy, in particular with the Environment’s Strategic Plan for 2016-2020 
still  needs  to  be  reinforced  because  no  evident  links  exist  with  the  EU  school  scheme. 
However, the EU school scheme objectives related to meeting consumer expectations for 
products  that  are  climate  and  environmentally-friendly  and  to  ensuring  a  viable  food 
production are coherent with the objective “EU economy is resource-efficient, green and 
competitive”. 

THE  ACCOMPANYING  EDUCATIONAL  MEASURES  ARE  AN  IMPORTANT  TOOL  FOR  ACHIEVING 
POLICIES’ OBJECTIVES. 

Accompanying  educational  measures  have  been  identified  as  one  of  the  most  effective 
tools to achieve the cross-cutting goals of the policies of interest as they can promote new 
knowledge  on  specific  topics  (e.g.,  healthy  nutrition;  sustainable  food  production; 
reduction of waste).   

Coherence with other national policies and interventions  

THE  NATIONAL  POLICY  INITIATIVES  INDICATED  BY  NATIONAL  AUTHORITIES  RELATED  TO 
EDUCATION  AND  HEALTH  HAVE  A  GOOD  LEVEL  OF  COHERENCE  WITH  THE  EU  SCHOOL  SCHEME 
OBJECTIVES.  

Coherence with education policies/interventions is mainly established by the use of school 
curricula  on  relevant  topics  (e.g.,  environmental  effects)  and  the  involvement  of  the 
different stakeholders both in the design and in the implementation of the scheme, while 
coherence with health policies/interventions is grounded in the implementation of national 
programmes and projects aiming at promoting healthy eating habits among children. In 
some  MS  ad  hoc  projects  were  later  further  implemented  within  the  EU  school  scheme 
strategy (e.g., through accompanying measures).  

ONLY A FEW NUMBER OF NATIONAL INITIATIVES REPORTED BY NATIONAL AUTHORITIES  FORESEE 
OBJECTIVES  LINKED  TO  AGRICULTURAL  ISSUES  AND  THESE  ARE  MAINLY  FOCUSING  ON  RATHER 
SPECIFIC OBJECTIVES . 

The analysis shows a coherence between the national interventions related to agricultural 
and the EU school scheme, although these are limited in number and implemented by a 
limited number of MS. Moreover, national interventions focus on quite specific objectives 
such as: support to organic farming (e.g., certificates awarded to schools reaching a certain 
share  of  organic  products  distributed);  promotion  of  quality  products  produced  under 
environmentally,  economically  and  socially  adequate  conditions;  support  to  local 
production,  also  through  the  application  of  specific  procurement  criteria  as  the  “Green 
Public Procurement”. 

5.4  Relevance  of  the  EU  school  scheme  towards  the  needs  of  the  EU 

stakeholders 

THE OBJECTIVES OF THE EU SCHOOL SCHEME RELATED TO INCREASE CONSUMPTION OF SELECTED 
AGRICULTURAL  PRODUCTS  AND  TO  PROMOTE  HEALTHY  EATING  HABITS  AND  SHAPE  HEALTHIER 
DIETS ARE RELEVANT FOR THE VAST MAJORITY OF MS/REGIONS.  

The needs related to these two main objectives of the EU school scheme are priority ranked 
as first, second or third in most national/regional strategies. 

The  analysis  based  on  primary  data  collected  across  the  EU-27  and  in  case  study 
MS/regions highlighted that the EU school scheme is perceived as most relevant in relation 
to  addressing  the  needs  of  “increasing  the  number  of  schools/children  involved  in  the 

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school scheme”, “increasing children consumption of F&V, milk and dairy products in the 
long  run”,  “promoting  healthy  eating  behaviour”  and  “raising  awareness  of  the  healthy 
benefits of F&V and milk consumption”, thus suggesting a good level of relevance also in 
relation to the two main school scheme objectives. 

Nevertheless, the results of the family survey suggest that the role played by the scheme 
in  addressing  the  need  to  increase  F&V  and  milk/dairy  consumption  outside  school  is 
positive but rather limited.  

Moreover, the analysis suggests that most school schemes are adequately addressing the 
need of “increasing children consumption of F&V and milk/dairy in the long run” through 
distribution frequency and exposure. By increasing the number of occasions for children to 
consume  F&V  and  milk/dairy  such  schemes  may  be  regarded  as  more  adequately 
addressing  the  need  of  increasing  consumption.  In  various  instances,  CS  interviews 
stressed  that  relevance  of  the  school  scheme  towards  increasing  consumption  of  the 
interested  products  should  indeed  be  assessed  in  the  long-term,  again  confirming  the 
relevance of the specific objective.  

However,  in  certain  MS  (e.g.,  France,  Greece,  Portugal  and  Belgium)  the  needs  of 
“increasing children consumption of F&V, milk and dairy products in the long run” and of 
“increasing the number of schools/children involved in the school scheme” can be hindered 
by the poor uptake. 

THE SCHEME IS PERCEIVED ACROSS THE EU 27 TO BE SUFFICIENTLY ADEQUATE TO ADDRESS THE 
NEED  OF  PROMOTING  CHILDREN’S  KNOWLEDGE  OF  FOOD  PRODUCTION  SYSTEMS  AND 
SUSTAINABILITY. 

The  analysis  of  information  collected  through  the  PA  survey  (EU-27)  and  case  study 
interviews  indicates  that  the  needs  related  to  environmental  and  sustainability  aspects 
identified when planning the strategies are still highly relevant today and suggest that the 
relevance of the EU school scheme may be improved by giving more attention to issues 
like  reducing  unnecessary  plastic,  use  more  eco-friendly  packaging  and  recyclable  glass 
bottles for milk, increase support for organic products, short supply chains and seasonal 
products. Furthermore, according to some stakeholders (health public authority  in Spain 
and dairy sector representatives in Spain and Bavaria) another issue  to be addressed  is 
increasing concern for the impact of consumption of animal products on the environment, 
which has made it increasingly difficult to implement the milk part of the scheme. 

Finally, the scheme is perceived to be less adequate with respect to the needs related to 
“reducing  overweight  and  obesity  rates  in  children”,  “addressing  the  needs  of 
disadvantaged  or  vulnerable  children’s  groups”  (expressed  only  by  few  strategies), 
“educating  children  to  reduce  food  waste”,  “encouraging  parents’  participation”  and 
“promoting  the  distribution  of  local  and  regional  agricultural  products”  based  on  data 
collected through the PA survey.  

ACCOMPANYING EDUCATIONAL MEASURES PLAY AN IMPORTANT ROLE IN ADDRESSING THE NEEDS. 

Different categories of stakeholders and in different MS clearly highlighted the important 
role  played  by  accompanying  educational  measures,  namely  in  relation  to  the  needs  of 
“promoting healthy eating habits” and “improving children’s knowledge of food production 
systems”.  

5.5  EU added value of the EU school scheme 

THE  SCHOOL  SCHEME  IMPLEMENTATION  AT  EU  LEVEL  GENERATES  ADDED  VALUE  PRIMARILY  IN 
TERMS OF ALLOWING MS AND REGIONS TO REACH A LARGER NUMBER OF SCHOOLS AND CHILDREN 
AND TO DISTRIBUTE LARGER PRODUCT QUANTITIES THAN IT WOULD BE POSSIBLE WITH NATIONAL 
OR REGIONAL SCHEMES ALONE.  

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The analysis across the EU27 and at case study level shows that implementing a school 
scheme at EU level, rather than many national or regional school schemes, increases the 
effectiveness of the school scheme towards attaining the objective of increasing children 
consumption of selected agricultural products.  

EU level implementation of the scheme is also perceived in most case study MS and regions 
as  adding  value  by  providing  the  opportunity  of  communicating  the  same  health  and 
nutrition messages to children across all MS. 

The  analysis  shows  that  EU  implementation  provides  added  value,  albeit  to  a  smaller 
extent, also in terms of better visibility of the scheme, contributing to reconnect children 
with agriculture, financing a larger number of educational measures, improving exchange 
of knowledge and best practices between MS and meeting consumer expectations. In spite 
of EU implementation being perceived as having the potential to improve the visibility of 
the school scheme, in many cases better visibility has not been accomplished at national 
level  due  to  poor  communication,  in  particular  towards  schools  and  families,  but  also 
towards the interested agricultural sectors and product suppliers. 

THE IMPLEMENTATION OF NATIONAL SCHOOL SCHEMES IN ADDITION TO THE EU SCHOOL SCHEME 
IN  FEW  MS  AND  THE  USE  OF  ADDITIONAL  NATIONAL  AID  IN  MOST  MS  HAVE  FAVOURED 
COMPLEMENTARITY WITH THE EU SCHOOL SCHEME. 

The results of the PA survey indicate that certainly in Ireland and to some extent in Finland, 
national  and  EU  schemes  complement  each  other.  The  PA  survey  also  suggests  that 
national payments have complemented Union aid but only to a limited extent, and slightly 
better  with  respect  to  providing  additional  educational  activities  for  school  children,  to 
distributing products to a larger number of schools and to distributing additional products. 
However, such opinions do not seem to be consistent with expenditure figures, which show 
high overall share of national payments over Union aid in the first four years of the school 
scheme. 

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6  RECOMMENDATIONS 

On the basis of the evaluation results and the conclusions, the evaluator recommends:  

EVALUATION 
CRITERIA 

RATIONALE 
FROM 
EVALUATION  RESULTS 
AND CONCLUSIONS 

RECOMMENDATIONS 

1 

Causal analysis 

2 

Causal analysis 

the 
The  execution  of 
definitive 
financial 
allocation of the EU school 
scheme 
varies 
considerably  across  EU 
MS  with  MS  showing  a 
financial  execution  below 
the  EU  average  and  in 
some cases well below the 
average.  Moreover,  the 
evaluation  revealed  that 
the  amounts  transferred 
by  MS  between  the  two 
parts  of  the  scheme  play 
a  marginal  role  on  the 
final execution rate. 

in 

number 
the 

The lack of data related to 
some MS (i.e.: number of 
children  involved  in  F&V 
and  milk  part  of  the 
of 
scheme; 
children 
target 
group  set  out 
in  the 
strategy), the provision of 
which  to  the  European 
Commission  is  currently 
optional,  affected 
the 
assessment of the effects 
of the policy at a general 
level,  and  made 
the 
evaluation exercise rather 
complex. 

3 

Causal analysis 

the 

During 
evaluation 
process, specific interest of 
the  EC  services  was  raised 
in relation to the quantities 
of organic products actually 
distributed.  However,  the 
monitoring  system  does 
not foresee the collection of 
(nor  of 
this  data 
the 
quantities 
products 
of 
related  to  other  product 
choice criteria). 

to 

improve 

the 
In  order 
execution rate of the EU school 
scheme, it is recommended to 
revise 
the  mechanism  of 
financial allocation to each MS 
(art.  5(4)  of  Regulation  (EU) 
No 1370/2013), 
into  
account  the  criteria  laid  down 
in  the  first  subparagraph  of 
art. 23a(2) of Regulation (EU) 
No 1308/2013 and the level of 
use of the definitive allocation 
of  Union  aid  in  the  previous 
school years. 

taking 

In  order  to  ensure  a  more 
effective  monitoring 
and 
evaluation of the effects of the 
policy,  it  is  recommended  to 
revise  the  monitoring  system 
by  converting  optional  data 
provision into mandatory (i.e.: 
number of children involved in 
F&V  and  milk  part  of  the 
scheme; number of children in 
the target group set out in the 
strategy). 

the 
of 

further 
Given 
that 
development 
organic 
production  is  a  EU  priority 
(Action  plan  2021-2027),  it  is 
suggested 
the 
monitoring system by including 
a 
collection 
system  for  distributed  organic 
products.  

specific  data 

revise 

to 

4 

Efficiency 

Unitary 
(per 
quantity  of  distributed 

costs 

It is recommended to increase 
the  efforts  to  monitor  more 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

products  and  per  child) 
are comparable to market 
prices  recorded  in  the 
years  at  stake.  Less 
information  is  available 
concerning  the  provision 
of 
accompanying 
educational  measures, 
which  strongly  support 
the 
scheme’s 
success. 

overall 

of 

provision 

precisely  the  costs  related  to 
the 
the 
educational 
accompanying 
the 
measures 
reports 
annual  monitoring 
and/or  via  specific  studies, 
workshops, etc). 

(either  via 

5 

Causal analysis 

Effectiveness 

6 

Causal analysis 

Efficiency 

7 

Causal analysis 

8 

Causal analysis 

it 

In  order  to  avoid  possible 
is 
deadweight  effects, 
recommended 
activate 
to 
more 
selective  distribution 
plans in schools, more focused 
on targets expressing stronger 
needs (i.e., in areas where the 
educational level of families is 
on average lower).   

EU 

the 

The  evaluation  revealed 
school 
that 
scheme was less effective 
in the case of families with 
higher 
education 
qualifications, since:  

  the  notions 

learnt  at 
school  by  children  are 
already part of the family 
background; 

  family’s  consumption  of 
F&V  and  milk  is  already 
relatively high.  

The  evaluation  revealed 
that 
children  do  not 
always  consume  all  the 
in 
products  distributed 
schools.  This  limits  the 
effectiveness  and 
the 
efficiency of the policy. 

It  would  be  appropriate  to 
discuss  with  MS  and  regions 
mechanisms 
the 
to 
awareness  of  participating 
schools  to  reduce  food  waste 
during 
the  distribution  of 
products in schools. 

raise 

The  evaluation  highlighted 
the  very  positive  role  of 
accompanying  educational 
measures  on  children’s’ 
learning  of  healthy  eating 
habits.  

the 
Furthermore, 
involvement of families is a 
facilitator  element  for  the 
adoption  of  healthy  eating 
habits  by  children  involved 
in  the  scheme  (but  also  of 
the other family members). 

The effects of the EU school 
scheme 
of 
improvement  of  children’s 

terms 

in 

It would be appropriate: 

  to  discuss  with  MS  and 
for 

tools 

focusing 

regions 
strengthening 
accompanying  educational 
measures 
on 
healthy eating habits, and in 
food  education 
particular 
actions, also through greater 
involvement of teachers and 
external experts.  

  to evaluate the possibility to 
further  promote  actions 
involving  parents  on  issues 
concerning  the  role  of  F&V 
and  milk  with  respect  to 
healthy  eating  habits  (i.e., 
boost  parent  meetings  led 
by external experts). 

It is recommended to reinforce or 
implement educational measures 
(not 
in 

secondary 

schools 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

9 

Coherence  

Relevance 

10  Causal analysis 

Efficiency 

attitude  and  behaviour 
towards  F&V  and  milk 
products  are  positively 
correlated  with  the  age  of 
the school children, but the 
distribution  of  products 
and, 
the 
accordingly, 
accompanying  educational 
are 
measures, 
concentrated 
in  primary 
schools.  Thus,  educational 
measures  involved  a  little 
adolescents 
share 
attending 
secondary 
school. 

of 

The  evaluation  shows  that 
themes 
among 
the 
addressed 
by 
accompanying  educational 
measures, two of the topics 
related to the environment: 
organic  production  and 
production 
sustainable 
seem 
less 
appealing.  

to  be  yet 

the 

needs 
Although 
identified  in  the  strategies 
are  still  relevant  today, 
there  is  room  to  make  the 
scheme  more 
school 
relevant 
in 
relation 
to  environment 
and sustainability. 

specially 

delegated 

Distribution  of  products 
and 
of 
provision 
accompanying 
educational  measures  is 
often 
to 
teachers, 
that  do  not 
receive any compensation 
for these tasks. This risks 
to  undermine  the  quality 
of these activities (taking 
also into account the little 
time  usually  devoted  to 
contacts  with 
families, 
that  influence  the  long-
term 
their 
children). 

diet 

of 

necessarily 
distribution). 

linked  to  product 

order 

ensure 
the 

to 
of 
the 

the 
In 
school 
contribution 
sustainable 
scheme 
to 
is 
it 
development 
recommended  to  invite  MS  and 
reinforce 
regions 
to 
educational 
accompanying 
on 
focusing 
measures 
sustainable agriculture. 

goals, 

It  would  be  appropriate 
to 
discuss with MS and regions tools 
for  motivating  teachers  in  non-
monetary  terms  or  examine  the 
possibility  of  introducing  in  the 
future compensation for some of 
the activities provided. 

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11  Causal analysis 

Efficiency 

reimbursement  of 
costs, 
its 

The 
distribution 
including 
administrative 
procedures,  can  be  a 
major factor of hindrance 
to  participation  in  the  EU 
school scheme. 

regions  should  be 
MS  and 
encouraged  to  make  a  thorough 
use  of  the  simplified  cost  option 
for  the  reimbursements  in  order 
to  simplify  the  administrative 
payments. 
process 
Additionally, 
cost 
option  rates  should  be  reviewed 
along the implementation period 
to  make  them  more  adaptive  to 
market 
(e.g., 
conditions 
inflationary crisis). 

simplified 

of 

12 

Effectiveness 

Coherence 

13 

Efficiency 

can 

choose 

included 

MS 
the 
products to be distributed 
in 
to  be 
or 
accompanying 
educational  measures  on 
the  basis  of  objective 
criteria  (Article  23(11)  of 
Regulation (EU) N 1308/2
013).  In  some  cases, 
there is need of definition 
(short  supply  chains)  or 
clarification 
need 
included 
(some 
national 
or 
agricultural 
voluntary 
certifications 
product 
criterion 
under 
recognised 
“products 
under 
quality 
the 
schemes  established  by 
Regulation (EU) N 1151/2
012). 

schemes 

the 

MS 

of 

of 

scheme 

Selection  of  suppliers, 
handling 
aid 
applications  and  on-the 
spot-checks are the most 
time-demanding 
implementation 
tasks. 
Depending on how the EU 
school 
is 
managed  by  different 
MS/regions 
the 
administrative  costs  shift 
different 
among 
the 
(national 
stakeholders 
and 
regional 
rules/procedures  play  a 
major role in this sense). 
innovative 
Some 
solutions 
and/or 
suggestions  to  increase 
scheme’s 
the 

overall 

It  is  recommended  to  adopt,  in 
the  regulatory  framework  of  the 
same 
school 
definitions of short supply chains 
and 
local  markets  given  by 
Regulation (EU) N 807/2014.  

scheme, 

the 

ensure 

common 
To 
understanding, 
it  should  be 
clearly  specified  which  quality 
schemes  are  included  in  the 
criterion  “products  recognised 
schemes 
under 
established 
by 
Regulation (EU) N 1151/2012”. 

the  quality 

to 
It  would  be  appropriate 
identify  best  practices  that  can 
be  adopted 
the  different 
in 
MS/regions  contexts  and  share 
them among MS/regions.  

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14 

Efficiency 

15 

Efficiency 

16 

Efficiency 

success  and/or  its  cost 
efficiency 
been 
found  in  selected  case 
studies. 

have 

The  implementation  task 
that 
an 
represents 
administrative  challenge 
National/Regional 
for 
the 
are 
Authorities 
carrying  out  of  on-the 
spot-checks, 
the 
preparation of the annual 
monitoring  reports  and 
the EC audits. 

The  evaluation 
results 
show that PAs are usually 
satisfied with the support 
from  the 
they  receive 
European 
Commission 
services;  yet  the  set  of 
different provisions of the 
actual  implementation  of 
the  EU  scheme  is  wide, 
and could be integrated in 
a  more  clearly  readable 
manner. 

The  amount  of  human 
resources allocated at  EU 
the 
to  manage 
level 
school 
seems 
scheme 
adequate  to  the  tasks 
foreseen  by  the  relevant 
EU provisions However, a 
significant  part  of  their 
time is devoted to request 
data 
clarifications 
provided 
MS 
(regarding  AMRs  and  EC 
audits). 

on 

by 

It is recommended to revise the 
current  guidelines 
regarding 
these  tasks  enriching  them  with 
operational examples in order to 
prevent  non-compliance  cases, 
and to organise capacity building 
events. 

It  is  recommended  to  foresee  a 
common set of written provisions 
currently regulating the scheme’s 
management  on  the  ground  to 
foster  a  correct  interpretation  of 
better 
and 
EU 
implementation  of  the  scheme 
(as  already  done  in  other  EU-
funded programmes- e.g., LIFE). 

rules, 

a 

Being aware that there is a trade-
off  between  requesting  more 
precise  data  on  the  scheme’s 
implementation  and  reducing  its 
administrative burden, gathering 
some  more  information  appears 
a  priority 
for  cost-efficiency 
analysis.  This  can  be  facilitated 
by  fostering  the  adoption  of 
digital  solutions  to  track  some 
data in the MS where this is not 
yet 
fostering 
by 
networking 
improving  the  guidelines  to  fill 
the  annual  monitoring  reports, 
and  to  better  select  and  specify 
the  cases  when  amendments  to 
strategies are needed (and when 
not). 

the  case;  by 

activities; 

17 

Efficiency 

have 

Some  areas  where  MS 
need more support and/or 
guidance 
been 
identified: carrying out of 
OSCs  and  of  EC  financial 
audits,  adopting  digital 
solutions  to  deal  with 

It  would  be  appropriate  for  the 
EC  to  increase  and  diversify  the 
range  of  opportunities  provided 
to relevant national stakeholders 
in  order  to  receive  potentially 
useful  inputs  and  suggestions 
about  the  scheme’  design  and 

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Evaluation support study of the EU school fruit, vegetables and milk scheme 

and 

for 
suppliers 
reporting 
pupils 
participation  in  the  two 
parts  of 
the  scheme, 
preparation  of  the  AMRs. 
Appropriate tools could be 
put  in  place  to  ease  MS 
work. 

performance  and  to  exchange 
knowledge and good practices In 
overall  terms  visibility  of  the 
scheme,  monitoring,  evaluation 
activities 
and 
with/among 
national 
stakeholders (especially in order 
to  share  lessons  learnt  and  best 
practices)  might  be  better 
promoted and supported. 

networking 

194 

 
 
 
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doi: 10.2762/00763 
ISBN 978-92-76-54150-9