Restructuring and planting vineyards in the EU : unclear impact on competitiveness and limited environmental ambition. Special report 23, 2023.
Date: 2023-09-26
Institutions: European Court of Auditors
Subjects: audit, common agricultural policy, competitiveness, ecological footprint, environmental impact, financial aid, global warming, pesticide, report, social impact, sustainable development, vineyard, viticulture

EN 

2023 

23 

Special report  Restructuring and planting vineyards 

in the EU  
Unclear impact on competitiveness and limited 
environmental ambition 

 
 
 
2 

Paragraph 

I-X 

01-16 

01-09 

10-11 

12-13 

14-16 

17-21 

22-70 

22-42 

24-32 

33-42 

43-70 

44-56 

57-61 

62-70 

71-76 

Contents 

Executive summary 

Introduction 

The EU wine sector 

Balancing supply and demand 

Roles and responsibilities 

Environment and climate 

Audit scope and approach 

Observations 

The EU actions for restructuring and avoiding over-supply in the 
wine sector are not targeting competitiveness directly 

Insufficient clarity on how the restructuring measure is increasing 
competitiveness 

The planting authorisation  scheme is not linked directly to improved 
competitiveness 

The EU’s wine policy falls short of CAP environmental objectives 

Little consideration for environmental sustainability in the restructuring 
measure 

The environmental effects of the planting authorisation  scheme are 
unknown 

Environmental ambition of the EU wine policy remains low 

Conclusions and recommendations 

Abbreviations 

Glossary 

Replies of the Commission 

Timeline 

Audit team 

 
 
 
 
3 

Executive summary 

I Wine growing and wine production are long-standing traditions in Europe that go 
back several thousand years. The EU is the world’s leading producer, consumer and 
exporter of wine. In 2020,  there were 2.2 million  wine holdings in the EU and vineyards 
covered about 2 % of the EU’s utilised agricultural  area. 

II Wine growers in the EU can receive financial support from the common agricultural 
policy to restructure their vineyards. The main aim is to make them more competitive. 
Member states had also the option to use the support to improve sustainable 
production systems and the environmental footprint of wine growing. Vines are one of 
the most pesticide-intensive crops, and global warming has a significant impact  on 
wine growing. 

III Since 2016,  wine growers can request authorisations to plant new vineyards. 
These authorisations are free of charge and can be distributed pro rata, and/or on the 
basis of eligibility  and priority criteria.  The purpose of this planting authorisation 
scheme is to allow  for progressive growth, while avoiding excessive supply capacity 
with negative social  and environmental effects. 

IV Our audit examined the extent to which the restructuring measure and the 
planting authorisation scheme helped to make wine growers more competitive and 
wine production more environmentally sustainable. We also looked at the design of 
the measure under the new CAP strategic plans in order to assess their environmental 
ambition. We decided to carry out this audit considering the materiality of the 
restructuring measure, which represents over €5 billion  for the 2014-2023  period. We 
have not covered this measure since 2012,  and our previous work has never covered 
the planting authorisation scheme. 

V We found that this policy framework for making wine growers more competitive 
has shortcomings in terms of design and implementation. Also, it falls short of the 
common agricultural  policy’s environmental objectives. 

 
 
4 

VI The framework underlying the restructuring measure lacks proper definitions, 
coherent strategies and relevant indicators. The five member states we visited funded 
all eligible requests, and did not use criteria  to select projects to foster 
competitiveness. These member states also funded projects for which a structural 
change could not be observed. Neither the Commission nor the member states we 
visited assess how the projects contribute to the competitiveness objective, and 
beneficiaries are not required to report on how their restructuring activity  made them 
more competitive. 

VII The planting authorisation scheme aims to avoid oversupply by limiting  the 
increase in vineyard area by 1 % annually. No impact  assessment was carried out 
before the limit was proposed and adopted by the co-legislators. Member states may 
also limit  growth in certain production areas. Therefore, the increase at regional/local 
level could be well above the 1 % limit,  and member states are not required to assess 
the impact of this growth. We found that restructuring old vineyards can significantly 
increase production. When granting authorisations, the member states we visited use 
only a few eligibility  and priority criteria  linked to competitiveness, and the 
authorisations are often distributed on a pro rata basis. Beneficiaries are granted very 
small areas and cannot plan ahead, thus potentially hampering the competitiveness 
objective. 

VIII We also found that the audited measure and scheme have only partially  taken 
environmental protection on board, despite the large amount of funding involved. The 
five member states we visited did not assess the expected environmental impact of 
their national  support programmes. The strategic objectives and targets they set for 
the restructuring measure showed little  ambition in terms of environmental 
sustainability.  In practice, projects did not aim to reduce the climate-related and/or 
environmental impact of wine growing. Under certain circumstances, we saw that they 
could even have the opposite effect, such as switching to varieties that need more 
water, requiring irrigation  systems to be installed. 

IX Environmental ambition remains limited in the 2023-2027  programming period. 
Cross-compliance has been discontinued for beneficiaries of the restructuring 
measure. Also, member states need to spend only a minimum of 5 % of the wine 
allocation  on climate  and environment objectives. In the context of a greener common 
agricultural  policy, 40 % of its expected expenditure should target climate-related 
objectives. 

 
 
5 

X Based on our findings, we recommend that the Commission should: 

o 

target the restructuring measure and the planting authorisation scheme to foster 
competitiveness; and 

o 

increase the environmental ambition of the wine policy. 

 
 
6 

Introduction 

The EU wine sector 
01 Wine growing and wine production are long-standing traditions in Europe that go 
back several thousand years. The EU is the world’s leading producer, consumer and 
exporter of wine (see Figure 1). EU wine growing provides almost 1 million  jobs 1. 

Figure 1 – EU vineyard area, wine production, consumption and exports 
in 2021 

Vineyard area

3.3 million ha

down from 
3.5 million ha 
in 2010

Wine 
production

154 million hl

down from 
156 million hl 
in 2010

Wine 
consumption

113 million hl
down from 
120 million hl 
in 2010

Wine exports

76 million hl

up from 
64 million hl 
in 2010

46 %

of world’s total

59 %
of world’s total

48 %

67 %

of world’s total

of world’s total

Source: ECA, based on data from the International Organisation of Vine and Wine (OIV). Information is 
presented only for those member states that communicate the relevant data. 

1  Eurostat, Farm labour force (ef_lf_size). 

 
 
 
 
7 

02 In 2020,  there were 2.2 million  wine holdings in the EU. Vineyards covered about 
2 % of the EU’s utilised agricultural  area (see Figure 2). 83  % of wine holdings had less 
than 1 hectare of vineyards 2. According to the Food and Agriculture Organization  of 
the United Nations, the value of EU grape production represents 7.5 % of the value of 
EU agricultural  production 3. 

Figure 2 – EU vineyard area (2020) 

Legend

> 650 000 ha

100 000 to 200 000 ha

45 000 to 70 000 ha

10 000 to 20 000 ha

1 000 to 10 000 ha

No data

Source: ECA, based on Eurostat, Wine-grower holdings by production (vit_t1). Information is presented 
only for those member states that communicate their vineyard area. 

2  Eurostat, Vineyards in the EU - statistics. 

3  Food and Agriculture Organization statistics, Value of Agricultural Production, 2019. 

 
 
 
 
8 

03 Global consumption of wine decreased slightly by 2.5  % between 2010  and 2021. 
The EU share of wine exports remained relatively constant at about 65-67  % in the 
same period, although the volume of EU wine exports increased from 64 to 
76 million  hl, or 19 % over the last decade. Italy, France and Spain produced and 
exported almost 80 % of EU wine in 20214.  The EU exports were mainly to the US (25 % 
of the total), the UK (14  %), Russia (9 %), China and Canada (7 % each) 5. In 2020, 82  % 
of the EU’s vineyard area was used to produce wine falling under the two European 
schemes for geographical  indications 6: protected designation of origin (PDO) and 
protected geographical indication  (PGI) – see Box 1. 

Box 1 – EU schemes for wine produced in specific geographical areas 

Protected designation of origin (PDO) 

PDO products must be produced within a determined geographical area using 
recognised and recorded know-how. PDO wines must be produced exclusively 
with grapes from the area in question. 

Protected geographical indication (PGI) 

PGI products have a quality, reputation or other specific features that can be 
attributed to a determined geographical  area. All PGI wines must be produced 
with at least 85  % of the grapes coming from the area in question. 

Source: Article 93 of Regulation (EU) No 1308/2013. 

04 The EU wine market is highly regulated. The basic legal act for the 2014-2022 
period under the common agricultural  policy (CAP) which, as regards wine support 
programmes, is valid until October 2023,  is Regulation (EU) No 1308/2013  establishing 
a common market organisation (CMO) in agricultural  products, and various delegated 
and implementing acts apply – see Figure 3. 

4  OIV, wine statistics, 2021. 

5  European Commission, Agridata portal – Wine trade, marketing year 2020/2021. 

6  Eurostat, Wine-grower holdings by production (vit_t1). 

 
 
 
Figure 3 – Legal framework for the wine market 

9 

Provisions on 
market 
standards and 
oenological 
practices
Regulation (EU) 
2019/934

Protection 
of designations 
of origin, 
labelling and 
presentation 
rules
Regulations (EU) 
2019/33 and 
2019/34

Vineyard 
register, 
authorisation 
scheme for 
vine plantings
Regulations (EU) 
2018/273 and 
2018/274

National 
support 
programmes
Regulations (EU) 
2016/1149 and 
2016/1150

Source: ECA, based on European Commission, Evaluation of the CAP measures applicable to the wine 
sector, SWD(2020) 232, pp. 10-12. 

05 Wine growers and wine makers are eligible for CAP financial  support. This can be 
specific support under the wine CMO (mainly through national  support programmes – 
NSPs – in the wine sector), but also direct payments, support for rural  development 
measures, and/or for horizontal  promotion measures 7. For the 2014-2020  period, the 
wine CMO represented €7.1 billion,  equalling 41  % of the total budget for market 
measures under the CAP and 1.7 % of the total CAP budget 8. At EU level, there are no 
data available to quantify direct payments and rural development support for the wine 
sector. 

06 The total yearly budget for NSPs is around €1 billion:  €5.5  billion  for the 
2014-2018  period and €5.3 billion  for the 2019-2023  period 9. NSPs can fund eight 
support measures, but the majority of EU funding was spent on three measures in the 
2014-2018  period: restructuring and conversion (50  % – further referred to as 
‘restructuring’), investments (22 %) and promotion (18  %) – see Figure 4. 

7  Regulation (EU) No 1144/2014 on information and promotion measures concerning 

agricultural products. 

8  European Parliament – Fact Sheets on the European Union – Financing of the CAP. 

9  ECA, based on the EU budget. 

 
 
 
 
10 

Figure 4 – NSP support measures and NSP funding in 2014-2018 

Restructuring and conversion of vineyards
Varietal conversion, relocation of vineyards, 
replanting for health or phytosanitary reasons, 
improvements to vineyard management 
techniques

50 %

22 %

Tangible and intangible 
investments

€5.5 billion

18 %
Promotion
in the EU and third 
countries

7 %
By-product distillation

3 %
Four measures: Harvest insurance, Green 
harvesting, Mutual funds and Innovation

Source: ECA, based on European Agricultural Guarantee Fund expenditure data. 

07 In 2014,  18 EU member states had a financial allocation  for the wine sector10. 
Two of them (Malta and Luxembourg) decided to transfer the funds to the direct 
payments budget, instead of having a national support programme. Spain opted for a 
mixed approach, and transferred only part of its allocation  to direct payments. Italy is 
the biggest recipient of NSP funding (32 %), followed by France (28 %) and Spain (19 %) 
– see Figure 5. 

10  Annex VI of Regulation (EU) No 1308/2013. 

 
 
 
 
Figure 5 – NSP expenditure per member state (2014-2018) in million 
euros 

11 

 1 600

 1 400

 1 200

 1 000

 800

 600

 400

 200

 -

 Restructuring and
conversion

 Promotion

 Investment

 Innovation

 Harvest insurance

 Green harvesting

 By-product distillation

 IT  FR  ES  PT  DE  HU  RO  BG  EL  AT  CZ  SI

 CY  SK  HR

Source: ECA, based on AGREX data. Lithuania did not incur any expenditure. 

08 The main objective of the 2013  wine policy reform was to “make EU wine 
producers more competitive while preserving authenticity and traditions  of European 
wine growing and boosting its social  and environmental role in rural areas”11. The 
Commission spells out the wine policy objectives more explicitly in its evaluation of the 
CAP measures applicable  to the wine sector: 

o 

o 

o 

o 

o 

strengthening the competitiveness of the sector; 

ensuring a smooth functioning of the internal market, notably by increasing  the 
marketability of wine products and ensuring an orderly growth of vine plantings; 

ensuring the quality of EU wine, taking into account consumer expectations; 

encouraging a responsible approach to crisis  situations; 

protecting the environment. 

11  EU wine policy contributes to maintaining the reputation and competitiveness of EU wine. 

 
 
 
 
12 

09 From November 2023  onwards, NSPs will  be embedded in the CAP strategic 
plans. Member states will  have the freedom to choose the objective(s) they want to 
achieve in the wine sector, from a list of 11  objectives 12, including economic 
sustainability  and competitiveness, climate change mitigation and adaptation, 
improving the sustainability  of production systems and reducing the environmental 
impact, improving the conditions of employment, adapting to market demands. 

Balancing supply and demand 

10 Between the late 1970s  and 2010,  the EU wine sector suffered from structural 
production surpluses which affected the competitiveness of wine growers. For 
decades, the focus of the EU’s wine policy  has therefore been to strike a balance 
between supply and demand, through subsequent sectoral reforms. The Commission 
has applied various measures, such as distilling  surpluses, planting restrictions, and 
providing subsidies for grubbing-up or restructuring vineyards. 

11 In 2016,  the new planting authorisation scheme (further referred to as ‘the 
scheme’) replaced the old planting  rights system, under which the rights to plant vines 
were purchased or sold. Under the new planting system, authorisations are granted to 
applicants  free of charge, distributed pro-rata and/or based on eligibility  and priority 
criteria.  Beneficiaries can apply for authorisation  to start or increase their vineyard 
area. The new scheme allows controlled growth of production potential (‘ensure 
orderly growth of vine plantings’) within certain limits,  i.e. a maximum yearly increase 
of 1 %. The scheme is applied in 13 EU wine-producing countries with a vineyard area 
of more than 10 000 ha, and runs until the end of December 2045.  As of April 2023, 
Croatia has not yet applied the scheme. 

Roles and responsibilities 
12 EU legislation  provides the framework for regulating the wine sector (see 
Figure 3), setting general eligibility  and priority criteria  for the different NSP measures 
and for the planting authorisation  scheme. The Commission is responsible for 
monitoring the sector’s performance and for overseeing the management and control 
systems established in the member states. The Commission assesses the NSPs, and 
checks if they comply with EU rules. 

12  Article 57 of Regulation (EU) 2115/2021. 

 
 
 
13 

13 Member states decide which measures to include in their NSPs, and the budget 
they allocate to each of them. National/regional authorities implement the NSPs under 
shared management. This means that they set specific eligibility  and priority criteria, 
carry out checks, and make payments to beneficiaries. Member states are also 
responsible for authorising vine plantings. They notify the Commission about the 
implementation of the scheme. 

Environment and climate 

14 Vineyards are often pesticide-intensive 13 – mainly using fungicides – to fight 
diseases such as mildew infections 14. For instance, in France, although vineyards 
represent 3 % of agricultural  land, the sector uses 20 % of the country’s fungicides 15. In 
Italy, over 95  % of wine growers apply phytosanitary products, the highest share 
among the main crop types 16. There are, however, environmental and health risks 
associated with the use of chemical  pesticides, in particular  from spray drift 17. 

15 In organic grape production, the use of pesticides is highly restricted when 
compared with conventional grape production. Organic vineyards in the EU grew by 
55  % (from 244  322 ha to 379 269 ha) between 2013  and 2019,  accounting for 12  % of 
the EU’s total vineyard area18. 

16 Climate change has a significant  impact on wine growing. A warmer climate 
influences yields and quality, and creates problems such as the over-ripening of 
grapes. Climate change also brings more extreme weather conditions, such as hail and 
spring frosts. Growers may need to consider different ways of adapting to these 
changing conditions, such as different grape varieties, delocalising  production, and 
different vineyard management techniques. 

13  Orre-Gordon, et al., Viticulture can be modified  to provide multiple ecosystem services. 

Ecosystem Services in Agricultural and Urban Landscapes, 2013, pp. 43-57. 

14  Delière, et al., Field evaluation of an expertise-based formal decision system for fungicide 
management of grapevine downy and powdery mildews, Pest Management Science, 
2015 71 (9), 1247–1257. 

15  Pesticide challenge leaving French viticulture with little choice, Euractiv, 2019. 

16  National Statistical Institute of Italy, 2010. 

17  Recital 14 of Directive 2009/128/EC on Sustainable use of pesticides. 

18  Eurostat, Organic crop area by agricultural production methods and crops (org_cropar). 

 
 
 
 
14 

Audit scope and approach 

17 This audit focuses on the support measure for restructuring vineyards and on the 
planting authorisation scheme. The measure aims to make wine growers more 
competitive, while the planting authorisation scheme should prevent oversupply. The 
measure for restructuring vineyards could also aim to improve sustainable production 
systems and the environmental footprint, while the scheme could address negative 
environmental effects. 

18 Our main audit question was whether the measure and the scheme helped to 
make wine growers more competitive and wine production more environmentally 
sustainable. We examined how the Commission designed and monitored the measure 
and the scheme, and how member states implemented them. For the measure, this 
audit covered the period 2014-2022.  The scheme was covered since its establishment 
in 2016.  We also looked at the design of the measure under the CAP strategic plans to 
assess environmental ambition. 

19 We decided to carry out this audit considering the materiality of the restructuring 
measure, which represents half of NSP budgets, i.e. over €5 billion  out of almost 
€11 billion  for the 2014-2018  and 2019-2023  periods together (see paragraph 06). In 
addition, we have not covered this measure since 2012  (see Figure 6), and our 
previous work has never covered the planting authorisation scheme. The audit also 
responds to issues of significant  stakeholder interest, as it focuses on the economic 
impact of the CMO. We expect our findings and recommendations to be relevant to 
the discussion of the new support measures for the wine sector under the CAP 
strategic plans. We did not cover the other seven measures for the wine sector 
financed through the wine CMO (see Figure 4). 

 
 
15 

Figure 6 – The ECA’s previous audit work on the wine sector 

the grubbing-up scheme and 
restructuring and conversion 
measure as part of the CMO reform

Special report 07/2012: The reform of the common 
organisation of the market in wine: progress to date

promotion and investment 
measures

Special report 09/2014: Is the EU investment and promotion 
support to the wine sector well managed and are its results 
on the competitiveness of EU wines demonstrated?

CMO measures on mutual funds, 
harvest insurance and green 
harvesting

Special report 23/2019: Farmers’ income stabilisation: 
comprehensive set of tools, but low uptake of instruments 
and overcompensation need to be tackled

geographical indications and 
intellectual property rights

Special report 06/2022: EU intellectual property rights -
protection not fully waterproof

private storage and crisis distillation 
of wine during COVID-19

Special report 09/2023: Securing agricultural product supply 
chains during COVID-19: EU response was rapid, but 
insufficiently targeted

Source: ECA. 

20 The audit ran from May to December 2022.  We carried  out audit visits in five 
member states: the Czech Republic (Moravia), Greece (the Peloponnese), Spain 
(Castilla-La  Mancha – CLM), France (the Rhône Valley and Provence) and Italy 
(Tuscany). These member states account for 70  % of restructuring funding. Our 
selection of member states covers a wide range of wine-growing practices in different 
geographical and climate situations, as well as a mix of centralised/regional 
management of the measure and scheme. 

21 We collected evidence through: 

o 

o 

o 

o 

a review of EU regulations, Commission guidelines and monitoring activities, 
statistics, evaluations and reports on all  wine-producing member states; 

a review of visited member states’ 2014-2018  and 2019-2023  NSPs, studies, calls 
for applications,  applicable national  and regional rules (including the 
implementation of the authorisation scheme since 2016),  statistics  and reports; 

interviews with Commission and member state authorities’ representatives, as 
well as beneficiaries; 

consultations of other stakeholders in the wine sector, such as European and 
national associations  of wine growers, cooperatives, and wine producers; 

 
 
 
16 

o 

analysis of a limited number of project files in the visited member states, selected 
to cover various actions and types of beneficiaries, through both desk review and 
on-the-spot visits. We selected beneficiaries ranging from smaller to bigger 
holdings, covering both organic  and conventional farming. Our selection included 
wine growers selling grapes, cooperatives, and wine growers producing wine. 

 
 
 
 
17 

Observations 

The EU actions for restructuring and avoiding over-supply in the 
wine sector are not targeting competitiveness directly 

22 The primary objective of the restructuring measure is to make wine growers 
more competitive while the planting authorisation  scheme aims at market stability 
limiting  the growth of vine plantings in order to avoid repeating the production 
surpluses that occurred in the past (see paragraph 10)19. The scheme has also the 
capacity  to improve competitiveness of wine growers if member states decide to use 
specific criteria  when granting the planting authorisations (see paragraph 11). 

23 We examined whether the restructuring measure and the planting authorisation 
scheme helped to make wine growers more competitive. We looked at how the 
Commission designed the measure and the scheme, and how the member states 
implemented them (e.g. by setting clear objectives, identifying target groups and 
setting eligibility  and priority criteria that could maximise impact, by setting up control 
systems). We assessed whether the Commission and member states set relevant 
indicators  and meaningful targets for the economic performance of wine growers, and 
carried out evaluations. 

Insufficient clarity on how the restructuring measure is increasing 
competitiveness 

Design of the restructuring measure 

24 The EU regulations and Commission guidelines on the NSPs in the wine sector do 
not define the competitiveness of wine growers nor how to measure progress. The 
Commission informed us that they consider competitiveness as linked to the capacity 
to deliver quality products at competitive costs and prices, while providing reasonable 
benefits for wine growers. The CMO Regulation connects the competitiveness of the 
wine sector to the EU market share in the world market. The evaluation of the CMO 
mentions that “Competitiveness depends on the EU wine sector’s capacity  to produce 
and sell products in various markets with specific features that make them more 
attractive than the products offered by competitors”. 

19  Recital 55 and Article 46 of Regulation (EU) No 1308/2013. 

 
 
 
18 

25 The member states we visited did not define how the restructuring measure 
should contribute to making wine growers more competitive. Their NSPs lack a 
strategy for the competitiveness objective. The authorities we interviewed believe that 
responsibility for strategic choices lies with wine growers. Since 2006,  neither the 
Commission nor the member states have carried out ex ante analyses or studies of the 
expected impact of EU support for wine on the competitiveness of wine growers. 

26 The Commission collects the main market indicators for the EU wine sector: 
prices, production, stocks and trade 20. Economic  parameters (such as revenues and 
production costs) of agricultural  holdings, including wine growers, are reported in the 
Farm Accountability Data Network (FADN) for a sample of producers, without 
information about their participation  in the measure. However, the data collected in 
the EU framework for the restructuring projects (see Figure 7), as well as the 
additional  indicators set by the member states we visited (see Box 2), focus on outputs 
and do not allow the impact of the measure to be assessed against the objective of 
making wine growers more competitive. We found that the Commission does not 
systematically collect  nor analyse data concerning the parameters relevant for 
assessing competitiveness of wine growers that used the restructuring measure. 

Figure 7 – Data collected for restructuring projects 

Total Union expenditure

Total area covered

Number of projects

Number of beneficiaries

Total expenditure of 
beneficiaries
Source: Annex IV of Commission Implementing Regulation (EU) 2016/1150. 

20  Wine market observatory. 

 
 
 
 
19 

Box 2 – Poor use of indicators to assess the measure’s impact on 
wine growers’ competitiveness 

Four of the member states we visited defined additional  indicators for 
monitoring the restructuring measure. We found a lack  of consistency between 
the specific objectives and the corresponding indicators  set by them at the 
national level. Spain did not define any additional  indicators. 

The Czech Republic’s choice included: 

o 

o 

the number of hectares of restructured vineyards with varieties mainly 
from Czech breeding for the ‘ensuring biodiversity of plant species’ 
objective; 

the number of young beneficiaries for the ‘retention of young wine 
growers in the field’ objective. 

There are no quantified targets for these indicators, and it is unclear how the 
achievement of the intended objectives can be assessed through these 
indicators. 

France defined additional  output indicators with quantified targets for making 
wine growers more competitive, including: 

o 

o 

at least 70  % of the replanted surfaces applying for restructuring aid; 

the number of replanted grape varieties reaching 30 different grape 
varieties per year. 

These indicators  do not provide any information on how the measure 
contributes to the competitiveness objective. 

27 The Commission did not adequately document its assessment of the objectives 
set by member states in their NSPs for the measure, and it does not follow up in a 
systematic and structural manner the extent to which those objectives have been 
achieved. This is confirmed by an internal Commission audit carried out in 2022  that 
found weaknesses in the way the Commission assesses and uses the information the 
member states have submitted. The internal auditors highlighted the risk that the 
Commission may not be able to monitor the performance of interventions in the wine 
sector effectively. 

 
 
20 

28 Studies financed by the Commission for assessing ex post the impact indicate that 
the measure has been widely used over the last 20 years to improve efficiency and to 
develop new products geared to consumer demand 21. However, the Commission’s 
2020  evaluation of the support measures for the wine sector reported that “the extent 
to which national support programmes contributed to changes in productivity, costs 
and income could not be assessed in the evaluation support study. This was because 
the support received from these national  support programmes was either not 
reported, or was poorly reported, in the FADN database”. Nonetheless, the 
beneficiaries interviewed during the evaluation study acknowledged that the 
restructuring and investment measures contributed positively to their turnover, and 
subsequently improved their negotiating position in the supply chain 22. 

Implementation of the restructuring measure 

29 Member states may establish priority criteria  for the restructuring measure in 
order to select projects that are likely to contribute to achieving the objectives they 
set. Table 1 shows the priority criteria  set by the member states we visited. However, 
we found that eligible requests are funded regardless of content or ambition. Where 
demand exceeded the available budget, member states either applied a reduction 
coefficient to all  the requests, transferred funding from other NSP measures, financed 
the remaining applications  the following year or used priority  criteria that did not allow 
targeting the applications in line with the objectives of the measure. 

21  Évaluation des mesures appliquées au secteur vinicole dans le cadre de la Politique Agricole 
Commune, octobre 2012, COGEA srl; Study on the competitiveness of European wines, 
October 2014, COGEA srl. 

22  European Commission, Evaluation of the CAP measures applicable to the wine sector, 

SWD(2020) 232. 

 
 
 
Table 1 – Priority criteria for the restructuring measure in the member 
states we visited 

21 

Source: ECA, based on information received from the member states. 

(1) 

(2) 

In the Czech Republic, specific geographic areas and young farmers are incentivised by additional 
funding rather than by priority points. 

In France, restructuring as part of collective plans and farms with insurance are incentivised by 
additional funding rather than by priority points. 

(3) 

In Italy, specific geographic areas are incentivised by priority points and additional funding. 

 
 
 
22 

30 According to EU rules 23, the restructuring measure should fund the following 
structural changes: (1) varietal conversion (i.e. changing from one grape variety to 
another); (2) relocation; (3) an improvement in vineyard management techniques (in 
particular,  the introduction of advanced systems of sustainable production) or 
(4) replanting for health or phytosanitary reasons (see Figure 4). According to the 
Commission’s guidelines, the activities should involve major modifications to the 
vineyard. ‘Normal renewal’ – defined as replanting the same grape variety using the 
same cultivation  system on the same parcel – is not eligible. Moreover, the cost of 
grubbing up a vineyard is eligible only in the case of points (1) and (2) above. 

31 However, some member states have set up systems that may not always prevent 
the financing of non-structural changes or normal renewal (see Box 3). It means, in 
practice, that the restructuring measure speeds up the normal renewal of vineyards, 
for example by introducing  minor changes on less productive parcels. In addition, we 
found that two member states we visited finance restructuring activities  that do not 
adhere to Commission guidelines on eligible actions. France and Italy finance the costs 
of grubbing up a vineyard also where the restructuring project concerns only a minor 
density modification of the vineyard, and the same variety is replanted at the same 
location. 

23  Article 46 of Regulation (EU) No 1308/2013. 

 
 
 
23 

Box 3 – Some member states may use the restructuring measure to fund 
normal vineyard renewal, while others prevent it 

 In France, replanting the same variety with a density change of less than 10  % is 

not eligible under the restructuring measure. However, during our audit, out of 
143 parcels, we found 19 parcels that had been replanted with the same variety and 
with a density change of below 10 %. 

 In Italy (Tuscany), the complexity of the information system does not facilitate 
checks on identical  replanting or minor density changes, nor does it provide alerts if 
beneficiaries have amended or replaced applications. Thus, there is a risk of Italy 
funding restructuring activities with minor modifications compared to the situation 
before restructuring, such as changing  the clone. 

 In the Czech Republic, the way the checks are organised makes it easier to check 

changes in variety by clearly showing in the inspection report what the variety was 
before restructuring (checked on the spot before the parcel was grubbed up). 

 In addition to the mandatory checks (administrative checks of production and on-
the-spot checks), Greece requests justification from the wine grower if production has 
decreased over the previous two years. 

 As Spain (CLM) does not allow density modification  without changing the variety 

or the vine training  system, this prevents normal renewal from being funded. 

32 EU rules and eligible activities leave member states the flexibility to clarify  the 
restructuring measure further at national/regional level, as they see fit. Table 2 
provides an overview of eligible activities  in the member states we visited. Almost any 
type of activity  is eligible in three out of the five visited member states, and managing 
authorities do not assess whether or how the projects contributed to the 
competitiveness objective. Also, beneficiaries are not required to report on how the 
restructuring activity improved their competitiveness. 

 
 
Table 2 – Eligible activities in the member states we visited 

24 

Source: ECA, based on information received from the member states we visited. 

 
 
 
25 

The planting authorisation scheme is not linked directly to improved 
competitiveness 

Design of the planting authorisation  scheme 

33 When discussing the 2013 CAP reform, the European Parliament and the Council 
concluded that the 2008  CMO objective of ending the structural surplus of EU wine 
production had been attained 24. The Commission proposed that vine plantings should 
be liberalised, because it expected wine consumption on the world market to grow 25. 
However, fearing a repetition of the situation of oversupply (see paragraph 10), the 
European Parliament and the Council  opted to retain a control mechanism governing 
vineyard areas (see paragraph 11). The key principles of the new authorisation scheme 
for vine plantings, in effect since 2016,  are shown in Figure 8. 

Figure 8 – Authorisation scheme for vine plantings – main features 

Source: ECA, based on Regulation (EU) No 1308/2013. 

34 When the co-legislators proposed and adopted the maximum percentage of 1 %, 
no impact assessment was carried  out. There is no justification for this choice, nor any 
analysis of whether it is suited to each of the member states. There is no EU definition 
of orderly growth, and also the member states did not further define it. 

24  Recitals (54) and (55) of Regulation (EU) No 1308/2013. 

25  Proposal for a Regulation of the European Parliament and of the Council establishing a 
common organisation of the markets in agricultural products (Single CMO Regulation), 
COM(2011) 626, p. 7. 

 
 
 
 
26 

35 According to the EU Regulation, member states may apply a lower threshold if 
properly justified. Two wine-growing member states – Spain and Germany – did so, 
opting for 0.5 % and 0.3 % growth, respectively (in 2021  and 2022,  Spain lowered this 
to 0.1  %). In order to justify its choice, Spain assessed the potential production growth, 
taking into account various indicators:  the area actually  planted by variety and 
irrigation  system; changes in potential production, yields, prices, and demand. They 
found that wine production is not decreasing, and they do not expect an increase in 
internal wine consumption or exports. In addition, Spain justified its choice because 
there were many planting authorisations from previous years yet to be used (about 
3.6 % of the vineyard area), and both new planting and restructured parcels are 
increasing productivity/yields. 

36 While complying with the maximum 1 % growth of total national vineyard area, 
member states may also set limits  for certain production areas (expressed in maximum 
number of hectares), e.g. PDOs/PGIs (see Box 1), following a proposal from 
professional organisations. Therefore, the growth of vineyard area may considerably 
exceed 1 % at regional/local level (see Box 4) with potential social  or environmental 
consequences. Member states are not required to carry out an impact assessment in 
these cases. 

 
 
27 

Box 4 – Examples of production areas where vineyard area growth 
exceeds 1 % 

In France, the Charentes-Cognac basin has registered average area growth of 3 % 
per year since 2017.  In 2022,  France granted more than half of the area for new 
planting authorisations to producers in this area (see graph). This exponential 
growth is sustained by the strong export potential of Cognac (92 % exports). 

Area granted for new plantings in France in 2022 (ha)

3 129

5 844

0

500

1000

1500

2000

2500

3000

3500

4000

4500

5000

5500

6000

Total area granted

Area granted to Cognac

In Spain, the PDO Ribera del Duero area grew on average by 4 % a year, i.e. 
eight times the limit  set at national  level (see paragraph 35). For example, in 2020, 
of the 4 750 ha available, 837  ha were allocated  to this PDO (18 % of the total 
area). 

Area granted for new plantings in Spain in 2020 (ha)

837

4 750

0

500

1000

1500

2000

2500

3000

3500

4000

4500

5000

5500

6000

Total area granted

Area granted to Duero

Source: ECA, based on information received from the European Commission and the member 
states we visited. 

37 While the planting authorisation scheme places a cap on the total EU vineyard 
area, it does not limit production. In reality, the overall vineyard area has declined in 
the EU, but production has remained stable overall (see Figure 9). New vine plantings 
and restructuring of old vineyards can increase plant density and increase yields 26, 
increasing the risk of offsetting the scheme’s aim of avoiding oversupply. 

26  Special report 07/2012, paragraphs IX, 36-37. 

 
 
 
 
 
Figure 9 – Changes in EU wine area and production 

In 1 000 hl

200 000

175 000

150 000

125 000

100 000

75 000

50 000

28 

In 1 000 ha

3 700

3 600

3 500

3 400

3 300

3 200

3 100

3 000

2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021

Source: ECA, based on AGRIDATA. 

Vineyard area

Wine production

38 In order to avoid a decline in vineyard areas, the authorisation scheme was 
modified in 202127.  Member states can now decide to use as a basis for calculating  the 
1 % either the area planted with vineyards on 31  July 2015  plus the rights available for 
conversion, or the area planted with vines on 31  July of the previous year (whichever 
suits them best). 

Implementation of the planting authorisation  scheme 

39 For the purpose of granting new planting authorisations, member states may 
apply objective and non-discriminatory eligibility  criteria  at national or regional level 
(e.g. available area, applicants’ skills, and the risk of misappropriating  the reputation of 
quality wines – see Table 3). All eligible applications  are accepted if the total eligible 
requested area does not exceed the area actually  available. If the total area of the 
eligible applications  exceeds the area available  for planting, member states should 
decide on the number of hectares to distribute (i) on a pro-rata basis and (ii) according 
to priority  criteria (see paragraph 11). Some of these criteria  can favour 
competitiveness of wine growers, e.g.: 

27  Article 63.1(b) of Regulation (EU) No 1308/2013. 

 
 
 
 
29 

—  new entrants, including  young producers; 

—  areas to be newly planted for land consolidation  projects; 

—  areas to be newly planted which contribute to increasing the production of wine 
holdings that show increased competitiveness or presence on the market; 

—  projects with the potential to improve the quality of products with geographical 

indications; 

—  areas to be newly planted with a view to increasing  the size of small  and medium-

sized wine holdings. 

40 The member states we visited have chosen to use only few eligibility  and priority 
criteria  that are linked to competitiveness (indicated in bold in Table 3). France makes 
extensive use of the eligibility  criterion for protecting PDOs/PGIs (i.e. the risk of their 
reputation being misappropriated) 28. Each year, more than half of the requested vine 
area under new plantings is not allocated because the organisations representing 
geographical indications  propose limitations  on growth in their area (see Box 4). This 
link between the planting scheme and the wine quality schemes is also present in 
Spain. Greece and Spain prioritise  small and medium-sized holdings by using a scoring 
system. Some member states cap the surface that a wine grower can request (e.g. 
10 ha in Greece, 50 ha in Italy), while different thresholds per region might also apply 
in the same member state (e.g. Italy). 

28  Article 64(1)(c) of Regulation EU No 1308/2013. 

 
 
 
30 

Table 3 – Overview of implementation of the scheme in the member 
states we visited 

Country 

% applied 

Eligibility criteria 

Priority criteria 

Czech Republic 

1 % 

Agricultural area of the applicant 
should not be smaller than the 
area requested (net of existing 
vineyards) 

o  Projects with the potential 
to improve the quality of 
products with geographical 
indications 

France 

1 % 

Application shall not pose a 
significant risk of 
misappropriation of the 
reputation of a PDO/PGI 

Greece 

1 % 

Agricultural area of the applicant 
should not be smaller than the 
area requested 

Italy (Tuscany) 

1 % 

Spain 

0.1 % 

Agricultural area of the applicant 
should not be smaller than the 
area requested (net of existing 
vineyards) 

o  Agricultural area of the 
applicant should not be 
smaller than the area 
requested 

o  Applicant should possess 
adequate professional 
capacity 

o  Application shall not pose a 

significant risk of 
misappropriation of the 
reputation of a PDO 

o  Applicant has never planted 

vineyards without an 
authorisation 

o  Young new producer 
o  Prior behaviour 

o  Young new producer 
o  Preservation of the 
environment 

o  Areas facing natural 

constraints 

o  Areas that increase the size 
of small and medium 
holdings 

o  Prior behaviour 

o  Preservation of the 
environment 

o  Areas facing natural 

constraints 

o  Non-profit organisation 
with a social purpose 

o  Young new producer 
o  Prior behaviour 
o  Areas that increase the size 
of small and medium 
holdings 

Source: ECA, based on 2021 data received from member states and the Commission. 

 
 
31 

41 A drawback of the distribution  of new planting areas is that it can result in 
granting very small areas. Consequently, beneficiaries request a larger area than they 
actually  need to plant, knowing they will  get only a proportion of it (e.g. in Greece and 
Italy). At the same time, they may have to apply several years in a row in order to 
obtain an area that they consider worth planting, given the significant investment that 
new vine plantings entail. This mechanism affects business planning since it creates 
uncertainty for beneficiaries about the new area authorised for planting, thus making 
it difficult to plan ahead. 

42 A wine grower that receives authorisation for new planting cannot be granted aid 
from the restructuring and conversion measure for such planting 29, since the support 
measure is meant to restructure or convert an existing vineyard. However, some wine-
growing member states or regional authorities provide for financial  support for 
planting through the rural  development programme (e.g. France – Languedoc-
Roussillon 30). 

The EU’s wine policy falls short of CAP environmental 
objectives 

43 In line with the CAP objectives 31, the restructuring measure aims to “contribute 
to improving sustainable production systems and the environmental footprint of the 
wine sector” (further referred to as ‘environmental objective’), while the scheme 
should avoid excessive supply capacity with negative social  and environmental effects 
in specific wine production areas 32. We examined whether the restructuring measure 
and the planting authorisation  scheme contributed to the sustainable management of 
vineyards. We also looked at future challenges for the wine sector in the 2023-2027 
CAP 33. 

29  Section 4.2.1 of the Commission Guidelines on the NSPs; Article 7(1)(d) and Article 42(3) of 

Regulation (EU) 2016/1150. 

30  FranceAgriMer Montpellier, Les autorisations de plantations nouvelles, septembre 2021. 

31  Article 110(2)(b) of Regulation (EU) No 1306/2013; recital 94 of Regulation (EU) 2021/2115. 

32  Article 46(3) and recital 55 of Regulation (EU) No 1308/2013. 

33  Recital 94 of Regulation (EU) 2021/2115. 

 
 
 
32 

Little consideration for environmental sustainability in the restructuring 
measure 

Design of the restructuring measure 

44 The 2013  CAP reform introduced protecting the environment into the objectives 
of the wine CMO (see paragraph 08), building  on the CAP objective of sustainable 
management of natural  resources. For the restructuring measure, this meant, for the 
first time, an option to contribute to the environmental objective of the wine sector. 

45 Since 2008,  national support programmes have had to include an appraisal 
showing, among other things, the expected environmental impact 34. Our review of the 
NSPs of the member states we visited showed that this section did not really include 
the results of an impact  assessment, but rather a description of how the different 
measures, including  restructuring, could help to preserve the environment (see 
Figure 10). 

Figure 10 – Expected impacts on the environment from NSPs 

Protecting and 
Protecting and 
conserving 
conserving 
landscape
landscape

Avoiding land 
Avoiding land 
abandonment
abandonment

Guaranteeing quality and 
Guaranteeing quality and 
increasing farmers’ 
increasing farmers’ 
income through certified
income through certified
production, e.g. organic
production, e.g. organic

Adapting to climate 
Adapting to climate 
change
change

Source: ECA, based on the NSPs of member states we visited. 

Improving biodiversity
Improving biodiversity

34  Article 6 of Regulation (EC) No 479/2008. 

 
 
 
 
33 

46 The contribution of the restructuring measure to the environmental objective 
was optional, i.e. member states could decide whether it fitted within their strategy for 
the wine sector, which is included in the NSPs. We found that the strategic objectives 
the visited member states chose and the quantified targets they linked to them had 
little, if any, ambition  in terms of environmental sustainability  (see Figure 11). 

Figure 11 – Strategic objectives and corresponding targets linked to 
environmental sustainability 

Promote a better allocation of vineyards in 
compliance with the principles of sustainability
ITALY

Protection of the environmental and landscape 
value and of the cultural traditions related to wine 
production
ITALY

1 % of requests concern organic or 
local production

+ 5 % of restructured surfaces in 
areas with high landscape value

Make Greek wines more competitive, by making 
qualitative improvements to products to ensure
better market orientation
GREECE

10 % of total annual areas of 
vineyards dedicated to organic, 
integrated production or 
PDOs/PGIs

Support socially and environmentally sensitive 
areas, such as island areas, with an emphasis on 
preserving the environment and the aesthetic value 
of rural landscapes
GREECE

>30 ha of annually restructured
areas in the islands of the Aegean
Sea

Support technical developments outside contextual
planting
FRANCE

1 500 ha/year with operations
linked to irrigation systems

Transfer vineyards to a slope
CZECH REPUBLIC

None
SPAIN 

>10 ha moved to a slope

None

Source: ECA, based on NSPs, section G on objectives, indicators and targets. 

47 The indicators  that are used relate to output, rather than results or impact, and 
so they do not provide information on the outcome of the measure. Several of them 
are only partially  relevant for the objective, and the targets are set very low. As a 
result, they do not provide information about any environmental improvement. For 
example, none of the indicators  concerning organic or integrated production show 
how many farmers converted to such cultivation  techniques. In the case of Greece, 
organic and integrated production count together with PDOs/PGIs, meaning that the 
quantified target could be achieved with just the latter. The French authorities have 

 
 
 
34 

chosen an indicator  on the number of irrigation  operations, and achieving the target 
might actually have negative effects on the environment (see paragraph 54). The Czech 
Republic has two additional  environmental objectives (for ensuring biodiversity and 
sustainable production) which were not included in Figure 11, as the Czech Republic 
did not set quantified targets for them. 

48 Environmental care is valued by wine consumers, together with quality and 
reputation. This is confirmed by a study that also states there is room to increase 
competitiveness by targeting a more environmentally-conscious audience 35. In its 
examination and validation of the NSPs, the Commission did not assess the 
environmental ambition of NSPs and did not follow up on the achievement of any of 
the additional indicators.  Additionally, the Commission did not provide a definition of 
sustainability  or sustainable production systems; nor did it explain in its guidelines for 
implementing the NSPs how the measure could be used to reduce the environmental 
footprint of the wine sector, or even how to calculate it. 

49 The restructuring measure (as well as the whole wine CMO) is subject to a high 
level of subsidiarity, where member states are free to decide about strategy (see 
paragraph 46), objectives and indicators  (see Figure 11), the measures they propose 
within their NSPs, and how to define the types of sub-actions eligible for financing. 
Contrary to other EU funds (e.g. the European Agricultural  Fund for Rural Development 
(EAFRD)), the wine CMO does not require any co-financing from member states. This in 
turn might not provide a sufficient incentive for member states to develop a proper 
strategy and pursue environmental targets. 

Implementation of the restructuring measure 

50 Member states may disburse the available funds on the basis of priority  criteria, 
favouring projects showing a potential positive contribution to achieving the 
environmental objective. The Commission guidelines do not offer particular  examples 
in this regard. In reality, the relevance of the priority  criteria is low, as almost all 
projects are financed anyway (see paragraph 29). Of the five member states we visited, 
only three made use of such criteria: 

o  Greece and Spain (CLM) decided to apply the “areas where vineyards contribute 
to the preservation of the environment” criterion by prioritising  organic farming 
or integrated production practices, or to protect old vineyards; 

35  Agrosynergie EEIG and European Commission, Evaluation of the CAP measures applied to 

the wine sector, 2019. 

 
 
 
35 

o  Greece and Italy (Tuscany) decided to prioritise “areas facing natural  or other 
specific constraints”, which cover terraces, steep slopes, etc. According to the 
Commission, this criterion can also be used to preserve the environment and 
traditional  landscape features. 

51 The projects we visited relating to the restructuring measure show little 
consideration in practice for improving sustainable systems or the environmental 
footprint of the wine sector, new varieties to be planted are chosen mainly based on 
predictions of future market demand (see Box 5). In certain regions, organic or 
integrated production is seen as a way to respond better to market demand and 
increase farmers’ income in addition to their environmental benefits. 

Box 5 

The example of Airén 

Airén is a traditional  Spanish grape variety, particularly  common in Castilla-La 
Mancha where it covered almost 200  000 hectares in 2020/2021.  Known for its 
resistance to extreme heat and drought, it grows easily and does not require much 
care 36. 

Between 2017  and 2022,  the authorities of Castilla-La  Mancha excluded Airén 
from the list of available varieties for the restructuring measure in order to favour 
varieties such as Syrah that better respond to market expectations. The 
Commission supported CLM in its decision, believing that Airén could be replaced 
by varieties with a better sale price. They concluded that the beneficiaries’ 
turnover would increase. 

This decision, which may have had negative environmental impacts, was reverted 
in 2023.  Airén is better suited to local  climate conditions, while other varieties 
such as Syrah can be more demanding in terms of water. 

36  Airén: características, Vinos de Castilla-La Mancha MEDIA. 

 
 
 
36 

Airén, bush vines, CLM 

Source: ECA, 2022. 

52 The restructuring measure could also finance the improvement of management 
techniques, where the link with sustainability should be stronger: the Regulation says 
this action should be used “in particular  [for] the introduction of advanced systems of 
sustainable production”37. However, projects are not assessed or selected in terms of 
their environmental ambition. In particular,  the proposed improvements do not 
usually involve any environmental commitment, or a description of how the changes 
should deliver on the objective of improving the sustainability  of the systems or the 
environmental footprint. The 2018  evaluation confirmed that “operations aiming at 
improving practices from an environmental and climate point of view were not 
supported by member states”38. 

37  Article 46(3) of Regulation (EU) No 1308/2013. 

38  Agrosynergie EEIG and European Commission, Evaluation of the CAP measures applied to 

the wine sector, 2019, p. 61. 

 
 
 
 
37 

53 Wine grapes have traditionally  been a dry crop, and irrigation  was not considered 
essential. In France, for most PDOs/PGIs, irrigation  is allowed only in exceptional 
circumstances. However, under the restructuring measure, the improvement of 
management techniques can also be used to fund irrigation  systems (in France and 
Italy). Such projects are approved as long as the eligibility  criteria  are met and funds 
are available. 

54 While irrigation  can be considered an adaptation measure, water availability 
should also be taken into account, as should studies on the feasibility of the 
transformation of vineyards from dry to irrigated  crops. A positive aspect of irrigation 
is certainly its capacity to stabilise wine growers’ yields, and thus production. However, 
under the CMO, the installation  of an irrigation  system – whether funded or not – is 
not linked to any environmental commitment, e.g. no increases in water use. The 
implementing rules do not set any clear conditions or environmental safeguards for 
water availability  or savings. 

55 In all  the member states we visited, we found examples of improved 
sustainability  in vineyard management. These concerned the use of chemical 
substances (pheromones) to prevent the reproduction of moths or the planting  of 
vegetation between vine rows to reduce soil erosion and improve biodiversity and soil 
structure. Such installations, however, did not result directly from specific 
requirements set in the restructuring measure’s calls  for projects. In some cases, 
additional  funding opportunities (e.g. via the EAFRD) were available in member states 
to support these practices. Due to the design of the EAFRD, the Commission does not 
have an overview of the extent to which EAFRD measures – such as agro-environment-
climate measures or organic  farming – are used by the wine sector, or how much 
support is granted to wine growers. 

56 Under the CMO, neither the Commission nor the member states set up a system 
for monitoring environmental performance. As a result, it is not possible to assess the 
impact of the EU framework for vineyards on the environmental objective or 
ultimately on the sustainable use of natural resources. 

 
 
38 

The environmental effects of the planting authorisation scheme are 
unknown 

Design of the planting authorisation  scheme 

57 The progressive increase in vineyard areas was not assessed from an 
environmental perspective, despite the existence of earlier studies (e.g. on the impact 
on landscape, on land-use change 39, and on turning to monoculture 40). In addition, 
although the planting  authorisation scheme was initially  planned to run from 2016 
until 2030,  it was extended in 2021  by an additional 15  years. It will now last until 
2045.  No impact assessment to account, among other things, for the environmental 
consequences of the scheme was carried out before this extension was made. The 
legislation  envisaged an intermediate review of the scheme in 2023  in order “to 
evaluate the operation of the scheme and, if appropriate, make proposals”41. This has 
been changed: now the first review is scheduled only for 202842. 

58 The CMO Regulation acknowledges the possible negative social  and 
environmental effects of excessive supply capacity.  This can result from an increase in 
vineyard area (see paragraph 43). However, the extent to which the scheme prevents 
negative consequences for the environment has never been assessed. 

59 A 2021  change in the rules governing the scheme 43 may have a positive 
environmental impact. The validity of planting authorisations  has been extended from 
three to six years where planting takes place on the same parcel of land. This allows 
producers to delay the planting  of vineyards in order to let the soil rest and improve its 
sanitary conditions with fewer chemical  inputs. 

39  Martínez-Casasnovas, et al., Influence of the EU CAP on terrain morphology and vineyard 

cultivation in the Priorat region of NE Spain, 2010. 

40  Altieri and Nicholls, The simplification of traditional vineyard-based agroforests in 

Northwestern Portugal: some ecological implications, 2002. 

41  Article 61 of Regulation (EU) No 1308/2013, initial legal act. 

42  Article 61 of Regulation (EU) No 1308/2013, consolidated version of 7 December 2021. 

43  Regulation (EU) 2117/2021, Recital (15). 

 
 
 
39 

Implementation of the planting authorisation  scheme 

60 When wine growers are granted authorisation to plant new vineyards, the 
legislation  proposes only one priority criterion  that has a direct link to the 
environmental objective 44. Member states in the EU can give priority  to those 
applications  that concern areas where vineyards contribute to preserving the 
environment or to conserving the genetic resources of vines. With the exception of 
Greece (since 2016),  Italy (since 2017)  and Austria (since 2021),  none of the other 
wine-producing member states has used this criterion. Most authorisations are 
distributed using a pro-rata system (see paragraph 39), even in those member states 
that have set priority criteria. 

61 While the Commission has an overview of the implementation of the scheme at 
national or regional level, the reporting obligations do not aim to and, therefore, are 
not sufficient to assess whether the scheme has a negative impact on the 
environment. 

Environmental ambition of the EU wine policy remains low 

62 From November 2023  onwards, wine measures will be included in the CAP 
Strategic Plans. The Strategic Plan Regulation introduces a revised set of 11  objectives 
for the wine sector, including one with a clear environmental and climate  component, 
“contributing  to climate change mitigation  and adaptation and to the improvement of 
the sustainability  of production systems and the reduction of the environmental 
impact of the wine sector, also by supporting wine growers in reducing the use of 
inputs and implementing more environmentally friendly sustainable methods and 
cultivation  practices”. 

63 It is up to the member states to link this environmental and climate objective to 
the measures. Ten out of 15 member states whose CAP Strategic Plans include 
restructuring support for the wine sector linked the restructuring measure to this 
environmental and climate  objective. If member states choose this objective, 
restructuring projects should pursue at least one relevant action, such as reducing 
inputs, limiting  water use, avoiding soil erosion, or protecting/improving the 
environment45. 

44  Article 64(2)(b) of Regulation (EU) No 1308/2013. 

45  Article 12 of Commission Delegated Regulation (EU) 2022/126. 

 
 
 
40 

64 Since 2013,  funding for restructuring has been linked to compliance with specific 
environmental obligations (also known as ‘cross-compliance’) 46. They comprise 
requirements from EU rules on the environment (such as record keeping of purchase 
and use of plant protection products), and standards imposing sustainable agricultural 
practices (such as complying with water abstraction authorisation  procedures). 
Farmers that are found not to comply with these requirements may face a reduction in 
their EU funding. According to the Commission, cross-compliance raises awareness of 
farmers regarding the need to comply with certain basic standards and it makes the 
CAP more compatible with the expectations of society. 

65 In the 2023-2027  period, the application  of cross-compliance (now part of 
‘conditionality’) to funding for restructuring has been discontinued 47, lowering the 
environmental ambition of the EU wine policy. In the past, we recommended linking  all 
CAP payments to farmers, including  those made through the common market 
organisation, to explicit environmental requirements, such as conditionality 48. 

66 Member states will have to use at least 5 % of the expenditure earmarked for the 
wine sector on interventions linked to objectives such as protecting the environment, 
adapting to climate  change or improving the sustainability  of production systems, or 
reducing the environmental impact  of the wine sector49. This is a rather low share 
compared to other sectors, such as fruit and vegetables. In the context of a greener 
CAP, 40 % of its expected expenditure should target climate-related objectives (see 
Figure 12). 

46  Article 92 of Regulation (EU) No 1306/2013. 

47  Article 2 of Regulation (EU) 2021/2115. 

48  Special report 20/2021, recommendation 2(b). 

49  Article 60(4) of Regulation (EU) 2021/2115. 

 
 
 
Figure 12 – Comparison of dedicated expenditure on climate and the 
environment 

41 

* The Regulation states that at least 40 % of the CAP expected expenditure should target climate-related
objectives.

Source: ECA based on Regulation (EU) 2021/2115. 

67 In the five member states we visited, none of the draft CAP Strategic Plans
described which measures would contribute to the 5 % target for climate and the 
environment. The Commission addressed this issue in its assessment of the plans 50. 
Our review of the approved plans revealed that: 

o

o

Greece, France and Italy’s strategies emphasised the need to adapt their
vineyards to climate  change. However, they intend to implement the
restructuring measure in the same way as they did in their NSPs, i.e. by fostering
competitiveness. France and Italy plan to make exclusive use of the by-product
distillation  measure to reach the 5 % figure. By-products from wine making –
when not appropriately disposed of – can be harmful for the environment. Greece
intends to use the 5 % for investments in sustainable wine production;

Spain, by contrast, prefers to reach the 5 % with the restructuring, by-product
distillation,  and investment measures. Its plan also requires compliance  with the
Water Framework Directive, does not finance irrigation  systems, and focuses on
integrated production;

50  Observation letters to the Czech Republic, Greece, Spain, France, and Italy. 

42 

o 

the Czech Republic intends to cover the 5 % target in full with the ‘varietal 
conversion’ sub-action component of the restructuring measure. Wine growers 
can convert to new varieties that are better suited to changing  climate conditions 
in order to make their production more resilient. 

68 From 2023  onwards, funding for investments in irrigation,  which could be eligible 
under the restructuring measure, will have to meet stricter requirements 51. Projects 
should commit to minimum water-saving targets; they cannot lead to a net increase in 
the irrigated area, except under clearly defined conditions, such as a positive 
environmental impact assessment, and must comply with the Water Framework 
Directive requirements. 

69 PDO/PGI production covers 82 % of the EU vineyard area (see paragraph 03). 
Applicable EU rules have been evolving: 

o 

o 

since 2021,  planting hybrid varieties of crosses of Vitis vinifera for both PDOs and 
PGIs has been allowed so as to enable producers to use vine varieties that are 
better suited to changing climate conditions and are more disease-resistant52; 

the ongoing reform of the PDO/PGI Regulation 53 seeks to encourage producers of 
PDO/PGI wines to follow higher standards for economic, social and environmental 
sustainability. 

70 Given that PDO/PGI wines account for most EU production, this reform has the 
potential to make wine growing in the EU more sustainable. However, uptake is 
voluntary and may remain limited. During our visits to the member states, we 
observed that wine growers hesitate to use these new varieties. 

51  Article 11 of Regulation (EU) 2022/126. 

52  Recital 28 of Regulation (EU) 2021/2117. 

53  Commission’s proposal on geographical indications, COM(2022) 134. 

 
 
 
 
 
43 

Conclusions and recommendations 

71 Through its wine policy, the EU supports wine growers with around €0.5  billion 
per year to restructure their vineyards, the main aim being to make them more 
competitive. The scheme for planting  authorisations intends to limit  the growth of vine 
plantings in order to avoid structural production surpluses. We found that this policy 
framework for making wine growers more competitive has shortcomings in terms of 
design and implementation, and falls short of the common agricultural  policy’s 
environmental objectives. 

72 Studies and evaluations indicate that EU support for the wine sector, including 
the restructuring measure, is conducive to competitiveness. However we found that: 

o 

o 

o 

o 

o 

o 

the Commission has not defined clearly, or collected and analysed data, on how 
the restructuring measure should contribute to that objective (paragraphs 24 and 
26); 

the member states we visited have not defined how the restructuring will  foster 
the competitiveness of wine growers, and have not developed a coherent 
strategy or established relevant indicators  for the 2014-2023  period to assess the 
impact of the restructuring measure on competitiveness (paragraphs 25-26); 

the member states we visited funded eligible requests, regardless of content or 
ambition, and did not use criteria to select projects which foster competitiveness 
(paragraphs 29 and 32); 

some member states we visited funded projects that do not entail a structural 
change, but rather accelerate the normal renewal of vineyards, something which 
is not eligible for EU support (paragraphs 30-31); 

the Commission did not document its assessment of the objectives set by 
member states nor follow up in a systematic way the extent to which those 
objectives have been achieved (paragraph 27); 

the member states we visited did not assess how the projects contribute to the 
competitiveness objective, and beneficiaries are not required to report on the 
outcome of their restructuring activity, or how it made them more competitive 
(paragraph 32). 

 
 
44 

73 The planting authorisation scheme aims to avoid oversupply by limiting  area 
growth to 1 % per year. However, we found that: 

o 

no impact assessment was carried  out before the co-legislators proposed and 
adopted the maximum percentage of 1 % growth of vineyard area at national 
level (paragraph 34); 

o  member states may allow growth well above 1 % at regional/local  level, and they 
are not required to carry out an assessment to evaluate its impact (paragraph 36); 

o 

the planting authorisation scheme places a cap on the total EU vineyard area, but 
it does not limit production, which risks offsetting the scheme’s aim of avoiding 
oversupply (paragraph 37); 

o  when granting authorisations, the member states we visited use only a few 

eligibility  and priority criteria  that are linked to competitiveness (paragraph 40); 

o 

allocating  new planting authorisations on the basis of pro-rata distribution may 
hamper the competitiveness objective in some member states where 
beneficiaries are granted very small areas and cannot plan ahead (paragraph 41). 

Recommendation 1 – Better target the measure and the 
scheme to foster competitiveness 

The Commission should: 

(a)  clarify what the competitiveness of EU wine producers entails so that the 

achievement of the main objective of the restructuring measure can be assessed; 

Target implementation date: Q1 2026 

(b)  provide observations to member states, as envisaged in the CAP Strategic Plan 

Regulation in the context of annual performance reporting and/or amendments 
to the CAP Strategic Plans, when the requirements of the restructuring measure 
do not effectively contribute to the competitiveness objective; 

Target implementation date: 2025 

(c)  assess, together with member states, the implementation of the measure and the 

scheme in order to identify and share good practices and risks. 

Target implementation date: 2026  for the measure, 2028  for the scheme 

 
 
45 

74 One of the aims of the common agricultural  policy is to manage natural  resources 
sustainably. However, wine policy has taken environmental protection on board only 
partially.  Despite the large amount of funding involved, the restructuring measure 
missed the opportunity to contribute to a key goal for the EU. We found that: 

o 

o 

o 

o 

the member states we visited did not assess the expected environmental impact 
of their national  support programmes for the wine sector. Their strategic 
objectives and targets showed little ambition in terms of environmental 
sustainability  (paragraphs 45-46); 

the Commission did not provide the wine-producing member states with 
guidance on how to define sustainability  or sustainable production systems, or 
how to use the restructuring measure for reducing the environmental footprint of 
the wine sector. In addition, it did not follow up the extent to which the indicators 
set by the member states had been achieved (paragraph 48); 

the national support programmes are fully funded by the EU, without any co-
financing from the wine-producing member states. Nevertheless, member states 
have significant discretion in defining their strategies, objectives and indicators 
for the wine sector, and there are few or no environmental restrictions or 
requirements (paragraph 49); 

although some of the member states we visited used criteria  to prioritise projects 
making a positive potential contribution to the environment, almost all  projects 
are funded in practice. As a result, financed projects do not aim to reduce the 
climate-related and/or environmental impact of wine growing. Indeed, under 
certain circumstances, they could even have the opposite effect, such as 
switching to varieties that need more water, or installing  an irrigation  system 
(paragraphs 50-54). 

75 The planting authorisation scheme was introduced in 2016  and extended by the 
co-legislators in 2021  without any assessment being carried out. It is impossible to 
determine the extent to which the scheme could prevent negative consequences for 
the environment (paragraphs 57-58). 

 
 
46 

76 Environmental ambition for the wine sector remains low in the 2023-2027 
programming period. Cross-compliance – a mechanism whereby payments to farmers 
depend on their meeting requirements in areas such as the environment and land 
management – has been discontinued for the restructuring measure. Also, member 
states need to spend only a minimum of 5 % of the wine allocation  towards 
environment and climate objectives (compared to 15  % for fruit and vegetables, and 
the 40 % climate  target for the common agricultural  policy as a whole; 
paragraphs 65-67).  On the other hand, funding for irrigation  has to meet stricter 
requirements, and the intention is to move towards new varieties and more 
sustainable production systems. However, uptake is voluntary and may remain limited 
(paragraphs 69-70). 

Recommendation 2 – Increase the environmental ambition of 
the wine policy 

The Commission should: 

(a)  assess whether the minimum 5 % share of earmarked wine expenditure required 
to be spent on the climate and the environment is appropriate in light  of the 
ambition for a greener CAP; 

Target implementation date: Q2 2026 

(b)  for the restructuring measure, facilitate  the exchange of best practices and 

disseminate the results for the protection of the environment; 

Target implementation date: 2026 

(c) 

for the authorisation scheme, assess, in the context of the planned mid-term 
review, the extent to which the scheme impacted the environment; 

Target implementation date: 2028 

(d)  provide observations to member states, as envisaged in the CAP Strategic Plan 

Regulation in the context of annual performance reporting and/or amendments 
to the CAP Strategic Plans, when the requirements of the restructuring measure 
do not effectively contribute to the environmental objective. 

Target implementation date: 2025 

 
 
This report was adopted by Chamber I, headed by Ms Joëlle Elvinger, Member of the 
Court of Auditors, in Luxembourg at its meeting of 12  July 2023. 

47 

For the Court of Auditors 

Tony Murphy 
President 

 
 
 
 
 
 
 
 
48 

Abbreviations 

CAP: Common agricultural  policy 

CLM: Castilla-La  Mancha 

CMO: Common market organisation 

NSP: National  support programme 

OIV: International Organisation  of Vine and Wine 

PDO: Protected designation of origin 

PGI: Protected geographical indication 

 
 
 
 
49 

Glossary 

Common agricultural  policy: The EU’s single unified policy  on agriculture, comprising 
subsidies and a range of other measures to guarantee food security, ensure a fair 
standard of living  for the EU’s farmers, promote rural development, and protect the 
environment. 

Cross-compliance: Mechanism whereby payments to farmers depend on their meeting 
requirements on the environment, food safety, animal health and welfare, and land 
management. 

Integrated production: Agricultural  approach that takes account of all  aspects of 
economic, environmental and social sustainability. 

Organic farming: Agricultural  approach based on the use of natural substances and 
processes to produce food and feed. 

Parcel relocation: One of the eligible activities of the restructuring measure, which 
consists in moving a vineyard parcel to a different location, by grubbing up the plants 
and planting  a new vineyard elsewhere. 

 
 
 
 
50 

Replies of the Commission 

https://www.eca.europa.eu/en/publications/sr-2023-23 

Timeline 

https://www.eca.europa.eu/en/publications/sr-2023-23 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
51 

Audit team 

The ECA’s special reports set out the results of its audits of EU policies  and 
programmes, or of management-related topics from specific budgetary areas. The ECA 
selects and designs these audit tasks to be of maximum impact  by considering the risks 
to performance or compliance, the level of income or spending involved, forthcoming 
developments and political  and public interest. 

This performance audit was carried  out by Audit Chamber I Sustainable use of natural 
resources, headed by ECA Member Joëlle Elvinger. The audit was led by ECA Member 
Joëlle Elvinger, supported by Ildikó Preiss, Head of Private Office and Paolo Pesce, 
Private Office Attaché; Ramona Bortnowschi, Principal  Manager; Els Brems, Head of 
Task; Antonella Stasia, Deputy Head of Task; Nicholas Edwards, Vincenza Ferrucci, 
Lenka Hill,  and Dimitrios  Maniopoulos, Auditors. Jindrich Dolezal, Mark Smith and 
Efstratios Varetidis provided linguistic  support. Marika Meisenzahl provided graphical 
support. 

From left to right: Efstratios Varetidis, Marika Meisenzahl, Paolo Pesce, Joëlle Elvinger, 
Antonella Stasia, Nicholas Edwards, Vincenza Ferrucci, Ildikó Preiss, 
Ramona Bortnowschi. 

 
 
 
 
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2 

The EU provides wine growers with support for vineyard restructuring 
to make them more competitive. This could also improve sustainable 
production and the environmental footprint of wine growing. Wine 
growers need to obtain authorisation before planting new vineyards, 
which are limited in number, so as to avoid excessive supply with 
negative social and environmental effects. We found that EU support 
has an unclear impact on the competitiveness of wine growers. There 
are flaws in the design and implementation of the planting 
authorisation scheme, and the EU’s wine policy falls short of common 
agricultural policy’s environmental objectives. We recommend that the 
Commission should target the EU’s actions better to foster 
competitiveness of wine growers and increase the environmental 
ambition of the wine sector. 

ECA special report pursuant to Article 287(4), second subparagraph, 
TFEU.