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  • EP’s Environment Committee CAP vote is a Valentine’s Day letter encouraging the sector to work WITH

    - Français - Español - The European Parliament’s Committee on the Environment, Public Health and Food Safety (COM ENVI) has today adopted an opinion on the reform of EUs Common Agricultural Policy (CAP). PAN Europe, Arche Noah and BeeLife welcome the vote and emphasise that by lifting the environment, health and climate ambitions of the CAP reform, COM ENVI has contributed to create longer term perspectives for both farmers and all EU citizens and taxpayers. EU agriculture should work with nature not against it. This is the main message of COM ENVI’s opinion on the CAP strategic plan voted today. COM ENVI proposes to reinforce the conditionality that farmers need to comply with to receive 100% CAP direct payments in the future. The opinion emphasises some of the best alternatives to using pesticides: good agronomic practices. The opinion proposes opening up several instruments allowing farmers to finally start applying Integrated Pest Management as foreseen in the EU’s Directive on Sustainable Use of Pesticides (1). Specifically, the opinion updates the so-called Good Agricultural and Environmental Conditions (GAEC) and the Statutory Mandatory Requirements (SMRs) which are conditional on receiving full CAP direct payments to farmers, but also proposes to upgrade the CAP-funded Farm Advisory Services so that they offer independent assistance to farmers taking up alternatives pest control techniques (2). The GAEC rules adopted by COM ENVI foresee: applying four years’ crop rotation with legumes, while encouraging farmers to build up functional biodiversity (pollinators, predators of pests) by integrating nature aspects into their fields, and protect water bodies from pesticides. It also foresees that farmers receiving direct payments need to prepare input management plans (3). The SMRs adopted by COM ENVI foresee that payments will be conditional upon keeping records of pesticide use for three years (4). This is key to measure progress in reducing pesticide dependency, allowing member states to set objectives for pesticide use reduction in their CAP plans. “Negotiations in the lead Agriculture Committee (COM AGRI) are ongoing; because of shared competence over environmental aspects, COM AGRI is obliged to take these issues on board. By introducing a planning aspect and putting focus on functional biodiversity and crop rotation, COM ENVI is contributing in farming becoming part of the solution to our nature crisis (5) driven by pesticide use. We urge COM AGRI to follow COM ENVI’s ambitious line. ” says Henriette Christensen, PAN Europe’s Senior Agriculture Advisor. Notes: (1) The Directive 2009/128/EC on sustainable use of pesticides Directive (SUD) foresees that Member States set up systems to assist farmers financially and technically in uptake of non-chemical alternatives and agro-ecological practices, and in this way encourage farmers to apply Integrated Pest Management and reduce their dependency on pesticides. A European Commission report (COM(2017) 587 final) on implementation of the SUD says: Integrated Pest Management is a cornerstone of the Directive, and it is therefore of particular concern that Member States have not yet set clear targets and ensured their implementation, including for the more widespread use of land management techniques such as crop rotation. The following compromise amendment was adopted in article 15 of the CAP strategic plans, including: The farm advisory services shall cover at least the following: transition to and maintaining agro-ecological practices, including agroforestry; Farm Sustainability Tool for Nutrients and Input Reductions The Good Agricultural and Environmental Conditions (GAEC) have been updated adding the part in bold to the European Commission text: GAEC 4: Establishment of buffer strips along water courses with a minimum width of 3 m and on which no fertilisers and plant protection products may be used Reason: Protection of river courses, pollinators, water supplies and aquatic species or ecosystems against pollution, toxicity and run-off GAEC 5: Use of Farm Sustainability Tool for Nutrients and Input Reduction Reason: Sustainable management of nutrients, pesticides and veterinary products, as appropriate to the size and intensity of the holding GAEC 8: Minimum four years crop rotation including a leguminous crop Reason: Preserve the soil potential GAEC 9: Minimum share of 7 % of agricultural area devoted to non-productive features or areas where no synthetic pesticides and fertilisers are used Reason: Maintenance of non-productive features and area to improve on-farm biodiversity including functional biodiversity and beneficial species The opinion updated the Statutory Mandatory Requirements (SMRs) so that now SMR 12 is respect of articles 55 and 67 of Regulation 1107/2009 on placing of plant protection products on the market, meaning farmers need to apply legal pesticides and record pesticides use for three years. Adding this aspect to SMR 12 is crucial in building up EU indicators on pesticide use:The European Commission has proposed to add a new SMR, SMR 13, relating to Directive 2009/128/EC on sustainable use of pesticides (SUD), see here, but failed to include Integrated Pest Management, which according to the SUD is mandatory as from January 2014. Instead, the Commission proposed to add other aspects (Art.5(2), Art.8(1-5), Art.12 and Art.13(1) and (3).COM ENVI has added article 14 to the list of articles covered by SMR13. “Plummeting insect numbers 'threaten collapse of nature'” Guardian, 10 February 2019, https://www.theguardian.com/environment/2019/feb/10/plummeting-insect-numbers-threaten-collapse-of-nature CONTACT : Pesticide Action Network Europe (PAN Europe), Henriette Christensen, +32473375671, henriette@pan-europe.info BeeLife European Beekeeping Coordination , Andrés SALAZAR, +32 492 53 99 77, comms@bee-life.eu ARCHE NOAH (Noah’s Ark) Seedsavers’ Association , Goncalo Macedo, + 32 (0) 497 068 396, goncalo.macedo@arche-noah.at

  • Open Letter for a More Just and Sustainable CAP

    Several organisations have joined together to ask the European Parliament to work for a more ambitious Common Agricultural Policy. BeeLife has co-signed the letter, as it stresses the importance of working towards a more sustainable way to produce our food in Europe. The open letter has been originally published in Good Food Good Farming's website . You may also continue reading below, as we re-publish the letter letter addressing Members of the European Parliament. _______________________________________ Dear Members of the European Parliament, We ‒ farmers, bee-keepers, cooks, civil society organisations, activists, consumers, young and old from urban and rural areas across Europe ‒ are calling on you to serve up a better future for farming. We face a climate and ecological emergency and massive loss of small farming communities across Europe. Without deep reforms of the EU’s Common Agricultural Policy (CAP) and a move towards coherent policies for sustainable European agri-food systems, we will not be able to farm and consume food in a healthy and environmentally-friendly way, that is low in emissions and socially acceptable. Science, including the latest IPBES* and IPCC* reports, tells us that we must act urgently and decisively to prevent further catastrophic climate shift and the collapse of biodiversity. All evidence, including the European Commission’s own assessments, shows that the current CAP fails farmers, the climate and nature. It is unable to secure fair revenues and generation renewal, it fails to protect diverse, small-scale farms from bankruptcy, land grabbing, speculation and urbanisation. It fails animal welfare and biodiversity. It escalates unsustainable trade between the EU and other countries, notably of the Global South. And ultimately, it threatens food sovereignty. During the European elections this year, many young and concerned citizens across Europe put their faith in you.They demand sustainable and socially-just solutions, not business as usual. Many thousands across Europe have rallied in support of fair and sustainable food production, not least at the 75 events in 21 countries during the ‘good food good farming days’ this October. Today, [hundreds] have come to Strasbourg ‒ carrying the calls of thousands more ‒ to ask you to change the current food and farming systems.  The post 2020 CAP must bring answers to the ecological, social and economic challenges we face. We urge you to use your Parliamentary mandate to work towards a new CAP that will tackle the climate crisis, reverse the rapid loss of biodiversity, ensure healthy and sustainable consumption and production. It must deliver quality rural employment and decent livelihoods for our farmers and rural communities, protecting them from harmful pesticides. Farmers, globally, are among the first to suffer from the impact of climate breakdown, biodiversity collapse and soil degradation. We call on all Members of the European Parliament to distance yourselves from the business-as-usual attitude of earlier reform negotiations. Time is running out. You must accelerate and finance an agricultural transition in farming to: + End the loss of small-scale community-based farming and deliver decent working conditions for farmers and farm workers globally with a CAP that combats market imbalances and injustices.  + Stop blind per-hectare farm payments and replace them by targeted funding and support that promotes the transition to more sustainable systems such as organic farming and agroecology. Public money must be spent on public goods, serve communities and consumers; not corporate profits.  + Tackle the climate crisis, restore soil-fertility and biodiversity, protect water, reduce energy- and chemical dependencies, and promote animal welfare while reducing the current unsustainable levels of production and consumption of animal products. + Prioritise seasonal, local and fair production of fruits, vegetables, grains, dairy and meat products ensuring access to healthy, nutritious, and affordable diets for all. Many organisations stand ready to work with you constructively to make the necessary changes in the CAP, the budget and other relevant instruments necessary to restore good food and good farming. * IPBES – Intergovernmental Platform on Biodiversity and Ecosystem Services * IPCC – Intergovernmental Panel on Climate Change INITIATORS ALSO SUPPORTED BY

  • Joint Letter to EU Commission on EFSA Bee Guidance Document and Specific Protection Goals

    It has been more than seven years of political blocage for adopting the European Food Safety Authority's (EFSA) Guidance on the risk assessment of plant protection products on bees (Apis mellifera, Bombus spp. and solitary bees). This document aimed at improving risk assessment of the effects of pesticides on non-target species, particularly on bees. At the moment, EFSA is presenting some new developments on its Bee Guidance Document for risk assessment following requests by the Member States. Unfortunately, the advances so far are troubling and may represent weak protection for bees. The latest developments for the future of the Bee Guidance document present significant deficiencies to ensure the future protection of bees. This deficiency is a severe risk for the European Commission's engagement to halt and reverse the decline of pollinators, as indicated in the EU Pollinators Initiative, and its other environmental objectives in the Biodiversity and Farm 2 Fork strategies. We highlight two primary deficiencies of the current development for future risk assessment. First, EFSA's current proposal depends on a colony development modelisation that is unreliable. It uses the Beehave model, which cannot correctly assess and predict the colony's real development and the interaction with external stressors. Fortunately, there is still an opportunity to replace this unpromising Beehave model with the ApisRAM model, currently under development by EFSA and expected to be put to the test later this year. A second major challenge is that the new rules for risk assessment would need to adequately address the current system's insufficiencies. Presently, risk assessment may indirectly deem as acceptable the loss of up to 25% of colony strength (or even more). This value is unacceptable from different perspectives, from beekeepers, environmentalists and even farmers depending on pollination services. We request a reassessment of the proposal that corrects these insufficiencies. We sent a joint letter with PAN Europe , POLLINIS , and Apimondia to the European Commission, which we make public below: Access and download the letter Dear Commissioner Kyriakides, Dear Vice-president Timmermans, On 13 January 2021, the European Commission held, jointly with the European Food Safety Authority (EFSA), a workshop where the EFSA exposed its methodology to fix the Specific Protection Goals (SPGs) for honey bees. We are writing to you because we have several concerns related to the scientific and technical approach that EFSA has applied and the regulatory consequences of this recent work from EFSA. About the scientific and technical approach of the EFSA for defining SPGs: This approach relies on the use of a model (Beehave) that has not been endorsed by the scientific or beekeeping community, that has been co-funded by Syngenta, and, to our knowledge, is currently being disregarded by non-industry researchers, while at the same time EFSA has been and still is investing in the preparation of another model, the ApisRAM model. During the meeting, we have been convinced that the proposed approach and its use are not appropriate and that this approach will not allow for a high-level of protection of bees against pesticides. In our view, the approach from EFSA is inappropriate as: 1. It relies on a very simple model (Beehave) that does not mimic reality, nor the different factors that affect bee colony dynamics. During the meeting, EFSA staff several times mentioned that the model was an important simplification of reality. 2. The environment/weather module of the model is very simple and does not mimic the reality of what bees are exposed to. EFSA considered that the egg-laying rate was the same in all colonies, they did not make differences between the different EU honey bee subspecies, landscapes, etc. Everything is over-simplified. 3. EFSA has been using data from honey bee colonies that are located in agricultural environments where pesticides are used, to define the possible variability in the size of a honey bee colony. This is not scientific: if we want to protect bees, we need to define what the normal variability of a colony is based on colonies placed in pristine environments. 4. EFSA used data from regulatory tests to validate the model. Honey bee colonies from regulatory tests are not real colonies: they are artificial small colonies created just before the test in a standardised way, all of them having the same approximate initial number of bees, brood frame, honey frames, etc. Furthermore, these are very small and nonproductive colonies. This has nothing to do with the reality of a healthy and productive honey bee colony. The pollination services of these small “regulatory test colonies” are expected to be significantly lower than those of real productive colonies. EFSA thus bases its work on artificial data, not on real-life colonies that regulators are supposed to protect. 5. During the meeting, EFSA has not been able to explain how this approach would lead to an efficient protection of honey bees. Furthermore, we consider that there is an excessive amount of uncertainties linked to this approach. We hence consider that the approach followed by EFSA is not in line at all with the high level of protection of bees as required by pesticide regulation 1107/2009. During the meeting, it was explained that the current model that EFSA is developing (ApisRAM) will be finalised in June 2021, and then it could take several months of work to validate it. Last week, the EFSA communicated around this development in the press[1]. This ApisRAM model is much more sophisticated, much closer to the reality of the biology of honey bees, it is mechanistic and includes a more developed landscape approach. We are well aware that looking for a better and more scientific alternative might lead to additional delays but we consider that it is the price to pay for a more appropriate risk assessment. Moving forward with the current approach is in our view, certainly not an improvement compared to the current situation. For the reasons mentioned previously, we respectfully ask you to send a mandate to EFSA to stop the current process of defining specific protection goals using the Beehave model. We also ask to mandate EFSA to assess the possibility of using the model ApisRAM to carry out the task of defining the variability of a honey bee colony and defining SPGs accordingly. We also request that the work includes honey bee modellers, honey bee biologists, and beekeepers that would use data from the beekeeping field, rather than data from artificial regulatory tests. About the potential future regulatory implications of the work developed by EFSA: We wished to express our extreme concern about some calculations made by EFSA and published in the document provided for the preparation of the January 13th meeting. Indeed, EFSA has shown (Table 4, p.28 of the supporting document) that to determine a reduction of a honey bee colony size of 7% - as fixed by the risk manager in the Bee Guidance Document of 2013 - the experiment would need to be carried out with more than 120 hives located at the edge of the field. This has been criticized by the pesticide industry as biologically irrelevant, unfeasible, and extremely expensive. EFSA has also shown that based on the power analyses of the field test set up according to the current praxis in terms of field trials for regulatory purposes, it would not be possible to demonstrate an effect that is, in the best-case scenario, lower than 25%. This means that beekeepers’ colonies could lose up to one-fourth (most likely more as the current approach considers bees are exposed to a single pesticide at the time) of their strength and it would still be considered acceptable in the eyes of risk managers. However, such a reduction is unacceptable from a beekeeping or environmental point of view. Table 4 of the supporting document contributes to new technical and scientific knowledge showing that for a large number of authorised pesticides for which a field trial has been requested, the risk to bees could not be detected unless the effects on the colony strength were larger than 25%. We expect that your services will take into consideration this new scientific knowledge produced by EFSA and mandate a study to verify the number of field trials in DARs and RARs for which this is the case. Following the results of this analysis, we request you to consider their potential withdrawal. Furthermore, it arose several times during the meeting the importance of setting SPGs at a level that allows industry to practically run field trials. All in all, field tests are the reference decision-making tier for honey bees. We strongly believe this approach is unacceptable and illegal. It should be obvious for the scientific EFSA staff, as well as for risk managers, that the current approach having field tests as the reference tier for decision-making does not work, neither from a biological nor from a statistical point of view. As a result, the reference tier should be changed at once and be replaced, for instance, by semi-field tests or laboratory tests. Decision-making could be then supported by post-registration Phyto-pharmacovigilance and bee health monitoring, and completed with modelisation with ApisRAM as soon as it is available. The SPGs should never exceed the level of 7%, as it was accepted in the 2013 GD no matter what it requires in terms of field trials. If the decision-making tool is not fit for purpose, we should not reduce the protection levels to make it workable. We need to set good protection levels first and then find ways to evaluate their fulfillment. Our goal is above all to ensure that we protect the bees and respect regulation 1107/2009. Finally, we also wished to draw your attention to bumblebees and solitary bees. Those have not been discussed during the workshop, but we consider that they must be protected as well, for many of their species are facing a dramatic decline. Together with honey bees, they play a major role to ensure pollination of wild plants and crops. Only pollination by a diversity of pollinator species can ensure resilient and productive agroecosystems. Therefore, we ask you to adopt the approach proposed by the EFSA in the 2013 Bee Guidance Document and define Uniform Principles for these species based on the existing amount of scientific knowledge. Today, in a meeting with stakeholders and Member States, the European Commission recalled, regarding the ongoing work on Specific Protection Goals for honey bees, the importance to work little step by little step, based on science and on the precautionary principle. We feel this is clearly missing here. To conclude, the very worrying evolution of the discussions around the Bee Guidance Document and SPGs is in complete opposition with the objectives of the Biodiversity Strategy. Only a strong risk assessment methodology and an efficient control of pesticide use will allow for the effective protection of bees and recovery of biodiversity in rural areas. An attempt by the Commission and Member States to implement the Bee Guidance Document “in a weak way” has already been opposed by the European Parliament. For the sake of coherence and good governance, we respectfully request you to align the revision of the Bee Guidance Document with the Biodiversity Strategy objectives and to swiftly put in place the implementation of a bumblebee and solitary bee risk assessment. From beforehand, we thank you for your consideration and your reaction. Best regards, Francesco Panella, President of BeeLife Nicolas Laarman, Director of POLLINIS Jeff Pettis, President of Apimondia Martin Dermine, Policy officer, PAN Europe [1] https://www.euractiv.com/section/agriculture-food/news/eu-food-safety-agency-presents-plan-for-integrated-risk-assessments-for-pollinators/

  • Open Letter for the Future CAP to Advance the EU Green Deal

    Download this open letter Mr Frans Timmermans Executive Vice-President for the European Green Deal European Commission Mr Janusz Wojciechowski Commissioner for Agriculture European Commission Ms Maria do Céu Antunes Minister of Agriculture of the Portuguese Republic Mr Peter Jahr Member of the European Parliament Mr Eric Andrieu Member of the European Parliament Ms Ulrike Müller Member of the European Parliament Open letter to the European Commission, the Presidency of the Council of the European Union, and the European Parliament’s rapporteurs on the CAP regulations calling for ambition in trilogues for a green and fair reform of the Common Agricultural Policy 25th March 2021 Dear Executive Vice President, Dear Commissioner, Dear Minister, Dear European Parliament Rapporteurs, We are writing as a wide-ranging coalition of organisations from the food, farming, environmental, protected area, animal welfare, development, and public health sectors across the EU representing millions of citizens and farmers, to urge you to deliver an ambitious, green and fair reform of the Common Agricultural Policy (CAP). The EU’s farming sector is faced with multiple crises which EU policies must tackle coherently and urgently. From the structural lack of viability due to imbalances of power in supply chains and chronic overproduction in several sectors, to the increasing impacts of climate breakdown and biodiversity collapse, many farmers will not survive another decade of business-as-usual policies. And they are not the only victims of the EU’s current unsustainable food system: farmers in the global South, seasonal farm workers, rural communities affected by agricultural pollution, and our fast-degrading natural world also deserve better policies. Addressing these structural challenges requires significant policy change, starting with the post-2022 CAP. The European Green Deal presented by the European Commission and welcomed by Member States and the European Parliament makes a clear commitment to “a fair, healthy and environmentally-friendly food system” as part of the just transition to a climate-neutral, biodiversity-rich Europe. This cannot happen in the agricultural sector without a much greener, healthier and fairer CAP that provides a clear pathway for change and supports farmers in the transition. As lead negotiators in the ongoing trilogues, we urge you to integrate the following overarching priorities into the three CAP regulations: 1. Incorporate the principles, objectives and targets of the Green Deal into the CAP to give national Strategic Plans a clear direction from their design all the way to their approval and performance reviews; 2. Fully implement the ‘do no harm’ principle into the CAP through strong environmental and social conditionality and safeguards; 3. Empower farmers and rural actors to adopt climate-, nature-, people-, and animal-friendly farming practices and models through fair and effective CAP support; 4. Adopt adequate instruments to manage and regulate agricultural markets to limit overproduction, which causes waste, price crashes for farmers, and contributes to unsustainable trade, and to increase the fairness and transparency of supply chains; 5. Ensure good governance in the new CAP through strong rules on transparency, accountability of Member States for EU budget spending, civil society participation, and performance monitoring and reporting against robust indicators. We are following carefully the trilogue negotiations and note with grave concern that to date they are falling far short of the ambition European citizens and farmers expect and demand from their leaders. Now more than ever, society requires a strong CAP reform and cannot accept a continuation of business as usual. Another failed reform of the CAP would not only further undermine the legitimacy of the EU’s farming policy, but would jeopardise the achievement of the European and global sustainability targets we have committed to for 2030. Europe needs to build a way forward that supports the agricultural sector not only today but also tomorrow, while accelerating the response to environmental and social crises. We therefore very much hope that you will give serious consideration to our concerns, listen to EU citizens’ demands for change, and act boldly during trilogues to deliver a greener, fairer, healthier, and future-proof CAP. Yours sincerely,

  • Open letter: Ending blind spots on agro-chemicals

    Today, 28 environmental and health organisations and beekeeper associations across Europe sent this open letter to the representatives of the EU27 to bring to their attention the necessary inclusion of a number of elements in the ongoing EU reform of agriculture statistics . The associations work for the public interest to protect the health of farmers, residents of rural areas, and other people exposed to pesticides, as well as pollinators, birds and the environment at large. This legislative reform is of a high importance as it will define what data will be available to monitor progress towards the sustainable use and reduction of pesticides, among other objectives. Setting reduction targets, as proposed in the EU Farm to Fork Strategy is of paramount importance. Ensuring that there will be relevant, reliable and public data to monitor progress towards these targets is equally crucial. The importance of monitoring and an evidence-based approach was particularly emphasised by the Council when it endorsed the Farm to Fork Strategy. Without systems in place to collect and publish such data, the targets set are empty political promises. This lack of transparency can also only fuel mistrust in society. For this reason, the associations call for: - The systematic and electronic annual collection of all farmers’ records on their use of pesticides - The collection of data not only on pesticides but also biocides and veterinary products - The systematic publication of the data on pesticides’ use at a meaningful level of detail - The unlimited and easy access to the raw data for the European and national public authorities Without these data collected and communicated, it will be impossible to measure the evolution of efficiency of the policy implementation and we will remain blinded to the real field situation. The open letter can be found here

  • Open letter to German ministries: Farm to Fork Strategy at risk

    BeeLife together with other NGOs sent an open letter to German ministries to support the SAIO ( Statistics on Agricultural Input and Output ) reform, to ensure transparency for effective pesticide reduction. The letter states the following The current EU reform of the Statistics on agricultural input and output (SAIO) is of great importance. Without the recording of actual pesticide use in agriculture ; through relevant, reliable and publicly accessible data, a pesticide reduction strategy can hardly be implemented in a meaningful way, as there is no reference value. The Slovenian Presidency plans to finalise the Council position before the end of its term. This could take place as early as next Friday, 10 December within the framework of the Special Committee on Agriculture (SCA). In order to ensure that the Commission's proposal meets the expectations of the Green Deal and the Farm to Fork Strategy, the following aspects also need to be integrated: the collection of data not only on pesticides but also on biocides and veterinary medicines used in agriculture; legal guarantees for the publication of data on pesticide use at a meaningful level of detail (i.e. per active ingredient, product, crop/species, year and at the geographical level of a local management unit); Full and easy access to the underlying raw data for European and national authorities responsible for the protection of public health and the environment (in line with Regulation (EC) No 223/2009, as farmers' records are not collected exclusively for statistical purposes). Without adequate systems to collect and publish such data, the goals set in the EU Farm to Fork Strategy are empty political promises. This lack of transparency would undoubtedly lead to a loss of trust in society. You can download the open letter (in German) here. Our open letter was successful! After the letter, the new German minister of agriculture declared that they will vote against the draft, stating the following: "Zielerreichung der #FarmToFork -Strategie muss systematisch überprüf- u. messbar sein. Übermittlung der Daten zur Anwendung von Pflanzenschutzmitteln nur alle 5 Jahre ist für BM @cem_oezdemir nicht akzeptabel. Deutschland wird deshalb gegen den vorliegenden Entwurf stimmen." "Achievement of the #FarmToFork strategy must be systematically verifiable and measurable. Transmission of data on the use of plant protection products only every 5 years is not acceptable to BM @cem_oezdemir. Germany will therefore vote against the current draft."

  • Open Letter - We request transparency in pesticide use across Europe

    Download the letter Today we sent an Open Letter with 78 other organisations to: Mr Denormandie, French Minister of Agriculture Mr Tavernier, Director General of INSEE Mr Gentiloni, Commissioner for the Economy Mr Kokkalis, MEP rapporteur for the European Parliament Subject: The reform of agriculture statistics ( File 2021/0020 COD ) On behalf of 79 organisations across Europe, including environmental and health associations, beekeepers associations, trade unions, the organisers of the European Citizens’ Initiative “Save Bees and Farmers” , the European umbrella organisation for organic food and farming, and the European association of drinking water and waste water services, we are writing to voice our concerns regarding the ongoing EU reform of agriculture statistics. Specifically, we are concerned about the limited availability of data on the use of pesticides and other toxic chemicals in agriculture. The Council just recently adopted its position which raises serious concerns in relation to two vital aspects of this reform. First, ensuring that the relevant data are collected from the relevant sources in the most efficient way; and second, ensuring that the relevant data are proactively published at a meaningful level of detail. We are urging you to raise these issues within the ongoing trilogue negotiations and ensure this reform delivers on these points. Public statistics should match the needs of public authorities and what is in the collective interest. Public statistics are meant to produce relevant data for public authorities so they can take informed decisions. [1] EU statistics are produced because they are “necessary for the performance of the activities of the Union”.[2] Public authorities have needed data on pesticide use to assess trends across the EU since at least 1993. [3] In 2022, due to inadequate legislation, the available data on pesticide use still do not fulfil this basic need.[4] Beyond the need to analyse trends, precise and public data on pesticides use are also indispensable to enabling more realistic analysis of the exposure of agriculture workers and residents in rural areas, as well as the exposure of wildlife and ecosystems. Such data are also key to monitoring water, notably for drinking water suppliers. They are also key for many other necessary tasks that are in the public interest. Reducing pesticide pressure on nature across Europe is not only urgent for biodiversity; it is also of great importance to millions of citizens. This matter was at the heart of the European Citizens’ Initiative “Save Bees and Farmers” which gathered 1.2 million signatures and was one of the three demands of the 2017 European Citizens’ Initiative “ Ban glyphosate and protect people and the environment from toxic pesticides ”. The European Commission’s strong legislative proposal to fix agriculture statistics, and the European Parliament’s many helpful amendments , rise to the challenge. In particular, the Parliament’s proposals aiming to ensure the new law meets the requirements under the European Green Deal and addresses the need for transparency are fundamental . However, as explained in detail in ClientEarth’s briefing , the amendments proposed by the Council would hinder much needed improvements in the availability of pesticide use data. Unfortunately, in the Council’s discussions so far, the concern to minimise burdens for public administrations seems to have taken precedence over ensuring the relevant data are collected and published, as PAN Europe and Global 2000 have shown. In view of the ongoing trilogue discussions, we reiterate that this reform needs to deliver the following to be a success and meet the public’s data needs . [1] - See the European Statistics Code of Practice available in French and in English [2] - Article 338(1) TFEU [3] - The Fifth Environmental Action Programme defined as a target the “reduction of chemical inputs” in agriculture, specifically setting as an objective “the significant reduction in pesticides use per unit of land under production” by 2000 and foreseeing the “registration of sales and use of pesticides”. [4] - See European Court of Auditors Special Report 05/2020: Sustainable use of plant protection products: limited progress in measuring and reducing risks, and Eurostat (2019) Research paper : Statistics on agricultural use of pesticides in the European Union (ESTAT E1/AES/2019/RP/1) You can access the full letter here.

  • Joint open letter: EU food supply and solidarity response to the war in Ukraine

    Download the open letter This letter comes as a reaction to the statement by Commissioner Wojciechowski that “ if food security is in danger, then we need to have another look at the objectives of the Farm to Fork strategy and correct them ”. We believe the contrary to be true: the war in Ukraine is yet another reminder of how essential it is to implement the Green Deal and its Farm to Fork and Biodiversity Strategies . More than ever, the EU must shift towards healthy, socially and environmentally friendly farming practices, such as agroecology, organic farming, and agroforestry, which provide the only path to ensuring long-term food security, food sovereignty, and the overall sustainability of the food systems. We must turn away from intensive agriculture, industrial fisheries and aquaculture. Thursday, 10 March 2022 Joint open letter: EU food supply and solidarity response to the war in Ukraine Dear President von der Leyen, Executive Vice-President Timmermans, dear Commissioners Wojciechowski, Kyriakides and Sinkevičius, We are writing to you in the context of the terrible acts of aggression against Ukraine and the knock-on effects on the global food production and trade they entail. This tragic situation that is destroying towns and lives, will need our solidarity and support. We ask you to address this immediate crisis without undermining the environmental and social progress to which you committed in the European Green Deal. This letter comes as a reaction to the statement by Commissioner Wojciechowski that “if food security is in danger, then we need to have another look at the objectives of the Farm to Fork strategy and correct them”. We believe the contrary to be true: the crisis in Ukraine is yet another reminder of how essential it is to implement the Green Deal and its Farm to Fork and Biodiversity Strategies. More than ever, the EU must shift towards healthy, socially and environmentally friendly farming practices, such as agroecology, organic farming, and agroforestry, which provide the only path to ensuring long-term food security, food sovereignty, and the overall sustainability of the food systems. We must turn away from intensive agriculture, industrial fisheries and aquaculture. Watering down the Farm to Fork strategy and its policies will maintain Europe’s dependence on non-renewable energy sources like fossil fuels, and will go against what is needed right now to secure food for all. Europe must support farmers to undertake an agroecological transition, notably by ensuring they and farm workers have a fair income. Practices such as organic and agroecological agriculture - especially as practised by small scale family farmers in Europe – should be effectively supported, as they are key to food sovereignty, biological diversity, natural pest control and pollination. The transition towards agroecology should be combined with policies that on the one hand, foster a reduction in the production of animals farmed industrially towards small scale extensive and animal welfare-friendly practices, through a just transition respectful of the right to farmers to have a fair income and, on the other hand, promote healthier and more plant-based diets. Indeed, the most recent IPCC report (IPCC Sixth Assessment Report: https://www.ipcc.ch/report/ar6/wg2/ )made it crystal clear that “while agricultural development contributes to food security, unsustainable agricultural expansion, driven in part by unbalanced diets, increases ecosystem and human vulnerability and leads to competition for land and/or water resources”. Global food systems will continue to be afflicted by crises and uncertainties over the coming years and decades. By acting responsibly now, we will ensure that Europe is well-placed to face possible future crises. This war will undoubtedly destabilise the cereal, oilseed and fertiliser markets. Russia and Ukraine provide a large part of the global cereal market and the EU imports much of its oilseed meal, oil and seeds (CDG Arable Crops Cereals, Oilseeds and pulses, 07 March 2022) and fertilisers (EU Agricultural Market Briefs, 2019. Fertilisers in the EU. Nr 15/June 2019) from Russia, Ukraine and Belarus. The dependency of low income countries on these imports poses major challenges for their food security, which in turn increases the risk of social unrest and conflict. In Europe, the surge in prices risks affecting the most vulnerable – both farmers and consumers – who are already struggling to recover from the COVID-19 pandemic. This calls for the Commission to support efforts aimed at securing the right to food and food sovereignty and, first and foremost, local food systems grounded in principles of agroecology and animal welfare, both in Europe and abroad. Ploughing more farmland, as is currently being put forward (FNSEA communication , 03 March 2022), to grow crops for biofuels and intensive animal farming by using even more synthetic pesticides and fertilisers would be absurd and dangerously increase ecosystem collapses, the most severe threat to social-ecological stability and food security. The European Union must tackle the current challenges by accelerating the implementation of its strategies to reduce the use of synthetic pesticides and fertilisers, to preserve its natural environment and the health of its citizens. Both the COVID-19 pandemic and the war in Ukraine have shed light on the weaknesses of the European food system, which requires concrete actions to ensure long-term sustainability. Current attempts by some lobby groups to use the war atrocities as an excuse to undermine the Farm to Fork Strategy are fully misplaced. In a world facing more recurrent shocks in the form of environmental crises or conflicts, we need policies oriented towards relocalising and democratising our food systems, building on traditional and ecological knowledge that support resilience. We strongly hope that you will consider our above recommendations with due care and diligence, and we remain at your disposal for a meeting to further exchange on these matters. Yours sincerely, European & International organisations Ariel Brunner, Senior Head of Policy, BirdLife Europe and Central Asia Teresa Anderson, Climate Justice Lead, ActionAid International Lili Balogh, President, Agroecology Europe Kajsa Pira, Policy officer, AirClim Oliver Moore, Editor, ARC2020 Francesco Panella, President, BeeLife European Beekeeping Coordination Monique Goyens, Director General, BEUC Clara Behr, Head of Policy and Public Relations, Biodynamic Federation Demeter International Anaïs Berthier, Head of EU Affairs, ClientEarth Sophie Nodzenski, Senior Campaigner, Changing Markets Foundation Mikhail Durkin, Executive Secretary, Coalition Clean Baltic Philip Lymbery, Global CEO, Compassion in World Farming Nina Holland, Researcher, Corporate Europe Observatory Reineke Hameleers, CEO, Eurogroup for Animals Zoe Lujic, Director, Earth Thrive Ilya Trombitsky, Executive Director, Eco-TIRAS International Association of River Keepers Todor Ivanov, Secretary General, EuroCoop Patrick Worms, President, European Agroforestry Federation Jeremy Wates, Secretary General, European Environmental Bureau Coordinating Committee, European Coordination Via Campesina Nikolai Pushkarev, Senior Policy Manager for Healthy Environments, European Public Health Alliance (EPHA) Virginia Enssle, Project and Policy Officer, Fair Trade Advocacy Office Carina Millstone, Trustee, Feedback EU Pierre Sultana, Director of the European Policy Office, FOUR PAWS / VIER PFOTEN Jagoda Munic, Executive Director, Friends of the Earth Europe Jorgo Riss, Executive Director, Greenpeace European Unit Almudena Garcia Sastre, EU Policy and Advocacy Officer, FIAN European sections Eric Gall, Deputy Director, IFOAM Organics Europe Shefali Sharma, Director, Institute for Agriculture and Trade Policy Europe Olivier De Schutter, Co-chair, IPES-Food Arnaud Apoteker, General Delegate, Justice Pesticides Martin Dermine, Health and Environment Policy Officer, Pesticide Action Network Europe Jasmijn de Boo, Vice-President ProVeg International, ProVeg International Marta Messa, Director, Slow Food Europe Fabian Holzheid, Political Director, Umweltinstitut München e.V. Isabel Alvarez Vispo, President, Urgenci National organisations Austria Franziskus Forster, Policy Officer, ÖBV-Via Campesina Austria Belgium Benjamin Clarysse, Policy and project coordinator, Bond Beter Leefmilieu Amaury Ghijselings, Advocacy Officer Food Sovereignty, CNCD-11.11.11 Fien Louwagie, spokesperson, EVA vzw François Grenade, Policy officer, Iles de Paix Sylvie Meekers, General manager, Inter Environnement Wallonie Thérèse Snoy, President, Grands Parents pour le Climat Bart Vangansbeke, President, Natuurpunt Vanya Verschoore, coördinator, Reset.Vlaanderen vzw Benoit De Waegeneer, Policy and Information Coordinator, SOS Faim Croatia Natalija Svrtan, CEO, Earth Trek Czech Republic Anna Kárníková, Director, Hnutí DUHA - Friends of the Earth Czech Republic Denmark June R. Bresson, Campaigner food, agriculture and nature, NOAH - Friends of the Earth Denmark Niklas Sjøbeck Jørgensen, Policiy Advisor, Green Transition Denmmark France François Veillerette, spokesperson, Générations Futures Khaled Gaiji, President, Friends of the Earth France Germany Thomas Radetzki, Board, Aurelia Stiftung Olaf Bandt, Chairman, BUND e.V. (Friends of the Earth Germany) Johanna Bär, Managing Director, Bündnis für eine enkeltaugliche Landwirtschaft e.V. Dominik Groß, Officer for Human Rights and Environmental Protection in Food Supply Chains, Christliche Initiative Romero e.V. Anne Siegert, Referee nature conservation communication, Deutsche Umwelthilf e.V. Sascha Müller-Kraenner, Director, Deutsche Umwelthilfe e.V. (Environmental Action Germany) Andrea Lichtenecker, Executive Director, Naturfreunde Internationale Gabriela Strobel, Speaker of the Board, Pestizid Aktions-Netzwerk e.V. (PAN Germany) Niels Dr. Kohlschütter, Managing Director, Schweisfurth Stiftung Fabian Holzheid, Political Director, Umweltinstitut München Peter Röhrig, Managing Director, Bund Ökologische Lebensmittelwirtschaft (BÖLW) Greece Konstantinos Foteinakis, President, Naturefriends Greece Georgia Davit Sidamonidze, International coordinator, The Greens Movement of Georgia/FoE Georgia Ireland Philip Kaerney, Chair, An Taisce - the National Trust for Ireland Caroline Lewis, Director, Friends of the Irish Environment Italy Federica Luoni, Agriculture policy officer, Lipu BirdLife Italy Francesco Romizi, EU Affairs manager, ISDE, Associazione Medici per l'Ambiente Christiam Facchetti, President, Naturefriends Italy Latvia Andrejs Briedis, Chairman of the Council, Latvian Fund for Nature Lithuania Lina Paškevičiūtė, Chair, Aplinkosaugos koalicija (Lithuanian Environmental Coalition) Domantas Tracevičius, Director, VšĮ Žiedinė ekonomika Netherlands Bernd de Bruijn, Head Policy & Strategy, Vogelbescherming Nederland (BirdLife in The Netherlands) Hank Bartelink, Director, LandschappenNL Marjolein Demmers, Director, Natuur & Milieu Patrick Nuvelstijn, Coordinator International & European Affairs, Natuurmonumenten Magriet Mantingh, Chair, Pesticide Action Network Netherlands Poland Aleksandra Pępkowska-Król, Project implementation specialist, Ogólnopolskie Towarzystwo Ochrony Ptaków Portugal Francisco Ferreira, President, ZERO - Associação Sistema Terrestre Sustentável Jorge Palmeirim, President, LPN - Liga para a Protecção da Natureza Scotland Pete Ritchie, Director, Nourish Scotland Slovenia Iztok Erjavec, Chief Idea Officer, Institute InTeRCeR Senka Šifkovič, project assistant, Umanotera, The Slovenian Foundation for Sustainable development Spain Tamara Rodríguez, Head of agriculture program, SEO/BirdLife Spain Elisa Oteros-Rozas, Coordinator Area of Agroecology, Food Sovereignty and Rural World, Ecologistas en Acción Concepción Fabeiro Cortés, President, Sociedad Española de Agricultura Ecológica y Agroecología (SEAE) Andrés Muñoz, Food Sovereignty Campaigner, Amigos de la Tierra Julia Martinez, Executive Director, Fundacion Nueva Cultura del Agua Switzerland Franco Ruinelli, Senior Committee Member, Naturfreunde Schweiz Download the open letter

  • Joint Letter on the Statistics on agricultural inputs and outputs (SAIO) reform

    We signed a joint letter with 57 other organisations addressed to the the Members of Standing Committee on Plants, Animals, Food and Feed (PAFF Committee) and the Chair of the PAFF Committee. We call on them to adopt without delay the Implementing Regulation harmonising the content and format of the pesticide use records. Read the letter here.

  • Open Letter to the European Parliament on Targeted Intervention by US Firm to Undermine Ecological Transition Policies in Europe

    In light of recent revelations that the United States government has undergone significant efforts through private firms to undermine the EU's strategy for ecological transition, non-governmental organisations (NGOs) have joined together to express their concern to the European Parliament. Since their efforts were paired with profiling efforts targeting scientists, journalists, and activists, we see this as a deeply unsettling strategy that puts European sustainability and independence at risk. Open Letter ( originally available at CEO's website ) ( Download the file ) We, as a network of NGOs working on reducing the use and negative impacts of pesticides and genetically engineered organisms on biodiversity and human health, reach out to you with an urgent request. As you may have seen, recent revelations from a Lighthouse Reports investigation showed how Trump's administration set up a strategy to torpedo the EU Green Deal (notably the Farm to Fork Strategy) using influence and misinformation campaigns to undermine Europe's food quality. The PR firms behind this strategy were also responsible for profiling hundreds of scientists, journalists and environmental activists from all over the world, including Europe. We consider this scandal to be a clear-cut example of foreign interference in crucial EU policy. The mentioned PR campaign was not only co-financed by the US government but had the successful aim of bringing down Farm to Fork (F2F) policies (as part of the EU Green Deal), like the 50% pesticide reduction (Sustainable Use of Pesticides Regulation). In 2022, Corporate Europe Observatory already shed light  on a US Department of Agriculture-backed campaign to attack European efforts to bring agricultural policies more in line with planetary boundaries . Recently, via the Lighthouse publications, it became clear that two PR companies - the White House Writers Group (WHWG) and v-Fluence had contracts with the USDA, and jointly prepared strategies to bring down European policies, which both the European Commission and science consider essential . As Lighthouse/Le Monde described, a specific event on July 29 2020, jointly organised by USDA and WHWG together with the ECR parliamentary group, served as kick-off for a campaign that ultimately was instrumental in undermining the F2F Strategy by changing the narrative and political debate. Le Monde writes that "in their November 19, 2020 memo to the US Department of Agriculture, v-Fluence and WHWG not only pledged to defeat the F2F strategy and the European Green Deal, they also proposed to step up operations in the countries of the South" . Some of the main findings from Lighthouse Reports include: The Lighthouse investigation reveals that in 2020, the US government awarded a contract worth up to $4.9 million to White House Writers Group and v-Fluence, as part of the US strategy to undermine the EU's Farm to Fork strategy. The contract also included services provided by v-Fluence, and access to the Bonus Eventus social media network. The two firms acted as co-managers of Bonus Eventus, the online social network, which the US government funded to profile critics of pesticides and GMOs and more than 3,000 organisations, including dozens based in Europe. The findings are part of a wider investigation which found that between 2013 and 2019, the US Agency for International Development (USAID) channelled over $400,000 to v-Fluence for the purpose of "stakeholder tracking" of industrial agriculture critics. As part of this "monitoring", v-Fluence created a private social network called Bonus Eventus, which profiled more than 500 individuals, including scientists, UN human rights experts, environmentalists, and journalists, as well as over 3,000 organisations. V-Fluence and its director - a former Monsanto corporate communication director - have been accused of leading a 20-year campaign to suppress information about the health risks of Paraquat, a very highly toxic herbicide banned in the European Union and associated with Parkinson's, an incurable neurological disease. We would like to ask you to use your voice as MEPs, to address your concerns to both the US embassy in Brussels as well as the European Commission. We urge you to: Call for an immediate investigation into possible breaches of European GDPR rules linked to the filing of EU citizens. Encourage the European Commission to strictly implement the existing privacy laws to protect scientific communities, journalists, and environmental activists from being targeted by covert profiling and misinformation campaigns. Urge the European Institutions to restart the ambitious work on the EU F2F, to achieve the much-needed science-based Food Policy in Europe. Given the success of the US and industry-led misinformation campaign in derailing the EU Green Deal, consider the investment of similar budgets on a public information campaign that will contribute to a better comprehension of the 2019 ambitions. Demand transparency from both the US government and EU institutions regarding external attempts to interfere with the EU's Green Deal and Farm to Fork strategy; as well as the funding and operations of the PR firms involved, focusing on their influence on EU policies and public opinion manipulation. Advocate for a legally binding transparency register , better rules against conflicts of interest for MEPs and an authority with sufficient resources and competencies to monitor and enforce compliance with the rules, to expose covert or manipulative influence on democratic processes. In our view, these kinds of toxic covert PR campaigns contribute to a political climate  where environmental and climate activists are increasingly being repressed , which threatens basic civil rights. These specific campaigns to undermine the EU Green Deal are not only violating democratic values and intoxicating the public debate with ‘fact-free politics’ and fake news, but above all, bring great damage to the health of your electorate and the future of their children.  Finally, influencing the scientific debate has been instrumental in this ‘ torpedo the Farm to Fork campaign ’. Several  scientific studies on the Green Deal  have been paid for and instrumentalised by commercial actors in the food-agri industry. Three years ago,  internal lobby documents from the agro-business lobby Copa-Cogeca leaked revealed a coordinated attack by industrial agri-food lobbies on the EU’s F2F ambitions. The lobbying strategy succeeded in creating an echo chamber of anti-F2F messages using partial findings from a series of academic ‘impact studies’, many of which were funded by the industry itself. Both Copa-Cogeca and CropLife, the pesticide manufacturers' interest group, paid for such studies at the Wageningen University & Research (WUR). In early October, Sjoukje Heimovaara, chair of the Board of Governors at WUR, criticised the fact that WUR researchers collaborated in the PR activities of CropLife. “ That should not have happened, because it creates at least the appearance of a conflict of interest, ”  she commented to a Dutch TV programme . All the examples exposed and mentioned above, clearly point in the direction of manipulation of science and the political and societal debate by agrochemical companies.  As elected representatives of EU citizens, EU citizens and consumers yourselves, who time and again have spoken out for a reduction of pesticide use, we believe you are best placed to defend those societal demands. On behalf of this civil society coalition, we thank you for your attention and for taking action. For any further information or questions, we remain at your disposal.  Kind regards, Hans van Scharen and Nina Holland ( Corporate Europe Observatory, CEO ) Martin Dermine and Natalija Svrtan ( PAN Europe, ECI Save Bees and Farmers ) Jörg Rohwedder ( International Executive Director Foodwatch ) Elena Artico and Natacha Cingotti ( Foodwatch ) Clara Bourgin ( Friends of the Earth Europe ) Christoph Then ( Testbiotech, Germany ) Francesco Romizi ( ISDE - International Society of Doctors for Environment ) Jonas Jaccard ( Humundi, Belgium ) Eoin Dubsky ( Ekō ) Nadine Lauverjat ( Générations Futures ) Gábor Wichmann ( BirdLife Austria ) Wetlands International ( Wetlands International Europe ) Gabriela Strobel ( PAN Germany ) Anouk Puymartin ( BirdLife Europe and Central Asia ) Lars Hellander and Noa Delso Simon ( BeeLife, ECI Save Bees and Farmers ) Célia Nyssens-James ( European Environmental Bureau ) Olga Speranskaya, Alexandra Caterbow ( Health and Environment Justice Support ) Suzanne Astic ( Child Rights International Network ) Barbara Berardi ( POLLINIS, France ) Lorine Azoulai ( CCFD-Terre Solidaire ) Constantin Dobrescu ( ROMAPIS - The Federation of the Romanian Beekeeping Associations ) Tara Glaser (Earth Trek, Croatia) Kistiñe García ( Ecologistas en Acción, Spain )

  • Open Letter on the Vision for Agriculture and Food

    Following European Elections earlier this year, the European Commission is now shaping its cabinet. Cristophe Hansen (Luxembourg, European People's Party - EPP) has been appointed Commissioner for Agriculture and Food. The Commission's new term is marked by the weight of past promises and commitments to 'fix' the EU's agricultural model, restructuring its vast budget to improve conditions for farmers and meet sustainability goals under the Farm to Fork Strategy. The new Commission will develop a new policy roadmap under the banner 'The Vision for Agriculture and Food'. Anticipating this development, a group of environmental and consumer protection NGOs (including BeeLife) have joined to provide some input on what the vision for the future should comprise. In an open letter addressed to Commissioner Hansen, the NGOs stress the importance of: Making prices fair for farmers and consumers, tackling harmful trading practices Making the healthy, sustainable choice the easy one for consumers Reforming the Common Agricultural Policy to assist farmers most in need and support those actually engaging in sustainable practices Supporting the ecological transition through appropriate financing measures The full text of the open letter is available below and available for download : Open letter on the Vision for Agriculture and Food Brussels, 9 December 2024 Dear Commissioner for Agriculture and Food Christophe Hansen, Cc: European Commission President Ursula von der Leyen, Executive Vice-President for a Clean, Just and Competitive Transition T eresa Ribera, Executive Vice-President for Cohesion and Reforms Raffaele Fitto, Commissioner for Environment, Water Resilience and a Competitive Circular Economy Jessika Roswall, Commissioner for Climate, Net Zero and Clean Growth Wopke Hoekstra, Commissioner for Budget, Anti-Fraud and Public Administration Piotr Serafin, Commissioner for Health and Animal Welfare Olivér Várhelyi, Commissioner for Fisheries and Oceans Costas Kadis, Commissioner for Intergenerational Fairness, Youth, Culture and Sport Glenn Micallef. Congratulations on your appointment as Commissioner for Agriculture and Food. While navigating the complexities of the food and farming sectors will be a challenging task, your mandate has the potential to bring significant positive change to our societies and the environment. We look forward to working constructively with you on the future of EU agriculture and food systems. We, the undersigned organisations, are a diverse group of civil society groups, farmers and fishers organisations, and policy institutes that support the transition to sustainable and agroecological food systems. We are writing to offer input on the Vision for Agriculture and Food that will be developed within your first 100 days. Additionally, we would appreciate the opportunity to meet with you to introduce ourselves and discuss your plans for this mandate in greater detail. Our food system is facing several challenges. Some farmers struggle to be paid fairly for their work, in a system rife with unfair trading practices. Some consumers struggle to access and afford healthy, sustainably produced food. All the while, society grapples with the triple planetary crisis of climate change, biodiversity loss, and pollution, to which the current food system - often reliant on intensive farming practices that compromise animal welfare - is both a contributor and victim. The Vision for Agriculture and Food needs to set the direction of travel and include a concrete work plan to address these challenges. It should build on the recommendations from the Strategic Dialogue on the Future of EU Agriculture in their entirety and will require close collaboration with your colleagues across the College to implement. The Vision must uphold an integrated food systems approach addressing the entire chain from production to consumption and hold all stakeholders, including commercial actors like traders, processors, and retailers, accountable to ensure a fair and effective transition without placing the burden solely on farmers and fishers. Five critical areas of work are particularly important to us, drawing from the Strategic Dialogue: Fair prices for farmers and consumers All farmers and farmworkers should have decent incomes and be fairly paid for their work. Unfair trading practices must be addressed to ensure that farmers can receive decent revenues from the market and do not have to systematically sell their products below production costs. A well-functioning Agri Food Chain Observatory is key in this regard, as it can provide transparency of prices, costs and margins all along the food chain. The cost of living is the greatest concern of many consumers. VAT reductions on more sustainable products can help with affordability and promote rebalancing diets to include more plant-based foods. However, it is critical to ensure that that benefit makes its way to consumers and is not absorbed by retailers. Make the healthy sustainable choice the easy one for consumers What we eat is largely shaped by our surrounding food environment. Hence, there is a need for demand-side policies that make sustainable and healthy food widely available, affordable, appealing, and easily recognizable to consumers. Public food procurement has significant untapped potential to address food poverty, provide healthy and sustainable options, and promote food education that can influence household eating habits. It can also support small-scale farmers, encourage organic and agroecological practices, and boost competitiveness. Updating the Public Procurement Directive to encourage Member States to procure sustainable, healthy, and high-welfare food in public institutions by prioritising "best value" over "lowest price" can help achieve these objectives (see also the Manifesto on Minimum Mandatory Standards for Public Canteens developed by some of our organisations). Developing an action plan by 2026 for plant-based foods can strengthen the plant-based agri-food chains from farmers all the way to consumers and helps consumers achieve sustainable healthy diets. Additionally, an evaluation by 2026 of national measures and voluntary industry commitments on marketing unhealthy food to children is key; if found to be inadequate, EU legislation to regulate such marketing should be introduced. Reform the CAP to assist farmers who need it most and support those who demonstrably engage in sustainable practices The CAP is currently failing to support the transition to agroecological systems on the scale and at the speed we need. It should be revised to target those who need it most, especially small farms and new entrants, including women, while ensuring the highest possible environmental, social, and animal welfare practices in a quantifiable manner. We were pleased to see that this Strategic Dialogue recommendation was echoed by President von der Leyen in your mission letter and look forward to working with you towards its realisation. Ensure food systems and farming practices work for nature and the climate We share your commitment to generational renewal in the farming sector. Yet as we secure the passage of family farms to the next generation or welcome new entrants into the sector, we must also ensure that the type of farming can last generations as well. Many agricultural practices contribute to the triple planetary crisis of climate change, biodiversity loss and pollution, and all are vulnerable to their impacts. Existing environmental legislation should be fully enforced, including the Nature Restoration Law. Establishing a Nature Restoration Fund can help farmers achieve the full implementation of that legislation and build resilience on their lands. The Sustainable Use of Pesticides Directive should be fully implemented without delay, to ensure that pesticides are truly only used as a very last resort through Integrated Pest Management (IPM), and to protect citizens and the environment against pesticides. Organic and agroecological practices demonstrate that it is possible to be economically viable and farm within planetary boundaries. These practices should take center stage in your Vision. Food systems and sustainable farm practices can and must contribute to an ambitious 2040 climate target. As you noted in your hearing confirmation, animal farming is responsible for the vast majority of the agricultural sector’s greenhouse gas emissions. The focus of your action should be on areas of high concentration of livestock and how to transition these to sustainable animal farming practices with a reduced weight of livestock clusters. Farmers, and the broader value chain, need to be given clear transition pathways that take planetary boundaries fully into account. T echnofixes, as the Strategic Dialogue notes, will not achieve the emission reductions necessary. Real transformation to holistic animal farming is needed, based on high levels of animal welfare, done in accordance with the carrying capacity of the land, thus regenerating agricultural landscapes by integrating animals into farmland and allowing nature to flourish. Support the transition through an Agri-food Just Transition Fund Farmers will need financial support as they transition away from industrial factory farming (as discussed above). This support should be provided through a dedicated Agri-food Just Transition Fund, established outside of the CAP. Modernising the outdated EU animal welfare rules on keeping and killing animals, as well as labelling, including in aquaculture systems, is a key piece of unfinished business from the last mandate. It is also demanded by European citizens, as demonstrated by the End the Cage Age ECI. Finalizing these rules will ensure farmers have the certainty needed for sustainable investments, though they will also need support. These two elements should be at the heart of what the Agri-food Just Transition Fund supports. We welcome your commitment to explore accessing funding via the existing Just Transition Fund, as there is no time to lose; however , any just transition funding must be linked to clear objectives to transition away from industrial factory farming and improve animal welfare standards. Several of the issues raised in this letter also apply to fisheries and aquaculture, including needing to take a systemic approach to food systems, and enabling sustainable consumer choices. While the Strategic Dialogue did not consider the issue, we consider it to be an integral part of the Vision as it relates to food and look for it to be reflected. Given the multiple crises that the food and farming sectors face, there is no time to waste in accelerating the transition towards sustainable food systems. We have been deeply disappointed with recent actions by the Commission, from the undemocratic and misguided CAP reforms taken earlier this year , to the shelving of the Sustainable Food Systems Law and the withdrawal of the Sustainable Use of Pesticides Regulation. We sincerely hope that the cooperative spirit of the Strategic Dialogue represents a new mode of working together . A European board on agri-food (EBAF) may serve to support this new cooperative mode of work, however its composition should reflect the food system in its entirety and at all levels of governance, build on the Strategic Dialogue, and its procedures should ensure genuine participation that delivers tangible results. European food production does not occur in isolation but is embedded in international agrifood systems. Through dialogue and cooperation, the EU can also lead a sustainable transformation beyond its borders. We would welcome the opportunity to meet with you to discuss the Vision and your plans for the next five years. Sincerely, NGO Coalition

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