EU Specialty Food Ingredients, the voice of over 200 manufacturers of specialty food ingredients, urges the President of the European Commission, Ms. von der Leyen, the Members of the European Parliament, and the Council of the European Union to continue engaging with tangible proposals in the transition towards a sustainable, resilient and innovative EU Food System.
EU Specialty Food Ingredients calls upon the European Commission Presidency to clearly define its ambitions within the forthcoming "Vision for Agriculture and Food" publication.
In light of this we submit the following five requests for inclusion in the forthcoming framework legislation:
1. Integrating the economic dimension of sustainability: In the previous mandate, the economic dimension of sustainability, which encompasses the resilience of the EU food sector, was neglected in the preparatory documents related to the SFSF. At the same time, this aspect is essential for ensuring the successful transition of the food ecosystem.
The European Commission must assess the impacts of geopolitical and macroeconomic factors. Inflation, supply chain disruptions, and rising energy and raw material costs have placed European producers at a competitive disadvantage compared to international stakeholders. Any future legislative proposals concerning the sustainability of the food supply chain must be accompanied by comprehensive impact assessments on competitiveness and innovation. A robust EU competitiveness strategy, underpinned by investments in research and development (R&D) to foster innovative and sustainable ingredients, is essential for meeting evolving dietary needs.
Public-private research and investment partnerships (Horizon Europe, Cluster 6) and specific industry-oriented provisions (e.g., Taxonomy delegated acts or other food industry-specific measures) should be encouraged. Thus, we support the Antwerp Dialogue pledges for a Clean Industrial Deal and a comprehensive cross-sectoral strategy and EU Food Investment and Resilience Plan to secure Europe's long-term food security and international competitiveness in the sustainable transition.
2. Establishing a conducive, business-oriented, EU regulatory environment for a stronger and harmonized single market: The current legislative framework hinders innovation, feeds unnecessary polarizations and cumbersome enforcement, and increases uncertainties in the food supply chain.
The legislative drafting process should include technical dialogues with food supply chain stakeholders to assess potential regulatory burdens, trade-offs, and inconsistencies before enforcement. Impact assessments must be an integral part of the legislative process to guide final decisions effectively.
Strengthening governance and long-term coordination within the food supply chain is critical for a successful transition to sustainable and resilient systems. To address these issues, we propose the establishment of a dedicated position for the agri-food sector within the European Commission, alongside a dialogue forum for the food supply chain ecosystem, including food ingredients manufacturers.
3. Fostering Innovation for Sustainable Transition: Innovation is crucial for the EU's sustainable transition and for the EU food industry to remain competitive in the long term in a changed market context. The specialty food ingredients sector invests 3-8% of its turnover in R&D to support sustainable practices, circular input usage, and healthy diets (i.e. the manufacturing of alternative proteins for diversified diets, support for nutrient-rich diets, i.e. probiotics, prebiotics, and dietary fibre), but many innovative products fail to reach the EU market due to slow and complex approval procedures and uncertainty about return on investment. While the European Commission promotes innovation, the 'innovation principle' has yet to be concretely integrated into EU legislation. To stimulate investment and confidence in developing sustainable products and novel foods, a supportive and predictable policy environment is essential. For instance, developing and authorizing a new food ingredient in the EU can take over ten years, a process several times longer than in third countries. This requires substantial financial resources and reduces the investment's profitability. This demanding process, further slowed down by regulative inconsistencies and a crowded regulatory system, causes talents and resources to drain from Europe. The European Commission must address these challenges and recognize the critical role of the 'innovation principle' alongside the 'precautionary principle.
4. Promoting an integrated and holistic approach: A resilient food system requires an integrated approach to legislation at the EU level, as well as engaging in dialogues with all food supply chain stakeholders. For instance, the legislation targeting the primary sector must account for its impacts on the broader food supply chain. This applies equally to provisions targeting food safety, competitiveness, industrial green transition, investment, and research provisions. Food safety regulations, for instance, should not inadvertently increase food waste or delay research into innovative ingredients. The EU food and drink industry was actively involved in numerous consultations, including those of the Advisory Group on the Sustainability of Food Systems. However, the role of specialty food ingredients manufacturers was overlooked in strategic food-linked initiatives such as the Strategic Dialogue on the Future of EU Agriculture.
A genuine open partnership is necessary to overcome the current in-silo legislative approach. To this end, we request the creation of a high-level position within the EU Commission dedicated to the agri-food ecosystem. The role of this person would be to coordinate and bring holistic thinking to legislation impacting the agri-food ecosystem.
5. Proposing scaling up provisions to support EU SMEs to adapt to the changed context: Recent reports underline the need to strengthen the resilience and competitiveness of the EU food industry by a stronger EU Single Market. SMEs, which constitute a significant portion of the EU food and drink industry, are particularly vulnerable to market disruptions and often lack the resources to invest in long-term projects. While the specialty food ingredients industry has developed numerous sustainable and circular innovations, many of these remain isolated due to the challenges SMEs face in scaling up innovative processes and products.
Regulatory obstacles and administrative burdens are significant concerns for over half of Europe’s SMEs. A conducive legislative framework is necessary to accompany SMEs in the green transition, fostering innovation and resilience in the food industry.
We urge EU policymakers to remain committed in delivering an ambitious, innovative, achievable, and coherent SFSF proposal that enhances the sustainability, resilience, and innovation of the EU food and food ingredients industries.
Read our full pledge here.