- Response to the Farm To Fork Strategy (March 2020)
The EPBA, European Professional Beekeepers' Association, recognizes the efforts made by the European Commission concerning the "Green Deal" and the "Farm to Fork" strategy: global approach of challenges throughout the entire food chain, from producers to consumers.
Beekeeping is often perceived as a mere hobby or an activity preventing farmers from doing their main job. The contrary is true. Beekeeping is indeed a part of agriculture and is an activity more than essential for European food security, e.g. through the pollination service provided by managed bees, as well as for its important contribution to the economic vitality of rural areas! Beekeepers provide the public services regardless of their status, the statistical threshold of 150 beehives to quality for a professional beekeeper (or “bee farmer”) having been largely outdated.
In the context of the Farm to Fork strategy EPBA, which represents more than 70 000 beekeepers in 16 EU Member States, advocates in particular for:
- A sustainable agriculture with clear objectives on reducing the use of synthetic plant protection products and the compliance with EU regulations such as the Directive on the sustainable use of pesticides. The fulfilment of these objectives should be a condition for the allocation of the Common Agricultural Policy (CAP) subsidies to farmers.
- A better traceability / transparency on the origin of agricultural and agri-food products.
1 / Setting and achieving ambitious objectives for a sustainable food production
The farmers’ dependence on plant protection products (PPP) cannot constitute a sustainable farm and food strategy. Many of the current PPP are products that farmers could do without. Many other PPP’s can be replaced by alternative treatments, which are less harmful to Pollinators, People (Producers themselves, incl. beekeepers, and the consumers) and leave less or no residues in the Product. Or they can be replaced by innovative practices that put agronomy - and no longer agrochemistry, back to the core of the food system from farm to fork level. We believe that it is necessary to promote these alternative and innovative practices so that they can disseminate and protect the Pollinators, People and farm Products, incl. hive products such as honey.
For us, there is no doubt that the CAP has to put in place tools to ensure fair income for European producers, including beekeepers, to maintain the viability of their farms. This must be done while abandoning an intensive production system, which the soil and other natural resources such as air and water cannot support any longer.
Financial support of farmers must be maintained, but it must be channeled more to a truly agro-ecological transition. To achieve this, both the 1st pillar of the CAP through the implementation of real eco-schemes across the EU and the 2nd pillar of the CAP are essential.
Reducing the use of PPP’s and their risks for pollinators
We draw attention to the persistence of distortions of competition between EU Member States, which arise by their arguments against implementing more environmentally friendly agricultural practices. More harmonization in legal regulations and practices pertaining to the use of PPP’s must therefore be achieved across the EU.
In this respect, we ask that the recommendations of the national French Health Agency (ANSES) be extended to all member states, namely:
- a spraying ban for all PPP’s on flowering crops, including application not only of insecticides, but also of fungicides and herbicides - which we now know are harmful to pollinators;
- in case of derogations, the application by spraying must be done after sunset in order to limit the impact on the entomofauna in general and on pollinators in particular. Night treatments allow better efficacy of the products (penetration) and thus a reduction in the doses used.
Other EU policies must be consistent with the objectives defined in the Farm to Fork strategy, in particular as regards as trade policy. EU market legal provisions on the use of PPP’s and their residues (MRLs) must apply to imported agricultural products. Otherwise, EU farmers are put in a situation of unfair competition and the efforts of European policy makers / public health authorities to provide the world’s best food safety and quality will be compromised.
Despite a pressure from EU trading partners to set up specific regulations for substances used in agriculture and food production and processing, the EU must continue to focus on the most advanced risk assessment (based on the state-of-the-art scientific knowledge) and on the prevention of exposure to PPP’s.
It should not be forgotten that a reduction in risks also requires better evaluations. For a long time and from the pollinators’ point of view, several routes of exposure to PPP’s have been neglected. Therefore, we ask for the implementation of the latest EFSA’s bee guidance document on the risk assessment of PPP’s on bees (Apis mellifera, Bombus spp. and solitary bees).
2 / Improving the traceability of agricultural and agri-food products: the case of honey
For European beekeepers, the transparency of the origin of honey in blends is a real issue. Beekeepers, who derive a significant income from the production of honey, are suffering from a critical market situation across Europe. To alleviate and improve the market situation, combat fraud in honey and unfair competition and improve transparency in the food chain, EPBA supports the following points of the Erdos report on the sector as adopted by the European Parliament in 2017.
53. Calls on the Commission to thoroughly test the large-scale import of honey from China in line with Regulation (EC) No 1036/2016, and particularly to probe the operations of companies exporting honey from China and to evaluate the quality, proportion of quantity and sale price level of the honey on the EU honey market;
54. Considers that, in the light of the large quantities of honey that are imported from China, a trend which has accelerated in the last 15 years, the buying-in price of honey under real production costs in the EU and the bad quality of ‘manufactured’ (rather than produced) imported honey should make it clear to the Commission that it is time to start investigating the practices of some Chinese exporters, in order possibly to initiate anti-dumping proceedings;
55. Calls on the Commission to require official batch-sampling and testing of honey from non-EU countries at the EU’s external borders, in line with Regulation (EU) 2017/625 (the former Regulation (EC) No 882/2004);
56. Notes that Directive 2014/63/EU stipulates that the country in which the honey has been harvested must be indicated on the label where the honey originates in a single Member State or third country; acknowledges, however, that further action is required to tackle fraud in the field of bee products and to address the unfair competition represented by adulterated ‘honey’;
57. Reminds the Commission that consumers have the right to know the place of origin of all foodstuffs; considers, however, that labelling such as ‘blend of EU honeys’, ‘blend of non-EU honeys’, and especially ‘blend of EU and non-EU honeys’, completely conceals the origin of the honey from the consumer and consequently fails to fulfil the principles of EU consumer protection law; calls on the Commission, therefore, to ensure the accurate and mandatory labelling of honey and bee products, as well as greater harmonisation for honey production, in line with the legislation on quality schemes for agriculture products, in order to prevent consumers from being misled and facilitate the detection of fraud; recognises the success of direct sales of honey, which eliminate part of the problem as regards labelling of origin;
58. Asks for the ‘blend of EU and non-EU honeys’ descriptor on labels to be replaced by an indication of exactly which country or countries the honey used in the final product come from, and that these be listed in the order which corresponds to the percentage proportions used in the final product (additionally stating the percentage by country in a given product);
59. Asks the Commission to amend the Honey Directive with regard to the use of the word ‘honey’ or the terms ‘containing honey’ or ‘made with honey’ in the designation of processed products, or in any graphic or non-graphic element indicating that the product contains honey, such that those terms may only be used if at least 50 % of the sugar- content of the product originates from honey;
60. Supports the idea of the Member States making it obligatory to indicate the place of origin of the honey on honey and other bee products, as is the case with certain meat and dairy products.