While Italy granted its approval on May 30th for field testing NGTs for experimental purposes, and the upcoming Spanish EC presidency declared its intention to support research and implementation on new genetic technologies, the release of the official EC’s proposal of regulation on NGTs was postponed from June 7th to July 5th.
In parallel, Canada Relaxed its NGTs regulation, while Japan developed CRISPR allergen-free eggs.
Structural changes call for structural responses. The stronger tights between Ukraine and the EU are here to stay. It is very likely that new processing capacities will be needed to valorise agriculture commodities that will be attracted by the EU market, depending on global markets and transport costs developments. This new reality calls for a new direction to be given to the Green Deal. A new impetus to the bioeconomy in the EU would not only strengthen strategic productions (food, feed, biofuels, biomaterial, etc.) and help stabilising agricultural markets, but also provide a long term support to Ukraine economy and democracy.
Imports of grains from Ukraine into neighbouring EU countries have disrupted local markets, pushing farmers to ask for an end of duty-free imports, and some countries to follow suit and block them. The crisis has raised shock waves in Brussels, as the well-justified support to the Ukrainian economy, victim of the Russian aggression, created a large movement of opposition to one of its key components – the temporary abolition of all custom duties.
The Commission attempted to compensate the affected farmers with a first additional support package through the CAP crisis reserve, but quickly enough a second and larger package was deemed necessary. Despite throwing resources to calm the protests, calls for an application of safeguard clauses are still on the table.
The competitiveness of Ukrainian wheat, maize, sunflower and barley (to mention only a few sectors), is well known. Already more than 20 years ago, after the fall of the Berlin Wall and the end of the USSR, Ukrainian imports of wheat were coming into the European Union, even after paying the full import taxes. That situation led the European Union to renegotiate its external protection for wheat in the WTO, raising the duties applied.
Ukrainian exports suffered with the Russian aggression, dropping in the case of maize from the highs of 27 million tonnes in 2021/22 to a forecast of 20 million tonnes in the current campaign, on wheat from around 19 to 15 million tonnes, and on barley from around 6 to 3 million tonnes in the same campaign years. However, despite the fall in exports, the opening of alternative trade routes to the traditional Black Sea made large quantities of Ukrainian grains available in the EU neighbouring countries.
The root causes of the problem will not go away. EU markets are more attractive to Ukrainian exports than far away markets in developing countries. Even when the war is over, and hopefully Ukraine starts recovering from the wounds, it is likely that the European Union will extend forms of financial, economic and trade support for a large period, also in view of a possible accession of Ukraine to the EU.
Therefore, the EU should figure out lasting solutions to the Ukrainian grain imports, instead of pilling up compensation package after compensation package. Boosting the bioeconomy could provide a long-lasting solution to the additional availability of grains beneficial for global food security.
Incentivizing investments in bioeconomy could add value to maize, wheat, barley and sunflower production to mention a few, into high value and much needed proteins, energy and all kinds of biomaterials. Those products are highly needed to overcome the challenges of food security and environmental transitions, while at the same time stabilizing agricultural markets. This would benefit global food security as imports from Ukraine would reduce the overall EU footprint on other markets, notably soy from South America.
In the first five months of 2023, the European Union imported roughly the same amount of grains from Ukraine as in the entire pre-war campaign. This, despite the war’s impact on Ukrainian agriculture. A large share of this grain face difficulties to be re-exported to global markets, as is already the case with Central European countries’ production. Logistic challenges in this part of Europe are not new.
The European Union needs to set up new processing capacities to valorise an additional production coming from Ukraine on a structural basis, that will otherwise weight yearly on the EU market, especially considering further integration of the Ukrainian economy to the internal market.
Short-term measures triggered by the EU won’t be enough to address a structural challenge. Indeed, the lack of effective market mechanism tools currently included in the Common Agricultural Policy to cope with market disturbance is plain to see. This should press the European Union to rethink its agricultural policy to provide more teeth to its economic levers. However in the current situation no market measure will compensate a structural shift in market reality. Structural changes call for structural responses.
In a context where high-value food, feed, energy, and biomaterials is increasingly strategic, the EU should not delay launching a new wave of investments in these sectors. This effort should provide a new direction to the Green Deal’s approach, promoting sustainable growth for agriculture and related sectors.
Included within the current Renewable Energy Directive (RED), the European Union has room for maneuver to incentivize bioeconomy that produce at the same time a wide range of food, feed, biofuels and biochemical products. Today, the percentage of crop-based biofuels in the transport energy mix in the EU hovers below 5%, whereas the RED accepts a higher limit of 7% to be accounted for the EU renewable energy mandates. Ambitious climate targets calls for higher contribution from agriculture in the decarbonation effort of the economy.
The recent Council Conclusions “on the opportunities of the bioeconomy in the light of the current challenges with special emphasis on rural areas”, on the initiative of the Swedish Presidency, “emphasises the role of a sustainable and circular bioeconomy in dealing with climate, biodiversity, energy and food security issues, as well as its potential to diversify income, create jobs in rural and coastal areas, and support the EU’s green transition and increased resilience.”
This political will should lead to actual investments. The Commission should facilitate the process through policies that encourage investment in the bioeconomy, without excluding any sectors that might contribute. Particular attention should be made not to hamper investments through ill-conceived taxonomy regulations. Member States should establish national mandates and policies that foster these investments.
Let us react to the present crisis to bring forward-looking and lasting solutions, mobilising the EU investment capacities to trigger a surge of the EU bioeconomy. This would also provide a long term support to the Ukrainian economy and democracy.
In response to criticisms related to the complexity of the Common Agricultural Policy (CAP) and its disconnection from reality, the European Commission has proposed the implementation of national strategic plans, leaving it up to the Member States (or regions) to define the details of the measures to be implemented for farmers to get direct payments. This is a key feature of the new CAP, with serious impacts on the level playing field at EU level for farmers. The implementation of GAEC5 is shedding lights on this new reality, with farmers in Wallonia paying the high price.
Articles 12 and 13 of Regulation 2021/2115 of the Common Agricultural Policy (CAP) deal with conditionality, i.e., the set of obligations relating to good agricultural and environmental conditions (GAEC) that farmers must comply with to access funds from the first pillar of the CAP. The national plans submitted by the Member States must specify the details of these measures, indicating concretely how they intend to apply them to their farmers. Although this new approach, initially presented as a common-sense evolution in response to the failure of multiple attempts to simplify the CAP, it nonetheless presents a major obstacle. As far as basic aid is concerned, it places European farmers in the face of variable rules, with sometimes strongly divergent economic and agronomic impacts.
Each of these GAEC measures aims to address common environmental, health or animal welfare challenges, with the ambition of having a positive impact on a very large scale across the entire territory of the European Union, mobilizing a collective effort of all EU farmers. These actions must complement other specific measures and financed within the framework of eco-schemes or agro-environmental measures. All national (or regional) strategic plans are known. Even, many Member States are already preparing to adjust their initial plan, with the insights of one year of implementation. It is therefore useful to examine the details, analyzing not only their but also their socio-economic impacts. It appears that national or regional administrations are sometimes just as – if not more – creative than the European administration in terms of complexity, sometimes leaving farmers isolated in the face of an increased risk of inequitable treatment, without any real European debate.
In this regard, the analysis of GAEC 5 is particularly significant. Faced with the important challenge of soil erosion, the cross-compliance rule in the EU regulation states that it is necessary to “manage soil work in order to reduce the risk of degradation and erosion, taking into account the slope.” The objective to be pursued is that of “minimal land management reflecting specific local conditions in order to limit erosion.”
It plays an important role at the European level, alongside GAEC 4 and 6, in combating this phenomenon that affects the long-term fertility of soils. All other parameters are now the responsibility of the Member States or regions. They are the subject of the comparative study below. Previously, despite some flexibility, most of the details were fixed by a delegated act of 2014, which established the basic principles of minimum soil cover, the minimum area of farms that must be covered to comply with this GAEC, crop rotation or reduced tillage.
The challenge of erosion throughout the European Union
It is important to recall that erosion is a challenge affecting all regions of the European Union, without exception, as shown by the recently published data from the Joint Research Centre in the context of discussions on soil strategy. By far, the most significant vector of soil erosion, both quantitatively and geographically, is water. This affects most Member States, with a stronger impact on Mediterranean countries and Central European countries. Erosion caused by ploughing also has a very large geographical impact, affecting all Member States, with a lesser impact in part of Belgium, the Netherlands, some regions in northern Germany and Poland.
As for wind erosion or erosion caused by harvesting, they are indeed more localised: the former occurs on the northwest coast, some regions of the Black Sea, southern Italy, or northern Spain, and the latter occurs in crop areas where uprooting is involved. The latter represents a much smaller part of the erosion phenomenon at the EU level. Measures planned under GAEC5 have limited relevance regarding harvest erosion. Combating this requires technical means aimed at limiting the amount of soil carried away during the harvesting of potatoes or beets through gentle digging or the use of specific conveyor belts.
Diverging ways to define targeted areas
In the case of Wallonia, the GAEC5, which determines the granting of all aid to farmers, is particularly detailed and expensive. Wallonia’s approach is very different from that of the majority of other Member States. We will analyse it in detail.
One substantial difference lies in the criteria used by Member States to define the areas to take specific actions. The vast majority of Member States (BG, EE, EL, ES, FR, HR, IT, CY, LV, LT, HU, MT, PL, PT, SI) only mention the “slope” of the soil as a criterion for defining intervention areas and almost always refer to areas with a slope greater than 10%.
Regarding other national plans, the criteria are, however, different. Generally, they are related to differentiated slopes or measures that apply to all areas, regardless of their erosion risk.
For example, Austria’s strategic plan refers to a soil slope greater than 10% but also prohibits agricultural machinery from working on frozen, water-saturated, flooded, and snow-covered soil. Ireland refers to slopes greater than 15% and 20%, but also proposes criteria for all meadows. Plowing of all meadows is prohibited between October 16th and November 30th. For the Netherlands, measures exist for slopes greater than or equal to 2% and greater than 18%. And for Slovakia, specific measures for areas severely threatened by water or wind erosion are mentioned, without specifying criteria. The measures apply to slopes greater than 3%. Finland, Denmark, and Sweden introduce criteria related to the proximity of soils to watercourses.
The Wallonia Region, on the other hand, stands out for its approach. It identifies three zones (high erosion risk, very high erosion risk, extreme erosion risk) using an equation based on the revised universal soil loss equation (RUSLE), which takes into account the following factors: the rainfall erosivity index, the soil erodibility index characteristic of the soil type and its properties, and the topographical factor combining slope length and steepness.
The only national plans that, along with Wallonia, identify different territorial zones with differentiated erosion risks based on multiple criteria are those of Flanders, Germany, Luxembourg, and the Czech Republic. However, these Member States use this tool with significant differences to be taken into account compared to the plan of Wallonia.
The strategic plan of the Flemish Region also provides that “the sensitivity to erosion of a plot is determined based on a calculation model of the average annual potential erosion per hectare using the Revised Universal Soil Loss Equation (RUSLE). Thus, slope, slope length, and soil type are taken into account. There are six erosion sensitivity classes: very high (purple), high (red), medium (orange), low (yellow), very low (light green), and negligible (green). But the impact of this formula in Flanders is marginal compared to that for Wallonia, according to the respective simulations carried out by the Wallonian (FWA) and Flemish (Boerenbond) agricultural organisations (1).
The German strategic plan delegates the designation of erosion risk zones to the Länder, based on uniform criteria, such as soil erodibility factor, slope factor, rainfall and surface runoff erosion factor, and wind erosion risk. The Czech strategic plan identifies several erosion risk zones based on the following criteria: slope length and steepness, structure and texture of the arable layer, soil organic matter content, soil erosion sensitivity, protective effect of vegetation, effectiveness of anti-erosion measures, and soil profile permeability.
Finally, the Luxembourg strategic plan uses a methodology based on multivariate statistical learning (machine learning) for arable land for classifying erosion risk zones. The calculation of potential erosion from RUSLE is only used for grasslands. In addition, there are measures for all agricultural land, for example, existing retention terraces must be maintained on the entire UAA (in arable land, permanent grassland, and permanent crops).
Ambition divide: various approaches for the same measure
As for intervention measures, there are numerous ones. The most common ones are related to soil work restrictions, such as the prohibition of plowing during certain periods. Twenty national plans provide for such measures (AT, BE-FL, BE-WA, CZ, DE, DK, EE, IE, FR, IT, CY, LT, LU, HU, MT, NL, RO, SI, SK, SE). In addition, 13 strategic plans (AT, BG, DE, EE, EL, ES, FR, HR, LV, MT, PL, PT, RO) include measures on the orientation of soil work relative to slope. Twenty-three strategic plans (AT, BE-FL, BE-WA, BG, CZ, DE, DK, EE, IE, EL, FR, HR, IT, LV, LT, LU, HU, NL, PL, SI, SK, FI, SE) include measures related to vegetation cover.
In addition to these common measures, many Member States or regions are identifying other measures to combat soil erosion. For example, the “anti-erosion strip”. Denmark, Finland and Sweden refer to a buffer strip along watercourses with a ban on fertilisation, spraying, and soil work on a minimum width of three meters (six for Sweden), a measure that also meets GAEC4, but which they also consider as an anti-erosion measure. Germany and the Czech Republic mention buffer strips as an anti-erosion measure, but do not specify their length, with Germany leaving the details of the measures to the Länder. The Luxembourg strategic plan provides for the mandatory installation (except in the case of meadows) of anti-erosion grass strips with a minimum width of 3 meters in areas with a high and medium risk of erosion. France and Austria also provide for vegetated strips, with a minimum width of 5 meters in both cases, as an anti-erosion measure.
Conclusion
The analysis of the 28 strategic plans of the new Common Agricultural Policy (CAP) shows that only the Walloon and Flemish plans mobilise for all agricultural land in their region the RUSLE mapping methodology to target the implementation of GAEC5. Flanders is less concerned with this mapping, given the strong topographical differences with Wallonia.
These two plans also stand out for the size of the buffer strips, which can be up to 9 meters. The impact of the targeting methodology of the plots excluding most Flemish farmers from the system means that the choices made in implementing GAEC5 in Wallonia put farmers in a unique position in Europe of competition distortion compared to other European farmers, including those in very similar regions.
This is despite the fact that it is a cross-compliance measure that impacts all CAP support, not just a specific measure that is subject to ad hoc compensation or incentive. While the options taken by some Member States can be explained by particular agronomic, climatic or topographic conditions, it is difficult to single out Wallonia to justify such a difference in approach in the implementation of this GAEC.
The expected impact in Wallonia is disproportionate compared to the impact of the same measure elsewhere in the European Union. However, unlike agri-environmental measures or eco-schemes, it does not involve additional remuneration to compensate for these distortions. It is mandatory for all farmers concerned, and not just targeted to those who wish to engage in practices on a voluntary and specifically remunerated basis.
The month of April was marked by concerns in the southern EU countries about the 2023 harvest due to persistent water deficits and the finalisation of negotiations in the European Parliament on the recast of the Geographical Indications Regulation.
Moreover, the International Wine Organisation has published data on world wine production, consumption and exports for 2022. These data show a further decline in export volumes, and a new export record in value terms which has been reached due to inflation.
The EC’s February positioning over the regulation on NGTs triggered contrasting reactions across European Countries and different sectors. Scientists believe they will help facing the environmental and food security challenges. Some ministers are worried on their impact on small farmers and firms.
On the other hand, the UK adopted the Precision Breeding Bill, which will allow the country to move forward in NGTs research and development, ensuring its competitive advantage on the international market.
Outside Europe, the US are expecting higher government investments on Biotechnologies, while Brazil and Indonesia approved the import and production of BH4 wheat.
In April 2023, the European Commission launched initiatives on food price fluctuations, agricultural subsidies and new regulations on the use of plant protection products. It has also launched a consultation on a new set of EU taxonomy criteria for economic activities contributing to the protection of water and marine resources, the transition to a circular economy, pollution reduction, and the protection of biodiversity and ecosystems.
EU institutions have also adopted measures to tackle deforestation, promote the bioeconomy and preserve honey production.
Finally, the European Regions Research and Innovation Network (ERRIN) and the European Commission have launched the Soil Mission Manifesto, which aims to protect soil health in Europe. The manifesto underlines the urgent need for action to remedy the degraded state of 60% of the European Union’s soils.