Nobel laureates and scientific coalitions call on the European Parliament to embrace new genomic techniques for climate and food security. Within the EU, debates intensify over proposals to patent gene-edited plant. EP adopted its negotiating position while the Council’s presidency is still anxious to build a majority to adopt its position on NGTs which would open the way to trilogues.

While FAO studies the impact of biotechnologies on small farmers holders, the UK develop disease-resistant bananas.

Farm Europe highlights that EU agriculture sovereignty is still to be built

Today, Farm Europe presents its Sustainable Food Systems Indicator (*) at the opening of the 7th Global Food Forum, in Brussels, in presence of David Clarinval, Vice Prime Minister and minister for Agriculture representing the Belgium Presidency of the Council, Janusz Wojciechowski, European Commissioner for Agriculture, Dacian Ciolos, Member of the European Parliament, former Prime minister and European Commissioner as well as Arnaud Rousseau, President of FNSEA and Ettore Prandini, President Coldiretti. 

This indicator shows that EU agriculture sovereignty is still to be built. It also shows the strengths and weaknesses of every Member States. An analysis of all indicators highlights that, if the EU remains a global power for agriculture, it is also fragile, exposed to geopolitical games, climate risks & dependence on feeds and fertilizers. In addition, the EU is missing the opportunity of the bioeconomy (bioenergy and biomaterials).

The level of interdependency of each Member State within the EU is high. In most EU countries, most of the agricultural economic indicators are in the red : income by hectare decrease by 12% over the last 20 years, the EU lost 37% of its farmers and direct payments decreased by 31%. Overall, consumers and public finances have been the big winners of the EU policies, farmers are the big losers. 

The environmental transitions are on going in all but a handful of Member States, like the Netherlands and Denmark. Together with Finland, Hungary and Lithuania, those 5 countries did not put environment as a priority. Nevertheless, over the last 20 years, emissions dropped by 8% in the agricultural sector, and 20% for the arable crops. The use of the most dangerous phytosanitary products has been reduced by 43% since 2011. 

Over the last 20 years, the weaknesses of EU production and urbanization led to the lost of 10 million hectares. In the meantime, the EU increased its impact on land use outside Europe with 11 million hectares of imported deforestation, in particular due to its dependency on feeds. 

Czech Republic has the highest score, along side France, Romania and Poland, for its capacity to deliver social, environmental and economic sustainability together. In contrast, Finland, Sweden, Cyprus and to a certain extend Germany’s production systems are the most challenged. 

Ireland, the Netherlands and Germany gave the top priority to low prices for consumers. The best environmental dynamics are on going in Greece, Romania, but also Ireland, France and Czech Republic. The economic parameters are less negative than in other countries in Czech Republic, the Netherlands and Romania, while the best production dynamics are on going in Poland and Latvia. Hungaria is the only Member States with real dynamic when it comes to bioeconomy. 

(*) Farm Europe’s sustainability indicator provides an overview of the key parameters of social, economic and environmental sustainability. It is built on 12 situation and trends indicators and provides a consistent picture of the current situation both at EU agriculture and for single Member States. It reflects 20 years of policy choices, as well as climate, social and geopolitical challenges. It is based on structural and economic data sets from International and EU institutions (Eurostat, FADN, FAO, etc.).

New Breeding Techniques : a good news for farmers, tarnished by a request for labelling

With 307 votes in favour 263 against and 41 abstentions the report on the legal framework for New Genomic Techniques (NGT) was approved by the European Parliament. This is good news that will give farmers new tools to adapt to climate change and use less chemicals.

However, the European Parliament voted for a position that differs in many respects from that of the European Commission making it much more cautious towards NGTs. While the Commission basically equated NGT1 with conventional varieties the European Parliament demands that NGT1 must meet sustainability criteria and pass an environmental assessment in order to be placed on the market. In addition Farm Europe regrets that today’s vote calls for imposing labelling not only on reproductive plant material but also on final products containing NGT1.

While the Commission avoided the issue of patents postponing it to a different legislation the Parliament imposes a patent ban on new genomic techniques. On the organic the exclusion of NGTs is confirmed but the Commission is asked for a revision of this decision after 7 years from the entry into force of the regulation. This text will then have to be negotiated with the Council once the 27 Member States agree on a general approach. This afternoon the Belgian presidency at Coreper will try to make progress in this direction.

Production norms: meaning, multiplication as well as red tape issues

One of the causes of farmers’ distress often mentioned in protests in recent days is the excessive bureaucracy they have to deal with to access CAP funds. Farmers feel that Brussels dictates to farmers how to cultivate and raise livestock. This feeling is certainly well-grounded considering recent policy developments both at EU and national levels. There are many reasons for this, but not all of them can be blamed on the CAP as such, and all of them call for real political will to be overcome.

First of all, it should be pointed out that, of course, the European budget for the Common Agricultural Policy is very significant. Therefore, it requires appropriate controls and guarantees to ensure responsible use of public money and to minimise the risk of fraud. Each European fund requires management and control costs, and those of the CAP are no higher than those of other European funds. For the administrative bodies, total annual administrative costs are estimated at around 3% of the CAP budget. For farmers, the share of administrative costs corresponds to around 2% of internal costs.

However, it’s also true that the last CAP reform increased bureaucracy with the introduction of green measures – particularly when it comes to the compliance with the definitions of Ecological Focused Areas (EFAs). For Member State administrations, this is main lever for the increased costs of complying with control requirements and mapping these areas. For farmers, this is linked to the correct declaration of EFAs (length of declaration, location and accuracy of dimensions) and to the increased number of auditing checks on farms.

This increasing complexity has accelerated with the latest reform of the Common Agricultural Policy. The eco-regimes introduced since 2023 are not simply a recognition of the environmental benefits of certain agricultural practices. They also entail adaptation costs, some of them substantial. This trend is made all the more difficult for farmers by the fact that CAP funds have shrunk in real economic terms: between 2003 and 2023, the European CAP envelope lost 40% of its value.

Weaker funding, harder to collect

With regard to the current CAP, which came into force on January 1, 2023, it is of course too early to quantify the impact on the bureaucratic burden for farmers. It’s normal that an implementation phase generates a considerable adjustment period. While, for administrations, the introduction of eco-regimes and the tightening of cross-compliance requirements have certainly represented a considerable increase in bureaucracy, at least in the initial phase, for farmers, the constant change of rules is in itself a major problem, associated with permanent stress that explains at least part of farmers’ resentment of the bureaucratic burden. For them, the additional administrative demands are real and lasting if nothing is done to lighten the load.

In addition, the bureaucracy that farmers have to deal with is not only linked to the European aspect of the CAP; in certain cases, it is a question of national requirements which are added by choice of the Member State to the conditions to be met in order to receive European funds. This trend has been reinforced under the New Delivery Model of the CAP. A significant share of the rules are under the responsibility of the Member States themselves, as part of their strategic plans, approved by the Euroepan Commission, but drafted at national level.

Given that national authorities manage CAP payments, it is no possible for farmers to distinguish between European and local administrative requirements. The level of implementation and the different Member States’ governance (centralized or regional) make bureaucratic demands on farmers unequal across the EU. However, one conclusion can already be drawn: transferring rules to Member State level is no guarantee of simplification, and it comes with a detrimental collateral effect, by undermining the level playing field on the internal market, generating unfair competition from one country to another.

All considered, there are concrete solutions to simplify this framework, and Farm Europe suggested some of them already in 2019.

  • In order to substantially simplify the administrative burdens of the CAP and national strategic plans, it is feasible to limit rules and associated audits to the most ambitious ones. When a farmer implements an eco-scheme, which is by nature more ambitious and more effective than the basic requirement (cross compliance) associated with direct payments, it should be considered that his efforts is higher than the cross-compliance rules by definition. As a consequence he should no longer be audited for the cross compliance itself. This would be an automatic equivalence measure, guaranteeing considerable simplification without any loss of ambition of the CAP. On the contrary, it would reinforce the attractiveness of eco-schemes, and thus support farmers in positive transitional steps.
  • In addition, a working group should be set up within the Council, made up by agricultural experts from each member state to ensure that the rules for implementing the Common Agricultural Policy are as simple as possible, and that they do not generate distortions of competition. In this respect, structured exchanges of best practices between member states should be encouraged, in order to ensure that each of the cross-compliance rules is subject to an equivalent level of ambition, consistent with the diversity of agronomic situations.
  • Finally, as part of the current debate on simplification of the rules, Member States should be allowed to revise their national strategic plans with a view to simplifying eligibility conditions as early as 2024. The European Commission should undertake to approve these revised national strategic plans as soon as possible.

In any case, it is more the meaning of the measures, the multiplication of rules, sometimes contradictory, than the administrative problems as such that seem to pose the problem.

Pursuing administrative simplification and streamlining

For a sample of farmers surveyed as part of the European Commission’s study (1), the median time spent on CAP-related administrative activities is 15 hours per year. This figure includes all time spent on administrative activities by the farmer, potential family members or paid workers. But this time varies considerably if we take farmers from different member states.

The possibility to rely on external assistance also has a significant impact on the time farmers spend on paperwork. In the same sample, 43% of farmers used external assistance (payed) for aid-related administrative tasks. This help is often provided by cooperatives or professional organizations and, to a lesser extent, by banks or other service providers. These services are often covered by cooperative membership fees or included in bank charges. Recourse to this solution is more widespread in Italy, Spain and Sweden, where requests for help are rarely made internally. By contrast, less than 30% of farmers surveyed in Malta, France, the Netherlands, Germany and Estonia do so.

The level of digitalization in the various member states also has a major impact on the simplification of paperwork – since the last reform, the digitization of procedures has been widespread. Automation, digitization and the use of new technologies for CAP management and controls should not only create benefits for the future, but have already proven to do so.

This study mentioned above estimates that the costs incurred by administrations for greening represent one of the main items of expenditure in the management and control of direct payments. However, the situation varies greatly from one Member State to another, with smaller Member States incurring higher costs than larger ones. For farms, the situation also varies according to labor costs in the different Member States. Indeed, processing applications and carrying out on-the-spot checks requires significant labor costs.

The EAFRD (Rural Development Fund) is a fund with a relatively high administrative burden due to the type, size, variety and conditionality of its interventions. Errors add an extra burden and cost for farmers and businesses, as well as for public administrations. When such errors occur, additional clarifications and data exchanges are required.

In 2017, the Omnibus Regulation already included a proposal to further simplify the four CAP regulations for the benefit of farmers and national authorities. However, it is necessary to do more.


  • Working on the meaning of the rules and the coherence between them
  • Considering farmers automatically eligible for basic cross-compliance rules as soon as they enter more ambitious programs (eco-regimes).
  • Preserving competition on the internal market by avoiding national rules that put farmers in one country at a disadvantage compared to another, by setting up a working group within the Council involving the farming world and the institutions.
  • Opening up the possibility for all member states to simplify the rules initially put in place in national strategic plans as of 2024.

Europe: it’s urgent to say what you expect from your farmers!

Farmers are demonstrating their dismay all over Europe, exhausted by standards and financially drained, while the value of CAP compensation payments has fallen by almost 40% in 20 years, with inflation doing the work of undermining them.

Ahead of the farmers’ protests in Brussels, the European Commission tried to clear the way with a few short-term announcements, which were certainly welcome and had been expected for months, but far from getting to the heart of the matter.

The 4% set-aside requirement has been replaced, for one year, by a requirement to grow nitrogen-fixing plants without the use of plant protection products. The opening of borders to Ukrainian products has been slightly delayed by a restrictive clause, should imports exceed the already very high 2022-23 levels for poultry, eggs and sugar. Remember the disruption to European markets and the consequences of these import levels for these sectors, as well as for arable crops!

However, these measures and the promises of future administrative simplification do not answer the fundamental question: does agriculture still have a strategic meaning for the European Union? Does the European Union still want its farmers? What it expects from them ?

In 1992, Europe decided to cut its agricultural prices by 50%. This decision was taken both to boost consumer purchasing power and to enable EU agriculture to become a major exporter. In response to this clear political choice, payments were created to compensate some of the losses of farmers’ income, on the assumption that the market and consumers would pay the rest.

Since then, farmers have been asked to continue producing and offering quality products at affordable prices, but also to be the pillars of rural life. More recently, they are the backbone of the European Union’s climate transition. All this has been achieved without recognition — or even by pointing the finger at a farmers focusing on the problems rather more than on solutions. Without additional support, and even with a dramatic budget reduction that is taking away from farmers’ all their productivity efforts every year.

The return of inflation, the benefits of a move upmarket that have not materialised, environmental standards imposed in certain countries without any real impact analysis or implementation strategy – foreshadowing some of the proposals put forward by the European Commission under the Farm to Fork initiative – have taken their toll on the resilience of European agriculture to the political choices of recent years.

The EU must not try to escape with a few temporary measures and a few nice words of compassion. It must state what it expects of its agriculture.

Are the political decision-makers ready to accept that the future of the European Union and its ecological transition depends on growth in agricultural production, if we are to achieve food sovereignty and sovereignty in the bio-economy?

Through photosynthesis, agriculture is the primary source of solar energy that can feed us and support the decarbonisation of entire sectors of our economy: food, energy, biochemicals and biomaterials. And all without rare metals!

Rather than cowering, we need to look to the future of agriculture, a sector of the future that is key to the challenge of transition, not only through its ability to reduce its own emissions, but also to reduce emissions from other sectors. This will undoubtedly not be achieved with constant technologies. Innovations in crop rotation, bio-control, low-carbon fertilisers, digital technology and improved seeds are just some of the additional tools available to farmers.

Rather than focusing on the constraints, we now need to focus on the solutions, with one major challenge: to ensure that these solutions are available to as many farmers as possible, and not just a handful. To achieve this, we need to get back on the investment track, and put an end to a fundamental trend that has made the Common Agricultural Policy, the cornerstone of European integration, a little less political, a little less agricultural and a little less common in recent years.

Strategic dialogue: getting back on track with good news for EU farmers

The President of the European Commission today launched the work of the strategic dialogue on agriculture. This debate comes at the end of the current European Commission’s term of office, and in a very special context.

Across the European Union, more than 16 countries have been affected by large-scale agricultural protests in less than 18 months, which shows that this is indeed a European crisis, over and above the national sparks that set off the movements.

This widespread frustration can be explained by both long-term and short-term trends.

In 1992, the political choice for the Common Agricultural Policy was to drive prices down, and to compensate for structurally low farm prices with direct aid. In two stages, 1992-1996 then 2000-2006, Europe moved from a system of guaranteed prices to a system of support at prices 50% lower than in the past.

Since then, direct aids have continued to fall as a result of the CAP budget cuts – between 2008 and 2027, they will have lost more than 40% of their value, even though they represent on average more than half of agricultural income. On top of this, they have become increasingly difficult for farmers to collect, due to increased environmental requirements (higher costs) and more complex aid mechanisms (paperwork): farmers have to justify and document their activities, and they are exposed to controls.

The result is simple: income per hectare has been falling for 30 years. It is now at the same level as it was in 1995, despite an increasing workload and a climate of much greater uncertainty than in the past due to price volatility and climate change.

To maintain their standard of living, farmers have had no choice but to expand their farms, invest (in particular to meet new regulatory constraints), and therefore go further into debt. As a result, they are even more exposed than in the past to the first market downturn.

In 2021 and 2022, exceptional aids have been paid to farmers in most countries (amounts representing the equivalent of 15% of the CAP budget have been added by the Member States that could do so, led by IT, DE and FR), which has temporarily masked the reality of a sharp fall in direct aids over the period 2021-2027.

With the end of whatever it takes, 2024 is a return to the crude reality of the political choices made in 2019: that of an increase in the level of environmental ambition, paradoxically associated with a net decrease in this public supports, which are more complex to get for farmers. At a time when prices are plummeting.

This is the paradox of this period, and of the coming years if a new course is not charted. At the same time, the public authorities have gradually disengaged themselves from the economic problems of the farming world, and have increased the number of environmental initiatives that directly affect the competitiveness of farms, telling growers how to cultivate and breeders how to raise livestock.

Admittedly, many of the new European standards set out in the Green Deal have not yet come into force, but the CAP to be introduced in 2023 already incorporates some of them (this is the CAP part of the Green Deal), particularly through the eco-regimes, and some Member States have chosen to anticipate certain obligations included in the proposals. Added to this is the increased complexity of receiving lower levels of aid, which farmers have been able to see for themselves since 2023.

The gamble taken with the Green Deal was what has been called “moving upmarket”: consumers were going to pay more for their food, given the environmental issues to which they are sensitive, and the investments needed to carry out agricultural transformations would be made with cheap money – which was the reality at the time. The idea was to have less aid and more prices. And so make consumers pay.

Except that the initial context in which this strategy was conceived is now over. Public money no longer has the leverage effect – sometimes totally unrealistic – that the European Commission was proposing at the time. And consumers have deserted the premium segments, forced by inflation to look for the lower prices. Organic farming is the first victim. But the whole strategy of moving upmarket has been turned on its head. Local production is being replaced by more competitive imports. The history of de-industrialisation is being rewritten for agriculture. Pollution is not decreasing, it is being exported, with a negative impact on the planet and the economy.

In addition to this stark reality, the European Commission’s approach to trade strategy is also a form of thoughtlessness. It insists on moving ahead with the Mercosur agreement, which would be a disaster for certain agricultural sectors, and has opened the floodgates to imports of agricultural products from Ukraine without measuring the consequences for European farmers.

De facto, today, Ukrainian agriculture is part of the European internal market, without any preparation or transition. This is not a distant prospect, it is an economic reality that is already here. However, the Ukrainian agricultural model is one of large estates, the average being over 1000 hectares – with a hundred or so estates of several dozen or even several hundred thousand hectares. The European average is around 20 hectares, or 70 in France for example.

Our model of agriculture is therefore facing a twofold challenge: a low-cost environmental transition, and direct confrontation with an agro-industrial power that is the antithesis of the economic reality of our farms, and which enters without respect for current and future standards.

The demonstrations are symptoms of an impossible equation for farmers to solve. It is now the responsibility of the European Union to get its agricultural policy back on track and to develop solutions – which do exist – at European level for the orderly management of environmental transitions, while maintaining the ambition of remaining an agricultural economic power, and therefore with a production component in all market segments. We now need to build a European leap forward by correcting the shortcomings of the Green Deal with a new European Farm Deal. This is certainly what is at stake in the Strategic Dialogue, but even more so in the forthcoming European elections.

Farm protests: structural responses from the EU needed

Since 2019, the Covid crisis and the war in Ukraine have put agriculture and food sovereignty back at the forefront, including in political speeches. This renewed interest in agriculture has not, however, been translated into strong actions in support of a sector facing the tangible effects of climate change and fierce international competition.

Farmers’ protests across EU countries are now spreading to France and Germany. Since the outbreak of farm discontent that began in the Netherlands more than a year ago, it has spread to more than 15 Member States that have seen large-scale protests. Only a handful of countries have not been affected by this movement: Cyprus, Malta, Austria, Croatia, Denmark, Sweden, Finland and, to a lesser extent, the Czech Republic and Italy.

Of course, the trigger is different from one country to another. In Central and Eastern Europe, the surge in imports from Ukraine is the main catalyst. In Western Europe, it is the standards leading to a decline in production. In this respect, a recent study by INRAE has confirmed previous analyses showing the negative impact of the measures envisaged by the EU through the Farm to Fork programme, the agricultural component of the Green Deal. It puts the potential fall in total European production at 15%, compared with 9.6% previously (-26% for arable crops).

It should be emphasised that the main components of these measures, which are still under discussion — reduction in the use of plant protection products and fertilisers, increased set-aside and organic farming — have not yet had their full regulatory impact at farm level, except in a few countries that have anticipated some of these measures. However, the dynamic cannot be ignored. It is based on an initial idea: to push farmers to embrace environmental transitions through new regulatory constraints on the top of the CAP, forcing them to invest.

One paradox is that this strategy is largely associated with a reduction in public support for agriculture, to be reallocated to other priorities. It was conceived in an economic and financial context that is now a thing of the past: the era of almost free credit. It is also based on another paradox: the idea that less production will solve the problems at a time when, more than ever, Europe needs its farmers and agricultural products to meet the multiple needs of food, feed and the growing green economy.

There is a consensus on the fact that COVID and the war in Ukraine have plunged Europe into a new world, where food is a fully-fledged strategic value chain, used as a geopolitical weapon by Putin’s Russia, but also by all the other major powers. We urgently need to draw all consequences within Europe, so that farmers are not caught between contradictory injunctions and an unresolvable equation: more costs, less production. The major challenge of the current movements and the responses to them is to reposition agriculture as a strategic sector through concrete actions promoting economic and environmental performance together.

There is one figure that illustrates the current situation. Inflation has returned, melting the economic value of Common Agricultural Policy (CAP) subsidies like snow in the sun. The budget agreement for the period 2021-2027 already drew a line under the equivalent of one year’s direct aid in constant euros. With inflation, at the very least, two years’ worth of direct aid to farmers will disappear from the economic equilibrium of EU farms.

All in all, farm incomes are now, in constant euros, at the same level as in 1995, despite, for those farmers who can afford it, larger structures and the obligation to make greater use of capital. This is bound to create dramatic financial situations as soon as the markets take the slightest false step.

It’s easy to understand why, in such a situation, farmers feel that they are not being supported in their transition by either the public authorities or consumers, whose spending on food continues to fall, despite recent inflationary pressures that have penalised the most vulnerable among them. Yet everyone knows that there can be no low-cost transition in agriculture, as elsewhere. It will have to be financed, unless we relocate our food elsewhere in the world, even if that means turning a blind eye to the economic, social, environmental and geopolitical impacts of such a choice.

Faced with all these challenges, it is clear that the nature of the demonstrations across Europe, and particularly in the western countries of the EU, is not a matter of cyclical problems or passing bad temper. They are about structural imbalances, linked to concrete political orientations, to be corrected.

To restore balance, the European Union will have to rediscover the political ambition of its biggest common policy, the CAP. Over time and through reform, the CAP has tended to become less political, less agricultural and less common. Its economic component has largely been disarmed. Let’s reverse the trend and rediscover the path of investment in the future and of solidarity with the agricultural world on a European scale. Rather than less Europe, the current situation calls for a surge in European agricultural sovereignty.

The strategic debate announced by the President of the European Commission, Ursula von der Leyen, could provide such an opportunity. It should enable us to agree on an objective and sincere assessment of the situation, combined with a real desire to support farmers at European level in the face of the many challenges – including economic challenges – that they face, and to give this strategic sector the support it deserves. Solutions exist.

IED: a need for consistency and collective work

The European institutions reached, yesterday, a provisional deal on the revision of the Industrial Emission Directive (IED), after very tense discussions on whether or not to include certain agricultural sectors in the scope of this regulation. Finally, thanks to the determination of the rapporteurs of the European Parliament, the co-legislators decided not to include the ruminant livestock sector, which is a move welcomed by Farm Europe. They also decided to tighten the thresholds for sectors already covered by this regulation: pig and poultry producers will be affected by this new regulation. 

However, all livestock sectors are covered by two very important — and most welcomed — provisions obtained by the European Parliament : 

  • First, the European Commission will have to “assess, and report to the European Parliament and the Council on the need for Union action to comprehensively address the emissions from the rearing of livestock, in particular cattle, taking into account the range of instruments available and the specificities of the sector”, by December 2026. This is a recognition that the specificities of agriculture should be covered by an adequate regulation, not IED. In other words, this provision paves the way for a potential exclusion of all livestock sectors. Agriculture must be lifted outside the remit of this regulation, and covered by a dedicated framework, as long as farmers are working with nature and animals. This activity should not be assimilated to an industrial activities. Therefore, a fit for purpose framework must be established grasping the complexity of agriculture when it comes to its environmental footprint, but also its co-benefits. 
  • Second, “the Commission should assess, and report to the European Parliament and the Council on the need for Union action to comprehensively address the emissions from the rearing of livestock, in particular cattle, taking into account the range of instruments available and the specificities of the sector”. This provision covers all livestock activities, and calls upon the Commission to set up a level playing field for all product placed on the EU market, meaning both Made in Europe and imported. At a time where the European Union is multiplying efforts to foster trade, producers would, rightly, not understand to be confronted with unfair competition from imported meat with higher environmental footprint. In fact, Europe would be shooting itself in the foot, increasing the burden on its producers, while at the same time opening widely its market. 

Therefore, while the compromise reached by the trilogue is certainly not perfect for all producers, it contains provisions that paves the way for an improved and more consistent approach that require a collective work of all livestock producers together, ahead of the review clauses. 

IED: beyond politics, good reasons not to include ruminant livestock

The final negotiations on the directive on industrial emissions will address major issues for the future of European livestock farming. There are good reasons to avoid making the mistake of including ruminant livestock farming within the scope of this regulation. 

We consider that the inclusion of ruminant livestock in the scope of IED would even achieve exactly the opposite of what it intends to do, fostering the trend of this industry toward intensification, while decision-makers aim at promoting extensive livestock farming because of its multiple co-benefits including for carbon storage, landscape features and biodiversity. 

That’s why we fully support the approach of the European Parliament on this file, and consider that EU Member States shall follow this path, excluding ruminant livestock from the scope of this regulation, and addressing the challenge of emissions in other dedicated regulatory framework, better grasping the complexity and the need for holistic approaches of this specific sector. 

Dealing with the sustainability of livestock farming solely through the lenses of emissions would offer a premium to the most intensive livestock farming models, in a position of optimising the management of their emissions to the maximum, and missing out on all the positive amenities associated with grass-based livestock farming. 

The directive on industrial emissions provides for the development of best available agricultural techniques (BAT) to take account of each type of livestock farming. The environment ministers are considering a derogation for extensive livestock farming, to exclude farms with less than 2 cattle per hectare. As such, these ideas demonstrate the specific nature of the sector. But in some cases, if those derogations are a response to the administrative burden associated with the IED, they do not resolve the most fundamental problem: future market development, which will give the direction of livestock farming in the future. 

If, in the future, certain type of livestock farming can be draped in virtues on the basis of emissions alone, it is on this parameter alone that major buyers, especially those quoted on the stock exchange will make their purchasing choices in order to comply with the ESG parameters valued by the financial markets. Priority for them will be given to reducing emissions from upstream agriculture, at the expense of all other co-benefits, including animal welfare, biodiversity and balanced regional development. 

Therefore, rather than regulating livestock farming via a simplistic approach, it is appropriate to develop an ad hoc pathway to reducing emissions within a broader framework that takes account of the storage capacity of grasslands and all the other parameters specific to this type of farming, including biodiversity, the impact on the landscape and the contribution to the economic development of remote areas. 

In other words, we need to recognise the reality that ruminant livestock farming is not an industrial activity in Europe. It has no place in a directive on industrial emissions.