The publication of the proposal for a « Regulation of the European Parliament and of the Council on plants obtained by certain new genomic techniques and their food and feed » is scheduled for 5 July next, and the draft is circulating among the various DGs in an interservices procedure for final amendments before publication.
The text that is now circulating – unless any last-minute substantial changes – gives us an idea of the direction in which the Commission intends to go. It confirms our expectations, providing a good working basis on this file to boost innovation, and meet the health, climate and environmental challenges, ahead of the negotiations to come with the co-legislators.
First of all, a clear distinction is made between 2 groups of NGTs:
1. Plants obtained through targeted mutagenesis or cisgenesis, which could also occur naturally or be produced through conventional breeding (‘category 1 NGT plants’) would be treated similarly to conventional plants and would not require authorisation, but a simple notification. In addition, a transparency register would be established. If the notification takes place before the field trial, the verification of the criteria takes place at Member State level and the national decision has EU-wide effects and also applies to the placing on the market. For placing on the market where no field trials have been carried out in the EU, including imports, the decision is taken by the Commission, after verification of the criteria by EFSA. No specific labelling would be required.
2. All plants from NGTs that do not fall under the first case are called category 2 NGT plants’ and would fall under GMO legislation and therefore undergo an authorisation process. The risk assessment would be adapted to take into account their different risk profiles and measures would be introduced to incentivise plant products that could contribute to a sustainable agri-food system. Traceability would be maintained as well as labelling. On a voluntary basis, GMO labelling can be supplemented with information on the purpose of genetic modification, e.g. to increase the sustainability of the plant. Unlike for GMOs, for these plants it will not be possible for Member States to restrict their cultivation or circulation on the market. There will be regulatory incentives for (potential) applicants of category 2 NGT plants containing traits with the potential to contribute to a sustainable agri-food system, e.g. an accelerated procedure or where the applicant is an SME, it shall be exempted from the payment of the financial contributions to the Union Reference Laboratory and to the European Network of GMO Laboratories.
With respect to these two categories of NGTs, herbicide-tolerant NGT plants, even if they fulfil the notification criteria (category 1 NGT) will remain subject to authorisation and the related requirements, in order to be able to assess their impact on human and animal health and the environment in the medium and long term. “There is evidence to show that herbicide-resistant weeds may result from the combined use of herbicide-tolerant varieties and associated herbicide overuse, with potential health and agroecosystem impacts,” the Commission explains.
As far as organic is concerned, according to the Commission initial draft, both NGT1 and NGT2 would be banned in organic production and to enable this, it would be mandatory to indicate the use of NGT in seed labelling. Member States would have to take implementing measures for coexistence.
Once formally adopted by the college of Commissioners on the 5th July, this proposal will be discussed under co-decision by the European Parliament and Council. Both ComENVI and ComAGRI will be involved until the end of this mandate. Most probably it will be up to the next Parliament to finalise the deal and negotiate with the Council.
At a time when the vote on the Nature Restoration Law in the European Parliament’s Environment Committee has taken a dramatic turn, and was held against a backdrop of unprecedented campaigning, it is worth taking a peaceful look at this text to go beyond the simplistic pro- or anti-nature postures that have been asserted in the debate over the last few days, and understand what is at stake. This law is not the only initiative aimed at protecting biodiversity.
The aim of this regulation is to enshrine in law the objectives of restoring natural ecosystems and biodiversity by requiring Member States to draw up national plans. It creates an obligation to achieve results, with the introduction of a legal risk, including through easier access to justice for any citizen with a sufficient interest in the matter, in the spirit of citizens’ initiatives such as the Affaire du siècle and the condemnation of certain States for climate inaction.
This judicialization of environmental protection is the main innovation of the text, which aims to place a legal risk on Member States in the event of non-compliance with progress trajectories. It comes on top of the many directives and regulations drawn up, and in some cases adopted, in recent months as part of the Green Deal to protect the environment, combat climate change and protect biodiversity.
The regulation covers all ecosystems, including agricultural land. Article 9, entitled “restoration of agricultural ecosystems”, aims to increase biodiversity on agricultural land. To achieve this, the European Commission proposes that Member States should achieve an upward trend at national level for each of the following indicators in agricultural ecosystems by 2030:
– grassland butterfly index ;
– organic carbon stock in cultivated mineral soils ;
– share of agricultural area with high-diversity landscape features.
These three indicators are described and specified in Annex IV, which states that “agricultural land with high diversity topographical features is permanent natural or semi-natural vegetation present in an agricultural context that provides ecosystem services and supports biodiversity” and must meet the following conditions: it may not be used for agricultural production (including grazing or fodder production), and it must not be treated with fertilisers or pesticides.
Member States are also expressly asked to restore the population of farmland birds by 2030, on the basis of a list of species detailed in the regulation, and to restore 70% of peatlands to wetland status by 2050.
The point on “agricultural area with high-diversity landscape features” is undoubtedly one of the most sensitive and the one that has prompted reactions from many MEPs. These are measures to be applied at Member State level, which will be responsible for applying them to farms.
In its proposal, the Commission defines the 10% target as a European Union objective, without specifying how it is to be applied by each Member State. This is left to the discretion of the European Commission, which, under Article 14, is required to ensure that the 10% of agricultural area with high-diversity landscape features is achieved. This would most probably lead the European Commission to ask Member States to take agricultural land out of production, when approving the national plans in order to achieve this objective, and if not, an increased legal risk would obviously weight on Member States.
In addition, this proposal creates an overlap and divergence with the CAP cross-compliance requirements which define the rules (different from those proposed in this nature restoration project) to be respected by farmers with regard to ecological focused areas and landscape features.
The draft text presented by the Commission must also be analysed in the light of the provisions of the proposed regulation on the sustainable use of pesticides, which calls for a reduction in their use at national level and a ban on the use of chemical pesticides in areas defined as sensitive covering 70% to 90% of the agricultural land of certain countries.
Finally, broad delegated powers would be given to the European Commission to define the outlines of future national plans, the conditions for their approval, as well as to amend the annexes to the regulation.
Interested in knowing more about the green transition, innovative intercropping systems and how this can benefit the overall agricultural system?
Then you may want to take a look at LEGUMINOSE H20 Research Project, which will focus on identifying the obstacles in intercropping and boost awareness among interested actors such as: farmers, stakeholders, etc. by providing information and practical demonstrations economic, environmental, and social benefits of legume-cereal intercropping.
Thanks to the diversified team, the LEGUMINOSE project aims at ensuring broad and various perspectives. Based on the policy analysis and workshops, Farm Europe will contribute to the team by providing a set of policy recommendations aimed to scale-up the intercropping practises across the EU.
In recent weeks, the world of wine has been marked by :
– The European Parliament vote to revise the system of protected geographical indications (PGIs), with the aim of preserving PGIs. This has strengthened the intellectual protection of wines.
– The problem of stocks in the main wine-producing countries, in the face of falling consumption and the imminent arrival of this year’s harvest. The European Commission has finally adopted a delegated act to allow the distillation of red and rosé wines.
– The complaint lodged by winegrowers’ representatives with the Commission against Ireland and its new regulations on health labelling of alcoholic beverages. Doubts about this legislation are shared by many member states, as well as by third countries within the WTO, most notably the United States.
During May 2023, the European People’s Party took the lead in the EP in order to reject proposed regulation on nature restoration, citing concerns about food security and economic viability. It succeeded in achieving rejection of the proposed regulation in COMAGRI and in COMPECH. In the meantime, the European Parliament released a report emphasising the need for collective action to ensure food security and address global challenges in the agri-food sector. Finally, Commission Executive Vice-President Frans Timmermans has defended in COMAGRI the proposed Nature Restoration Law, emphasising its benefits for farmers and the importance of addressing the climate and biodiversity crisis, without convincing most of the Comagri’s MEPs.
Spain has appealed to the EU Commission for assistance in dealing with a severe drought that is affecting the country’s agricultural sector. In parallel, various stakeholders in the food chain have called for the development of a new EU framework legislation on sustainable food systems.
The European Food Safety Authority has released animal welfare recommendations, and the Economic & Financial Affairs Council has given final approval to a regulation on the trade of commodities associated with deforestation.
Prior to any step forward at EU level on cellular food products a serious work should be launched to identify all the potential risks that are still unclear. At least the risks are clearly closer to the pharmaceutical world than food products. The evaluation by public authorities shall not be limited to the final product, but instead must cover the full process, which makes the Novel Food regulation not fit for purpose.
The draft own-initiative report by MEP Emma Wiesner (Renew Europe) has caught most of her colleagues in the European Parliament by surprise, planting the subject of cell-based food high on her wish-list to address the EU’s protein autonomy challenge alongside more positive elements like the synergies between protein and bioenergy production, which are important to underline.
The Swedish MEP believes that “cell-based agriculture and seafood are promising and innovative solutions”, suggesting that “innovative cell-based foods can help increase protein production and complement agriculture”. Therefore, for the MEP, the marketing process “should be based solely on the safety of the product” under the Novel Food Regulation, which should itself be simplified to speed up the authorisation process and thus encourage innovation.
In this context, European elected representatives will have to quickly shape their opinion on a complex subject that touches on a multitude of ethical, environmental, technological, economic and of course health dimensions.
They will have to take a position while cell culture processes are still at an emerging step, in a test phase to move from the laboratory to the industrial scale, without any clarity on the chances to succeed safely for consumers. It is therefore essential to mobilise thinking to bring rational elements to a debate that is really taking food into hitherto unknown and uncertain territory.
What are we talking about?
There are many processes and variants for cell culture. Most of them are laboratory production processes for food and other animal products. Starting with a sample of animal cells taken from muscle or embryos of living animals and placed in a nutrient-rich medium, the cell tissue is grown under controlled conditions in bioreactors to develop into muscle, fat or other tissue cells to form conglomerates of animal cells and other animal products (such as leather, gelatine, collagen) (Warner, 2019).
The medium, in which the cells are grown, is synthesised from fetal bovine serum, although currently many companies are attempting to develop animal-free serum options for cost and ethical reasons. The cells are then harvested and aggregated or processed to give the product its final formulation.
After seeing these products as a potential answer to the climate challenge a decade ago, the latest scientific studies are much more cautious about any benefits, given the multiple sources of pollution and the amount of energy required. In most cases, livestock farming requires more land, but less energy, chemicals or plastics, for example, not mentioning hormones. This is all the more true since the comparative impact analyses initially carried out by the cellular meat sector fail to take into account in a serious manner the co-products or co-benefits associated with breeding on the one hand, and the issues associated with a possible transition to the industrial phase on the other.
What is the status of their development?
It might sound like science fiction for most EU citizens. But since the first synthetic burger was presented to BBC viewers in August 2013, cell culture has become a reality both in terms of product development and influential economic ecosystem. In December 2020, Singapore became the first country to allow synthetic imitation chicken meat onto the market. A first step was also taken in the US when the Food and Drug Administration completed its pre-market consultation in November 2022.
Nevertheless, the transition to industrial scale remains a challenge, despite the significant financial investments already made by market players. The transition from the laboratory stage to large-scale development lines is far from complete, and the control of cell variability in non-“natural” atmosphere is not guaranteed. The development of “culture medium” – most often today fetal serum – which represents a significant cost, remains unresolved, as do ethical questions. The energy costs associated with these culture processes remain extremely high.
There are many initiatives underway to produce imitations not only of products such as meat or milk, but also of breast milk, egg white, foie gras, oils, leather, gelatine and collagen, caviar, seafood, chocolate and coffee.
What legislative authorisation process should apply in the EU?
Currently, cell-based products can fall under either the Novel Food Regulation (EU/2015/2283), which specifically mentions cell culture, or the Genetically Modified Food and Feed Regulation 1829/2003. EU law defines a novel food as “any food which was not used for human consumption to any significant degree within the Union before 15 May 1997”, the date on which the Novel Foods Regulation entered into force. The regulation further specifies that novel foods can be newly developed food, innovative food, food produced using new technologies and production processes, as well as food that is or has been traditionally consumed outside the EU.
The Novel Food process usually takes between 18 and 24 months, but can take longer as in the case of Chia seeds, for which the UK authorities’ application to the Commission in 2004 was successful in 2009. The European Food Safety Authority plays a key role in this.
While a representative of the European Commission indicated at an event in the European Parliament on 13 July 2022 that cellular products should follow the Novel Food Regulation, this analysis is far from unanimous, due to the multitude of questions raised by those disruptive products. Some experts believe that the GMO regulation is much more appropriate, as most of the time the manufacturing process involves genetically modified organisms. Furthermore, given their proximity to pharmaceutical products, the question of pre-clinical and clinical studies to be carried out prior to any marketing, as for new drugs, could arise. This is all the more true as the risks themselves have not yet been fully identified.
Towards a specific framework yet to be developed?
“While many risks are already well known and exist in conventionally produced foods, it may be necessary to focus on materials, inputs, ingredients (including potential allergens) and equipment specific to the production of cell-based foods,” note the WHO and the FAO in its first large-scale analysis of the issues related to cell-based products, published on 5 April. This analysis highlights specific risks to be taken into account that bring cell-based products closer to biotechnologies, cloned products or gene therapies in the field of human health. This is particularly the case for new toxins or allergens, used at the cell production stage, and for the structural or chemical stability of the genetic material used, a risk associated with all biotechnologies used in the food field.
“There is currently a limited amount of information and data on the food safety aspects of cell-based foods to help regulators make informed decisions,” say the FAO and WHO, whose analyses are limited to health issues, for which they call for more international cooperation and transparency. Moreover, these international agencies do not address the ethical, economic or commercial issues raised by these new products, such as the question of patenting life forms, which remains a particularly sensitive issue in the strategic field of food.
It is clear that all the risks linked to the health safety of the final products and the stability of the production processes themselves lead the scientists involved in the evaluation into unknown territory.
Before concluding on the need to accelerate the pace, as suggested in the draft report on the European protein strategy currently under discussion in the European Parliament, it would be better instead of taking the time to assess all the challenges raised by cellular agriculture, including the head-on collision with food systems based on natural cycles. An in-depth study of the impacts of scaling up, and all the industrial processes and consumption that this would entail, seems absolutely essential. Moreover, the FAO and the WHO are being particularly cautious. At the very least, an analysis, followed by an in-depth and transparent reflection on an ad hoc analysis framework should be envisaged by the European Commission before any approval process is launched.
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.
