[EU] Evaluation of marketing standards [Regulation (EU) No 1308/2013]

Evaluation of EU marketing standards (contained in the Common Market Organisation (CMO) regulation, the “breakfast directives” and CMO secondary legislation)

17. Are you familiar with any EU marketing standards in any of the following product sectors? (CCC Responses are in Green)

×Olive oil and table olives×Poultry meat Coffee and chicory extracts
 Fruit and vegetables Spreadable fats Cocoa and chocolate products
 Processed fruit and vegetable products Hops Fruit jams, jellies and marmalades
 Bananas×Beef and veal Fruit juices
 Live plants Wine Honey
 Eggs Milk and milk products None of the above

18. In your opinion, to what extent have the EU marketing standards, in the product sectors you are familiar with, contributed to supplying the market with products of a standardised and satisfactory quality ?

 Very strong positive contribution Moderate negative contribution
 Strong positive contribution Strong negative contribution
 Moderate positive contribution Very strong negative contribution
×Had no effect No opinion

19. In your opinion, to what extent have the EU marketing standards, in the product sectors you are familiar with, contributed to improving the conditions for production and marketing and creating a level-playing field in these sectors ?

 Very strong positive contribution Moderate negative contribution
 Strong positive contribution Strong negative contribution
×Moderate positive contribution Very strong negative contribution
 Had no effect No opinion

20. In your opinion, to what extent have the EU marketing standards, in the product sectors you are familiar with, contributed to providing adequate and transparent information to consumers ?

 Very strong positive contribution Moderate negative contribution
 Strong positive contribution Strong negative contribution
 Moderate positive contribution Very strong negative contribution
×Had no effect No opinion

21. In your opinion, to what extent have the EU marketing standards, in the product sectors you are familiar with, contributed to providing the purchaser with value for money ?

 Very good value for money
 Good value for money
×Limited value for money
 No value for money
 No opinion

22. In your opinion, to what extent could efficiency be improved by harmonising the control and reporting requirements of the different marketing standards ?

 Very strong potential for improvement
 Strong potential for improvement
 Moderate potential for improvement
×No potential for improvement
 No opinion

23. In your opinion, what could be simplified, and how, in order to improve the management and implementation of the EU marketing standards ?

Authorities should gather specific data on consumer consultation of marketing information, in order to identify consumer priorities. It is not sensible to increase compliance costs (resulting in higher consumer prices) for information that consumers are not interested in to begin with. The CCC also believes that new technologies already offer non-regulatory information carriers (through mobile applications and barcodes) that need to be considered as a substitute mechanism.

24. In your opinion, to what extent are the EU marketing standards, in the product sectors you are familiar with, consistent to other EU policy interventions in these sectors?

 Very strongly consistentStrongly consistentModerately consistentNot consistentNo opinion
EU rules on food safety   X 
Food information to consumers   X 
Geographical indications X   
Organic products   X 

Please specify:

On organic products: EU organic product labelling does not address the potential health implications of pesticide use in organic farming.

25. In your opinion, to what extent are the EU marketing standards, in the product sectors you are familiar with, consistent with international marketing standards and with private marketing standards?

 Very strongly consistentStrongly consistentModerately consistentNot consistentNo opinion
International marketing standards – Codex Alimentarius (CODEX)    X
International marketing standards – United Nations Economic Commission for Europe (UNECE)    X
Private marketing standards    X

26. In your opinion, has the implementation of the EU marketing standards caused any unexpected or unintended effects in terms of food waste ?

 Yes
 No
×No opinion

27. In your opinion, has the implementation of the EU marketing standards caused any unexpected or unintended effects in terms of animal welfare ?

 Yes
 No
×No opinion

28. In your opinion, has the implementation of the EU marketing standards caused any potential of abuse by market actors ?

×Yes
 No
 No opinion

29. In your opinion, to what extent do the EU marketing standards, in the product sectors you are familiar with, fit with the needs of the supply chain in these sectors (i.e. producers, processors, traders, retailers) ?

 Fit very well
 Fit well
 Fit moderately well
 Did not fit
×No opinion

30. In your opinion, to what extent do the EU marketing standards, in the product sectors you are familiar with, fit with the needs of consumers ?

 Fit very well
 Fit well
 Fit moderately well
×Did not fit
 No opinion

31. In your opinion, to what extent do the EU marketing standards, in the product sectors you are familiar with, fit with the needs of Member States administrations ?

 Fit very well
 Fit well
 Fit moderately well
 Did not fit
×No opinion

32. In your opinion, what are the most essential benefits of the EU marketing standards that cannot be achieved by the Member States/sectors acting on their own ?

N/A

33. Do you have any suggestions on how EU marketing standards could further improve product quality and production/marketing conditions in these sectors ?

N/A

34. In your opinion, has the implementation of the EU marketing standards caused any unexpected or unintended effects in regard to the sustainability of the food chain ?

 Yes
 No
×No opinion

35. Please feel free to upload a concise document, such as a position paper. The maximum file size is 1MB.

Please note that the uploaded document will be published alongside your response to the questionnaire which is the essential input to this public consultation. The document is optional and serves as additional background reading to better understand your position. 

The Consumer Choice Center (CCC) is an advocacy group standing up for the rights of consumers who want to make their own choices on a free and fair market. While product information and oversight is key, regulators need not overburden the regulatory framework with too many well-intended rules. It so happens that compliance costs in the field of fast-moving consumer goods are paid by consumers, acting as a tax on the consumption of ordinary people. Therefore the Consumer Choice Center encourages opposes “better regulation” to “more regulation”, in a spirit of streamlining the process of compliance. While market access regulations should be harmonised and permissive, product information should be adapted to local needs. A product being “made in Italy” is not helpful for an Italian consumer seeking Southern Italian products – particularly since producer addresses do not necessarily reflect the lieu of production. In this example, Italy should have the possibility to establish more than just country of origin, but even region of origin. In a comparable application of the same principle, countries wishing to keep up with agro-tech innovations (that have been proven to be safe for consumption by national authorities), should never need to require labelling of products that do not need labelling for public health concerns, since it would needlessly stigmatise certain products and mislead consumers. The CCC therefore opposes strict horizontal regulation of marketing standards across all sectors, and draws attention to the fact that paragraph 70 – which stipulates that consumers being misled “as a result of their expectations and perceptions” – opens the door with arbitrary interpretations of what those expectations and perceptions are. Labelling requirements — as for instance suggested for harmonisation in paragraph 104 for wine — do not respect regional priorities on the matter, and should be left to national authorities.Furthermore, we also believe that Regulation (EU) No 1308/2013 creates market interventions that can lead to price distortions, for example through state aid on private storage (paragraphs 10, 17, 18, 21), quantitative limitations and price fixing (paragraphs 5, 11, 14), or purchase terms (in the case of sugar) (paragraph 118).The CCC supports the Commission’s effort to support educational facilities with fruits and vegetables, with the aim of diversifying diets and making them more healthy (paragraphs 24, 25, 26, 27). Adding to that, we would like to add that physical exercise programmes have proven to be more efficient than radical dietary changes, so efforts need to be coordinated with other educational programmes, in order to achieve the desired goalsThe Consumer Choice Center declares its interest as a stakeholder to take part in further consultations and is happy to contribute to studies undertaken. We agree to the publication of these statements.

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