FEFAC response to European Commission Proposal on Green Claims Directive

FEFAC has taken note of the European Commission Proposal for a Directive on Green Claims, published on 22 March 2023, mainly addressing communication of green claims towards consumers. FEFAC members have succeeded in establishing a harmonized way of working on environmental footprint calculations through their involvement in the development of the FAO LEAP Guidelines on Animal Feed Supply Chains and the PEFCR Feed for Food-Producing Animals, which were published in 2015 and 2018 respectively. FEFAC is also a founding member of the GFLI (Global Feed LCA Institute), whose Database has become the leading global reference for public access datasets for all major feed ingredients used in compound feed production.

FEFAC members appreciate the European Commission’s objective to set up common criteria that underpin the substantiation of environmental claims using a reliable and credible methodology. FEFAC would however strongly recommend addressing B2B activities (pre-farm gate) and intermediate products, such as compound feed, which can be considered ’low-hanging fruits’ in terms of their proven capacity to make substantial contributions to reduce the environmental impact of livestock and aquaculture production with sustainable feed solutions substantiated by the PEFCR Feed for Food-Producing Animals.

In view of a forthcoming European Commission proposal on a legislative framework for a Union sustainable food system, FEFAC co-signed a letter to DG SANTE Director-General Sandra Gallina together with agri-food chain partners who developed a PEF Category Rules. The signatories recommend that when a PEFCR is available to a sector, legislators should mark these methodology rules as the ones that shall be followed. The organizations shared the concerns that allowing a variety of different methodologies to substantiate their environmental footprint claims, could strongly undermine the European Commission’s objective of halting confusing and misleading green claims in sectors which already have committed to developing a PEFCR. This could ultimately jeopardise the functioning of the Single Market which will adversely affect the overall Green Deal objective of a more sustainable food chain & circular economy.