15 December 2020
Primary Food Processors (PFP) expressed serious concerns regarding the European Commission’s first draft delegated act supplementing Regulation 2020/852 on sustainable finance and climate related objectives. According to the organisation, several provisions within the proposal risk undermining the competitiveness of Europe’s primary food processing industries and limiting their contribution to climate change mitigation and adaptation.
PFP specifically objected to provisions restricting the use of agricultural raw materials as feedstocks for industrial and energy applications, including plastics, biofuels, biowaste processing and organic chemicals. The organisation argued that these activities represent an essential component of Europe’s bioeconomy and contribute directly to decarbonisation objectives.
PFP represents industries processing sugar, starch, wheat flour, vegetable proteins, cocoa, vegetable oils and protein meals. Together, these sectors process approximately 220 million tonnes of agricultural raw materials annually, employ more than 120,000 people across the European Union and support around one million indirect jobs throughout associated value chains.
The organisation highlighted the role of primary food processors in replacing fossil based carbon with renewable plant based alternatives. Through resource efficient production systems, the sector transforms agricultural raw materials into food ingredients, animal feed, detergents, cosmetics, bioplastics, fuels, paper products, paints, pharmaceuticals and other bio based materials while generating almost no food waste.
PFP argued that the draft delegated act creates inconsistencies with several existing European Union policies. According to the organisation, the proposed criteria do not align with broader objectives established under the European Green Deal, the Circular Economy Action Plan, the Farm to Fork Strategy, the Common Agricultural Policy and the Renewable Energy Directive.
The association also raised concerns regarding regulatory governance and representation. It argued that the Technical Expert Group responsible for developing recommendations lacked sufficient expertise from the primary food processing sector and noted that PFP industries were not represented within the EU Platform on Sustainable Finance.
According to PFP, delegated acts should not effectively redefine which economic activities qualify as sustainable. The organisation warned that sustainable finance rules have significant implications for investment decisions, access to capital and the future development of bioeconomy value chains.
The organisation also expressed concern that taxonomy classifications increasingly influence both regulatory and voluntary investment frameworks. Restrictive criteria could therefore discourage future investment in renewable materials, biorefineries and climate friendly industrial technologies.
PFP called for the removal of provisions affecting the manufacture of organic base chemicals, plastics in primary form, transport biofuels and anaerobic digestion of biowaste. According to the association, these provisions unnecessarily restrict the use of renewable agricultural raw materials and risk weakening Europe’s bioeconomy.
PFP concluded that primary food processors should be fully recognised as contributors to climate neutrality, sustainable industrial development and the transition towards a circular and bio based European economy.
PFP members process approximately 220 million tonnes of agricultural raw materials annually, employ more than 120,000 people across the European Union and support around one million indirect jobs throughout associated value chains.
