Freshfel Europe Warns the European Commission on Far-Reaching Implications of Proposed Marketing Standards for the Pre-Cut Fruit and Vegetables Industry

Freshfel Europe warned the European Commission this week on the far-reaching implications of its draft
proposal on marketing standards if rules on mandatory country-specific origin labelling are maintained for
pre-cut fruit and vegetables. The draft is currently in public stakeholder consultation. The sector urges the
European Commission to withdraw or amend specific parts of its draft proposal that will impact
competitiveness, raise prices and impact consumption of convenience fresh produce.

The draft Regulation on marketing standards is meant to align with the objectives of the Farm to Fork Strategy,
namely the provisions relating to increased information for consumers and reduction of food waste. While the
European Commission’s intentions correspond to the objectives of the Farm to Fork Strategy, the proposed
draft text is expected to lead to a significant price increase of pre-cut fruit and vegetables marketed as IV
gamma products. Freshfel Europe believes that the new rules will reduce fresh produce’s attractiveness to
consumers, breaching the ambition of the Farm to Fork Strategy to move to a more plant-based diet. Freshfel
Europe is also conclusive that the Commission’s proposal will increase plastic packaging waste and generate
more food waste. Eglė Baecke, the Director of Food Quality & Security stated: “The proposal of the Commission
will not allow the IV gamma industry to process ‘ugly’ fruit and vegetables or oversized products. While the
Commission intends to reduce food waste by allowing ‘ugly’ fruit and vegetables to be sold locally and directly by
producers to consumers, the share of these fruit and vegetables is negligible compared to the volumes used by
the IV gamma industry and sold as kitchen-ready or ready-to-eat to consumers. If adopted, the rules will unfairly
discriminate operators involved in the preparation of IV gamma products against the manufacturers of frozen or
canned fruit and vegetables. Manufacturers of processed foods will still be allowed to source ‘ugly’ fruit and
vegetables. As such, the IV gamma industry will no longer be able to contribute to reduce food waste. Moreover,
there are products, such as lettuce, that cannot be processed other than by cutting and will therefore be

For sourcing raw materials, diversification is not straightforward and is usually a long process. The draft proposal
suggests a mandatory origin labelling for all IV gamma products. This will be significantly challenging for current
supply patterns and business practices while impacting food security and diversification of sourcing of raw
materials. Philippe Binard, the General Delegate of Freshfel Europe underlined: “We noticed huge
inconsistencies in the text with regard to origin labelling of IV gamma products. The same rules on origin
labelling do not apply to all food categories. Different labelling rules are proposed for products presented in
mixes or as single ingredient. Moreover, rules will differ for products composed of raw materials that fall under
specific or general marketing standards. This will heavily restrict the daily operations of business operators
involved in the production of IV gamma products. It will impose barriers to sourcing raw materials because
packaging materials that include origin indications must be pre-printed in advance. This will be reflected in the
final price for the European consumer putting further pressure on consumption of fresh fruit and vegetables.
Consumption today is already below the recommended norm of 400 g/day. The new rules will impact the already
low consumption. Consumers choose IV gamma products because of their convenience in combination with

Currently, the labelling of IV gamma products is covered by the Regulation on Food Information to Consumers.
The industry insists this to be continued. Alternatively, the industry urges the European Commission to amend
its proposal and compromise for the benefit of consumers’ health across the EU, reduction of food waste and
protection of the environment. This can be achieved by providing a legal framework which would allow the
industry to use ‘ugly’ fruit and vegetables and oversized products as ingredients of IV gamma products. In
addition, the compromise has to include the legal framework that would allow the origin indication as ‘EU, ‘nonEU’, ‘EU & non-EU’ for all products in all compositions falling under the definition IV gamma products.

Eglė Baecke added: “The sector urges the Commission services to propose policy initiatives which are justified
and meet the objectives of the Farm-to-Fork Strategy based on factual evidence of whether these policy
initiatives will not result in devastating consequences in other areas proposed under the same strategy. A
Commission-wide governance is needed to address the objectives set under the Farm to Fork Strategy”.