CEJA Reaction to Commission Communication

CEJA Reaction to the European Commission Communication on the CAP2020

January 2011

General remarks

CEJA notes of the general guidelines provided by the Communication of the Commission on “The Common Agricultural Policy towards 2020: meeting the food, natural resources and territorial challenges of the future”. CEJA notes that at this stage of the consultations the Communication is a very general document, which calls for general comments.

CEJA supports the Commission’s orientation that the Common Agricultural Policy (CAP) should remain a strong European policy, based on a two pillar structure. Agriculture is a strategic sector for the European Union (EU) and should be recognised as such, through a strong CAP. CEJA also supports the three objectives put forward by the Commission, which are sustainable food production, sustainable management of natural resources and territorial balance.

Three policy options are indicated in the paper: an enhanced status quo, based on a more equitable distribution of direct payments, a more balanced and targeted support, based on an adjustment of direct payments, the abolition of all market and income support. CEJA believes that neither the first nor the third option are viable and is committed to provide constructive comments to decision-makers on how to best achieve the second option.

The proposed basic rate should not be described as a simple income support as its purpose is to meet the fundamental objectives of the CAP, together with all the other support measures.

Priority to young farmers

CEJA notes the two mentions of young farmers in the document. CEJA would like to reiterate that as key actors of tomorrow, the young farmers will play an important role in the future of agriculture. Consequently, the CAP should include provisions targeted at the new generation of farmers.

CEJA therefore urges the Commission to support a strong and ambitious CAP that targets young farmers and attracts a new generation into agriculture. CEJA also calls on the Commission to introduce a combination of policy tools supporting the renewal of generations under Pillar I and Pillar II (see CEJA document “Young Farmers’ Package” of November 2010). 

To seriously address the specific needs of young farmers, the new CAP should include mandatory support measures for YF as first priority under both Pillar I and Pillar II.

Direct payments

CEJA has expressed itself many times against the historical model of direct payments. CEJA therefore welcomes the Commission’s comment that aid should be better targeted at active farmers. A clear definition should be put forward.

For CEJA, active farmers are understood as:

-          Farmers taking the financial responsibility for managing the business and production and who sell products individually or through cooperatives and;

-          Farmers recognized as such by the public administration and;

-          Farmers delivering public goods from their agricultural activity.

CEJA also calls for the direct payment system to be transparent and fair for all farmers in each Member States, and therefore welcomes a system of entitlements linked to active farmers and linked to eligible agricultural land. Any new model has to recognize the high level and long term investment made by young farmers.

CEJA asks for clarification regarding the upper ceiling for direct payments received by large individual farms. The Commission should prevent more administrative burdens when making a distinction between small, medium and large farms. The Commission should provide clear guidance and criteria in the distinction between farms and how to reach the effect of fair distribution based on farm size.

CEJA notes the recognition by the Commission that the market fails to adequately remunerate farmers for the provision of public goods. CEJA calls for an open dialogue with the Commission on the precise definition of public goods and the method to calculate and remunerate them.

CEJA believes that the main public goods that farmers deliver to society are related to food production, food safety, healthy and quality food at remunerative prices for producers and reasonable prices for consumers, at enough quantity to meet the EU and worldwide demand. In addition, CEJA believes that agri-environmental services, such as preservation of natural resources, respecting and enhancing bio-diversity, soil protection, water resources management, landscape management, play an active role for mitigating and adapting to climate change, and should be remunerated.

Greener CAP

CEJA underlines the importance of direct support to meet the fundamental objectives of the CAP. In addition CEJA accepts the challenge of greening the first pillar, through a top-up to direct payments, recognizing the high standards of environmental protection.

Examples of greening the CAP in order to improve environmental protection could include crop rotation, higher animal and crop biodiversity, set-aside of agricultural land, pasture, and higher synergies from erosion-reducing crops amongst others. Programmes which reduce competitiveness like agri-environmental measures that lead to higher costs or lower yields of farming activities have to be rewarded within the second pillar.

CEJA reiterates the importance of additional measures within Pillar II to address specific environmental objectives of Member States. Farmers’ organisations should be consulted to define specific green elements. There should not be any administrative burden linked to the greener CAP element or high extra costs.

Competitiveness at global level

The Commission should negotiate at international level including at the Codex Alimentarius, stronger and stricter norms and standards, in order to achieve a level playing field in trade in agriculture commodities and products and competitiveness at global level.

Young farmers are open to implement a greener CAP, provided that there is a level playing field and that trading partners are bound to apply similar standards. Alternatively the EU should negotiate at WTO level that imports from third countries should meet similar standards as EU products.  Finally, the general public should be better informed about norms and standards which EU agriculture produces by. 

Market management tools

A safety net and market stabilising tools should remain in case of extreme market volatility crisis. A combination of public and private tools should be used in case of market failure to provide more predictability and stability. This could take the form of public intervention and both public and private storage.

CEJA welcomes the proposal to make available to Member States a ‘risk management toolkit’ that could be used to mitigate production and income risks. CEJA however calls for an EU method and criteria that would be triggered at EU level, in case of market crises, so as to avoid a re-nationalisation of the CAP or different interventions across the EU.

CEJA stresses the importance of better cohesion between market management tools and the proposals of G 20 on regulation of commodities.

Empowerment of farmers and transparency in the food chain

CEJA welcomes the orientation of the Commission which would support initiatives that assist farmers to be ‘price makers’ in the food chain, as opposed to ‘price takers’, including transparency measures.

To encourage transparency in the food chain, origin labeling is fundamental. Moreover, young farmers face difficulties due to the volatility of the food chain in which they represent the weakest part. For this reason, it is important to strengthen primary producers’ capacity and bargaining power vis-a-vis other economic operators in the food chain.

A certain importance should be recognised to the development of direct sale and local market managed by farmers.

On rural development, CEJA demands a stronger European-wide policy in favour of the renewal of generations.

CEJA regrets that funds and measures available for Young farmers under the current development programmes are not being implemented and/or used by many Member States. Therefore the ratio for co-financing such measures should be amended and 80% of the funds should come from EU level, the 20 remaining from national level.

CEJA also calls for mandatory implementation of Rural Development Programmes when it comes to Young Farmers measures. In addition, any new objectives put forward under Rural Development programmes shall not undermine financial resources that shall be available to young farmers.

The priority of Axis 1 (Competitiveness) within Pillar II must be increased from its current minimum of 10% of Pillar II funding to 20%. This will ensure that young farmers can be adequately supported.

Measures to help the young generation of farmers should be supported through rural development programmes such those encouraging adding value to products, fostering innovation, direct selling to local markets and providing public goods and services..