KOM (2025) 0236 - svar på spm. 1 om non-papers eller positionspapirer

Udenrigsministeriet
Asiatisk Plads 2, 1448 København K Tlf.: +45 3392 0000 Fax: +45 32 54 05 33
E-mail: um@um.dk Web: UM.dk 1/1
Medlemmerne af Folketingets Europaudvalg Dato
18-06-2025
Bilag
3
Sag/ID Nr.
25/01477
Enhed
EUKOOR
SVAR PÅ UDVALGSSPØRGSMÅL
Til underretning for Folketingets Europaudvalg vedlægges Ministeriet for
Fødevarer, Landbrug og Fiskeris besvarelse af spørgsmål 1 ad KOM (2025) 0236 af
12. juni 2025 vedrørende non-papers.
Marie Bjerre
Offentligt
KOM (2025) 0236 - endeligt svar på spørgsmål 1
Europaudvalget 2025


Den 17. juni 2025
FVM 449
Hermed sendes besvarelse af spørgsmål nr. 1 (EUU forslagsdel), som Folketingets Europaudvalg har
stillet til ministeren for fødevarer, landbrug og fiskeri den 12. juni 2025.
KOM (2025) 0236
Forslag til ændring af forordninger inden for landbrugspolitikken (Forenklingspakken for den fælles
landbrugspolitik - Omnibus III)
Spørgsmål 1
”Vil ministeren oplyse, om regeringen er initiativtager til eller underskriver på nogle non-papers eller
positionspapirer, som vedrører elementer i EU-sagen, og vil ministeren oversende disse til udvalget, evt.
i fortrolig form?”
Svar:
Med henvisning til udenrigsministerens brev til Folketingets Europaudvalg af den 29. august 2024,
hvori der redegøres for regeringens praksis om at dele non-papirer og positionspapirer med
Europaudvalget på baggrund af en konkret vurdering, kan jeg oplyse, at der ikke vurderes at være
relevante non-papirer eller positionspapirer, der falder inden for forespørgslen.
Det skal dog bemærkes, at man fra dansk side ved rådsmøderne (landbrug og fiskeri) den 18. september
2023 og den 27. maj 2024 under eventuelt tog initiativ til drøftelser om behovet for generel forenkling
af blandt andet den fælles landbrugspolitik.
./. Noterne fra drøftelserne i Rådet er vedlagt til udvalgets orientering.
Jacob Jensen
/
Jesper Wulff Pedersen
Folketingets Europaudvalg
Christiansborg
1240 København K
Offentligt
KOM (2025) 0236 - endeligt svar på spørgsmål 1
Europaudvalget 2025


12926/23 dd 1
LIFE EN
Council of the
European Union
Brussels, 13 September 2023
(OR. en)
12926/23
AGRI 509
FOOD 66
PECHE 349
VETER 84
NOTE
From: General Secretariat of the Council
To: Delegations
Subject: Simplification and better regulation in EU Common Policies on food,
agriculture and fisheries
- Information from the Danish delegation, on behalf of the Bulgarian,
Czech, Danish, Estonian, Finnish, Hungarian, Latvian, Lithuanian,
Netherlands, Portuguese, Slovak and Swedish delegations
Delegations will find in the Annex a note from the Danish delegation, on behalf of the Bulgarian,
Czech, Danish, Estonian, Finnish, Hungarian, Latvian, Lithuanian, Netherlands, Portuguese, Slovak
and Swedish delegations, on the above mentioned subject to be dealt with under "Any other
business" at the Council meeting (Agriculture and Fisheries) on 18 September 2023.
Offentligt
KOM (2025) 0236 - endeligt svar på spørgsmål 1
Europaudvalget 2025
12926/23 dd 2
ANNEX LIFE EN
ANNEX
Simplification and Better Regulation in EU Common Policies on Food, Agriculture and
Fisheries
Information from the Danish delegation on behalf of Bulgaria, Czech Republic, Denmark, Estonia,
Finland, Hungary, Latvia, Lithuania, Netherlands, Portugal, Slovakia and Sweden
The common policies on food, agriculture and fisheries are some of the pillars of the European
Union. The sectors deliver a significant contribution to the European economy. While the policies
have undergone significant reforms in recent decades, more needs to be done to strike the right
balance between policy objectives and implementation and control rules, with more emphasis on
goal-oriented policies instead of directly prescribed measures. This is especially acute as Europe
faces major challenges related to climate change, environment, animal welfare, food availability
and affordability in the coming years. EU institutions, Member States, farmers, fishers, food
producers, the environment and consumers would all benefit from a rethink that puts simplification
at the heart of future legislative and policy reform proposals in line with the Better Regulation
Principles.
Better regulation in EU Common Policies on Food, Agriculture and Fisheries
Ensuring the internal coherence and compatibility between different policy areas, proposals and
existing EU legislation is important. Unintended overlaps and double regulation must be avoided.
Repeal of outdated legal acts and refit of existing legislation must be continued. All stakeholders –
from authorities and large food companies to family farmers and consumers – must be able to
understand what rules apply to them. It creates uncertainty when several initiatives cover the same
scope and seek to address the same substance matter in different ways.
12926/23 dd 3
ANNEX LIFE EN
As outlined in the Council (ECOFIN) on 16 June 2023, the systematic use of thorough impact
assessments is necessary, containing costs at Member State level for the entire scope of the
proposals. New proposals from the Commission must be accompanied by comprehensive impact
assessments that describe the positive and negative consequences of the proposal for society as a
whole, for the environment and for the stakeholders who are directly affected, e.g. food producers
and authorities. Impact assessments are crucial for the co-legislator to ensure that EU legislation has
the desired effect, without unnecessary burdens on Member States and businesses. In this context,
extensive public consultation is a powerful tool that needs to be fully utilized to collect the
necessary information on the impact of legislative action.
However, integrating simplification more firmly in the legislative process going forward will only
address future rule-making. A structured effort should also be made to simplify existing rules to
make them easier to understand and adhere to, as well as to encourage innovation and development.
The administrative and technical rules that stakeholders face most directly are often determined in
secondary legislation, through implementing and delegated acts. New legislative proposals should
clearly define the scope of implementing and delegated acts in order to avoid disproportional
burdens at a later stage.
Food safety and animal welfare
The Farm-to-Fork Strategy called for several new food labelling initiatives. Improved labelling may
contribute to healthier diets, increased sustainability and answer to consumer demands, but it also
represents an administrative burden to food producers and processors. New labelling requirements
should therefore be balanced and evidence-based so that they can help consumers make healthier
choices, contribute to animal welfare or sustainability, e.g. by reducing food waste, or be called for
by the consumers. Labelling needs to be easy to understand for consumers.
The European Commission is expected to present a proposal for a revision of EU animal welfare
legislation in the second half of 2023. Consumer expectations and scientific evidence call for
improvements in protection and enforcement. Consequently, it is all the more important that the
revision is carried out in a way that makes it straight forward for farmers to comply with the rules.
12926/23 dd 4
ANNEX LIFE EN
Agriculture
The reform of the Common Agricultural Policy 2023-27 aimed to introduce a simplification with
the development of CAP strategic plans. Going forward, further simplifications will be needed to
ensure that the Common Agricultural Policy will be sufficiently flexible to support inter alia the
green transition of the sector. In this respect, more possibilities to support green measures should be
considered. Furthermore, in order to fully achieve the simplification potential of the strategic plans,
the approval process needs to focus on objectives and identified needs and avoid focusing on
details.
As another important simplification, it could be considered to allow not only annual but also
plurennial financial management of financial allocations for climate, environment and animal
welfare across both pillars of the Common Agricultural Policy, as is already possible under the
financial management of pillar II. This would mirror year-on-year fluctuations in agriculture and
provide farmers and Member States with a much needed flexibility.
Moreover, further flexibility to allow amendments if necessary in the CAP strategic plan under
pillar I during the year would constitute another important simplification for farmers and paying
agencies. It is important that the acceptance process of Member States’ strategic plan amendments
is clear and fluent, and that the Commission respects the Member States’ national leeway.
Fisheries
The 2013 reform of the Common Fisheries Policy introduced the landing obligation. It was a major
step forward for sustainability, but implementation and enforcement have been challenging for
fishers and authorities. Electronic monitoring including cameras is included in the revision of the
EU’s fisheries control system. Fishers using electronic monitoring including cameras should be
given more flexibility, for example in the choice and development of gears that are fit for purpose
for the individual fisher whilst securing the objective of management measures. In that way,
innovative methods and simplification can go hand-in-hand.
12926/23 dd 5
ANNEX LIFE EN
One example of double regulation in the Common Fisheries Policy is fishing capacity ceilings. It
could be questioned if such ceilings are the most relevant tool in fish stocks management systems
where sustainable management of fish stocks is ensured by setting annual TACs and quotas. The
same applies in the case of small-scale coastal fisheries where passive fishing gear is used for
targeting local stocks, which are not managed at EU level and where national management
measures are in place. Furthermore, fishing capacity ceilings must not be a barrier to the green
transition on fishing vessels.
In recent years, consultations with third countries have become increasingly complicated. This has
major impacts on fishers’ planning. In the follow-up to the Commission’s Communication on the
Common Fisheries Policy today and tomorrow of 21 February 2023, it is important that emphasis is
put on ensuring smoother cooperation with third countries in the years ahead.


10218/24 VW/lg 1
LIFE.3 EN
Council of the
European Union
Brussels, 23 May 2024
(OR. en)
10218/24
AGRI 429
BIOTECH 1
NOTE
From: General Secretariat of the Council
To: Council
Subject: Simplification and Innovation-Friendly Regulation in the Agri-Food Sector
- Information from the Danish delegation, supported by the Czech,
Estonian, Finnish, Irish, Lithuanian, Portuguese and Spanish delegations
Delegations will find in annex an information note from the Danish delegation, supported by the
Czech, Estonian, Finnish, Irish, Lithuanian, Portuguese and Spanish delegations, on the above-
mentioned subject to be dealt with under “Any Other Business” at the session of the Council
(Agriculture and Fisheries) on 27 May 2024.
Offentligt
KOM (2025) 0236 - endeligt svar på spørgsmål 1
Europaudvalget 2025
10218/24 VW/lg 2
ANNEX LIFE.3 EN
ANNEX
Simplification and Innovation-Friendly Regulation in the Agri-Food Sector
Information from Denmark, supported by Czechia, Estonia, Finland, Ireland, Lithuania,
Portugal and Spain
Against the backdrop of the open strategic autonomy and the objective to move towards a more
resilient and competitive EU, it must be considered how the agri-food sector is best able to
contribute. The agri-food sector can play a significant role, if regulation of importance to the sector
promotes and supports efficiency and innovation. New solutions are needed to drive the green
transition and to solve the combination of challenges facing the sector; climate change, biodiversity
loss, and global competition. Furthermore, the land used for agricultural production in the EU has
decreased by around 10 percentage points since 1970. In the future, land use will be under
increasing pressure due to climate change, nature conservation, renewable energy projects and other
purposes. Consequently, there is a great need to increase efficiency in the European agri-food
sector.
At the Council (Agriculture and Fisheries) on 18 September 2023, Denmark raised the need for a
stronger focus on simplification and better regulation. From the discussion, it was evident that
Member States support the principles of better regulation and its application in EU policy making.
To make this happen, there is a need for EU-regulation that supports and enables the development
and deployment of innovations in the agri-food sector with the aim of producing more with less, by
means of optimizing input use. To this end, the Commission’s communication on boosting
biotechnology and biomanufacturing in the EU from 20 March 2024 is welcomed. The initiative is
an important first step in promoting biotech solutions in the EU.
10218/24 VW/lg 3
ANNEX LIFE.3 EN
Biotech solutions have great potential in reducing the climate and environmental impact of the agri-
food sector without limiting the productive capacity or reducing the competitiveness of European
farmers. However, to realize the benefits, there is a need for an EU regulatory framework that
reduces time-to-market constraints, and to enhance the attractiveness of the EU when it comes to
research and development, production, and post-production activities.
To this end, the Commission and the Council are called upon in the future to consider how to make
the existing regulatory regime within areas such as new genomic techniques, feed additives, and
biological plant protection products simpler and more innovation-friendly, without compromising
safety. The Commission’s anticipated study on how relevant EU-legislation can be further
streamlined (expected mid-2025) could constitute a starting point for a reform of the regulatory
framework. In addition, a cross-cutting administrative review should be carried out in order to
reduce administrative burdens for farmers and national authorities. The reform shall aim at
improving the competitiveness of the EU’s agri-food sector, address climate and environmental
challenges, and deliver benefits for farmers and consumers.