The EU starch industry’s contribution to the Commission’s consultation on the Farm to Fork strategy

Starch Europe fully supports the EU ambition, as expressed in the EU Green Deal, to achieve climate neutrality by 2050. We also fully recognize the need for a holistic approach to sustainable EU food systems, the objective of the EU Farm to Fork Strategy.

1.     Current contribution

Starch Europe members have for decades been contributing to a more sustainable EU Food System, through inter alia:

A.    Economic pillar

• Processing and adding value to 24 million tonnes of EU agricultural raw materials, in 78 plants located in 19 EU Member States and producing 11 million tonnes of starches and starch derivatives and over 5 million tonnes of proteins and fibres as ingredients for food, feed and industrial customers
• Providing their customers with a broad portfolio of safe and high quality products (up to six hundred in some starch plants) ranging from native starches, modified starches, liquid and solid sweeteners to oils, proteins and fibres that are used as ingredients and functional supplements in a wide array of applications.
• Generating annual revenues of 7.4 billion Euros, re-investing 535 million Euros, of which 75 million in Research & Development

B.    Environmental pillar

• The EU agricultural raw materials sourced by the EU starch industry comply, as a minimum, with the EU Common Agricultural Policy’s cross-compliance and greening measures, amongst the most advanced in the world
• Starch plants, operating as efficient biorefineries, valorise the entire crop to create ingredients for food, feed and industrial customers. More than 99% of the EU agricultural raw materials processed by our industry find a use in food, feed or industrial applications
• Starch-based ingredients, produced using the highest industry safety standards, contribute to the safety of Europe’s food and feed products. Many starch-based ingredients also contribute to extending the shelf life of food and drink products and helping to prevent food waste
• The plant-based proteins produced by the EU starch industry act as an alternative to animal proteins in meat or dairy products, or are used as functional ingredients in food, and reduce the EU’s reliance on imported proteins in animal feed
• The 40% of starch-based ingredients used in industrial applications are often used as a renewable alternative to replace fossil-based ingredients
• By, for example, introducing combined heat and power and other new technologies (e.g. biomass, biogas, geothermal energy, spray-drying towers, high efficiency heat pumps and mechanical vapor recompression) in its plants, CO2 emissions per tonne of product are being reduced
• The sector was one of the first to produce sector-wide Life Cycle Assessment studies

C.    Social pillar

• The European starch industry creates 15,560 direct jobs and 100,000 indirect jobs on a full-time equivalent basis, mainly in rural areas, of which 60,000 are farmers
• The EU starch industry safety programme, launched in 2014, recognises best performers in health and safety
• The ingredients produced by the starch industry (carbohydrates, oils, proteins and fibres) are the building blocks of a balanced and varied diet.

2.     Comments on the objectives suggested by the EU roadmap consultation

A.    Ensure sustainable primary production

The EU starch industry sources more than 95% of the agricultural raw materials it processes from EU farmers. Paramount to the development of the EU starch sector is the reliable supply of safe, sustainable agricultural raw materials at affordable prices and in consistent quality. Recent reforms of the EU Common Agricultural Policy have had as their objective, to improve the sustainability of EU primary production. Under the proposed CAP for 2021-2027, these objectives will be further pursued, a development Starch Europe fully supports.

EU starch companies, both as agricultural co-operatives as well as privately owned, will continue to support the EU farmers who supply them raw materials in adopting more sustainable practises, both in the context of the national strategic plans on CAP implementation and the Farm to Fork Roadmap. It is essential that these initiatives are complementary and not contradictory, and should make use of already existing initiatives and tool boxes which have proven their positive impact.

The EU starch industry was one of the first agri-food sectors to adopt a sector-wide Life Cycle analysis report: the industry’s carbon footprint study was first published in 2001, then a full Life Cycle Assessment (LCA) study was released in 2012 and updated in 2015. A new sector sectorial LCA study is planned for 2021. These reports consistently confirm that the growing of raw materials is the major source of the environmental impact in the starch supply chain.

The roadmap suggests plant protection products and pesticide use are one source of concern. Starch Europe fully acknowledges this concern and members are already working with their farmers to reduce pesticide use. Pesticides are however used for a reason, and any restrictions in their use must be accompanied by measures to promote alternative means of disease limitation and must not lead to shortages or negatively impact farmers’ profitability.

In this respect the soon to be launched review of the EU approach to new breeding techniques will, Starch Europe hopes, provide clarity in terms of what alternative techniques will be available. Such techniques can not only significantly reduce the need for pesticide use but can also have other environmental (decrease of the water need for instance) and nutritional benefits.

B.    Stimulate sustainable food processing, retail, hospitality and food services’ practices

B.1 Improving energy efficiency

EU starch companies are important energy users and are covered by the carbon leakage list of the EU Emission Trading Scheme. For decades, EU starch plants have been seeking to improve their own energy efficiency through, inter alia, the introduction of combined heat and power (co-generation). No pan-EU figure yet exists on the impact of these measures but it will be one subject of the updated LCA study to be published next year.

Whilst significant efforts will continue to improve further the starch industry’s energy efficiency, the industry is likely to need to continue to purchase much of the energy it needs from the ‘Grid’. The industry’s ability to achieve carbon neutrality will therefore be heavily influenced by the extent to which energy from the ‘Grid’ improves its carbon footprint.

B.2. Bioeconomy

Starch biorefineries are core to the success of Europe’s bioeconomy. Starch Europe is therefore a strong supporter of the EU Bioeconomy strategy and its action plan on all four bioeconomy outlets (food, feed, industrial and fuel), as updated in 2018 (Starch Europe position here). The food and drink sector is our main outlet, through its broad and constantly evolving portfolio of food ingredients. 40% of starch-based ingredients are used for industrial applications, often as an alternative to fossil-based ingredients, and over 80% of the protein products produced are sold to the animal feed industry. It is precisely because the EU starch industry operates its production plants as efficient biorefineries that it can serve all the outlets of the bioeconomy and fully valorise 100% the agricultural raw materials it processes and be a zero waste industry.

As a founding member of the European Bioeconomy Alliance, Starch Europe welcomed the Council Conclusions of 29 November 2019 calling “upon Member States and the European Commission to implement the updated Bioeconomy Strategy without delay”. We would encourage the action plan to implement concrete actions, such as boosting investments and research and innovation funding across food, feed and industrial areas, introducing market-creation incentives for bioeconomy products in strategic sectors and promoting public-private partnerships such as Circular Bio-based Europe. Starch Europe strongly advocates for the full and urgent implementation of the 2018 action plan. The measures proposed in this action plan are entirely consistent with the objectives of the Farm to Fork strategy. Their urgent implementation can make a major contribution to the EU’s Green Deal targets.

C.    Promote sustainable food consumption, facilitating the shift towards healthy, sustainable diets

By providing essential building blocks of a healthy diet, including carbohydrates, fibres, oils and proteins, the EU starch industry has been constantly innovating to produce ingredients to make food and drink products taste better, and be more nutritious and healthy. The industry will continue its significant research and innovation investments and work with its customers to improve its contribution to healthy and sustainable food, notably in their reformulation initiatives.

C.1. Science-backed information and transparency

In order to help consumers opt for healthier and more sustainable diets, providing clear and science-backed information is critical. We call upon policy makers and all other stakeholders in the food value chain to adhere to these principles while supporting the development of the Farm to Fork strategy.

To support this goal, Starch Europe launched its consumer facing www.starchinfood.eu website in 2018 and its BeyondStarch campaign in 2019. These information efforts will continue in order to help consumers better understand the ingredients from the starch industry: where they come from, why they are added and what their nutritional value is.

The Roadmap specifically refers to Front-of-Pack nutrition labelling. Starch Europe does not produce products for the final consumer and, as such, will support the efforts and positions of its food and drink customers on this issue. Starch Europe would stress that any new food labelling initiative must be based on robust science, and not perception. ‘Clean label’ food and drink products are not by definition healthier and more sustainable. Innovation efforts by the food supply chain should be driven by real health and sustainability improvements, and not simply by the label.

In addition to supplying building blocks of nutritious and varied diets (carbohydrates, lipids, protein), the starch industry also markets fibre, which is an ingredient with proven health benefits and which many consumers do not consume enough of.

C.2. Plant-based protein products

Of particular interest today are also the plant-based protein products manufactured by the starch industry. Together with our customers, we strive to offer convenience & diversity in plant-based food and drink products.

In our Position paper, we detail the recommendations alongside three axes:

1. Production and processing in the EU plant protein supply chain

We welcome the release of the EU Plant Protein Plan. To date, most Member States’ plans focus on the growing of the protein crops themselves, and overlook the processing steps and circular economy principles of biorefineries.

We therefore call on the Commission to take a farm-to-fork approach and integrate the value of the first processing of cereals and protein crops into plant-based protein food and drink products.

2. Research and Innovation

The starch industry is investing in its protein potential to introduce new crops, valorise even more the protein fraction contained in the grains, the peas and the starch potatoes and to sell them to the food and feed markets.

We call on the Commission to support the development of a sustainable and competitive EU supply chain for all existing plant-based proteins and potential new protein sources for use in food and feed through research and innovation funding at each level of the plant-based value chain in e.g.:

• • improving seeds to achieve better and more stable yields and greater disease resistance in protein crops
    • optimising first transformation processes of agricultural raw materials to produce ingredients for food, feed and industrial applications
    • improving know-how on the functionality, quality, consistency and consumer acceptance of plant-based protein products in food applications
    • assessing the nutritional quality and impact of new protein sources alone or in combination with animal proteins.

3. Promotion and awareness-raising

Since the announcement of the EU Plant Protein Plan in 2018, EU policy for promoting plant-based protein products has proved more challenging than expected. The Commission must include CN codes 2106 10 and 21 06 90 (“Food preparations not elsewhere specified”) in Annex I of Regulation 1144/2014 thus covering plant-based food and drink products.

D.    Reduce food loss and food waste

The EU starch industry fully valorises all the components of the agricultural raw materials which it processes. Waste in EU starch plants is less than 1%.

By producing ingredients which extend the shelf-life, it also helps reduce food losses at consumer level. As the Roadmap consultation rightly suggests, reducing food waste must be a priority in the move towards a more sustainable EU food system and Starch Europe will continue to work with its customers in this area.

E.     The global dimension

EU starch producers have to compete in a global market. The major international competitors to the EU starch industry already benefit from either lower raw material costs, lower energy costs, more government support, lower regulatory constraints or greater economies of scale, or a combination of these.

If the EU’s Farm to Fork objectives are not matched by its international competitors, the EU’s competitive disadvantage may be further reinforced. In the absence of a global level playing field, suitable mechanisms will be needed to ensure that EU starch producers can compete. A significant threat to a sustainable EU food system is the outsourcing of any link in the supply chain to less sustainable international competition.

The EU starch industry fully supports the holistic approach of the proposed Farm to Fork strategy and stresses that a holistic approach means a thorough impact assessment of all the impacts on all three pillars of sustainability (economic, environmental and social) of each new policy initiative.

3.     Conclusions

Starch Europe welcomes the opportunity to input into this consultation. EU starch producers, and other primary food processors, will be key enablers in the move towards a more sustainable food system. EU policies need to reflect the sector’s potential and challenges. With that policy support, the EU starch sector can play a key role in increasing transparency, meeting changing consumer needs, developing a more efficient and sustainable food system, whilst also maintaining the need for food security and food safety. The sector is already an important contributor to an EU sustainable food system and looks forward to working with the European Commission and other stakeholders on detailed proposals to help improve that contribution further.