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Sacar Newsletter - oCTOBER - November 2022


October and November are traditionally the busiest months in the EU policy agenda. We at SACAR are happy to finally meet our FRUCOM members, speakers and guests at our first in-person post Covid event. We are very enthusiastic about yet another addition to our portfolio: CEEREAL, the EU association representing breakfast cereals, has come on board in October. We are pleased to provide you with our take on the policy developments in the customs and trade fields important for SACAR members. Finally, in preparation for the festive season, please have a look at our new nutrition page, with plenty of information to guide you through the benefits of some of our exciting products!

The SACAR team


The first FRUCOM in-person event after Covid took place at Thon Hotel EU in Brussels on 13-14 October.

The Dried Fruit and Nuts working group focused on contaminants, official controls, trade, pesticides, additives and organics. Among the speakers were Alejandro Rodarte, FoodDrinkEurope, Frans Verstraete and Tim Gumbel, DG SANTE. The Nutrition and Communication Working Group’s central topic was the role of dried fruit and nuts in the product reformulation. Bo Dohmen, FoodDrinkEurope and Virginie Maenhout, EUFIC-EU Food Information Council, were among the speakers. The sustainability working group’s main topic was sustainability labelling and environmental footprint, with Mr. Rogge, DG SANTE and Ms. Veerle Poppe, Colruyt Group as speakers.

FRUCOM would like to thank all the participants for taking part!


SACAR is happy to announce a further addition to its portfolio. As of 17th October, we have started working for CEEREAL, the European association representing the breakfast cereal and oat milling industry towards the European Union and its institutions, industry and consumers associations as well as consumers. CEEREAL was established in 1992 by 8 breakfast cereal associations, and counts today 9 member associations in 8 European countries and 10 company members. SACAR team is supporting the association, with Anna Boulova is the new Executive Director and Martina Zurli and Katri Saari in charge of food safety.


The new FRUCOM page dedicated to nutrition is online. The new section of FRUCOM website will present all FRUCOM work around nutrition. The page will give the possibility to download public presentations of the past Nutrition and Communication Working Groups, replies to public consultation about nutrition, and visual content from FRUCOM LinkedIn page. It will also contain all FRUCOM articles related to nutrition and the main nutrition and health claims for FRUCOM products : Nutrition (frucom.eu)


During the FRUCOM Brussels Event on 14 October, FRUCOM members gathered in person to discuss the very topical subject of sustainability labelling for food.

Alexander Rogge who is overseeing the Sustainability labelling framework for food in DG SANTE, European Commission, and Veerle Poppe Sustainability Strategist in Belgian retailer Colruyt Group, presented the state of play, key developments, and existing challenges related to sustainability labelling for food in the EU’s policy framework, and also in the retail environment.

The exchange with FRUCOM members representing producers in the USA and Turkey, importers in the EU, as well as audience members from other agri-food sectors resulted in an energetic and passionate discussion about the impact of sustainability scoring of food on producers, consumers, and trade partners.


Customs is often perceived as somewhat of a tedious subject, but the European Commission’s Directorate General for Taxation and Customs (DG TAXUD) is doing everything in its power to bring this subject into the 21st century. This can’t come a moment too soon, as the Union Customs Code (UCC) is the bedrock of the Single Market, part of the machinery that enables the movement of goods to take place across the vast territory of the EU.

SACAR recently participated in DG TAXUD’s Trade Contact Group’s Plenary Group Meeting which took place online on 20 October 2022. This forum brings together industry representatives, DG TAXUD and other experts to discuss pressing issues concerning customs in the EU customs union, and in relation to trade with third countries.

We were impressed to witness DG TAXUD’s eagerness to present some exciting and forward thinking ideas to make customs work less burdensome for operators and customs authorities. What has also been insightful is the weight afforded to the responses from industry to the summer consultation on the future of the UCC – this was despite very vocal complaints from the group members that the holidays would have to be spent cajoling colleagues to fill in surveys or draft position papers.

Despite initial misgivings, the approach by DG TAXUD looks to have borne early fruit, allowing for the possibility to discuss the outcome of the consultation before the December scheduling of the proposal on the customs code reform – a very impressive timeline indeed!

ASSUC looks forward to seeing how DG TAXUD will be meeting the demands of operators for greater interoperability of Member States and EU customs digital infrastructure, and to ensure that the customs union functions as one system, with consistent interpretation and enforcement of the rules across all 27 Member States.


At a period where key UK official appears to be expressing buyer’s remorse over the trade agreement it signed with Australia, the progress of the EU – Australia trade negotiations has again come under the spotlight, with the European Commission keen to remind trade stakeholders and Australian partners that the EU is not the UK.

The 13th negotiation round of the EU – Australia FTA took place from 17-21 October 2022, following which a Civil Society Dialogue meeting was organised by the European Commission’s DG TRADE to brief stakeholders on the state of play and progress following the latest round of discussions.

Christophe Kiener, Chief Negotiator for the EU-Australia trade agreement in DG TRADE, took the helm in briefing participants, together with DG AGRI’s Raimondo Serra. Stakeholders were keen to understand how the FTA negotiations would affect sugar, animal welfare, geographic indicators, among various subjects.

Whilst the EU is keeping tight-lipped about the market access it intends to offer Australia for its sugar, one thing is clear – it will be neither duty free nor quota free.

Australia’s summary of the 13th round can be found here: https://www.dfat.gov.au/trade/agreements/negotiations/aeufta/aeufta-news/australia-eu-fta-report-negotiating-round-thirteen-17-21-october-2022

The EU’s report from the 13th round can be found here: https://policy.trade.ec.europa.eu/eu-trade-relationships-country-and-region/countries-and-regions/australia/eu-australia-agreement/documents_en



It was with impressive speed that the European Commission published its proposed Regulation on the banning of products using forced labour on 14 September, just a year after the State of the Union address where Commission President Ursula Von Der Leyen first touted her intention to present such a measure.

The proposed Regulation certainly empowers member state authorities to investigate, report, and ban products made using forced labour from being placed on the EU market. However, these powers are not without burden.

As Member States customs authorities will be in charge of enforcement at the EU borders, the question becomes – is there anything more governments could possibly add to the job of customs authorities? As it is, in addition to their job of ensuring the right taxes are imposed on imports, customs authorities are already expected to deal with a long list of other concerns, including monitoring goods and accompanying paperwork to make sure that imports enter the EU for the right purpose, that goods are not counterfeit, or that dangerous or prohibited goods do not enter the EU territory. Whether customs authorities across 27 Member States will have the capacity or wherewithal to enforce product bans related to forced labour is an issue one can only hope the Commission will do its utmost to address.

Many questions remain unanswered, for example, whether one finding of forced labour in a product by a Member State authority means that all other Member States authorities will have to issue recalls of the product concerned? Will there be a rapid alert system or a US style portals such as the “Better trade tool”? How will the Commission ensure that all Member States are interpreting the regulation in a consistent manner, to ensure certainty for traders and avoid undermining the single market? All of these are either outstanding issues or questions that will be addressed through as yet unpublished secondary legislation.

Operators will have to tread with care, given the reputational risk and costs should a finding be made that their product is made using forced labour. This is all the more so given the broad scope of the regulation, which will apply to “products for which forced labour has been used at any stage of their production, manufacture, harvest and extraction, including working or processing related to the products,” and “to all products, of any type, including their components, and should apply to products regardless of the sector, the origin”.

More information: https://ec.europa.eu/commission/presscorner/detail/en/qanda_22_5416


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