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Reading 1 - The EU Green Deal - How Will It Impact My Business
Reading 1 - The EU Green Deal - How Will It Impact My Business
Reading 1 - The EU Green Deal - How Will It Impact My Business
Last updated:
13 October 2021
In 2019, the European Commission launched the European Green Deal (EGD). The EGD is a
package of actions to reduce greenhouse gas emissions and to minimise the use of resources
while achieving economic growth. This means that products sold in the EU market will need
to meet higher sustainability standards. If you export to the EU, you want to know how the
EGD policies can impact your businesses and prepare yourself for those impacts.
The EGD policies will likely impact trade within and imports to the EU, and it is possible that environmental and
sustainability standards will become stricter at a later stage. This will mean more requirements for businesses
from developing countries that export to the EU. Many decisions will be taken in the coming 2 years, and these
decisions will determine the extent of the impact on business. In any case, it is important to be informed about
the targets and ambitions of the EGD in order to be prepared to comply with higher standards.
Ambitious goals
The EGD aims to preserve, maintain and improve the EU’s natural resources, land and ecosystems as well as to
protect the health and well-being of European citizens against environmental risks and the impacts of climate
change. To achieve the climate goals, up to 2% of Europe’s GDP will go into greening the economy, including
new infrastructure, public procurement, R&D and industrial reorganisation.
The EGD also seeks to lead the way in global action against climate change. But the EU cannot achieve its
climate goals alone, as it requires the participation of its allies and trade partners worldwide. The EU recognises
that there will be some regions, industries and workers that will find it more difficult to make this transition.
Therefore, the EGD will take a fair and inclusive approach to achieve a just transition.
F2F was launched on 20 May 2020 with the goal to reduce the EU food system’s environmental and climate
footprint, as well as to reverse biodiversity loss. In this context, F2F seeks to reduce food waste, to ensure that
there is a sufficient and affordable supply of foods for its citizens, while also guaranteeing that farmers receive a
fair price for their products and that the EU remains competitive on a global scale (Figure 1).
As part of the actions required to achieve these objectives, the EU is planning the revision of many existing
regulations for food and agriculture, as well as the creation of new rules and the improvement of coordination
tools within the EU (Table 1). Promotion programmes have also been proposed, establishing a sustainable food
labelling system (Table 2 and Table 3), including organic products in schools and public institutions and the
adoption of an Action Plan for Organic Agriculture 2020-2026.
Table 1: Sustainable food production actions to deliver the Farm to Fork Strategy
Table 2: Ethical food production actions to deliver the Farm to Fork Strategy
Table 3: Nutrient content, food safety and labelling actions to deliver the Farm to Fork Strategy
But the EU food system depends on global supply chains: from animal feed to spices and tropical fruits.
Therefore, to achieve the goals of F2F, EU trade policy will boost cooperation with countries outside the EU to
improve nutrition and to alleviate food insecurity by strengthening the resilience of food systems and reducing
food waste.
F2F is expected to create big changes in the way that food is produced, transported, distributed and
marketed. The most immediate impact of the F2F strategy on businesses that export to Europe will be
from the New Common Agricultural Policy, which will enter into force in Q1 2023. Businesses from non-EU
countries exporting to the EU will have to comply with stricter regulations regarding labelling and
information.
Figure 2: F2F will impact the way food sold on the EU market is produced, transported, distributed and packaged
Photo: CBI
There are also potentially impactful regulations entering into force in the long term (3 to 10 years). For example,
there is the Action plan for integrated nutrient management to reduce pollution from fertilisers, which will
include considerations of impacts of fertilisers not only on human health, but also on the environment. This will
likely result in more restrictions for the type and amounts of chemical fertilisers used in agriculture, with
consequences for the business model of enterprises under a conventional agriculture regime.
We still know very little about the requirements that new or revised regulations will entail. It is likely, however,
that these new rules will bring changes in:
The types of materials used to package raw materials and specially processed products;
The type and amount of pesticides allowed in agriculture;
The type of genetic technologies allowed in plant breeding and cultivation;
The type of information provided to consumers, including front-of-pack labelling and other marketing
standards.
Tips:
Read about informative sessions on Pesticides, New Genomic Techniques and Veterinary medicine
that have been held since 2020 for Embassies and Missions of non-EU countries as part of the F2F
strategy.
Check the European Commission’s F2F page regularly for upcoming informative events.
3. What is the Circular Economy Action Plan?
The EU’s Circular Economy Action Plan (CEAP) is a set of interrelated initiatives which aim to reduce pressure on
natural resources by transforming the design, production and consumption of products so that no waste is
produced. These initiatives target many different materials and commodities such as packaging, technology,
vehicles and textiles.
This is different to the current, linear economic model, where materials are used in products, consumed,
and thrown away.
The CEAP is sometimes referred to as the ‘new CEAP’ because it builds on the first CEAP adopted in 2015. It will
be more coherent and cover more products and materials than before.
Measures that will be introduced under the new CEAP aim to:
Of the actions that are relevant to SMEs from developing countries (Table 4), many have to do with reviewing
current laws, assessing the impact of transitioning to a circular economy and holding public consultations. The
Commission is also proposing 3 new laws in 2021 which will still need to be reviewed before becoming law. This
means that, if these proposals are reviewed and approved, they likely will not be implemented until 2023 or
later.
Table 4: Summary of relevant actions by the European Commission to implement the CEAP
Source: Profundo summary based on the European Commission’s reference on CEAP implementation and other
European Commission announcements. Note: “Relevant policies and legislation” means relevant to the CBI
sectors covered in this research and relevant to production/trade in non-EU countries
In the short term (1-2 years), there will be little difference in the way European companies import goods and
services because of the CEAP, since no laws will be implemented in this time.
There are, however, changes in the market from bigger players in affected sectors who are responding to
changing norms and practices. Already, there are signs that buyers want more recycled packaging, more
recycled textiles and generally more information from suppliers about sustainability aspects in the supply chain.
Figure 4: There are indications that EU buyers want more recycled textiles
Source: CBI
In the long term (3-10 years), laws and regulations may be put in place to determine how products are made,
packaged and reported on in the European market. The main things that SMEs exporting to Europe will likely
need to adapt to are:
Laws on creating sustainable products which minimise waste throughout the life cycle;
Laws limiting how much packaging and what type of packaging you can use for your products;
Demands for more information on processing and production practices so that buyers can make ‘green
claims’ and European consumers can be informed about their purchasing choices.
See the section below for more information on each potential law which may emerge from the CEAP and tips for
how to deal with it.
Tips:
Watch this introduction video to the Masterclass on the EGD.
Read the sections below for more information on each potential law which may emerge from the CEAP
and tips for how to deal with it.
The European Green Deal will change existing norms to make businesses and supply chains more sustainable.
This will impact imports to Europe in the following ways:
Higher standards for social and environmental sustainability in production and processing of goods and
services
Even if laws and regulations do not change, or do not come into practice for many years, the market is shifting
towards products that are proven to be made in a sustainable way that is respectful of human rights. In other
words, buyers, especially larger companies, are looking for goods that are produced, processed and packaged
using high standards for respecting human rights and the environment. Major global retailers have agreed on a
2-year pact with garment workers and factory owners in Bangladesh, extending a pre-existing agreement that
makes retailers liable to legal action unless their factories meet labour safety standards.
Basically, all large food and beverage brands have made commitments to sourcing agricultural products
responsibly, and fisheries sectors are also following suit. In the area of apparel and textiles, companies are also
communicating their intention to create a sector that respects human rights and sources sustainable materials.
For example, high street retailer Zara announced 2 years ago that it would only be using sustainable fabrics by
2025.
All of this means there is an increased demand for sustainably produced goods and services. The laws and
measures being proposed under the European Green Deal will only make this demand stronger. This presents a
huge opportunity for SMEs which are already producing food and textiles in conformance with high sustainability
standards, like organic.
In addition to this, voluntary sustainability initiatives from certification schemes and companies’ own initiatives
have also increased the availability of goods marketed as sustainable. Today, in some sectors, sustainable-
certified goods occupy a significant portion of the market (Figure 3). Coffee has been sustainable-certified the
longest, for over 30 years. Other certified commodities have seen their share in their markets grow in the last
10 years. In some cases, this growth started even earlier. Seafood production, from both wild catch and
aquaculture, is also increasingly expected to comply with basic sustainability standards.
Overall, this means that SMEs exporting to European buyers will certainly need to adjust to providing more and
more information about how goods are produced and will potentially be audited on this information. For SMEs,
this may mean putting in place systems for collecting information from your suppliers about production and
labour practices and justifying where your goods are coming from (also called traceability). It may also mean
becoming compliant with a voluntary sustainability standard, whether a certification scheme or a company’s
own initiative.
What is traceability?
Traceability is the ability to track down all processes involved in a product cycle: from procurement of raw
materials to production, consumption, and disposal. The purpose of traceability if to clarify where the
product was produced, in what time period, and by whom.
For animal products and by-products imported to the EU, there are already some traceability
requirements in place for food and safety reasons. More and more, traceability is required by buyers with
high social and environmental sustainability standards for all types of products, including agricultural
products, fisheries and raw materials for textiles.
In the short term, increased costs of transitioning to new models of sustainable production
There will certainly be costs associated with the transition to a more sustainable and circular economy. Some
examples of these costs are for recycled materials, adjusting production and processing to higher standards of
sustainability, determining traceability of products and ensuring adequate auditing of these processes. The
question of who will be responsible for these costs is still very much being debated.
Overall, it is too early to know how the Green Deal will be passed and implemented and what exactly this will
mean for the investment that producers exporting goods to the EU will be expected to make as well as the
impact on costs of goods. What is known is that the EU has promised a just transition, which means that it will
account for impacts on small businesses and the people they employ and that there will be time to adjust to the
costs of transitioning. This might also mean the EU will create support programmes through supply chains or in
bilateral/cooperative funding agreements with countries. Notably, in Africa, several green cooperation
programmes exist already.
In the long term, the EGD is preparing exporters of goods for a sustainable global market
Europe is not the only important market considering legal measures to increase sustainability of traded
products. The UK passed a Modern Slavery Act requiring companies to report on the risk of forced labour in
supply chains, and the US has a ban on imports of forced labour goods. International treaties on climate change
mean all nations have to draw up plans to achieve lower emissions in the next 30 years, which will impact
supply chains everywhere. In theory, in the long term, no market should be immune to demands for sustainable
production of materials, goods and services.
The European Commission recognises explicitly that it cannot achieve the aims of the EU Green Deal solely
within the EU’s boundaries. It has stated that “[…] circularity goals are unlikely to be met without ensuring that
suppliers in developing countries also adopt circular business practices.” Not only does the EU need and want
goods and services from outside its borders, it also knows that the impacts of climate change, inequality and
environmental degradation are global. Because of this, the EU has already made statements about ensuring a
just transition which positively impacts small businesses and production of sustainable goods outside of Europe.
This means that it will need to support this transition in 1 form or another.
Tips:
Get to know the main sustainability certification schemes and standards relevant to your sector. The
State of Sustainability Initiatives has good summaries for many products, including bananas, coffee,
cocoa, cotton, palm oil, soybean, sugar, tea, timber, wild catch and aquaculture.
Refer to this briefing from Proforest for more information on how to obtain traceability in your supply
base and what types of information your buyers are looking for.
A proposal for a regulation on substantiating green claims was planned to be adopted by the Commission in Q2
2021 but has not yet been released. There will be a public feedback process on the proposal, after which it will
need to be reviewed and approved by Parliament and Council to become a law.
The EU believes that the further development of common and global standards for circular goods is necessary,
whether this is through a regulated certification scheme or voluntary ‘soft standards’. It is not yet clear if and
when this legislative proposal will proceed, but the 2 key options it is considering to change the status quo are:
A voluntary system where companies choose to make standardised green claims alongside existing methods
(e.g., sustainable certification schemes); or
A mandatory EU-wide legal framework requiring companies making ‘green’ claims to do so in a standardised
and verified way.
The Commission claims that any proposed regulation will consider world trade rules on fair competition. This
means that, for example, any labelling/information tool should result in no less favourable treatment of
imported products compared with goods produced in the EU.
Tip:
Read the Hungarian Consumer Authority’s rules of thumb for making green claims.
While no other details have been published about this regulation yet, its adoption is planned for Q2 2021. It may
lead to far-reaching legal reforms for all companies in the EU, as well as their suppliers in non-EU countries.
Specifically, it could be that the European Commission will introduce a duty of care that will require businesses
to consider the environmental, human rights and social impacts of their activities and to integrate these in the
company’s strategy and decision-making.
Moreover, it could be that identifying, preventing and mitigating negative impacts and ensuring stakeholder risk
through adequate procedures and measurable targets will become mandatory. This could mean that companies
may be required to actively trace the conditions under which production processes further up the supply chain
take place. For SMEs exporting to the EU, this might mean more rigorous traceability mechanisms.
The Code includes a set of 7 aspirational objectives, each with specific targets and actions which make healthy
and sustainable food choices easier for European consumers. Commitments may take the form of a declaration
of engagement and actions in major areas, together with an agreement to move towards higher levels of
ambition within a defined timeframe. For the more advanced companies that wish to make greater
commitments, the Code also includes a framework for more ambitious, measurable actions.
For you as an exporter to Europe, this might mean more strenuous traceability requirements, as well as
corporate social responsibility (CSR) policies.
Tips:
Read CBI’s market information on requirements for food exports to the EU, including code of conduct
and CSR policies.
Find more information published by CBI on trends and opportunities for healthy and sustainable food
choices for EU consumers.
For now, it is not clear which aspects of this strategy, if any, will become law. However, some implications of a
circular textiles economy for SMEs outside Europe include:
Demand for recycled content in textiles (in the short term, likely to be mostly recycled polyester, as this is
the most available), including designing less complex material combinations to make textiles more
recyclable;
A trend of reshoring formerly outsourced supply chains. This means that EU retailers will want to cut down
supply chain costs that are determined by proximity between R&D, product development and
manufacturing, time to market and increased wages in offshoring destinations (such as China, the
Philippines and India);
A growing secondary material market in Europe that is focused on reuse, repair and return. In theory, this
means there will be greater availability of quality second-hand textiles products and materials and less
consumption of new products, which may translate to decreasing demand for newly produced textiles from
outside of Europe; and
Implementation of extended producer responsibility in promoting sustainable textiles and in the treatment of
textile waste.
Tip:
Read the CBI study on sustainable transition in apparel and home textiles for more information.
A proposal for a directive on creating sustainable products is planned to be adopted by the Commission in Q4
2021. There will be a public feedback process on the proposal, after which it will need to be reviewed and
approved by Parliament and Council to become a law.
Because of the precedence of the EcoDesign Directive, aspects of the proposal will likely be approved into law,
alongside other rules of relevance to SMEs in exporting countries, such as:
Making producers responsible for providing more circular products and intervening before products can
become waste (see green box);
Mandatory sustainability labelling and/or disclosure of information to buyers;
Preventing unsustainable production processes, including use of harmful chemicals in production processes;
and
Banning the destruction of unsold durable goods.
This approach is already being applied in specific contexts and sectors. For example, in the EU, producers
of certain products like batteries and vehicles are responsible for the financing of collection, recycling and
end-of-life disposal.
Tip:
Watch this webinar on the Sustainable Product Policy. It discusses concrete ways to make products in
the EU more sustainable and resource efficient.
If the goods you export require a lot of packaging, or a special type of packaging, these rules will apply to you
and to your buyers in Europe. You may need to find ways to reduce the amount of packaging and/or use
different materials that are, for example, lighter, have more recycled content, have no plastic content or can be
reused.
A proposal for a directive on reducing packaging and packaging is planned to be adopted by the Commission in
Q4 2021. There will be a public feedback process on the draft, after which it will need to be reviewed and
approved by Parliament and Council to become a law.
Tip:
Visit Glopack’s page for links for ongoing EU projects developing innovative packaging solutions, or
join its stakeholder’s platform to connect with innovators developing sustainable packaging.
This initiative will specify approval criteria for microbial active substances in Annex II to Regulation (EC) No
1107/2009. The aim is to reflect the particularities of these substances, which are different from chemical
substances. While no other details have yet been published about this regulation, its adoption is planned for Q4
2021.
For SMEs that are primary producers exporting to Europe, this might mean that they will have to adopt other
agricultural practices or apply different products (thus, new investments and to involve technical experts as well
as some degree of experimentation). For processers of agricultural products, this might mean closer
involvement with their suppliers to assist them in adopting different agricultural practices that comply with the
biopesticide initiative.
Tips:
Tradin Organic offers technical support globally to farmers who would like to switch from conventional
to organic agriculture.
Check out the website of the Integrated Pest Management (IPM) Coalition, which provides several
resources aimed at helping farmers worldwide reduce their use of hazardous pesticides. These
resources include a pesticides database and the ’Pesticides & Alternatives’ app, a free telephone
application to learn about the toxicity levels of over 700 pesticides as well as measures to prevent and
control almost 3,000 agricultural pests without the use of chemicals. The app can be downloaded from
GooglePlay or the iTunes app Store and is available in English, Portuguese or Spanish. Once you have
downloaded it, you will be able to use it offline.
Regulations planned for Q1 2022
New organics legislation
On 1 January 2022, the new Regulation on Organic Production and Labelling of Organic Products (also called the
new organics legislation) will enter into force. Apart from the general labelling requirements that exist for all
food products, additional rules will apply to labelling of organic products and raw materials.
The aim of the new organics legislation is to strengthen the control system, helping to further build consumer
confidence in the EU organics system. It is supported by the action plan for organic production in the EU, which
was launched by the European Commission in March 2021.
The EU regulations on organic farming are designed to provide a clear structure for the production of organic
goods across the whole of the EU. This is to satisfy consumer demand for trustworthy organic products while
providing a fair marketplace for producers, distributors and marketers.
Imported organic food is also subject to control procedures to guarantee that it has been produced and shipped
in accordance with organic principles.
In this context, changes that will be made under the new organics legislation include:
The rules on ‘Labelling’ in the new organics regulation will not only cover the label on the product, but apply
to all statements, indications, trademarks, trade names, pictures or signs concerning a product on
packaging, documents, signs, labels, rings or bands accompanying or referring to that product.
Using terms such as organic and ecological (or shorter terms like ’bio’ and ’eco’), will only be permitted if the
product is certified organic. Likewise, producers must observe that product packaging design is not too
similar to the colours (green and white) and shapes (leaf) of the EU Bio logo, as this could mislead
consumers into believing a product is organic.
Labels for organic products entering the EU market must include the code number of the control body to
which the producer is subject and the place where the agricultural raw materials of which the product is
composed were grown (e.g., EU/non-EU agriculture and whether the product and its raw materials were
partially or entirely produced in third countries).
Tip:
Read CBI’s article on the implications of the EU Organic Regulation for exporters of grains, pulses and
oilseeds.
Figure 7: The new organics legislation will require that products marketed as ‘organic’ or ’ecological’ be certified
organic
Source: CBI
Tip:
Read the section on the Farm to Fork Strategy, its likely impacts and different tips to anticipate these
impacts.
In the long term, better tools will help SMEs improve their businesses
The EU and your own national governments may be setting up support programmes, especially directed at
SMEs, to transition to compliance with new EU Green Deal regulations.
There will be better tools and mechanisms to provide information on your product and improve your
processing/production practices in a harmonised way, such as a digital product passport. This means you will
no longer need to comply with a multitude of information requests from your different buyers.
Many of the policies and legislative measures of the EGD build on existing regulations that you likely already
comply with if you currently export to Europe (or that you will have to comply with if you aspire to export to
Europe). Mainstreaming sustainability in your industrial processes will not only give you the opportunity to
conduct business with Europe but could also give your business a competitive advantage in other
international markets.
The Biodiversity strategy for 2030 and the legal framework to halt and
reverse EU-driven deforestation
Closely linked to the development of a sustainable and fair food system is the preservation and defence of
biodiversity and ecosystems. This is why the European Commission has also published the Biodiversity
strategy for 2030. Like F2F, the Biodiversity strategy seeks to build society’s resilience to future threats such
as food insecurity, outbreaks of diseases that spread between animals and people (also known as zoonotic
diseases), the impacts of climate change and forest fires. The Biodiversity strategy will establish protected
areas for at least 30% of land and 30% of sea in Europe. Moreover, it will restore degraded land and sea
ecosystems by increasing organic farming and biodiversity-rich landscape features on agricultural land,
halting and reversing the decline of pollinators and reducing the use and risk of pesticides by 50% by 2030.
In a resolution published on 9 June 2021 on the EU Biodiversity Strategy for 2030, the Parliament asked the
Commission to urgently present a proposal for an EU legal framework based on mandatory due diligence
that ensures that value chains are sustainable and that products or commodities placed on the EU market do
not result in or derive from deforestation, forest degradation, ecosystem conversion or degradation or
human rights violations.
Although nothing has yet been communicated publicly, possible instruments in the proposal may include
mandatory labelling, voluntary commitments and labelling, due diligence and verification schemes. It is not
yet clear how ‘deforestation-risk’ products will be defined, but the initial impact assessment mentions the
palm, soy, beef and timber sectors. It may be that forest-risk crops such as cocoa, coffee and rubber will also
come under the proposal.