While some limited improvements have been maintained, the final outcome raises serious concerns and, in several respects, moves away from the stated objective of strengthening the position of producers in the agri-food supply chain.
Although the more restrictive definition of non-recognised producer organisations is welcome, allowing these entities to benefit from exemptions under competition law for a period of up to five years without any certainty of ultimately obtaining recognition risks weakening the incentives for formal recognition and undermining the integrity of recognised producer organisations, which remain at the core of the CMO.
In addition, the proposed wording of Article 153 risks circumventing the principle of single membership. The obligation to belong to a producer organisation (PO) for “any given product”, with products defined as “sufficiently distinct, in particular due to their characteristics or intended end uses”, lacks legal certainty and introduces excessive interpretative flexibility.
This ambiguity could facilitate multiple PO memberships for closely related products, including different varieties of the same product. Given the practical difficulties linked to the implementation of this provision, AREFLH urges the co-legislators to address this issue in the next revision of the CMO within the framework of the new CAP.
Concerns over contract rules for perishable products
AREFLH also regrets that the improvements proposed by Parliament to better reflect the contractual realities of perishable and seasonal products were not taken into account, as this could increase administrative burdens and further fragment the internal market.
Taken as a whole, these elements not only fail to strengthen the position of producers, but also risk weakening a framework that has supported the development and competitiveness of the fruit and vegetable sector for decades.
AREFLH therefore expresses its deep concern about the outcome of this reform and calls for renewed attention to the specific needs of the fruit and vegetable sector in the upcoming discussions on the Multiannual Financial Framework (MFF).
