EUROPEAN COMMISSION
Brussels, 13.12.2019
COM(2019) 625 final
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL
on the implementation and impact of voluntary labelling provisions under Regulation (EC) No 1760/2000 as amended by Regulation (EU) No 653/2014
1.Introduction
Pursuant to Article 23a of Regulation (EC) 1760/2000 1 , the Commission shall submit to the European Parliament and the Council a report dealing with the implementation and impact of the provisions on voluntary beef labelling, including the possibility of their review.
Regulation (EC) No 1760/2000 was adopted in the aftermath of the Bovine Spongiform Encephalitis (BSE) crisis, in order to improve transparency and strengthen the confidence of consumers in beef.
The Regulation provided for strict rules concerning the approval and use of voluntary information, justified by a serious loss of consumers’ confidence and subsequent serious market disturbances.
Regulation (EU) 653/2014 2 amended Regulation (EC) No 1760/2000 and significantly simplified the provisions on voluntary beef labelling, with the main aim of reducing the administrative burden for operators and competent authorities, as well as to reduce costs borne by operators to provide such voluntary information.
The amended rules do not foresee the requirement for authorisation of voluntary beef labelling any more. Such voluntary information must comply with the horizontal legislation on labelling and in particular Regulation (EU) No 1169/2011 3 on food information to consumers.
The objectives of this report are, pursuant to Article 23a of Regulation (EC) No 1760/2000:
-to assess the implementation and impact of the current EU legislation on voluntary beef labelling along the supply chain, in particular taking into account the views expressed by competent authorities, producers, processors and consumers;
-to explore the possibility of reviewing provisions on voluntary beef labelling.
2.BACKGROUND AND LEGAL FRAMEWORK
Council Regulation (EC) No 1760/2000 was adopted in the context of a loss of consumer confidence after the BSE; it repealed and replaced Council Regulation (EC) No 820/97 4 , adopted in response to serious market disturbances caused by the BSE crisis. Regulation (EC) No 820/97 introduced the principle of individual traceability of animals and origin labelling of beef.
Regulation (EC) No 1760/2000 established the following elements:
1.it reinforced the identification and registration system for bovine animals, Articles 1 to 10;
2.it introduced a compulsory beef labelling system under which operators marketing beef have to indicate on the label information concerning origin, in particular where the animals from which the beef was derived were born, fattened and slaughtered, Articles 11 to 15;
3.it introduced a voluntary labelling system to allow operators to provide additional information to consumers, Articles 16 to 18.
The provisions referred to in the third point (voluntary labelling system) were amended in 2014 by Regulation (EU) No 653/2014, essentially removing the requirement for authorisations, by competent authorities, of voluntary labelling information and the obligation of controls on operators carried out by an independent body recognised by the competent authority.
Voluntary beef labelling typically covers breed and category of animals, region of production, feeding and production systems.
Regulation (EU) No 653/2014 amended Regulation (EC) No 1760/2000 as follows:
·a newly introduced Article 15a in particular requires information to be objective, verifiable by the competent authorities and comprehensible for consumers;
·Article 15a moreover empowers the Commission to adopt delegated acts concerning definitions and requirements applicable to terms and categories that may be put on the labels of pre-packed fresh and frozen beef and veal.
·Article 22, as amended, provides among other things that, if an operator or organisation has labelled beef without complying with the obligations laid down for compulsory or voluntary labelling, Member States shall, as appropriate, and in accordance with the principle of proportionality, require the removal of the beef from the market. Member States may authorise that such beef be placed on the market after properly being labelled in accordance with Union requirements, provided that the meat conforms to the relevant veterinary and hygiene rules.
2.1voluntary labelling system before entry into force of regulation (eu) no 653/2014
Before the entry into force of Regulation (EU) No 653/2014, the general rules for the authorisation and control of voluntary information on beef, were provided in Articles 16 and 17 (now repealed) of Regulation (EC) No 1760/2000.
Briefly:
·the operator was required to send the specification for approval to the competent authority of the Member State in which beef production or sale took place;
·the specification had to describe the information to be included on the label;
·the operator had to set up a specific control system to be applied at all stages of production, including controls carried out by an independent body recognised by the competent authority and designated by the operator; these independent bodies had to comply with the criteria set out in European standard EN/45100;
·operators using the labelling system had to bear the cost of controls by an independent body;
·the competent authority had to examine the specifications and the measures taken to ensure the accuracy of the information provided on the label;
·if the production and/or sale of beef took place in two or more Member States, the competent authorities of the Member States concerned had to examine and approve the specifications related to operations within their respective territories;
·any specification approved by a Member State had to be communicated to the other Member States through the Committee for the Common Organisation of the Agricultural Markets;
·in case the production of beef took place in a third country, operators were allowed to provide voluntary information on beef labelling according to Regulation (EC) No 1760/2000 upon prior notification to the Commission from the third country concerned containing the following elements:
§the competent authority designated to grant the approval;
§the procedures and criteria that the competent authority followed when examining the specification;
§the list of operators and organisations allowed to use the specifications approved.
·the Commission had to examine the notifications received from third countries in order to evaluate the equivalence of the procedures and criteria applied from the third country to the standards set out in Regulation (EC) No 1760/2000;
·the notifications received by third countries had to be transmitted to the Member States.
2.2Voluntary labelling after entry into force of regulation (eu) No 653/2014
Article 15a of Regulation (EU) No 653/2014 provides:
“Food information other than that specified in Articles 13, 14 and 15 which is added to labels voluntarily by operators or organisations marketing beef shall be objective, verifiable by the competent authorities and comprehensible for consumers.
That information shall comply with the horizontal legislation on labelling and in particular Regulation (EU) No 1169/2011 of the European Parliament and of the Council…”.
With this provision, rules on voluntary beef labelling have been harmonised with other meat types and foodstuffs in general under the horizontal food information to consumers’ Regulation3; operators can now provide voluntary information on labels under their own responsibility, without the need for a prior approval by competent authorities and without third-party controls.
Chapter V of Regulation (EU) No 1169/2011 provides general rules on voluntary food information. In particular, Article 36(2) of the Regulation lays down that information provided on a voluntary basis shall meet the following requirements:
(a) it shall not mislead consumer as referred to in Article 7 of the Regulation (‘fair information practices’), particularly:
oas to the characteristics of the food and, in particular, as to its nature, identity, properties, composition, quantity, durability, country of origin or place of provenance, method of manufacture or production;
oby attributing to the food effects or properties which it does not possess;
oby suggesting that the food possesses special characteristics when in fact all similar foods possess such characteristics, in particular by specifically emphasising the presence or absence of certain ingredients and/or nutrients;
oby suggesting, by means of the appearance, the description or pictorial representation, the presence of a particular food or ingredient while in reality a component naturally present has been substituted with a different component.
(b) it shall not be ambiguous or confusing for the consumer; and
(c) it shall, where appropriate, be based on relevant scientific data.
The reference to Article 7 of the Regulation (EU) No 1169/2011 is particularly important. Since it states that the information provided shall not be misleading in relation, among others, to the characteristics of food, to the place of provenance and to the method of manufacture and production, it is de facto covering all the information previously provided as voluntary labelling under Regulation (EC) No 1760/2000. In this sense, fair information practices are guaranteed by reference to Article 7.
3.METHODOLOGY
The present report is based on the following information:
-analysis of previous reports and evaluations carried out on voluntary beef labelling;
-consultation of Member States through a specific questionnaire and bilateral contacts;
-consultation of stakeholders through a specific questionnaire and bilateral contacts.
3.1Previous reports and evaluations
The results of the following studies and reports were used to evaluate the implementation of the voluntary beef labelling system:
a)Report from the Commission to the Council and European Parliament on the implementation of Title II of Regulation (EC) No 1760/2000 5 .
b)Opinion on agriculture of The High Level Group of Independent Stakeholders on Administrative Burdens 6 .
c)Evaluation study for the Commission “Evaluation of EU beef labelling rules” 7
3.2Consultation with Member States
In order to integrate, update and complement the analysis carried out within the framework of previous evaluations, information was collected through specific questionnaires addressed to the competent authorities of all 28 Member States.
The questionnaire was presented at the meeting of the Committee for the Common Organisation of Agricultural Markets on 19 July 2018 and distributed to Member States.
The aim of the questionnaire was to collect information, opinions and assessments from the competent authorities in charge of implementing the system.
Member States were asked in particular:
-whether they kept a national system of notifications and control on voluntary beef labelling after the entry into force of Regulation (EU) No 653/2014;
-to provide an estimate of the market share of bovine meat voluntarily labelled before and after the entry into force of Regulation (EU) No 653/2014;
-which were the main information elements provided under the voluntary labelling system;
-the number of controls carried out and non-conformity rates before (2013-2014) and after (from 2015 onwards) the entry into force of Regulation (EU) No 653/2014;
-the types of non-conformities detected in relation to voluntary beef labelling;
-the difficulties encountered in implementing voluntary beef labelling after the entry into force of Regulation (EU) No 653/2014;
-to assess the main effects (positive or negative) of the simplification introduced by Regulation (EU) No 653/2014;
-to assess (on a scale of 1 to 5) the system of voluntary beef labelling before and after the entry into force of Regulation (EU) No 653/2014 in relation to the following aspects: effectiveness of the system, reliability of the system, complexity for competent authorities, complexity for producers, administrative burden for competent authorities to implement and run the system, administrative costs for producers, capacity to correctly inform consumers.
Out of 28 Member States, 12 responded in detail to the questionnaire (BE-DK-DE-ES-FR-IT-AT-PT-SI-FI-SE-UK). 5 Member States replied that they were not applying voluntary beef labelling before 2014 (BG-HR-LV-LT-PL).
11 Member States did not reply or sent a partly completed questionnaire (CZ-EE-IE-EL-CY-LU-HU-MT-NL-RO-SK).
A discussion with Member States on the main outcomes of the questionnaire took place at the meeting of the Committee for the Common Organisation of Agricultural Markets on 8 November 2018.
3.3Consultation with stakeholders
Similar to the consultation of Member States, the questionnaire addressed to stakeholders aimed to collect information, opinions and assessments in relation to the following aspects:
-whether previous rules on beef voluntary labelling (i.e. approval from MS, third-party controls, notifications etc.) were considered useful in the past to sustain the market after the BSE crisis and to correctly inform consumers;
-whether there would be valuable reasons to differentiate beef from other types of meat and food in relation to voluntary information to consumers;
-how previous rules on voluntary beef labelling were perceived and the main effects (positive or negative) of the new rules introduced by Regulation (EU) No 653/2014;
-whether consumers were aware of the different rules applied to voluntary beef labelling before Regulation (EU) No 653/2014 compared to other food;
-any difficulties encountered by stakeholders (at the relevant market stage) to adapt to the new rules introduced by Regulation (EU) No 653/2014 and whether the new rules on voluntary beef labelling had an impact (positive or negative) on stakeholder's marketing strategies;
-to assess (on a scale of 1 to 5) the system of voluntary beef labelling before and after the entry into force of Regulation (EU) No 653/2014 in relation to the following aspects: effectiveness of the system, reliability of the system, complexity for competent authorities, complexity for producers, administrative burden for competent authorities to implement and run the system, administrative costs for producers, capacity to correctly inform consumers.
By the end of November 2018, seven replies had been received from the following associations: European Livestock and meat trade unions (UECBV), Federación Empresarial de Carnes e Industrias Cárnicas (FECIC), British Meat Processor Association (BMPA), CULTURE VIANDE, EUROCOMMERCE (3 replies sent from different associated organisations).
4.ANALYSIS AND CONSULTATION RESULTS
4.1Analysis of the previous reports and evaluations
A first assessment of the rules on voluntary beef labelling was carried out in 2004 by the European Commission in its “Report on the implementation of Title II of Regulation (EC) No 1760/2000”.
In this report, the Commission noted that:
·the voluntary labelling system was mainly used by operators in business to business relations;
·contractual agreements between commercial partners were in place to ensure the transmission of product specific information;
·the role of voluntary labelling schemes was perceived by competent authorities in a different way, leading to different criteria to authorise the specifications;
·these different approaches led to the fact that cases of mutual recognition of approved specifications were rare which risked disturbing intra-EU trade as well as distorting competition between operators who were not subject to the same restrictions in obtaining approval of their specifications.
A second assessment was carried out by The High Level Group of Independent Stakeholders on Administrative Burdens ('HLG'), set up in 2007 to advise the Commission on the implementation of the Action Programme for Reducing Administrative Burdens in the European Union.
In its opinion on Agriculture/Agricultural subsidies of 5 March 2009, the HLG identified the procedure for approval of voluntary beef labelling specifications and the control system laid down in Regulation (EC) No 1760/2000 as a source of administrative burden for both operators and administrations.
Therefore, the HLG advised the Commission to eliminate the notification requirements with regard to the use of additional labelling indications other than those compulsory for beef.
According to the HLG report, this would allow a 15% reduction in administrative burden (EUR 21 million, out of a total of EUR 139 million for beef labelling) with respect to the identification of bovine animals, without compromising the traceability guaranteed by the compulsory labelling elements.
A third detailed evaluation “Evaluation of EU beef labelling rules” was carried out for the Commission in 2014, a few months after the adoption of Regulation (EU) No 653/2014.
In relation to the voluntary labelling system, the main outcomes were:
-the volume of beef subject to voluntary schemes represented an average of 23% of all beef sold in the national markets of the six case study Member States (DE, FR, IT, ES, UK, IE).
-stakeholders had diverging views on the consequences of the implementation of Regulation (EU) No 653/2014 simplifying voluntary labelling rules: some appreciated the simplified procedure; others saw the risk of deteriorating the whole system and loss of consumer confidence.
-consumers were generally able to understand indications provided in accordance with voluntary rules. However, some consumers interviewed complained that labels provided in accordance with the voluntary rules often resulted in crowded labels. This led to the paradox whereby labels on beef simultaneously provide too much information without sufficient explanation, rendering them difficult to understand.
-in general, voluntary indications did not feature as factors that have a major influence on consumers’ self-described purchasing behaviour. 8
-most stakeholders highlighted that Regulation (EU) No 653/2014 brought voluntary labelling rules for beef in line with general food labelling rules.
-in some cases, voluntary labels were used only in business to business sales.
-some retailers feared that the 2014 simplification of voluntary labelling would lead to a proliferation of labels with low levels of guarantee that the information provided on the voluntary label is objective, verifiable and comprehensive for consumers, which could damage the image of the sector. Others considered it a positive development: the simplification of procedures allows for economic operators to develop new voluntary claims, responding to consumers’ demand.
4.2Outcome of Consultation with Member States
In the 2018 consultation, the 12 Member States that replied completely to the questionnaire represented more than 72% of EU bovine meat production. The results can thus be considered as significant and representative of the EU situation.
Two Member States (PT and SI) maintained their national system of approval by the competent authority and third-party control for voluntary beef labelling after the entry into force of Regulation (EU) No 653/2014.
One Member State (IT) simplified the system: information that can be retrieved from an official register and documents can be put directly on the label by operators, while the use of further information has to be communicated to the competent authority but without requiring a formal approval.
One Member State (FR) reported that, despite simplification, many operators continued to use the specifications approved before 2014 with controls from an independent body. Other operators switched to other national or European labelling and quality schemes or they implemented private certification schemes to label their products. New specifications are no longer checked and approved a priori.
In all other Member States that replied to the questionnaire, the system of notifications was completely repealed, as provided under the new provisions on voluntary beef labelling.
Very few Member States 9 were able to provide information on the market share of bovine meat labelled with voluntary information before and after the entry into force of Regulation (EU) No 653/2014.
According to the evaluation study, the weighted average of the beef sold in accordance with voluntary labelling schemes for the six studied Member States (DE, FR, IT, ES, UK, IE) from 2014 amounted to 23% of the total beef meat marketed.
Interestingly, Member States with a high share of meat marketed under voluntary labelling schemes did not report significant changes in the questionnaire. Austria estimates a 5% decrease in the use of voluntary information (from 80-90% to 75-85 % of the meat marketed before and after 2014, respectively). In Sweden, this share increased from 90 to 95%, while Denmark reported no significant change.
The main information provided under the voluntary labelling system were the breed and category of animals, together with the region of production and the feeding and production systems.
No Member State reported difficulty in the transition from previous rules on voluntary beef labelling to the new simplified rules.
Simplification was considered the main positive effect by Member States who replied to the questionnaire, with 10 Member States out of 12 recognising that the new system streamlined the rules by avoiding all the administrative steps needed under the previous rules before getting the approval of the specification. This caused an appreciable reduction of the administrative burden for the competent authorities.
The harmonisation with other types of meat (pig, poultry, sheep and goat meat) was also recognised as a positive effect because the reasons for stricter rules on beef labelling (BSE crisis) are no longer relevant.
Finally, Member States highlighted that simplified rules allow operators to react quickly to market demands if new information on labels becomes necessary.
As possible negative consequence of the new system, an increased risk of non-compliances, due to the abolition of controls from an independent body, was identified by three Member States (ES, AT, UK).
This is, however, not confirmed by data provided on controls and non-conformity rates found on voluntary beef labelling before and after the entry into force of Regulation (EU) No 653/2014. Many Member States were not able to provide specific data on controls on voluntary labelling, since data are collected in an aggregated way together with those on compulsory labelling. Four Member States (FR-IT-AT-PL) were able to provide detailed disaggregated data.
In the first three years of application of the new rules (2015-2017) the average percentage of non-compliances reported by these four Member States indicated that the non-conformity rate did not vary significantly and that the new simplified system is not more risky than the previous one.
The analysis of the assessment submitted by Member States on the previous and new rules of voluntary beef labelling - using a point system ranging from 1 (lowest value) to 5 (highest value) - showed that overall Member States considered positively the simplification introduced in 2014.
In particular, Member States were asked to provide an assessment on the following aspects:
-effectiveness of the system - average points scored: 3.7 before 2014 and 3.5 after 2014; Member States perceived no substantial differences in effectiveness of the system; the new rules are still effective in ensuring a clear information on labelling to consumers.
-reliability of the system - average points scored: 4.0 before 2014 and 3.5 after 2014; despite a small decrease in the average points scored, the results from Member States indicate that the new system is almost as reliable as the previous one. The controls carried out by the competent authorities ensure and guarantee a good level of trustworthiness in the system.
-complexity for competent authorities - average points scored: 4.2 before 2014 (complex and burdensome) and 2.3 after 2014; in this case the difference in the assessment before and after the introduction of the new rules was important. Member States believed that the previous system was quite complex to manage from the administrations side while the new rules reduced the complexity of the system.
-complexity for producers - average points scored: 4.3 before 2014 (time-consuming and burdensome) and 2.1 after 2014 (less complex and burdensome); also in this case there was an appreciable reduction in the points scored. The new system is perceived as much less complex. The process of specification approval and the management of the whole system were time-consuming and burdensome for operators.
-administrative burden for competent authorities - average points scored: 4.1 before 2014 and 2.2 after 2014; the previous system was considered burdensome; the new system allowed a sensible burden reduction for competent authorities.
-administrative costs for producers: - average points scored: 4.0 before 2014 and 1.9 after 2014; the reduction in costs for producers after the simplification was perceived as very significant. This is related to the abolition of controls.
-capacity to correctly inform consumers - average points scored: 4.4 before 2014 and 3.7 after 2014; while both the previous and the new system scored high value on this aspect, the previous system was considered as slightly more informative to consumers. Avoiding complex authorisation procedures, operators can communicate more effectively on information considered as important for consumers.
From Member States’ consultation, it can be concluded that they considered satisfactory the implementation of the new system at administrative level.
4.3Outcome of consultation with stakeholders
In the 2014 evaluation7 on EU beef labelling rules, neither compulsory nor voluntary beef labelling seemed to play a decisive role in accompanying the beef market recovery after the BSE crisis, although both contributed to strengthening consumers’ confidence in beef.
Stakeholders’ opinions diverge on the usefulness of the previous voluntary beef labelling system to sustain the market after the BSE crisis.
While the industry considered the system to play some role in tackling consumers’ loss of confidence following the BSE crisis, retailers thought differently.
Stakeholders’ opinions converged on one point: there are no more valid reasons to differentiate beef from other types of meat and food in relation to voluntary information to be given to consumers.
Stakeholders described the previous rules on voluntary beef labelling as burdensome, costly and disproportionate, notably because of the long and complex process of preparation, approval and control of the relevant specification.
In stakeholders’ views, consumers were not aware that different rules were applicable to beef compared to other food in relation to voluntary labelling and therefore voluntary labelling was not a main discriminant in consumers’ purchasing behaviour.
With regard to possible difficulties encountered by operators to adapt to the 2014 rules, stakeholders did not report any difficulty. Rather the contrary: four stakeholders replied that they had not to adapt their marketing strategies and three that they had positive impacts on their business strategies.
In particular, stakeholders that reported a positive impact considered that the new rules allowed more flexibility in the production chain to react quickly to market opportunities and demands.
The analysis of the assessment submitted by stakeholders clearly showed that the new system, being equally reliable as the previous one (average points scored on this aspect: 4.1 before 2014 and 4.0 after 2014), allowed to achieve important results in terms of:
-effectiveness of the system - average points scored: 2.8 before 2014 and 4.5 after 2014: the system is now perceived as more effective.
-complexity and administrative burden for competent authorities and producers - average points scored: 4.4 before 2014 and 2.4 after 2014 in relation to complexity for competent authorities and 4.3 before 2014 and 2.3 after 2014 in relation to complexity for producers. In stakeholders opinion an appreciable reduction in complexity was registered for competent authorities and producers.
-administrative burden for competent authorities - average points scored: 4.4 before 2014 and 2.4 after 2014. Stakeholders considered the administrative burden for the competent authorities as high under the previous rules, and medium with the new system, related mainly to controls.
-administrative costs for producers - average points scored: 4.1 before 2014 and 2.5 after 2014. The new system allowed for a cost reduction for producers. It is worth noting that the extent of this reduction was judged more important by competent authorities than stakeholders.
-capacity to correctly inform consumers - average points scored: 3.1 before 2014 and 4.1 after 2014. In stakeholders’ opinion, the new system was considered more suitable to provide correct information to consumers.
The analysis of the replies provided to the questionnaire by stakeholders showed clearly that the simplification introduced in 2014 had positive effects on the sector.
5.CONCLUSIONS
The simplification introduced by Regulation (EU) No 653/2014 provides for an alignment with horizontal rules laid down in Regulation (EU) No 1169/2011 on food information to consumers.
In addition to voluntary beef labelling now following horizontal rules in all Member States, some national specifics were maintained in four Member States. Portugal and Slovenia kept a full national system of notification and control, Italy simplified the national system and, in France, many operators continued using the specifications approved before 2014 with controls from an independent body.
Overall, the effects of simplification were evaluated positively by Member States and stakeholders. Competent authorities and operators did not find difficulties to introduce the new rules at administrative and operational levels.
The new rules were considered positively by most respondents, allowing to achieve simplification, harmonization with other sectors, reduction of the administrative burden and improved capacity of operators to respond to consumers’ demand, without causing problems at intra-EU trade level or undermining the effectiveness and reliability of the system.
A risk of more frequent non-conformities was mentioned by some respondents but without supporting evidence confirming it. The analysis of available data on non-conformity rates before and after the introduction of the new rules showed comparable levels of non-conformity.
On the basis of the analysis carried out during previous evaluations and of replies to the questionnaires received from Member States and stakeholders, the Commission considers that the simplification of voluntary beef labelling under Regulation (EU) No 653/2014 is functioning satisfactorily and there is no need to review current provisions on voluntary beef labelling.
Regulation (EC) No 1760/2000 of the European Parliament and of the Council of 17 July 2000 establishing a system for the identification and registration of bovine animals and regarding the labelling of beef and beef products and repealing Council Regulation (EC) No 820/97, OJ L 204, 11.8.2000 p. 1.
Regulation(EU) No 653/2014 of the European Parliament and of the Council of 15 May 2014 amending Regulation (EC) No 1760/2000 as regards electronic identification of bovine animals and labelling of beef, OJ L 189, 27.6.2014, p. 33.
Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers, amending Regulations (EC) No 1924/2006 and (EC) No 1925/2006 of the European Parliament and of the Council, and repealing Commission Directive 87/250/EEC, Council Directive 90/496/EEC, Commission Directive 1999/10/EC, Directive 2000/13/EC of the European Parliament and of the Council, Commission Directives 2002/67/EC and 2008/5/EC and Commission Regulation (EC) No 608/2004, OJ L 304, 22.11.2011 p.18.
Council Regulation (EC) No 820/97 of 21 April 1997 establishing a system for the identification and registration of bovine animals and regarding the labelling of beef and beef products. OJ L 117, 7.5.1997, p. 1.
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HLG Opinion on the priority area of Agriculture / Agricultural subsidies of 5 March 2009, https://ec.europa.eu/info/sites/info/files/action-programme-for-reducing-administrative-burdens-in-the-eu-final-report_dec2012_en.pdf .
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