2021 CALL FOR PROPOSALS

SIMPLE PROGRAMMES

Grants to information provision and promotion measures concerning agricultural products implemented in the internal market and in third countries in accordance with Regulation (EU) No 1144/2014 of the European Parliament and of the Council

(2021/C 31/06)

Table of contents

0.

Introduction

8

1.

Background

9

2.

Objectives — Themes and priorities — Activities that can be funded — Expected impact

9

AGRIP-SIMPLE-2021-IM-EU QS

9

Objectives

9

AGRIP-SIMPLE-2021-IM-ORGANIC

10

Objectives

10

AGRIP-SIMPLE-2021-IM-SUSTAINABLE

10

Objectives

10

AGRIP-SIMPLE-2021-IM-PROPER-DIET

10

Objectives

10

AGRIP-SIMPLE-2021-IM-CHARACTERISTICS

11

Objectives

11

AGRIP-SIMPLE-2021-TC-ASIA / AMERICA and OTHERS

11

Objectives

11

AGRIP-SIMPLE-2021-TC-ORGANIC

11

Objectives

11

Activities that can be funded

11

Expected impact

11

3.

Available budget

12

4.

Timetable and deadlines

13

5.

Admissibility

13

6.

Eligibility

14

Eligible participants

14

Consortium composition

16

Eligible activities

16

Geographic location (target countries)

18

Duration

18

7.

Financial and operational capacity and exclusion

18

Financial capacity

18

Operational capacity

19

Exclusion

19

8.

Evaluation and award procedure

20

9.

Award criteria

21

10.

Legal and financial set-up of the Grant Agreements

21

Starting date and project duration

22

Deliverables

22

Form of grant, funding rate and maximum grant amount

22

Budget categories and cost eligibility rules

22

Reporting and payment arrangements

23

Certificates

23

Liability regime for recoveries

24

Provisions concerning the project implementation

24

Non-compliance and breach of contract

24

11.

Help

24

12.

Important

25

0.   Introduction

This is a call for EU action grants in the field of Information provision and promotion measures concerning European agricultural products (AGRIP Programme) implemented in the internal market and in third countries through simple programmes.

The regulatory framework for this EU Funding Programme is set out in:

—	Regulation (EU, Euratom) 2018/1046 of the European Parliament and of the Council (1) (EU Financial Regulation),

—	the basic act (Regulation (EU) No 1144/2014 of the European Parliament and of the Council (2)),

—	Commission Delegated Regulation (EU) 2015/1829 (3) and

—	Commission Implementing Regulation (EU) 2015/1831 (4)

The call is launched in accordance with the 2021 Work Programme (5) and will be managed by the Consumers, Health, Agriculture and Food Executive Agency (CHAFEA) entrusted by the European Commission with the management of the promotion policy.

The call covers the following five topics in internal market:

—	AGRIP-SIMPLE-2021-IM-EU QS (Topic 1) — Internal Market

—	AGRIP-SIMPLE-2021-IM-ORGANIC (Topic 2) — Internal Market

—	AGRIP-SIMPLE-2021-IM-SUSTAINABLE (Topic 3) — Internal Market

—	AGRIP-SIMPLE-2021-IM-PROPER-DIET (Topic 4) — Internal Market

—	AGRIP-SIMPLE-2021-IM-CHARACTERISTICS (Topic 5) — Internal Market

In addition, it concerns the following four topics in third countries:

—	AGRIP-SIMPLE-2021-TC-ASIA (Topic 6) — Third Countries

—	AGRIP-SIMPLE-2021-TC-AMERICAS (Topic 7) — Third Countries

—	AGRIP-SIMPLE-2021-TC-OTHERS (Topic 8) — Third Countries

—	AGRIP-SIMPLE-2021-TC-ORGANIC (Topic 9) — Third Countries

We invite you to read the call documentation on the Funding & Tenders Portal Topic page carefully, and in particular this Call Document, the Model Grant Agreement, the EU Funding & Tenders Portal Online Manual, the AGRIP Programme Guide and the EU Grants AGA — Annotated Grant Agreement.

These documents provide clarifications and answers to questions you may have when preparing your application:

—

the Call Document outlines the: — background, objectives, scope, activities that can be funded and the expected results (sections 1 and 2) — timetable and available budget (sections 3 and 4) — admissibility and eligibility conditions, criteria for financial and operational capacity and exclusion (sections 5, 6 and 7) — evaluation and award procedure (section 8) — award criteria (section 9) — legal and financial set-up of the Grant Agreements (section 10)

—	the Online Manual and the AGRIP Programme Guide outlines the: — procedures to register and submit proposals online via the EU Funding & Tenders Portal (‘Portal’) — recommendations for the preparation of the application

—	the AGA — Annotated Grant Agreement contains: — detailed annotations on all the provisions in the Grant Agreement you will have to sign in order to obtain the grant (including cost eligibility, payment schedule, accessory obligations, etc.).

You are also encouraged to visit the Promotion of Agricultural Products Portal to consult the list of projects funded previously.

1.   Background

The general objective of the AGRIP Programme is to enhance the competitiveness of the EU agricultural sector.

The specific objectives of this Programme are to:

(a)	increase awareness of the merits of EU agricultural products and of the high standards applicable to the production methods in the Union

(b)	increase the competitiveness and consumption of EU agricultural products and certain food products and to raise their profile both inside and outside the EU

(c)	increase the awareness and recognition of EU quality schemes

(d)	increase the market share of EU agricultural products and certain food products, specifically focusing on those markets in third countries that have the highest growth potential

(e)	restore normal market conditions in the event of serious market disturbance, loss of consumer confidence or other specific problems.

2.   Objectives — Themes and priorities — Activities that can be funded — Expected impact

AGRIP-SIMPLE-2021-IM-EU QS

Objectives

The objective is to increase the awareness and recognition of the Union quality schemes, namely:

(a)	quality schemes: protected designation of origin (PDO), protected geographical indication (PGI), traditional specialty guaranteed (TSG) and optional quality terms;

(b)	the logo for quality agricultural products specific to the outermost regions of the Union.

Information and promotion programmes on Union quality schemes should be a key priority in the internal market since such schemes provide consumers with assurances on the quality and characteristics of the product or the production process used, achieve added value for the products concerned and enhance their market opportunities.

One of the expected results is to increase the levels of recognition of the logo associated with the Union quality schemes by the European consumers. According to special Eurobarometer (No 504), only 14 % of European consumers recognise the logos of products that benefit from a protected designation of origin (PDO), 20 % recognise a protected geographical indication (PGI), and 14 % recognise a traditional specialty guaranteed, these being the main Union quality schemes.

The expected ultimate impact is to increase awareness of the Union quality scheme and to enhance the competitiveness and consumption of products registered under a Union quality scheme, raise their profile and increase their market share.

AGRIP-SIMPLE-2021-IM-ORGANIC

Objectives

The objective is to increase the awareness and recognition of the Union quality scheme on organic production.

Information and promotion programmes on the Union quality scheme on organic production method should be a key priority in the internal market since this scheme provides consumers with assurances on the sustainability, quality and characteristics of the product and the production process used and the environmental benefits they generate, achieve added value for the products concerned and enhance their market opportunities.

One of the expected results is to further increase the levels of recognition of the EU organic logo by the European consumers. According to special Eurobarometer (No 504), the awareness of the organic farming logo has increased by 29 percentage points since 2017 with 56 % of European consumers who recognise the EU logo of organic farming.

The expected ultimate impact is to increase awareness of the Union quality scheme on organic production and to enhance the competitiveness and consumption of organic products, raise their profile and increase their market share.

AGRIP-SIMPLE-2021-IM-SUSTAINABLE

Objectives

Actions should highlight the sustainability of EU agriculture, stressing its beneficial role for climate action and the environment. Actions should address how the product(s) promoted and its/their production method(s) contribute to:

(a)	climate change mitigation (e.g. reduction in greenhouse gas emissions) and/or adaptation (e.g. water savings, climate-resistant crops and crop varieties) and

(b)

at least one of the following: (i) biodiversity conservation and sustainable use of natural resources (e.g. wildlife, landscape, genetic resources); (ii) sustainable water management (e.g. water use efficiency, reduction of nutrients or pesticides load); (iii) sustainable soil management (e.g. erosion control; nutrient balance; prevention of acidification, salinisation, reduction of pesticides); (iv) sustainable, carbon-efficient methods of livestock production. (v) reduction of use of antimicrobials (vi) reduction of food loss and food waste (vii) sustainable consumption (viii) animal welfare.

AGRIP-SIMPLE-2021-IM-PROPER-DIET

Objectives

The Commission is committed to promote proper dietary practices, in line with the European Commission's white paper on a strategy on nutrition, overweight, and obesity related health issues (6). Actions shall highlight the benefits of consuming fresh fruit and vegetables in a balanced diet. The messages could notably focus on: aiming at having at least 5 portions of a variety of fruit and vegetables each day; the place of fruit and vegetables in the food pyramid, beneficial impact on health, etc.

The objective is to increase the consumption of EU fresh fruit and vegetables by informing consumers about balanced and proper dietary practices.

The expected ultimate impact is to enhance the competitiveness and consumption of the concerned EU fruit and vegetables, raise their profile and increase their market share.

AGRIP-SIMPLE-2021-IM-CHARACTERISTICS

Objectives

The objective is to highlight at least one of the specific features of agricultural production methods in the Union, particularly in terms of food safety, traceability, authenticity, labelling, nutritional and health aspects (including proper dietary practices and responsible consumption of eligible alcoholic beverages), animal welfare, respect for the environment and sustainability (including climate benefits), and the characteristics of agricultural and food products, particularly in terms of their quality, taste, diversity or traditions.

The expected ultimate impact is to increase the awareness of the merits of Union agricultural products by the European consumers and to enhance the competitiveness and consumption of Union agri-food products, raise their profile and increase their market share.

AGRIP-SIMPLE-2021-TC-ASIA/AMERICA and OTHERS

Objectives

The information and promotion programmes shall target one or more countries identified in the corresponding topic.

The objectives of these programmes shall comply with the general and specific objectives set out in Article 2 and the aims listed in Article 3 of Regulation (EU) No 1144/2014 highlighting in particular the specific features of agricultural production methods in the Union, particularly in terms of food safety, traceability, authenticity, labelling, nutritional and health aspects, animal welfare, respect for the environment and sustainability, and the characteristics of agricultural and food products, particularly in terms of their quality, taste, diversity or traditions.

The expected ultimate impact is to enhance the competitiveness and consumption of Union agri-food products, raise their profile and increase their market share in these targeted countries.

AGRIP-SIMPLE-2021-TC-ORGANIC

Objectives

The objective is to increase the awareness and recognition of the Union quality scheme on organic production in the third countries.

Information and promotion programmes on the Union quality scheme on organic production method should be a key priority since this scheme provides consumers with assurances on the sustainability, quality and characteristics of the product and the production process used and the environmental benefits they generate, achieve added value for the products concerned and enhance their market opportunities.

The expected ultimate impact is to increase awareness of the Union quality scheme on organic production and to enhance the competitiveness and consumption of organic products, raise their profile and increase their market share in third countries.

Activities that can be funded

The activities that can be funded under this call are information and promotion campaigns covering products and schemes listed in Article 5 of Regulation (EU) No 1144/2014.

More details on ‘Eligible activities’ are provided in section 6.

Expected impact

The expected ultimate impact of this call for proposals is to enhance the competitiveness and consumption of EU agri-food products and/or to increase awareness of the Union quality schemes, raise their profile and increase their market share in the targeted countries.

For more information about the Promotion of agricultural products, see https://ec.europa.eu/chafea/agri/en

3.   Available budget

The available call budget is EUR 81 000 000.

Specific budget information per topic can be found in the table below.

Internal market

Topic	Topic budget	Topic details
1 — AGRIP-SIMPLE-2021-IM-EU QS	EUR 5 000 000	Information provision and promotion programmes aiming at increasing the awareness and recognition of Union quality schemes mentioned in Article 5(4)(a) and (c) of Regulation (EU) No 1144/2014
2 — AGRIP-SIMPLE-2021-IM-ORGANIC	EUR 6 000 000	Information provision and promotion programmes aiming at increasing the awareness and recognition of Union quality scheme on organic production method as defined in Article 5(4)(b) of Regulation (EU) No 1144/2014
3 — AGRIP-SIMPLE-2021-IM-SUSTAINABLE	EUR 6 000 000	Programmes increasing the awareness of Union sustainable agriculture and the role of the agri-food sector for climate action and the environment
4 — AGRIP-SIMPLE-2021-IM-PROPER DIET	EUR 9 100 000	Information provision and promotion programmes aiming at increasing the consumption of fresh fruit and vegetables in the internal market in the context of balanced and proper dietary practices (*1). Products eligible under this topic are those listed in Part IX and fresh bananas in Part XI of Annex I to Regulation (EU) No 1308/2013 of the European Parliament and of the Council.
5 — AGRIP-SIMPLE-2021-IM- CHARACTERISTICS	EUR 6 000 000	Information provision and promotion programmes aiming at highlighting the specific features of agricultural methods in the Union and the characteristics of European agricultural and food products, and quality schemes defined in Article 5(4)(d) of Regulation (EU) No 1144/2014

Third countries

Topic	Topic budget	Topic details
6 — AGRIP-SIMPLE-2021-TC-ASIA	EUR 16 300 000	Information provision and promotion programmes targeting one or more of the following countries: China (including Hong-Kong and Macao), Japan, South Korea, Taiwan, South-eastern Asia or Southern Asia
7 — AGRIP-SIMPLE-2021-TC-AMERICAS	EUR 8 300 000	Information provision and promotion programmes targeting one or more of the following countries: Canada, USA or Mexico
8 — AGRIP-SIMPLE-2021-TC-OTHERS	EUR 12 300 000	Information provision and promotion programmes targeting other geographical areas (*2)
9 — AGRIP-SIMPLE-2021-TC-ORGANIC	EUR 12 000 000	Information provision and promotion programmes concerning the organic products under Union quality scheme defined in Article 5(4)(b) of Regulation (EU) No 1144/2014 in any third country/ies (*3)

The call budget amount is subject to the availability of the appropriations provided for in the general budget of the EU for 2021 following its adoption by the EU budgetary authority or provided for in the provisional twelfths. This amount is also subject to the availability of appropriations for the following three years taking into account the non-differentiated nature of the appropriations.

We reserve the right not to award all available funds or to redistribute them between the call priorities, depending on the proposals received and the results of the evaluation.

If for a given topic there are not enough proposals on the ranked list to exhaust the whole foreseen amount, the remaining amount may be reallocated to other topics according to the following criteria:

(a)	the total of the remaining foreseen amount for the five topics for the internal market will be allocated to the projects targeting the internal market with the highest quality score, irrespective of the topic for which they have applied

(b)	the same approach will be taken for the four topics for third countries

(c)	if the foreseen amount is still not exhausted, the remaining amounts for both internal market and third countries will be merged and assigned to projects with the highest quality score, irrespective of the priority and topic for which they have applied.

4.   Timetable and deadlines

Timetable and deadlines
Call opening:	28 January 2021
Deadline for submission:	28 April 2021 – 17:00:00 CET (Brussels)
Evaluation:	April – September 2021
Decision by the European Commission	October 2021
Information on evaluation results by Member States	October 2021
GA signature between Member States and beneficiaries	< January 2022

5.   Admissibility

Proposals must be submitted before the call deadline (see timetable section 3).

Proposals must be submitted electronically via the Funding & Tenders Portal Electronic Submission System (accessible via the Topic page in the Search Funding & Tenders section). Paper submissions are NOT possible.

Proposals (including annexes and supporting documents) must be submitted using the forms provided inside the Submission System ( NOT the documents available on the Topic page — they are only for information).

Proposals must be complete and contain all parts and mandatory annexes and supporting documents.

The Application Form consists of:

—	Part A (to be filled in directly online) — contains administrative information about the participants (future coordinator and beneficiaries) and the summarised budget for the project

—	Part B (to be downloaded from the Portal Submission System, completed and then assembled and re-uploaded as PDF in the system) — contains the technical description of the project

—	mandatory annexes and supporting documents (to be uploaded as PDF files).

At proposal submission, you will have to confirm that you have the mandate to act for all applicants. Moreover you will have to confirm that the information in the application is correct and complete and that the participants comply with the conditions for receiving EU funding (especially eligibility, financial and operational capacity, exclusion, etc.). Before signing the grant, each beneficiary will have to confirm this again by signing a declaration of honour (DoH). Proposals without full support will be rejected.

Your application must be readable, accessible and printable.

Proposals are limited to 70 pages. Evaluators will not consider any additional pages.

Mandatory annexes and supporting documents

Mandatory annexes and supporting documents (directly available in the Submission System) for this call are:

—	detailed budget table

—	CVs of the project manager and eventually of project team

—	activity reports of last year

—	list of all EU-funded projects for the last 3 years with indication of the previous projects for which the proposal is a continuation according to article 1.4 of the Delegated Regulation (EU) 2015/1829

—

supporting documents demonstrating that the applicants are organisations or bodies as referred to in Article 7(1) of Regulation (EU) No 1144/2014 for each applicant, documentation proving that it meets the representativeness criteria set out in Article 1 of the Delegated Regulation (EU) 2015/1829 (see section below), together with the legal entity documents

—	financial documents: annual accounts (or business plan), pre-filled financial form and, if needed, audit report (or self-declaration) (see section below).

For more information about the submission process (including IT aspects), consult the Online Manual.

6.   Eligibility

Eligible participants

In order to be eligible, the applicants must be:

—	legal entities (public or private bodies)

—	established in an EU Member State (including overseas countries and territories (OCTs))

—

eligible organisations or bodies as referred to in Article 7(1) of Regulation (EU) No 1144/2014: — trade or inter-trade organisations, established in a Member State and representative of the sector or sectors concerned in that Member State, and in particular the interbranch organisations as referred to in Article 157 of Regulation (EU) No 1308/2013 of the European Parliament and of the Council (7) and groups as defined in point 2 of Article 3 of Regulation (EU) No 1151/2012, provided that they are representative for the name protected under the latter Regulation which is covered by that programme — producer organisations or associations of producer organisations, as referred to in Articles 152 and 156 of Regulation (EU) No 1308/2013 that have been recognised by a Member State or — agri-food sector bodies the objective and activity of which is to provide information on, and to promote agricultural products and which have been entrusted, by the Member State concerned, with a clearly defined public service mission in this area; those bodies must have been legally established in the Member State in question at least two years prior to the date of the call for proposals referred to in Article 8(2).

The abovementioned proposing organisations may submit a proposal provided that they are also representative of the sector or product concerned by the proposal, complying with conditions set out in Articles 1(1) or 1(2) of Delegated Regulation (EU) 2015/1829 of 23 April 2015, namely:

—

trade or inter-trade organisation, established in a Member State, as referred to in Article 7(1)(a) and (b) of Regulation (EU) No 1144/2014 respectively, is deemed to be representative of the sector concerned by the programme: — where it accounts for at least 50 % as a proportion of the number of producers, or 50 % of the volume or value of marketable production of the product(s) or sector concerned, in the Member State or — where it is an interbranch organisation recognised by the Member State in accordance with Article 158 of Regulation (EU) No 1308/2013 or with Article 16 of Regulation (EU) No 1379/2013 of the European Parliament and of the Council (8)

—

a group as defined in point 2 of Article 3 of Regulation (EU) No 1151/2012 of the European Parliament and of the Council (9) and referred to in Article 7(1)(a) of Regulation (EU) No 1144/2014, is deemed to be representative of the name protected under Regulation (EU) No 1151/2012 and covered by the programme, where it accounts for at least 50 % of the volume or value of marketable production of the product(s) whose name is protected

—

a producer organisation or an association of producer organisations as referred to in Article 7(1)(c) of Regulation (EU) No 1144/2014 is deemed to be representative of the product(s) or sector concerned by the programme where it is recognised by the Member State in accordance with Articles 154 or 156 of Regulation (EU) No 1308/2013 or with Article 14 of Regulation (EU) No 1379/2013;

—	an agri-food sector body as referred to in Article 7(1)(d) of Regulation (EU) No 1144/2014 is deemed to be representative of the sector(s) concerned by the programme by means of having representatives of that product(s) or sector among its memberships.

Lower representativeness thresholds than 50 % may be accepted if the proposing organisation demonstrates in the submitted proposal that there are specific circumstances, including the evidence on the structure of the market, which would justify treating the proposing organisation as representative of the product(s) or sector concerned.

Beneficiaries must register in the Participant Register — before the submitting the proposal.

In order to assess the participants’ eligibility, the following documents are requested:

—	private entity: extract from the official journal, copy of articles of association/statutes, extract of trade or association register, certificate of liability to VAT (if, as in certain countries, the trade register number and VAT number are identical, only one of these documents is required);

—	public entity: copy of the resolution or decision establishing the public company, or other official document establishing the public-law entity;

—	entities without legal personality: documents providing evidence that their representative(s) has/have the capacity to undertake legal obligations on their behalf.

Other entities may participate in other consortium roles, such as associated partners, sub-contractors, third parties giving in-kind contributions, etc. (see section 12).

Specific cases

Entities without legal personality — Entities which do not have legal personality under their national law may exceptionally participate, provided that their representatives have the capacity to undertake legal obligations on their behalf, and offer guarantees for the protection of the EU financial interests equivalent to that offered by legal persons (10).

Associations and interest groupings — Entities composed of members may participate as ‘sole beneficiaries’ or ‘beneficiaries without legal personality’ (11).

Please note that if the action will be implemented by the members, they should also participate (either as beneficiaries or as recipients of financial support to third parties, otherwise their costs cannot be covered by the action).

EU restrictive measures — Special rules apply for certain entities (e.g. entities subject to EU restrictive measures under Article 29 of the Treaty on the European Union (TEU) and Article 215 of the Treaty on the Functioning of the EU (TFEU) (12) and entities covered by Commission Guidelines 2013/C 205/05 (13)). Such entities are not eligible to participate in any capacity, including as beneficiaries, associated partners, third parties giving in-kind contributions, subcontractors or recipients of financial support to third parties (if any).

Consortium composition

Proposals by single applicants are allowed.

Proposals must be submitted by one or several organisations referred to in points (a), (c) and (d) of Article 7(1) of Regulation (EU) No 1144/2014, which must be from the same Member State and comply with the conditions on representativeness for the product of the sector promoted.

The trade or inter-trade organisations of the Union that are representative at Union level for the product or sector promoted (point (b) of Article 7(1) of Regulation (EU) No 1144/2014) are excluded from this call.

Eligible activities

Eligible activities are the ones set out in section 2 above.

The information and promotion campaigns may cover the following activities:

1.	Management of the project

2.	Public relations — PR activities — Press events

3.	Website, social media — Website setup, updating, maintenance — Social media (accounts setup, regular posting) — Other (mobile apps, e-learning platforms, webinars, etc.)

4.	Advertising — Print — TV — Radio — Online — Outdoor — Cinema

5.	Communication tools — Publications, media kits, promotional merchandise — Promotional videos

6.	Events — Stands at trade fairs — Seminars, workshops, B2B meetings, trainings for trade/cooks, activities in schools — Restaurant weeks — Sponsorship of events — Study trips to Europe

7.	Point-of-sale (POS) promotion — Tasting days — Other: promotion in retailers' publications, POS advertising

Tastings and distribution of samples are not allowed in the context of campaigns on responsible drinking implemented in the internal market; these activities are however acceptable if ancillary to and supportive of the provision of information measures on the quality schemes and organic production method.

Activities should be complementary to and should not overlap with activities financed through the Common Agricultural Policy and/or though the funds or instruments of the different Member States supporting at the national level the promotion of agricultural products. Projects must be designed to complement other private or public activities implemented by the proposing organisation(s) in the targeted markets; synergies with such activities must be ensured.

Projects should take into account the results of previous co-financed campaigns clearly describing their impact and reasons for resubmission.

The complementarities must be described in the project proposal (Part B of the Application Form).

Projects must comply with EU policy interests and priorities (such as environment, climate, social, development and trade policy, etc.).

Proposals must:

a)

ensure that the measures are implemented through implementing bodies as referred to in Article 13 of Regulation (EU) No 1144/2014. Proposing organisations must select bodies responsible for implementing programmes ensuring best value for money and absence of conflict of interest (see Article 2 of Delegated Regulation (EU) 2015/1829). The proposing organisation shall undertake that the body responsible for the implementation of the programme shall be selected at the latest before the signature of the grant agreement (see Article 10 of Implementing Regulation (EU) 2015/1831);

b)	ensure that the costs of the measure which it plans to carry out itself is not in excess of the normal market rates, if the proposing organisation proposes to implement certain parts of the proposal itself;

c)	comply with Union law governing the products concerned and their marketing and have a Union dimension;

d)

for proposals in the internal market covering one or more schemes as referred to in Article 5(4) of Regulation (EU) No 1144/2014: focus on the(se) scheme(s) in their main Union message. When in this programme, one or several products illustrate(s) the(se) scheme(s), it/they must appear as a secondary message in relation to the main Union message;

e)

for messages containing information on the impact on health: — in the internal market: comply with the Annex to Regulation (EC) No 1924/2006 of the European Parliament and of the Council (14), or be accepted by the national authority responsible for public health in the Member State where the operations are carried out — in third countries: be accepted by the national authority responsible for public health in the country where the operations are carried out

f)	for proposals proposing to mention origin or brands: comply with the rules as referred to in Chapter II of Implementing Regulation (EU) 2015/1831.

For the purposes of assessing the eligibility of the activities, the following information must be provided:

—	for proposals covering national quality schemes: documentation or a reference to publicly available sources that prove that the quality scheme is officially recognised by the Member State

—

for proposals targeting the internal market and relaying a message on proper dietary practices or responsible alcohol consumption: description how the proposed programme and its message(s) are in line with the relevant national rules in the field of public health in the Member State where the programme will be carried out (including references or documentation in support of this claim)

—	for proposals promoting sustainable products or methods: documentation or a reference to publicly available sources that prove that the product/method is certified as sustainable.

Financial support to third parties is allowed for grants under the following conditions:

—	the financial support is given only to entities that are linked to the beneficiary (15) and identified already in the project proposal

—	the project specifies the maximum amount of financial support for each third party and the criteria and procedures for giving the financial support

—	the beneficiaries ensure that the costs charged to the action are limited to the costs actually incurred by those third parties and that the entities comply with the principle of sound financial management and keep records on their costs.

Geographic location (target countries)

Applications must relate to activities targeting one or several countries covered by the chosen topic of the call.

Duration

Projects should have a minimum duration of 12 and a maximum duration of 36 months.

Proposals should specify the duration of the action.

7.   Financial and operational capacity and exclusion

Financial capacity

Applicants must have stable and sufficient resources to successfully implement the projects and contribute their share. Organisations participating in several projects must have sufficient capacity to implement all these projects.

The financial capacity check will be carried out on the basis of the following documents:

—	the annual accounts (including profit and loss account and balance sheet) for the last financial year for which the accounts were closed;

—	for newly created entities, a business plan (if the accounts are not available);

—	the pre-filled financial viability form summarising the necessary data from the annual accounts contributing to the assessment of the financial capacity.

In addition, for participant requesting an EU contribution of more than EUR 750 000 (threshold per applicant):

—	an audit report issued by an approved external auditor certifying the accounts for the last available financial year, if such report is available and a statutory audit is required under EU or national law; OR

—	a self-declaration signed by the applicant's authorised representative certifying the validity of its accounts. The self-declaration must be accompanied by legal documents proving the legal representative’s identity and that they are entitled to sign on behalf of the participant.

The analysis will be based on neutral financial indicators, but will also take into account other aspects, such as dependency on EU funding and deficit and revenue in previous years.

The check will normally be done for all beneficiaries, except:

—	public bodies (entities established as public body under national law, including local, regional or national authorities)

—	if the individual requested grant amount is not more than EUR 60 000.

Operational capacity

Applicants must have the know-how, qualifications and resources to successfully implement the projects and contribute their share (including sufficient experience in projects of comparable size and nature).

Applicants must demonstrate that at least one natural person working under employment contract with the applicant (or assigned to the action on basis of an equivalent appointing act, secondment against payment or on the basis of other types of direct contracts, e.g. covering provision of services) will be appointed as a project manager. The project manager must have at least three years’ experience in project management.

The operational capacity will be assessed as part of the ‘Quality’ award criterion on the basis of the competence and experience of the applicants and their project teams, including operational resources (human, technical and other) or, exceptionally, the measures proposed to obtain it by the time the task implementation starts.

If the evaluation of the award criterion is positive, the applicants are considered to have sufficient operational capacity.

Applicants will have to show their capacity via the following information in the Application Form (Part B):

—	general profiles (qualifications and experiences) of the staff responsible for managing and implementing the project (e.g. CV of the project manager, CVs core project team, etc.)

—	applicants’ activity report of the last year

—	list of EU-funded projects for the last 3 years.

In case where proposing organisations propose to implement certain parts of the proposal, evidence shall be given that they have at least 3 years’ experience in implementing information provision and promotion measures. Therefore, shall provide the following information:

—	description of the relevant activities performed by the applicant.

Additional supporting documents may be requested, if needed to confirm the operational capacity of any applicant.

Exclusion

Applicants which are subject to EU administrative sanctions (i.e. exclusion or financial penalty decision) (16) or in one of the following exclusion situations that bar them from receiving EU funding can NOT participate:

—	bankruptcy, winding up, affairs administered by the courts, arrangement with creditors, suspended business activities or other similar procedures (including procedures for persons with unlimited liability for the applicant’s debts)

—	in breach of social security or tax obligations (including if done by persons with unlimited liability for the applicant’s debts)

—	guilty of grave professional misconduct (17) (including if done by persons having powers of representation, decision-making or control, beneficial owners or persons who are essential for the award/implementation of the grant)

—

committed fraud, corruption, links to a criminal organisation, money laundering, terrorism-related crimes (including terrorism financing), child labour or human trafficking (including if done by persons having powers of representation, decision-making or control, beneficial owners or persons who are essential for the award/implementation of the grant)

—

shown significant deficiencies in complying with main obligations under an EU procurement contract, grant agreement, prize, expert contract, or similar (including if done by persons having powers of representation, decision-making or control, beneficial owners or persons who are essential for the award/implementation of the grant)

—	guilty of irregularities within the meaning of Article 1(2) of Council Regulation (EC, Euratom) No 2988/95 (18) (including if done by persons having powers of representation, decision-making or control, beneficial owners or persons who are essential for the award/implementation of the grant)

—

created under a different jurisdiction with the intent to circumvent fiscal, social or other legal obligations in the country of origin or created another entity with this purpose (including if done by persons having powers of representation, decision-making or control, beneficial owners or persons who are essential for the award/implementation of the grant).

Applicants will also be refused if it turns out that (19):

—	during the award procedure they misrepresented information required as a condition for participating or failed to supply that information

—	they were previously involved in the preparation of the call and this entails a distortion of competition that cannot be remedied otherwise (conflict of interest).

8.   Evaluation and award procedure

The proposals will have to follow the standard submission and evaluation procedure (one-stage submission + one-step evaluation).

Proposals will first be checked for formal requirements (admissibility and eligibility) and then evaluated (for each topic separately) by an evaluation committee (assisted by independent outside experts) for operational capacity and award criteria (see sections 7 and 9) and then ranked according to their quality score.

For proposals with the same score (within a same topic) a priority order will be determined according to the following approach:

For every group of ex aequo proposals, starting with the highest scored group, and continuing in descending order, proposals which allow for diversification in terms of products or targeted markets will be prioritised.

This means that, between ex aequo applications within the same topic, priority will be given to applications which are not yet represented in the higher ranked proposals firstly in terms of products, secondly in terms of targeted market.

If these criteria cannot be applied, then projects with highest score for individual award criteria will be selected.

We will first compare projects scores for the award criterion ‘Relevance’. When these scores are equal, priority will be based on the scores for the criterion ‘Impact’. When these scores are equal, priority will be based on the scores for the criterion ‘Quality’.

The order of the ranked lists will be strictly followed.

The European Commission shall adopt an implementing act determining the simple programmes selected, any changes to be made to them, and the corresponding budgets (award decision). This Commission decision will list the selected programmes accepted for a financial contribution from the Union under Article 15 of Regulation (EU) No 1144/2014. The decision will be addressed to the competent Member States.

As soon as the Commission adopts this implementing act, it shall forward the copies of the selected programmes to the Member States concerned. Member States shall without delay inform the proposing organisations concerned whether or not their applications have been accepted.

9.   Award criteria

The award criteria for this call are as follows:

—

Relevance (25 points): — Relevance of the proposed action to the general and specific objectives listed in Article 2 of the Regulation (EU) No 1144/2014, to the aims listed in Article 3 of the same Regulation, as well as to priorities, objectives and expected results announced under the relevant thematic priority of the call. — Contribution of the proposed information provision and promotion project in respect of the objectives of the climate and environmental ambition of the CAP, the Green Deal and Farm to Fork strategies, in particular concerning sustainability of production and consumption. — Quality and relevance of the market analysis. — Coherence of the action strategy, specific objectives, target groups and key messages. — EU message of the campaign.

—

Quality (50 points): — Suitable choice of activities with respect to objective and action strategy, adequate communication mix, synergy between activities. — Concise description of activities and deliverables. — Quality of the proposed evaluation methods and indicators. — Suitable allocation of budget in relation to objectives and scope of activities. — Clear description of the estimated costs and accuracy of the budget. — Consistency between the estimated costs and deliverables. — Project organisation and management structure. — Quality control mechanisms and risk management

—

Impact (25 points): — Impact of project at EU level. — Justification of the overall level of investment. Award criteria Minimum pass score Maximum score Relevance 15 25 Quality 30 50 Impact 15 25 Overall (pass) scores 60 100 Maximum points: 100 points. Individual thresholds per criterion: 15/25 and 30/50 points. Overall threshold: 60 points. Proposals that pass the individual thresholds AND the overall threshold will be considered for funding — within the limits of the available call budget. Other proposals will be rejected.

10.   Legal and financial set-up of the Grant Agreements

The Member States concerned shall be responsible for the proper implementation of the simple programmes selected and for the relevant payments.

Member States shall conclude grant agreements for the implementation of programmes with the selected proposing organisations in accordance with the requirements mentioned under Article 10 of Implementing Regulation (EU) 2015/1831.

This Grant Agreement will set the framework for your grant and its terms and conditions, in particular concerning deliverables, reporting and payments.

The Model Grant Agreement that will be used (and all other relevant templates and guidance documents) can be found on Portal Reference Documents.

Starting date and project duration

The project starting date and duration will be fixed in the Grant Agreement (Data Sheet, point 1). Normally the starting date will be after grant signature. It should not be later than 6 months after the date of entry into force of the grant agreement. Retroactive application can be granted exceptionally for duly justified reasons — but never earlier than the proposal submission date.

Project duration: minimum 12, maximum 36 months.

Deliverables

The deliverables for each project will be reflected in Annex 1 of the Grant Agreement.

Form of grant, funding rate and maximum grant amount

The grant parameters (maximum grant amount, funding rate, total eligible costs, etc.) will be fixed in the Grant Agreement (Data Sheet, point 3 and art 5).

Project budget: No limit. The grant awarded may be lower than the amount requested.

The grant will be a budget-based mixed actual cost grant. This means that it will reimburse ONLY certain types of costs (eligible costs) and ONLY costs you actually incurred for your project (NOT the budgeted costs).

The costs will be reimbursed at the funding rate fixed in the Grant Agreement (75/85 % for beneficiaries that are established in EU Member States receiving financial assistance and 70 (for simple programmes in the internal market)/80 % (for simple programmes in third countries) for beneficiaries from other countries).

The no-profit rule applies to for-profit organisations applying under this call. The grant may NOT produce a profit. If there is a profit (i.e. surplus of revenues + EU grant over costs), we will deduct it from your final grant amount.

Moreover, please be aware that the final grant amount may be reduced in case of non-compliance with the Grant Agreement (e.g. improper implementation, breach of obligations, etc.).

Budget categories and cost eligibility rules

The budget categories and cost eligibility rules are fixed in the Grant Agreement (Data Sheet, point 3 and art 6).

Budget categories for this call:

—	A. Personnel costs — A.1 Employees, A.2 Natural persons under direct contract, A.3 Seconded persons — A.4 SME owners and natural person beneficiaries

—	B. Subcontracting costs

—	C. Purchase costs — C.1 Travel and subsistence — C.2 Equipment — C.3 Other goods, works and services

—	D. Other cost categories — D.1 Financial support to third parties

—	E. Indirect costs

Specific cost eligibility conditions for this call:

—	personnel costs: — supplementary payments: standard — SME owner/natural person unit cost: Yes — volunteers costs: No

—	travel & subsistence costs: actual costs

—	equipment costs: depreciation

—

other cost categories: — costs for financial support to third parties: allowed for grants; maximum amount per third party EUR 60 000 EUR, unless a higher amount is required because the objective of the action would otherwise be impossible or overly difficult to achieve and this is duly justified in the Application Form — indirect cost flat-rate: 4 % of the eligible direct personnel costs (category A)

—	VAT: non-deductible VAT is eligible (but please note that since 2013 VAT paid by beneficiaries that are public bodies acting as public authority is NOT eligible)

—

divers: — in-kind contributions for free are allowed, but cost-neutral, i.e. cannot be declared as cost — inception meeting: costs for inception meeting organised by the granting authority are eligible (travel costs for maximum 2 persons, return ticket to Brussels and accommodation for one night) only if the meeting takes place after the project starting date set out in the Grant Agreement; the starting date can be changed through an amendment, if needed — financial contributions given by third parties, specifically to be used for the costs that are eligible under the action are not allowed, except if given by the members of the beneficiary’s organisation.

Reporting and payment arrangements

The reporting and payment arrangements are fixed in the Grant Agreement (Data Sheet, point 4 and art 21 and 22).

After grant signature, you are entitled to receive an advance payment to start working on the project (float of normally 20 % of the maximum grant amount).

The proposing organisation may submit an application for an advance payment to the Member State concerned in accordance with Article 13 of Implementing Regulation (EU) 2015/1831.

The advance payment shall be paid on condition that the proposing organisation has lodged a security equal to the amount of that advance in favour of the Member State in accordance with Chapter IV of Commission Delegated Regulation (EU) No 907/2014 (20).

There will be an interim payment (with detailed cost reporting) at the end of each year of completed implementation of the action.

Applications for the interim payment shall be submitted by the proposing organisation to the Member States in accordance with Article 14 of Implementing Regulation (EU) 2015/1831.

Applications for payment of the balance shall be submitted by the proposing organisation to the Member State States in accordance with Article 15 of Implementing Regulation (EU) 2015/1831. The Member State will calculate your final grant amount. If the total of earlier payments is higher than the final grant amount, the Member State will ask the coordinator to pay back the difference (recovery).

All payments will be made to the coordinator, if any.

Certificates

Depending on the type of action, size of grant amount and type of beneficiaries, you may be requested to submit different certificates. The types, schedules and thresholds for each certificate are fixed in the grant agreement (Data Sheet, point 4 and art 24).

Liability regime for recoveries

The liability regime for recoveries will be fixed in the Grant Agreement (Data Sheet point 4.4 and art 22).

For beneficiaries, it is one of the following:

—	limited joint and several liability with individual ceilings — each beneficiary up to their maximum grant amount

—	unconditional joint and several liability — each beneficiary up to the maximum grant amount for the action or

—	individual financial responsibility — each beneficiary only for their own debts.

Provisions concerning the project implementation

Security rules: see Model Grant Agreement (art 13)

Ethics rules: see Model Grant Agreement (art 14)

IPR rules: see Model Grant Agreement (art 16 and Annex 5)

—	list of background: Yes

—	rights of use on results: Yes

Communication, dissemination and visibility of funding: see Model Grant Agreement (art 17 and Annex 5)

—	additional communication and dissemination activities Yes

—	special logo: Yes

Specific rules for carrying out the action: see Model Grant Agreement (art 18 and Annex 5)

—	specific rules for information and promotion campaigns for agricultural products

—	specific rules for financial support to third parties.

Non-compliance and breach of contract

The Grant Agreement (chapter 5) provides for the measures we may take in case of breach of contract (and other non-compliance issues).

For more information, see AGA — Annotated Grant Agreement.

11.   Help

As far as possible, please try to find the answers you need yourself , in this and the other documentation (we have limited resources for handling direct enquiries):

—	Online Manual

—	FAQs on the Topic page (for call-specific questions)

—	Portal FAQ (for general questions)

—	Specific FAQ on the Promotion policy (https://ec.europa.eu/chafea/agri/faq.html)

Please also consult the Topic page regularly, since we will use it to publish call updates.

Contact

For individual questions on the Portal Submission System, please contact the IT Helpdesk.

Non-IT related questions should be sent to the following email address: CHAFEA-AGRI-CALLS@ec.europa.eu

Please indicate clearly the reference of the call and topic to which your question relates (see cover page).

12.   Important

IMPORTANT — Don’t wait until the end — Complete your application sufficiently in advance of the deadline to avoid any last minute technical problems. Problems due to last minute submissions (e.g. congestion, etc.) will be entirely at your risk. Call deadlines can NOT be extended. — Consult the Portal Topic page regularly. We will use it to publish updates and additional information on the call (call and topic updates). — Funding & Tenders Portal Electronic Exchange System — By submitting the application, all participants accept to use the electronic exchange system in accordance with the Portal Terms & Conditions. — Registration — Before submitting the application, all beneficiaries must be registered in the Participant Register. The participant identification code (PIC) (one per participant) is mandatory for the Application Form. Associated partners can register later on (at the latest during grant preparation). — Consortium roles — When setting up your consortium, you should think of organisations that help you reach objectives and solve problems. The roles should be attributed according to the level of participation in the project. Main participants should participate as beneficiaries; other entities can participate as associated partners, subcontractors, third parties giving in-kind contributions. Associated partners and third parties giving in-kind contributions should bear their own costs (they will not become formal recipients of EU funding). Subcontracting must be performed by third parties (not by one of the beneficiaries). — Coordinator — In multi-beneficiary grants, the beneficiaries participate as consortium (group of beneficiaries). They will have to choose a coordinator, who will take care of the project management and coordination and will represent the consortium towards the granting authority. In mono-beneficiary grants, the single beneficiary will automatically be coordinator. — Associated partners — Applicants may participate with associated partners (i.e. partner organisations which participate in the action but without the right to get grant money). They participate without funding and therefore do not need to be validated. — Consortium agreement — For practical and legal reasons it is recommended to set up internal arrangements that allow you to deal with exceptional or unforeseen circumstances (in all cases, even if not mandatory under the Grant Agreement). The consortium agreement also gives you the possibility to redistribute the grant money according to your own consortium-internal principles and parameters (for instance, one beneficiary can reattribute its grant money to another beneficiary). The consortium agreement thus allows you to customise the EU grant to the needs inside your consortium and can also help to protect you in case of disputes. — Balanced project budget — Grant applications must ensure a balanced project budget and sufficient other resources to implement the project successfully (e.g. own contributions, income generated by the action, financial contributions from third parties, etc.). You may be requested to lower your estimated costs, if they are ineligible (including excessive). — No-profit rule — Grants may NOT give a profit (i.e. surplus of revenues + EU grant over costs). This will be checked by us at the end of the project. — No double funding — There is a strict prohibition of double funding from the EU budget (except under EU Synergies calls). Outside such Synergies calls, any given action may receive only ONE grant from the EU budget and cost items may under NO circumstances declared to two different EU actions. — Completed/ongoing projects — Proposals for projects that have already been completed will be rejected; proposals for projects that have already started will be assessed on a case-by-case basis (in this case, no costs can be reimbursed for activities that took place before the project starting date/proposal submission). — Combination with EU operating grants — Combination with EU operating grants is possible, if the project remains outside the operating grant work programme and you make sure that cost items are clearly separated in your accounting and NOT declared twice (see AGA — Annotated Model Grant Agreement, art 6.2.E). — Multiple proposals — Applicants may submit more than one proposal for different projects under the same call (and be awarded a funding for them). Organisations may participate in several proposals. BUT: if are several proposals for the same/very similar project, only one application will be accepted and evaluated; the applicants will be asked to withdraw one of them (or it will be rejected). — Resubmission — Proposals may be changed and re-submitted until the deadline for submission. — Rejection — By submitting the application, all applicants accept the call conditions set out in this this Call Document (and the documents it refers to). Proposals that do not comply with all the call conditions will be rejected. This applies also to applicants: All applicants need to fulfil the criteria; if any one of them doesn’t, they must be replaced or the entire proposal will be rejected. — Cancellation — There may be circumstances which may require the cancellation of the call. In this case, you will be informed via a call or topic update. Please note that cancellations are without entitlement to compensation. — Language — You can submit your proposal in any official EU language. However, for reasons of efficiency, we strongly advise you to use English. — Transparency — In accordance with Article 38 of the EU Financial Regulation, information about EU grants awarded is published each year on the Europa website. This includes: — beneficiary names — beneficiary addresses — the purpose for which the grant was awarded — the maximum amount awarded. The publication can exceptionally be waived (on reasoned and duly substantiated request), if there is a risk that the disclosure could jeopardise your rights and freedoms under the EU Charter of Fundamental Rights or harm your commercial interests. — Data protection — The submission of a proposal under this call involves the collection, use and processing of personal data. This data will be processed in accordance with the applicable legal framework. It will be processed solely for the purpose of evaluating your proposal, subsequent management of your grant and, if needed, programme monitoring, evaluation and communication. Details are explained in the Funding & Tenders Portal Privacy Statement.

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(1)  Regulation (EU, Euratom) 2018/1046 of the European Parliament and of the Council of 18 July 2018 on the financial rules applicable to the general budget of the Union, amending Regulations (EU) No 1296/2013, (EU) No 1301/2013, (EU) No 1303/2013, (EU) No 1304/2013, (EU) No 1309/2013, (EU) No 1316/2013, (EU) No 223/2014, (EU) No 283/2014, and Decision No 541/2014/EU and repealing Regulation (EU, Euratom) No 966/2012 (OJ L 193, 30.7.2018, p. 1).

(2)  Regulation (EU) No 1144/2014 of the European Parliament and of the Council of 22 October 2014 on information provision and promotion measures concerning agricultural products implemented in the internal market and in third countries and repealing Council Regulation (EC) No 3/2008 (OJ L 317, 4.11.2014, p. 56).

(3)  Commission Delegated Regulation (EU) 2015/1829 of 23 April 2015 supplementing Regulation (EU) No 1144/2014 of the European Parliament and of the Council on information provision and promotion measures concerning agricultural products implemented in the internal market and in third countries (OJ L 266, 13.10.2015, p. 3).

(4)  Commission Implementing Regulation (EU) 2015/1831 of 7 October 2015 laying down rules for application of Regulation (EU) No 1144/2014 of the European Parliament and of the Council on information provision and promotion measures concerning agricultural products implemented in the internal market and in the third countries (OJ L 266, 13.10.2015, p. 14).

(5)  Commission Implementing Decision C(2020) 8835 final of 16 December 2020 concerning the adoption of the work programme for 2021 and the financing decision for the implementation of the Promotion of Agricultural products.

(6)  COM(2007) 279 final, 30.5.2007.

(*1)  Simple programme on ‘fruit and vegetables' for the internal market are also eligible under other topics. The message of campaigns on fruit and vegetables under other topics targeting the internal market shall be different than highlighting the benefits of consuming fruit and vegetables within a balanced and proper diet (except if fruit and vegetables are associated with (an)other product(s)).

(*2)  Programmes targeting least-developed countries (LDC) according to UN list available at https://www.un.org/development/desa/dpad/wp-content/uploads/sites/45/publication/ldc_list.pdf should be coherent with EU development objectives. Applicants will be asked to submit their own assessment explaining why the proposed promotion programme will not adversely affect EU development policy goals in the least-developed country targeted by the promotion programme.

(*3)  Simple programmes promoting organic products in third countries shall apply under topic AGRIP- SIMPLE-2021-TC-ORGANIC. They cannot apply under other topics, except if organic products are combined with other products.

(7)  OJ L 347, 20.12.2013, p. 671.

(8)  OJ L 354, 28.12.2013, p. 1.

(9)  OJ L 343, 14.12.2012, p. 1.

(10)  See Article 197(2)(c) EU Financial Regulation 2018/1046.

(11)  For the definitions, see Articles 187(2) and 197(2)(c) EU Financial Regulation 2018/1046.

(12)  Please note that the EU Official Journal contains the official list and, in case of conflict, its content prevails over that of the EU Sanctions Map.

(13)  Commission guidelines 2013/C 205/05 on the eligibility of Israeli entities and their activities in the territories occupied by Israel since June 1967 for grants, prizes and financial instruments funded by the EU from 2014 onwards (OJ C 205, 19.7.2013, p. 9).

(14)  Regulation (EC) No 1924/2006 of the European Parliament and of the Council of 20 December 2006 on nutrition and health claims made on foods (OJ L 404, 30.12.2006, p. 9).

(15)  ‘Linked entities’ are entities that have a link with the beneficiary, in particular, a legal or capital link, which is neither limited to the action nor established for the sole purpose of its implementation.

(16)  See Article 136 of EU Financial Regulation 2018/1046.

(17)  Professional misconduct includes: violation of ethical standards of the profession, wrongful conduct with impact on professional credibility, false declarations/misrepresentation of information, participation in a cartel or other agreement distorting competition, violation of IPR, attempting to influence decision-making processes or obtain confidential information from public authorities to gain advantage.

(18)  OJ L 312, 23.12.1995, p. 1.

(19)  See Article 141 EU Financial Regulation 2018/1046.

(20)  OJ L 255, 28.8.2014, p. 18.