Issue Number 18: 6th October 2017

A (bitter) sweet future? The EU abolishes its sugar production quotas
Finland approves insects for food use – but not all insect-based food. Food safety authority to publish guidance
Towards the regulation of voluntary precautionary allergen labelling in the EU?
Recently Adopted EU Legislation

A (bitter) sweet future? The EU abolishes its sugar production quotas

On 30 September 2017, EU sugar production quotas were abolished and, since 1 October 2017, EU sugar beet growers are able to determine their crops themselves, without being limited to the previous cap on sugar beet production. At the same time, guaranteed minimum prices have also been removed. While the EU had to import sugar until now to satisfy domestic demand, it is now expected to increase its sugar production and actually become a net exporter of sugar. Overall effects on the market and on global sugar trade, however, are still uncertain. Increased sugar production in the EU, and potentially decreased sugar prices, might also lead to public health concerns.

EU production quotas for sugar date all the way back to 1968 and, together with a support price for producers significantly above the world market price, were introduced as elements of the EU’s common market organisation (CMO) for sugar. The EU’s Common Agricultural Policy (CAP), also introduced during that time, aimed at achieving self-sufficiency in terms of EU food production. From that time, EU sugar policy covered all aspects relevant to the industry, from production quotas and guaranteed prices, to exports subsidies and import restrictions. In 2004, in the World Trade Organization (hereinafter, WTO) dispute settlement case of European Communities – Export Subsidies on Sugar initiated by Brazil and Australia, a dispute settlement panel and subsequently the WTO’s Appellate Body, found that the EU sugar regime violated international trade rules, in particular through its export subsidies for sugar. More specifically, the panel concluded that the EU, through its sugar regime, had acted inconsistently with its obligations under Articles 3.3 and 8 of the Agreement on Agriculture (hereinafter, AoA), by providing export subsidies within the meaning of Article 9.1(a) and (c) of the AoA in excess of the quantity commitment level and the budgetary outlay commitment level specified in Section II, Part IV of Schedule CXL (i.e., the EU’s Schedule of Concessions within the WTO). The EU started to reform its sugar policy and to adapt the various policy elements. In 2006, the reform of the CAP included a number of measures leading to a transition period for the EU’s sugar producers. EU Member States agreed to phase out the EU’s sugar quotas by 2015. In 2013, the European Parliament and EU Member States agreed to postpone the end of EU sugar production quotas until the end of the 2016/2017 agricultural year, which now came to a close on 30 September 2017.

During the application of the sugar production quotas, a quota of 13.5 million metric tonnes was divided between 20 EU Member States. Out-quota production (i.e., production above the 13.5 million metric tonnes), was only eligible for export up to the EU’s annual WTO limit of 1.374 million metric tonnes and had to be destined for biofuel and other industrial non-food uses, or could be stored and counted against the following year’s quota. There was also a 0.72 million metric tonnes quota for isoglucose (also known as glucose fructose syrup or high fructose corn syrup) and export of excess production was also restricted. Finally, inulin syrup was subject to a production quota of zero, thereby prohibiting the production within the EU. The end of production quotas now removed any limits on EU sugar, isoglucose and inulin syrup production.

Despite the end of the sugar production quotas, EU agricultural policy will continue to support the EU sugar sector. In a fact sheet, the Commission lists a number of measures, benefitting the EU’s sugar beet producers: 1) Voluntary coupled support by EU Member States linked to production to address sectors in difficulties (eleven EU Member States are already using this option and overall support sugar beet producers amounts in 2017 amounts to around EUR 180 million); 2) A system of collective bargaining aimed at helping the position of beet growers when negotiating with sugar producers, allowing for predictable terms for delivering and buying beet and not subject to competition law scrutiny; 3) The provision of detailed information to farmers through the EU’s Sugar Market Observatory; 4) Private storage aid; and 5) Disturbance clauses, allowing the Commission to take action in the event of severe market crises, involving a significant decrease of market prices.

Another aspect of the Commission’s assurance to sugar producers that it would continue to protect them and aim at mitigating the effects of the liberalisation, concerns the EU’s import tariffs. The case of import tariffs is particularly interesting, because the EU is currently conducting negotiations for preferential trade agreements with various sugar-producing countries. Most importantly, the EU is currently negotiating with the Southern American Mercosur countries of Argentina, Brazil, Paraguay and Uruguay. Brazil is the world’s largest cane sugar producer and the world’s largest sugar exporter. In the most recent crop year season 2016/2017, Brazil produced 39.2 million metric tonnes of sugar. Brazilian sugar exports to the EU benefit from a tariff-rate quota, which, however, keeps those exports at very low level. Until the negotiation round held during the first week of October 2017 in Brazil, important sectors, such as beef, sugar and ethanol, were not part of the formal negotiations. Reportedly, after considerable pressure from Brazil, the EU has now tabled market access proposals that include provisions on beef and ethanol. Sugar is still not part of the most recent proposals, though. According to Article XXIV:8(b) of the General Agreement on Tariffs and Trade (GATT), preferential trade agreements must cover “substantially all the trade” between the parties. The specific interpretation of this requirement, however, remains unclear and open to various interpretations. It appears, therefore, at least legally questionable if the total exclusion of sugar from the scope of the future trade agreements is compatible with WTO rules.

One relatively certain consequence of the end of sugar production quotas will be an increased yield of sugar beet and, consequently, increased sugar production in the EU. In France and Germany, the EU’s most important sugar beet producers, this season’s harvest has already begun, with the first production indications suggesting a significantly increased yield. Analysts are forecasting an EU production increase of 20-25% in the 2017/2018 agricultural year, which began on 1 October 2017. The Commission appears confident that sugar producers would be able to adjust to market signals and avoid oversupply.

The larger amount of sugar produced in the EU is expected to be exported. Hence, the abolition of the EU sugar quotas will also have repercussions on global sugar trade. Currently, the EU is a net importer of sugar under a highly regulated import regime, consisting of preferential trade arrangements, tariff-rate quotas (hereinafter, TRQs) and high most-favoured-nation (MFN) tariffs. Most sugar is imported under preferential trade agreements. The EU grants duty-free access to developing countries under the ‘Everything But Arms’ (EBA) facility for least developed countries (LDCs) and the ‘Economic Partnership Agreements’ (EPAs) with the African, Caribbean, and Pacific (ACP) countries. In the agricultural year 2015/2016, the EU imported a total of 2.96 million metric tonnes of sugar, around 60% of which originated in countries benefitting from EBA and/or EPAs. India and Brazil also benefit from enhanced market access through TRQs, which allow the import of a pre-determined amount of sugar under reduced or zero duty. With the expected increase in EU sugar production, the need for imports looks poised to decrease and may, over time, completely vanish. This will have potentially significant consequences for current suppliers of sugar to the EU. A number of small ACP-countries will be most affected, with Mauritius and Swaziland accounting for nearly half of the imports on the basis of the EBA/EPAs. Some ACP countries, such as Belize, which accounts for less than 10% of EU sugar imports on the basis of EBA/EPA, are already looking for alternative markets. However, with the EU likely to be joining the global sugar market as a net sugar exporter, competition will grow. The US Department of Agriculture (USDA) forecasts that EU sugar exports could double during this agricultural year and reach 2.2 million metric tonnes, with some analysts forecasting even stronger export figures. The EU notes that it had allocated additional funds to the affected developing countries, allowing them to “move up the value chain” and/or to “diversify away from sugar”.

At the same time, the prohibitively high import tariffs currently in place for cane sugar might negatively affect EU food and beverages manufacturers, and ultimately EU consumers, during times of sugar beet supply shortages. It also negatively affects sugar cane processors in the EU, who claim unfair treatment due to the stronger presence of sugar beet producers in the EU. Sugar cane processors in the UK are reportedly eagerly awaiting Brexit and the potential to newly regulate market access for sugar cane. UK sugar cane processors were indeed campaigning for Brexit, but the future regulatory and tariff framework in the UK post-Brexit remains largely uncertain and still unpredictable.

In the context of increased pressure to improve public health, any measure that were to facilitate market access for sugar cane and lead to a further decrease of sugar prices in the UK or the EU, would likely be met by fierce opposition from public health advocacy organisations. For instance, the removal of the production quota on isoglucose is already causing health-related concerns within the European Parliament. On 26 July 2017, a Member of the European Parliament (hereinafter, MEP), Mairead McGuinness of the European People’s Party group, raised the issue of isoglucose with the Commission by tabling a parliamentary question. The MEP noted that there were both positive and negative implications to abolishing sugar quotas and that some studies had shown that the abolition of quotas could cause the production of isoglucose to triple between 2016 and 2026. The MEP recalled that, according to the European Food Safety Authority (EFSA), “high fructose intakes (25% of total energy) induce dyslipidaemia, insulin resistance and increased visceral adiposity in healthy and in hyperinsulinaemic insulin-resistant subjects”. The MEP then asked if the Commission had evaluated the health implications of abolishing quotas and if the Commission planned to introduce labelling requirements in order to inform consumers of the presence of isoglucose in products.

On 1 September 2017, Vytenis Andriukaitis, European Commissioner for Health & Food Safety, answered on behalf of the Commission. Most importantly, he noted that a comprehensive review of the scientific evidence and policies on the consumption, energy intake and impact of high fructose syrups on overweight and obesity and health was funded by the European Parliament and that the results were expected by the end of 2017. He further noted that the Commission would continue to follow the issue and might discuss it again with EU Member State representatives in the High Level Group on Nutrition and Physical Activity. With respect to food labelling, Commissioner Andiukaitis noted that, in accordance with EU food labelling rules, it was mandatory to label all the ingredients of a food in the list of ingredients and that ingredients must be designated by their specific name, which means their legal name, or in the absence of this, with their customary name, or, if there is no customary name, a descriptive name of the ingredient. He noted that all types of sucrose, including isoglucose, may be labelled as ‘sugar’ in the ingredients list. Finally, he noted that, in order to inform consumers about the total content of sugars in foods, a nutrition declaration, including a declaration of the total sugars content, was mandatory on the majority of pre-packed foods since 13 December 2016. Public health concerns involving sugar consumption, including obesity, and the soon to be published study on high fructose syrups might cause further debate and lead to further regulatory initiatives by EU Institutions. For now, the Commission underlines the potential positive effects of growing isoglucose production for the EU’s economy and employment, as well as its own efforts to promote healthy eating habits.

While increased sugar production in the EU, with potentially decreased sugar prices, appear the probable consequences of the EU’s sugar quotas abolition, further and more specific consequences are yet to be determined. A regime in line with WTO trade rules is an important step, but EU sugar policy should arguably also take global sugar trade and imports into account in order to guarantee predictability and stability for all economic operators involved. Sugar producers, sugar processors and sugar users should closely monitor the developments related to sugar production, sugar exports, the EU’s sugar import regime and the developments surrounding isoglucose and inulin syrup.

Finland approves insects for food use – but not all insect-based food. Food safety authority to publish guidance

On 27 September 2017, the Finnish Ministry of Agriculture and Forestry announced that the cultivation and sale of insects as food is now permitted. In recent years, the interest in using insects as food has increased in Finland, among consumers and food manufacturers alike. However, according to the Ministry of Agriculture and Forestry, the use of insects as foodstuff was banned in Finland until now, due to the strict interpretation of EU law and guidelines. The Ministry of Agriculture and Forestry announced that it had now decided to interpret the relevant EU law and guidelines in the same way other EU Member States already do, so that insects can be cultivated and sold as food.

The Finnish Food Safety Authority Evira, which operates under the auspices of the Ministry of Agriculture and Forestry, welcomed the decision. The practice of using insects as food is relatively new to western countries, but people in Finland appear to be more interested in it than in other EU Member States. A survey carried out in 2016 by the University of Turku and the Natural Resources Institute found that 50% of respondents would buy insect-based food if it were available. One third of respondents had already tried eating insects in some form.

With its move to approve insects for food use, Finland appears to have closed a legal loophole just in time before new EU rules on novel foods enter into effect (see Trade Perspectives, Issue No. 3 of 13 February 2016). Regulation (EU) 2015/2283 of the European Parliament and of the Council of 25 November 2015 on novel foods, amending Regulation (EU) No. 1169/2011 of the European Parliament and of the Council and repealing Regulation (EC) No. 258/97 of the European Parliament and of the Council and Commission Regulation (EC) No. 1852/2001 (hereinafter, the new Novel Foods Regulation, or NFR) entered into force on 31 December 2015, but most of its provisions only apply from 1 January 2018 (for the history of the adoption of the NFR, see Trade Perspectives, Issue No. 3 of 6 February 2015 and Issue No. 11 of 29 May 2015). A transition is currently ongoing towards a new centralised authorisation procedure for novel foods. Implementing acts by the European Commission (hereinafter, Commission) under the NFR, laying down: 1) The administrative and scientific requirements for traditional foods from third countries; and 2) The administrative and scientific requirements for novel food applications, still need to be adopted. A draft Commission Implementing Regulation laying down administrative and scientific requirements concerning traditional foods from third countries in accordance with Regulation (EU) 2015/2283 of the European Parliament and of the Council on novel foods and a draft Commission Implementing Regulation laying down administrative and scientific requirements for novel food applications are currently debated in the REFIT (i.e., the Commission’s Regulatory Fitness and Performance programme) Platform, bringing together the Commission, national authorities and other stakeholders in regular meetings to improve existing EU legislation.

Insects and insect-based products are already widely consumed around the world, and to a certain extent, in the EU, as well. However, in the EU, the consumption of insects is still considered something ‘novel’. Novel foods are foods that have not been consumed to any significant degree by humans in the EU before May 1997, when the first novel foods Regulation (EC) No. 258/97 entered into force. In principle, in order to be able to commercialise novel insect foods in the EU, producers need to gain pre-market approval (i.e., be declared safe for consumption). This is achieved via the submission of a detailed dossier and the carrying out of a risk assessment of the product. This is why the NFR is so relevant. Parts of insects (such as legs, wings, head, etc.) were already included in the EU definition of novel food as food ingredients isolated from animals, while whole insects arguably were not (see Trade Perspectives, Issue No. 3 of 6 February 2015). The NFR clarifies that whole animals, such as whole insects, if not consumed in the EU to a significant degree by humans prior to 15 May 1997, fall under the definition of novel food. While awaiting the entry into effect of the NFR, trade in some edible insects is tolerated in certain EU Member States, including Belgium and Austria. This does, however, not apply to ingredients that were isolated or extracted from insects, such as protein isolates. The UK Food Standards Agency (FSA) has carried out a public consultation, which concluded in September 2015 and that asked UK food businesses selling edible insects to submit relevant information regarding the history of human consumption of insects prior to 15 May 1997 (see Trade Perspectives, Issue No. 18 of 9 October 2015).

Article 35(2) of the NFR (on transitional measures) provides that foods not falling within the scope of Regulation (EC) No. 258/97, which are lawfully placed on the market by 1 January 2018 and which fall within the scope of the NFR (e.g., whole insects), may continue to be placed on the market until a decision is taken (following an application for authorisation of a novel food or a notification of a traditional food from a third country submitted by the date specified in the implementing rules to be adopted by 1 January 2018, but no later than 2 January 2020).

It appears that the new Finnish interpretation is based on this transitional provision. Finland has made a reinterpretation of the NFR regarding whole insects. The Finnish Food Safety Authority Evira is currently drafting guidelines for the food industry concerning the farming, sales and preparation of insects for consumption. The guidelines, expected for November 2017, are being prepared in consultation with the insect food industry and are intended for use by the food control authorities, insect farmers and companies producing food from insects. According to Evira, Finland will only allow the use of farmed whole insects. Which insect species will be permitted has not been revealed yet. In comparison with other EU Member States, Belgium permits ten insect species (the safety of which has been evaluated in a common opinion of the Scientific Committee of the Belgian Food Safety Authority, FASFC and the Superior Health Council of 30 September 2014 on food safety of insects intended for human consumption) and Austria also ten (according to guidelines of the Federal Ministry for Health and Women’s Affairs, the “Leitlinie für gezüchtete Insekten als Lebensmittel” of 15 February 2017).

While, whole insects may be crushed, ground or dried, according to Evira no parts (such as wings, legs or head) may be removed, isolated or used for extraction (e.g., fat or protein fractions). Once the guidelines are completed, insect farmers may register as food business operators whose activities are governed by food legislation and controlled by the authorities. Insect products so produced may be marketed as foodstuffs. Currently, insect products are marketed in Finland as “decorative kitchen items”. These products may not be sold as food because the production is not controlled in compliance with food legislation and it has not been possible to verify the safety of the products accordingly. Insect farmers, manufacturers of insect products, and sellers are responsible for ensuring that the foodstuffs produced and marketed by them are safe for consumers. For example, steps need to be taken to ensure a high standard of hygiene and correct and sufficient labelling. It is also advisable to take into account that insect proteins may cause allergic reactions. The last point made by Evira addresses the important issue that, for example, persons suffering from allergies to crustaceans and shellfish, and/or dust mite, may have an allergic reaction to the consumption of insects.

The registration and approval requirements of insect food businesses referred to by Evira appears to stem from EU food hygiene rules on animal products (i.e., Article 4 of Regulation (EC) No 853/2004 of the European Parliament and of the Council of 29 April 2004 laying down specific hygiene rules for food of animal origin). For non-animal products, establishments need not to be approved. A FAQ document published by Evira addresses, inter alia, the interesting question of whether the exportation of insects to countries outside of the EU, for use as food, is allowed. Evira states that the exportation of insects for use as food is not possible until the national guidelines for the production and marketing of insects, and for the registration of insect producers, are available and complied with. The food import requirements in force in the destination country must also always be verified prior to exportation.

The developments in Finland of “lifting the ban” of marketing whole insects as food is an important step for manufacturers of insect food based in Finland. The impact in other EU Member States that did not expressly permit whole insects (different from Belgium or Austria) needs to be further evaluated. Do Finnish insect foods benefit from the free movement of goods within the EU? It is very important to note that insects not belonging to the specific species (yet to be determined by the Finnish authorities), food ingredients isolated from insects, such as protein isolates, and insects or products based on insects from third countries, are not covered by the Finnish permission.

Questions related to insects and insect-based products are increasingly addressed by EU Member States. Authoritative guidance in the EU on how to interpret the rules on novel foods is still missing. With respect to the authorisation of novel foods, the NFR provides two main novelties: a new centralised procedure and an additional notification procedure for traditional foods from third countries. Implementing acts will soon be adopted by the European Commission under the NFR, laying down administrative and scientific requirements for traditional foods from third countries; and administrative and scientific requirements for novel food applications.

The next steps taken in the EU and its Member States on insect foods should be monitored and stakeholders should be prepared to participate in shaping upcoming science-based and non-discriminatory guidelines by interacting with the relevant EU Institutions, trade associations and other affected parties.

Towards the regulation of voluntary precautionary allergen labelling in the EU?

For many years, EU legislation has required that food manufacturers declare the use of major allergenic foods and ingredients on their product labels. However, allergenic substances may also be inadvertently present in food products, due to cross-contamination during transport, storage or processing. Regulation (EU) No. 1169/2011 of the European Parliament and of the Council on the provision of food information to consumers (hereinafter, the FIR) sets out rules relating to ingredients that can cause food allergies and/or intolerances. In particular, the presentation of allergens in the list of ingredients of prepacked foods has been harmonised and mandatory allergen information for non-prepacked food has been introduced. However, EU legislation does not yet establish specific requirements for the so-called ‘precautionary’ allergen labelling (hereinafter, PAL), which is increasingly used on pre-packaged foods by statements like ‘may contain...’ or ‘produced in a factory which uses...’ or ‘produced on shared equipment…’. Europe’s food and drink producers, therefore, have recently called on the European Commission (hereinafter, Commission) to define EU-wide standards on PAL, arguing that it was a much-needed step towards completing the single market.

When used in the production of foods and still present therein, certain ingredients or other substances or products can trigger allergies or intolerances in some people, and some of those allergies or intolerances may constitute a danger to their health. Information on the presence of such substances or products with a scientifically proven allergenic or intolerance effect must be provided in order to enable consumers, particularly those suffering from a food allergy or intolerance, to make informed choices that are safe for them and their health. The first harmonised EU rules on the labelling of food allergens were established by Directive 2003/89/EC of the European Parliament and of the Council as regards indication of the ingredients present in foodstuffs, which introduced Annex IIIa to the FIR’s predecessor, Directive 2000/13/EC on the labelling and presentation of foods. The new rules entered into effect in 2005 (for more details, see Trade Perspectives, Issue No. 1 of 9 January 2015).

Further to the intended presence of ingredients that are allergens, the realities of food production cannot avoid the unintended presence of allergens, which can pose a risk to susceptible people. Precautionary and voluntary allergen labelling has evolved as a tool for food manufacturers to communicate to consumers that allergens could be present as a result of unintended allergen presence. However, food manufacturers, control authorities and regulators know that the allergen is not always present in the finished product, nor is it necessarily present at a consistent level throughout the production batch, production run or even in the single product. In some EU Member States, regulatory agencies (e.g., the UK Food Standards Agency; the Danish Veterinary and Food Administration) have advised businesses that precautionary allergen labelling should only be applied following a thorough risk assessment rather than being used as an automatic default position.

There is currently no specific EU legislation, which determines when precautionary allergen labelling should be applied. In general, food safety in the EU is regulated by Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002 laying down the general principles and requirements of food law (General Food Law Regulation, or GFL). Article 14 of the GFL provides that food must not be placed on the market if it is ‘injurious to health’. In determining whether any food is injurious to health, according to Article 14(4)(c) of the GFL, regard shall be had, inter alia, to the particular health sensitivities of a specific category of consumers. However, the amount of an allergen that is considered to be injurious to health is an area of uncertainty and inconsistency, due to the lack of consensus on agreed reference doses on which actions can be based to drive labelling decisions.

Article 36 of the FIR sets out a framework, which can be used to implement a comprehensive, consistent and science-based approach to PAL. According to Article 36(2)(c) of the FIR, the Commission has the option to introduce by an implementing act new rules on the following voluntary information: “information on the possible and unintentional presence in food of substances or products causing allergies or intolerances”. Such implementing act must be adopted in accordance with the examination procedure referred to in Article 48(2) of the FIR. As a general rule, Article 36(2) of the FIR provides that food information provided on a voluntary basis must meet the following requirements: (1) It must not mislead the consumer; (2) It must not be ambiguous or confusing for the consumer; and (3) It must, where appropriate, be based on the relevant scientific data.

It is important to note that the application of precautionary allergen labelling should only be made after a thorough risk assessment has been performed and it is considered that there is a real risk to the food-allergic or food-intolerant consumer. The use of precautionary allergen labelling, when there is not a real risk, could be considered to be misleading. Reportedly, there is evidence demonstrating that there is limited or no correlation between such warnings and the actual risks. Many products with zero or negligible risk carry warnings, and products without warnings sometimes contain high levels of allergens.

The EU currently has no harmonised quantitative criteria or benchmarks for precautionary allergen labelling in foods or drinks, meaning that EU Member States are free to carry out their own risk assessments and set their own benchmarks for risk levels that must be labelled. The head of analytical testing at UK retailer Sainsbury’s, in particular, has called for agreement on threshold limits for the presence of allergens in food and beverages to provide reassurance to food manufacturers, retailers and, most importantly, consumers about the risk of allergic reactions. According to a 2016 ‘non-paper’ by FoodDrinkEurope, the trade association representing Europe’s food and drinks producers, entitled “Precautionary Allergen Labelling (PAL): a science-based approach based on Quantitative Risk Assessment”, there is mounting evidence that PAL is increasingly losing credibility among stakeholders, including critically those for whom it is primarily intended (i.e., allergic consumers).

In its summary recommendations on PAL, FoodDrinkEurope calls for a defined framework for the application of PAL, which meets the requirements of Article 36(2) of the FIR. It should be clear (i.e., a single statement with a single meaning, easy to translate into EU languages, i.e., “may contain [allergen]”); and not misleading (i.e., precautionary allergen labelling should only be applied where a defined, appreciable risk has been identified through a quantitative risk assessment). FoodDrinkEurope further requests that the framework be based on relevant scientific data and that the “Voluntary Incidental Trace Allergen Labelling (VITAL®) system” be identified as the most fully elaborated system, since it has been subjected to extensive peer review and it has also been recognised by several European national authorities. It should further be applicable in practice, taking into account that analytical methods have limitations with regard to sensitivity and accuracy, and that quantitative benchmarks (i.e., reference doses) require the development of capable protocols and methodologies. In addition, consumers need to be informed, using multiple channels of communication, such as websites, customer care lines, etc. (i.e., not just through labelling), that products have been through a risk assessment and that the presence or absence of PAL is a consequence of that process.

Interested parties should closely monitor any developments and potentially upcoming initiatives in the EU on PAL in order to ensure that their legitimate interests are duly taken into account and safeguarded. Stakeholders should be prepared to participate in shaping potentially future EU legislation by interacting with relevant EU Institutions, trade associations and other affected stakeholders.