IMACE Vision Statement CAP Reform

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agricultural-machine-1918989 (2)IMACE welcomes the opportunity to provide input into the CAP and support the route towards more sustainable living.

Sourcing large amounts of European vegetable oil, IMACE has a strong interest in a competitive, economically viable and healthy agricultural sector. IMACE welcomes that European Commissioner for Agriculture Phil Hogan suggested that he is open to real reform (Livingstone, 2017), and is focussing on cutting bureaucracy, protecting the environment, and ensuring farmers are not left at the mercy of volatile markets. A focus on competitive markets, sustainable production and healthy living should go hand in hand throughout the entire reform process.

Competitive markets

Our members are facing direct competition from the butter industry. The sector’s 2016 difficulties highlight its dependency on public support. IMACE is particularly concerned regarding trade and market distorting measures still present in the CAP. The World Trade Organization is clear on this: all domestic support measures considered to distort production and trade fall into the Amber Box[1] and must be reduced.

Direct dairy support and milk price intervention measures stimulate adverse risk taking and unfair risk pricing. Risk assessment and pricing should be left to specialised players and market instruments. IMACE’s members bear the full cost of operating risk. The proposed interventions cannot be seen as an isolated intervention without further repercussions throughout the business cycle. They cannot be explained simply as crisis support. The proposed interventions reward farmers that ignore market risk during “good times.”

Note that the European Court of Auditors (CoA) is highly critical towards the CAP measures in support of farmers’ incomes (European Court of Auditors, 2016). It finds the impact of the €270bn farm subsidies impossible to measure. The CoA mentions “vague objectives”, absence of representative data on the disposable income of farm households, no reliable system for comparing agricultural incomes with other sectors, and when data is available, neither the Commission nor Member States assure it is of appropriate quality.

IMACE supports the role of the CAP in an expanding world market. To remain competitive, the CAP reform should lead to greater simplification with fewer market management tools. IMACE members source large amounts of healthy European vegetable oils, thus contributing to farmers’ income. IMACE considers a productive farming system and an efficient market to be the best way towards a sustainable income for the European farmers.


The revised CAP should support innovation and allow farmers to adjust to evolving trends and scientific knowledge. In particular, it should support farmers to respond to health and environmental considerations.


Currently, there is a contrast between dietary targets and CAP budget (Figure 1). The CAP should allow for and incentivise innovation towards meeting the dietary targets. Notably, public bodies increasingly recognise the need to shift from saturated fatty acids to unsaturated fatty acids. (EFSA, 2004; Health Council of the Netherlands, 2015; Healthy Ireland, 2016; Hoge Gezondheidsraad van België, 2016; Public Health England, Food Standards Scotland, & Food Standards Agency, 2016; WHO, 2015).

Figure 1: Contrast between dietary targets and CAP budget. Source: Pushkarev (2015).
 Agri Support vs health recomm


Agricultural land occupation to produce margarines and raw materials for margarines is about half of that to produce butter, and carbon footprint of margarine production is about one third (Nilsson et al., 2010). Yet, the EU agricultural output is significantly biased towards dairy  (EP, 2016). Taking into account environmental considerations means rethinking diets (Springmann et al., 2016; Tilman & Clark, 2014; Westhoek et al.,, 2016) and adjusting agricultural production accordingly. As the European Commission – Standing Committee on Agricultural Research (SCAR) already concluded: “The promotion of a healthy diet also reduces the environmental footprint of food consumption in Europe and globally” (Freibauer et al., 2011).

Closing remarks

The current evaluation must dare to ask the difficult questions. Is the European farm system with its reliance on small farming (EP, 2016) equipped to face the environmental and social challenges of the future? Market, environmental, and health considerations should go hand in hand. Only as such can we build a competitive, economically viable and healthy agricultural sector equipped for the future.


[1] Amber box: In WTO terminology, subsidies in general are identified by “boxes” which are given the colours of traffic lights: green (permitted), amber (slow down, i.e. be reduced), red (forbidden) (WTO, 2002).




EFSA. (2004). Opinion of the Scientific Panel on Dietetic products, nutrition and allergies [NDA] related to the presence of trans fatty acids in foods and the effect on human health of the consumption of trans fatty acids. EFSA Journal, 2(8), n/a-n/a.

  1. (2016, July). At a glance: Agriculture in the European Union and United States. European Parliament.

European Court of Auditors. (2016). Special Report: Is the Commission’s system for performance measurement in relation to farmers’ incomes well designed and based on sound data? Luxembourg: Publication Office of the European Union. Retrieved from

Freibauer, A., Mathijs, E., Brunori, G., Damianova, Z., Faroult, E., Gomis, J. G., … Treyer, S. (2011). Sustainable food consumption and production in a resource-constrained world. The 3rd SCAR (European Commission–Standing Committee on Agricultural Research) Foresight Exercise. Retrieved from

Health Council of the Netherlands. (2015). Dutch Dietary Guidelines 2015. Health Council of the Netherlands. Retrieved from

Healthy Ireland. (2016, December 6). Healthy Food for Life: The Food Pyramid guide to every day food choices for adults, teenagers and children aged five and over. Irish Minister of State for Health Promotion. Retrieved from

Hoge Gezondheidsraad van België. (2016, September). Voedingsaanbevelingen voor België – 2016 (HGR Nr. 9286). Hoge Gezondheidsraad. Retrieved from

Livingstone, E. (2017, February 2). Hogan floats major structural shake-up of CAP. Politico Pro, (Agriculture and Food).

Nilsson, K., Flysjö, A., Davis, J., Sim, S., Unger, N., & Bell, S. (2010). Comparative life cycle assessment of margarine and butter consumed in the UK, Germany and France. The International Journal of Life Cycle Assessment, 15(9), 916–926.

Public Health England, Food Standards Scotland, & Food Standards Agency. (2016). The Eatwell Guide: Helping you eat a healthy, balanced diet. UK. Retrieved from

Pushkarev, N. (2015). A CAP for Healthy LivingMainstreaming Health into the EU Common Agricultural PolicyEuropean Public Health Alliance (EPHA), 2015. AIMS Public Health, 2(4), 844–886.

Springmann, M., Godfray, H. C. J., Rayner, M., & Scarborough, P. (2016). Analysis and valuation of the health and climate change cobenefits of dietary change. Proceedings of the National Academy of Sciences, 201523119.

Tilman, D., & Clark, M. (2014). Global diets link environmental sustainability and human health. Nature, 515(7528), 518–522.

Westhoek, H., Ingram, J., van Berkum, S., Özay, L., & Hajer, M. (2016). Food Systems and Natural Resources. (UNEP, Ed.). New York, USA: UNEP. Retrieved from

WHO. (2015, September). Fact scheet N°394: Healthy diet. Retrieved 15 September 2016, from

WTO. (2002, October 1). Domestic support in agriculture: The boxes. Retrieved 13 February 2017, from


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