On 22^nd May, the European Commission published a draft implementing regulation on “notifications to the Commission of information and documents” in order to improve market transparency in the food supply chain.

Specifically, this proposal aims to provide greater transparency on pricing information at a processor and retailer level, these being considered the “black box” of the agri-food supply chain. It also aims to improve the timeliness and accuracy of the data supplied by the existing European Market Observatories.

The proposals for the dairy sector include:

• Notification of weekly selling prices: Currently dairy processors are required to notify the Commission of the selling price of whey, SMP, WMP, butter and commodity cheeses. Under the proposal the prices of cream, drinking milk and fat filled powder will also be required.  Mozzarella prices will now too be required as part of commodity cheeses.
• Notification of weekly buying prices: Representative retailers and other representative food business operators will be required to notify the Commission of the buying prices for butter and commodity cheeses.
• Notification of monthly raw milk prices: Processors will now need to notify the Commission of the price of organic raw milk, in addition to the current notification of standard raw milk prices. A new tighter deadline has also been set for the 15^th of each month in respect to the preceding month supply. (Currently the deadline is for the end of the month.)
• Notification of milk quantity and content: The proposal includes a new requirement for processors to notify the Commission of the quantity of organic milk produced (in addition to the existing requirements on total milk quantity produced) as well as the fat content and the protein content of raw milk as a percentage of the product weight. This is also now required to be reported by the 15^th of each month for the preceding month’s supply, while previously the deadline was for the 25^th of the month.
• Notification of Fat Filled Powder production: There is a new requirement for dairy processors to notify the Commission of the quantity of fat-filled powder produced, expressed in tonnes, by the 15^th of each month for the preceding month’s production.
• Method: This additional information will be made available by operators to the Commission via Member States authorities or directly (under the supervision of Member States) through an online system. It will be made available to the public through the existing EU Market Observatories. Member States can choose the most cost-effective approach for gathering this information and can choose to collect solely representative data as a means to alleviating the administrative burden on SME businesses. 

ICOS made a contribution to the Commission public consultation on the initiative, which can be found in full here: [Link to Submission on ICOS Website]

Our key messages are:

• ICOS supports the drive towards greater market transparency and improving the timeliness and reliability of the data supplied by the European Market Observatories.
• However, the new tighter deadlines for the reporting of raw milk prices by the 15th of each month in respect to the preceding month will be impossible to fulfil due to the democratic price setting structures within Irish dairy cooperatives.  Therefore, flexibility is needed with regard to this deadline, in order to ensure that price reporting is possible and representative.
• There is also a concern about the comparability of the data on selling and buying prices due to the wide range of production systems, processing methods, product and quality variations and multiple market streams across the EU food supply chain. In order to address the issue of reliability and accuracy, it is necessary to standardise data across Member States with regard to the definitions, collection methods and use of representative products. This will make the data more comparable and improve the accuracy of EU level aggerated data.
• There is a concern that the new requirement for price reporting regarding fresh products in the dairy sector could negatively impact processors vis a vis their negotiations with retailers. This is particularly relevant with regard to the price differences between branded drinking milk and private label drinking milk, which could lead to downward pressure on branded milk prices.

Alison Graham – European Affairs Executive