REPORT OF THE ADVISORY GROUP MEETING ON BEEKEEPING 18 NOVEMBER 2009

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1 REPORT OF THE ADVISORY GROUP MEETING ON BEEKEEPING 18 NOVEMBER 2009 CHAIRMAN: Mr. Kari Koivulehto Observers participate: from the European Medicines Agency (EMEA) and representatives of Tuscany authorities region by has Chairman. 1. ELECTION OF THE CHAIRMAN AND TWO VICE-CHAIRMEN (TERM ) Prior to the election of the new President and Vice Presidents, the work of the former president Mr Kari Valonen (Copa-Cogeca) was honoured by the Commission and the sector was invited to a constructive cooperation for the new period. Election of the new Chairman: Mr. Kari Koivulehto from FEEDM (European Federation of Honey Packers and Distributors) Vice President Adopted Mr. Rolf Tuchel from CELCAA (European Liaison Committee for the Agricultural and Agri-Food Trade) /FRUCOM (European Federation of the trade in Dried fruit, Edible nut, Processed fruit and vegetable, processed fishery products, Spices, Honey and Similar Foodstuff) Second Vice-president: the candidate of Copa-Cogeca not elected Mr Manuel Izquierdo (COPA-COGECA) could not be elected as Vice President at the meeting as his candidature had not been communicated to Commission services in due time (pending finalisation of internal procedure in Copa-Cogeca). The election of Mr. Izquierdo will be possible at the next meeting. Implementation rules concerning the good functioning of the group: After the chairman and vice chairman election, the Commission representative congratulation for has election concerning the two years terms and stresses the need to receive in the future clear concrete proposals of agenda items. In particular concerning the strategic agenda has to submit before the next meeting a draft covering at least the period of his mandate tow years, in which the essential subjects which concern the sector will be indicated. Tasks to do: preparation by the Chairman, as a result of the consultation with the other sectors organisations The Commission representative called upon the participants in the Standing Group to develop exchanges of views at the next meetings by providing their own written analyses with a view to improving the quality of the consultation, which could then be conducted closely. This was an issue for the mandate over the next two years and following years. In this connection, all the trade organisations within the said Group should decide on and make known in advance the subjects of interest to them so that these could be selected for the future, in order to be able to create strategic agendas in mutual agreement with the competent Commission departments. The Commission representative also asked the new Chairman to ensure that the final versions of the minutes of meetings were circulated to the members within a maximum of two to three weeks. 2. APPAPPROVAL OF THE AGENDA AND THE REPORT OF THE LAST MEETING OF THE ADVISORY GROUP OF 18 NOVEMBER 2008 DRAFTED BY THE CHAIRMAN.

2 Agenda as well as the report were adopted 3. POSSIBLY PRESENTATION OF THE STRATEGIC AGENDA ON THE GROUP BY THE CHAIRMAN. As a basis, the producers proposed its document which outlines a strategic plan for EU beekeeping. Other issues that might be set in the strategic agenda: - Interaction of agricultural practices with beekeeping, e.g. impact of intensive agriculture on beekeeping, impact of GMO s on beekeeping activity and on honey market - Role of small-scale hobby beekeepers (e.g. difficulties to meet increasing requirements) - Sanitary and veterinary questions, e.g. risk of residues in honey due to environmental contamination A draft of the strategic agenda will be prepared for the next meeting for discussion and approval by the group. VETERINARY QUESTIONS: 4. INFORMATION BY THE COMMISSION ON THE STATE OF PLAY: (DG SANCO, DG ENV and representatives of the Tuscany region) a ) Concerning the important problems on the losses of colonies. I suppose this Tuscany speaking :it should be clear Tuscany region) The Advisory group has already discussed the matter at several meetings. APENET RESEARCH PROGRAMME (see the summary paper and presentation available on CIRCA) The Italian Ministry of Agriculture together with the Region of Tuscany and of other Regions financed a research programme, denominated APENET, in order to monitor the health conditions in the apiaries of the Region of Tuscany and to investigate the possible causes of honeybee and colony losses, described by the chairman of Tuscany region as a phenomenon which threatens agriculture and the whole humanity. The project is not finalised yet the sampling should be finished in few months before final report could be prepared. The project involves a network which integrates university researchers, regional agencies and beekeepers associations. First Results: There would be a link between pesticide treated seeds and bees mortality. The pesticide causing this mortality would be from the neonicotinoïdes family. Actually, following the ban of neonicotinoïdes in Italy, less bees mortality has been observed. Recommendations from the APENET programme: - The ban of neonicotinoïdes should continue in Italy and be extended to the whole EU.

3 - Better labelling of insecticide-treated (coating) seeds: the risk that these substances trigger bees mortality should be more clearly indicated. In addition, a symbol indicating that this substance is hazardous should also be set on the packaging. - Other areas would be further developed in Tuscany region: complementary and alternative bee medicines, quality of honey, monitor environment pollution by pesticides, social implications of beekeeping etc. b ) Animal Health Strategy- consultation on the new legislation. The Commission representative indicate on 27 November 2009, the first inter-service meeting amongst different DG s will be held. The main discussion will focus on EFSA report regarding Bee Mortality and Bee Surveillance in Europe. The report is due to be published by the end of There is a need for a better co-ordination and harmonisation of the methods to monitor bee mortality Stakeholders might be invited in the future to these meetings as guest speakers. The Commission representative provided information on the General consultation on possible approaches for the new Animal Health Law. Further information on this consultation may be found at the following link: A questionnaire for stakeholders is available at the following link: However, the deadline to participate in the consultation was on 31 December Based on the extensive discussions of the Steering group for the creation of the new EU Animal Health Law, which held its meetings during spring 2009, Commission developed a questionnaire for wide stakeholders consultation, focussing the issues raised by the group into two main items being: 1) Prevention involving different stakeholders (on-farm bio security) 2) Simplification of the curent rules The Commission is expected to submit a proposal to the European Parliament and the Council by end of Political discussion would then follow in early The producers representative referete he context of the new EU animal health strategy See the related power point presentation available on CIRCA The producers' spokesperson highlighted the following issues: The goal of veterinary measures dealing with existing diseases should be to control rather than to eradicate. There is a lack of veterinarians skilled in bee health and lack of veterinary medicines availability for bees Varroa mite is the major pathology and for most treatments a veterinary prescription is required which further complicates their use.

4 Further studies should be carried out on the matter e.g. on the impact of pesticides on bees resistance to varroa Bacterial diseases: currently beekeepers usually do not notify symptoms to avoid the destruction of their colonies. Common EU control strategy should be set out and assistance provided to beekeepers affected. Impact of pesticides on bees should be further studied and tests of active substances on bees enhanced. New parasites and predators: Vespa velutina It is very quickly spreading and difficult to be monitored Other speakers from producers delegation added the following concerns: Impact of the changes of agricultural policy (types of crops, methods) on beekeeping should be taken into account as beekeepers cannot control their production environment; beekeeping should not be treated as an isolated production sector taking into account bee specificities; honeybee might serve as a valuable indicator for agricultural policies Problems associated with an increase in queen sterility Need for a specific Community veterinary approach for bees with the possibility for emergency actions As many times discussed at the Advisory Group meetings, antibiotic residues limits should be established for honey. This could give access to beekeepers to more authorized medicines The Commission representative comments: EU Animal health law consultation should be used to present views on specificities of beekeeping. The law will look at providing more flexibility. There could be different approaches for different diseases. For example bluetongue disease (affecting ruminants) will be dealt with the goal of disease control and prevention rather than eradication. The chairman) conclusions: He request to the Commission to organise two meetings of the Advisory group per year. He welcomed the creation of the Commission inter-service group which should improve the co-operation and suggested that the major stakeholders should have 1-2 observers to these meetings. 5. ALKALOIDS' IN HONEY - EXCHANGE OF VIEWS Alkaloids are a group of naturally occurring toxins that are found in a number of plant species. In the comments submitted by Member States to the Commission, it was considered that there was no need to take any actions on the matter. There seems to be no updated information since the EFSA report made in 2007 with relation to animal feed (honey has been mentioned too) Further studies are now

5 available. However, further data would be needed for honey and the EU Commission should perform a new study on the issue, It would also be necessary to determine how the honey industry should tackle this problem and how to prevent an eventual food crisis on the matter. German labs may already perform the analyses. Copa-Cogeca spokesperson said that it was a potential new problem which required a rapid investigation at the EU level as all operators in honey supply chain needed clarity from the scientific point of view. Any action should be based on scientific risk assessment. 6. INFORMATION BY THE COMMISSION CONCERNING REGULATION 470/2009, REGARDING THE MAXIMUM RESIDUE LIMITS (MRL) RESIDUES OF PHARMACOLOGICAL SUBSTANCES (DG.ENTR.) The Commission representative comments: According to Directive 2001/82, medicines may be authorised in food production only if assessed as safe. The new Regulation setting residue limits of medicines in foodstuffs of animal origin, Regulation (EC) 470/2009, introduces the following interesting changes for the beekeeping sector: Article 6: The scientific risk assessment of substances used in medicines may take into account monitoring data and exposure data when the metabolism and depletion of the substance can not be assessed. Article 9. (1): Interested party or organisation may submit to EMEA a request for an opinion on maximum residue limits for minor species or minor uses. Article 27: Extrapolation: For any substance for which a maximum residue limit has been established, the Commission or a Member State may also submit to the EMEA a request for an opinion on extrapolation to other species or tissues Taking over MRL s set up by Codex Alimentarius globally unless there is an opposition from Member States. This would be without further assessment by EMEA. The EMEA representative comments: The difficulties regarding the setting of MRLs for honey have been discussed since a long time in the EMEA scientific committee (CVMP). In accordance with the EU legal framework the EMEA is responsible for recommending the establishment of MRLs for substances intended for use in veterinary medicinal products (and, since implementation of the new MRL Regulation, for biocides for use in animal husbandry). The EMEA does not have competence on the establishment of MRLs for pesticides nor for the establishment of Reference Points for Action for control purposes. The EMEA and its scientific committee make recommendations for the establishment of MRLs only following the evaluation of data submitted with the request. It is then up to the EU Commission to take the legislative measures to make the recommended MRLs legally binding in all EU Member States. The Commission being the decision body may disagree with the recommendation from the EMEA and therefore not adopt the legislative measures. The EMEA can only make a recommendation for the establishment of MRLs following a request and evaluation of specific data. It is recognised that bees represent a specific case where conventional residue data may not be available. However, data allowing the

6 assessment of residues in honey following intended treatment should be made available. The new MRL Regulation foresees that in case metabolism and residue data cannot be assessed, monitoring and residue data can be taken into account. It has been acknowledged that there are difficulties in relation to generating the required data due to the lack of interest from commercial companies, but there have already been examples of data generated following co-operation between authorities, public institutions (universities) and beekeepers. The EMEA and its scientific committee are keen to contribute to the discussion on options for generating data as well as giving advice on data requirements. It is however essential to identify the critical situations/diseases and which substances without MRLs are considered essential for the treatment of these diseases. For that purpose the EMEA would like to receive concrete proposals from beekeeping experts. The new MRL Regulation foresees that Interested Parties or organisations can submit a request to the EMEA for the establishment of MRLs for substances intended for use under Article 11 of Directive 2001/82/EC (cascade) in case of use in minor species and minor uses. Bees are considered to be a minor species. Representatives from EU associations recognised as CVMP Interested Parties (i.e FEEDM; COPA-COGECA, HIPA), can request to meet the Committee (once a year) in order to address issues of common interest in a specific session (1 hour). Willing to help the sector, EMEA will organise a workshop to discuss and find solutions to the current situation with the availability of medicines for bees on December 2009 at the EMEA in London. The agenda of that meeting can be found at the following link: Stakeholders comments: Recently, producers and industry together have already proposed values for some residues (e.g. tetracycline) in order to set MRL. However, no progress has been made since. The different Commission DG s involved in the matter as well as EMEA should better co-operate. The type of data to be submitted and the procedure with regard to regulation (EC) 470/2009 (MRLs, reference points for action) should be clarified. EMEA will only be able to make its risk assessment once data will be provided. As they are no medicines authorised in the EU, data could be collected in laboratories checking imported honey. Another way to follow would be to take into account data available at international level (Codex Alimentarius). The zero tolerance of antibiotics is unacceptable and leads to a huge legal insecurity of all EU market operators. The honey sector wants to maintain the image of honey as a natural product. So, the limits requested by the industry and beekeepers are very low. In addition, the honey sector refuses preventive use of medicines. The industry representative suggested that data existed for products already having MRLs (and not authorised in bees) and these might be used to set the MRLs for honey by extrapolation (cascade). The Commission representative indicated the trying to make some progress on the availability of medicines for small sectors (e.g. aquaculture. Setting reference points for action (RPA) is the competence of DG SANCO. It was emphasised that RPAs are not the same as MRLs. It was pointed out no MRLs can be

7 established without appropriate data. To his opinion the sercvices of the Commission are cooperating well. The EMEA representative confirmed that there are no antibiotic medicines approved for bees in the EU. The EU accepted automatically values from Codex Alimentarius. If there are any products authorised and in use in 3rd countries, stakeholders request EMEA to approve MRLs for them. RPAs were in principal intended for control of illegally used substances such as chloramphenicol. The Commission s suggestion: The point should be discussed in DG SANCO Advisory group or all stakeholders involved should organise a separate meeting in order to discuss the setting of MRLs for medicines for honey. At that meeting, the competent officials on honey from different Commission s DG s would be invited. EU PRODUCTION AND MARKET ISSUES: 7. INFORMATION BY THE COMMISSION ON THE STATE OF PLAY OF THE 4TH REPORT TO THE EUROPEAN PARLIAMENT AND THE COUNCIL CONCERNING THE IMPLEMENTATION OF THE TRI-ANNUAL PROGRAMS (REG 1234/2007), FOLLOWED BY AN EXCHANGE OF VIEWS. The Commission provided a presentation (see below) the use of Community budget has improved in 2009 to reach some 88%. However, some Member States still show an important underuse (e.g. Portugal). The EU Commission has to provide a report on the implementation of the 4th triennial programme of EU support for beekeeping to European Council & European Parliament by mid EU Member states were asked to submit comments for the report on 27 November 2009 at the latest. EU Commission has received a detailed contribution from producers which asked for concrete improvements in this important Community tool for beekeeping. Member States have to present their future program for next three years programming period on 15 April 2010 at the latest. It has been suggested that the next Advisory group on beekeeping would be organized during the first half of 2010 in order to present the report and its recommendations, as well as summary of programmes submitted by Member States.

8 8. EXCHANGE OF VIEWS ON THE COMMUNITY MARKET SITUATION AND MARKET MANAGEMENT OF HONEY AND THE WORLD MARKET SITUATION, IN PARTICULAR: IMPORTS/EXPORTS. 9. The Commission representative provided a presentation on the market situation (available on CIRCA). Comments from Stakeholders: On the world market, there are factors that will manifest increasingly in future, e.g. climate change, extension of GMO crops. A good example of this would be the production decrease in South America where the climatic change has triggered prolonged droughts in Argentine (honey production reduced by half) and where monoculture farming reduces honey production this being combined with pesticides use in zones where beekeeping was taking place. Profitability of the whole industry would be more instable in future. Concerns expressed regarding the increase of the honey exports from China and triangular trade with it. The very low prices of the honey exported from the EU to Morocco could be justified by the fact that the exported product is of very poor quality. Need to have more data and request to receive again trade and market data by individual Member States as previously provided, in particular regarding the imports from China and Argentina. The Commission reaction: As already mentioned in a letter from the Commission, in the case of suspicions regarding the quality of Chinese products, producers should report them to their national authorities. Member States are responsible to verify the composition of honey and to not allow its marketing if it does not fulfil the requirements set in the EU legislation. The Commission already mentioned this matter in a letter. This had been informed by the Commission in a letter already. Proofs were badly needed to take action. A proportion of honey from Argentina was not authorised to enter the EU market. EU agricultural policy had no direct effect on agricultural development in Argentina. Official statistical source EUROSTAT was not best suited for data on beekeeping due to the specificity of the sector compared to other food producing animals (e.g. lack of slaughtering). 10. LABELING OF HONEY The industry representative asked if labelling of a blended honey from two monofloral honeys required a list of ingredients (QUID). E.g. Does a blend ACACIA/LIME Honey requires the percentage of ACACIA and LIME?

9 As honey is not a compound food, like water or wine, the industry finds that a list of ingredients on honey is rather irritating than helpful. The Commission representative replied that the Commission services have clarified the situation in a letter recently providing an interpretation of the respective Regulation (EC) 2000/13. The labelling of floral origin (all ingredients) composing a blended honey was required. 11. A.O.B.: No item has been raised