Even though increasing EU soy and legumes production is highly desirable, this cannot be the only response to the EU protein deficit and import dependence. While we understand the foreseen strategy of enhancing soy and protein production in the EU, we should also emphasize that there needs to be coherence between policies: in this sense, over 11 million tons of protein-rich meals, mainly from rapeseed, are directly related to the production of biodiesel and will disappear if the phasing out of crop-based biofuels proposed in the post-2020 revision of the Renewable Energy Directive is actually implemented. The Commission proposal, indeed, is in clear contradiction with the protein plan announced by Commissioner Hogan and would trigger the loss by EU farmers of a highly valuable source of high protein-containing feed and an essential source of revenue.
Putting the emphasis on the fact that enhancing production of legumes, and particularly soy, will replace imported soy that contributes to deforestation, means ignoring the considerable efforts that have been undertaken by European stakeholders and their overseas partners to supply from sustainable sources. Soy is not necessarily unsustainable per se and there are options for addressing deforestation and preventing it from happening at origin. A promotion of EU soy cultivation should leave space to initiatives that support sustainability and no-deforestation in the soy chain. Similarly, it should be noted that the non-GM/GM status is not a criterion for sustainability and the choice for one or the other quality should be left to market decision as is currently the case.
We recommend that the newly established Market Observatory for Crops looks into the potential impact of such strategy and comes up with a detailed assessment and with recommendations.