Brussels, 2 June 2023 – On the occasion of FEDIOL’s annual conference, dedicated to  Innovation and Decarbonisation, members and stakeholders discussed tools to reduce greenhouse gas emissions. The food system being responsible for a significant share of the total GHG emissions, decarbonisation is imperative and the industry crushing oilseeds and refining vegetable oils is tackling emissions from its own activities (scope 1 and 2).

“Although, we may not be at the centre of attention in the debate on energy and carbon, our production processes are energy intensive and require large volumes of heat and electricity”, explained Jordi Costa, the President of FEDIOL and he went on saying: “Companies in our sector for more than ten years have already made efforts to decarbonize their activities through investments in enhanced energy efficiency and through enhanced use of biomass that becomes available as side stream during the processing of our raw materials.” Whereas it may still be possible to improve energy performance, significant reductions of CO2 emissions will require access to renewable electricity and heat allowing to reach temperatures up to 250° C.

Manufacturing of vegetable oils is vital for EUs food security and for the safety of the food and feed that is produced. The products, oils and proteinmeals are essential nutrients that will continue being relevant components for human and animal nutrition.

At sector-level, within our association, there is value added in enhancing collective intelligence and sharing experience or best practices. The sector-wide monitoring carried out with FEDIOL member companies about their GHG emissions over the period 2019-2022, delivered data, which will serve as a starting for future efforts. Achieving emission reductions is work in progress.

The industry also discussed addressing scope 3 emissions, in particular those of arable farming. The panel discussion on this gave insights into best practices to improve carbon farming, but also the challenges faced by farmers who are keen to have a broader approach, in which the co-benefits of carbon storage in the soil (biodiversity, water,…) can be considered as strategic as carbon.

Download the press release here

COCERAL, FEDIOL, and FEFAC, representing the EU grain and oilseed trade, the industry crushing oilseeds, refining vegetable oils and the animal feed industry, approve the European Parliament’s push for stronger alignment of the CSDDD with the principles and language of UN and OECD due diligence guidelines. However, other elements may be detrimental to trade and supply chains without added value to addressing harmful human rights and environmental impacts.

The strengthened risk-based approach and introduction of prioritisation of adverse impacts based on their severity and likelihood is crucial to ensure that companies’ efforts are targeted where they are most needed and can deliver the most impact. The risk-based approach is also more in alignment with the existing international frameworks on due diligence guidelines, which are built on best practices.

The provisions on civil liability offer greater legal certainty to companies and legal fairness by limiting it to situations in which a company has “caused” or “contributed to a harm”.

We equally endorse the European Parliament’s inclusion of the obligation to develop sector-specific guidelines for agriculture, group-level due diligence, ensuring harmonisation at EU level, and the introduction of minimum standards for independent third-party verification via a delegated act.

However, we regret the inclusion of suspension of products from free circulation or export among the sanctions to be imposed by Member States, as this disruption to trade and supply chains will not contribute to improvements in due diligence.

We now call on the European Parliament and Council to work towards a final text that is truly consistent with a risk-based approach, in line with UN/OECD best practice; enhances harmonisation to ensure a level playing field and avoid further internal market fragmentation; and bases civil liability provisions on legal traditions around breach-damage-causality. We stand ready to contribute to the dialogue during the trilogue negotiations.

Full press release also available here 

European business remains supportive of the objectives of the proposed directive on corporate sustainability due diligence (CS3D) and we urge co-legislators to work on a reasonable approach that is manageable for companies in practice. The European economy, including SMEs which will be impacted even if formally out of the scope, need a workable due diligence framework that is drafted in a balanced and proportionate way. There should be no room for legal uncertainty and fragmentation which will hamper the possibility for European companies, already facing a legally complex and crisis abundant environment, to contribute to the sustainability transition. We would therefore like to ask for number of key recommendations and concerns to be taken into account for the next stages of the legislative process:

1. We strongly call for full harmonisation to ensure a level playing field and avoid further internal market fragmentation. This is also in the spirit of the 30th Anniversary of the Internal Market. Divergent national legal regimes on due diligence would not only be costly and burdensome for companies of all sizes but, more importantly, risk undermining the achievement of the goals of the legislation in an efficient and effective manner.

2. To ensure that the future Directive is truly consistent with a risk-based approach, widely supported in international instruments in the UN and OECD, companies cannot be expected to focus on every single element of their value chains. The ability to prioritise the identification of and action to address the most salient risks is a necessity that must have a crucial impact on compliance with the due diligence process and its consequences. More prominence to industry and multi-stakeholder schemes is needed to help companies better comply with the new rules.

3. Legal liability provisions, including sanctions, need to be balanced, follow legal traditions around breach-damage-causality and truly incorporate the widely accepted principle that due diligence is first and foremost an obligation of means. The complexity of value chains cannot be underestimated when analysing impacts which can have multiple competing causes, players and dynamics. Therefore, companies cannot be made liable for damages they have not -intentionally or negligently - caused.

4. We acknowledge that, where relevant, due diligence requires engagement from relevant stakeholders in order to be effective. However, this should not mean creating wide open litigation powers to any entity to bring claims to court which could give rise to mass abusive litigation, ultimately depriving victims of harmful impacts to bring themselves claims to courts or mandate a representative (of their choice) to act on their behalf.

5. Legal clarity is paramount for the success of this initiative. This implies, for example, that definitions are robust and in line with what is used at international level (UN/OECD) and that provisions around climate objectives match with the recent Corporate Sustainability Reporting Directive (CSRD). Also, we call for revisiting and shortening the 2 annex to only include those conventions and treaties that create concrete obligations on companies so not to mix up their roles with the one of states. Timely guidance will be necessary on the new rules to avoid additional complexity both for the companies to secure compliance with a multi-layer set of rules, and for competent authorities to assess compliance with an over-prescriptive framework.

6. Regulating directors’ duties does not belong in a due diligence framework. It will have negative side-effects, including the disruption of existing, well-established governance models of the member states, without added value to the ability of companies to apply effective due diligence.

Full document also available here.

Brussels, 25 May 2023 – FEDIOL, the vegetable oil and protein meal industry, draws attention to acute market developments due to massive increases of imported biodiesel which lead to devastating consequences for the Europe based feedstock up to EU farm level.

Imports of biofuels, classified as waste based, for example identified as HVO (hydro-treated vegetable oil) or FAME (fatty acid methyl esters) are taking place at such scale, that it has led to important disturbances in the EU markets for rapeseed methyl ester, and as a consequence also in the rapeseed and rapeseed oil markets.

Over the last 5 months, prices for rapeseed oil have dropped significantly by over 30 % to 800 €/ton, driving down physical rapeseed prices for spot delivery from 625 €/ton to 410 €/ton over the same period. Also, futures prices for new rapeseed crop, providing rapeseed farmers with a price indicator, have declined from about 600 € per ton early January 2023 to levels of about 400 € per ton by mid-May 2023. This will not only impact rapeseed farmers’ revenue, but also future planting decisions.

These trends cannot be explained by other market developments and are a signal that there is abnormal market behaviour. The magnitude of biodiesel imports’ growth is such that it raises question as to the authenticity of their classification as originating from waste streams. There is urgent need to investigate the legitimacy of these imports.

FEDIOL acknowledges the accord in principle reached on EU exceptional safeguard measures to counter the unilateral decisions by the five frontline countries to ban Ukrainian agriculture imports.  Read our full statement

FEDIOL position on date marking.  Click here

COCERAL, FEDIOL, and FEFAC issued a press release following today's EP Legal Affairs Committee vote on Corporate Sustainability Due Diligence Directive. While they support the effort to improve consistency of the CSDDD with the principles and language of UN and OECD due diligence guidelines, they put in evidence that other elements may be detrimental to trade and supply chains without added value to addressing harmful human rights and environmental impacts.

Following the formal approval of the Deforestation-free Commodities Regulation, COCERAL, FEDIOL, and FEFAC call on the European Commission and Member States to work with stakeholders to facilitate the implementation of the Regulation. Read the press statement

FEDIOL has signed the EU Code of Conduct for responsible business and marketing practices in June 2021. To implement the various aspirational objectives of the Code, FEDIOL has set up a Action Plan for Implementation of the Code and its content was shared in the annual report, to the Commission in April 2022. To contribute to aspirational objective one on Healthy, balanced, and sustainable diets for all European consumers, thereby contributing to: 1) Reversing malnutrition and diet-related non communicable diseases (NCDs) in the EU 2) Reducing the environmental footprint of food consumption by 2030, FEDIOL decided among others to develop a FEDIOL recommendation on the labelling of frying oils, which was finalised in March 2023 and is available here.

FEDIOL welcomes the public consultation on the draft scientific opinion on the update of the risk assessment of mineral oil hydrocarbons in food to which will contribute by submitting comments to EFSA. Read in full here

The three signatories urge the Council and European Parliament to ensure mandatory structural engagement between the European Commission and Member States and producing countries in the final text of the EU Regulation on deforestation-free supply chains to mitigate the exclusionary impact of the Regulation on smallholders. Read the full press release here

Today, marks the launch of a new dedicated website focusing on vegetable oils and fats with the aim of outlining their health and nutritional aspects. Read the press release and visit the new website here

COCERAL, FEDIOL, and FEFAC published a press release in reaction to the provisional deal between European Parliament and Council on the EU Regulation for deforestation-free supply chains. Document available here 

EU Grain and Oilseeds sector welcomes EU Council General Approach on Corporate Sustainability Due Diligence Directive.

Read the press release

EBB-FEDIOL Recommendations for the trilogue negotiations on the Renewable Energy Directive III. Full document

FEDIOL position on revised Nutriscore. Click here

Joint open letter from 17 agri-food chain organisations regarding the potential impact of the current proposal on Sustainable Use of Plant Protection Products Regulation (“SUR”) on the EU agricultural value chain, considering the current socioeconomic situation in Europe. Click here

Today FEDIOL releases its monitoring of responsible soybean data collected in 2021 from participating member companies. 

Read the Press Release

Find the Factsheet

The exercise monitors volumes of crude #PalmOil & #PalmKernelOil entering EU refining plants of our member companies participating in the survey.

Read our Press release

See the Factsheet

FEDIOL co-signed the cogeneration sector letter handed to the European Commission demanding concrete actions to increase EU energy efficiency ambition. Decarbonization, affordability and energy security heavily depend on energy efficiency. Read more 

FEDIOL publishes its annual report covering the period June 2021 - June 2022.

FEDIOL welcomes the European Parliament’s decision to maintain the role of crop-based biofuels in meeting the EU’s transport renewable energy target. However, it regrets the EP approach on high ILUC feedstocks, which departs from the European Commission’s position and could lead to further instability on the EU energy market. Read more

Following the EP’s plenary vote on the Deforestation Regulation, COCERAL, FEDIOL, and FEFAC regret that the outcome falls short of the ambition to tackle global deforestation and risks fuelling supply chain shortages and price inflation in the EU. Read more

Ahead of the Extraordinary EU Energy Council meeting of 9 September 2022, FEDIOL voices its concerns over cost and availability of gas and electricity, calling on options to ease pressure to maintain domestic vegetable oil and meal production. Read full statement here

Joint statement from EU biofuels, food and feed chain partners – from harvesting to transformation for food, feed and energy uses – after the ITRE vote to preserve a key role for crop-based biofuels. Read more

FEDIOL welcomes maintenance of 7% cap for crop-based biofuels in RED III ITRE vote but rejects provisions that disadvantage crop-based biofuels. Our press release

COCERAL, FEDIOL, and FEFAC Welcome Stronger EU Partnerships with Producing Countries in ENVI Report on EU Deforestation-free Commodities Regulation but Regret Traceability Provisions. Read the full press statement here

Read the joint FEDIOL and EBB statement here

Following the adoption of the General Approach of the Council on the EC proposal on deforestation-free products at the 28/6 Environment Council meeting, COCERAL, FEDIOL, and FEFAC welcome certain elements like the Council’s move to avoid duplication of due diligence but are concerned that no significant changes have been put forward on traceability, cooperation with third countries, and chain of custody. 

Press Statement available here

FEDIOL welcomes the Council’s decision to maintain the Commission’s approach on crop-based biofuels, which are an available and cost-effective means to decarbonise transport in the EU and reduce fossil fuel imports. Read more

FEDIOL held its annual event on Friday 17 June on the theme, Transitioning to sustainable food systems: The role of environmental life cycle assessment after the release, earlier in the week, of the study on environmental footprint (PEF) profiles of vegetable oil and protein meal products. Read the post-event press release

Today, FEDIOL releases a study on Product Environmental Footprint (PEF) profiles of vegetable oil and protein meal products. The life cycle stages covered include the industrial processing of commodities, such as oilseeds and crude vegetable oils, but also the up-stream stages of cultivation and transport and the downstream stages of transport of the processed products to the customer.

Executive Summary - PEF study - PEFCRs Vegetable Oils Products are now accessible.

EU action on tackling deforestation is urgently needed, as rising demand for commodities is exacerbating pressure on land worldwide. To have an impact on deforestation rates, the EU cannot act alone nor focus exclusively on cleaning its own supply chains.

Real our full opinion editorial published on EurActiv on 30 May 2022

Joint statement of palm oil sector organisations on the EU Proposal for a Regulation on Deforestation-free products. Read the full paper

Ensuring the positive contribution of sustainable biofuels to RePowerEU´s ambitions for Europe´s energy independence. Read the full letter here

The temporary export ban decided by the Indonesian government is affecting several palm oil products, including crude palm oil, which FEDIOL member companies source and process to refined palm oil for the European market. More info here

While the market situation for sunflower oil was rather tense at the beginning of the war, the situation has over the last weeks improved.

Read more

The EU Biofuels Value Chain urge the Commission to not encourage Member States to reduce their blending biofuels mandates.

Read more here

A month after the invasion of Ukraine by Russia, FEDIOL member companies continue monitoring market developments and assess the short and longer-term consequences of the sudden loss of Ukrainian oil crops. Read more

The war situation in Ukraine will, according to FEDIOL members, have important consequences on European supplies of sunflower seed oil.

Read our full Press Statement here

FEDIOL co-signed today a Joint Statement urging the European Parliament and the EU Member States to adopt measures that can secure the contribution of high-efficiency cogeneration (CHP) by industrial operators to achieve the 2030 climate goals. Full Joint Statement here

Read our full statement

COCERAL, FEDIOL, and FEFAC, representing the EU grain and oilseed trade, crushing and animal feed industry, support the EU’s ambition to halt deforestation and only allow imports of deforestation-free products in Europe. For the EU framework to also achieve sustainable transformation in the countries of origin, it requires putting in place tools and processes that are practicable for the whole food and feed supply chain, from the site of production to the market of destination. There is no one-size-fits-all solution. Tools and processes will have to be adapted to the supply chain models of the different commodities concerned --> press release

--> Our position paper

In the context of the inclusion of gas-based generation in the European Commission’s Taxonomy draft Complementary Delegated Act, the signatories would like to raise concerns about the negative impact of too rigid criteria for cogeneration (CHP) on the decarbonisation and integration of the industrial operators in the energy system. Read more here

Joint statement Gas based generation in the EU Taxonomy: A step in the right direction, though adaptations are needed 

Joint press release by COCERAL, FEDIOL and FEFAC in response to the Commission’s legislative proposal for a regulation on deforestation-free products, entitled “The EU grain and oilseed chain flags wrong approach as the proposal only focuses on cleaning up domestic supply chains from deforestation”

27 EU organisations co-sign a joint statement following the EP plenary vote on the Farm to Fork Strategy - see here

The price for natural gas has sharply increased putting energy intensive sectors under additional competitive pressure compared to their peers abroad exporting to the EU. Read our full open letter here

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The Farm-to-Fork Strategy published by the EU Commission in May 2020 and the EU Biodiversity Strategy are decisive for the agricultural sector. Measures such as reducing the use of pesticides by 50% and expanding organic farming to 25% will have a major impact on production and food prices in Europe.
Prof. Dr. Dr. Christian Henning (Christian-Albrecht University of Kiel) and Dr. Peter Witzke (EuroCare, Rhenish Friedrich Wilhelm University of Bonn) carried out a study on the consequences of the Farm-to-Fork Strategy for the agricultural sector on behalf of the Grain Club and other associations in the German and European agricultural industry. 

→ Press release

→ Executive summary

You will find here facts & figures, statistics, milestones and priorities of our association! See report

FEDIOL undertakes a yearly survey which covers intake volumes of crude palm oil and palm kernel oil entering the EU refi­neries of member companies participating in the survey. A substantial reduction in total palm oil refined volumes in 2020 played a major role in the limited increase in sustainable palm oil refined by FEDIOL companies, which amounted to 65% (only 2% more than 2019 volumes). The total palm kernel oil refined volumes increased instead by 11%, but resulted only in +1% of the absolute share of refined certified sustainable palm kernel oil. Read the full statement here

The Renewable & Low-Carbon Liquid Fuels Platform considers the publication of the European Commission’s Fit For 55 package a step in the right direction; however, the proposals do cause some concerns as they fail to fully recognise the crucial contribution of renewable and low-carbon liquid fuels in the decarbonisation of transport and the value of multiple technological pathways to achieve 2030 and 2050 targets -> read the full statement

As members of the Renewable & Low Carbon Liquid Fuels Platform, we are committed to contributing to the decarbonisation of the mobility sector in a sustainable, affordable and socially inclusive way.  Read the full statement here

FEDIOL signs the voluntary EU Code of Conduct on responsible food business and marketing practices launched at a Commission-led High-Level event on 5 July 2021. Read our press release here.

At its annual meeting held on 16 June, the General Assembly of FEDIOL elected Mr Jordi Costa as President of FEDIOL for the 2021-2023 mandate. Read the press release: bit.ly/FEDIOLNewPresident 

Major organisations operating in the liquid fuels value chain have joined forces to form the Renewable & Low-Carbon Liquid Fuels Platform. These partners are working together to contribute to the decarbonisation of the mobility sector in a sustainable and affordable way. Read more

Mandatory Due Diligence as a part of the Smart Mix of EU Measures to tackle Deforestation and Human Rights Issues.

Read the position paper here

Despite improvement, more changes are needed to allow European Bioeconomy to be part of the solution towards climate neutrality. The activities of the members of the European Bioeconomy Alliance (EUBA) together represent nearly €2 trillion providing more than 22 million jobs to EU citizens. Our activities are essential to the sustainable production of renewable resources and their conversion into food, feed, fibres, materials, chemicals, pharmaceuticals and bioenergy through efficient processes and/or innovative technologies. Read the full statement here

EU Biofuels Chain Joint position paper on the revised Sustainable finance draft Delegated Regulation.

The European Commission's Circular Economy Action Plan sets important ambitions for reducing consumption by making products more renewable, reusable and recyclable throughout their whole lifecycle – ambitions that cannot easily be achieved without taking full advantage of Europe's bioeconomy. In this paper, the European Bioeconomy Alliance (EUBA), which represents a wide variety of primary producers, processors and technology providers, highlights the significance of its sectors in contributing bioeconomy solutions for this essential transition to a circular economy.

The EU can lead the sustainable transformation of our supply chains towards no-deforestation. If we want producer countries to follow, we need to support them in improving practices instead of only offering criticism and bans.

Read the full COCERAL, FEDIOL, FEFAC op-ed here

The industry and trade members of COCERAL, FEDIOL and FEFAC share public concern of the incidence of fires on native vegetation, wildlife and on local communities. Fires in the Amazon region are raising particular attention because of their alleged link with land grabbing practices and with deforestation. Read our joint statement here

Rapeseed oil is produced from the seeds of several species of plants of the Brassica family. Rapeseed is a bright-yellow flowering plant, cultivated mainly for its oil-rich seed. The main growing regions are Canada, China, India and the European Union.  See full factsheet here

At its meeting held on Thursday, 11 June 2020 in Brussels, the General Assembly of FEDIOL confirmed the unanimous election of Mr Roger Janson as President of FEDIOL for a two years’ mandate, 2020-2022. Full statement here

In response to the EU’s declared intention to reduce its role in global deforestation by targeting commodities and products entering its market via a set of regulatory and non-regulatory measures, COCERAL, FEDIOL and FEFAC share their views on the best way forward to achieve a sustainable transformation of their supply chains. Read full position here

Today marks the publication of two key components of the European Green Deal: the Farm-to-Fork and Biodiversity Strategies. As the EU association representing producers of vegetable oils and protein meals, FEDIOL shares the objective of supporting the transition towards a more sustainable EU food system. At a moment when the COVID crisis has highlighted major strengths, but also certain weaknesses of the agri-food sector, these strategies should help increase resilience to climate change and adaptation to future challenges and help put in place a transformative plan to tackle the biodiversity crisis by protecting and restoring nature.  Read our full press release

The ambitious European Commission strategy to drastically reduce greenhouse gas emissions in the EU and achieve climate neutrality by 2050 has recently been set in motion as the European Green Deal. The European Bioeconomy Alliance (EUBA), representing twelve organisations in various sectors active in the bioeconomy, welcomes such a comprehensive policy tool that should ensure alignment and coherence between the different initiatives that are part of the Deal. Read the full position here

During these times of crisis, COCERAL, FEDIOL, FEFAC, their member associations and individual companies are fully committed to fulfil their core mission: to continuously supply the food and feed chain by ensuring that nutritious and safe products are available at all times to the food and livestock industry. This helps provide access to affordable food to all European citizens and adequate nutrition to animal husbandry --> Joint statement

Given the dramatic consequences of the spread of COVID-19, the priority of the whole food and feed supply chain is obviously to strictly comply with EU and national instructions to prevent further dissemination of the virus among its employees, suppliers and customers. At the same time, we are taking all the actions required to avoid disruptions in the food and feed supply chain, so as to be able to continue supplying farmers, the food industry and feed processors with the agricultural raw materials and ingredients they need. Press release

Grain traders, crushers and compound feed manufacturers engage in constructive dialogue aimed at mitigating impacts on trade of the ongoing regulatory transition to lower maximum residue levels (MRLs) for pesticides in commodities. Press statement here

The variability of mineral oil results observed between different laboratories is an issue faced by different food sectors. Along with other industry players, FEDIOL contributed to a new article which provides a deeper insight on the reliability/reproducibility of the analytical methods used by commercial laboratories offering testing services to determine residues of mineral oil in foods. The article also identifies possible gaps and suggests improvements that may enhance the reliability of the data. This article was published on 22 October 2019 and can be found here

EU grain and oilseed trade, crushing and feed industry sectors represented by COCERAL, FEDIOL and FEFAC welcome the European Commission Communication on Stepping up EU Action to Protect and Restore the World’s Forests, adopted on 23 July 2019. See full press release here.

Brussels, 23 July 2019 – Today the European Commission released its Communication on Stepping up EU Action to Protect and Restore the World’s Forests, giving a clear signal on the need for all relevant actors to engage in the transformation of their supply chains via active commitment and support. See full press release here.

Coconut oil is produced from coprah, the dried kernel of coconuts. Imported into EU from the Philippines, Indonesia, Inda, Vietnam, as crude oil it is refined before use is food and non-food. See full factsheet here.

Maize oil is produced from maize germs and a by-products from starch production. Maizeoil is mainly used for food purposes in cold or warm preparations. See full factsheet here

Brussels, 14 June 2019 – The FEDIOL annual conference on “EU oilseeds processing: reconciling public and private objectives on food safety and sustainability” held today confirmed sustainability as one the key priorities for the vegetable oil and protein meal industry. See press release

Brussels, 21 May 2019 – In the absence of objections by European Parliament and Council on the proposed text within the given two-month scrutiny period, the European Commission has published today in the Official Journal the Delegated Act on the determination of high indirect land-use change-risk feedstock and the certification of low indirect land-use change-risk biofuels. See press release

On 23 April, 22  EU food and feed chain organisations jointly signed a letter urging Member States and the EU Commission to ensure EU legislation allows EU operators of the food and feed chain to preserve access to competitive supply of innovative food and feed ingredients. On 09 May, the letter received support from four additional business organisations. In total, 26 organisations are reiterating their concern about the European Court of Justice ruling on case C-528/16.

At the end of 2018, 66% of the approximately 3.7 million tonnes of palm oil getting into European refining plants of FEDIOL companies, were certified sustainable. This shows a slight increase compared to last year’s levels. See press release and monitoring leaflet

Read our  Press Release

22 EU food and feed chain organisations sent an open letter urging Member States and the EU Commission to ensure EU legislation allows EU operators of the food and feed chain to preserve access to competitive supply of innovative food and feed ingredients.

On 25 July 2018, the European Court of Justice interpreted the provisions of the EU GMO Directive 2001/18 in such a way that products resulting from innovative, targeted mutagenesis methods are regulated under the provisions of the GMO-Directive. This decision triggered strong reactions from many stakeholders and the scientific community, stressing that this would hinder dramatically the delivery of innovative and more sustainable agricultural products produced using new gene editing breeding techniques.

For EU organisations of the food and feed chain including FEDIOL, products that could have been produced by conventional methods and are indistinguishable from conventional ones should not fall under the GMO Directive 2011/18 and this means adapting the legal framework to that extent.