EU: news on meat sounding, short supply chains, hemp and vinegar

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Dario Dongo
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The prohibition on using meat and egg names in the labeling of foods of a different nature – meat sounding, egg sounding – intensifies the debate on an EU reform project that also considers other aspects such as the concept of ‘short supply chain‘, public procurement of agricultural and food products, and the definitions of ‘hemp‘ and ‘vinegar‘.

Below is a brief analysis of the position adopted by the European Parliament on October 8, 2025, at first reading of the Commission’s proposed regulation aimed at ‘strengthening the position of farmers‘ in reforming the single Common Organisation of the Markets (CMO), Regulation (EU) No 1308/13.

Bans on ‘meat sounding’ and ‘egg sounding’

The livestock sector has for years denounced the use of names that recall products of animal origin in consumer information relating to foods of a different nature, such as vegetarian and vegan alternatives to such products.

‘Milk sounding’ and ‘meat sounding’, the precedents

The Court of Justice of the European Union (CJEU) has already declared the illegality of references to milk and dairy products (milk sounding, cheese sounding) on plant-based products, in the TofuTown.com GmbH case (case C-422/16), precisely because such products have a legal designation established in the single CMO.

This ban is not, however, extended to references to the names of meat, meat preparations and meat products (meat sounding), in the absence of corresponding legal designations. And the European Parliament – in the previous legislature, on October 23, 2020 – had already rejected the idea of introducing them, in the reform of the Common Agricultural Policy.

The CJEU has meanwhile declared the illegality of the national bill with which France had tried to ban meat sounding, in case C-438/23, clarifying that Member States may introduce legal designations on condition that they do not obstruct the free movement of goods in the single market.

‘Meat sounding’ and ‘egg sounding’, the position of the European Parliament

The European Parliament, in its first reading of the proposed regulation, voted in favor of a reform of the CMO to include a series of definitions and prohibitions that also extend to products derived from cellular agriculture:

  • ‘For the purposes of this part, “meat” means edible parts of the animals referred to in points 1.2 to 1.8 of Annex I to Regulation (EC) No 853/2004, including blood‘. This therefore refers to domestic ungulates (cattle, pigs, sheep and goats, equidae); poultry (farmed birds, excluding ratites, e.g. ostriches); lagomorphs (rabbits and hares, rodents); game wild, feathered and farmed, small and large. ‘The meat-related terms and names that fall under Article 17 of Regulation (EU) No 1169/2011 [food name, ed.] and are currently used for meat and meat cuts, shall be reserved exclusively for the edible parts of animals‘;
  • ‘“Meat preparations” means fresh meat, including meat that has been reduced to fragments, which has had foodstuffs, seasonings or additives added to it, or which has undergone processes that do not alter the internal muscle fibre structure of the meat enough for the characteristics of fresh meat to be eliminated‘;
  • ‘“Meat products” means processed products resulting from the processing of meat or from the further processing of such processed products, so that the cut surface shows that the product no longer has the characteristics of fresh meat‘;
  • ‘Names that fall under Article 17 of Regulation (EU) No 1169/2011 [food name, ed.] that are currently used for meat products and meat preparations shall be reserved exclusively for products containing meat. These names include, for example: steak; escalope; sausage; burger; hamburger; egg yolk; egg white‘;
  • ‘The poultry products and cuts defined in Regulation (EU) No 543/2008 laying down detailed rules for the application of Council Regulation (EU) No 1234/2007 as regards the marketing standards for poultry meat shall be reserved exclusively for the edible parts of animals and products containing poultry meat’;
  • ‘The above-mentioned names shall not be used for any product other than the products referred to and shall exclude cell-cultured products’ (amendment 113 to Article 1 of the proposed regulation, reforming Regulation (EU) No 1308/2013, Annex VIII – new Part II A).

Short supply chain

The Strasbourg Assembly also intends to tighten the conditions for using the term ‘short supply chain‘ in commercial information relating to food, introducing a constraint on product categories (only those considered in the CMO), a territorial constraint (production and trade limited to the EU), and the obligation to obtain prior consent from the agricultural supply chains concerned. Without introducing any condition on the environmental sustainability of agricultural production and related supply chains. As follows:

  • ‘The term “short supply chain” may be used only, alone or in combination with other terms, on the labelling, in the presentation, on advertising material or on commercial documents of a product of the sectors listed in Article 1(2) [i.e., only the foodstuffs falling within the scope of the CMO, ed.], ‘produced in, and placed on, the single market, with the prior consent of the farmers or their representative organisations, provided that the term is used to inform purchasers about existing modalities for the organisation of production, distribution, or placing on the market, which provide for at least one of the following conditions:

    a) a direct connection or a limited number of intermediaries between the farmer, cooperative or producer organisation and the final consumer of the product, or

    b) a close connection, and geographical proximity, understood as a short distance or short travelling time, including cross-border contexts, between the farmer, cooperative or producer organisation and the final consumer of the product‘;

  • ‘The Commission may adopt delegated acts in accordance with Article 227 in order to supplement this Regulation by specifying further the conditions‘ referred to above, ‘taking into account any relevant international standard and related quality certified schemes‘;
  • ‘The Commission shall assess the feasibility and added value of introducing a harmonised Union visual label on short supply chain products’ (amendments 37-41 to Article 1 of the proposed regulation, reforming Regulation (EU) No 1308/2013, new Article 88a).

Public procurement

MEPs also call for a constraint on public procurement for the supply of agricultural and food products, to be restricted to (only?) ‘Made in EU‘ foodstuffs, with priority given to those with registered ‘Geographical Indications’ (GIs):

  • ‘Member States shall ensure that supply contracts awarded under public procurement procedures are sourced from agricultural and food products originating in the Union, in particular with local and seasonal products, with the aim of enhancing the quality, sustainability and food safety of European agricultural products‘;
  • ‘Products benefiting from protected geographical indications, protected designations of origin and traditional specialities guaranteed shall be given priority in the implementation of these actions‘;
  • ‘The Commission shall adopt delegated acts, laying down the conditions for the application of this Article, ensuring compliance with Union rules‘ (amendment 147 to Article 1 of the proposed regulation, reforming Regulation (EU) No 1308/2013, new Article 210b).

The compatibility of these provisions with the agreement establishing the World Trade Organization (WTO) and other trade agreements between the European Union and other partner States will, however, require careful examination before their final approval, in order to prevent international disputes.

Hemp

The draft reform extends the scope of application of the CMO to the hemp sector. An important step forward in recognizing the agricultural and industrial value of this crop, which is among other things an emblem of the circular economy and of combating climate change, thanks to its notable carbon sequestration capacity.

Definitions for the hemp sector

The European Parliament introduced the definition of “hemp” as ‘the plant Cannabis sativa L., of varieties listed in the common catalogue of varieties of agricultural plant species grown for its seeds, flowers, fibres, shives and roots‘ (amendment 110 to Article 1 of the proposed regulation, reforming Regulation (EU) No 1308/2013, Annex II – new Part IIIa).

Import conditions

‘The following products may be imported into the Union only if the following conditions are met:

a)  raw true hemp falling within CN code 5302 10 00 meeting the conditions laid down in Regulation (EU) 2021/2115;

b)  seeds of varieties of hemp falling within CN code ex 1207 99 20 for sowing accompanied by proof that the tetrahydrocannabinol level of the variety concerned does not exceed that fixed in accordance with Regulation (EU) No 2021/2115;

c) hemp seeds other than for sowing, falling within CN code 1207 99 91 and imported only by importers authorised by the Member State in order to ensure that such seeds are not intended for sowing;

d)  hemp flowering tops accompanied by proof that the tetrahydrocannabinol level of the variety concerned does not exceed the level set in accordance with Regulation (EU) No 2021/2115 and imported only by importers authorised by the Member States‘ (amendment 93 to Article 1 of the proposed regulation, reforming Regulation (EU) No 1308/2013, Article 189, paragraph 1).

Vinegar (products other than wine vinegar)

The scope of application of the CMO is also extended, according to the wishes expressed by the European Parliament, to vinegars other than wine vinegar:

  • ‘The vinegar sector includes products other than wine vinegar that are listed in the following table: CN code 2209 00 91 and 2209 00 99‘;
  • ‘Description: fruit vinegar, including kiwi vinegar, or fruit wine vinegar, berry vinegar or berry wine vinegar, cider vinegar, spirit vinegar, grain vinegar, malt vinegar, distilled malt vinegar, honey vinegar, flavoured vinegar‘; (amendment 110 to Article 1 of the proposed regulation, reforming Regulation (EU) No 1308/2013, Annex I – new Part XIIa).

Definition of vinegar

‘The name “vinegar” shall only be used for product obtained exclusively by the biological process of double fermentation, alcoholic and acetous, from liquids or other substances of agricultural origin. It shall always be followed by the indication of the raw material used. With the exception of references to ingredients with flavouring properties, all additional indications are prohibited‘.

  1. ‘Notwithstanding‘ the above, ‘the name “vinegar” can be part of a registered protected designation of origin or a protected geographical indication protected under Regulation (EU) 2024/1143, in which case it shall be used in accordance with the specific rules provided by the relevant product specifications and regulations.
  1. The name “vinegar” shall not be used for mixtures of vinegar and acetic acid food grade.
  1. The acetic acid content of vinegar, expressed as their total acidity in g/100 ml, shall be given on the label as “… % acidity“‘ (amendment 110 to Article 1 of the proposed regulation, reforming Regulation (EU) No 1308/2013, Annex II – new Part IVa).

Pesticides MRLs on imported products

‘Food and feed of plant and animal origin may be imported from third countries only if they comply with obligations related to the maximum residue levels of pesticides in food and feed produced in the Union‘ (amendment 92 to Article 1 of the proposed regulation, reforming Regulation (EU) No 1308/2013, Article 188, new paragraph 3a).

This provision is not a true legal novelty, as Regulation (EC) No 396/2005 already establishes that ‘the same MRLs apply to all food and feed products placed on the EU market, whether they are produced in the EU or imported from non-EU countries’. However, Article 6(4) of that regulation allows for ‘import tolerances‘ – individual residue limits for products from third countries to account for different agricultural practices.

Amendment 92 therefore appears to be a political reinforcement aimed at restricting or eliminating import tolerance exceptions, strengthening enforcement, and closing potential loopholes in the existing framework.

Outlook

Following the adoption of the European Parliament’s position at first reading on the proposed reform in question, on October 8, 2025, two possible outlooks are envisaged:

  • if the Council of the European Union approves the Parliament’s position in its entirety, the act may be adopted definitively already at first reading;
  • otherwise, the Council will adopt its own position at first reading, which will be transmitted to Parliament for second reading.

In the second scenario, interinstitutional negotiations (trilogue) between Parliament, Council and Commission may be initiated to reach a political agreement and allow adoption of the text within a relatively short time frame that can be estimated at 6-12 months, based on precedents.

Dario Dongo

Cover art copyright © 2025 Dario Dongo (AI-assisted creation)

References

  • European Parliament. Amendments adopted by the European Parliament on 8 October 2025 on the proposal for a regulation of the European Parliament and of the Council amending Regulations (EU) No 1308/2013, (EU) 2021/2115 and (EU) 2021/2116 as regards the strengthening of the position of farmers in the food supply chain. (Ordinary legislative procedure: first reading) https://www.europarl.europa.eu/doceo/document/TA-10-2025-0214_EN.html
  • Regulation (EU) No 1308/2013 of the European Parliament and of the Council of 17 December 2013 establishing a common organisation of the markets in agricultural products. Consolidated text: 08/11/2024 http://data.europa.eu/eli/reg/2013/1308/2024-11-08
  • Regulation (EU) 2021/2115 of the European Parliament and of the Council of 2 December 2021 establishing rules on support for strategic plans to be drawn up by Member States under the common agricultural policy (CAP Strategic Plans) and financed by the European Agricultural Guarantee Fund (EAGF) and by the European Agricultural Fund for Rural Development (EAFRD) and repealing Regulations (EU) No 1305/2013 and (EU) No 1307/2013. Consolidated text: 25/05/2024 http://data.europa.eu/eli/reg/2021/2115/2024-05-25
Dario Dongo
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Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.

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