Should we respect the CAP’s environmental requirements in the event of a food crisis?

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1. Learn the ropes

Do you know where your food comes from?
In 2019, France had the highest total agricultural output among Member States (or about 18% of the EU total), followed by Germany and Italy. That same year, European countries have produced 299,309 thousand tonnes of cereals, 166,853 thousand tonnes of root crops (carrots, potatoes, leeks…) and 60,905 thousand tonnes of fresh vegetables. Thanks to its food production, the EU is the largest global exporter of agri-food products: in 2018, the top five destinations for EU’s agri-food products were the United States, China, Switzerland, Japan and Russia. That same year, the EU became the second-biggest importer of agri-food products. According to the European Commission, this brought “the EU trade balance for this sector to a positive net of €22 billion”. The EU mainly sources three types of products: products that are not produced in the EU (such as tropical fruit, coffee and fresh or dried fruits), products that are destined for animal feed, and products used as ingredients in further processing (such as palm oil). In 2018, the U.S. were the EU’s top supplier of agri-food products.
What’s cross-compliance ?
The food industry represents an important part of the EU economy. The farming industry has evolved a lot in recent years, and environmental issues now are at the heart of the CAP, the Common agricultural policy of the EU, one of its largest source of expenditure. The European Commission explains that “In order to receive EU income support, farmers must respect a set of basic rules. The interplay between this respect for rules and the support provided to farmers is called cross-compliance. Farmers violating EU law relating to environmental, public and animal health, animal welfare or land management will have their EU support reduced and may face other penalties.” The goal is to make European agriculture more sustainable. As such, the CAP will reflect higher green ambitions and contribute to the targets of the European Green Deal and the Farm to Fork Strategy. However, some experts argue that these new rules aren’t compelling enough to tackle climate change. Over time, this could have a significant impact on our harvests, since ensuring soil resilience is essential to secure our future food production.
Why are we talking about food security so much?
The war in Ukraine and inflation have dreadfully reminded us of how dependent we are on food supplies from other countries (wheat, oil, soy…). To secure our own food sovereignty, several exemptions from cross-compliance rules have been permitted in Europe: there is no crop rotation requirement in 2023, and cultivation of fallow land will be tolerated. These rules were supposed to preserve soil quality and enrichment, as well as protect biodiversity. This use of fallow land (about 1% of French total agricultural surface) will theoretically allow for larger cereal production that would secure food supply not only in Europe, but also in countries that rely on Ukrainian and Russian exports. Thanks to these exemptions, European exports of protein crop should increase by 19% in 2022. This will have no impact on the calculation of eligibility criteria for the green payments for French farmers. Some experts argue that these exemptions are necessary to ensure food security in Europe, while others say that we are going backwards with a lack of environmental ambition and a risk for long term yields.

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Should we let go of the CAP’s environmental requirements in the event of a food crisis?


Environmental rules are essential to tackle climate change and virtuous for our long-term competitiveness

Marianne Lefebvre

Associate Professor in agricultural economics at the Angers University


Letting go of the cross-compliance rules of the CAP (Common agricultural policy), even in the context of a decrease in food production in Europe because of the war, would be a mistake.

Many elements in the cross-compliance rules are based on common agronomic sense

We are currently facing huge challenges related to climate change, especially regarding biodiversity loss. There is an urgent need to alter the farming industry if we want to tackle these problems. We are in the situation of a food crisis, but the environmental crisis we are going through will cause even more problems. If we delay our actions to protect the environment, it will be too late. Cross-compliance rules should therefore not be managed on a short-term basis, because these rules will produce long-term positive impacts on the environment.

Furthermore, environmental standards do not always lead to yield losses. On the contrary, many elements of the cross-compliance rules are based on common agronomic sense and can generate production surplus in the medium term. For instance, cover crops contribute to good soil management, which ultimately helps produce more. We can also mention agro-ecological infrastructures that host crop auxiliaries that help reduce the number of pests. As such, cross-compliance rules do not necessarily result in yield losses.

We underestimate other factors which could explain our poor competitiveness

Moreover, the solution would not be to have fewer environmental rules or to get rid of the cross-compliance system in Europe, but to have more rules in the rest of the world to make sure that European products would not be in competition with food supplies produced in poorer conditions. This raises the question of carbon border tax and mirror clauses, which would impose rules on production systems in other countries.

If some European agricultural products are not competitive in comparison with supplies coming from other continents, it is not because of cross-compliance rules. We underestimate other factors which could explain our poor competitiveness, such as our climate and our soil, but also our workforce: fewer and fewer people want to work in the farming industry. We focus too much on environmental rules. They hide much bigger problems for the industry. It is not through lowering our environmental standards that European productions will suddenly become more competitive. 

Incentives to greener agricultural practices can reduce environmental impacts while increasing nutritional gains

When farmers argue that their yield loss is obvious when they have to respect more rules related to environmental protection, it is because they are thinking of the transitional period. However, once this adaptation period of the production systems has passed, these systems become more resilient and can be just as productive. We know for a fact that farmers can gain higher income after an ecological transition. 

Some will say that what really is at stake is to keep producing as much quantity. The other debate thus is whether what matters more is the quantity produced, or the nutrient intakes generated. Even if yields are reduced, if nutrient intakes increase, we have a clear nutritional gain. Incentives to greener agricultural practices in the CAP can reduce environmental impacts while increasing nutritional gains of the European agricultural production.


We cannot give up on producing more food in such an unstable international context

Thierry Pouch

Economist, French Chambers of Agriculture, Research Associate at the University of Reims


The European Union probably is the only region of the world that has made the environment its main priority in the past few years. Reforms of the Common Agricultural Policy are emblematic of this ambition to bring farmers to rally in the fight against global warming through changing their cultivation and breeding practices and accepting cross-compliance to receive subsidies for their work. The climax of this strategy is the European Green Deal (signed in 2019), especially with its Farm to Fork scheme. Nothing seemed to be able to keep the EU off this path.

Some countries have to produce more in order to make up for the missing supply from Ukraine

Two events have nevertheless altered the EU ambition, despite its persistence to maintain its strategy. The Covid pandemic is the first element: it showed how dependent we are on food supplies coming from other countries. The lockdowns and partial stop of maritime transport globally have weakened countries that heavily relied on imports to feed their population. France has not been spared by this new awareness, particularly regarding its dependence on plant-based proteins, which are essential to feed livestock and to produce meat and milk.

The war in Ukraine is the second element and has brought this awareness to its peak. Russia is one of the biggest producers and exporters of fertilizers, oil, gas, as well as sunflower oil and cattle cake. As a consequence, some proposals have been issued to identify how the EU could reorganize its food production in order to rely less on fertilizer and energy supplies. Moreover, some countries are very dependent on Ukraine and Russia to access food (wheat, corn, sunflower oil…) such as Egypt, Turkey, Lebanon, Somalia… The war thus raised a new question: which countries would be capable of producing more in order to make up for the missing supply from Ukraine?

The EU must not lose sight of its role in contributing to the vital balance of the planet

This is why, right after the war started, some people raised their voice to warn the European Commission against these food supplies threats. Their suggestion was to temporarily put on hold actions to protect the environment, and thus allow farmers to produce larger quantities and thus meet global demand and address the risk of famine and food insecurity in several regions of the world, as well as the risk of geopolitical conflict.

If the year 2022 thankfully ended without a radical disruption in the world food production and supplies, 2023 might know a different fate. As a consequence, we cannot give up on producing more food in such an unstable international context. This trajectory is not in contradiction with environmental issues, since in the EU, farmers have already changed their agricultural practices, especially with the reduction of pesticides use in the past few years. Nevertheless, we need to keep our production level to avoid situations like food riots (2009) or Arab Spring (2011). 

If the EU intends to become a normative global power in environmental protection, it must not lose sight of its role in contributing to the vital balance of the planet. As the first agricultural power of the EU, France thus has an essential role to play.

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