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In July 2025, the European Commission presented a proposal to amend Regulation (EU) No 1308/2013 (the CMO – Common Market Organisation). The package introduces, among others:
the establishment of a separate sector for protein crops,
harmonised rules for the cultivation and marketing of hemp (THC ≤ 0.3%),
the possibility of setting market standards for cheese, plant protein and meat (beef, pork, sheep/goat),
clarification of rules on additional import duties,
stronger crisis preparedness and stock requirements,
adjustments in the sugar sector (contracts, beet pulp).
The initiative stems from the post-2027 review of the Common Agricultural Policy and the Commission’s communication “A Vision for Agriculture and Food”. The focus is on strengthening the resilience of EU agriculture, stabilising farmers’ incomes, and building strategic autonomy in plant protein.
The proposal merges existing CMO instruments with new financing rules under the National and Regional Partnership Fund (NRPF) and the Performance Regulation, which will apply in the next financial framework. It also reflects lessons learned from 2020–2024, when the agri-food sector was severely affected by the pandemic, the war in Ukraine and market disruptions.
Another important source of inspiration was the Commission’s 2023 report on marketing standards, which opened the way for origin labelling rules for pulses and soy, and launched work on harmonising the definition and composition of certain cheeses.
School Fruit, Vegetables and Milk Scheme – to be implemented as an NRPF intervention, excluding highly processed products and those with high sugar or fat content, with mandatory educational measures; technical transition period until 31.12.2027.
Separate protein crops sector – designed to reduce EU dependence on imported protein.
Hemp – unified production and marketing rules covering the whole plant (not only fibre), with a THC threshold of 0.3%; clear legal framework after the CJEU judgment on CBD; transitional rules for plantings before entry into force.
Marketing standards – empowerment to adopt standards for plant protein (origin), meat (beef, pork, sheep/goat) and cheese (possible harmonisation of definitions and composition). At the same time, protection of “meat designations” to ensure transparency of composition and nutritional value, and to reduce the risk of consumer deception. Details will be set at secondary and national law level.
If adopted as proposed, the CMO amendments will have far-reaching consequences across the food chain.
Plant protein companies will need to reassess supply chains and consumer communication due to new sector rules, possible marketing standards, and enhanced origin labelling. Producer organisations and interbranch structures may reshape the balance of power, thereby strengthening farmers’ negotiating positions with processors and distributors.
Dairy and meat sectors will face harmonisation of definitions and composition of certain cheeses, and new quality standards for meat. Protection of meat-related terminology will also affect plant-based alternatives, requiring companies to review product names and marketing claims.
Hemp operators will benefit from greater legal certainty under harmonised EU rules, while maintaining the 0.3% THC threshold.
New crisis-preparedness obligations will pose challenges to supply chain management. Member States will have to develop response plans, report stock levels and establish strategic reserves – meaning operators may face additional reporting requirements and closer cooperation with authorities.
School scheme suppliers will need to adapt their offer to less processed products with lower sugar and fat content, and ensure educational activities and proof of EU origin. Since part of the decision-making will shift to the national level, close monitoring of implementation under NRP/NRPF will be essential.
For companies investing in innovative protein ingredients, it is crucial to remember that many such ingredients qualify as novel food under EU law. This does not prevent commercialisation, but it requires formal authorisation, often delaying market entry by several years.
At IGI FOOD LAW we strongly recommend verifying the legal status of protein ingredients before committing to investments or partnerships. Our experts provide comprehensive support – from novel food status analysis and authorisation procedures to consultation processes – helping companies plan realistic timelines for product launches and avoid costly setbacks.
The proposal amending Regulation 1308/2013 will be discussed at the AGRIFISH Council on 22–23 September 2025. Intensive negotiations and amendments are expected in 2025–2026, particularly on marketing standards, meat designations, and hemp rules. Most changes are scheduled to apply from 1 January 2028, with transitional periods for selected sectors – that’s only 27 months away.
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