Positions
Where the Council stands.
Council Positions are the European Heat Council’s published statements on industry standards: what we mean by “independent producer,” where we draw lines on product quality and provenance, and how member commitments are verified. Each Position is dated, issued under Council authority, and revised as evidence accumulates.
Positions are not advocacy. They describe how the Council itself operates, what it asks of members, and what buyers, journalists, and other producers can take from a Council-issued claim. Every empirical claim in a Position is backed by independent sources cited at the foot of the document.
Published Positions
Position 01 · Issued 2026-06-25
Defending the independent producer
The conditions under which independent food producers in the EU now operate, and the Council’s response to them. Three Findings on compliance burden, retail consolidation, and Member State enforcement variation.
Position 02 · Issued 2026-06-25
Safe food, proportionate rules
Proportionate, risk-based application of EU food safety rules to independent producers. Three Findings on existing flexibility provisions, Member State implementation variance, and where food safety risk actually concentrates according to public RASFF data.
Position 03 · Issued 2026-06-25
Ingredient quality and provenance
Adulteration risk, pesticide residue concentration in imported origins, and the conditional narrowness of the EU country-of-origin rule for primary ingredients. Three Findings drawn from the DG SANTE coordinated control plan, EFSA pesticide reports, and Regulation (EU) 2018/775.
Position 04 · Issued 2026-06-25
Championing local and regional supply chains
The Council’s affirmative case for local and regional sourcing. Three Findings on consumer demand for origin information, the climate footprint of long-distance food transport, and existing EU policy support for short food supply chains. Introduces the three-tier Council recognition framework: seed-to-sauce, EU-internal sourcing, and mixed traceable.
Position 05 · Issued 2026-06-25
Shipping rates for small producers
Cross-border parcel pricing as a structural single-market barrier. Three Findings on Regulation (EU) 2018/644’s own framing of the problem, the cost asymmetry between large contracted shippers and small operators, and the measurable suppression of cross-border e-commerce that follows.
Position 06 · Issued 2026-06-25
Energy costs in food SMEs
Structurally elevated EU industrial energy prices, the food sector’s 17 per cent share of EU gross energy consumption, and the Commission’s repeated use of temporary State aid frameworks as policy recognition that the cost pressure is structural, not transient.
Position 07 · Issued 2026-06-25
Packaging compliance under PPWR
Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation — applies from 12 August 2026. Three Findings on the scale of the change, the absence of a general micro-producer exemption, and the differential treatment of glass packaging.
Position 08 · Issued 2026-06-25
Novel food authorisation barriers
Regulation (EU) 2015/2283 and the 31-month average authorisation timeline. Three Findings on documented evaluation duration, the procedural barrier for SMEs, and the conditional 25-year evidence threshold of the traditional-food pathway.
Position 09 · Issued 2026-06-25
Geographical indication access
Regulation (EU) 2024/1143 and the practical access of small producers to PDO, PGI, and TSG protection. Three Findings on the two-phase procedure, registration cost (~EUR 8,000-12,000) and timeline (~28-34 months), and the producer-group requirement.
Position 10 · Issued 2026-06-25
EUDR and traceability
Regulation (EU) 2023/1115, the seven-commodity scope (cattle, cocoa, coffee, oil palm, rubber, soya, wood), the December 2025 postponement, and the indirect reach of EUDR into small food producers using listed commodities as secondary inputs.
Position 11 · Issued 2026-06-25
Chilli research commentary
Methodological Position establishing the Council’s chilli, capsaicin, and Capsicum research commentary track. Three Findings on research output growth, scope spanning health and agronomy, and EFSA’s role as canonical EU primary source.
Press and policy enquiries
For questions about forthcoming Positions or to request comment on a Position once published, use the contact page.