The Co-decision Trap: How the Co-decision Procedure Hindered CAP Reform

Since the 1980s, the European Union’s Common Agricultural Policy has undergone a series of reforms that were facilitated by the changes in decision-making rules such as the introduction of the qualified majority vote. This article argues that the introduction of the co-decision procedure under the Lisbon Treaty, which increased the European Parliament’s legislative powers, has generated a “co-decision trap” that has hindered further reforms.

Since the 1980s, the EU’s Common Agricultural Policy (CAP) has undergone a series of reforms, influenced by the changes in the external trade environment and the need to accommodate the policy to the budgetary framework, as well as emerging issues such as environmental concerns. Although these changes acted as a push factor for the reforms, theoretical and empirical evidence suggests that the reforms were in fact made possible by the changes in institutions of representation and decision-making, introduced with the changes in the EU treaties prior to the reforms.

Following Pokrivcak et al. and Crombez,1 two institutional changes that are considered to be particularly important for improving the chances for reform are the change in decision-making procedures and the change in the Commission appointment procedures. Firstly, the replacement of the unanimity rule in decision-making on the CAP with the qualified majority vote (QMV), introduced by the Single European Act of 1987, prevented individual member states from blocking policy changes. The Commission, possessing the exclusive power to propose legislation, was then able to propose more substantial reforms. Secondly, by giving the European Parliament the right to veto the appointment of the Commission, the Maastricht Treaty of 1992 put pressure on member states to propose credible and competent candidates, and the Treaty of Nice of 2000 changed the Commission appointment procedures by introducing QMV.

The influence of institutional changes was demonstrated during the 2003 Fischler reform, which introduced substantial changes to the CAP. In order to gain support for the reform, the Commissioner for Agriculture Franz Fischler negotiated with agricultural ministers bilaterally until a qualified majority was secured. Furthermore, due to the opposition in France to Fischler’s nomination, the appointment of a strong Commissioner would not have happened without changes in the Commission appointment procedures.2 Additional institutional changes were introduced by the Treaty of Lisbon (2007). First, the European Parliament was given the right to co-decide with the Council and propose amendments to new CAP legislation. Second, the European Parliament gained the power to approve the EU budget.

It will be argued in this paper that the combination of the change in decision-making procedures provided by the Treaty of Lisbon and the interaction of actors’ preferences made reform more difficult. As demonstrated by Crombez,3 under the co-decision procedure, a European Parliament that was more reform-minded than the Council would not be able to influence policy reform, since the Council would use its veto right. However, a more conservative Parliament would be able to influence the reform by threatening to block it. Introduction of the co-decision procedure in the decision-making on the CAP thus resulted in a “co-decision-trap”.4 In comparison, the ability of the Parliament to veto the long-term budget was considered to be less important. Because of the unanimity rule applied to the budget negotiations, there were already a number of veto players, meaning the Parliament could influence the outcome only in case its preferences were even more conservative than those of other veto players (member states).

Previous research has demonstrated that CAP reforms are complex political processes which depend on interaction between particular historical contexts and political institutions.5

Changes in the policy environment

Past CAP reforms were influenced by the ongoing changes in the environment in which it operated, which challenged policy objectives and the way they were being pursued. There is an ongoing debate on how particular changes (or their combinations) influenced the reform, the dynamics of external trade, the Community budget and new issues such as environmental concerns.6 Since the latest reform, changes in these contexts have led to pressure for additional accommodations for CAP.

Agricultural policy has been subject to the integration of world markets and ongoing multilateral trade negotiations. At this point, most of the support measures that were considered to be trade-distorting have been phased out. In order to compensate producers for the income foregone due to the reduction of financial support, direct payments were introduced. After the Fischler reform of 2003, the majority of this direct support was “decoupled” from production; thus, in order to be eligible, farmers were no longer required to produce. If they did decide to produce, they had to comply with certain management requirements regarding, for example, animal welfare and environment. If they decided not to produce, they were obliged to keep the land in good environmental and agricultural condition. Thus, direct payments were justified as compensation for higher production standards and, potentially, for the provision of public goods. Member states were able to apply regional schemes for the distribution of support funds and were granted flexibility in allocating some direct support.7 However, the compliance criteria did not introduce substantial costs to the recipients of agricultural support, and the majority of direct payments, which became the main support mechanism, were still allocated based on historical levels of production and support.8

It was expected that the new CAP reform would phase out some of the remaining market measures such as supply controls that hindered the development of competitive production.9 What is more, even though direct support was considered as non-trade distorting in the Doha negotiations,10 its status was being increasingly questioned.

New issues emerged in the late 2000s, such as the growing global demand for food, which was expected to increase by 70 per cent by 2050, and the volatility of agricultural commodity prices. Even though there was no reason to believe that agricultural producers would not be able to meet the demand (historically, productivity in agriculture grew by two per cent per year),11 this was expected to produce additional pressures on the environment, threatening long-term supply. The volatility of agricultural prices and the effects of this volatility on farmers’ incomes was influenced by the type of the support mechanism; if it were based on the implicit support for production, it would make farmers even more dependent on the markets.

The second major external change that induced further need to reform the CAP was the common budget. The CAP budget was stabilised with the introduction of direct support. Even though the relative share of the CAP costs in the overall EU budget had decreased, they still accounted for approximately 40 per cent of all expenditures. Due to the fiscal pressures faced by member states in the aftermath of the financial and economic crisis, pressure to curb the budgetary volume of the CAP and to use these resources more wisely strengthened.

The third big issue consisted of environmental concerns.12 Intensive farming practices were responsible for the degradation of soil, loss of biodiversity, water pollution and the depletion of water resources. Agriculture accounted for 16 per cent of greenhouse gas emissions. Since 2003, direct support was conditioned upon compliance with various environmental standards, and around 40 per cent of funds available for rural development programmes were devoted to agri-environment measures. However, most of the support given in the form of historical payments in fact subsidised the application of capital-intensive production practices harming the environment. The growing demand for food acted as an incentive for the introduction of intensive production and the turning of pastures and forests into agricultural land, thus diminishing natural carbon reduction.

The final issue was the distribution of funds. There was a growing debate over the fact that 80 per cent of support funds went to 20 per cent of all recipients, many of whom were not genuinely involved in farming at all. Secondly, in per area terms, the support received by farmers in the new member states was lower than the EU average. The 2003 reform introduced the mechanism of “modulation”, which transferred five per cent of individual payments higher than €5,000 to rural development funds. The 2008 Health Check reform increased the modulation to ten per cent and introduced a “degressive capping” mechanism, which transferred an additional four per cent from those receiving more than €300,000 to the rural development pillar. Apart from redistributing part of the funds towards smaller farmers, these two mechanisms also resulted in the redistribution of funds towards countries with higher shares of small farmers.13 Even though a substantial share of rural development funds was allocated to developed regions, they were considered to be much more appropriate for addressing various structural issues such as problems of low income in agriculture.

The reform process

In spring 2010, the European Commission launched a public debate on the “future of the CAP”. An “independent report” found that the majority of respondents pointed out issues such as food security, various environmental concerns and unequal distribution of support between small and big farmers and between farmers in old and new member states.14 Based on the outcomes of the public debate, the Commission published a 15-page strategic document in November 2010,15 which presented three reform options: to implement the necessary modifications of the CAP as it is (the “conservative scenario”); to continue with the phasing out of the remaining price supports, move towards per area payments and introduce new simple, general environmental actions (the “reformist scenario”); or to replace existing support schemes with environmental and rural development programmes (the “reorientation scenario”). The conservative scenario was considered to fall short of the new challenges faced by the CAP, and the reorientation scenario was considered to put too much pressure on farmers’ incomes. According to the Commission, the reformist scenario was the most promising.

Member states that were big net contributors to the budget, such as the United Kingdom, the Netherlands, Sweden and, to a certain extent, Germany (also known as the “CAP reformists”), pressured for the CAP budget to be curbed. Member states that received substantial amounts from the CAP budget, such as Spain, Ireland and France (also known as the “conservatives”), were unwilling to accept any reductions to the support received by their farmers and opposed any redistribution measures or additional costs based on new environmental measures. The new member states wanted to see their direct payments rise to the average EU level.16 Germany and France published a joint paper which was generally supportive of the Commission’s approach, but argued the reform should bring “no disadvantages to member states or farmers” and, more explicitly, that “full convergence of payments was not an option”.17

Just before the Commission published its proposals for the new budget and CAP reform, the European Parliament passed a resolution on the future of the CAP, calling for “sufficient resources in order to be able to meet the new challenges”.18 The EU-level organisation of farmers’ unions and cooperatives (COPA-COGECA) pressured for a CAP with proper teeth and was strongly against any reduction of support or the introduction of new measures that would increase the costs of production or even prevent farmers from producing.19 Environmental organisations were satisfied with the “green” rhetoric but wanted to see concrete proposals.

The Commission’s proposal

In June 2011, the European Commission first published a proposal for the 2014-2020 budget, which – taking into account the growing budgetary needs – was slightly larger than the one that was expiring. The relation between the funds available for direct payments and rural development support was left unchanged.20

In October 2011, this was followed by a proposal for further CAP reform. The new market regulation provisioned a further tailoring of the remaining market measures to the level of safety net.21 Major changes were introduced by the new direct payments regulation.22 Existing payments schemes were replaced by a “basic payment”, allocated on a regional per area basis. In order to prevent non-active farmers from receiving support, specific eligibility criteria were introduced. Distributional issues were addressed by capping,23 which entailed the transfer of funds from the biggest recipients to the rural development fund and redistribution of support towards member states in which per area payments were under 90 per cent of the EU average, to the extent that 30 per cent of this gap would be closed. Up to five per cent of payments to farmers (ten per cent where the share was higher at the time) could continue to be coupled with production. The basic payment scheme, accounting for up to 60 per cent of total direct support, was accompanied by “green payment”, accounting for a further 30 per cent, to compensate farmers for three types of obligatory environmental actions: the preservation of permanent grassland, crop diversification with at least three crops each covering from five to 70 per cent of the area, and the establishment of ecological focus areas (EFAs) such as fallow land, buffer strips and afforested areas on at least seven per cent of the land. Farms under three hectares and those engaged in organic farming were exempted from the “greening” requirements. Furthermore, farmers were expected to comply with additional environmental requirements such as those documented in the water framework directive.

The remaining share of direct payments was designated to top up support for young farmers and those farming in regions facing natural constraints. Member states could allocate up to ten per cent of the funds to small farmers under a simplified scheme. Finally, member states were enabled to reallocate up to ten per cent of direct payments to a rural development fund, while those member states with payments under 90 per cent of the EU average were granted flexibility to switch up to five per cent of funds in the opposite direction.24

The intra-institutional negotiations

In accordance with the final negotiation framework proposed by the President of the European Council, Herman Van Rompuy, market measures and direct as well as rural development funds were reduced by approximately ten per cent each, with the reduction of the rural development funds being slightly higher (see Table 1). The text set the nominal floor for direct payments at €196 per hectare (75 per cent of the average payment in the EU) and introduced the principle of progressive financing of “external convergence”, which meant that countries with payments closer to the EU average such as Germany and France would have to contribute less. Under pressure from Germany and the United Kingdom, where the number of big recipients of CAP funds was relatively large, capping was rejected. Member states were able to switch 15 per cent of funds between direct payments and the rural development pillar. Those countries in which direct payments in per area terms were lower than 90 per cent of the EU average were granted an additional ten per cent flexibility.25 Finally, several member states that were considered to be put in an unfavourable position by the agreement were earmarked for discrete allocations of support for rural development. After some minor corrections, the European Council endorsed an agreement in February 2013.26

Already during the budget negotiations, a wide conservative coalition emerged in the Council that argued against further pressures on farmers’ income and asked for “more realistic” regionalisation and greening. France, Spain and Italy opposed the full regionalisation of payments, stressing that this would redistribute support from more productive to less productive farmers.27 Ilse Aigner, the German agriculture minister, referred to the proposed EFAs, arguing that in times of increasing global demand, “it would be absurd to leave 7% of farmland fallow”.28

After a lot of effort had been invested by the Irish presidency to reduce the regionalisation and greening proposals of the Commission, in March 2013 a substantial majority in the Council of agricultural ministers (only Slovenia and Slovakia voted against) agreed on a common position for the CAP reform. Compared with the Commission’s proposal, this position slightly extended some of the interventionist measures, rejected active-farmer criteria and proposed a negative list instead, limited the regionalisation target by introducing internal convergence criteria and, based on the French proposal, allowed member states to top up payments on first hectares (“reversed degressivity”), thus reversing the regionalisation effects.

Up to seven per cent of the support funds (12 per cent where the share was higher at that time) could remain coupled with production. The Single Area Payment System applied by the majority of the new member states was extended until 2020. As far as greening was concerned, arable areas of 10-30 hectares were required to grow at least two crops, of which one would be planted on more than 80 per cent of the area, and farms larger than 30 hectares were expected to grow at least three crops, with the main crop planted on less than 75 per cent of the area and two main crops planted on less than 95 per cent of the area. Only farms larger than ten hectares were required to devote five per cent of their land to EFAs, and 50 per cent of the EFAs could be provided collectively or regionally. Farms with high shares of grassland and forest were exempted from greening. Areas covered with protein crops and oilseeds were considered to satisfy EFA requirements. Member states could apply “equivalent measures” based on their national certification schemes. With the penalty for not applying green actions set at 125 per cent of the green payment, greening was no longer obligatory. Any additional compliance criteria were rejected.29

The Parliament’s position presented in March 2013 was close to the position of the Council,30 except for the fact that the Parliament supported a further extension of supply controls, a slightly reduced version of internal convergence and larger shares of support funds coupled with production. Representatives of the Agricultural Committee first wanted to prevent a plenary vote on the negotiating position. However, the plenary did vote on it and rejected the possibility of “double funding”, resulting from the ability of member states to apply equivalent greening measures that could have already received support from Pillar II. The European Parliament also rejected the European Council’s budget agreement.31

Inter-institutional agreement

Farmers’ organisations that asked for a more gradual regionalisation and flexible greening were satisfied with how the process evolved and urged the European Parliament not to further delay the reforms. Environmental NGOs, who advocated EFAs on ten per cent of the land, were critical towards the CAP reform, arguing that first rural development programmes were sacrificed and then greening was relaxed to an extent that it became meaningless and that greening had in fact become “greenwash”.32

Following approximately 50 rounds of “trialogue” negotiations among the representatives of the European Commission, the Council and the Parliament between May and June 2013,33 an agreement on non-financial issues was reached. In accordance with the compromise agreement on direct support, the target of 60 per cent convergence of basic payments to a member state was set for 2019, with several options available to limit the redistribution of funds. The share of payments that could be coupled with production was somewhat in between the Council’s and the Parliament’s positions. The rest of the compromise was based on the position of the Council, with the exception of double funding, which was rejected.34 A compromise solution on CAP-related financial issues, which had been negotiated during the summer, was formally agreed to in September 2013. It provisioned for a five per cent capping for individual payments higher than €150,000, with countries applying redistributive payment of at least five per cent exempted. In addition, higher co-financing rates were set for the support of rural development, and funds reallocated to rural development would not require co-financing by member states.35 After almost four years, the reform process had been completed.

Analysis and discussion: is the CAP trapped?

The CAP 2020 reform continued the phasing out of the remaining market measures, albeit at a somewhat slower pace. Historical support measures were replaced by regional per area support. However, due to a relatively modest internal convergence target and the ability to apply mechanisms constraining and reversing the redistribution effects, to a large extent, payments will in fact continue to correspond to the historical levels. As far as external convergence is concerned, closing of the gap will basically only take payments in the three Baltic countries to the level of Romania.36 A share of 30 per cent of direct support will now be conditioned upon new environmental actions. However, measures are relatively weak; the EFAs, which were considered to be the most important measure, will be applied to five per cent of the areas, but they were already in place in three per cent of the areas.37 Furthermore, a substantial number of farmers (some estimates say up to 50 per cent) are exempted from the requirements, and member states are allowed to set equivalent measures. Finally, the scope of support for rural development was reduced.38 Member states will be able to further reduce the scope of these programmes in order to top-up direct support.

It was argued that it was necessary to relax regionalisation of direct support and greening in order to continue to support farmers’ incomes and not to hinder the production potential in times of increased price volatility and growing global demand for food. However, as explained above, direct payments were mostly based on historical levels of production and support and not on farmers’ incomes.39 Due to their influence on investment into intensive technologies, they could even increase income volatility, not to mention their negative effects on the environment, which endangers the stability of long-term supply. The increased payments for young farmers will not reverse the fact that the majority of support will go to existing producers and landowners, thus hindering new entrants to the business.

The reform seems to have failed to meet the expectations with regard to better targeting of new objectives. The legislative changes proposed by the Commission were already conservative in terms of the distribution of funds among member states and among various types of support programmes.40 Regionalisation and the greening of the direct payments represented the most innovative part of the proposal, which was of significant importance for the Commission.41 In accordance with the estimated allocation of CAP support, the position of big past beneficiaries such as Spain, Ireland, Italy and France remained unchanged, demonstrating the implications of veto power, which enabled these countries to block any substantial changes to the CAP budget. The new member states, where direct payments were only being phased in, had to accept the largest reduction of funds, with the exception of the Baltic countries, whose positions improved due to the external convergence mechanism.42

During budget negotiations, a strong conservative coalition emerged in the Council which opposed regionalisation and greening. An important role was played by the alliance between France and Germany, with the latter defending relatively conservative interests.43 Simultaneously, the European Parliament started to prepare its own negotiating position. Since this was its first opportunity to co-decide on the CAP reform, it was eager to make a difference. The process was heavily influenced by rapporteurs, being the key members of the Agricultural Committee that defended interests similar to those of the conservative member states and agricultural lobbies. Their intention was to draft Parliament amendments, take advantage of the number of different views to acquire general support in order to start inter-institutional negotiations and then to present the outcome as a take-it-or-leave-it choice to the rest of the Parliament. In this context, conservative member states, seconded by the Irish presidency, managed to negotiate a non-ambitious position of the lowest common denominator. Even though the plenary in the Parliament did vote on its negotiating position, most of the conservative elements introduced by the Agricultural Committee remained. Furthermore, Parliament decided to reject the financial framework, pressuring for its interests to be taken into account.44

During the trialogues, the Commission basically tried to defend the principles of regionalisation and greening but gave up on their real effects.45 Due to the conservative position of the Parliament, the Commission was unable to seek a qualified majority in the Council that would support a more substantial reform. The Parliament’s persistence enabled it to introduce further setbacks to what had been agreed to in the Council. Finally, it was able to enforce changes to the financial provision of the agreement, where reformists had to accept a (substantially reduced) version of capping. On many occasions, it seemed as if the conservative alliance was taking advantage of the Parliament’s position in order to further relax the agreement reached in the Council. Realising the negative perception of their role, the members of Parliament ultimately supported higher co-financing rates for rural development programmes. An important role was played by timing – by blocking and postponing decisions between parliamentarians and the Council, the implementation of the reformed CAP was delayed by one year.

The trap produced by the introduction of the co-decision procedure is not an optimistic prospect for future reforms. However, the role of the European Parliament depends on its preferences; with a more liberal-reformist majority, the Parliament could not have exerted so much influence on the negotiations. The dominant role played by the Agricultural Committee, where conservative interests were overrepresented, could be mitigated by simply improving the transparency of the process and by improving the flow of information. Non-agricultural non-governmental organisations, which have so far been mostly focused on the Commission and on national governments, will have to take into account that there is a new player in the CAP reform process.

• 1 J. Pokrivcak, C. Crombez, J. Swinnen: The Status Quo Bias and Reform of the Common Agricultural Policy: Impact of Voting Rules, the European Commission and External Changes, in: European Review of Agricultural Economics, Vol. 33, No. 4, 2006, pp. 562-90; C. Crombez: Institutional Reform and Agricultural Policy Reform, in: J.F.M. Swinnen (ed.): The Perfect Storm: The Political Economy of the Fischler Reforms of the Common Agricultural Policy, Brussels 2008, Centre for European Policy Studies, pp. 25-40.
• 2 J.F.M. Swinnen (ed.), op. cit.
• 3 C. Crombez, op. cit.
• 4 Here we refer to the term “joint-decision trap”, which was used by Scharpf to describe suboptimal decisions that result from veto-based procedures. See F.W. Scharpf: The Joint-Decision Trap. Lessons From German Federalism and European Integration, in: Public Administration, Vol. 66, No. 2, 1988, pp. 239-78.
• 5 H.W. Moyer, T.E. Josling: Agricultural policy reform. Politics and process in the EU and US in the 1990s, Aldershot 2002, Ashgate; I. Garzon: Reforming the CAP. History of a paradigm change, Houndmills, Basingstoke, Hampshire 2006, Palgrave Macmillan; J.F.M Swinnen (ed.), op. cit.
• 6 For a detailed analysis, see H.W. Moyer, T.E. Josling, op. cit.; I. Garzon, op. cit.; C. Daugbjerg, A. Swinbank: Curbing Agricultural Exceptionalism: The EU’s Response to External Challenge, in: The World Economy, Vol. 31, No. 5, 2008, pp. 631-52.
• 7 I. Garzon, op. cit.
• 8 At the end of the 2007-2013 period, only Germany, England, Northern Ireland and Finland applied the regional distribution scheme, apart from the new member states, which applied the Single Area Payment System. Direct supports were, to a certain extent, still supporting past producers and their production practices, thus hindering the market access of non-EU producers.
• 9 J.-C. Bureau: Where Is the Common Agricultural Policy Heading?, in: Intereconomics, Vol. 47, No. 6, 2012, pp. 316-321.
• 10 A. Matthews: Doha negotiations on agriculture and future of the WTO multilateral trade system, IIIS discussion paper No. 436, presented at the 135th European Association of Agricultural Economists’ Seminar, Belgrade, Serbia, 28-30 August 2013.
• 11 S. Tangermann: CAP Reform and the Future of Direct Payments, in: Intereconomics, Vol. 47, No. 6, 2012, pp. 321-326.
• 12 A. Matthews: Greening the Common Agricultural Policy Post-2013, in: Intereconomics, Vol. 47, No. 6, 2012, pp. 326-331.
• 13 M. Lovec, E. Erjavec: The common agricultural policy health check: time to check the health of the theory of the reform?, in: Journal of International Relations and Development, Vol. 16, No. 1, 2013, pp. 111-137.
• 14 European Commission: The Common Agricultural Policy after 2013, Public debate, Summary report, 17 October 2013.
• 15 European Commission: The CAP towards 2020: Meeting the food, natural resources and territorial challenges of the future, COM(2010) 672 final, Brussels, 18 November 2010.
• 16 Council of the EU: CAP reform: Presidency Progress Report, Brussels, 8 June 2012.
• 17 Government of France and Government of Germany: New challenges and expectation for food, biomass and environment, 14 September 2010.
• 18 European Parliament: Resolution on Investing in the future: a new Multiannual Financial Framework (MFF) for a competitive, sustainable and inclusive Europe, 2010/2211(INI), 8 June 2011.
• 19 Euractiv: Brussels outlines vision for ‘fairer’ EU farm policy, 19 November 2010.
• 20 European Commission: Proposal for a Regulation laying down the multiannual financial framework for the years 2014-2020, COM(2011) 398 final, Brussels, 29 June 2011.
• 21 European Commission: Proposal for a regulation establishing a common organisation of the markets in agricultural products (Single CMO Regulation), COM(2011) 626 final/2, Brussels, 19 October 2011.
• 22 European Commission: Proposal for a Regulation establishing rules for direct payments to farmers under support schemes within the framework of the CAP, COM(2011) 625 final/2, Brussels, 19 October 2011.
• 23 Proposed capping, after deduction of total labour costs: €150,000-200,000 (20%); €200,000-250,000 (40%); €250,000-300,000 (70%); > €300,000 (100%).
• 24 Agra Focus, November 2011, pp. 2-8.
• 25 Council of the EU: CAP reform: Presidency Progress Report, 17592/12, December 2012; Agra Focus, December 2012, pp. 7-10.
• 26 European Council: MFF 2014-2020, European Council Conclusions, EUCO 37/13, February 2013; Agra Focus, March 2013, p. 9.
• 27 Agra Focus, July 2012, p. 12; Agra Focus, December 2012, pp. 2, 15.
• 28 Euractiv: EU fallow farmland goal ‘absurd’, says German minister, 18 January 2013.
• 29 Council of the EU: 3232nd Council meeting, Agriculture and Fisheries, Press release, Brussels, 18-19 March 2013; Agra Focus, April 2013, pp. 2-3.
• 30 Euractiv: MEPs back a less green, more ‘flexible’ CAP, 25 January 2013.
• 31 Agra Focus, January 2013, pp. 13-15; European Parliament: Decision of 13 March 2013 on the opening of, and on the mandate for, inter-institutional negotiations on the proposal for regulations establishing rules for direct payments to farmers under support schemes within the framework of the CAP.
• 32 Agra Focus, March 2013, p. 15.
• 33 Agra Focus, April 2013, pp. 9, 11-12; May 2013, p. 5.
• 34 European Commission: Political agreement on new direction for common agricultural policy, Press release, IP/13/613, Brussels, 26 June 2013; Agra Focus, July 2013.
• 35 Council of the EU: Reform of the common agricultural policy. Final political agreement between EU institutions for MFF related issues, Press release, Brussels, 24 September 2013; European Commission: Reform of the Common Agricultural Policy (CAP): Political agreement reached on last remaining points, IP/13/864, Brussels, 24 September 2013; Agra Focus, September 2013, p. 2.
• 36 European Commission: Common Agricultural Policy towards 2020. Impact Assessment, Commission Staff Working Papers, SEC(2011) 1153 final/2, Brussels, 19 October 2011.
• 37 J.-C. Burreau, op. cit.
• 38 K. Hart, H. Menadue: Equivalence mechanisms used for complying with greening requirements under the new CAP, 2013, Institute for European Environmental Policy; Agra Focus, March 2013, p. 15.
• 39 S. Tangermann, op. cit.
• 40 G. Anania: The state of the play of the negotiations on the CAP post-2013, AIEAA, Parma, 6-7 June 2013.
• 41 J.-C. Burreau, op. cit.
• 42 Agra Focus, March 2013, p. 17.
• 43 Agra Focus, November 2012, p. 7.
• 44 European Parliament: Decision of 13 March 2013, op. cit.
• 45 Agra Focus, July 2013.