The European Parliament voted today to determine its position on two amending pieces of legislation proposed by the Commission that can significantly modify rules for Member States and farmers in the remaining years of the current CAP. One is the Omnibus Simplification Regulation COM (2025) 236 amending the CAP Strategic Plans Regulation 2021/2115 and the Common Market Organisation (CMO) Regulation 1308/2013, while the other is the proposal COM (2024) 577 to amend the CMO Regulation and some aspects of the Strategic Plans Regulation to strengthen farmers’ position in the food supply chain.
The context for these two proposals is, firstly, the general shift in Commission priorities to boost competitiveness, innovation and growth in the wake of the Draghi report. This report called for increased investment in innovation, a stronger Single Market through market integration, a greater focus on resilience and strategic autonomy for critical sectors like energy and raw materials, as well as a more supportive business environment by reducing regulatory burdens.
At the same time, the Commission proposals were a response to the farmer protests in spring 2024. These had already led to a relaxation of the GAEC standards farmers should observe to be eligible for CAP payments in Regulation (EU) 2024/1468. Agricultural Ministers called for further simplification in January 2025, to lower the burden on both farms and national administrations, again justified as a way to improve competitiveness of EU farms. The Commission proposal on strengthening farmers’ position in the food supply chain followed on from a Commission reflections paper published in March 2024 as well as taking up some proposals in the report of the Strategic Dialogue on the future of agriculture in September 2024.
The Council agreed its general position on the Supply Chain Regulation in May 2025 and its general position on the Simplification Regulation in September 2025. COMAGRI forwarded its report to the European Parliament plenary on the Supply Chain Regulation amendments (the Imart report) and its report (Rodrigues report) on the Simplification Regulation amendments last month. European Parliament procedure also allows amendments to be introduced directly on the floor of the plenary by the rapporteur or committee responsible, by political groups, and by individual MEPs. These amendments are found in the Texts Tabled page for the relevant reports (here for the Imart report and here for the Rodrigues report). The Parliament voted today on its positions on the two legislative acts. The trilogue process will now start between the two institutions to determine the final shape of each legislative act.
In this post, I summarise the Commission proposals and the main amendments proposed in the Council and Parliament positions. These positions are interesting not only in their own right, but also as an indication of how these institutions might respond to some of the Commission proposals in the CAP package for the next programming period 2028-2034. In preparing this post, I want to acknowledge the very useful briefings prepared by the European Parliament Research Service on the two pieces of legislation. The briefing on the Supply Chain Regulation amendments and the briefing on the Strategic Plan Regulation amendments can be found at these links.
Key amendments in the Simplification Regulation
I have grouped the Commission proposals into four groups:
- Further relaxation of GAEC conditionality
- Streamlining support requirements for farmers
- Greater possibilities to respond to crises
- More flexibility to Member States for management of the CAP Strategic Plans.
Where relevant, I note significant Council or COMAGRI amendments to the Commission proposals, though we need to keep in mind that any differences here will need to be thrashed out in the trilogue process and not all these amendments will ultimately be agreed.
Further relaxation of GAEC conditionality
GAEC 1. This standard that aims to maintain the permanent grassland ratio would be made more flexible. The current rule is that the ratio of permanent grassland to agricultural area on the national, regional or other level decided by Member States cannot decrease by more than 5% compared with 2018. The proposal would increase this maximum to 10%. There is also a proposed change to allow Member States to prolong the time it takes for grassland to be considered permanent from five to seven years or more, to discourage farmers from ploughing grassland after five years to keep it as arable land.
GAEC 2. Member States would be allowed to cover costs related to the implementation of this GAEC, aiming to protect peatlands and wetlands, by excluding it from the baseline of eco-schemes and agri-environment-climate commitments. This prefigures the opening in the post-2027 CAP Regulation to allow Member States to compensate farmers for the cost of implementing any of the GAEC standards (called ‘protective practices’ in the new Commission proposal).
GAEC 4. The ban on the use of pesticides and fertilisers within at least three metres of watercourses as a general rule would stay, but Member States would be able to define watercourses in line with their national legislation, provided that that definition is in line with the main objective of this GAEC standard. An amendment by the Renew group to qualify the extent to which Member States could define the watercourses affected and to require Commission approval for the definition was rejected.
GAEC 7. The Parliament proposes an amendment that farmers whose entire holding is less 50 ha shall be deemed to comply with the three-crop rule per GAEC standard 7, while the 2-crop rule should be removed entirely.
Organic farmers. Farms certified as organic in their entirety would be automatically considered to comply with GAEC 1 on the maintenance of permanent grassland, GAEC 3 on the ban on burning arable stubble, GAEC 4 on the establishment of buffer strips along water courses, GAEC 5 on tillage management, GAEC 6 on minimum soil cover, in addition to GAEC standard 7 on crop rotation.
The Council position would leave it up to Member States whether farmers certified for part of their holdings should be deemed compliant with these GAEC standards in this way. The Parliament amendment would extend this provision automatically also to organic farmers in conversion and to farmers with part of their holding managed organically, as well as to farmers who have parts of their holdings in Special Areas of Conservation or Special Protection Areas. It also proposes an amendment to extend this automatic compliance to any farmer “involved in other sustainable production methods, such as integrated farming, and those who apply integrated management in an accredited manner.” The absence of any formal definition of these terms in the Regulation would seem to make it risky to adopt this amendment in the trilogues.
Controls and checks on farmers: Member States would be required ‘to the extent possible and taking account of the associated risks’ not to perform more than one on-the-spot check of a farm in a given year.
Social conditionality. Small farmers would be exempted from the application of the system of social conditionality.
The Parliament also requests the Commission to present a report on the implementation of social conditionality by Member States to assess its effectiveness and impact by 31 December 2026. The current Regulation has a rendez-vous clause outlined in a Joint Statement by the Council and Parliament mandating such a study in 2027, so the Parliament amendment would bring that forward by one year.
Streamlining support requirements for farmers
Small farmer intervention made more attractive. The option to make a lump-sum payment to small farmers following a simpler application process was not taken up by many Member States. Therefore, the Commission proposal increases the maximum possible lump-sum payment for participating farmers to €2,500. In addition, it is proposed that Member States have the possibility to allow farmers benefitting from the lump-sum payment to apply for payments under eco-schemes. The Parliament would increase the limit to €5,000.
Business development of small farms: A new type of installation aid under the rural development interventions would be created. Member States would have an option to support small farms with a one-off payment of up to €50,000 for business development.
Increased flexibility for eco-scheme and AECM payments. Payments for eco-schemes for animal welfare commitments, commitments combating antimicrobial resistance, commitments for agricultural practices beneficial for the climate and commitments to convert to or maintain organic farming practices and methods could be paid per livestock unit or per beehive, not only per hectare. The same would apply to agri-environment commitments that are beneficial for the climate and commitments to convert to or maintain organic farming practices and methods under the rural development interventions.
Potential for increased support for Producer Organisations in the fruit and vegetable sectors. The limits on the amount of financial support these POs can receive for operational programmes can be increased for certain interventions, subject to fulfilment of certain conditions.
Remove taxation of direct payments. The Parliament introduces an amendment that direct payments should not be subject to tax in Member States. This is a rather extraordinary amendment that one assumes has no chance of being agreed in the trilogues as it extends well beyond the competences of the Union. A Council amendment that the first tranche of advance direct payments paid to farmers in a calendar year should be increased from 50% to 75% (which is now regularly requested as a derogation by Member States) has greater likelihood of success.
New possibilities to respond to crises
I have previously discussed the Commission proposal with respect to crisis aid in this blog post. Two main changes are proposed. One is a matter of principle, namely, that the agricultural crisis reserve in future should be reserved only to address crises due to market disturbances and should not be used to help with natural disasters and adverse climate events. The other change is to introduce two new complementary crisis payment interventions, to be funded by reallocating part of a Member State’s direct payments ceiling and rural development ceiling, respectively, which Member States could use in case of natural disasters and adverse climate events. Maximum limits are proposed for these new payments so that they do not have a disproportionate impact on other interventions in the CAP Plans. These new payments would be excluded from the scope of application of the conditionality system and social conditionality system. To increase the potential impact of such payments, provisions are introduced to enable paying national financing of up to 200%.
Both the Council and COMAGRI have adopted a coordinated position to eliminate the proposal to create a complementary crisis payment using part of a Member State’s direct payments ceiling. This mirrors the reluctance in the previous CAP programming period to using the crisis reserve when it meant reducing payments to one group of farmers to make payments to another group. Re-allocating payments from the CAP Pillar 2 rural development fund is easier as they are not pre-allocated to individual farmers.
The Parliament, in addition, pushes back on the Commission proposal not to use the agricultural crisis reserve to address natural disasters and adverse climate events by proposing to delete this proposal. This element is central to the crisis architecture proposed for the post-2027 CAP (see my previous blog post), so it will be interesting to see whether this amendment survives in the trilogues.
Risk management. Experience shows a low use of the possibility to use a part of the direct payments of farmers as contributions to risk management schemes. To further help the take-up of such schemes, the Commission proposal relaxes the rules for some farmers when calculating when a farmer can receive support. The current Regulation allows Member States to provide support through risk management schemes to farmers that experience losses that exceed 20% of annual production or income in a three-year period. A Parliament amendment would reduce that further to 15%.
More flexibility to Member States for management of CAP Strategic Plans
Reduced need for Commission approval of Plan amendments. To simplify amendment procedures, approval by the Commission should be required only for strategic amendments of CAP Strategic Plans. What is meant by strategic amendments is defined in the proposed amendment.
Annual performance clearance. In the light of the experience gained after the first annual performance clearance exercise for financial year 2023, the Commission proposes to discontinue the annual performance clearance to ease the administrative burden upon Member States.
Elimination of requirement to update the Strategic Plans Regulation to new legislative acts. The Regulation currently requires that the list of Union legislative acts concerning the environment and climate is updated and taken as the basis by Member States to assess whether their CAP Strategic Plans should be amended. These provisions would be deleted “to ensure stability of the Union legal framework until the end of the programming period.” A proposal from the Socialist and Democrats group in the Parliament plenary to delete this Commission proposal was defeated.
CAP data and interoperability governance. The Commission has noted the absence of coordination structures at Member State level, as well as differences in digital transition among Member States, which hinder the effective implementation of interoperability, including seamless exchange of data, between information systems used for the implementation, monitoring and evaluation of the CAP. It therefore proposes provisions to ensure that each Member State designates one authority responsible for drawing up and implementing a roadmap to achieve and maintain interoperability and seamless exchange of data. To the extent possible, Member States shall base their assessment of needs and the design of the measures on the principle that data is collected only once and re-used. The Parliament would strengthen that to require that data provided by farmers and other CAP beneficiaries is collected only once and reused across information systems.
Perhaps not surprisingly, the Agricultural Ministers do not like this provision and propose to delete it. However, the issue of data interoperability is central to the Commission’s vision of how monitoring of the CAP would be implemented in the post-2027 programming period, and it would make sense for Member States to be preparing for that as early as possible.
Key amendments to the Regulation to strengthen farmers’ position in the food supply chain (Supply Chain Regulation)
Here, I summarise the Commission proposals under four headings. In addition, the Parliament has made use of the opportunity to propose additional amendments:
- Minimum requirements for optional terms describing supply chain characteristics
- Extended requirement for written contracts
- Strengthened role for Producer Organisations and operational programmes
- Additional scope for sustainability requirements
Minimum requirements for optional terms describing supply chain characteristics
It is proposed to explicitly define the conditions for use of terms such as ‘fair’, ‘equitable’ or equivalent terms. These are set out as the following:
(a) stability and transparency in the relations of farmers with purchasers along the supply chain,
(b) a price considered equitable by participating farmers for their products, and
(c) collective initiatives pursuing one or several of the United Nations Sustainable Development Goals.
Determining whether these criteria are met seems very subjective, and the Commission is given the power to adopt implementing acts to further define these conditions. The Parliament agrees that these criteria are vague and risk weakening more demanding national systems, but its own amendments seeking to clarify these criteria are not any more precise. An amendment to require that the use of these terms should be subject to a certification scheme was defeated.
The term ‘short supply chain’ will also be explicitly confined to situations where there is a direct relationship between farmers and consumers, including by means of distance communication or via an intermediary that facilitates direct exchange at the moment of sale. Alternatively, the term can be used where a close connection between farmers and consumers within their geographic proximity exists, including in cross-border contexts. The hope is that this will incentivise consumers to pay prices that give a higher return to farmers that engage in short supply chain channels.
The Parliament again notes a certain vagueness about these definitions. It proposes that the number of intermediaries should be limited, that geographic proximity should be specified to include distances or transport times as criteria, and that only European production should be eligible. The Council amendment would only allow one intermediary in the chain, again provided that the direct connection between the farmer and consumer is maintained.
Extended requirements for written contracts
Written contracts will be mandatory. Under the current CMO Regulation, written contracts between farmers or their organisations and first buyers are only mandatory in the sugar sector. For milk and all other agricultural products, they are mandatory only where Member States have opted for this, although deliveries by a producer to their co-op or to a small or medium-sized enterprise are exempted (Art. 148 and Art. 168, CMO Regulation). Written contracts are required to fulfil certain conditions. Where written contracts are not mandatory, any producer, Producer Organisation or Association of Producer Organisations can require a first purchaser to offer a written contract. And it is a prohibited practice under the Unfair Trading Practices (UTP) Directive for a buyer to refuse to confirm in writing the terms of a supply agreement for which the supplier has asked for written confirmation.
However, the recitals to the Commission proposal suggest that due to the weaker bargaining position of farmers and the fear of commercial retaliation by purchasers, it can be difficult for farmers and their associations to make such a request. Yet relatively few Member States have availed of the option to require written contracts. Thus, the new proposal would make written contracts mandatory for all transactions between buyers and farmers, with certain additional exemptions such as sales to a producer’s own producer organisation or co-operative, low value sales, seasonal or perishable products, as well as sales to micro- or small-sized enterprises.
In the Parliament’s plenary session, there was a significant effort by MEPs from the EPP group to roll back this provision and to leave it optional for Member States whether to require written contracts or not. Their amendments to this effect were defeated.
The Commission proposal would make it mandatory for the first purchasers of any agricultural product (sugar has its own rules) to make a written offer for its delivery. The Parliament would amend that to make it the obligation of producer organisations, associations of producer organisations or farmers to make a written offer for a contract for any agricultural product leaving sugar aside.
The content of written contracts. Mandatory written contracts must fulfil certain conditions under the current CMO Regulation. The price must be stated, either as a fixed price or in terms of the variables that go into determining the price. It should also cover the volumes that may/must be delivered and their timing, the duration of the contract (which can be indefinite with termination clauses), and details regarding payment periods and procedures.
Under the new proposal, where the price is based on a formula comprising several indicators, to avoid that farmers are forced to sell systematically below their production costs, the indicators, indices and methods of calculation of the final price shall reflect changes in market conditions and production costs of the agricultural products delivered. Contracts with a duration of more than 6 months should include a revision clause that may be triggered by the farmers and their organisations.
The Council amendment would increase the length of contract for which a revision clause should be included to 12 months. The Parliament proposes to add a recital that “The final price should cover the full production costs including fair remuneration of producers and total costs for additional services” but its amendment to the relevant Article remains aspirational. It would also allow the revision of contracts at any time in light of unforeseen circumstances such as extreme weather events or geopolitical tensions that adversely affect the ability of the agreed price to cover farmers’ costs.
Mediation mechanisms. The current CMO Regulation allows Member States to establish a mediation mechanism to cover cases in which there is no mutual agreement to conclude a written contract. The Commisison proposal would make it mandatory for Member States to establish mediation mechanisms. A Council amendment would leave this optional for Member States. A Parliament amendment would make the use of such a mediation mechanism voluntary for both parties.
Strengthened role for Producer Organisations (POs) and operational programmes
Easier recognition for certain POs. The proposal explicitly recognises that POs can be formed between organic producers, be constituted by producers from multiple and not only a single sector, while POs that pursue initiatives promoting short supply chains or the use of optional terms such as ‘fair’ or ‘equitable’ can also be recognised. The Parliament would remove the reference to making specific provision for the creation of POs among organic producers, arguing that they can use the existing mechanisms to enhance their collaboration.
Strengthened collective bargaining rights. A major benefit of being a recognised PO is that it can plan production and negotiate contracts and prices on behalf of its members without fear of falling foul of competition law. This possibility of negotiating contract terms on behalf of their members would be extended to non-recognised producer organisations, including cooperatives, for some or all of their production, provided they meet the criteria for recognition. Recognised associations of producer organisations would also be allowed to negotiate contract terms on behalf of their members, including price, for some or all of their members’ production. This possibility should be allowed provided that the volume of products covered by the activities of the association does not exceed 33% of the total national production of any given Member State.
The Council would eliminate the possibility for non-recognised POs to get equivalent privileges to negotiate contract terms and prices. The Parliament would require non-recognised POs to be in the process of seeking recognition to benefit from this provision.
Increased financial support for operational programmes. Operational programmes are defined in the Strategic Plans Regulation. They are drawn up and implemented by POs for a wide array of possible objectives and co-financed by CAP funding. The new proposal would allow Member States to use more of their direct payment ceiling (up to 6%) to support POs implementing operational programmes. Increased co-financing would be available to support operational programmes in the fruit and vegetables sector in Member States with a very low degree of organisation of producers.
The proposal also introduces the possibility that crisis measures undertaken by POs, such as the withdrawal of product from the market during periods of market imbalance, could be funded by the agricultural crisis reserve.
Additional scope for sustainability requirements
Social sustainability objectives. Under the current CMO Regulation, agreements to apply a sustainability standard contributing to certain objectives (environment, animal health and welfare) higher than that mandated by law are exempted from competition law. The new proposal would add social sustainability objectives to the list, namely, supporting the economic viability of small farms relying mainly on family labour; attracting and supporting young producers; and improving working and safety conditions in production and processing.
Additional Parliament amendments
Revision of support prices. One amendment concerns the obligation on the Commission to keep reference thresholds under review (these are reference prices used as signals for market conditions and potential EU market interventions). The Parliament amendment would give the EU Agri-Food Chain Observatory the power to call for a review and would require the Commission to develop a methodology on which to base a review, based on objective indicators such as inflation, production costs and changes on agricultural markets. It would extend the list of products eligible for public intervention (currently limited to certain cereals including rice, beef, butter and skimmed milk powder) to include white sugar, sheepmeat, pigmeat, and poultrymeat. It would also require the Council, when setting intervention prices, to use objective and transparent criteria in line with the objective of ensuring a fair standard of living for the agricultural community.
Support for voluntary supply reduction measures. The Parliament also seeks to amend Article 219 of the CMO Regulation to require the Commission to implement support measures for producers in a sector where the market price has fallen below a certain flexible threshold set by the Agri-food Chain Observatory (AFCO) and who voluntarily agree to reduce their production according to a schema designed by the AFCO, with a corresponding additional levy on producers who increase their production over the reference period.
Market disturbance management plans. The Parliament also introduces a new article that would require the Commission to draw up a market disturbance prevention and management plan for each agricultural product covered by the CMO Regulation, setting out its intervention strategy to stabilise each market in the event of a disturbance. It should provide a report detailing how it has implemented these plans each year, evaluating their impact, effectiveness and the coherence of the tools it has used.
Prohibition on use of meat terms for products if not produced from animals in traditional ways. This amendment proposed by Parliament is justified by the argument that this protection is needed to avoid consumers being misled by terms such as ‘plant-based burger’ or ‘vegan sausage’. It would confine the use of meat-related terms currently used for meat, meat cuts, meat preparations and meat products exclusively for the edible parts of animals. The amendment includes an open-ended list of example terms including steak, escalope, sausage, burger, hamburger, egg yolk and egg white (despite the latter two terms not having anything to do with meat, which refers to the edible parts of animals). It would also ban the use of these terms for cell-cultured products.
The Commission in its post-2027 CAP proposal also proposes to limit the use of meat-related terms but using a different classification. It proposes (in an amendment to Annex VII of the CMO Regulation) to reserve 29 terms for products derived exclusively from meat at all stages of marketing. Unlike the Parliament’s amendment, which would ban functional or form-based meat product terms (e.g. burger, sausage) except when used in connection with the edible parts of animals, the Commission’s proposal would ban the use of the names of meats themselves (e.g. beef, turkey, mutton), together with some product terms, such as T-bone, brisket or wing for non-animal products. An amendment put forward by the Renew group would have moved the Parliament’s position closer to that of the Commission but it was defeated.
Conclusions
Having itemised the state of play on the issues addressed in the two Commission proposals and the topics to be resolved in the trilogue negotiations that will now start, my assessment is that the Commission proposals themselves are rather underwhelming and represent minor adjustments rather than a radical restructuring of the CAP.
When the Simplification Regulation was published, the elements that attracted the attention of environmental NGOs were the further potential weakening of the GAEC standards. The European Environment Bureau saw ‘sweeping revisions’ that would mean that nature and climate protection takes another major hit. Birdlife Europe saw another ‘rollback for nature and farming’. But much of the criticism was against the symbolism of the proposal. What the substantive implications might be are less clear.
For the GAEC 2 standard that requires the protection of wetlands and peatlands, the change does not change the obligations themselves but allows Member States to compensate farmers for any costs incurred in meeting this obligation. At face value, this should improve compliance with the measure in Member States that take up this option.
It is unclear what substantive changes are involved in the modification of GAEC 4 to allow Member States to use their national definition of a watercourse in applying the standard. The Commission has never given a definition of a watercourse and there are already significant differences in the Member State definitions. The fear is that Member States may exclude small or intermittent watercourses that still carry pollutants downstream. It is not clear to me whether these are included under current rules or not. Ultimately, the binding constraint on Member States is the obligation in the Water Framework Directive that all surface water and groundwater bodies achieve good ecological status (for surface waters), good chemical status (for surface and groundwater) and good quantitative status (for groundwater) by 2027.
The substantive impact of increasing the threshold for action in the GAEC 1 standard designed to maintain the ratio of grassland to cropland is also unclear. Converting grassland to cropland releases soil carbon (though if it results in fewer ruminant animals, it will also reduce non-CO2 emissions). It is not clear how many Member States are close to reaching the 5% limit in the current programming period, nor how many would make use of the additional flexibility to convert up to 10% of their grassland. Eurostat statistics at EU level show that the permanent grassland percentage has fluctuated around a constant figure (it is lower in 2020 than in 2016 but higher than in 2013) but this does not rule out larger changes at national or regional levels. Not knowing what the impact of this measure might be, and which farmers in which countries might benefit from it, clearly leads to disquiet about its potential effects.
The major change in the Regulation on strengthening farmers’ position in the supply chain is the requirement for all Member States to require written contracts for all purchases of agricultural products from farmers or their organisations. Despite this option in the current Regulation, relatively few Member States have taken it up, so this will be a significant change. Unlike the Simplification Regulation, the Supply Chain Regulation was accompanied by a staff working document that, if not a formal impact assessment, nonetheless presented a justification for the measures proposed. The proposal to formalise contracts in writing is expected to provide benefits in terms of greater transparency and predictability of the terms agreed and to reduce asymmetric price transmission along the supply chain. At the same time, the Commission is realistic that written contracts alone are not likely to substantially rebalance bargaining power or address underlying market imbalances.
Written contracts are likely to introduce additional compliance costs for both farmers and buyers, which appears to run counter to the deregulatory agenda of the current Commission. It is possibly for this reason that a significant number of EPP MEPs proposed a series of amendments in plenary today that sought to remove the mandatory requirement for a written contract and to maintain the status quo where it is up to the individual Member State to decide whether written contracts should be mandatory or not. In view of the many benefits to farmers spelled out in the Commission’s staff working document, this attempt to remove the single most significant change in the draft Regulation to strengthen farmers’ bargaining power was surprising, to say the least. The series of amendments by these EPP MEPs was voted down.
Finally, I note the way in which the Parliament used the opportunity to introduce amendments to the CMO Regulation which went beyond the immediate focus on strengthening farmers’ bargaining power. The most controversial of these was undoubtedly Amendment 113 prohibiting the use of meat-related terms except for edible parts of animals. Organisations representing plant-based foods such as the European Vegetarian Union reject the claim that consumers are misled by the use of these terms, so the Parliament’s position seems driven by the fears of the livestock sector and the desire to protect it rather than by any intent to protect consumers. The Commission has already acceded to the principle of limiting the use of meat-related terms in its post-2027 CAP proposal, albeit in a different and less intrusive way (while terms such as ‘vegan sausage’ or ‘plant-based burger’ have become widely accepted and generally understood, I cannot think of anyone crazy enough to try to market a product as ‘vegan beef’ or ‘plant-based duck’, terms which the Commission proposes to ban). There could well be a majority of Agriculture Ministers who would be willing to support the Parliament amendment in the trilogues. So yet more regulation put in the way of innovation by a political majority that claims to want the opposite.
This post was written by Alan Matthews.
Photo credit: Jardin du Luxembourg, Paris, own photo.
Update 9 Oct 2025. Added the EP amendment on GAEC 7.
