La UE ultima la aprobación de la Directiva sobre prácticas desleales en la Cadena Alimentaria

https://mailchi.mp/cms-asl.com/alerta-productos-de-consumo-novedades-enero-2019-2133233?e=ade680c64d

El Parlamento Europeo ha dado luz verde a la negociación final de la propuesta de Directiva Europea relativa a las prácticas comerciales desleales en las relaciones entre empresas en la cadena de suministro alimentario (la propuesta de Directiva), que tanto revuelo está causando en el sector. 

Mediante esa Directiva, la Comisión Europea (CE) propone prohibir las prácticas comerciales desleales más perjudiciales en la cadena de suministro con el fin de garantizar “un trato más justo para las pymes alimentarias agrícolas”. 

En particular, la Directiva contempla la prohibición de (i) las demoras en los pagos de productos perecederos, (ii) las cancelaciones de última hora, (iii) las modificaciones unilaterales o retroactivas de los contratos y (iv) la posibilidad de obligar al proveedor a hacerse cargo de los gastos de los productos perdidos. 

Además, otras prácticas solo se permitirán si están sujetas a un acuerdo previo, claro y sin ambigüedades, entre las partes. Entre otros, que el comprador devuelva productos alimenticios no vendidos al proveedor o que cargue al proveedor unos gastos por asegurar o mantener un acuerdo de suministro de productos alimenticios; o que el proveedor corra con los gastos de promoción o comercialización de los productos alimenticios vendidos por el comprador. 

La propuesta incluye asimismo disposiciones para garantizar su aplicación, como la capacidad de las autoridades nacionales de imponer sanciones en casos de infracción. En concreto, los organismos de control del cumplimiento deberán disponer de los poderes necesarios para abrir una investigación por iniciativa propia o sobre la base de una denuncia, recabar información, poner término a una infracción e imponer sanciones y publicar las decisiones adoptadas para que tengan un efecto disuasorio. 

Cabe resaltar que la ley española de medidas para mejorar el funcionamiento de la cadena alimentaria (Ley 12/2013)  (“LCA”), que se adoptó con el fin de proteger a las pequeñas y medianas empresas en las negociaciones con los grandes grupos industriales españoles e internacionales, incluye ya varias de las disposiciones contempladas por la nueva Directiva. 

Así, la LCA iría incluso más allá que las medidas incluidas en la propuesta de Directiva, dado que, en España, existe la obligación de formalizar por escrito las relaciones comerciales que afectan a la contratación, así como de incluir expresamente en los contratos sus elementos esenciales (identificación de las partes, objeto, precio, condiciones de pago, entrega de productos, derechos y obligaciones, duración y causas y efectos de la extinción). 

En todo caso, hay ciertos aspectos de la propuesta de Directiva que, de adoptarse, mejorarían el sistema actual, por ejemplo, la posibilidad de presentar una denuncia de forma anónima, o la obligación de publicar las multas adoptadas por los organismos encargados de velar por el cumplimiento de las normas establecidas por la Directiva, garantizando así el efecto disuasorio de las sanciones –que, a día de hoy, no se conocen–.

Por último, cabe resaltar que España ha solicitado incluir una prohibición general de la venta a pérdida en la Directiva, como la que contemplaba la Ley de Ordenación de Comercio Minorista y que fue declarada contraria a la Directiva 2005/29/CE relativa a las prácticas comerciales desleales de las empresas en sus relaciones con los consumidores en el mercado interiorpor el Tribunal General de la Unión Europea (TGUE) en su sentencia de 19 de octubre de 2017 en el caso Europamur Alimentación. 

A este último respecto, el Gobierno de España publicó, el 7 de diciembre de 2018, el Real Decreto-Ley 20/2018, de medidas urgentes para el impulso de la competitividad económica en el sector de la industria y el comercio en España, por el que adapta la Ley de Ordenación del Comercio Minorista a lo dispuesto en el caso Europamur y a la Directiva de prácticas comerciales desleales. Para más información en este sentido, ver aquí.

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Kraft Heinz's recipe turns sour

Source: https://www.just-food.com/alerts/viewmail.aspx?id=106134&list=2

It's fair to say your correspondent’s jaw almost hit his keyboard yesterday when Kraft Heinz made its latest stock-market filing.

The Kraft cheese, Heinz ketchup and Oscar Mayer meats maker raised eyebrows across the industry, with a multi-faceted announcement that included an SEC probe into the company’s procurement, fourth-quarter profits that missed expectations, an outlook for 2019 that also disappointed Wall Street and the small matter of a US$15bn write-down on certain assets.

Shares in Kraft Heinz tumbled post the closing bell being rung in New York yesterday and they've continued to slide today, down more than 27% at the time of writing.

"Our model is working," Kraft Heinz CEO Bernardo Hees insisted as he spoke to stunned analysts after the announcement.

But such an announcement will naturally prompt questions about the strategy of Kraft Heinz and its owners Berkshire Hathaway and 3G Capital. Kraft Heinz's modus operandi has been built on M&A and then driving synergies from the transactions to grow margins. 

Its margin improvement has been strong – and has in recent years prompted almost all listed majors to take long, hard looks at their own cost base. 

However, the question about Kraft Heinz has always been about its long-term growth. Savings can only go so far. Management has, in recent quarters, sought to emphasise the work the company was putting in to try to grow its sales. On an organic basis, Kraft Heinz's sales grew 2.4% in the fourth quarter year-on-year.

Nevertheless, Kraft Heinz is facing questions on Wall Street a

bout its strategy. "All said, while a challenging industry backdrop is likely partly to blame, frankly, we believe some of Kraft Heinz's issues are distinct," Barclays analyst Andrew Lazar wrote today.

It also appears clear the fabled 3G model of M&A plus synergies equalling profits and returns to investors has not proved the right recipe for a business laden with centre-store, legacy brands facing a squeeze from the rise of private label in its home market on one side and, in the US and in a number of markets around the world, the growing popularity of smaller, more agile, on-trend insurgent brands on the other.

New EU Food Law Raises Bar to Protect Confidential Business Information

By Laura van der Meer and Dan Nobil on February 19, 2019 

The U.S. and other companies that export foods, additives, colorings, etc. to the European Union (EU) should take notice: new legislation applicable to the agri-food industry is being billed as one of the world’s “most transparent” laws raising potential concerns about protecting proprietary information from competitors.  Controversy surrounding the use of genetically modified organisms and the associated herbicide glyphosate paved the way for a European citizens’ initiative, which ultimately led to a legislative proposal by the European Commission to enhance public confidence in risk assessment of foods.  The ensuing regulation on the transparency and sustainability of the EU risk assessment in the food chain will amend the EU’s General Food Law Regulation, a law that was adopted following a series of food incidents in the late 1990s.

The revised regulation aims to ensure that market approvals related to the food chain by the European Food Safety Authority (EFSA) are founded on reliable, objective and independent studies and risk analysis.  It will entail automatic publication of all studies and information submitted to EFSA to support the authorization of a proposed product or ingredient.  It appears that this data will be uploaded early in the approval process, a decision opposed by industry groups.  In addition, the law will establish a database of studies for EFSA to verify whether all relevant research on a substance is considered in evaluating market applications.  The intent is to deter corporations from withholding unfavorable data.  In addition, stakeholders and the general public will be invited to join consultations to help identify any omitted information and ensure EFSA’s comprehensive access to evidence.

For obvious reasons, negotiation of the new legislation was plagued by thorny issues around business information as the legislators struggled to strike a balance between the protection of intellectual rights and commerce and exposing business secrets in a more transparent risk assessment process.  The final acquired text is not yet publicly available but it appears that confidentiality of information will be able to be maintained where companies provide a “verifiable” justification for doing so.  According to a document reportedly seen by Politico, companies will be able to seek confidential treatment of information on: “the manufacturing or production process, including the method and innovative aspects thereof, as well as other technical and industrial specifications inherent to that process or method, except for information which is relevant to the assessment of safety.”                                                                                                         

Posted in European Union (EU), Foods and Beverages, Imports/Exports
https://www.fooddruglaw.com/2019/02/19/new-eu-food-law-raises-bar-to-protect-confidential-business-information/#page=1

                                                                                                                                                    

The revised regulation requires formal approval of the European Parliament and the Council of the EU.  It is scheduled to take effect 20 days after its publication, however, operative provisions will be delayed for some time to come.

No-deal Brexit threat: Gove admits ‘no absolute guarantee’ food trade with EU will continue

Food Navigator.com [William Reed] News & Analysis on Food & Beverage Development - Europe

By Katy Askew

The UK has said it will extend the deadline on some food policy consultations as Environment Secretary Michael Gove admits a no-deal exit from the EU could see an immediate halt to food trade with the bloc.

https://www.foodnavigator.com/News/Policy/No-deal-Brexit-threat-Gove-admits-no-absolute-guarantee-food-trade-with-EU-will-continue?utm_source=copyright&utm_medium=OnSite&utm_campaign=copyright


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‘Cocoapolitics and Choconomics’, the main themes of Amsterdam’s Chocoa Conference

Confectionery News.com - News & Analysis on Chocolate, Candy and Biscuits

By Anthony Myers

The economics and politics of cocoa are will be the main talking points when the 2019 Chocoa Conference opens on Thursday to provide a platform for sustainability and quality and a direct connection to the market through its Cocoa Fair.

https://www.confectionerynews.com/Article/2019/02/19/Cocoapolitics-and-Choconomics-the-main-themes-of-Amsterdam-s-Chocoa-Conference?utm_source=copyright&utm_medium=OnSite&utm_campaign=copyright

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No-Deal Brexit Does Not Have to Mean Non-Compliance for Your Products

by Raminta Dereskeviciute, Clare Reynolds

18 February 2019

With less than six weeks left to the 29 March deadline - and little political consensus, the possibility of a ‘no-deal’ Brexit and the UK crashing out of the customs union and becoming a ‘third country’ increases. If your business manufactures, exports or imports, distributes, or otherwise deals in consumer or industrial products in the UK or the EU, you may need to take steps now to ensure that your products remain compliant under applicable UK and EU law in the event of a no-deal Brexit.

The requirements for placing products on the UK and EU markets (including conformity assessments, marking and labelling) will change overnight unless a deal transitional arrangements or otherwise an extension is agreed before the 29 March deadline. In case of a ‘no-deal’ scenario, the following issues in particular may need to be addressed in respect of product trading in the EU or the UK post-Brexit:

CE marking and conformity assessment - EU market: 

The consequences of the UK’s withdrawal for trading within the EU-27 will depend upon the particular product type and specific conformity assessment procedure, and importantly, whether that product was placed on the EU-27 market before the withdrawal date. Products not placed on the EU-27 market before this date may need to be re-certified, re-labelled or modified in order to trade within the EU post withdrawal. 

In particular, for products where the applicable conformity assessment procedures require intervention by a notified body, UK notified bodies will lose their status as EU recognised bodies. Unless such products have been placed on the EU-27 market before the withdrawal date, the European Commission advises operators to consider obtaining a new certificate from (or arrange for a transfer of the certificate to) an EU recognised notified body. How this works in practice will depend on the specific conformity assessment procedure for the applicable product,although the European Commission advises that any transfer of certificates would need to take place before the withdrawal date.

Where manufacturers place a CE mark on products on the basis of a self-declaration that the product is compliant, this declaration will remain valid when exporting to the EU. 

CE marking and conformity assessment - UK market: 

Goods already placed on the UK market by 29 March 2019 can continue to be lawfully circulated on the UK market. For goods placed on the market after the withdrawal date, the UK Government has unveiled a new logo to replace the CE mark in the UK, dubbed the “UKCA” (“UK Conformity Assessed”), which would require companies to change their product packaging, advertising and labelling at additional cost for manufacturers. Goods made in the UK for export to the EU may need to be stamped with both the CE and UKCA marks. There is still a lot of uncertainty about how the UKCA will work in practice; whilst the government may in time grant concessions to industry, significant disruption for businesses is inevitable.

Economic operators established in the EU: 

UK-based importers and manufacturers will no longer be considered as “economic operators established in the Union” under the EU’s product legislation following Brexit. For products entering the EU post Brexit, EU distributors who previously relied on UK economic operators will become “importers” for the purposes of EU law when making the products available on the EU market for the first time. This will require them to meet more stringent obligations in relation to product compliance. For example, EU legislation generally requires the contact details of the importer or manufacturer to be provided on the product itself or its label, which may need to be updated where this previously referred to a UK-based party.

Authorised representatives and responsible persons: 

Certain EU product legislation requires the appointment of an authorised representative (e.g. medical devices, marine equipment) or a responsible person (e.g. cosmetic products) within the EU. Post-withdrawal, UK-based authorised representatives or responsible persons will not be recognised as such in the EU. As a result, manufacturers must take steps to ensure that their designated representatives or responsible persons are established in one of the remaining EU Member States and that appropriate notification is carried out in relation to such legal entity change. 

Product specific regimes and requirements: 

Several product sectors - Automotive, Aerospace, Pharmaceutical Products, Medical Devices, Batteries, Chemicals, etc and non-harmonised goods subject to national regulations - are subject to specific regimes and requirements. Each regime will have to be assessed for specific changes in order to ensure uninterrupted trade. For example, we have recently advised a number of chemicals manufacturers and traders on transferring UK REACH registrations to the EU, which can be time consuming if a new entity needs to be established. We recommend that businesses seek advice on the available options as soon as possible, as it may take time to implement any necessary changes. 

K&L Gates can advise on the full spectrum of EU product compliance matters to help your business prepare contingency plans for Brexit. We also have lawyers who can help manage Brexit concerns in relation to: Trade & Tariffs, State Aid & Merger Clearance, Intellectual Property, Commercial Contracts, the Workforce, and Travel. 

Contacts

• Raminta Dereskeviciute
  P +44.(0)20.7360.8264
  raminta.dereskeviciute@klgates.com
• Clare Reynolds
  P +44.(0)20.7360.8184
  Clare.Reynolds@klgates.com

http://www.klgates.com/no-deal-brexit-does-not-have-to-mean-non-compliance-for-your-products-02-15-2019/

USA - Challenge to Ben & Jerry’s ‘Humanely Sourced’ Claims Moves Forward

https://www.manatt.com/Insights/Newsletters/Advertising-Law/Challenge-to-Ben-Jerrys-Humanely-Sourced-Claims

A Washington, D.C., judge denied a motion to dismiss and allowed a false advertising suit accusing Ben & Jerry’s of deceiving consumers about the treatment of their cows to move forward.

Last summer, the Organic Consumers Association (OCA) sued the ice cream maker and its parent company, Unilever, over the claim that its products are humanely sourced and environmentally responsible. The group alleged that the defendants touted their ice cream as being produced by “happy cows” raised in “caring dairies” in contrast to factory-style, mass-production dairy operations. In reality, the milk comes from large farm operations with concentrated animal feeding and contains traces of the herbicide glyphosate, the OCA said.

The defendants moved to dismiss the case, arguing that no reasonable consumer would conclude that ads with “happy cows” meant that none of the cows lived at mass-production farms.

But the court disagreed, finding that the complaint was not limited to a challenge of unquantifiable representations about the “happiness” of cows.

“To the contrary, the complaint alleges that fewer than 100% of Ben & Jerry’s partner farms are ‘Caring Dairies’ even though content on Ben & Jerry’s website suggests that all farms supplying ingredients are in the program,” Judge Neal E. Kravitz wrote. “Taken together with the complaint’s references to Ben & Jerry’s general messages about humane treatment of cows and ‘values-led sourcing,’ the allegations concerning the misleading suggestions of full participation in the Caring Dairies program are sufficient to state a claim of misleading labeling and marketing, since a reasonable consumer could plausibly interpret Ben & Jerry’s labeling and marketing as affirmatively (and inaccurately) communicating that the company’s ice cream products are sourced exclusively from Caring Dairies and/or other humane sources.”

As for the environmental responsibility claims, Ben & Jerry’s told the court that no reasonable consumer would view its environmental advocacy as a guarantee that its products contain no glyphosate, which it characterized as a “ubiquitous herbicide.”

OCA countered that the defendants were again taking too narrow a reading of the complaint and that the ice cream maker’s environmental marketing, taken as a whole, misleads consumers into believing Ben & Jerry’s ice cream products contain no chemicals that harm the environment.

Judge Kravitz sided with the plaintiff, finding the facts alleged in the complaint provide sufficient support to plausibly claim that consumers would be misled, as it identified specific representations and did not rely upon vague commitments to environmentalism and sustainability.

“For example, in addition to phrases like ‘promoting business practices that respect the Earth and the Environment’ and ‘high standards for environmental practices,’ the complaint identifies specific messages related to the purity of Ben & Jerry’s products like ‘values-led sourcing’ and advocacy for transparency in labeling (‘Labelize it!’),” the court wrote.

The court also rejected the defendants’ federal preemption argument that the relief sought by the OCA would interfere with the Federal Insecticide, Fungicide, and Rodenticide Act, as well as the Food, Drug and Cosmetic Act. In addition to indicating that dismissal of a suit on preemption grounds based on arguments about potential relief was “premature,” Judge Kravitz reiterated that the complaint focused on Ben & Jerry’s advertising message as a whole.

To read the order in Organic Consumers Association v. Ben & Jerry’s Homemade, Inc., click here.

Why it matters: The D.C. court repeatedly emphasized that the complaint challenged the messages delivered by Ben & Jerry’s advertising as a whole and rejected the defendants’ narrow reading of the claims.

https://www.manatt.com/

rplawson@manatt.com

EUIPO to use blockchain in fight against counterfeiting

https://www.limegreenipnews.com/2019/02/euipo-to-use-blockchain-in-fight-against-counterfeiting/#page=1

What has happened?

The European Union Intellectual Property Office (EUIPO) has launched a new forum based on blockchain to combat counterfeiting.

What does this mean?

The Anti-Counterfeiting Blockathon Forum will be built on blockchain technology and will bring together people and organisations to shape and deliver the future anti-counterfeiting infrastructure.

It follows last year’s Blockathon coding competition, which was run by the EUIPO and the European Commission, and is linked to the EU Blockchain Observatory.

The Forum will connect private organisations, enforcement authorities and citizens to support the identification of authentic and counterfeit goods throughout the distribution chain.

It will focus on drafting and defining the anti-counterfeiting use case and related pilot with the ultimate goal of delivering the next level of anti-counterfeiting infrastructure based on blockchain.

The Executive Director of the EUIPO, Christian Archambeau, called on private sector organisations, and all interested individuals to join the anti-counterfeiting forum to help develop and test solutions that would successfully combat the “global plague” of counterfeiting.

“In today’s fast moving world, we need to use the latest technology to keep a reliable record of the origin of goods and their progress through international supply chains. Blockchain’s ability to create permanent and unchangeable records makes it one of the best candidates to deliver results on the ground”, he added.

POSTED BY LIMEGREEN IP NEWS

Brexit: Where Do We Stand at the End of January?

After the UK government overwhelmingly rejected Prime Minister May’s Withdrawal Agreement in January, the Prime Minister is back to negotiations with the EU in an attempt to hammer out a Brexit deal favorable for Britain before the 29 March deadline. 

In the most recent update, our Brexit team summarizes the vacillating developments surrounding Britain’s exit as of the end of January, lays out possible scenarios of the various permutations of Brexit in 2019 and explains how you can take advantage of the opportunities posed by Brexit.

POSTED IN EU, TRADE POLICY & MARKET ACCESS, UNITED KINGDOM

https://www.tradepractitioner.com/

https://www.squirepattonboggs.com/~/media/files/insights/publications/2019/02/brexit-where-do-we-stand-at-the-end-of-january/brexitwhere-do-we-stand-by-end-of-january-2019.pdf

How Brexit will change the food industry (Fourth Brexit Blog)

Brexit – How Brexit will change the food industry

In our fourth Brexit Blog, we will focus on the food industry, which causes one of the biggest trade flows between the United Kingdom (UK) and the ‘mainland’ of the EU (EU). We will discuss some of the consequences of Brexit, which can be already felt, so that food business operators know what to expect.

The UK currently imports 30% of the food it consumes from the EU, but all of that will be impacted by Brexit. Also, considerate amounts of products (e.g. meat, dairy and other agricultural products) are shipped from the UK to the EU. In total about EUR 46 billion of food products exchange the EU/UK borders annually. The food industry will therefore (and for other reasons) be one of the industries most affected by Brexit.

Financial consequences

As the UK is currently a member of the customs union of the EU, generally custom duties, tariffs or quota are prohibited on the trade of food within the (current) EU-market. With the UK leaving the customs union (under a no deal Brexit), this prohibition will no longer apply to the EU/UK-trade and other rules come into force, the World Trade Organization-rules. These WTO-rules, in short, prescribe that a country cannot discriminate between trade partners (unless a bilateral trade agreement is concluded). As all trade partners must face the same trade tariffs under the WTO-rules, the currently applicable tariffs for ‘third countries’ will apply to the EU/UK trade until a trade agreement is concluded. These tariffs (from the UK to EU) are especially high for food products, as they vary from 12 % for fish products, to 23,6 % on sugar and confectionary, to 35% on dairy products, to even higher for specific products (up to 87 % (!) for frozen beef).

Obviously it is possible to conclude a free trade agreement between the EU and the UK, but generally trade agreements can easily take up to 5 years to conclude (provided both countries have enough trade negotiators). As the UK did not (and is not allowed to) negotiate a trade agreement since their accession to the EU – and therefore probably won’t be able to act swiftly, a full free trade agreement will not be (expected to be) in force any time soon. EU food operators will therefore have to take into account that food products, such as livestock, ingredients and actual groceries will face considerable trade tariffs in case of a no-deal Brexit. Adding to these tariffs will be further pricing issues such as amending VAT-regimes (for exporting to a third country) as well as price instability caused by a turbulent GBP-EUR rate the coming months.

Logistical consequences

Another impact for food companies relate to the logistical structure of the food chain. Billions worth of food products cross the Channel each year, mostly at Calais-Dover or via the port of Rotterdam. At these border crossings currently no border control points are operational, nor is much paperwork required to cross. After Brexit however, this may radically change, with severe consequences for supply chains and (further) administrative burdens.

Where traffic currently flows easily on and of the ferries at Calais and Rotterdam, after Brexit trucks will have to fulfill certain requirements in order to be able to cross the Channel. The amount of paperwork will increase and also product checks, such as veterinary checks, will be put in place. This will increase the time it takes to cross the border to up to 45 minutes per truck. However, as not all trucks can be checked at the same time, this will lead to massive congestion on the roads to the British ports. In the UK tests are run with scenarios where traffic jams of up to more than 20 kilometers lead up to the port of Dover. Specific food products such as certain fruits and vegetables will be checked and live animals and animal products will have to be imported into the EU through designated Border Inspection Posts where they are checked by veterinaries. It can therefore take quite a bit longer for products to reach a location in the EU or the UK.

These measures lead to massive logistical difficulties, especially where perishable goods are involved or where supply chains are very tight. Also, according to government officials the government expects that in the first weeks after a no-deal Brexit the delays will lead to a diminishing of the flow of imports to a mere 13% of current imports (with supply deficits/empty shelves as a consequence). For this reason many (UK) companies in the food industry have been stockpiling (at the request of the British Department of Health) to be able to survive the first months after Brexit (no matter what scenario is chosen by the politicians).

Besides the time delays, further administrative burdens will apply. For the import or export of food products from and to the UK, additional administrative actions are required. First of all, filings will have to be made with the relevant customs offices and possible duties must be paid. Also – depending on the arrangement post Brexit – additional controls or (origin) certificates may be required before a product can cross the Channel. This might require further administrative custom skills from employees, skills that currently may not (and do not have to) be present with many food business operators.

Regulatory consequences

As if the financial and logistical consequences are not enough, several regulatory consequences that might be of importance to food business operators can also occur. Obviously, UK producers will have to ensure that their product complies with EU-labelling law (including the indication of a EU-representative/importer that is responsible for the food and food information). As the UK will adopt its own rules, the labels may have different requirements for EU-products compared to for UK-products. As a consequence, UK-products, for example, can no longer be sold in Ireland without amending the label. Topics for which the post Brexit situation may require further amendments to the product and/or the administration are origin indications, traceability, hygiene, front-of-pack schemes, biological products and specific products such as honey, meat, spirits etc.

The future requirements of labelling for food products in the UK are uncertain, but the UK has historically been in favor of mandatory ‘traffic light’ labelling front-of-pack, indicating nutritional values of products. Such indications are not mandatory (and in some cases not allowed) under current EU-legislation, so this would already be a big difference. Also, in the UK pleas are made to introduce new health warnings and animal welfare indications. All these measures may potentially widen the gap between EU-requirements and UK-requirements and as such hinder fluent trade between the two markets.

What kind of Brexit will be likely, is – with seven weeks to go – still unclear. This will prove quite the challenge for (amongst others) food business operators to efficiently prepare for (the right type of) Brexit. One thing however is certain and that is that any Brexit will require changes to the operation, production and financing of food products and production.

Victor van Ahee

victor.van.ahee@loyensloeff.com 

https://www.loyensloeff.com/en-us/news-events/news/brexit-blog-4-food-beverages