Food security is a CAP objective. It still isn't a duty.

On 17 July 2026, EU Member States hit the deadline to identify which food and water operators on their territory count as “critical entities” under Directive (EU) 2022/2557. Six weeks later, Danube water levels sat at record lows, dozens of vessels queued off the Sulina Canal waiting to reach Ukraine’s river ports, and Kyiv’s Agriculture Ministry had cut its 2026/27 export forecast by more than half, from roughly 64.4 million tonnes to 29.6 million.

The system meant to identify who is responsible for keeping food moving had just switched on. The disruption it was built for was already underway.

That timing is the useful detail sitting underneath a Euractiv opinion piece published on 2 September by Chris Kremidas-Courtney, arguing that Europe regulates what people eat without a plan for whether they will have enough to eat during a crisis. The piece points to NATO’s baseline requirements and the EU’s own cybersecurity and energy-security regimes as proof that binding resilience law is normal practice everywhere except food and water.

The diagnosis holds up, and the proposed fix—a single binding EU framework that treats food and water as infrastructure, not just as safety and environmental questions—points in the right direction. It is also worth noticing that Europe has more of the raw material for that framework already in place than the case for a wholly new regulation suggests. A new preparedness chapter is already under negotiation within agricultural law, while the proposed post-2027 CAP could provide part of the financial architecture needed to implement it. That changes the shape of what “closing the gap” would actually take.

A sector that is covered, but only partially

The CER Directive lists eleven sectors, and food—production, processing and distribution -sits alongside drinking water and wastewater among them. Obligations attach, however, only to entities that a Member State affirmatively designates as “critical,” not to the sector as a whole.

That is the real limit on CERD’s reach: a designation model built for a few hundred banks, grid operators and hospitals is now being asked to map a sector with millions of producers, processors, mills and hauliers, most of them small.

The Directive already treats food as critical infrastructure in principle. As framed, however, its food-sector coverage concentrates on wholesale distribution and large-scale industrial production and processing. It does not systematically cover the agricultural production of food or the input and service networks on which that production depends.

An objective without an obligation

There is a second piece worth folding into the picture. Regulation (EU) 2021/2115, which sets the rules for CAP Strategic Plans, has named “long-term food security” as its first general objective—Article 5(a)—since December 2021.

Food security is therefore the CAP’s own stated, foundational purpose, sitting atop the regulation that distributes roughly a third of the EU budget.

What Article 5(a) does not carry is a mechanism: no requirement to map dependencies, hold reserves or maintain continuity of supply when a shock hits.

The Single CMO Regulation adds crisis powers on top- a market-disturbance reserve and exceptional measures under Articles 219 and 222 of Regulation (EU) No 1308/2013, both used repeatedly since 2022. These are price-stabilisation and crisis-response tools triggered after disruption, not a standing resilience regime.

The ambition is already written down. It has never been fully operationalised.

Coordination, waiting to be given weight

The third piece, the European Food Security Crisis Preparedness and Response Mechanism, traces to a November 2021 Commission Communication, COM(2021) 689 final, drawn up in response to supply-chain lessons from Covid-19.

It convenes Member State authorities and supply-chain stakeholders, has produced risk-mapping and crisis-communication recommendations, and can be called on at short notice in an emergency. What it cannot do is compel follow-through. A 2024 survey of its own recommendations drew replies from only 25 members and observers—a thin return for a mechanism meant to track preparedness across the Union.

The infrastructure for coordination exists. It just does not bind.

A preparedness chapter is already on the table

That could now begin to change through the Commission’s pending COM(2025) 553 proposal to amend the Single CMO Regulation.

The proposal would insert a new chapter on the availability of agricultural supplies during emergencies and severe crises. Member States would have to adopt national food-security preparedness and response plans covering structural vulnerabilities, major disruption scenarios, early-warning systems, information on stocks, institutional responsibilities and cooperation with private operators.

It would also place the EFSCM on a legislative footing. The mechanism would support stress testing, risk assessment and scenario planning. During a declared severe crisis, the Commission could require Member States and operators to provide real-time information on stocks of agricultural products and inputs.

This is more than another coordination exercise. It would establish a binding public preparedness duty within agricultural law.

But the proposal still stops short of an operator-level continuity regime. It does not generally require farms, processors, suppliers or logistics operators to map dependencies, maintain alternatives or meet recovery targets before a crisis. Agricultural reserves remain optional: the proposal regulates them where Member States decide to establish them but does not require them to do so.

COM(2025) 553 therefore narrows the gap considerably. It does not close it.

What is actually missing

Put the existing and pending layers together and the picture is one of ambition without a complete enforcement chain.

CAP names the goal. CERD binds a slice of the sector. EFSCM coordinates the wider chain. The proposed CMO preparedness chapter would require governments to plan, monitor vulnerabilities and collect information.

What none of them yet does is systematically require an operator, in advance, to map a critical dependency, keep a fallback route ready, maintain minimum capacity or hold stock against exactly the kind of disruption now playing out on the Danube.

The Euractiv piece’s central instinct—that this needs to be binding, rather than aspirational—is therefore the right one.

The open question is which vehicle gets there fastest.

The decision that is now open

A new sectoral regulation, along the lines suggested by Kremidas-Courtney—a Food and Water Resilience Regulation—is one route, and probably the cleanest conceptually: a single instrument purpose-built for resilience rather than retrofitted from safety, environmental or market rules.

It is also the slower route. A fresh proposal would mean a new impact assessment, a new negotiation over scope and proportionality, and several years before any obligations applied.

An alternative would be to complete the architecture already under construction. That could mean widening CERD’s food-sector reach beyond its present processing and logistics focus and strengthening the operator-facing requirements attached to the CMO preparedness plans.

The post-2027 CAP proposal provides another relevant layer. It envisages at least €300 billion in ring-fenced income and crisis support, a €6.3 billion Unity Safety Net, stronger preventive risk-management measures and investment support to restore production after natural disasters or animal-disease outbreaks.

Those instruments can fund resilience, but they do not define what must remain operational. The opportunity is to connect future CAP support directly to the vulnerabilities identified in national food-security plans: shared storage, backup energy, alternative input supplies, water resilience, seed capacity, veterinary coverage and decentralised processing.

That would not turn every farm into a regulated critical-infrastructure operator. Nor should it. Obligations would need to be proportionate and, for smaller operators, capable of being fulfilled collectively through cooperatives, producer organisations or territorial arrangements.

It would, however, connect the three things that remain separated today: the duty to plan under the proposed CMO chapter, the identification of critical entities under CERD, and the financial capacity available through the CAP.

Either route lands in the same place Kremidas-Courtney is pointing: food and water treated as infrastructure that has to keep functioning, not just as supply that has to be safe.

But the legislative choice is no longer simply between adopting a wholly new Food and Water Resilience Regulation and doing nothing. A binding framework is already beginning to take shape through COM(2025) 553. The immediate question is whether the EU will complete that framework—by attaching operational responsibilities and CAP financing to it—or leave another well-designed preparedness mechanism without the authority to ensure follow-through.

Food security is already an objective. Preparedness is close to becoming a legal requirement. Continuity is the remaining duty.

Primary commentary source: Chris Kremidas-Courtney, “Europe regulates food safety but not food survival,” Euractiv Opinion, 2 September 2026.