The EU Commission (EC) is carrying out a review of the current organic regulation (834/2007) that sets the baseline rules for all organic food and farming throughout Europe.

Some of the draft proposals are quite revolutionary, others are not. We need to argue against any changes that would harm SOPA member businesses.

We are using this online survey as the most convenient way for you to have your say. We will be sending the survey in three parts so please ensure to complete all three.

This is Part 3.

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* 1. YEAST
In December 2013 yeast was defined as an agricultural ingredient and this provision remains unchanged in the draft proposal.


What impact will this have on your organic business?

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* 2. GROUP CERTIFICATION
The draft proposal includes the possibility of group certification for small-scale farms (< 5Ha) to reduce certification cost and administrative burden. There is provision for this in 834/2007 as SOPA already offers group certification in certain circumstances.



What impact will this have on your organic business?

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* 3. ONE CERTIFIER IN THE SUPPLY CHAIN
To reduce fraud, the draft proposal states that products must be certified by the same certification body throughout its supply chain.


What impact will this have on your organic business?

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* 4. RISK BASED APPROACH
The draft proposal removes mandatory annual inspections. This introduces a risk-based approach to inspections – so a low-risk business could be subject to fewer or lighter-touch inspections, while a high-risk business would be more closely monitored. The Commission argue that this would be a more efficient use of resources. SOPA believes this could result in better compliance with regulations, although we need more clarity on how risk would be calculated.


What impact will this have on your organic business?

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* 5. SHIFT TO DG (Directorate General) SANCO
Administration of the organic regulation would be moved from DG Agri to DG Sanco – which amounts to a change of department in Brussels. This is significant in that 834/2007 is based on agricultural food production and DG Agri has experience and expertise in food production systems, whereas DG Sanco remit surrounds consumer and health and has a different approach to policy.


What impact will this have on your organic business?

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* 6. RESIDUE TESTING
The draft proposal introduces new provisions where any non-authorised products or substances are present beyond given levels the product can’t be marketed as organic. This represents a major change of approach from the current regulation in which controls are process focussed rather than product focussed. Currently, in the UK, if an unauthorised substance is discovered in a product an investigation into the cause of the presence of unauthorised substance is carried out to establish whether it was intentional or adventitious. However, this approach is not harmonised across Member States. This change of approach would mean that any products contaminated with unauthorised substances unintentionally (e.g. from neighbouring farms) would still lose their organic status and this could result in a number of complex liability issues. This raises a number of concerns as a fully compliant organic producer could suffer the consequences of loss of the ability to sell their products as organic even though they have met the organic production standards. There would also be additional costs to industry for laboratory tests.


What impact will this have on your organic business?

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* 7. LABELLING
The labelling requirements in the draft proposal are largely the same as 834/2007. Processed food should only be labelled as organic where at least 95% by weight of its agricultural ingredients are organic.
The draft proposal provides that small quantities by weight of ingredients may be disregarded provided that the total quantity of the disregarded ingredients does not exceed 5% of the total quantity by weight of agricultural raw materials. This is an increase in percentage from the current 2% for labelling of origin of minor ingredients. This would be positive for producers of processed goods who may benefit from increased flexibility and potentially decreased production costs. Consumers may be negatively affected through the restriction of information concerning the good they are purchasing. And there does appear to be a contradiction of the consumer-driven urge for 100% organic supply.
Unlike 834/2007, the draft proposal does not specify labelling requirements for organic feed; in-conversion products of plant origin; vegetative propagating material or seeds for cultivation. The labelling requirements in the proposal only cover organically produced products, ingredients or feed materials.



What impact will this have on your organic business?

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* 8. TRADE: EQUIVALENCE BETWEEN CERTIFICATION BODIES
Under 834/2007 imports of organic products from outwith the EU can be certified as equivalent to 834/2007 where the EU and non-EU certification bodies (CB) have an agreement to accept their mutual standards as equivalent. The draft proposal requires the EU CB to certify that products from outwith the EU fully comply with the EU organic regulations. The Commission argue that this would result in fairer competition and reduce the current disadvantages to EU producers of cheaper Third Country imports resulting from less stringent production rules. It would also encourage consumer confidence in the traceability and certification of imported organic products. However there are some concerns that it will limit the number of exporters from developing countries where the environmental conditions are very different to those in the EU and as a result may not be able to meet the strict EU requirements. This could have knock on effects for producers in the EU not being able to source products and ingredients and could result in a decline in product variety available to consumers.


What impact will this have on your organic business?

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