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 2.

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* 1. AUTHORISED PRODUCTS
The lists of authorised plant protection products; fertilisers, soil conditioners and nutrients; feed materials; feed additives and processing aids and products for cleaning and disinfection are not yet provided in the draft proposal and are likely to be added later through delegated/implementing acts. Article 19 sets out the criteria for the inclusion of products in these lists which are similar to the current regulation. We would be concerned if there were further restrictions on authorised products and delegated acts are not a helpful instrument in this case.

What impact will this have on your organic business?

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* 2. DEHORNING
The draft proposal introduces a ban on dehorning. Clarification is required on what the ban covers to evaluate whether some current UK practices would be permitted or not. There are concerns relating to both animal welfare and health and safety of farm workers if all types of dehorning were to be banned.


What impact will this have on your organic business?

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* 3. ORGANIC FEED
The percentage of feed required to be ‘produced on the farm or if this is not feasible, from the same region’ has increased from 60% to 90% for bovine, ovine and caprine; and from 20% to 60% for porcine and poultry. If ‘region’ is confined to a small area, farmers may face difficulty in changing farm cropping patterns to grow more feed. On the other hand, if region is interpreted as Europe then this provision would have reduced impact. The increased percentages may still not be achievable for some species. The Commission introduced this provision to ensure organic meat production meets consumer expectations. In the stakeholder consultation 49% of respondents stated that organic livestock should be fed with 100% feed from the farm or region. The potential benefit of this draft proposal would also be dependent on the definition of region but could include lower transport costs and an associated reduction in GHG emissions. The draft proposal still allows the use of up to 100% in conversion (second year) feedstuffs if it is produced on the agricultural holding. However, the maximum amount of first year conversion feedstuffs permitted for use has declined from 20% to 15% and there is a reduction from 30% to 20% for bought in-conversion (second year) feedstuffs. SOPA has some concerns that Scotland’s climate has impacted our ability to grow nutritional feeds for our organic livestock and their health and welfare could be at risk. If there had been more investment in research of appropriate varieties of feed that could be grown in northern latitudes, but without that investment there is a risk of feed failure and an inherent lack of resilience in organic feed.


What impact will this have on your organic business?

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* 4. ORGANIC PLANT SOURCES
The draft proposal requires organically produced plant reproductive material to be used for the production of organic plants and plant products. This requirement means that Member States can no longer authorise the use of non-organic seed or vegetative propagating material (such as growing compost) if they’re not available in organic form. The Commission argue that this will contribute to the development of the market for organic seeds and ensure that organic products meet consumer expectations. This is likely to have significant impacts as there is a range of seeds that are not currently available in organic form as their production is not commercially viable. If these seeds were made available it could increase the production costs of organic crops and therefore increase the cost for consumers. If the seeds were not made available it could limit the range of organic products available to consumers which would restrict the growth of the sector.


What impact will this have on your organic business?

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* 5. DELEGATED ACTS
A delegated act is a change of EU law suggested by the EU Commission to the European Parliament, where there is little or no consultation with wider stakehold¬ers or formal committees. A delegated act is often a later addition or subsequent definition to a EU regu¬lation. Under the Lisbon Treaty the Commission was given limited powers to make minor changes to laws, provided these do not affect the “core” legislation decided by Parliament and the Council. The Commis¬sion is given the power to adopt ‘non-legislative acts of general application to supplement or amend certain non-essential elements of a legislative act’. There are concerns at this lack of transparency and democracy.

What impact will this have on your organic business?

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* 6. PROCESSED FOODS: ORGANIC MATERIALS
The production rules for processed food and feed in the draft proposal are similar to those in the current regulation. However, the draft proposal removes the ability to use non-organic food and feed materials where they are not available on the market in organic form. This is expected to have significant implications.


What impact will this have on your organic business?

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* 7. AGRICULTURAL INGREDIENTS IN PROCESSED FOODS
834/2007 requires processed food to be produced mainly (95%) from organic agricultural ingredients. The draft proposal includes this provision but removes the possibility to temporarily authorise the use of non-organic agricultural ingredients if they are not available on the market. There are fewer permitted non-organic ingredients (listed in annex II, part IV paragraph 2.2.4) – so some edible fruits, nuts and seeds, edible spices and herbs, some sugars, starches and other products from cereals and tubers would no longer be authorised. The listings for animal products and fats and oils remain the same as in the current regulation.


What impact will this have on your organic business?

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* 8. SEAWEED AND AQUACULTURE
More detailed EU rules for seaweed and aquaculture have been included in the proposal. In the current regulation, Member States are permitted to certify to national or private standards for aquaculture. This will no longer be possible.


What impact will this have on your organic business?

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* 9. EXPORTS
The draft proposal also includes a provision to develop export certificates to improve traceability of imports and exports. Details would be developed in a delegated act and therefore it is difficult to evaluate the potential implications.


What impact will this have on your organic business?

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* 10. PERMITTED SUBSTANCES IN PROCESSED FOODS
Article 19 in the draft proposal will list the permitted processing aids, food additives and food enzymes to be used as food additives but the list has not yet been published and therefore the potential changes cannot be evaluated. As in the current regulation, the draft proposal retains ability to use natural flavourings; colours for stamping meat and eggshells; drinking water and salt; minerals, vitamins, amino acids and micronutrients as far as their use is legally required.

What impact will this have on your organic business?

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