International Federation of Organic Agriculture Movements

1

• European Parliament, 27th March 2006
• The organic movements appraisal
  of the proposed new organic
  regulation
• What are the concerns?
• Questions that need answering
• What changes we would like

International Federation of Organic Agriculture
Movements
2
Stakeholder involvement

• Concern
• No proper and formal stakeholder involvement -
  either in the regulation itself, or in the means
  of agreeing the proposals
• Management Committee set to replace Standing
  Committee
• Question
• What possibilities, mechanisms and structures are
  foreseen for an active stakeholder involvement?
• Would like
• Formal consultation as we review this proposed
  new regulation
• Formal stakeholder stakeholder involvement
  written into article 31
• Standing Committee to remain

3
Time scale and completeness

• Concern
• Timescale too short for proper consultation and
  consideration of a completely new text
• We only have half the picture (no annexes)
• Question
• What is a realistic time-scale to allow
  sufficient evaluation, discussion and
  consultation?
• What are the plans for the annexes (which
  revised, which remain, what criteria) and why are
  they not mentioned in the text?
• Would like
• Sufficient time for the detailed consideration
  necessary to ensure a well constructed regulation
  that everyone can support
• At least an outline of the annexes so we know the
  whole context

4
Scope and definitions (12)

• Concern
• Scope too narrow
• Definition of GMOs
• Question
• How to address the demand of the sector to
  include catering?
• How to protect the term organic for non-food
  products of organic agriculture, such as
  textiles, cosmetics, managed wild animals, etc?
• What is the intention of changing the definition
  of GMO - 2 (q) and (r)?
• Would like
• Catering and restaurants to be included
• The term organic protected (though not
  necessarily with detailed standards) for all
  products of organic agriculture
• The same definitions of GMOs as in the existing
  regulation

5
Objectives and principles (36)

• Concern
• Very limited objectives and unsure of their
  purpose
• Confusion over aspirational principles or
  over-arching rules
• Many essential aspects missing
• Question
• What is the structure that frames the objectives
  and principles - objectives for what? Are they
  aspirations or rules?
• How to reconcile the gaps with the IFOAM
  principles, especially to improve international
  harmonisation?
• Would like
• Use the 4 IFOAM principles as the objectives of
  organic farming
• Use the output of the Organic Revision project
  (yet to report) for drawing up the objectives and
  principles

6
Production rules and flexibility (716)

• Concern
• Some key rules missing - unclear of the division
  between production rules in the regulation and in
  the annexes
• Flexibility good, but impossible to assess
  implications (eg potential for distortion of
  trade) without clear criteria
• Question
• Why are there no references to the annexes in the
  regulation?
• What are the criteria for deciding between the
  regulation and the annexes?
• How will stakeholder involvement be used, and
  what rules will there be, to ensure that specific
  conditions meet genuine needs?
• Would like
• At least an outline of the annexes so we know the
  whole context
• Clear criteria and an open process for deciding
  on flexibility

7
Labelling (1820)

• Concern
• EU-ORGANIC text unnecessary and
  counter-productive
• Restrictions on private organisations covered by
  existing laws
• Question
• How will the EU ORGANIC text fragment, which
  can occur in 21 different languages, help to
  inform consumers across the EU?
• What is the benefit of these restrictions on
  private label organisations and their
  communication when they are already sufficiently
  covered by general legal framework?
• Would like
• EU logo voluntary (and redesigned)
• No text fragment
• Concentrate instead on a harmonised certifier
  code
• Delete Article 20

8
Control (2225)

• Concern
• 882/2004 rules not adapted for organic
  agriculture
• Powers of private bodies restricted and/or
  centralised to authorities
• Question
• How to prevent any unintended impact of 882/2004
  and avoid it colliding with mature current
  practices of organic inspection and
  certification?
• What are the derogations from and adjustments
  to 882/2004 for organic farming, who decides
  these, and where are they?
• Would like
• Surveillance of competent authorities must be
  strengthened but organic farming should be
  removed from 882/2004
• Delete Article 24.3
• Control bodies must be able to issue sanctions

9
Imports (27)

• Concern
• Codex Guidelines are inadequate (only general
  guidance, only indicative input lists, inadequate
  cover of organic certification systems
• No recognition of IFOAM standards and
  accreditation
• Question
• Why not judge equivalence with IFOAM Guarantee
  system (specifically developed (from ISO65), in
  use and internationally recognised)?
• What will be the requirements for accrediting
  certification bodies in third countries and their
  listing by the EU as being equivalent?
• What will be the requirements for supervising the
  activities of EU certification bodies in third
  countries?
• Would like
• Recognition of the IFOAM Guarantee system
  (standards, certification criteria and
  accreditation)

10
The positive aspects

• The new structure is more logical and easier to
  understand than the current regulation
• The attempt to formulate basic principles as a
  starting point to develop detailed, certifiable
  standards from these agreed principles
• The inclusion of wine and aquaculture within the
  scope of the regulation
• The objective to decrease the details and number
  of derogations

11
More positive aspects

• The possibility of certain flexibility to deal
  with regional variations, as it can provide an
  alternative for much derogation and facilitate
  development
• The intention to use a risk-based approach to
  determine necessary inspection
• A better accessibility proposed for imported
  products from outside the EU

12
Conclusions

• We have called for, and support, a major revision
• We recognise the good intentions in the new
  proposals
• We have some grave concerns
• We want constructive engagement, but we need
• one stage process (articles and annexes)
• realistic timescale for analysis, consultation,
  discussion
• participation in the process (and in the S/M
  committee)
• removal of the various restrictions on the
  private bodies