COPA-COGECA RESPONSE TO PUBLIC CONSULTATION ON THE REVIEW OF EU POLICY ON ORGANIC AGRICULTURE LEGISLATION AND ACTION PLAN

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1 ABI(13)1242 :5 Brussels, 14th March 2013 Annex COPA-COGECA RESPONSE TO PUBLIC CONSULTATION ON THE REVIEW OF EU POLICY ON ORGANIC AGRICULTURE LEGISLATION AND ACTION PLAN Copa - Cogeca European Farmers European Agri-Cooperatives 61, Rue de Trèves B Bruxelles EU Transparency Register Number Copa Cogeca

2 Annex COPA-COGECA RESPONSE TO PUBLIC CONSULTATION ON THE REVIEW OF EU POLICY ON ORGANIC AGRICULTURE LEGISLATION AND ACTION PLAN Organic farming is a holistic production system based on the management of natural resources which restricts the use of both non-renewable resources and resources not from the same holding, which places strict limitations on the use of chemical and synthetic inputs, and which prohibits the use of GMOs. This kind of production encourages prevention rather than cure, as well as the use of mechanical and physical crop production over chemical products. It also promotes the selection of varieties and species which are adapted to conditions inherent to individual production areas, and closed production circuits made possible by recycling farm effluent and plant/animal by-products. For Copa-Cogeca, above all, it is a global method of production which cannot be simply be summed up as a set of finished products which meet one or several specific characteristics. ORGANIC PRODUCTION STANDARDS Europe has stringent organic farming standards. Nevertheless, the different ways in which certain rules are interpreted can prevent the single market from functioning effectively. There are several areas of regulation where regulation has been written in a very succinct form, which provide Member States and control bodies with a large amount of room for manoeuvre in their interpretation and application of these rules. To ensure that the market functions effectively, a more harmonised legal framework needs to be defined at European level in several areas of regulation, notably for organic poultry production and organic glasshouse production. Furthermore, a harmonised system of sanctions in the event of infringements or irregularities between Member States and control bodies is also necessary, and guidelines on this issue should be established. Pesticide residues Organic farming prohibits the use of chemical and synthetic pesticides and regular monitoring during mandatory annual on-site control checks and voluntary monitoring by operators ensures that these rules are being adhered to. Nevertheless, the useable agricultural area (UAA) in organic farming amounts to only 5% of the EU's UAA. Therefore the risk of adventitious pesticide contamination can never be completely ruled out, despite the precautionary measures taken by the industry. According to the 2011 report on pesticide residues found in food in the European Union (EU) during 2009 by the European Food Safety Authority, the MRL recorded in organic products was 7 times lower than conventional products. It is not appropriate to check for the absence of all pesticide residues in all organic products given the low level of exceedance rate for organic products. It would be more appropriate for control bodies to carry out monitoring based on risk analysis. Additionally, there are still uncertainties surrounding the analysis methods linked to the quantification thresholds of active substances, the analysis results, and to the interpretation of these results. These vary depending on the laboratory carrying out the analysis and the pairs of molecules/products. Additionally, several cases of false positives in analysis results have also been reported. This technical issue therefore needs to be dealt with before considering setting a lower pesticide residue level for organic products. In the opposite case, farmers will be confronted with greater uncertainty than that caused, for example, by climate change. Additionally, analysis results must be viewed as a way to increase understanding which can be combined with other investigation tools, and they should not be seen as unquestionable examination tools to monitor the organic nature of products. All in all, harmonisation of controls at European level is also needed.

3 GMOs As is mentioned in the introduction, organic farming is a holistic production system which does not allow the use of GMOs. However, the organic production system is not isolated from the rest of the production chain - encompassing the production of organic seeds to processing - and as a result accidental GMO contamination can never be completely ruled out. The threshold of the adventitious presence of GMOs set out in horizontal legislation was determined based on an analysis of potential risk and an economic analysis. Taking these criteria into account, it does not seem justified to establish different thresholds for different production systems. Additionally, it is essential that the level of accepted risk be the same throughout the chain and that it not be stricter at the production stage than the processing stage. Furthermore, the issue of adventitious GMO contamination thresholds for organic seeds should also be dealt with as a pre-condition. Derogations It is essential that organic farmers in all EU countries adhere to the same regulation in order to ensure that the internal market functions effectively. Nevertheless, given that the organic market is not yet sufficiently developed and, in certain cases, there are no organic alternatives, derogations may be granted. The application conditions for these derogations must be strengthened and restricted, and must only be permitted for a limited amount of time. However, the scheduled end of the derogations must be realistic, based on the availability of organic products, the development of substitutes for conventional products and regional conditions in dominant markets. That is why the timeframe must be agreed on in advance in consultation with the entire organic farming sector, so that farmers can adapt their production methods and structures to the new situation they face. At the same time appropriate resources must be made available for research on organic farming so that the development of organic production makes it possible to end these derogations. As a result, climatic events should be the only grounds on which derogations are authorised. Local origin of feed Pursuant to Article 14 of Regulation No 834/2007 concerning organic production, there should be a close link between feed production and the holding where the animal is kept or other holdings in the region. Yet there is no harmonised definition or interpretation of the term "region" at EU level. Defining this term should be a pre-requisite for any progressive change to legislation. However, this definition should not lead to an overly restrictive system which might endanger the health and well-being of organic livestock. Organic protein crops The EU cannot meet its own organic feed production requirements; this is particularly true of protein used in organic livestock nutrition which meets the essential amino acid needs of monogastric animals and it is also true of legumes for ruminants (which make up between 15% and 35% of their feed ration). The EU is therefore obliged to import these materials. Yet this goes against the principle of local origin of animal feed. At the same time, an overly stringent application of this principle would results in a fall in European organic meat production. A strategy to boost production of organic protein crops at EU level therefore needs to be developed which takes into account the link between the prices of different agricultural products, industryrelated problems and the competition posed by non-eu countries. On a separate note, synthetic amino acids should not be permitted in organic farming.

4 Animal welfare The animal welfare standards which apply to organic farming are specific rules enshrined in EU legislation. They also correspond to even stricter standards than those set out in horizontal legislation on animal welfare. Nevertheless, harmonisation in the way they are interpreted in Member States is necessary in order to avoid unfair competition in the organic poultrymeat production sector. Procedure for authorising substances The current system should be maintained. Adding or removing substances should be carried out following an impact assessment. It is vital that each substance used abides by the principles of organic farming and also adheres to existing general regulations. PROMOTION- INFORMATION Consumers should be better informed about the qualities of organic products and the new EU organic logo. In particular, European promotion campaigns should focus on the methods and standards involved in organic production and not just the characteristics of the finished products so that consumers have a clear overall picture of organic products. These European promotion campaigns should also promote the new EU logo since in several Member States this new logo is less well known that the respective national logos. Besides this, promotion campaigns should highlight European production standards so that consumers are informed of these and become acquainted with them. Promotion campaigns should thus make people aware of the term "EU Agriculture" which accompanies the logo and which refers to foodstuffs which have been produced in the EU. The European Commission website provides useful information on organic farming, but it should be updated more frequently. Furthermore, this website should provide more precise details on current research and research findings. It should also provide more legal information, production data from the different Member States as well as information for professionals on crop-growing and livestock-rearing techniques, and plant and animal health. CONTROLS The European certification and control system applied to organic products is one of the most stringent and rigorous in the world. To ensure fair competition against products from third countries and to secure consumer confidence, it is vital that control systems for organic products from countries outside the EU be at least as rigorous as those in the EU, even if that were to lead to an increase in their price. In this context the European Commission must pay greater attention to the rules on mutual recognition set out in agreements with third countries where standards are recognised as equivalent in order to guarantee that imported products adhere to production and control standards which are a strict as those for EU organic products. Greater vigilance is also essential regarding the equivalence system for control bodies for imports from non-recognised third countries where we consider that the supervision guarantees made by the European Commission are lacking. In addition, the control system within the EU should be strengthened further to address the weaknesses highlighted in the Court of Auditors' 2012 report.1[1] However, the control system must become more effective without this leading to an increase in the price of organic products and certification costs. Risk analysis allows us to better target controls and to better identify weak links in the production chain. For example, improved exchange of information between control bodies, between Member States and the Commission, as well as between Member States would make the system more effective without necessarily increasing costs. Besides this, competent authorities in the Member States must strengthen their supervisory role over control bodies (verifying risk assessment procedures and how they are put into practice). There is a need for a harmonised approach to the supervision practices of control bodies in the European Union, [1] Special Report No 9/ Audit of the Control System governing the production, processing, distribution and imports of organic products.

5 particularly private control bodies. Professionals should also be given feedback after the controls have been carried out by certifying bodies. The Commission should also improve its monitoring of Member States' control systems by carrying out audit visits more frequently. The sector should also have more exhaustive, reliable, up-to-date and transparent statistical data on the different categories of products in Europe, as well as a European databank on transactions with third countries because of the large amounts traded. Strengthening controls on imported organic products is also necessary. Finally, due to the effort required and potential delays caused by the obligation to submit an original certificate of inspection, it would be worth investigating the feasibility of creating a secure database of electronic certificates made available for control, clearance and supervision purposes which would be supervised by the European Commission and Member States. This would facilitate a quick response by Member States in cases of infringement as they could block non-compliant products. Group certification Group certification is not compatible with the current mandatory annual on-site inspections. As a result, it should not be authorised in the EU. TRADE WITH NON-EU COUNTRIES The consumption of organic products from the EU currently outstrips EU production of organic products, and today some demand is covered by imports. Consequently, it is important that the EU equips itself with instruments which will guarantee the development of organic production in the EU so that first and foremost the internal market is satisfied and demand generated by European consumers can therefore be met. The EU must also not be content to remain an area which imports and consumes organic products. A strategy must be developed in order to once again strike a balance between the EU and its partners. This must be done in order to support the emergence of high-performing organic production sectors and to develop export capacity for organic products within the EU which have high added value and which can be exported to third countries. This strategy includes identifying the most promising markets by establishing priorities which combine specific products with specific countries. Promotion campaigns for organic farming products in third countries are an important tool. Sector-specific market studies as part of this promotion action are vital to ensure that these campaigns are run effectively. These market studies should be available to all EU operators. RESEARCH AND INNOVATION Research and innovation are particularly necessary in the following areas: plant health; greenhouse gas reduction; better water management; maintaining soil fertility; improving energy efficiency in organic production systems; seeds and plants adapted to low-input agriculture; low-growth strains of animal; local production of high-protein crops; co-existence of organic agriculture, conventional agriculture and GMOs; and the social and economic dimension of organic agriculture. Research and innovation are becoming more and more important to agriculture as the sector strives to remain competitive, while also responding to the major challenges of our time, such as climate change, increasing scarcity of resources and the rising number of global trade agreements. As public funds for research are being cut, notably in agriculture, allocating public funds exclusively to organic agriculture would result in a substantial reduction in the funds channelled into other kinds of agricultural research and horizontal questions. Public funds should therefore not be reserved exclusively to research on organic production.