3 rd ORGANIC PROCESSING CONFERENCE SUSTAINABILITY QUALITY INTEGRITY AND NEW REGULATION November 2014, Paris, France

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1 d 3 rd ORGANIC PROCESSING CONFERENCE SUSTAINABILITY QUALITY INTEGRITY AND NEW REGULATION November 2014, Paris, France Report from the Conference [Type here]

2 3 rd Organic Processing Conference in Paris On November 2014, 125 organic processing experts from companies, organisations, control bodies and public institutions, representing 14 European countries, met in Paris to discuss the further development of the organic food sector, as well as technical and regulatory challenges processors face in their daily work. The Commission proposal for a new European Organic Regulation also offered many topics for debate. The conference started on Monday with two plenary sessions; in the first one, the speakers gave an introduction on the aims and challenges of the organic sector and in the second, the Commission proposal for a new organic regulation was presented. In the afternoon, discussions and debates took place in six sessions, around the three main topics of the conference: - The sustainability of the organic chain production; - The integrity of the organic products; - And their quality. The Commission proposal for a new organic regulation was discussed throughout the conference. Participants highlighted the parts of the regulation that need to be improved and proposed alternatives that would be relevant for the sector. This document is a report of the discussions and conclusions from the sessions of the processing conference. The different point of views and opinions that are expressed in this paper reflect these of the people present during the Conference and not the IFOAM EU position. Table of Contents 3 rd Organic Processing Conference in Paris... 1 Content of the session... 2 I. Integrity... 2 II. Quality... 4 III. Sustainability... 6 IV. Conclusions December 2014

3 Content of the session I. Integrity The discussions on the integrity of organic production focused on the feasibility of enforcing a decertification threshold for unauthorised substances, the removal of annual control and of the equivalence for import from third countries. There was consensus that the measures proposed by the Commission are neither sufficient nor effective enough to achieve the stated goals of reducing fraud. The lack of harmonised implementation by Member States is what must be corrected; introducing new legislation will simply lead to new interpretation. Furthermore, the sector itself is developing many highly sophisticated tools to prevent and monitor potential contamination, and to improve transparency and traceability in the supply chain. 1. Protecting organic products from the risks of contamination by unauthorised substances and understanding the question of decertification threshold The presentations were given by: - Hans Braeckmann from Fytolab on analysis and interpretation - Kirsten Arp from BNN on the threshold decision tree and a guide of the values that could be implemented as a threshold. - Sophie Taufour from La Vie Claire, who presented the implementation of thresholds and of a private standard plus the programme Securbio developed by Synabio. Context: the European Commission in its proposal to review the European organic regulation presents a system of decertification threshold, in cases of residues of unauthorised substances in organic products. Discussion: making analysis is not a 100% reliable tool. There could be a lot of uncertainty on the analysis and the interpretation of the result. The lack of reliability from the analysis can be demonstrated by many factors. The control bodies should ensure that the sampling is done in a way that represents the batch. On the laboratory side, different methods of analysis are used (multi-methods and single residue methods). The methods are different also according to what you are looking for and to the substances. Not all the substances can be analysed at the same time, some important substances could be left out. An example to illustrate this issue was the case of Glyphosate that definitely shows the limit of the threshold as a tool since: Laboratories are not able to quantify glyphosate in flour at levels close to 10 ppb so far. The specified reporting limits of 10 ppb are not supported by the results of this performance test From the results of this test, a reporting limit at a level of around 50 ppb seems more appropriate to guarantee reliable and robust results 1. 1 Study made by Kamut Entreprise of Europe 2 18 December 2014

4 Furthermore, the level of pesticides found does not always reflect the pesticides used. It is difficult to interpret the result of pesticide residues and to know if there was a use of unauthorised substances or if it is an unfortunate contamination. Finally, the organic sector stressed that being organic doesn t mean that products are free from pesticide residues. It is not relevant to compare conventional and organic products only on the aspect of zero pesticides. Solution: there are already many thresholds which exist from private standards, control body guidelines that can be used in a more efficient way than a unique threshold. Furthermore, thresholds can be a tool to improve the finding of malpractice. The creation of a European observatory on substances in organic products could help to enhance our expertise and strategy on this issue. Conclusion: A harmonised threshold for all the possible contaminants and products is in general not feasible. The baby food threshold (under 10ppb) for some toxicology is not applicable. The answer is too simple for such a complex question and will not help to find out if there is fraud. Assessment of each case is important. But there is a need for efficient and reliable solutions to this issue. The Control bodies practices need to be harmonised at least in terms of investigation threshold. 2. Evolution of the import regime with the removal of the principle of equivalence for control bodies and the proposition to modify the regime on control Presentations were given by the three following speakers: - Michel Reynaud from EOCC - Gerald A.Herrmann form Organic services - Henri de Pazzis from Pro Natura a. Exchange with third countries Context: the Commission proposal does not allow the possibility for control bodies in third countries to be recognised as equivalent according to the European organic regulation. Control bodies would have to be recognised as compliant. Some countries will be recognised as equivalent but only in the frame of trade agreements. Discussion: Behind the questions of equivalence or compliance, there is the issue of fair access to the market for all - from European farmers to North American farmers and Third World farmers. Many questions are raised by the fact that the equivalence recognition within trade agreements is not transparent, since we don t know who will be evaluating the other regulations and deciding if they are compliant. A fundamentally political question is raised: should Europe impose its rules on the entire world? And technical questions on how to deal with the specific production rules of the third countries arise December 2014

5 Conclusions: Specificities from third countries should be identified, for instance regarding the substances authorised. An alternative would be to propose a system of compliance but with exceptions in order to make the access to the European market more flexible, especially productions that don t take place in the EU for climate reasons. Another alternative would be to create regional standards. b. Control system Context: the Commission has removed the organic control requirements from the organic regulation and integrated them into the regulation on official control for food and feed. Furthermore, the Commission proposal rendered inactive the obligation for annual controls and replaced it with a risk-based concept. Finally, if the proposal is adopted, the possibility to exempt retailers of organic pre-packaged foods from controls will be removed. Discussion: Technical expertise should drive the political decisions and not the other way. In terms of control, traceability needs to be put as a central point of the regulation: The current lack of reliable information has to be changed to full supply chain traceability while keeping business data confidential 2 Traceability is the best way to enhance the elimination of fraud in the organic sector. The proposed risk-oriented approach is already the basis for the current control system. Nevertheless, criteria are not yet fixed and harmonised. There is a consensus that the annual controls should be kept and there is no need to require certification for retailers selling pre-packaged food. II. Quality Starting from the products themselves, company representatives discussed ways to improve quality by using the simplest processing methods, minimising processing and trying to limit the use of additives as much as possible. It was also mentioned that the rules for organic processing could be better defined in both the existing regulation and the Commission proposal. 1. Evolution of the use of additives, processing aids and flavours in organic food processing Presentations: Janis Garancs from Aloja Starkelsen on organic potato starch Alexander Beck from EGTOP, on the EGTOP recommendations for food. Discussion: the aim of this workshop was to identify ways to reduce the use of external substances in organic processing. For instance starch from potato, maize or wheat are simple ingredients that in some cases can replace additives. 2 Gerald A. Herrmann, Director Organic Services GmbH 4 18 December 2014

6 We could consider the use of additives and processing aids as equivalent to the use of external input (e.g. fertilisers) in farming in terms of their targeted technical action for specific issues. Instead of additives, should we encourage the holistic approach - appropriate processing and use of food technology to find solutions? In terms of regulation, it is written that within organic processing the true nature of the product shouldn t be modified. The question raised by this principle is how we define and evaluate the true nature of the product. Solutions: The answers to these questions were divided in three key themes: 1. Innovation Innovation is seen as an essential tool to answer to the challenges of maintaining quality in organic processed food. Measures should be put in place to motivate innovation in organic processing. The market can also lead the innovation and there should be incentives in the market for innovative solutions, where appropriate and feasible. 2. Ingredients Recommendations for this key theme are to use only organic, local and clever ingredients. On the local theme, it is for instance better in a European context to use sugar beet rather than cane sugar. In terms of clever technological functionality, it is also better to use plant extracts to replace nitrites (where safe to do so) or potato starch in baking powder. The core principle is to be transparent with the consumers so if we use some substances, it must be clear why. 3. Processing techniques The know-how of good food processing should be protected. We shouldn t compromise on traditional skills and knowledge. Regarding the use of new technologies and substances the precautionary principle should always be used. Criteria that can be suggested regarding the use of processing techniques are: - Necessity - Conservation of the vitality and naturalness of the product. Conventional products are prone to complex processing. Organic products on the other hand should be as simply processed as possible. Conclusion: - Promote innovation for organic processing sector - Keep processing simple in order to keep the naturalness of the product (e.g. use biological, mechanical and physical methods) - Use organic, local and clever ingredients. 2. Careful processing in organic farming Presentations: - Regula Bicket from Fibl, on BioSuisse standards. - Rafael Guardeno Amaro from Biosabor Nature, on innovative processing techniques and packaging. - Rodophe Vidal from ITAB, on research of careful processing December 2014

7 Discussion: organic processing is a systems based operation, just like organic farming. Nevertheless, the processing part is not illustrated sufficiently in the regulation and more details are needed in order to have a better framework for processing. The research data from the various European research projects currently in progress must be available to the legislative bodies. Solutions: the criteria for evaluating processing methods: - Product: nutrition, impact on quality, taste, appearance, structural changes in the food - Environmental impact energy and waste. - Social / economic and consumer impact. III. Sustainability The organic sector is a model of innovation and sustainability for the agri-industry as a whole and aims to stay in the lead. That is why companies would like to see some environmental management requirements in the organic regulation, based on criteria that come from the private standards, developed specifically for organic producers in multiple countries. 1. Environmental management requirements Impacts and opportunities Context: In article 7 of the Commission proposal, an environmental management system is mandatory for the processors and retailers of the organic production sector (except microenterprises). Discussion: There were three presentations: - Manuel Rossi Prieto from the European Commission explained the reason why the Commission decided to introduce an environmental management system in the regulation. - Karine Martins and Sébastien Conan from Ecocert Environment presented a comparison between ISO and EMAS. - Lucas le provost from Triballat, presented the environmental management system that they implement in their company. The company decided not to be certified at the moment, because it doesn t see the advantage. An environmental management system is enough. Including environmental performance monitoring for the organic processing companies, was a request resulting from the public consultation and from the stakeholders (e.g. IFOAM EU). DG Environment did a study showing that companies (except micro-enterprises) have all in all more benefits implementing environmental management systems than costs (e.g. companies can save money by saving energy) Added value of the product thanks to its reputation. The Commission is open in terms of the choice of an environmental management system, even if they think EMAS is the ideal system in this context December 2014

8 ISO and EMAS: ISO is an international private standard. There is a commitment to respect the local law, but no external communication mandatory. EMAS is a system that comes in addition to the ISO with some more requirements on environmental performance and the involvement of the employee. There is also an obligation to communicate with the public within the EMAS system. Companies are certified according to EMAS by the competent authorities. EMAS easy is not a light version of EMAS, but it is a tool to help small companies to reach the EMAS objectives. Both systems have the objective to improve constantly the environmental management system of the companies and their efficiency. There are objectives to reach every year, and the system helps companies to prioritize their actions and to be coherent in order to reach these objectives. Observations: Few companies have an environmental management system. There are many initiatives taking place in the companies but few of them are formed based on the framework of EMAS or other certifications for management systems. In general companies are afraid of getting certified to an already established system, as they fear a static, not very flexible approach. In France only about 30 companies are certified within EMAS, and only some among these companies belong to the food sector. In general, it is stated that a system which is too strict would not fit to the organic idea and values. Suggestion: It would be more appropriate to have a concept created for the organic companies that would provide a minimum of framework for the evolution of the environmental performance. A first step should be to let companies assess their own environmental impact before obliging them to get certified. Conclusion: Environmental management systems are really useful but we should find alternatives to EMAS and ISO. Tools that are coming from the companies should be formalised. Bioentreprisedurable - developed by Synabio - is a good example of a private standard that could show the way towards an environmental management system. 2. Best environmental performance practices, focusing on food waste management Discussion: Within this workshop there were presentations from: - Dider Perreol from Ekibio on good practices from an important organic processing company in terms of environmental management and of food waste. The management of the food waste is very diverse. Within the production cycle, the raw materials are directly recycled. 80% of the waste is recycled and an additional 10% is sold as organic feed December 2014

9 When the products have nearly reached its recommended consumption date then they are given to the employees or to associations. As a long term strategy, the company created a foundation, organising trainings on sustainable cooking, and raising awareness about sustainable food consumption. Having harmony and satisfied employees in a company has no price - Louise Browaeys from Synabio presented the private standard Bioentreprisedurable. It exists since There are around 30 criteria and 6 pillars. The pillar on environment covers the sustainable use of resources, the reduction of the impact of the company s activity on the environment, the reduction of climate change and the preservation of Biodiversity. Conclusion: the good practices that the companies exchanged were the following: Within the production cycle: - Recycling production water (used to cook) in order to use it afterwards for cleaning - Control of the energy consumption - Reduction of the paper consumption - Reducing the packaging Beside the production cycle: - Local suppliers - Gifts to food banks - Special trainings for the employees and their children - Biodiversity on the production site, like hive or sheep for mowing grass - Promotion of alternative means of transport to and from work; CO2 compensation within the proper production chain of the company not in a place that has no link with the company IV. Conclusions 1. Pesticide threshold Use the guidelines that already exist to settle an efficient system rather than a unique threshold. Thresholds can be a tool to improve the findings of malpractice, but not to decertify products. The creation of a European Monitoring Centre on substances in the organic products could help to enhance our expertise and strategy on this issue. 2. Import Before setting an import system only based on compliance, specificities from third countries should be identified, for instance regarding the substances authorised. Develop a system of compliance with exceptions in order to make access to the European market more flexible, especially for production systems that are not regulated at European level because they concern other types of climate. Or to recognise already existing regional organic standards December 2014

10 3. Control Keep annual controls. Settle criteria for risk based approach in order to harmonise the practices of the control bodies. Traceability should be reinforced in the regulation to efficiently fight against fraud in the organic sector. 4. Quality Promote innovation for organic processing sector. Keep processing simple to maintain the naturalness of the product (use biological, mechanical and physical methods) Use organic, local and clever ingredients. 5. Careful processing Criteria to evaluate processing methods: Product: nutrition, impact on quality, taste, appearance, structural changes in the food Environmental impact energy and waste. Social/economic and consumer impact. 6. Environmental performance Companies ask for a procedure/system created for organic companies, providing basic framework for the evolution of the environmental performance. The first step should be to let the companies assess their own environmental impact before obliging them to get certified 7. Some Environmental management good practices - Recycling the water from the production (used to cook) in order to wash after the production - Control of the consumption of energy - Reduction of paper consumption - Limitation of packaging - Technique of intermediate storage - Local supplies - Gift to food banks - Special training for employees and their children - Biodiversity on the production site, like flocks of sheep for mowing grass - Promotion of alternative ways for the employees to travel to work - CO2 compensation within its own production chain Not in a place that has no link with the company December 2014