BEUC BEUC/130/2003 The European Consumers' Organisation 19/03/2003 Bureau Européen des Unions de Consommateurs Avenue de Tervueren, 36/4 B - 1040 Bruxelles Tel: (32 2) 743.15.90 Fax: (32 2) 740.28.02 consumers@beuc.org BEUC Comments Towards a European Action Plan for organic food and farming Consultation of the European Commission, DG Agriculture BEUC, the European Consumer s Organisation, representing 36 members from 26 countries, welcomes the opportunity to comment on the Commission's consultation paper Towards a European Action Plan for organic food and farming. General Comments Community aid must favour farms that take environmental aspects into account. Community action should focus on agro-environmental measures, by developing the concept of "reasoned agriculture" or good agricultural practice and by supporting organic agriculture. New and better agro-environmental criteria must be developed. CAP reform therefore should not merely maintain the status quo but should bring about environmental benefits that would not otherwise be achieved. We want money to be spent on better and improving more sustainable agricultural practices ("agriculture raisonnée"), improved environment, rural development, animal welfare and better quality, safety and choice of food for consumers. There should be a substantial transfer of direct aids from the first to the second pillar of the CAP (and more than envisaged in the Mid-Term Review proposals). Organic farming should be given special support as an important contribution to sustainability but, more generally, policies should be directed towards improving sustainability across all forms of production in all sectors and for all farms. Over-concentrating on organic production however does not best help the environment, it is rather that the contribution to sustainability should involve organic as well as conventional (and GM?) production. New technologies may also affect consumer choice. BEUC is not in principle opposed to GM food for example but the introduction of GM technology must not be allowed to damage conventional or organic agriculture. In the particular conditions obtaining in Europe there are still unresolved questions regarding the possibility of co-existence between agriculture based on GM technology and conventional agriculture, particularly in the long term. There is growing consumer demand for organic food for a variety of reasons. Organic farming has among other things the potential to make an important contribution to the overall objective of sustainable agriculture. BEUC130//2003 Page 1/7
European consumers want more variety and choice in the food on sale. Organic products, smallscale products as well as standard products must co-exist on EU markets. Individual comments 1. Marketing: Developing and facilitating various systems for organic produce sales. Do you think this is. Organic farming so far contributes less than 5% to the overall community farming system, but it has the potential to be a fast growing market, depending on consumer demands and their rising environmental concerns. It is important to maintain and encourage organic agricultural systems in each country so as to contribute to local and global preservation of biodiversity, varieties/species and more. An effective legislative framework is therefore necessary to harmonise marketing, developing and facilitating systems for organic produce sales. One should however think of the simplification of rules in general. If member states wish to apply higher organic standards than suggested by the EU, they should be allowed to do so. However this should not be to the detriment of countries that have decided to do different, but in line with European standards. In should never happen that the rules practised in one country are perceived as being laxer than in another country to the detriment of the promotion of organic production. In addition, as Member States may be unable to produce enough organic foods to meet demand, an important share is imported into the EU. The legislative framework must therefore integrate the international dimension of trade in this sector. Organic food can contain food additives, but the list is much more restricted, around 35, compared with hundreds in conventional food. It seems that the use of additives might be handled differently at national level. It is important that the strictest rules apply with regard to the use of additives, as this is one of the shopper s arguments for buying organic products. Consumers who wish to buy organic products should have access to: High quality, priced products 1 from organic production that consumers can afford; Clearly and conspicuously labelled products that state the organic production method The use of various different organic labels does not contribute to consumer understanding and can only reach a small part of the interested consumer who know the particular meaning of these individual organic logos the majority of consumers can not be expected to know them; Products that are labelled in a way that easily allow the comparison of products. 1 reasonable = relation between higher production costs and sales price. This should not include unreasonably high trade margins. BEUC130//2003 Page 2/7
2. Targeting: Targeting organic farming to environmentally sensitive areas. Do you think this is. Generally speaking organic farming puts less stress on the environment than many conventional farming systems. Therefore it makes sense to use organic farming as a specific tool in environmental protection. Especially when protecting drinking water resources for future generations. 3. Adviser service: Encouraging the exchange of technical information between farmers. Do you think this is VERY It is important to ensure the recognition of standards and the participation of farmers in the further improvement of standards. Links between research and practical farming should be very close. We find it important that there is an exchange of views amongst farmers. We find it equally important to tell consumers more about the principles of the organic farming processes, as consumers in general need more information about how modern agriculture (organic and conventional) is organised. Some consumers are disappointed about the way modern organic farming works, because they have no basis of rating any criteria. It is important to make consumers aware of the potentials of the production method and to compare different agricultural systems. On the other hand one should not promise more via advertising and promoting organic production, than it is possible to get out of it. 4. CAP: Ensuring that the Common Agricultural Policy supports the development of organic farming. Do you think this is NECESSARY There should be a substantial transfer of direct aids from the first to the second pillar of the CAP (and more than envisaged in the Mid-Term Review proposals). Organic farming should be given special support as an important contribution to sustainability but, more generally, policies should be directed towards improving sustainability across all forms of production in all sectors and for all farms. The encouragement of organic farming should be market-oriented. Being market-oriented will benefit consumers because, logically, farmers will then be producing only what consumers want. This is also true for organic farming. The demand should be encouraged and be supported by measures on the supply/farmingside (e.g. accessibility, presentation) but not vice versa. BEUC130//2003 Page 3/7
5. Traceability: Ensuring traceability and organic food authenticity. Do you think this is VERY linked to controls Organic farming contributes to the enhancement of food choices for consumers, all the more when they are aware of organic standards. Organic farming is based on particular product standards that are relying on trade agreements, certification systems and controls by independently recognised and approved laboratories. Regular testing of the products may not always be possible and therefore the reliance on a proper certification system is all-important. To give sufficient reassurances to the consumers we believe a proper traceability system must be in place. The organic products must be known by the inspection bodies to assure regular inspections of the facilities and control of the products. The controls should be focusing on the proper paper trails, which requires the correct functioning of a traceability system to be in place. Where possible controls should also rely on chemical testing to support the paper trails if technically viable and therefore adding value to the controls. The checks for compliance should be subject to regular controls allowing organic products produced according to the standards to be put on the European market, The controls should be extended to the complete food chain, and consequently not solely apply to the producer level, but also to retailers and distributors. One should explore what is meant by organic food authenticity. 6. Logo: Reinforce the use of the EU logo. Do you think this is We are in favour of a wider use of the EU logo. It will facilitate trade and expose more consumers to a stronger and easily recognised organic alternative when buying food. But equally we strongly disagree with any proposal to make the use of the EU logo mandatory within the European Union. A much better strategy would be to make the EU logo an attractive logo to use for all organic producers. Other established logos following stricter rules should not be prevented from being used, as long as their standards are transparent and the consumers would know what they are standing for, as it is for instance the case for the French AB Logo. 7. Private standards: The access to information (common database) on additional standards and inspection requirements where they exist. Do you think this is NECESSARY VERY We support the establishment of a database of different standards to facilitate comparison between private standards and thus facilitate trade and mutual recognition of standards and certification systems. This database should be publicly accessible. Products allowed on such a database should be subject to an independent evaluation by recognised and certified bodies to judge their compliance with recognised organic standards and to judge for the comparability or equivalence of standards. BEUC130//2003 Page 4/7
These different standards however may not contribute to misleading consumers as to the promotion of products having particular properties, which, in the end, cannot be proven to be true. 8. Testing methods: The harmonisation of testing methods, control procedures, supervision and accreditation together with efficient co-operation between all actors involved in the inspection system, including Community inspections. Do you think this is Failures in proper implementation of European legislation, in general, into national legislation have led consumers to question the efficiency of the European supervising systems and led consumers to question the efficiency of the control mechanisms. Organic farming contributes to the enhancement of food choices for consumers, all the more when they are aware of organic standards. Organic farming is based on particular product standards that are relying on trade agreements, certification systems and controls by independently recognised and approved laboratories. Regular testing of the products is not always possible and therefore the reliance on a proper certification system is all-important. The harmonisation of testing methods, control procedures, supervision and accreditation together with efficient co-operation between all actors involved in the inspection system, including Community inspections is therefore important and adds credibility to the use organic logo. The special status of organic products should these products not prevent for being an integrated part of monitoring programmes with regard to residues, levels of contamination, nitrate content or residues of animal medicines. 9. Import: The implementation of appropriate standardised procedures to ensure that imported products respect both fair competition with EU products and EU commitments regarding developing countries. Do you think this is NECSSARY VERY As Member States may be unable to produce enough organic foods to meet the demand, an important share is imported into the EU. The legislative framework must therefore integrate the international dimension of trade in this sector. For imported products that are labelled organic European organic standards must be applied. Standards should be open and non-discriminatory. It is necessary to provide international guidelines for organic food control systems in order to facilitate recognition of national systems as equivalent for the purposes of imports. 10. Standards: The establishment of a body for delivering independent, excellent and transparent advice on which production methods, substances etc. can be accepted in order to assure conformity with the principles of organic farming. Do you think this is USEFUL If the EU were not allowed to perform controls outside the EU we agree that control bodies should be accredited by IFOAM. BEUC130//2003 Page 5/7
11. Statistical data: The collection and communication of official statistical data on production, consumption, and trade (EU imports and exports) on a more permanent basis. Do you think this is Statistical data are important and should contribute to realistic market analyses to make the right choices to promote particular production systems towards sustainable farming systems. 12. Research: The effective funding of research in organic farming from the point of view of food safety and quality, including expanding research into the development of new products and processing methods and the environmental sustainability of organic farming, and into comparison studies between organic and conventional food. Do you think this is Your ideas and comments on "Research": The use of copper in organic agriculture gives rise to concerns when considering organic farming as being an important contribution to sustainable agriculture. Research should look into the replacement of this agent to contribute to the further improvement of organic agriculture. In its opinion from 12 April 2001 on food-borne zoonoses the Scientific Committee on Veterinary Measures relating to Public Health suggested that the risks posed by the use of manure and recycled sewage and slurry for fertilising vegetables and berries should be investigated. Since a substantial growth is foreseen in organic farming we believe it is important to look into this particular issue, either through setting standards by the risk manager or through research to further improve recycling of manure to be used in organic farming. Many of the concerns of farming today such as consideration of the environment and nature, animal welfare, product quality and health are all fundamental aspects of organic farming. The wide range of factors that can affect plant composition (e.g. genetics, agronomic practices, climate and post harvest conditions) makes investigation of the nutritional value of organically and conventionally produced food difficult to carry out and to interpret. Because of the significant interest in this topic further research should be done. We support research programmes that include consumer concerns and expectations, as well as other projects that attempt to develop more environmentally friendly and sustainable methods of agricultural production. Organically and conventionally produced products should be compared regularly based on adequately defined study types. Apart from the proposals listed above, what else do you think could be done in order to facilitate organic farming in Europe? We have received various comments from our member organisations. To give an impression of the variety of comments we attach 3 individual comments for further consideration - the views of any our organisation are not necessarily shared by all our members. BEUC130//2003 Page 6/7
Danish position Statisk kopi afhøringssvar, EU... German position Stellungnahme Organic farming... French position paper Agriculture biologique-positio... END BEUC130//2003 Page 7/7