EU Regulation – a Wolf in Sheeps clothing

The EU have proposed changes to the EU regulation that governs the way organic agriculture is certified – the rules to which organic farmers and processors adhere.  The first question should be whether there is a need for a change?   Whilst not perfect the current regulation seems to work reasonably well.  The market is developing across Europe and the rest of the world and starting to recover in the UK.  There is a regular grumble about seed derogations but this is perhaps more to do with interpretation and implementation of the regulation that the regulation being at fault.  A significant piece of regulation with just one fault could be regarded as a success – so why change it?

The changes have been significantly influenced by a consultation exercise which was poorly promoted and the majority respondents were French organic consumers.  A discerning group no doubt with a fine food heritage but hardly the best constituent to determine the direction in which technical organic production intricacies should be pushed.  Their views perhaps represent an idealised view of what organic production should be and, perhaps, could be if the sector continues to grow and develop but I doubt they have little detailed understanding of how we might get from where we are now with the current regulation to their ideal position.

So what does the new regulation require?  Below is a response to many of the most important changes that will effect the organic grain sector in the UK and some reasons as to why we should not adopt these proposals and should fight to have see they are not implemented.  It is far from a comprehensive critique.

The new regulation:

  • will end the concept of “parallel production”.  This is the ability for farms to run both organic and conventional land at the same time.  Most of the larger organic cereal producers in the UK will have used a phased conversion to complete the conversion of their land without leading to significant problems of contamination of organic products.  Whilst some producers wish to maintain their conventional businesses alongside their organic ones for perfectly sound reasons such as landlord preference or simple risk management.  This does not mean these producers are in any way seeking to act outside the regulation and I believe we have the certification process in place to ensure such producers maintain high quality organic production systems.
  • reduces the quantity of inconversion grain which may be fed to 15%.  This will reduce the demand for inconversion cereals and make the costs of organic conversion greater.  Both this and the measure above will reduce enthusiasm for additional conversion to organic production.
  • will end all “exceptional acts” or derogations as we know them.  This would effectively end the ability for organic growers to use non-organic untreated seed.  Without robust seed production systems this makes organic arable systems less robust when faced with a poor quality harvest.  Such an idea may have merit if it led to the development of varieties truly suited to organic productions systems but the size of the sector means this is very unlikely as the investment in the breeding would not be recovered.
  • require that all feed (60% for monogastrics) come from the holding of livestock production or within the region.  The “region” remains undefined but seems hugely problematic unless the definition means the “region” is so large to the point it is simply meaningless.  Whilst a greater focus on UK production is welcome this measure would send such massive shock-waves through the industry it seems likely that operators in the livestock sector would decertify and the sector shrink significantly.  Perhaps then rather than importing grain form less well regulated Black Sea sources we would simply import livestock products.  Is this really the intended consequence the EU seeks?
  • require decertification of produce that tests positive even if the contamination is not the fault of the producer.  This is the inversion of “innocent until proven guilty”.  A positive test could lead to product decertification regardless of the cause of the problem.  The response to this would be the introduction of greater testing through the supply chain at huge cost.  In the arable sector the UK producer base has tiny instances of contamination coming from farm.  The more problematic supply chains whether fraudulent or adventitious are those abroad and particularly outside the EU.

Other organisations will have varied and compelling arguments as to the effect on the proposals in their sectors.  The policy-heads at Organic Research Centre and the certifiers have concerns about the way in which the new proposals will be implemented and the structure of the decision making process with the EU bureaucracy.  These are also valid criticisms if they make the process less open and difficult to influence by operators and stakeholders.

The consumer responses to the consultation have given the EU a position of championing the consumer and their wishes but the task of political leadership is surely to balance these wishes with the multiple concerns and needs of the operators within the sector.  These proposals have an unbalanced basis and have not been well considered as the seems to be little thought or regard been paid to the consequences that may result.

Please take every opportunity you have to oppose the changes the EU is suggesting and support industry bodies in their opposition.