Essay: Introduction to IFOAM EU (organic food and farming)

Introduction to IFOAM EU
IFOAM EU is the European umbrella organisation for organic food and farming. Its main goal is to achieve ecologically, socially and economically sound systems which should be based on the principles of organic agriculture – health, ecology, fairness and care. IFOAM EU is supported by more than 190 member organisations. It covers the complete range of organic food chain and organic establishments – the farmers, where it all starts, through processors, retailers, certifiers, consultants, traders and researchers to environmental and consumer advocacy bodies.
IFOAM EU was founded in 1972. Since then IFOAM EU works to achieve true sustainability in agriculture from the farmers on the field to the consumers. The Organisation has over 1000 affiliates in more than 120 countries. Every three years there is a General Assembly meeting in order to unify, lead and achieving the goals. It has 10 regional bodies all over the world. IFOAM AgriBioMediterraneo is organic international body from 16 Mediterranean countries, IFOAM Asia, IFOAM EU Group which stands for European Union, IFOAM Euro-Asia representing Russian speaking countries, IFOAM France which is a small national group in France, IFOAM Iran, IFOAM Japan, IFOAM Latin America which represents all affiliates in Latin America, ISAN which stands for Southern Africa and IFOAM North America which is the newest regional body). The IFOAM EU Group represents more than 300 IFOAM EU member organisations from the 28 states of European Union, the EU accession countries and EFTA. It was formally constituted in February 2000. The office is in Brussels.
The Organisation’s main mission is to lead change in organic way. IFOAM EU represents the work for sustainability in agriculture for the whole way of the value chain. Three key areas of IFOAM EU’s interest are:
Supply – facilitating capacity development for sustainable production.
Awareness raising – campaigning and acting as a resource centre for organic communications.
Policy & Guarantee – advocating and providing support for the creation of a favourable policy environment.
IFOAM EU organizes high profile events for organic stakeholders where they share their knowledge and expertise. It implements projects all around the world to empower local stakeholders and help raise consumer awareness. IFOAM EU puts Organic Agriculture on the agenda of international decision makers and helps consumers to go through the organic standards and regulations. The last but not the least activity is shaping the future of the organic sector by training a new generation of leaders through Organic Leadership Courses.
The main aims of IFOAM EU
The main milestone of IFOAM EU interest group is to make Europe more organic. IFOAM EU supports the idea of sustainable growth of the organic sector throughout Europe and a further development of organic production based on organic principles. The idea of Commission’s proposal of organic regulation is fully supported by the IFOAM EU group although IFOAM EU has continually pushed against the strict harmonisation in Europe. While membership in the European Union presupposes compliance with the European Union’s legal system, IFOAM EU believes that it is important to bear in mind that not all European Union countries are at the same level of economic maturity and do not have a well-developed ecological sector. These countries must be able to adapt to the organic farming regulation slowly and at a satisfactory pace in order to achieve the most favourable outcome. That is why IFOAM EU believes that the proposal is not suitable for achieving these aims. IFOAM EU has the opinion that European citizens have to benefit the most from organic food and farming  and organic production and they have to have the highest amount of benefits as possible. The proposal does not completely look on the impacts and recommendations offered by the sector throughout the Commission’s regulatory review and revision process. The proposal introduces more obligations and obstacles for the states rather than offering real benefits compared to current legislation. IFOAM EU believes that the proposal may lead to fall of the organic production across Europe. Small organic farms and businesses and less developed regions would have the biggest problems in case of reducing the production. The demand for sustainable food in Europe is growing every year and IFOAM EU represents the opinion that the proposal puts this at risk. Another important point is the diversity across all the European member states which IFOAM believes that the proposal does not reflect enough. The main advantage of the organic farming is not the organic production itself but the process of ‘learning’ how to produce organic food and business and sustainability. The biggest benefit is finding new technologies and practices which are relevant for the food production system. Furthermore, thinking about the future generations is one of the steps to the sustainability. IFOAM EU stresses out the importance of further development of the organic legal framework with balance of the basic regulation and annexes and the necessary resources needed for good implementation and any other proposals. Therefore, IFOAM EU supports the proposal of organic farming but not in the shape as it is proposed now. IFOAM EU requires substantial changes, otherwise IFOAM EU would have to reject the proposal.
The foundation of IFOAM EU’s position
IFOAM EU has constructive and detailed proposals for the necessary changes to the proposed organic regulation. There are three main aims – removing obstacles for a sustainable growth, ensuring fair competition for farmers and all operator in the organic value chain and maintaining consumer confidence by guaranteeing organic quality.
IFOAM EU’s position is supported by the problems with the regulation which arose in practice. One of the main misunderstandings in the process of drafting a new organic EU regulation has been assumption that there is a problem with “regulation” and with consumer trust. The proposal is not proposed in compliance with the external evaluation report which was made by Thünen Institute. The report says that “the organic legislation generally provides a good basis for a sustainable development”, “more guidance for MS is needed to avoid lack of harmonisation”, “rules are generally adequate, but impact needs to be increased”, “in many cases the rules are adequate but there is a lack of harmonised interpretation and enforcement in Member States”. This was also outlined by IFOAM EU – the current legislation is adequate and the right way to protect the organic production and farming is improving the current way of things, not necessarily frame a new legislation.
The proposal also ignores the conclusions of the scientific evaluation of the sector and the stakeholders’ opinions are not considered enough. Their opinion is that the current problem is that the demand for organic products is bigger than the real production. It means losing the real sustainable growth as a goal of the EU 2020 Strategy. The new proposal does not consider this at all.
The demand of organic production and organic products grows every year in Europe but the number of organic farmers is decreasing every year. It is necessary to define how to achieve the goal of organic production based on its principles. IFOAM EU supports the new European Union Organic Action Plan (2014), however believes that the proposal does not have clear commitments and has no ambition for concrete action. Even in cases when there are any actions in the proposal, there is no clear objective or timeframe.
These are the main arguments why IFOAM EU does not support the proposal for a regulation on organic production and labelling of organic products.
The arguments of IFOAM EU
IFOAM EU expresses its satisfaction that many suggestions proposed by IFOAM EU were included in the new proposal, such as group certification for small farmers or environmental requirements for processors and traders. Nevertheless, further improvements are necessary in order to achieve faster growth of organic farming in the European Union. Current proposal fails to reach its aim of sustainable growth of organic sector and brings new obstacles which may lead to a decline of organic production in Europe, particularly in less developed regions and at small farms. The Organisation believes that there is a necessity of progressive improvement of implementation of organic production rather than radical changes which brings the new proposal. In this context, IFOAM EU calls for ongoing debate on this matter and for further development of farming based on organic principles.
The new proposal changes the basic scope of agricultural products which are under organic legal framework. IFOAM EU believes that this modification is not necessary and cause pointless confusion. The scope from Regulation (EC) No 834/2007 clearly identifies four categories of products which is more understandable and practical. The categories are (a) live or unprocessed agricultural products, (b) processed agricultural products for use as food, (c) feed and (d) vegetative propagating material and seeds for cultivation. IFOAM EU expresses its conviction that in order to implement the Regulation, the scope must be easily comprehended by everybody. Moreover, the reference to the Treaty on the Functioning of the European Union and additional products which are not covered by this Treaty does not simplify the legal basis for organic production. Furthermore, the Organisation considers reinserting the possibility to establish national rules for out-of-scope animals as a crucial point. At the same time, fruit juices and some herbal teas should be included in the scope of the new proposal. In addition, cosmetics, textile, organic farming inputs and other non-food products should be also included in the scope since these products are present at the current market and their protection based on proper standards is very important.
Other changes are considered by the Organisation in the Article 3 where definitions are defined. Even though Commission included in the new proposal IFOAM EU’s suggestion of group certification for small farmers, the definition of group of operators is ineffective. The proposal defines an operator as a farmer who has a holding of up to 5 hectares of utilised agricultural area and who may, in addition to producing food or feed, be engaged in processing of food or feed. However, this criterion is not suitable since farm with for instance 5 ha of raspberries is not a small farm. Therefore, IFOAM EU proposes that the criterion of small farmers should not be based on a farm’s area but on total turnover or labour use. Furthermore, the Organisation believes that farmers should be divided into groups based on geographical principles. Another term which should be properly defined or replaced is integrity. This expression is used on variety of parts of the Regulation without explanation.
In the new Regulation there is a possibility to adopt implementing acts twelve times and delegated acts nearly three times more. This is considered by IFOAM EU as not allowable. The Commission would have a power to make fundamental changes which would cause unclearness in the future. Delegated acts should be used only in cases when fast decisions are required and where basic requirements are already set. They should be used only if it is necessary. Implementing acts should be used only for technical questions where national specifics and experts are needed. Fundamental parts of the Regulation should not be possible to change with non-legislative acts. Finally, IFOAM EU suggests that some requirements can be left on individual national consideration.
Furthermore, IFOAM EU finds the necessity of changes in Articles 21 and Article 22. Terms bio and eco should not be used as derivatives or synonyms of the term organic since it can cause a confusion for both consumers and farmers. The use of multiple terms in labelling or advertising can bring many misunderstandings and conflicts about what is and what is not organic. In addition, the organic production logo of the European Union should not be required to appear on the packaging, it should be the choice of the producer. The Organisation considers European organic logo as unfair for non-EU producers and producers who do not want be identified with the organic production logo. Moreover, IFOAM EU suggests that the indication of the raw material of which is the product composed should be in case of EU/non-EU Agriculture, where the product is created from both raw material from European Union and raw material from the third country, with marked ratio of materials originating in the EU and originating outside the EU. Consumers have the right to know the percentage of how much is the product composed from EU materials and how much from non-European materials. This ratio is important for purchasing and consumption decisions where the consumer may prefer product mainly produced in the EU or in the third country.
As another crucial point, IFOAM EU considers the necessity of differing on basis of diverse situation in organic production through Europe. On behalf of this matter, the Recital (21) and Article (22) of Regulation (EC) No 834/2007 on flexibility should be re-inserted. This would help small farmers and farmers operating in countries where the organic production is not fully developed. Member States differ in organic production, infrastructure, geographical and climatic conditions etc. and farmers have diverse conditions in which they can develop organic products. Since availability of ingredients and practices vary depending on the region, The Regulation should consider differences in Member States.
IFOAM EU stresses out one more time the importance of effective changes in the new Regulation in order to increase an organic production in the European Union. The proposal should be based on the principles of organic farming and therefore the Organisation invites all political and interest groups towards further debate which will lead to an acceptable compromise.