The Organic Inputs Evaluation project >Bernhard Speiser, Otto Schmid & Lucius Tamm, FiBL >Brussels, 12 March 2007

Contents Introduction to the project and its aims Main results of the project >evaluation process & review by an expert panel >new evaluation criteria Implementation in the new Organic Regulation >evaluation criteria in Article 11 >test with case studies > suggestions for amendments Conclusions, research needs

Acknowledgements >Administrative co-ordination: DARCOF (Lizzie M. Jespersen) >Scientific input from project partners and many external experts >Funding from: Commission of the European Communities, 5 th Framework Programme of RTD, contract QLK5-CT and from: Swiss Federal Office for Education and Science (BBW)

The Organic Inputs Evaluation project >Concerted Action >Duration: January 2003 – December 2005 >12 partners and many external experts >Website: Objectives >To develop harmonized and standardized procedures for evaluation of plant protection products, fertilizers and soil conditioners for use in organic agriculture.

Considerations on objectives >Evaluation of inputs should be based on scientific evidence and on principles of organic farming. >Progress must be possible. It should be possible to authorize new inputs, but the principles of organic farming must be conserved. >The evaluation process should be transparent and involve stakeholders. >International harmonization is desirable, especially with the Codex Alimentarius guidelines.

Organic farming Reg. 2092/91 New Council Regulation Inputs: overlap with other legislation Plant protection Dir. 91/414 4 th stage re-evaluation New Regulation What can be used Support from Organic Inputs Evaluation Support from REBECA

Two inventories of the existing system Main findings >Large variability between EU Member States concerning allowed products. >Inclusion of new plant protection products on Annex II B is impossible in most cases (non-contact clause). >If inclusion is possible, the process is very slow. Download:

The evaluation process present Request Discussions Decision proposed Request Evaluation Decision Review Final recommendation advice by EU expert panel

Why review by an EU expert panel ? >Homogeneity across requests - order of presentation of facts - degree of detail - line of argumentation >Completeness of facts >Adequate interpretation Applicant and expert panel should try to reach consensus, to avoid contradictions in the dossier.

EU expert panel >Is, or is part of, the independent expert panel for technical advice cited in Action 11 of the EU Organic Action Plan. >Acts in the public interest. >Permanent members, to ensure continuity over time and consistency with other organic farming legislation. >Ad-hoc members to provide additional expertise for individual inputs.

Composition of the EU Expert panel >1 chair >6 organic farming experts, covering wide range of animal and crop husbandry and broad geographic spread >1 expert for - marketing, policies, standards, consumer expectations - organic inspection and certification - soil science - biochemistry or inorganic chemistry - ecotoxicology - human health - plant protection and/or plant nutrition >Can one expert cover more than 1 field of expertise ? >This is the composition suggested for evaluation of inputs. For other tasks, composition of the panel might have to be enlarged (see proposals of the Organic Revision project).

The Criteria Matrix >The Criteria Matrix was developed as a tool for the evaluation process. >It contains all information necessary for the evaluation process. >It makes the evaluation process transparent. >It is a systematic collection of arguments, which allows to compare the Member State views in a simple way. >Two case studies illustrate its use >Matrix has been used to evaluate potassium bicarbonate

Criteria … must allow the «right products» New «candidate» substances ? How to define ? Natural products of low concern > YES Synthetic products > NO Products of high concern > NO

Project‘s assumptions for the criteria >They should reflect the current consensus on which inputs are allowed. > Products currently listed in Annex II should pass the criteria. >Organic evaluation should not duplicate efforts from pesticide registration (risk assessment for environment, human health, residues …). >They should be harmonized with the Codex Alimentarius guidelines for organically produced foods. >Emphasis on criteria, not on traditional use. >Products must fulfill all criteria to pass.

Present criteria (Article 7) >Traditional use >Non-contact (for pesticides only) >Necessity >Environment allowed contact: not allowed must be essential no unacceptable effects

Criteria proposed by the project >Traditional use >Non-contact (pesticides only) >Necessity >Environment >Origin >Manufacture >Human health >Socio-economic impact >Organic farming principles (delete) existing new no yes partly yes Codex Alimentarius

Implementation After the end of the Organic Inputs Evaluation project, a New Organic Council Regulation was proposed. >Article 11 (current numbering) contains evaluation criteria. >Last version considered here: 22 Dec 2006 Note: Because this was after the end of the Organic Inputs Evaluation project, the following slides represent the authors‘ view, not that of the project.

Criteria in the new Organic Regulation (Article 11) >Organic farming principles >Environment >Human health >Necessity >Origin (rule & 2 exceptions) >Traditional use >Manufacture >Socio-economic impact new (part of objectives) existing new existing not included

Origin, the rule Art. 11, 2. (b) «all products shall be of plant, animal, microbial or mineral origin …» Examples >Plant: compost, pyrethrine >Animal: farmyard manure >Microbial: Bacillus thuringiensis >Mineral: clay

Art 11, 2. (b): «… except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available» Art 11, 2. (c) (ii): «if products are not of plant, animal, microbial or mineral origin and not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop» Origin, the exceptions and, for plant protection products:

Case study 1 Plant protection products fertilizers Farmyard manure allowed 2. The authorization […] is subject to the objectives and principles laid down in Title II … 2. (a) Their use is necessary for sustained production and essential for its intended use; 2. (b) … shall be of plant, animal, microbial or mineral origin except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available; 2. (c) (i)... is essential for the control … 2. (c) (ii) if products are not of plant, animal, microbial or mineral origin and are not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop; 2. (d) … is essential for […] fertility of the soil … 3. (c) Products and substances used before the adoption of this Regulation […] may continue to be used after said adoption…

Case study 2 Chilean nitrate not allowed Art. 4. (b) (iii) low solubility mineral fertilizers Plant protection products fertilizers 2. The authorization […] is subject to the objectives and principles laid down in Title II … 2. (a) Their use is necessary for sustained production and essential for its intended use; 2. (b) … shall be of plant, animal, microbial or mineral origin except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available; 2. (c) (i)... is essential for the control … 2. (c) (ii) if products are not of plant, animal, microbial or mineral origin and are not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop; 2. (d) … is essential for […] fertility of the soil … 3. (c) Products and substances used before the adoption of this Regulation […] may continue to be used after said adoption…

Case study 3 Pheromones for mating disruption allowed Plant protection products fertilizers 2. The authorization […] is subject to the objectives and principles laid down in Title II … 2. (a) Their use is necessary for sustained production and essential for its intended use; 2. (b) … shall be of plant, animal, microbial or mineral origin except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available; 2. (c) (i)... is essential for the control … 2. (c) (ii) if products are not of plant, animal, microbial or mineral origin and are not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop; 2. (d) … is essential for […] fertility of the soil … 3. (c) Products and substances used before the adoption of this Regulation […] may continue to be used after said adoption…

Case study 4 Plant protection products fertilizers Spinosin allowed (?) Art. 4. (c) (iii) … unacceptable environmental impacts ? 2. The authorization […] is subject to the objectives and principles laid down in Title II … 2. (a) Their use is necessary for sustained production and essential for its intended use; 2. (b) … shall be of plant, animal, microbial or mineral origin except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available; 2. (c) (i)... is essential for the control … 2. (c) (ii) if products are not of plant, animal, microbial or mineral origin and are not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop; 2. (d) … is essential for […] fertility of the soil … 3. (c) Products and substances used before the adoption of this Regulation […] may continue to be used after said adoption…

Case study 5 Plant protection products fertilizers Glyphosate herbicide allowed ! Art. 4. (c) (iii) … unacceptable environmental impacts ? 2. The authorization […] is subject to the objectives and principles laid down in Title II … 2. (a) Their use is necessary for sustained production and essential for its intended use; 2. (b) … shall be of plant, animal, microbial or mineral origin except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available; 2. (c) (i)... is essential for the control … 2. (c) (ii) if products are not of plant, animal, microbial or mineral origin and are not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop; 2. (d) … is essential for […] fertility of the soil … 3. (c) Products and substances used before the adoption of this Regulation […] may continue to be used after said adoption…

Plant protection products general Proposed amendments … 2. The authorization […] is subject to the objectives and principles laid down in Title II … 2. (a) Their use is necessary for sustained production and essential for its intended use; 2. (b) … shall be of plant, animal, microbial or mineral origin except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available; 2. (c) (i)... is essential for the control … 2. (c) (ii) if products are not of plant, animal, microbial or mineral origin and are not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop; […] except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available; 2. (c) (ii) if products are not of plant, animal, microbial or mineral origin and are not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop; 2. (c) (ii) if alternatives are not available, products which are not of plant, animal, microbial or mineral origin may be approved, if they are identical to their natural form, or if they are used in traps and dispensers; «traps and dispensers»: Codex Alimentarius

Case study 5 repeated Plant protection products fertilizers Glyphosate herbicide not allowed Art. 4. (c) (iii) … unacceptable environmental impacts ? 2. The authorization […] is subject to the objectives and principles laid down in Title II … 2. (a) Their use is necessary for sustained production and essential for its intended use; 2. (b) … shall be of plant, animal, microbial or mineral origin; 2. (c) (i)... is essential for the control … 2. (c) (ii) if alternatives are not available, products which are not of plant, animal, microbial or mineral origin may be approved, if they are identical to their natural form, or if they are used in traps and dispensers; 2. (d) … is essential for […] fertility of the soil … 3. (c) Products and substances used before the adoption of this Regulation […] may continue to be used after said adoption…

A lot has been achieved in the New Organic Regulation! What remains to be done: >Expert panel: should be installed. >Criteria: some amendments are needed. For cleaning and disinfection agents, the same exceptions as those proposed for plant protection products should be allowed. Conclusions The problem explained for glyphosate herbicides applies to all substances - applied outside the growing season or - applied to non-edible crop parts or to the soil - and also to substances other than plant protection products! Evaluation now based on scientific evidence and on principles of organic farming More progress is now possible International harmonization

Research needs Topic no 1: «right input on the right occasion» >Optimization at regional / crop level with specific conditions for use (instead of «need recognized …») >Replacement of currently allowed inputs by new inputs or alternative methods Topic no 2: new technologies >Compliance of upcoming new technologies such as nanotechnology with organic farming principles Thank you for your attention !