Concerns and Recommendations on Non-Organic Agricultural Ingredients
Various Member States express concerns about the inclusion of new non-organic agricultural ingredients in Regulation 889/2008 Annex IX, emphasizing the need to maintain the integrity of organic production. Suggestions include keeping the list as short as possible, searching for organic alternatives, and granting national authorizations for non-organic products. There are calls for caution in adding new ingredients and a focus on reducing the existing list. Some advocate for specific supply chains for organic products rather than introducing or maintaining derogations. The revision of Annex IX is seen as potentially impacting the sector's development and availability of organic ingredients.
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Non - organic agricultural ingredients AGRI B4 COP 17 April 2018 1
Regulation 889/2008 ANNEX IX Ingredients of agricultural origin which have not been produced organically referred to in Article 28 2
General remarks from MSs AT should not lose sense by adding almost 50 new ingredients, which could mislead the integrity of organic production DK Annex IX should be kept as short as possible, only in cases of a structural supply problem (otherwise this must be handled via national authorizations). Allowing non-organic products (i.e. conventional juveniles in organic aquaculture) does not motivate the organic sector to use or demand the product in the organic version. There must always be an obligation to regularly search the market for the organic version, if an operator uses a non- organic ingredient. The market must do the work not the authorities More basic discussion of the interpretation of the right quality and amounts of the ingredient needed between MSs with concrete examples. 3
IE Would welcome proposing MS justification for inclusion and discussion before offering a final position. While we see the justification for having such a list; notwithstanding - we would desire that the list be as short as possible. Suggest that the current procedure for granting National authorisations for non-organic products/substances provides sufficient lead in time to stimulate the market to produce or import organic products or, alternatively, for operators to seek an alternative organic substitute. The provisions of granting multi National authorisations up to the permitted limits should be exhausted before submission for inclusion in Annex IX. LU Revision of Annex IX should not mislead the integrity of organic production by adding more new ingredients. The main focus should be the deletion of most possible ingredients from the list. 4
FR Wants to know the treatment that will be reserved for ingredients used in infant milk (ARA, DHA, DHASCO/ARASCO, Galacto-oligosaccharide and Lacprodan All Annex IX ingredients can be withdrawn but a delay should be provided in order to avoid that operators face temporal difficulties and try to obtain national authorisations. The delay provided for lecithin seems to be the good approach IT In general we think that the list in annex IX should be reduced as much as possible or even eliminated. New additions should be deeply assessed. There is the need to build up specific supply chain for organic products (e.g. organic hops), rather than introduce/maintain derogations 5
IFOAM No new ingredients should be added to Annex IX ! The list of Annex IX was first established in 2000 and was supposed to be temporary to make the sector able to provide ingredients that were not available in organic form. The organic sector has significantly developed since then and today many of the ingredients listed in Annex IX are The revision of Annex IX should not be used to add new ingredients, such as hops. This would be a big step backward for the organic movement that aims at going towards 100% organic ingredients. Possible additions would frustrate the many organic producers that are producing those ingredients organically, and who will have huge difficulty on placing them on the market A new transparent system is established to evaluate the availability of organic ingredients. It should be a more market- driven and flexible system that can be updated according to the actual market situation to limit the use of non-organic ingredients to the bare minimum. Temporary shortages of specific ingredients can be addressed by National derogations 6
General remarks Withdrawals almost all current Annex IX Additions majority of products that were suggested to be added contested by at least 1 MS OVER 40 products suggested by end March 2018 and only 3 with no opposition from another MS Methodology required to take a decision 7
MSs suggestions to withdraw (by end March 2018) 8
Proposal What to withdraw from Annex IX 11
Part 1. UNPROCESSED VEGETABLE PRODUCTS AS WELL AS PRODUCTS DERIVED THEREFROM BY PROCESSES To be withdrawn: 1. Acorns Quercus spp. (tbc by DE) 2. Gooseberries Ribes uva-crispa 3. Maracujas (passion fruit) Passiflora edulis 4. Raspberries (dried) Rubus daeus 5. Red currants (dried) Ribes rubrum 6. Pepper (Peruvian) Schinus molle L. 7. Horseradish seeds Armoracia rusticana 8. Safflower flowersCarthamus tinctorius 9. Watercress herb Nasturtium officinale 12
Part 2. VEGETABLE PRODUCTS To be withdrawn: 1. Fats and oils current negative list 2. Fructose in liquid form 3. Rice paper (tbc by ES) 4. Unleavened bread paper (tbc by BE) 5. Pea proteinPisum spp. (tbc by ES) 6. Rum, only obtained from cane sugar juice 7. Kirsch prepared on the basis of fruits and flavourings as referred to in Article 27(1)(c) 13
Part 3. ANIMAL PRODUCTS To be withdrawn: 1. Aquatic organisms, not originating from aquaculture, and permitted in no- organic foodstuffs preparation (tbc) 2. Gelatine from pork 3. Whey powder herasuola (tbc by FI) 14
MSs suggestions to add (by end March 2018) 15
Proposal How to decide on what needs to be added to Annex IX 18
Methodology - - Full dossier required for each product in structured form (no brand names!) Discussion in the COP on each dossier required before we take a decision Additional product can be included in Annex IX only when sound justification and consensus reached by MSs - Requests to add should be followed by a full dossier with justification; Template will be agreed by MSs (poss. COP VI'18) (also indication how many national authorizations were granted in the past by different MSs needed) Deadline to provide all dossier (poss. VIII'18) Discussion based on the dossier provided (poss. COP IX'18) 19
