ORGANIC BELGIAN BEERS :
legislation and organic raw materials
Part I. LEGISLATION
I.1. Organic agriculture
I.2. EC regulation for processed products
I.2.1. Production
I.2.2. Certification
I.2.3. Labelling
I.2.4. Commercialisation
I.3. Organic logos
I.4. Non EC regulation
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
I.1. ORGANIC AGRICULTURE
General objectives:
(a) Management system for agriculture that:
(i) respects nature's systems and cycles and sustains and enhances
the health of soil, water, plants and animals;
(ii) contributes to a high level of biological diversity;
(iii) makes responsible use of energy and the natural resources;
(iv) respects high animal welfare standards;
(b) aim at producing a wide variety of high quality foods produced by the
use of processes that do not harm the environment, human health, plant
health or animal health and welfare.
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
I.2. EC REGULATION FOR PROCESSED PRODUCTS
Legislation: EC 834/2007 and 889/2008 regulations
Common objectives and principles concerning:
a) all stages of production, preparation and distribution of organic
products and their control;
b) the use of indications referring to organic production in labelling
and advertising.
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
I.2.1. Regulation for processed products
● Organic agricultural ingredients
● Processing of food using mechanical, physical or biological methods
● Processing of organic food to be separated in time or space from non-organic
food
● Restriction of the use of food additives and processing aids (to be used to a
minimum extent and only in case of essential technological need)
● Strict limitation of the use of chemically synthetised inputs
● GMOs and products produced from or by GMOs are prohibited
● Ionising radiation (treatment of organic food or raw materials) is prohibited.
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
Regulation for processed products: application to the organic beer production
● Organic agricultural ingredients:
▪ at least 95% of the raw materials must be organically certified;
▪ non-organic ingredients must be authorized on a restricted list
(see annex IX of 889/2008);
▪ an organic ingredient shall not be present together with the same
ingredient in the non-organic form.
● Processing of food with the use of mechanical, physical or biological methods
no specificity regarding the traditionnal brewing process
● Processing of organic food to be separated in time or space from non-organic
food
general organisation of the brewery:
▪ good practices for raw materials reception and storage,
▪ good practices for production ‘s management (organic
must be processed before non-organic, …),
▪ traceability,
▪…
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
ANNEX IX (full version)
Ingredients of agricultural origin which have not been produced organically
•
•
•
1. UNPROCESSED VEGETABLE PRODUCTS AS WELL AS PRODUCTS DERIVED THEREFROM BY PROCESSES
1.1. Edible fruits, nuts and seeds:
— acorns Quercus spp. — cola nuts Cola acuminata — gooseberries Ribes uva-crispa — maracujas
(passion fruit) Passiflora edulis — raspberries (dried) Rubus idaeus — red currants (dried) Ribes rubrum
•
•
1.2. Edible spices and herbs:
— pepper (Peruvian) Schinus molle L. — horseradish seeds Armoracia rusticana — lesser galanga Alpinia
officinarum — safflower flowers Carthamus tinctorius — watercress herb Nasturtium officinale
•
•
1.3. Miscellaneous:
Algae, including seaweed, permitted in non-organic foodstuffs preparation
•
•
•
2. VEGETABLE PRODUCTS
2.1. Fats and oils whether or not refined, but not chemically modified, derived from plants other than:
— cocoa Theobroma cacao — coconut Cocos nucifera — olive Olea europaea — sunflower Helianthus
annuus — palm Elaeis guineensis — rape Brassica napus, rapa — safflower Carthamus tinctorius —
sesame Sesamum indicum — soya Glycine max
•
•
2.2. The following sugars, starches and other products from cereals and tubers:
— fructose — rice paper — unleavened bread paper — starch from rice and waxy maize, not chemically
modified
•
•
2.3. Miscellaneous:
— pea protein Pisum spp. — rum, only obtained from cane sugar juice — kirsch prepared on the basis of
fruits and flavourings as referred to in Article 27(1)(c).
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
Regulation for processed products: application to the organic beer production
● Organic agricultural ingredients:
▪ at least 95% of the raw materials must be organically certified;
▪ non-organic ingredients must be authorized on a restricted list
(see annex IX of 889/2008);
▪ an organic ingredient shall not be present together with the same
ingredient in the non-organic form.
● Processing of food with the use of mechanical, physical or biological methods
no specificity regarding the traditionnal brewing process
● Processing of organic food to be separated in time or space from non-organic
food
general organisation of the brewery:
▪ good practices for raw materials reception and storage,
▪ good practices for production ‘s management (organic
must be processed before non-organic, …),
▪ traceability,
▪…
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
Regulation for processed products: application to the beer production
● Restriction of the use of food additives and processing aids
must be part of a restricted list (see annex VIII of 889/2008) and respond
to specific conditions of use and are to be found in the nature:
▪ no exogen enzymes (brewing, beer stabilisation, …);
▪ no preservatives like sulfites, …;
▪ no chemical treatment for beer stabilisation (PVPP, …) or foam stability;
▪ Isinglass and tannic acid are authorized.
● Strict limitation of the use of chemically synthetised inputs
no synthetic preservatives, flavouring or colouring agents, …
● GMOs and products produced from or by GMOs are prohibited
raw materials selection, yeast, (enzymes), …
● Ionising radiation (treatment of organic food or raw materials) is prohibited.
raw materials, process, …
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
ANNEX VIII : partial selection
SECTION A : FOOD ADDITIVES INCLUDING CARRIERS
E270
Lactic acid
E334
Tartaric acid
E290
carbon dioxide
E422
Nitrogen
E296
Malic acid
E501
Potassium carbonates
E300
Ascorbic acid
E941
Nitrogen
E330
Citric acid
E948
Oxygen
SECTION B : PROCESSING AIDS AND OTHERS PRODUCTS FOR PROCESSING OF INGREDIENTS
Water (drinking water quality)
Calcium carbonate
Ethanol
Tannic acid
Isinglass
SECTION C : PROCESSING AIDS FOR THE PRODUCTION OF YEAST
Carbon dioxide
Citric acid
Lactic acid
Nitrogen
Oxygen
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
Regulation for processed products: application to the beer production
● Restriction of the use of food additives and processing aids
must be part of a restricted list (annex VIII of 889/2008) and respond to
specific conditions of use and are to be found in the nature:
▪ no exogen enzymes (brewing, beer stabilisation, …);
▪ no preservatives like sulfites, …;
▪ no chemical treatment for beer stabilisation (PVPP, …) or foam stability;
▪ Isinglass and tannic acid are authorized.
● Strict limitation of the use of chemically synthetised inputs
no synthetic preservatives, flavouring or colouring agents, …
● GMOs and products produced from or by GMOs are prohibited
raw materials selection, yeast, (enzymes), …
● Ionising radiation (treatment of organic food or raw materials) is prohibited.
raw materials, process, …
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
I.2.2. Control system
Member States must :
• set up a system of controls ;
• designate one or more competent authorities responsible for controls.
What is controlled ?
Farm inspection:
Control organism considers:
• each piece of land under cultivation,
• any fertilizers or other treatments used (such as pesticides or
herbicides),
• records,
• storage facilities,…
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
What is controlled ?
Processing plant inspection:
• installations (workshops, production lines and warehouses);
• manufacturing methods:
- recipes : ingredients, % organic, …,
- process,
- separation of organic and non organic during all the process,
permanent identification of the organic products,…
• book-keeping procedure recording nature, origin (certification) and quantities
of raw materials as well as quantities and destination of finished products.
Quantities of raw materials used are to be in accordance with quantities of
finished products delivered ;
• labeling (raw materials and products);
• invoices and output;
• Samples are taken away for analysis in independent, accredited laboratories:
- raw materials analysis,
- commercial finished products analysis (taken in commercial stores).
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
In practice, each producer will be controlled several times per year:
• by appointment for the yearly general control (book-keeping, installations,
recipes, invoicing, commercial supports, …);
• through spot checks (2 or 3 times per year) for raw materials analysis, beer
analysis,…;
• recipe for a new product, creation of a new label or new packaging always need
to be submitted for acceptance by the control organism.
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
In case of non conformity, the control organism has the sufficient authority to stop
the commercialisation of a product.
The sanction scale can be the following:
▪ simple remark (minor non-compliance);
▪ improvement action demand (and time for implementation);
▪ warning (improvement action demand that was not respected always gives place
to a warning);
▪ revocations and suspensions:
▪ revocation of lot (definitive revocation of a given part of the
production);
▪ suspension of product (prohibition to the operator of marketing the
concerned product with reference to the organic mode of production for
a given period of time);
▪ suspension of license (prohibition to the operator of marketing any
product with reference to the organic production mode for a given period
of time).
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
Fees are to be paid by the producer to the control organism and will vary
according to:
• turnover in organic production ;
• complexity of the control:
▪ mixed or 100 % organic activity,
▪ variety of raw materials,
▪ variety of finished products,
▪ importation of raw materials,
▪…
Fees can represent 0,25 to 0,50 % of the turnover for a moderate activity
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
I.2.3. Labelling
For products containing at least 95 % of organic ingredients (% of the weight of the
agricultural ingredients):
■ the list of the ingredients indicates which ingredients are of organic origin;
■ obligation of using the new european logo on the packaged products:
■ close to the logo, the producer has to mention the origin af the raw materials :
• « agriculture EC » : when raw materials are produced in the EC;
• « agriculture non EC » : when raw materials are produced outside EC;
■ obligation of referring to the operator’s control organism (code number of the
control organism: BE-BIO-999 or GB-ORG-999).
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
I.2.4. commercialisation
Each actor is controlled by the official control organism: from the farmer to the
producer, grossist, distributor, importer as well as the final point of sale.
Each entreprise receive a certificate on which are mentionned the organic
products that this actor is authorized to sell.
This certificate is valid during 1 year and has to be renewed thanks to the yearly
general inspection.
Any label modification, any promotional document or support must be approved
by the control organism.
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
I.3. ORGANIC LOGOS
Since 2009, the EC regulation doesn’t accept more strict
norms than the European ones but some countries still
work with their « old » national logos (authorized)
together with the new EC logo (obligatory).
Among these national logos, we can find:
• PRIVATE LABELS
Belgium
UK
• PUBLIC LABELS
France
J. De Clerck Chair, september 2012
Germany
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
I.4. NON EC REGULATIONS
Organic legislation may be different outside EC but EC certification becomes more and more
recognized.
Exporting EC certified organic products outside EC can lead to the following:
1. EC certification recognized and nothing additionnal needed (except labelling rules)
Canada
2. Equivalence of certification but lot certificate requested for each export (as well as
labelling rules)
2.1. Official equivalence
USA (since 01/06/2012)
2.2. No official equivalence
Russia, Turkey, Serbia, Chile, Australia, Korea
3. No equivalence (specific certification needed)
Japan (no legislation for organic beer), Brazil, China
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont
This logo certifies that EC regulations for
organic production have totally been respected
J. De Clerck Chair, september 2012
Organic belgian beers: legislation
Olivier Dedeycker, Brasserie Dupont