Position Paper on Organic Greenhouse production
Updated Position - February 2013
Introduction
Growing in greenhouses is a longstanding horticultural practice. Greenhouses are used to lengthen the growing season and to protect vulnerable crops.
Organic greenhouses exist in many Member states. Organic greenhouse production falls within the scope of Regulation EC 834/2007. The general rules for
plant production apply.
This means in particular that also for organic greenhouses the basis is that: soil fertility is based on the use of crop rotations which include legumes and
other green manures and the application of organic manures. If these methods are insufficient, products listed in annex 1 of Regulation EC 889/2008 may be
used in addition. Rapidly soluble fertility amendments should be allowed only as a last resort when other fertilization techniques have proved insufficient.
But in greenhouse production, due to its character, growing measures are applied that are not possible in arable farming or non covered cropping such as
heating, lighting or cooling. Furthermore other growing measures that are common practice in arable farming are more difficult in greenhouse production,
such as a wide crop rotation.
Due to harmonization of organic rules and increase in demand for organic products, trade between Member states has increased. The producers that are
confronted with different practices and interpretations in the Member states demand a level playing field. At the same time differences in climatic
conditions and the demand for local produce should be respected. Finally, the energy input in greenhouses can be such a considerable part of that specific
plant production system that it needs to be addressed in an organic regulation.
Regulating organic production in greenhouses touches upon many issues. It should be noted that some of the issues addressed are relevant for more types
of production than only for greenhouses but we are proposing the measures only for greenhouses. Next to production of food crops this does include
seedling production and production of ornamentals.
In this paper we have taken a position on conversion, soil, fertility, use of peat, CO2 use, water use, steam sterilization, energy use and urban farming.
IFOAM EU Group
Position Paper on Organic Greenhouse production - Feb.2013
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1
Subject
Position
Rationale
Definition of greenhouse
A greenhouse is a structure in which plants
are grown. For the purpose of this
regulation, a greenhouse is a covered
structure which stays for several years at
the same place.
Specific provisions are required for protected cropping
under permanent structures as this is considered as a
system rather different from arable farming.
As a consequence of this definition the proposed provisions
do not apply to moveable structures like fleece covering,
part season tunnel or netting.
2
Definition of waste heat
Waste heat is heat generated in a process,
e.g. an industry, that can be utilised as a
resource.
This is relevant for the position on the use of renewable
energy
3
Definition of renewable energy
Renewable energy means renewable nonfossil energy sources: wind, solar,
geothermal, wave, tidal, hydropower,
landfill gas, sewage treatment plant gas,
biogases and wood products.
This is almost similar to the existing definition in reg.
889/2008, art. 2.K, with one addition, namely wood
products. Biofuels are not included in the definition for the
moment.
4
Definition of natural substrate
A mixture of soil and/or soil improvers that
are mentioned in Annex I.
If we accept that we can use pots for seedlings, herbs and
ornamentals we need to have a description of what can go
in the pots. Soil is not included in Annex I but is in practice
used for some of the mixtures that go in the pots. This
definition does justice to practice. We do not need to adapt
Annex I.
The article should be read as: “soil and/or [soil improvers
that are mentioned in Annex I].
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5
Conversion of production in natural
substrates
Substrates used in a conventional system
cannot be converted to organic.
6
Production in soil
The main principle of organic greenhouse
production: greenhouse production must
be in living soil (mineral soil mixed and/or
fertilised with materials and products
included in Annex I of Regulation (EC) No
889/2008) in connection with the sub-soil
and bedrock.
7
Production in pots
Only seedlings, ornamental plants and
herbs can be produced in substrates
authorised by the organic regulation and
sold in pots.
8
Systems that were allowed before the
EU regulation came into force
In some Northern countries , growing in
demarcated beds is an accepted organic
practice, due to local, climatic, traditional
and environmental specificity and
historical* development and approaches.
Only existing organic greenhouses certified
until 31st December 2012 in these
countries using demarcated beds can
continue the existing practise. No extension
of the practice to other member states or
countries would be acceptable.
IFOAM EU Group
This line is to clarify that in accepted practices where you
grow plants in pots (seedlings, herbs and ornamentals), you
can only convert between batches. You cannot convert the
plant in the pot to organic.
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* historical means that this practise was
accepted before the very first EU organic
regulation came into force in that country.
9
Plan on soil fertility
Operators need to prepare a plan to
develop soil fertility in the greenhouse,
which should be updated regularly. This
plan should demonstrate that the
greenhouse production system:
- enhances the efficiency of nutrient use
- builds soil health and fertility
- optimises sustainability of fertility inputs.
10
Fertilization
The main principle of fertilisation in organic
greenhouse production for all systems,
excluding production in pots is that
nourishing of plants works primarily
through the soil ecosystem
In practice this means that in greenhouse
production:
* A maximum of 50% of nutrients are
provided after planting.
* A maximum of 25 % of fertilisation is
allowed in liquid form.
This is already a basic principle for agriculture in Article 5a of
EU Regulation (EC) No 834/2007. It is elaborated now for
greenhouse production.
11
Use of peat
Use of other material is preferred to peat.
Although we ackowledge that there is a diversity of systems
all over Europe we think that for those MS where peat is
scarce other materials should be used first.
12
Re-examination of use of peat
The use of peat should be re-examined at
the latest 4 years after this regulation
comes into force.
IFOAM EU Group
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13
Steam sterilization of the soil
Steam sterilization of soil, of natural
substrates and of compost made on the
farm is only allowed in exceptional
circumstances and only to combat or
regulate soil borne diseases.
Steam sterilization should be considered an exceptional
instrument.
No routine or systematic use is accepted
and the need should be documented.
14
Use of CO2
Carbon dioxide is accepted in protected
cropping only if it has been produced as a
by-product of another process. Fuel must
not be burned solely to produce carbon
dioxide.
As there seemed to be different understandings on the use
of CO2 as a growth stimulator IFOAM EU feels it necessary to
make a clear position on this.
15
Water collection
If climatic conditions allow it, rainwater
must be collected from greenhouses if the
total size of structures on one operation
site is 5000 m2 or more. New structures
must be build so that rainwater is collected.
As water is a scarce resource it needs to be addressed.
16
Annual energy analysis
Holdings using non renewable energy/
fossil fuels above 130 kWh/m2 per year for
heating must make an annual energy
analysis.
In the future this topic should be further developed to
become more complete and it should cover the whole farm.
But as it is the first time energy is regulated in the EU organic
regulation, we take a careful approach.
The annual energy analysis must record the
energy use for lighting and climate control
(climate control includes heating,
We only want to target the heavy users and not create extra
bureaucracy, so only the holdings that exceed the use limit
of 130 kWh/m2/year will need to make an analysis.
IFOAM EU Group
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dehumidification and ventilation).
The energy analysis must be calculated on
quantity harvested crop and per cropping
area in m2. For potted plants, it is sufficient
to calculate energy consumption per
cropping area in m2.
The number of 130 kWh/m2/year was chosen after
exchange of information among experts that were consulted
by the IFOAM EU.
The energy analysis must record the source
of energy.
17
Plan to increase energy use efficiency
Based on the energy analysis an energy use
efficiency plan must be elaborated. The
plan must describe how:
(1) to reduce total amount of energy;
(2) to improve energy efficiency;
(3) to reach a limit of either a maximum in
fossil fuel use or a minimum requirement
on the use of renewable energy sources.
The plan in itself will raise awareness among the farmers.
We need to collect experiences and learn from experience
before eventually introducing a more specific common
regulation.
In Sweden this system is in place on a voluntary basis since
early 2010 and also inspected. The energy efficiency plan is
part of the inspection and growers have to show what they
have improved since the last control.
4 years after the regulation enter into force
the Commission must present an
evaluation on the functioning of this
paragraph and if needed formulate
additonal rules.
18
Urban farming
IFOAM EU Group
Many currently operating urban farming
initiatives claim to follow organic
production principles. Some of them
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produce only for own use thus no
certification is needed. Those which
produce for sale but do not follow the
principle of production “in soil with
connection with sub-soil/on bedrocks”
cannot be certified as organic. However
urban farming is a valuable way of
delivering fresh food to cities. The organic
sector and the urban gardening sector
should work together and support each
other in their development .
IFOAM EU Group
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