The
Organic Inputs Evaluation
project
www.fibl.org
>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
www.fibl.org
> 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
www.fibl.org
> Funding from:
Commission of the European Communities,
5th Framework Programme of RTD,
contract QLK5-CT-2002-02565
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: www.organicinputs.org
www.fibl.org
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.
www.fibl.org
> The evaluation process should be transparent and
involve stakeholders.
> International harmonization is desirable, especially
with the Codex Alimentarius guidelines.
Inputs: overlap
Support from Organic Inputs
Evaluation
with
other legislation
Plant protection
Dir. 91/414
Organic farming
www.fibl.org
Reg. 2092/91
What can be
used
4th stage
re-evaluation
New Regulation
New
Council
Regulation
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).
www.fibl.org
> If inclusion is possible, the process is very slow.
Download: www.organicinputs.org
The evaluation process
present
proposed
Request
Request
advice by
EU expert
panel
Review
Discussions
Evaluation
www.fibl.org
Final recommendation
Decision
Decision
Why review by an EU expert panel ?
> Homogeneity across requests
- order of presentation of facts
- degree of detail
- line of argumentation
> Completeness of facts
www.fibl.org
> 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.
www.fibl.org
> 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
www.fibl.org
> 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.
www.fibl.org
> 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»
How to define ?
Products of
high concern
> NO
www.fibl.org
Natural products
of low concern
> YES
Synthetic products
> NO
New «candidate»
substances ?
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 …).
www.fibl.org
> 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
www.fibl.org
> Environment
allowed
contact: not allowed
must be essential
no unacceptable effects
www.fibl.org
Criteria proposed by the project
Codex
Alimentarius
> Traditional use
(delete)
no
> Non-contact (pesticides only)
(delete)
no
> Necessity
existing
yes
> Environment
existing
yes
> Origin
new
yes
> Manufacture
new
yes
> Human health
new
yes
> Socio-economic impact
new
partly
> Organic farming principles
new
yes
Implementation
After the end of the Organic Inputs Evaluation
project, a New Organic Council Regulation
was proposed.
> Article 11 (current numbering) contains
evaluation criteria.
www.fibl.org
> 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.
www.fibl.org
Criteria in the
new Organic Regulation (Article 11)
> Organic farming principles
new
> Environment
(part of objectives)
> Human health
(part of objectives)
> Necessity
existing
> Origin (rule & 2 exceptions)
new
> Traditional use
existing
> Manufacture
not included
> Socio-economic impact
not included
Origin, the rule
Art. 11, 2. (b)
«all products shall be of plant, animal, microbial or
mineral origin …»
Examples
www.fibl.org
> Plant: compost, pyrethrine
> Animal: farmyard manure
> Microbial: Bacillus thuringiensis
> Mineral: clay
Origin, the exceptions
www.fibl.org
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»
and, for plant protection products:
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»
Case study 1
Farmyard
manure
2. The authorization […] is subject to the
objectives and principles laid down in Title II …
fertilizers
www.fibl.org
Plant protection products
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…
allowed
Case study 2
Chilean
nitrate
Art. 4. (b) (iii) low solubility
mineral fertilizers
fertilizers
www.fibl.org
Plant protection products
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…
not allowed
Case study 3
Pheromones
for mating
disruption
fertilizers
www.fibl.org
Plant protection products
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…
allowed
Case study 4
Spinosin
Art. 4. (c) (iii) … unacceptable
environmental impacts ?
2. The authorization […] is subject to the
objectives and principles laid down in Title II …
fertilizers
www.fibl.org
Plant protection products
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…
allowed (?)
Case study 5
Art. 4. (c) (iii) … unacceptable
environmental impacts ?
Glyphosate
herbicide
fertilizers
www.fibl.org
Plant protection products
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…
allowed !
Proposed amendments …
Plant protection products
www.fibl.org
general
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 ifif products
products or
or substances
substances from
from such
such sources
sources are
are not
not
except
available in
in sufficient
sufficient quantities
quantities or
or qualities
qualities
available
or ifif alternatives
alternatives are
are not
not available;
available;
or
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. (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
Art. 4. (c) (iii) … unacceptable
environmental impacts ?
Case study 5 repeated
Glyphosate
herbicide
fertilizers
www.fibl.org
Plant protection products
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…
not allowed
Conclusions
A lot has been achieved in the New Organic Regulation!
Evaluation now based on
scientific evidence and on
principles of organic farming
More
progress is
now possible
International
harmonization
What remains to be done:
> Expert panel: should be installed.
www.fibl.org
> Criteria: some amendments are needed.
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!
For cleaning and disinfection agents, the same exceptions as those
proposed for plant protection products should be allowed.
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
www.fibl.org
Topic no 2: new technologies
> Compliance of upcoming new technologies such as
nanotechnology with organic farming principles
Thank you for your attention !