Organic and
Biodynamic
Produce
Comparing Australian and
Overseas Standards
- Discussion Paper
A report for the Rural Industries Research
and Development Corporation
by Mr Rod May and Dr Andrew Monk
March 2001
RIRDC Publication No 01/05
RIRDC Project No RAM-1A
© 2001 Rural Industries Research and Development Corporation.
All rights reserved.
ISBN 0 642 58228 9
ISSN 1440-6845
Organic and Biodynamic Produce – Comparing Australian and Overseas Standards
Publication No. 01/05
Project No. RAM-1A
The views expressed and the conclusions reached in this publication are those of the author and not
necessarily those of persons consulted. RIRDC shall not be responsible in any way whatsoever to any
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Mr Rod May
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Dr Andrew Monk
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- ii -
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Foreword
This report has been compiled for the purposes of outlining aspects of Organic Standards
comparisons inter and intra nationally. The key aim is to highlight elements of similarity as well
as divergence both in content, in detail and in formation process between international
governmental, intergovernmental, non-government organizational and inter-certifier
arrangements.
The report is timely and relevant for the purpose of reflecting on Australia’s current position
and relative stance in relation to content and detail and Organic Standard formation and
maintenance processes. It outlines areas of concern or interest and recommends 16 changes to
the Australian organic industry standard and the standard setting process.
This project was funded from RIRDC Core Funds which are provided by the Federal
Government.
This report, a new addition to RIRDC’s diverse range of over 600 research publications, forms
part of our Organic Produce R&D program, which aims to optimise the profitability of
Australian organic production in domestic and overseas markets and to promote the utilisation
of organic farming systems as a means of enhancing the sustainability of Australian
agricultural systems.
Most of our publications are available for viewing, downloading or purchasing online through
our website:
• downloads at www.rirdc.gov.au/reports/Index.htm
• purchases at www.rirdc.gov.au/eshop
Peter Core
Managing Director
Rural Industries Research and Development Corporation
- iii -
- iv -
Contents
Foreword
Executive Summary
iii
vi
1.
Introduction
1
2.
Australian Organic Standard
2
2.1
2.2
2
4
3.
Comparison – Australian Standards v’s Overseas Standards
3.1
3.2
3.3
3.4
3.5
3.6
3.7
3.8
3.9
3.10
3.11
3.12
3.13
3.14
3.15
3.16
4.
6.
Terms Regulated
Accreditation Criteria
Conversion Requirements
Parallel Production
Buffer Zones
Organic Plan Requirements
Input Materials Criteria
Livestock Feed
Manures
Record Keeping (estimates)
Labelling / Mixing Conversion
Residues
Inputs including Inert Ingredients or Synergists
Land and Water
Comparison of Sundry Items
Comparison Summary
6
6
8
10
12
13
14
15
17
19
20
21
23
24
24
25
25
Processes for Setting Standards
26
4.1
4.2
26
29
29
29
30
30
30
31
4.3
5.
Origin and Structure
Evolution of the standard
Australian – Evolution and Challenges
International Standards and Regulatory Processes
4.2.1 United Kingdom
4.2.2 United States
4.2.3 Japan
4.2.4 IFOAM
4.2.5 Codex
Australian – Proposed Approach
Implications for Australia
32
5.1
5.2
5.3
32
33
34
Australian and Issues of Equivalence and Harmonisation
Getting the Australian Message and Perspective Across
Summary
35
Recommendations
Annex
Abbreviations
References
37
39
40
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Executive Summary
Over the last five years consumers have driven the rapid emergence of the global “certified
organic” industry. Consumers demand confidence in their food, with regard to both its
physical attributes and to the sustainability of production and farming systems.
In a domestic Australian sense this is a relatively straightforward concept, if challenging.
However, in a world trade context of cross cultural tastes and preferences, product credence
becomes a far more complex and risky dimension for consumers. And the issue of what is an
acceptable sustainable farming system across five continents further compounds the risks for
consumers.
But this issue is very important for Australia. As an export intensive economy we must
understand global consumer trends and the opportunities and threats arising in certified organic
markets we service.
This study compares and contrast the current and emerging organic standards for each of the
EU, USA, IFOAM (International Federation of Organic Agricultural Movements) and Japan
with the Australian Standard, and any relevant matters considered by the international food
coordinating body, CODEX.
It sets out in detail the regulatory status for each of the 13 key regulatory dimensions in each
market or agency. Terminology and sundry categories are also compared. The study finds that
Australia compares favourably against our key partners and international regulatory standards.
In some aspects Australia has been and remains a world leader in organic regulation. The
relatively strong degree of cohesion among Australian certification agencies has contributed to
our current good standing.
The study discusses the key implications for Australian organic industry as it seeks to enhance
its position in these three world markets. The study also recommends 16 changes to the
Australian organic industry standard and the standard setting process.
The role of standard setting is considered central to the ongoing development of standards and
to the strong linkage and equivalence of Australian industry to trading partners. It is
recommended that the process be actively managed by industry through its new peak body, the
Organic Federation of Australia, with support and input from Government and consumers.
However, the lack of a clear domestic organic standard is seen as a significant shortcoming to
be overcome for industry to meet consumer expectations. Such a standard must be congruent
with the current National Standard (used as the basis for exports), thereby immediately gaining
legitimacy for domestic producers in international eyes.
All actions taken by an increasingly united industry must lead to enhanced access to all
markets for Australian organic producers.
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1. Introduction
This report has been compiled for the purposes of outlining aspects of Organic Standards comparisons
inter and intra nationally. The key aim is to highlight elements of similarity as well as divergence both
in content, in detail and in formation process between international governmental, intergovernmental,
non-government organizational and inter-certifier arrangements.
The main texts taken for comparison are: the Australian National Standard for Organic and
BioDynamic Produce (1998); IFOAM – International Federation of Organic Agricultural Movements
(1998); Codex 1; EEC 2092/91 and amendments and brief sketches of the drafts or working documents
for the US and Japan.
This report is timely and relevant for the purpose of reflecting on Australia’s current position and
relative stance in relation to content and detail and Organic Standard formation and maintenance
processes.
This report outlines areas of concern or interest combined with recommendations on how these issues
may ideally be dealt with in the coming 1-5 years.
1
The Codex Alimentarius Commission is a world body established by Food and Agricultural Organisation
(FAO) and the World Health Organisation of the United Nations. Its role is to establish minimum standards and
guidelines in food related issues and in so doing facilitate international trade.
-1-
2. Australian Organic Standard
2.1
Origin and Structure
The National Standard for Organic and Biodynamic Produce is a regulatory instrument of the
responsible authority, the Australian Quarantine and Inspection Service (AQIS).
The Standard permits control of organic agricultural practices within Australia both exports and
imports, and domestic production. Through accredited agents, (referred to as the certifying bodies),
AQIS may ensure that claims relating to organic production in Australia are in conformance with the
National Standard. Figure 1 illustrates this relationship, including the certified inspectors who are the
infield agents of the certifying bodies.
Figure 1.
Certification Framework of the Australian Organic Industry
CODEX
AQIS
NATIONAL
ORGANIC
STANDARD
ORGANIC
CERTIFIERS
ORGANIC INSPECTORS
Domestic
Consumers
Distributors and
Exporters
Processors and
Manufacturers
Farmer
Producers
Export
Consumers
ORGANIC SUPPLY CHAIN
In Australia, there are currently seven accredited certifiers, regulated under this AQIS National
Standard system. These certifiers pursue varying production sectors, sometimes focusing on specific
commodities or regions. All however are commonly bound by this National Standard/guideline.
These certifiers are Biodynamic Research Institute (BDRI), Biological Farmers of Australia (BFA),
Organic Vignerons Association of Australia Inc (OVAA), Organic Food Chain of Australia (OFC),
Organic Herb Growers of Australia Inc. (OHGA), Tasmanian Organic Producers (TOP), and
National Association of Sustainable Agriculture, Australia (NASAA).
-2-
AQIS has legal jurisdiction in relation to imported foods under the Imported Foods Control Act.
There is no specific domestic certification framework 2, nor a relevant authority. Industry currently
uses the AQIS export certification imprimatur to maintain domestic accreditation, by default, in the
domestic market.
The National Standard contains both the guidelines for operating a certification system, and
minimum requirements which must be observed by the licensees of their respective
certification agent/s. AQIS’ internal operational guidelines are satisfied by the
Administrative Arrangements.
There is ongoing debate as to the status of the National Standard – whether it indeed is a National
Standard, or merely a guideline document for certification agencies to implement their own Standard
– with the National Standard being a lowest common denominator to which clients must conform.
Some suggest that the National Standard cannot be deemed to be a production standard in its own
right, for the reason that in section 4.2 (a) “that the (certifying) organisation will provide a
certification program to documented standards which must meet the requirements of this Standard”
However some certifiers within Australia currently utilise the National Standard as their own, with
their own additional “Codes of Practice” or other additional guidelines as amendments to these
requirements.
The National Standard has placed Australia in good stead in terms of both a unifying force for the
service of certification, as well as being cause for significant international recognition and reputation
in terms of comparative organic regulatory frameworks. In as much as the National Standard is seen
by some as a stand alone document, it will be important for it to be serviced in detail and with
regularity.
It is important to note the chronology of Australian regulation, and how this has evolved sometimes
behind, and sometimes ahead of, international developments. The National Standard has sometimes
evolved concurrently, if not ahead of, similar organic regulations of other government and nongovernment systems.
The National Standard is similar to the Codex guidelines for organic production, certification and
labelling, but addresses a level of detail that goes beyond Codex. Further, there are significant
“tightenings” in some areas, giving the Australian National Standard prestige and world leading
status in terms of the degree and nature of organic regulation.
The AQIS quality management system (organic) is deemed to be compliant with EN45011 – the
European governmental regulatory version of ISO 65. Certifying organisations by extrapolation,
must also be deemed equivalent to this standard for operating certification systems.
Approved certifying organisations are fortunate that Australia is recognised through international
Government to Government arrangements which include listing them as inspection bodies under EEC
directive 2092/91. The AQIS accreditation scheme permits relative ease of entry to foreign ports.
Many certifying organisations from non-listed countries have been subjected to a demanding range of
barriers which has impacted negatively on their trade in organic produce.
2
The Organic Retailers and Growers Association of Australia (ORGAA) supports retailers and distributors but
is not an AQIS certified body.
-3-
The importance for the organic certification sector regarding this EU status cannot be underestimated.
The Organic Produce Export Committee (OPEC) and the Australian organic industry need to ensure
the National Standard is maintained so that it reflects current global trends in organic production.
Recommended aspects of this diligence are contained within this report.
It is vital that certifying organisations both collectively and individually continue to take
responsibility for their quality systems, diligence and adherence to good corporate governance. For
while they all share the umbrella of AQIS accreditation, and despite the fact that they now enjoy
individual listing in terms of the European Union Commission, they will also risk share any negative
impact that may arise from individual transgression or oversight. Such a scenario would possibly see
a degeneration of the otherwise inherently resilient and much supported approach of industry self
regulation and voluntary “community promulgated and supported” regulations.
This report is therefore based, in part, upon these issues and perspectives. These particularly unique
aspects need to be taken into account in dealing with the organic industry within Australia and in
relation to its ties with international regulation and arenas of Standards setting.
2.2
Evolution of the Standard
It is valuable to consider the history of the organic standards, certifiers and regulation as it has been
the organisations themselves, and the relationships and political linkages between them, that have
defined much of the nature of the National Standard and its respective applications.
The performance of the private certifiers and the regulatory overseer/s is integral to a meaningful
application of the organic standards, and to this end cannot be separated from issues of standards and
standards setting generally. The1980s saw the arrival of certifying bodies which today carry the bulk
of numbers and volume of trade in the organic industry. This period was a defining period in the
organic industry’s history within Australia – following on from trends on other areas of the industrial
world.
A basic chronology looks something like the following:
1960s
Registration of Demeter label in Australia
1985
ORGAV / ORGAA founded as a an industry body
1986
NASAA established as a certifier
1987
BFA established as a certifier
1992
AQIS – OPAC – National Standard and Regulatory System
1994 OHGA established as a certifier
1995 NASAA accredited by IFOAM
1996
Eco-Organics established as a certifier
1996
OVAA established as a certifier
1998
OFC established as a certifier
1998
Organic Federation of Australia (OFA) established as peak body.
1998
AQIS moves accreditation system into Operations (from Policy)
1999
OCA – Certifier peak grouping formalised.
1999
TOP accredited with AQIS
1999
Withdrawal of Eco Organics as a certifier
2000
OPEC – Modification to former OPAC.
The emergence of a formalised Australian certification system mostly occurred in the 1980s, with
roots of some of these organisations emerging informally in the decades before. It would be safe to
suggest that Australia in terms of Certifier and regulatory history is some 10 years behind in some
key areas. At the same time, the emergence of a nationally agreed upon standard, in existence now
for almost one decade, has placed Australia in a key internationally recognised position and lent
crucial weight to enabling currently uniformly administered arrangements in terms of certification
services.
-4-
The servicing of certification is nonetheless contested in terms of competition. Whilst delivering at
one level a healthy degree of competition between certification agencies, enabling a true service
provision sector to flourish, at another level the regulatory climate has in the past been cause for
concern from some sectors of the industry in terms of the administration and regulation of certifiers
themselves.
A key event to note is the arrival of OPAC – in 1992 – a broad grouping of organic industry and
government representatives, formally united for the purposes of administering the National Standard
– a guideline document for the purposes of guiding regulation for organic production.
Standards setting is now more complex as a greater number of importing countries develop their own
requirements, and the crucial necessity to display operational competence and homogeneity grows
greater.
Whilst Government to Government arrangements and the legal frameworks of world trade and issues
of equivalence and regulatory parity are growing more important, it will be necessary for OPEC to be
fully cognisant of these issues and be capable of seeing that their conduct of regulatory requirements
through the certifiers competent and transparent conduct of certification is faultless.
With AQIS having shifted their regulatory activity from Food Policy into Animal and Plant Programs
Branch, follow-up and rigour in terms of auditing and regulation has now significantly changed.
Given the international nature of organic programs – irrespective of their ultimate provision and
support for localised communities and food production systems – continuance of this increased rigour
and assurance of parity with international requirements is crucial.
The 1999 EU audit on the Australian organic program highlighted a less than uniformly administered
and actively regulated organic program. Also highlighted at the time of the EU audit was the effect
that one non conforming group alone could have on the overall export program. With this now
changing, there is a revitalised confidence in more uniformly administered auditing and regulation of
the certifiers themselves.
Given that Australia remains well in advance of many nations in terms of a uniformly administered
and legislated National Standard, this ongoing performance of AQIS in regard to industry
conformance to the Standard offers Australia the opportunity to remain competitively ahead in the
arena of internationally accepted and credible organic certified goods.
The contents of the National Standard are discussed in detail in Chapter 3.
-5-
3. Comparison – Australian Standards v’s
Overseas Standards
This chapter compares and contrasts the current and emerging organic standards for each of the EU,
USA, IFOAM and Japan with the Australian Standard. Additional comment is also made where
relevant matters are considered by CODEX.
The respective international Standards have been compared and contrasted across the following
fourteen criteria:
1. terms regulated
2. accreditation criteria
3. conversion requirements
4. parallel production
5. buffer zones
6. organic plan requirements
7. input materials criteria
8. livestock feed
9. manures
10. record keeping (estimates)
11. labelling / mixing conversion
12. residues
13. inputs including inert ingredients or synergists, and
14. land and water
The initial set of tables sets out the detailed comparison of terms for each of the six Country / Agency
Standards. This is followed by a summary discussion of each criteria.
3.1
Terms Regulated
Table 1.
Equivalence Assessment – Australia; EU; USA; Japan; Codex; IFOAM
COUNTRY/
AGENCY
1. TERMS REGULATED
Australia
1. Organic, bio-dynamic, biological or words of similar intent.
EU
In English: Organic,
Also Biologique, Ecologique, etc.
Organic
(1) yuuki nousanbutsu (organic agricultural product)
(2) yuuki saibai nousanbutsu (organically grown agricultural product)
USA
JAPAN
CODEX
IFOAM
In English Organic
In English Organic.
Note: The term equivalence refers to mutual formal recognition of a standard enabling reciprocity for
trade purposes.
-6-
Australia is broadly in line with comparisons. The breadth of intent is wider than many, with the
unique inclusion of Biodynamic as an overarching description of the Standard. It could be interpreted
that by definition, organic is biodynamic to uninitiated observer. There is no reason why this should
not remain but it would be clearer if those additional practices which constituted BD were separately
identified.
A Standard or Guideline?
There is no reason why the National Standard should not be unique including its blending of
guidelines and standards. Indeed, the nature of the National Standard is arguably a compilation of
what IFOAM may call “General Principles, Recommendations and Standards”. It is important to
identify the difference between these. An example may be best used:
General Principle:
3.2
The aims outlined above are achieved through management practices that create soils of
enhanced biological activity, as determined by the humus level, crumb structure and feeder root
development, such that plants are fed through the soil ecosystem and not primarily through soluble
fertilizers added to the soil.
Recommendation:
3.8
Sufficient organic material should be returned to the soil to increase, or at least maintain,
humus content.
Standard
3.9
Sheet composting using animal manures must go through two green manure crops
before the area is used for small crops;
(Whilst itself an arbitrary system of standards layout, the IFOAM document does more succinctly
separate the various categories above). The fine details regarding the application of standards are
not always addressed in the National Standard. The use of the word appropriate is made with
reference to a rotational program for example and to stocking densities.
There are further areas where the National Standard is subject to interpretation. These include living
conditions for semi intensive livestock, requirement to maintain livestock per se, definition of
drought or natural disaster, pollution avoidance including GMOs and any requirements for landscape
management, water use and management and biodiversity management. In the area of processing and
handling, there is also a lack of specificity. Additionally, no where in the National Standard is an
appropriate rotation described, nor could it be, without reference to a wide range of systems.
The point which should be drawn form this is that it is not always possible for a standard which
relates to so many production systems to adequately describe what exactly constitutes an acceptable
vegetation management regime for example, or a definition of drought. However, it is arguably an
improvement to the capacity of the National Standard to include the requirement that the certification
body indeed have a policy on those matters.
A further dimension of the above and a notable divergence within the National Standard is the
absence of an area of meaningful restriction of input products. Whilst the general caveats in 3.11 and
3.14 are noted, there is no requirement for the certification body to note any detailed requirements on
the limits, possible uses and volumes of any of those annexed materials.
-7-
3.2
Accreditation Criteria
Table 2.
ACCREDITATION CRITERIA
Australia
For an organisation to become an approved certifying organisation, at least the
following will be taken into account by AQIS:
a. that the organisation is an incorporated body, which operates preferably on a
national basis, and will provide a certification program to documented
standards which must meet all the requirements of this Standard;
b. the quality management system which describes the operation of the
organisation including;
• a regular internal audit and management review program; and
• the maintenance of appeal and complaints procedure; and
• the inspection procedures to be used, including a detailed description of
the inspection measures and precautions which the organisation
undertakes to impose on operators subject to its inspection;
c. the penalties which the organisation intends to apply where irregularities are
found;
d. the availability of appropriate resources in the form of qualified staff,
administrative and technical facilities, inspection competence and reliability;
and
e. the objectivity, impartiality and transparency of the organisation with respect to
the operators subject to its inspection.
Before and after an organisation has become an approved certifying organisation,
AQIS will:
a. ensure that the inspections carried out by the organisation are objective; and
b. ascertain the objectivity of separation of decision making procedures; and
c. take cognisance of any infringements found and penalties applied.
EU
For the approval of a private inspection body, the following shall be taken into
account:
a. the standard inspection procedure to be followed, containing a detailed
description of the inspection measures and precautions which the body
undertakes to impose on operators subject to its inspection;
b. the penalties which the body intends to apply where irregularities are found;
c. the availability of appropriate resources in the form of qualified staff,
administrative and technical facilities, inspection experience and reliability;
d. the objectivity of the inspection body vis-à-vis the operators subject to its
inspection.
USA
Based upon ISO 65 with adaptations for organic regulation. Certification body
shall be assessed for compliance with all requirements of the organic standards.
JAPAN
Currently pending. Assessment by MAFF (Ministry of Agriculture, Forestry and
Fisheries) – Agriculture Authority. ISO 65 guidelines for certifiers forms basis of
requirements – particularly technical competence, commercial independence, etc.
Note that accredited certifiers shall require office and personnel based within Japan.
-8-
CODEX
In order to attain approval as an officially recognized certification body or
authority, the competent authority, or its designate, when making its assessment
should take into account the following:
a. the standard inspection/certification procedures to be followed, including
detailed description of the inspection measures and precautions which the body
undertakes to impose on operators subject to inspection;
b. the penalties which the body intends to apply where irregularities and/or
infringements are found;
c. the availability of appropriate resources in the form of qualified staff,
administrative and technical facilities, inspection experience and reliability;
d. the objectivity of the body vis-à-vis the operators subject to inspection.
IFOAM
Must be in compliance with IFOAM Basic Standards and accredited by the IOAS
(International Organic Accreditation Service) in accordance with accreditation
criteria. The program must demonstrate competence, independence, accountability,
responsibility, objectivity, confidentiality, etc. Standards shall be published for all
production systems or product categories certified by the program.
The National Standard contains general criteria for accreditation and leaves the detail to the
administrative arrangements and the Export Control (Organic Produce Certification) Orders 1995.
This contrasts with the US where much more detail is included and to Japan where there is none. It is
likely that the status quo will remain serviceable, but the principles of SECTION 4 should be retained
within the Standard, with administrative arrangements per se based on principles of transparency,
consultation and audited by any competent body recognised by the competent authority (AQIS).
In line with all other Standards the provision for the accreditation of individual operators should be
removed.
-9-
3.3
Conversion Requirements
Table 3.
IN-CONVERSION REQUIREMENTS
Australia
The principles outlined in this section must have been applied on the land for
at least three years before the harvesting of products covered under Section 1
can be labelled as organic. Whatever the length of the conversion period the
product may only be labelled in conversion to organic once a production unit
has been under an inspection system as required by Section 4 for 12 months.
EU
The principles set out in this Annex must normally have been applied on the
parcels during a conversion period of at least two years before sowing or, in
the case of perennial crops other than grassland, at least three years before the
first harvest of products as referred to in Article 1(1)(a). The inspection body
may, with the approval of the competent authority, decide, in certain cases, to
extend or reduce that period, having regard to previous parcel use.
USA
Have had no prohibited substances, as listed in § 205.600, applied to it for a
period of 3 years immediately preceding harvest of the crop.
JAPAN
Production fields shall be those in which agricultural production has been
performed in accordance with the Standards listed as follows:
for growth management in production fields etc., on seeds and seedlings sown
or planted in the fields and for harmful animal and plant control, for more
than three years precedent to the first harvest in the cases of production of
perennial crops other than grasslands, or more than two years precedent to
sowing or planting in the case of production of other crops (more than one
year precedent to sowing and planting in the case of production fields newly
developed or prohibited use materials not used for over two years).
CODEX
The competent authority, or where delegated, the official or officially
recognized certification body or authority may decide in certain cases (such as
idle use for two years or more) to extend or reduce that period in the light of
previous parcel use but the period must equal or exceed 12 months. Whatever
the length of the conversion period it may only begin once a production unit
has been placed under an inspection system
IFOAM
Plant products from annual production can be certified organic when the
Standards requirements have been met for a minimum of twelve months
before the start of the production cycle. Perennial plants (excluding pastures
and meadows) can be certified organic at the first harvest after at least
eighteen months of management according to the Standards requirements.
Pastures, meadows and their products can be certified after 12 months of
organic management. The conversion period can be extended by the
certification program depending on e.g. past use of the land and
environmental conditions.
The National Standard has yet to finalize conversion requirements, in the light of what appears to
have been a less than clear interpretation of the 1998 version than in the past. The National Standard
- 10 -
should be cognizant of both the general principles of 3 years of organic management which is in
place in US, and for parity purposes the language which relates to harvest vs. sowing is important and
therefore some two year requirements are actually more like three.
However, the mechanisms by which past compliance is judged is another question, as indeed the
question of the use of a conversion label. It is possible that limited retrospectivity can be applied by
the certifier and this would satisfy most parity requirements, but the period under which the operation
is subject to scrutiny is a factor which needs to be taken into account.
These is no clearer articulation of prescribed conversion periods than within the National Standard
although by definition the non use of a conversion label such as the US and other certifiers and
traders has similar implications. Unless there is a change in US rules (which must be expected), there
is a period which requires that no conversion label may be used. The use of a conversion label is the
key to permitting the new applicant /operators to enter the market before elapse of a 3 year period.
Whatever the length of the conversion period it may only begin once a production unit has “been
placed under an inspection system”, is one which the industry is currently dealing with. Perhaps as a
result of its greater maturity, the National Standard has been through some revisions of language in
this area to help to make more clear the concept of conversion. The past practices which have
included the possibility of overnight entry of operators into organic certification (as conversion or
fully organic) based on a self declaration are seen as less than diligent by many.
The National Standard should be based on 3 years as a benchmark for historic organic farming
practices preceding organic certification. The Standard should also be definite with regard to the
minimum period under which a certification scheme has been in place before the provision of a
labelling claim which should include the conversion label as an alternative to a more lengthy period
without label usage. This period should remain at least as a 12 month period prior to achieving a
minimum certification label to ensure uniformity, regulatory parity and industry regulatory diligence.
- 11 -
3.4
Parallel Production
Table 4.
PARALLEL PRODUCTION
Where the whole farm is not converted at the same time, certified crops or
Australia
livestock complying with this Standard must be visibly distinguishable from
product that does not comply with this Standard. In the case of perennial crops
the management system must demonstrate through management practices and
record keeping the separation of harvested material from the certified and noncertified enterprises.
EU
Where an operator runs several production units in the same area, units in the
area producing crop or crop products not covered by Article 1 must also be
subject to the inspection arrangements as outlined. Plants of the same variety
as those produced at the unit referred to in point 1 may not be produced at
these units.
NB For non-EU, European country certifier Bio Suisse, parallel production is
not allowed.
USA
Allowed with conditions: distinct and separate areas, managed to ensure no
commingling. Records kept to verify audit trail.
No GMO crops may be grown on other areas of non certified land.
Fields may not be switched back and forth from organic to conventional.
JAPAN
Specifications for segregation of certified products only.
Not otherwise defined
CODEX
Production should take place in a unit where the land parcels, production
areas and storage facilities are clearly separate from those of any other unit
which does not produce according to these guidelines; preparation and/or
packaging workshops may form part of the unit, where its activity is limited
to preparation and packaging of its own agricultural produce.
IFOAM
If the whole farm is not converted, the certification program shall ensure that
the organic and conventional parts of the farm are separate and inspectable.
No certification shall be offered where such products are indistinguishable
from one another.
Australia holds a relatively strong position with regard to parallel production. It is in parity with the
EU, but there is no similar requirement in the US or Japan. Codex supports the principle, and so does
IFOAM although neither forbid products of the same variety being produced on the same farm.
Some go further by saying that the conventional sector must be inspectable, and it is becoming the
case that GMO’s are prohibited in parallel production by Countries, certifiers and by IFOAM.
Australia should retain its strong position in the interests of consumer confidence and relative ease of
monitoring. The National Standard could consider language which makes the conventional sector
inspectable and prohibits GMO’s on parallel production cases.
- 12 -
3.5
Buffer Zones
Table 5.
BUFFER ZONES
Australia
Arrangements need to be provided to suit the potential risks and consequences
of spray drift or other sources of external contamination.
EU
Segregation and management to ensure non contamination applies.
USA
Practices to ensure no contamination shall be outlined in the Organic Farm
Plan. Buffer zones shall be under the management of the certified operator.
(Current draft) - a 25 foot buffer minimum shall be established based upon
consideration of other strategies employed.
JAPAN
Production fields must be clearly separated from the surrounding environment
and shall not be influenced by the drift of fertilizers, soil improving materials
and pesticides.
CODEX
Specified under measures taken to ensure contamination control only.
IFOAM
Specified under contamination control only.
The use of buffer zones is referred to in principle by the National Standard. There is little description
of such areas in other standards. It would be useful for the National Standard to expand on this area
or make it a provision that each certification agency has a detailed policy on buffer zones, their size,
location and the requirements for harvest, packaging and labelling of crops from those zones.
- 13 -
3.6
Organic Plan Requirements
Table 6.
ORGANIC PLAN REQUIREMENTS
An undertaking by the operator to carry out the operations in accordance with
Australia
the Standard. Where applicable, a summary of all the practical measures to
be taken to ensure compliance with the Standard.
When the inspection arrangements are first implemented, the producer and
EU
inspection body must draw up:
• a full description of the unit, showing the storage and production premises
and land parcels and, where applicable, premises where certain processing
and/or packaging operations take place,
• all the practical measures to be taken at the level of the unit to ensure
compliance with this Regulation.
• A description of practices and procedures to be performed and maintained,
USA
including the frequency with which they will be performed;
• A list of each substance to be used as a production or handling input,
indicating its composition, source, and location(s) where used;
• A description of the monitoring practices and procedures to be performed
and maintained, including the frequency with which they will be
performed, to verify that the plan is effectively implemented;
• A description of the record keeping system implemented to comply with
the requirements established in § 205.103;
• A description of practices and procedures to prevent commingling of
organic and non-organic products and to prevent contact of organic
production and handling operations and products with prohibited
substances; and
• Additional information deemed necessary by the certifying agent to
evaluate compliance with the regulations.
• Such requirements shall constitute part of the Organic Farm Plan.
Not at this point specified.
JAPAN
Codex requires operators and inspection/certification bodies to draw up a full
CODEX
description of the production unit and/or collection area which shows the
storage and production premises and land parcels and, where applicable, the
premises where certain processing and/or packaging operations take place
IFOAM
There should be a clear plan of how to proceed with the conversion. This plan
shall be updated if necessary. The standards requirements shall be met during
the conversion period. All the standards requirements shall be applied on the
relevant aspects from the beginning of the conversion period onward.
There is no specific mention in the National Standard for an organic plan whereas other Standards do
make such mention. The National Standard should contain language which defines the organic plan
and it should be included in section 4.
- 14 -
3.7
Input Materials Criteria
Table 7.
INPUT MATERIALS CRITERIA
Australia
•
Any additions or changes to the lists may be made only where it can
be demonstrated that they satisfy the requirements of this Standard.
•
•
EU
USA
JAPAN
CODEX
Presumption of a closed (farming) system to the maximum extent feasible.
Added where (such inputs) can be demonstrated to satisfy the
requirements of the Standard.
a) if they are used for the purpose of plant pest or disease control:
•
They are essential for the control of a harmful organism
or a particular disease for which other biological, cultural, physical or
plant breeding alternatives are not available, and
•
the conditions for their use preclude any direct contact
with the seed, the crop or crop products; however, in the case of
perennial crops, direct contact may take place, but only outside the
growing season of the edible parts (fruits) provided that such
application does not indirectly result in the presence of residues of the
product in the edible parts, and
•
their use does not result in, or contribute to, unacceptable
effects on, or contamination of, the environment;
(b) if they are used for fertilization or soil-conditioning purposes:
•
they are essential for specific nutrition requirements of
crops or specific soil-conditioning purposes which cannot be satisfied
by the practices mentioned in Annex I, and
•
their use does not result in unacceptable effects on the
environment or contribute to the contamination thereof.
Allows individuals to petition the NOSB (National Organic Standards Board)
to review materials to be either added or deleted from the National List. The
Secretary can delete substances from the National List as stipulated by OFPA.
Natural substances or those derived from natural substances (limited to those
manufactured through combusting, roasting, melting, carbonizing or
saponifying natural substances, or those manufactured from natural
substances through a method other than chemical one) without addition of
chemically synthesised substances, to be used in soil in order to change soil
characteristics to provide plants with nutrients or to contribute to plant
cultivation, and such substances (including living organisms) to be used on
plants to provide the plants with nutrients
Any new substances must meet the following general criteria:
•
they are consistent with principles of organic production
•
use of the substance is necessary/essential for its
intended use;
•
use of the substance does not result in, or contribute to,
•
harmful effects on the environment;
•
they have the lowest negative impact on human or
animal
•
health and quality of life; and
•
approved alternatives are not available in sufficient
•
quantity and/or quality.
- 15 -
IFOAM
The ingredients are of plant, animal, microbial or mineral origin which may
undergo the following processes:
•
physical (mechanical, thermal)
•
enzymatic
•
microbial (composting, digestion), and
•
their use does not result in, or contribute to, unacceptable
effects on, or contamination of, the environment, including soil
organisms, and their use has no unacceptable effect on the quality and
safety of the final product.
There is no input materials criteria at the time of writing this report. These should be developed in
line with Codex and IFOAM and be clearly linked to the existing lists which should remain positive
lists.
- 16 -
3.8
Livestock Feed
Table 8.
LIVESTOCK FEED
a. Animals to be fed on 100% certified organic origin feed, except for that
Australia
listed below.
b. Up to 5% of all feed may be brought in as feed supplements in the form
of any of the following:
Minerals;
•
•
Kelp;
•
Molasses;
•
Stone meal and charcoal;
•
Fish oils and other fish by-products;
•
Shells, cuttlefish bones;
•
Meat meal consisting of no more than 2% of total diet
for poultry, pigs and aquaculture.
With regard to minerals and trace elements used in animal nutrition,
EU
additional sources for these products may be included in Annex II
provided that they are of natural origin or failing that, synthetic in the
same form as natural products."
By derogation from paragraphs 2.2.1, 4.2 and 4.4 if there is simultaneous
conversion of the complete production unit, including livestock, pasturage
and/or any land used for animal feed, the total combined conversion period
for both livestock, pasturage and/or any land used for animal feed, shall be
reduced to 2 months subject to the following conditions:
• the derogation applies only to the existing animals and their offspring
and at the same time also to the land used for animal feed/pasturage
before starting the conversion;
• the animals are mainly fed with products from the production unit.
USA
JAPAN
CODEX
Up to 30 % of the feed formula of rations on average may comprise inconversion feeding stuffs. When the in-conversion feeding stuffs come
from a unit of the own holding, this percentage can be increased to 60 %.
For poultry, the feed formula used in the fattening stage must contain at
least 65 % cereals.
Feed materials from animal origin (whether conventional or organically
produced) can only be used if listed in Annex II, Part C, section 2, and
subject to the quantitative restrictions imposed in this Annex (Only
includes milk and milk products and fish products)
The producer of an organic operation must not feed mammalian or poultry
slaughter by-products to mammals or poultry.
Livestock to be fed feed in compliance with the Standard.
Exceptions for dairy production – some 20% may come from conventional
sources until 90 days prior to milk use as organic.
Not at this point specified.
Feedstuffs of animal origin, with the exception of milk and milk products,
fish, other marine animals and products derived therefrom should
generally not be used or, as provided by national legislation. In any case,
the feeding of mammalian material to ruminants is not permitted with the
exception of milk and milk products.
- 17 -
IFOAM
For the calculation of feeding allowances only, feed produced on the farm
unit during the first year of organic management, may be classed as
organic. This refers only to feed for animals which are themselves being
produced within the farm unit and such feed may not be sold or otherwise
marketed as organic. Feed produced on the holding in accordance with
these Standards is to be preferred over conventionally grown, brought-in
feeds.
Where it proves impossible to obtain certain feeds from organic farming
sources, the certification program may allow a percentage of feed
consumed by farm animals to be from conventional farming origin.
As discussed further in this report the National Standard has a very strong position on livestock feed.
Consideration should be given to relaxing the requirements for 100% organic feeds rather than
pursue the uptake of meatmeal to fill nutritive gaps in the conversion process. Furthermore, there is a
deficiency in the National Standard relating to the use of conversion feeds and if they may, and at
what percentages they may be used.
Note, there appears to be a significant push by some countries to exclude the use of animal byproducts in animal feed.
- 18 -
3.9
Manures
Table 9.
MANURES
Australia
EU
USA
JAPAN
CODEX
Manures to be composted prior to use on farming system, apart from
exception below.
Sheet composting using animal manures must go through two green
manure crops before the area is used for small crops.
Incorporation in the soil of organic material, composted or not, from
holdings producing according to the rules of this Regulation
a. Raw animal manure, which must be composted, unless it is:
•
Applied to land used for a crop not intended for
human consumption;
•
Incorporated into the soil not less than 120 days prior
to the harvest of a product whose edible portion has direct contact
with the soil surface or soil particles; or
•
Incorporated into the soil not less than 90 days prior
to the harvest of a product whose edible portion does not have
direct contact with the soil surface or soil particles;
b. Other uncomposted plant or animal wastes, such as aged, fully
decomposed animal manure;
Not specified in Standard.
a. Farmyard and poultry manure: Need to be recognized by certification
body or authority if not sourced from organic production systems.
’Factory’ farming sources not permitted.
b. Slurry or Urine: If not from organic sources, need to be recognized by
inspection body. Use preferably after controlled fermentation
and/or appropriate dilution.
“Factory” farming sources not
permitted.
c.
IFOAM
Human excrements: Need to be recognized by certification
body or authority. If possible aerated or composted. Not
applied to crops intended for human consumption
a. The certification program shall set limitations to the total amount of
biodegradable material of microbial, plant or animal origin brought
onto the farm unit, taking into account local conditions and the
specific nature of the crops.
b. Manures containing human excrement (faeces and urine) shall not be
used on vegetation for human consumption, except where all
sanitation requirements are met. Procedures shall be in place which
prevent transmission of pests, parasites and infectious agents.
The use of uncomposted animal manures is permissible in certain systems if from an uncertified
organic holding. The use of manure from factory farms is now prohibited by Codex. Australia’s
position on composting manures has been well received by the industry at large for good technical
reason, not always related to contamination. The use of off farm manures should not be restricted
except that volumes used and the background of manures should be monitored with reference to
“factory farming”. Certifiers should be required to draw up a standard regarding the origins and
application of composted manures.
- 19 -
3.10 Record Keeping (estimates)
Table 10.
RECORD KEEPING (ESTIMATES)
Australia
Written and/or documentary accounts must be kept to enable an
approved certifying organisation to trace the origin, nature and
quantities of all raw materials brought in and the use of such materials.
Records must also be kept of the nature, quantities and consignees of all
certified agricultural products.
EU
USA
JAPAN
CODEX
IFOAM
Each year, before the date indicated by the inspection body, the producer
must notify the body of its schedule of production of crop products, giving a
breakdown by parcel.
a. A certified operation must maintain records concerning the production,
harvesting, and handling of agricultural products that are or that are
intended to be sold, labeled, or represented as "100 percent organic,"
"organic," or "made with organic (specified ingredients)."
b. Such records must:
•
Be adapted to the particular business that the certified
operation is conducting;
•
Fully disclose all activities and transactions of the
certified operation in sufficient detail as to be readily understood
and audited;
•
Be maintained for not less than 5 years beyond their
creation; and
•
Be sufficient to demonstrate compliance with the Act
and the regulations in this part.
c. The certified operation must make such records available for inspection
and copying during normal business hours by authorised
representatives of the Secretary, the applicable State program's
governing State official, and the certifying agent.
Not specified.
a. Written and/or documentary accounts should be kept which enable the
official or officially recognized certification body or authority to trace
the origin, nature and quantities of all raw materials bought, and the use
of such materials.
b. In addition, written and/or documentary accounts should be kept of the
nature, quantities and consignees of all agricultural products sold.
c. Quantities sold directly to the final consumer should preferably be
accounted for on a daily basis.
Addressed in accreditation criteria:
• A record keeping system adapted to the type of production that enables the
certification program to retrieve necessary information and to get
verification of the production, storage, processing, purchase and sales.
There is a general requirement for record keeping of all inputs and production, although the case of
parallel production is not mentioned. The National Standard has no requirement for the capacity of
individuals to project production levels. Provision should be made for this.
- 20 -
3.11 Labelling / Mixing Conversion
Table 11.
LABELLING/MIXING CONVERSION
a. 95% minimum requirement for ingredients to be sourced from organic
Australia
sources (excluding salt and water), with exception of up to 5% from
other acceptable non certified ingredients.
b. Less than 70% of ingredients from certified sources requires that no claims
to certification be made on the label.
c. NB Amendment/s pending in relation to clarification re in conversion and
organic mixing.
During a transitional period expiring on 1 July 1994, indications referring to
EU
conversion to organic production methods may be given on the labelling and
in the advertising of a product referred to in Article 1 (1)(a) or (b) where it is
composed of a single ingredient of agricultural origin.
USA
JAPAN
a. Products sold, labelled, or represented as "100 percent organic." A
raw or processed agricultural product sold, labelled, or represented as
"100 percent organic" must contain (by weight or fluid volume,
excluding water and salt) not less than 100 percent organically
produced raw or processed agricultural product. No such product or
product ingredient may contain or be created using excluded methods
or be produced using sewage sludge or ionising radiation. If labelled as
an organic food product, such product must be labelled pursuant to §
205.303.
b. Products sold, labelled, or represented as "organic." A raw or
processed agricultural product sold, labelled, or represented as
"organic" must contain (by weight or fluid volume, excluding water
and salt) not less than 95 percent organically produced raw or
processed agricultural product. Any remaining product ingredients
must consist of non-agricultural substances or non-organically
produced agricultural products approved in the National List of
Allowed and Prohibited Substances in sub-part G of this part and must
not contain or be created using excluded methods or be produced using
sewage sludge or ionising radiation. If labelled as an organic food
product, such products must be labelled pursuant to § 205.303.
c. Products sold, labelled, or represented as "made with organic
(specified ingredients)." Multi ingredient agricultural product sold,
labelled, or represented as "made with organic (specified ingredients)"
must contain (by weight or fluid volume, excluding water and salt) at
least 50 percent organically produced agricultural products which are
produced and handled pursuant to requirements in sub-part C of this
part. The non-organic ingredients must not contain or be created using
excluded methods or be produced using sewage sludge or ionising
radiation. If labelled as an organic food product, such products must be
labelled pursuant to § 205.304.
d. Products with less than 50 percent organic ingredients. The organic
ingredients in multiingredient agricultural product containing less than
50 percent organic ingredients (by weight or fluid volume, excluding
water and salt) must be produced and handled pursuant to requirements
in sub-part C of this part. The non-organic ingredients may be
produced and handled without regard to the requirements of this part.
Multi ingredient agricultural product containing less than 50 percent
organically produced ingredients may represent the organic nature of
the product only as provided in § 205.30
Not specified.
- 21 -
CODEX
Foods composed of a single ingredient may be labelled as “transition to
organic” on the principal display panel.
IFOAM
a. Where a minimum of 95% of the ingredients are of certified organic
origin, products may be labelled "certified organic" or similar and
should carry the logo of the certification program.
b. Where less than 95% but not less than 70% of the ingredients are of
certified organic origin, products may not be called "organic". The
word "organic" may be used on the principal display in statements like
"made with organic ingredients" provided there is a clear statement of
the proportion of the organic ingredients. An indication that the product
is covered by the certification program may be used, close to the
indication of proportion of organic ingredients
c. Where less than 70% of the ingredients are of certified organic origin, the
indication that an ingredient is organic may appear in the ingredients
list. Such product may not be called "organic".
The National Standard is broadly in line with labelling requirements of other Standards etc. There is
no articulation of conversion ingredients in products so labelled. The labelling requirements should
consider removing the requirement for the appending of the name and address of the certifier and
simply require the logo or seal. A response will need to be considered to meet individual country
requirements.
- 22 -
3.12 Residues
Table 12.
RESIDUES
Australia
No specifications on historic or ambient levels acceptable. Note made of
compliance required with all normal “laws of the land” in relation to
agricultural chemicals, veterinary chemicals, etc.
EU
Requires inspection bodies to make a full physical inspection, at least once a
year, of the unit or premises. Samples for testing of products may be taken
where the use of unauthorised products is suspected. However, residue testing
is not specifically mentioned and not clearly identified.
USA
When residue testing detects prohibited substances at levels that are greater
than the estimated national mean of detected residues for specific
commodity/pesticide pairs, as demonstrated by USDA's (USA Dept of
Agriculture) Pesticide Data Program, or unavoidable residual environmental
contamination, as determined by the Administrator, the agricultural product
must not be sold, labelled, or represented as organically produced. The
Administrator, the applicable State program's governing State official, or the
certifying agent may conduct an investigation of the certified operation to
determine the cause of the prohibited substance residue.
Not specified
Samples for testing of products not listed in these guidelines may be taken
where their use is suspected. An inspection report must be drawn up after
each visit countersigned by the person responsible for the unit inspected.
JAPAN
CODEX
IFOAM
In case of reasonable suspicion of contamination the certification program
shall make sure that an analysis of the relevant products and possible sources
of pollution (soil and water) shall take place to determine the level of
contamination.
There is no mention of specific levels of residue permitted. There is language which would see OC’s
OP’s and heavy metals analysed. Provision should be made for the inclusion of a risk management
strategy (eg Australian Standard 4360) drawn up by certifiers with reference to any residue levels and
there should be a requirement that the certifier have a policy on residues and GMO risk analysis and
management.
As a general rule, approved certifying organisations reference the residue standards published by the
National Registration Authority for Agriculture and Veterinary Chemicals (NRA). Furthermore, it is
understood that 10% of the Maximum Residue Limit (MRL) is adopted by most approved certifying
organisations. For organic food products, reference to MRL’s can be found under the Australia New
Zealand Food Standards code.
NITROGEN (N) FERTILISER
The National Standard makes it clear that N fertilizer may only be from biological sources. Given
the intrinsic nature of and general principles of organic farming and the strong position of IFOAM
and many private certifiers, this should remain so.
- 23 -
3.13 Inerts and Synergists
Table 13
INPUTS INCLUDING INERT INGREDIENTS OR SYNERGISTS
No specific mention of inerts or synergists.
Australia
No specific mention, but understood that synergists are not “listed” in
EU
what is a positive list.
Prohibits EPA Lists 1 and 2 inerts, allows EPA List 4, prohibits EPA List
USA
3 unless specifically allowed.
Not specified.
JAPAN
CODEX
Preparations on basis of pyrethrins extracted from Chrysanthemum
cinerariaefolium, containing possibly a synergist.
IFOAM
Inputs should not contain harmful amounts of man made chemicals
(xenobiotic products). Chemically synthesised products may be accepted
only if nature identical.
The National Standard has no language on these agents. Consideration should be given to their
inclusion.
3.14 Land and Water
Table 14
LAND & WATER
Not specified.
Australia
EU
Not specified.
USA
The producer must select and implement tillage and cultivation practices that
maintain or improve the physical, chemical, and biological condition of soil
and minimize soil erosion.
JAPAN
In the case of rice paddy fields, necessary measures shall be taken to prevent
the irrigation water from contamination with the prohibited use materials.
CODEX
Not specified.
IFOAM
Clearing of land through the means of burning organic matter, e.g. slash-andburn, straw burning shall be restricted to the minimum. The clearing of
primary forest is prohibited.
Relevant measures shall be taken to prevent erosion. Excessive exploitation
and depletion of water resources are not allowed. The certification program
shall require appropriate stocking rates which do not lead to land degradation
and pollution of ground and surface water. Relevant measures shall be taken
to prevent salination of soil and water.
Only very general reference is made to issues of land and water. These areas should be carefully
considered and language which provides both recommendations and minimum requirements in these
areas should be developed with consideration given to require that certifiers develop their own
standards of land, water, landscape and biodiversity management.
- 24 -
3.15 Comparison of Sundry Items
Table 15
Item
1. Copper for pests
(restricted)
2. Chlorine sanitiser
(processing)
3. Sulphates in food
Australia
EU
USA
Japan
Codex
IFOAM
Yes
Until
2002
No
Yes
Yes
Yes
4 PPM
N/S
N/S
Must
reduce
No
N/S
Wine only
4. Nitrates in food
N/S
Wine
only
No
5. Social Justice
N/S
N/S
N/S
N/S
N/S
Yes
6. Beekeeping
Draft
Draft
N/S
N/S
N/S
Principles
7. Aquaculture
N/S
N/S
N/S
N/S
N/S
Principles
8. GMO permitted
No
No
No
No
No
No
9. Natural Herbicides
N/S
?
Yes
?
?
Yes
10. Textiles
No
No
No
No
No
Yes
Farm
only
Yes
Farm only
Farm only
Principle
Expectation
Expectatio
n
Expectatio
n
11. Biodiversity
Stock/Crop ie
Farm
farm only
only
12. Organic Seedlings
Yes with
By
exemptions
2003
N/S = Not specified. ? = Classification Uncertain
No
N/S
Restricted
Restricted
No
N/S
N/S
N/S
3.16 Comparison Summary
The comparison of overseas requirements with the National Standard reveals that the National
Standard is very much on par with, or in numerous cases well in excess of, requirements currently
specified in key international regulatory texts. However there are two areas which need attention.
One is the ongoing development of international standards, and the other is the issue of differences in
production environments and the need to have the Australian specific case put forward and
understood by international market place regulators for the purposes of equivalence recognition.
With the increasing scrutiny being placed upon national regulatory systems, ensuring that
equivalence recognition is maintained is essential for Australian export trade.
Given the recent concern over the changes in EU regulations (addition of livestock as an amendment
to EEC 2092/91) and the EU revision which the Australian regulatory system underwent in relation
to these changes, it is advisable that Australia remains both abreast of international developments,
and ensures key lobby access to the appropriate international regulators. This should be pursued
whilst ensuring that the National Standard remains in front of, or at least abreast of, these
developments.
Issues of regional differences in Standards specifications may or may not be acknowledged by
overseas market regulators into the future. Given Australia’s unique production environments, this
issue may be important for the maintenance of competitive Australian trade with international trade
partners.
- 25 -
4. Processes for Setting Standards
4.1
Australian – Evolution and Challenges
The setting of standards is a practice which has, and will inevitably come under growing pressure as
new technologies emerge and as commercial interests and mass production systems attempt to
embrace organic practices.
At the time of writing this report, standards setting in Australia is ultimately the responsibility of the
Australian organic industry with OPEC finalising any recommended changes to the National
Standard.
The mechanisms at work inside OPEC involve the selection of a Standards Committee recommended
by the certifiers OCA 3, members of whom are present on the OPEC committee. This Standards
Committee is selected based on criteria which chiefly involve demonstrated competence – technically
in relation to knowledge of the industry, and regulatory matters. One member is a consumer chosen
from a consumer group – not necessarily expected to be cognisant with all the above.
The recommendations of the committee are privy to review by OCA, but are passed in their entirety
to OPEC. OPEC may seek further input from the OCA, but any recommendations of the OCA would
be put once again before the Standards Committee for their input, before being placed once again in
front of OPEC for a final determination.
Thus, the composition of OPEC will effect the composition of Standards. The current composition is
a diverse one but is unquestionably dominated by certification organisation representatives. This is
not to say that the certification agencies will necessarily have unanimous positions on standards
issues, but through their mutual membership of the OCA, a usually consolidated position is
established.
Lack of resource or funding issues often prohibit some other key industry members or representatives
from attendance. This is of course a challenge for all industries. While still in an evolutionary stage
of its existence, the organic industry has sourced the best personnel from wherever possible – and this
has to date fallen mostly to the certifiers to establish. There are pragmatic reasons for this – this
group is the only grouping of commercially viable representatives in the regulatory arena, and with
resources and people’s time short, such representatives have proven the most effective and
sustainable means of ensuring ongoing, technically proficient debate and decision making in these
industry circles. The RIRDC’s Organic Subprogram provides a travel contribution to reimburse
participants to Standards Committee meetings.
The integrity of the Standards Committee process is crucial to the support and endorsement of the
National Standard by industry, community and government. While there is no doubt there is
considerable interest from the wider industry in becoming involved in standards setting, such
activities need to be informed by technical back-up, prior knowledge of the industry, clear
understandings of the international nature of the industry, and the context within which Australia’s
industry is emerging.
3
At the time of writing the Certifiers organisation OCA appears to be currently negotiating a split into two
bodies, the OCA (representing BFA, NASAA, OVAA and OFC), and the Ethical Organic Certifiers of Australia
(ECO) (representing BDRI, OHGAA and TOP).
- 26 -
Standards development is time consuming and requires dedication and commitment from those
involved. This necessarily means that there will always be short supply of appropriate personnel for
such positions of authority and decision making. Such personnel also therefore need to remain aware
of their own positions – as representative ones of the wider industry.
There is some ad hoc criticism levelled at the standards setting process in regard to a perception that
the process is either: a) controlled by the certifiers, and / or b) controlled by a small clique of the
industry. It is the authors’ contention that this has happened more by default, rather than design, and
in part reflects the smaller and still maturing nature of the industry. Nonetheless, this is criticism that
needs to remain as an issue by all future standards setting personnel. A transparent and professional
process must be maintained.
The terms of reference for the appointment of the Standards Committee include the biannual revision
of the Standards. This is intended to include a round of public consultation as has been done in past
major revisions. The amendment of standards through the period between reviews has been practiced
and whilst no clear guideline has been laid down, it has been carried out at the request of the (then)
OPAC members. The most recent recommendations to OPEC on Standards changes have been taken
up in part, following amendments between biennial reviews.
It is understandable that non-routine “out of session” amendments should be made to the National
Standards. The capacity to rectify unforeseen flaws in structure, emerging technologies and other
reasons all point to some need for such intervention. It will be important that understandings of
principle remain in place through the process of amendment however, and that pragmatism alone
does not drive the amendment or indeed revision process.
Out of session amendments will sometimes be driven by parity issues and at other times by domestic
interests as been the case in the past. A practical technique for consideration of such amendments
should be the development of a list of criteria for the inclusion (or deletion) of practices and
substances in the National Standard. A set of general principles and transparent guidelines should be
established to enable, at all times, the committee to make its recommendations.
It will be important for the OPEC group to provide not only transparent and open processes but well
defined structure to its working groups, of which the Standards Committee could be considered the
first. The “committee protocols” make it a requirement that “the committee be transparent and
accountable to the organic community”. Whilst technically, deliberations and minutes of the
committee are confidential until they are presented to OPEC, there is a clear intent by OPEC to
maintain the interests of the organic community within the committee.
It could be expected that there will continue to be a strong presence within the committee from the
certification community, not surprisingly since the culture of certification resides within that group
and it enjoys good representation on OPEC.
The membership criteria are broad but reflect at least an equal representation from each of the
farming, processing, auditing and scientific communities. On an ongoing basis, and in order to
ensure effective deliberations and decisions on standards reflective of the community, it will be
important that OPEC select committees which appropriately represent the balance of characteristics
contained within their membership criteria.
It is probably true that the composition of the National Standard committee will drive the ultimate
character of a National Standard, although the more political composition of OPEC will tend to
exercise a levelling effect on any outbursts of gross oversight of the committee.
It could also be noted that the industry has made suggestion that the standards setting process be
more congruent with and directed by the broader organic community itself.
The OPEC structure is not necessarily bound by some constitutional certainty, but is best seen as a
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genuine attempt by Government to be advised by and be seen to be advised by a broadly based
industry group, which one must argue, OPEC currently is. The Australian organic industry has
enjoyed at times a turbulent relationship with AQIS, but at its core there has been notable success in
the relationship.
The process of standards setting is a complex one however, and should not be seen as an entirely
political or popular process. Issues of parity (with other key certification and regulation texts),
realities of the Australian production environment (and provision therefore for international
“exemptions” as well as practical technical allowances), historic development (while not unique in
Australia, is very different from the UK, US, NZ or Japan), consumer demands and perception and
the perceived principles of the Australian organic sector are all relevant.
The following discussion suggests some change to the standards setting process.
Highlighted at this point should be the notions and definitions of the “organic community” which has
arguably to date been somewhat more definable if not homogeneous. With current industry and
consumer market expansion, and technological change, the original “movement” has progressed
somewhat from its original tethers. This raises the issue of how to define the current dynamic
community of interests that make up the organic movement/industry. And how this will be reflected
in standard setting processes.
Such questions cannot be answered with ease in such a report, however it is important to note that
this is an open ended issue, and one without great clarity, although nonetheless one with great
bearing on the process and outcomes of future standards setting activities.
The organic industry is generally uncertain and potentially anxious regarding this entire process of
reliance upon government regulation. The uncertainty is partly driven by the reality that government
policy responds to the ebb and flow of politics. Government policy can change rapidly, and in an age
of globalisation where national sovereignty is increasingly under pressure from international shifts in
power, finance and politics, the nature of organic agriculture regulation is not inured from these
forces in the current structure.
The organic community, which has given life to this new emerging industry, could be rightfully
forgiven for some anxiety in handing over the process to government control. If it is seen that the
process of standards setting itself is one also fully ceded technically to Government, then alternatives
should be considered by the Australian organic policy makers.
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4.2
4.2.1
International Texts, Standards and Regulatory Processes
United Kingdom
This standard setting process in the UK is based upon a distinct and evident presence of consumer
and producer input. This approach is managed by the well respected Soil Association of the UK.
Whilst governed by a UK ROFFS national body which audits to the European requirements, the Soil
Association has effectively transcended this standard and established a process of standards setting
by their not-for-profit, open membership charity. Hence the Soil Association has retained not only
“community” control of the standards setting process, but have also distanced standards setting from
the certification sector with its own relatively recent internal subdivision.
It should be recognised that there are a number of historic and structural differences between the UK
system and Australia, not least being the historic domination of the organic landscape by the 50 year
old plus Soil Association. It would be a mistake to attempt to import any blueprint of a foreign
organic scheme and futile to make detailed comparisons, but the principle of a standards setting
process which is entrenched in the hands of a community who have the vision of a long term
sustainable agriculture and the holistic view of a society where each one of us can equally enjoy the
fruits of such an agriculture is probably a high priority.
4.2.2
United States
Currently the US has a National Standard – Organic Standard – under second draft, with submission
dates for this having closed. The US has combined a mixture of direct (and voluminous) public
comment into the process of standards setting, with somewhat direct and overt moves by the USDA
to regulate the organic industry possibly at levels beyond acceptability from some organic
community quarters.
Most notable have been the advancement of concepts such as the inability of a given certifier to
arrange their own standard at a higher level than the USDA set level. This has never been mooted to
date in an Australian environment, and whilst the intent may be honourable in terms of delivering a
non-confusing uniform system to consumers, the ultimate outcome could prohibit the ongoing
evolution of organic standards and requirements in other key areas. These would include social
justice, fair trade, and related mooted topics worthy of future clarified insertion into organic
certification schemes.
A number of notable draft proposals have been withdrawn from the process, possibly as a result of
the first round reaction to the draft. (+250,000 submissions). Industry advice suggests these
withdrawn proposals sought provision for use of: GMOs; sewerage sludge and irradiation processes
within organic production systems.
The US has a number of distinct organisations worth discussion. One is OMRI, the Organic
Materials Research Institute, which assesses (for an industry levelled fee) materials and substances
for potential use within organic systems. This list is extensive, and not always acceptable to all
certifying bodies, however the list can be used as a guide by producers and processors across the
country.
Also the US is represented by a broad based grouping, the Organic Trade Association, which
provides forums and a focus for lobbying of organic industry issues.
It should be noted that although a considerably larger country, the US also has a considerable number
of certifiers with as much diversity amongst their ranks as the Australian counterparts.
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4.2.3
Japan
A national domestic organic standard has been designed recently, (notably with considerable speed).
This standard has had significant support from NSSS (MAFF – Ministry of Agriculture, Forestry and
Fisheries) and key input from the existing organic community.
The standard has mostly been guided by adoption of existing key international texts, most
particularly Codex.
Note should be made that Japan has recently “won” a Codex ruling in relation to organic livestock
production, allowing penning systems and non mandatory requirements for “free access to pasture”.
This is in line, they argued, with their specific production environments which require more rational
use of land than in many other countries.
April 2001 is the cut off date for products on Japanese supermarket shelves being at that point
required to bear reference to the new “JAS” mark denoting certification by a registered certifier.
4.2.4
IFOAM
Where does IFOAM sit? It is often misunderstood due to the various roles that it plays in the
industry, and the often confusing reference made to it by certifiers claiming “membership of
IFOAM”. Reflection on its name reveals its broader nature as well as the inherent style and approach
of the wider organic community.
IFOAM is not just an accreditation process for a limited but significant number of certifiers but also a
broader representative group; the international organic community represented by approximately 120
countries.
Given the international credence that IFOAM enjoys, it is judicious for the Australian regulatory
system to recognise the IFOAM accreditation program as complying with the basics of Australia’s
own National Standard. The grass roots of organic agriculture, and an increasingly respected
regulatory body recognised not only by marketplaces but by the government regulatory sectors of
most countries.
Australia should consider recognition of IFOAM accreditation as equivalent to its own and
equivalent to the other official accreditation schemes that are accepted by the Australian industry.
Credence has been lent to the IFOAM Standard for its inherent role in the early start up of the organic
industry, to the extent that IFOAM is now recognised by ISO as a standards setting body. Further
recognition is made by TACD, an international consumer forum representing 46 consumer
organisations from the US and the EU
4.2.5
Codex
Codex is the world body established by Food and Agricultural Organisation (FAO) and the World
Health Organisation of the United Nations. Its role is to establish minimum standards and guidelines
in food related issues and in so doing facilitate international trade. Organic production systems are
an integral component of the Codex brief, reflecting the international nature of organic regulation.
Codex cannot be overlooked in future plans for domestic legislation and for purposes of pressing for
import and export equivalence.
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4.3
Australian – Proposed Approach
It is opportune for the Australian organic industry to move forward using insights from developments
in key trading partners, and the current domestic industry situation.
Given that government regulation and presence has always been invited at the request of the industry,
this should continue. This will assist in supporting the overall long term aim of regulation. However
the industry needs to be more proactive in establishing standards setting processes and community
linkages. It needs to develop an effective mechanism to enable organic community support, and
consumer feedback. This will ensure legitimacy is maintained in what is otherwise an essentially
community oriented or driven international industry.
Such provision would include a far greater input and feedback in relation to aspects such as standards
setting. This would include a higher degree of input both from consumers generally – in relation to
their perceived notions of what organic should be – as well as input from a more formally grouped
and networked industry body which would become the conduit for particular industry views,
demands and technical positions.
This could become a highly complimentary approach to the existing technical and regulator biased
arrangements, whilst continuing to instill both wider industry support and acceptance of industry
regulations and standards. Most importantly this approach is being supported and driven forward in
some key centres of organic industry growth – namely the US and the EU.
Domestic legislation is relevant for export markets for two key reasons:
• perceptions of Australian products by overseas consumers, and
• the ease and effectiveness of regulation within Australia.
With (to date unsuccessful) ongoing industry and government discussion regarding provision for
domestic legislation this point is relevant 4. As other key trade countries are now reviewing /
implementing domestic organic legislation, (eg Japan) it is important for Australia to progress this
domestic process.
Domestic legislation will work to both:
1. ensure ongoing legitimacy within the eyes of the international community – while enabling WTO
compliant regulatory equivalence for demands placed upon imported product into Australia.
Requirements are such that countries may not impose import specifications on products for which
they have no legal domestic specifications themselves, and
2. assist in equitable and straightforward regulation of organic produce generally – instilling
confidence and enabling ease of investment by the commercial community and producers in
organic production systems.
The implementation of domestic legislation cannot be over emphasised in importance. Ensuring
ongoing uniformity and industry harmonisation will be essential to maintain consumer confidence
and organic regulatory integrity. Failing to deliver in this area may well expose the industry to future
chaos and uneven implementation of standards. All would be losers under such a regime – producers
and processors, certifiers and consumers.
4
For a more extensive discussion of the potential for development of the domestic organic legislation refer to
RIRDC Report MS990.20; Organic Certifiers – AQIS Charges Review. December 1999.
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5. Implications for Australia
5.1
Australia and Issues of Equivalence and Harmonisation
The implications for Australian management of organic equivalence are driven by the ongoing
growth in world trade. The priority afforded these implications is compounded further by the export
intensive nature of our agricultural product and service economy
The Australian organic community needs to further develop a structure with sufficient cohesion and
durability to permit this almost osmotic process to flourish. Thus far, it has only been within the
structure of government aided assemblies where this process has occurred.
To be sure, the old OPEC members played a core role in standards setting and now the OCA have
created a new forum of their own volition. But they would be considered by many including a more
educated general public and the auditors of the future to be too close to application and compliance
with standards to be entirely responsible for their creation.
The OFA promises some new opportunity for a more representative basis of the organic community
to participate in standards development. If the current structure can be retained, and the OFA can
become a respected and independent voice of the organic movement then there is some good
argument for them to be responsible for standards, and/or for key elements of the establishment of
those standards.
Complexity potentially arises when a standards setting process is both aimed at satisfying
international parity and satisfying domestic consumers. Whilst there is remarkable and growing
homogeneity of organic standards around the world, there is a growing pressure to satisfy more
detailed international demands. Any independent standards setting done outside of government
auspices would require cognisance of these factors. Fortunately, as with other food sectors there is a
recognisable demarcation between the standards process and the compliance process, which has
earlier been described.
What should be emphasised is the difference between the actual standards for farming operators, and
the standards for certification (Administrative Arrangements or “criteria”). The latter are more
intrinsically entwined with the reality of custom AQIS auditing, and the expectations of the various
international standards for operating a product certification system. (Note particularly “product”, and
not “process”). In this arena, there has been little historic development and limited discussion / input
by the organic community, and it might be argued, this area could best remain overseen under the
current OPEC structure.
The organic industry does not necessarily fit into conventional government or QA structures the way
it may otherwise be expected to. A recognition of the specialized nature of the industry is crucial to
understanding the unique and careful path forward.
However, as a formalised process of import equivalence or harmonisation eventually takes root, it is
quite conceivable that there will be a divide which emerges between the export driven sector and the
domestic one. Exporters will be careful to nurture any market edges they have arising from natural
and competitive production environment factors, but will automatically precipitate towards the
pragmatism of meeting minimum importing country requirements when this is not possible. The
WTO rules, in as much as they are observed, could therefore be expected to place pressure on driving
down the standards for imports when this happens.
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The dynamic within this process needs to be carefully considered by a maturing organic sector which
derives its existence from confident and trusting consumers, not only abroad, but at home. The
export focused nature of the OPEC group may ultimately be the factor which precipitates a schism in
Australian organic standards setting which requires that a more evenly balanced group be developed
to oversee standards development.
The Australian industry should seek to achieve a level of harmonisation at an international level
where the process of standards setting compliance and application of organic principles and practices
are as homogenous as possible and to this end, consideration should be given to the aims and
objectives of the IFOAM group.
However, not withstanding the efforts to achieve harmonisation there will always remain issues
which, as a consequence of climatic, ecological, social and other issues, there will need to be
differing approaches to those of other countries. Even within our large continent the standard needs
to incorporate temperate and tropical system diversity.
It is here that equivalence needs to be recognised. The Australian Industry should continue to
develop a framework from within which equivalent approaches respectful of general principle can be
made, and should support those mechanisms that will be necessary to introduce, support and have
accepted by trading partners, those specific issues. An example of these might be nutrient and water
management, issues which differ markedly form many northern agricultural models.
5.2
Getting the Australian Message and Perspective Across
Australia has to date had some “wins” in regard to arguing for Australian specific allowances for
particular standards requirements. For example the issue of mulesing in sheep is a very Australia
specific need, arguably and ideally essential in managing to organic requirements in many areas of
Australia. In other areas Australia to date has faired less well, with the losing of the debate over
phosphonic acid for allowance for use as a remedy for phytophthora control in certain horticultural
systems.
It could be argued that there is room for negotiation and movement in some regulatory areas which
Australia has an interest.
One of these is the issue of feeds for certified livestock. The requirement for 100% of feed to come
from either certified sources with 5% provision for other very specific allowances, is arguably
restricting uptake of organic production systems in some of the more intensive livestock such as
dairy, pigs and chickens. The EU for example has far less – up to 50% coming from non “A”
certified sources. In the absence of allowance for meat meal this may also be understandable,
however the Australian context allows for effectively no meatmeal in dietary allowances currently.
Clearly here is an example where a mixture of good external communication combined with a
pragmatic interim approach to enabling these industries to “get off the ground” would be judicious.
(It is clearly noted that in many standards, such temporal derogations are commonplace). The
analogy would arguably be in the horticulture sector where currently there are certified organic
operators still sourcing non certified seed and seedling stock. While not an ideal scenario, this has
been allowed, with sunset clauses, by two of Australia’s major certifiers, revealing a pragmatic
approach to ensuring these industries survive under organic production requirements.
The variety and number of certification schemes should not necessarily be reason to expect a
splintering of interests and regulatory function within the industry. Comparisons with the US, EU
countries and possibly Japan, suggest that this diversity, to a point, is obviously in demand within the
industry and encouraged within what is after all a multi-sector, highly varied industry.
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The number and type of certifiers in comparative models is relevant because this bears directly on
administration and regulation of the standards. Further, this bears directly on the type and nature of
standards implemented, the process of change to those standards and the ease or challenge of
ushering in industry reform or modification.
Hence Australia is not unique in having this diversity. In fact it could be noted that even New
Zealand, starting from a base of one main certifier, now arguably has three functioning systems.
Again, what should be noted as essential is not the number nor nature of the certification agencies
(which after all ultimately provide a regulated service of certification to their respective clients /
licensees). But what is essential is the degree to which these certifiers operate as a harmonious whole
in relation to overall regulation of the industry, ongoing modification to standards and the delivery of
equivalent certification services such that healthy and equal competition is enabled within the
industry and in trade.
Against this view must be juxtaposed the alternative. That is a limited pond of certified farmers,
possibly less than 2000 in the whole country, driving the cloning of small scale certification agencies
ad infinitum. This alternative could be expected to deny forever the economy of scale needed to
operate competent certification and farming systems. In a competitive commercial environment of
limited clientele, the pressure to offer a reduced service in terms of competence and independence
must remain high.
5.3
Summary
In some aspects Australia leads the world in terms of an homogenous nation-wide approach to
organic regulation. Also it has been noted that whilst there are currently a high number of certifiers
within Australia relative to the industry’s size, this is not uncommon in other countries. What is
important is the degree of convergence between certifiers, which in Australia’s case has been
relatively high.
Setting standards is an issue which will always need broad consultation and an ongoing vision of the
evolution of organic farming and the needs and interests both of organic consumers and producers, as
well as issues of parity with key international regulators and texts.
The high degree of legitimacy which the industry enjoys will be maintained by a mixture of enlisting
the ongoing support of government to administer and assist in regulation of what is ultimately an
industry driven, self regulatory, voluntary code of practice. Ongoing ownership of standards by the
organic industry will be essential to maintain this legitimacy, and will be achieved by a mixture of
extensive producer, exporter / importer and consumer feedback and input into standards setting.
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6. Recommendations
1. That the organic industry / organic community, in concert with an industry export working group
and AQIS, provide the industry with a domestic Standard as soon as possible.
2. That the establishment of any domestic – state or national – Standards must be congruent with the
current National Standard and all key international Standards. Failure in this task will unravel
confidence and perceived legitimacy of the overall industry, while creating significant problems
for the industry in its overall aim of ensuring legitimate, homogeneous and internationally
compliant regulation.
3. That clarification, and if necessary, content be given to the existing National Standard such that it
may function in a dual role as both a stand alone standard as well as a guideline for standards
setting.
4. That specifications of the National Standard continue to not require mandatory conformance to a
lowest common denominator, but rather allow certifiers to specify their own standards above this
in accord with their own perceived constituent demands and commercial needs.
5. That in the interim the OFA – as the organic industry’s peak body – channels direct consumer and
generalist industry representation into the standards setting process. Also that this process via the
OFA be formalised and given considerable resources and effort to establish such a system or
organic community wide input and recognition.
6. That within 5 years the organic industry moves towards a Standards setting model in line with the
principles utilised both by the US and the UK, requiring wide industry consultation, involvement
of all key sectors and interest parties. However an added proviso is that such standards setting
procedures ensure Australia’s ongoing ability to remain ahead of organic regulations, ensuring
ongoing access to key markets via parity provisions, and ongoing enjoyment of the good
reputation the country has in relation to commitment to leading organic regulation and standards.
7. That in the longer term (2-5 years) the OFA – or similar independent and broadly representative
industry group – become the bearer of Standards and standards setting. Note should be made that
this should NOT be seen in the longer term as a certifier realm. Such standards setting activity
would be reliant upon direct technical, industry international equivalence issues and consumer
and producer ownership. This is a subtle point, easily overlooked, but essential in continuing the
legitimacy and integrity that the industry currently holds.
8. That the organic industry, to continue to maintain consumer and regulator confidence, must
ensure its ongoing unique nature in terms of Standards and standards setting procedures. This
must be contingent upon direct consumer and producer feedback and consumer driven demand,
evident in more recent events as the popular support for the prohibition on GMOs, but arguably
also present in prohibition of most agrichemicals, etc.
9. That there be a formalised technically based Standards Advisory Panel, supported industry wide,
which feeds into the standard bearer’s structure – both informing, directing, as well as taking
direction from, consumer, producer and other interests in the standards formation process.
10. That moves be made to clarify aspects of the National Standard as outlined in this report in terms
of comparison tables and other areas of concern or note.
11. That government regulators and support structures be seen and utilised specifically as that –
structures of support for the industry to continue to enable the industry to assess, direct and
provide itself with its own Standards and regulatory aspects. The nature of the organic industry
is such that government intervention at a regulatory level, beyond that invited by the industry, is
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likely to undermine the very strength of the industry in both the market place and in terms of
regulatory function.
12. That the Standard moves toward and continually takes signals from the models currently in
existence in IFOAM and Codex. This requirement for parity would guide overall recommended
changes or modifications to the Standards. This needs to be achieved by effective resourcing of
authoritative research and personnel to enact informed decisions on Standards.
13. That efforts are made in ensuring regional regulatory aspects are clearly communicated and
lobbied for in appropriate places, (e.g. IFOAM and Codex, US, EU and Japan) to ensure that the
unique Australian production environments are considered and accommodated in reference to
specific Standard requirements.
14. That consideration be given to areas of the Australian National Standard currently well in excess
of requirements of all key international texts. Further, that resources be allocated to assessing
where such regulations do not pose problems to Australia’s growing organic industry, versus
areas where some emerging industries are now finding it difficult to establish, namely poultry,
porcine and dairy.
15. That recurrent resources are allocated to ensure that the industry remains efficient and effective in
the areas of technical proficiency, technical assessment and regulatory function, to both respond
to and lobby for, the interests at stake on the international and domestic arenas.
16. That immediate priority be given to ensuring adequate and appropriately directed representation
be affixed to future delegations to Codex, IFOAM, and related trading partners/regulatory
organisations to ensure that Australia’s ongoing work in establishment of world leading
Standards continues to enhance its overall reputation.
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Annex
Example
Clarification #1
Animal Feeds
This area of regulation and Standards setting would require mature balance, in that there are
constituents from both consumer as well as producer circles which have interest in this
arena. One example, likely to be visited by the industry in the coming year is the issue of
animal feeds. Currently the Australian National Standard is higher than almost all noted
Standards of the world in respect of requirements for 100% of all feeds needing to arise from
certified organic sources (with some mostly non agricultural source exceptions).
For a country with a current deficit of sufficient specific organic certified grain feeds, this is putting
pressure on more intensive industries such as dairy, as well as poultry. Both will suffer badly –
economically and technically – without sufficient access to certain specific feedstuffs which include
maize and pulse products in particular.
This regulation, while in essence laudable, given the current context is inappropriate and needs
reassessment. Note should be made that no other country currently has such stringent requirements.
While it would not be judicious to lower Australia’s requirements in this regard given our
comparative advantage in this area, such areas of divergence and Codex and IFOAM allowance
highlight the nature of regulatory divergence related to regional appropriate regulations. Further, the
aspect of livestock feeds is currently accepted both in the US and EU as allowing proportions of non
certified or non “A” level or “Organic” (ie “in conversion certified”) feeds – in some cases up to 50%
of total diet.
Whilst there are sunset clauses built into these allowances, endorsed as sensible by the authors, such
a move towards these levels would enable a boost to our fledgling and highly promising dairy, pigs
and chicken industries.
We suggest provision be made for effective feedback, both from technical sources and interest groups
(ie industry specific and consumer), to enable ongoing sensibly apportioned standards requirements
which remain realistic for producers to achieve.
In this instance this may be establishing a sunset clause provision for the sourcing of percentages of
uncertified feeds. Or possibly, in the case of poultry and porcine production, the provision of
acceptable levels of protein meal in the form of mammalian meat meal (currently allowed in small
proportions).
Example
Clarification #2
Aquaculture
Australia needs to develop a more detailed set of aquaculture standards which address all those
details currently applied to terrestrial systems and make special note of several factors which are
currently under debate at an international level. Specifically these should include:
1. Feedstuffs. Can the use of a diet of perhaps 50% or more commercial fish meal be accepted for
organic production.
2. Pollution. Whilst there is ample precaution required in most standards to protect organic fish
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from pollution, there is a need to specify very clearly, those levels of pollution in the form of bio
foulding which might be accepted in organic production systems.
3. Wild harvest. What are the limits of this? Can marine products from wilderness systems be in
any way regarded as organic?
Other areas not yet covered sufficiently by international regulation but regulated within Australia and
in need of clarification in the National Standard are:
• Aquaculture
• Bees
• Wild harvest
• Processing Inputs
While all noted as currently pending future Codex meetings, in the tradition of Australian standards
setting processes, it is important to push forward and establish guidelines which assist in guiding
certifiers. The unacceptable alternative is to enable a subsequent addition to regulatory requirements
after regulations are put into train by individual certifiers themselves or by the international
community.
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Abbreviations
AQIS
Australian Quarantine and Inspection Service
BDRI
Biodynamic Research Institute
BFA
Biological Farmers of Australia
CODEX
Codex Alimentarius – specifications on organic production.
EU
European Union
IFOAM
International Federation of Organic Agriculture Movements
NASAA
National Association for Sustainable Agriculture, Australia
OCA
Organic Certifiers of Australia
OFA
Organic Federation of Australia
OFC
Organic Food Chain
OHGA
Organic Herb Growers of Australia
OPAC
Organic Produce Advisory Committee
OPECC
Organic Produce Export Consultative Committee
OPEC
Organic Produce Export Committee
ORGAA
Organic Retailers and Growers Association of Australia
ORGAV
Organic Retailers and Growers Association of Victoria
OVAA
Organic Vignerons Association of Australia
TOP
Tasmanian Organic Dynamic Producers
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References
AQIS (2000) Comparison with US and Australian Organic Regulations AQIS, Canberra, ACT.
Codex Alimentarius (1999) Organic Production Specifications.
Council Regulation (EEC) 2092/91 (1991) On Organic Production…(and following amendments)
European Union.
IFOAM (1998) Standard for Organic Production.
Organic Trade Association (1999) American Organic Standard, OTA, US.
OPAC (1998) National Standard for Organic and BioDynamic Produce.
Monk, A (1998) Sustaining Organic Agriculture in Australia PhD Thesis, Wollongong University,
Wollongong NSW.
RIRDC (1999) Report MS990.20; Organic Certifiers – AQIS Charges Review. December
1999.
United States Department of Agriculture, Agriculture Marketing Service (1999) National
Organic Program, RIN 0581-AA40, USDA.
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