Asociación de Salinas Marinas
SALIMAR
La Asociación tiene como fines: la defensa de los intereses profesionales colectivos de sus afiliados, promoviendo y cooperando en el desarrollo de la industria salinera de origen exclusivamente marino y en la coordinación y fomento de tales intereses
ID: 958999035182-60
Lobbying Activity
Response to Detailed production methods for organic salts
4 Jan 2023
SALIMAR, the Spanish Sea Saltworks Association, welcomes the opportunity to provide feedback to the European Commission public consultation about detailed production rules for organic sea salt and other salts for food and feed. The European Green Deal is at the heart of the Commissions policy agenda. It emphasizes that it is key to manage the transition towards a more sustainable food system to tackle climate change, protect the environment and preserve biodiversity. In this direction, Organic Regulation introduces specific objectives and related principles focused on the Unions environmental policy. Further, the Commission's Farm to Fork and Biodiversity Strategies include the target of reaching 25% of agricultural land under organic farming by 2030 for which sea saltworks can represent an important contribution. The rules applicable to organic production of salt should be based on best environmental practices and techniques and use of products that do not comply with the objectives of the Organic Regulation cannot be accepted. Salt production techniques are different and not all of them can be authorised simply because they are used in some countries for salt production. Some of them may be employed for salt intended for other uses, but they do not meet the requirements to be considered organic. Customers value organic products versus non-organic products because they have both a natural origin and a production behind that contribute to the protection of the environment. Salt is a natural resource located in different areas of Europe. Salt extraction sites occur where the natural resource is located but organic salt, like many other organic products, is produced where climatology and geographical conditions allow it provided they accomplish the rest of organic requirements. Local production should be encouraged but not all organic products are produced in all European countries. SALIMAR appreciates the efforts made by the Commission to draft these rules to comply with organic production requirements. We have always argued that salt should be considered as organic only if its source is natural (sea water or rock salt natural brines such as spring water and salt lakes) and its crystallization is produced uniquely by solar evaporation without any added substances. Rock salt could have a place in this regulation only if it is ensured that its extraction and production are done without any harm to the environment and without the addition of chemical products. Therefore, we share that several methods should be prohibited to produce organic salt in order to contribute to the protection of the environment and the climate, to minimize the use of energy and to contribute to a non-toxic environment and we would like to underline some technical and legal arguments that support the prohibition of: The use of explosives (2.1.a) Solution mining or artificial dissolution of rock salt on surface (2.1.b) Upgrading of salt (2.1.c) Recrystallization (2.1.d) Use of plastic liners (2.1.f) Additives and processing aids (2.3.1) Please find attached our position document with more arguments about these prohibitions. Finally, despite this proposal does not reflect completely our point of view as stated in previous positions (i.e. in relation to restriction to only renewable energy for drying unlike other organic products), we welcome the current Commissions proposal that puts an end to years in which organic salt has been certified with different criteria in function of each countrys private standards. Common criteria are needed and, for the sake of consistency of the salt sector, organic production and towards the consumer, we hope this proposal is finally adopted by the European Parliament in the following weeks.
Read full responseResponse to Labelling of organic pet food
14 Dec 2022
SALIMAR, the Spanish Association of sea saltworks, welcomes the opportunity to provide its views on the European Commission proposal to establish specific rules for the labelling of organic pet in the attached document.
Read full responseResponse to Rules for organic production (supplementing rules)
4 Oct 2019
Spanish Association of Sea Salt Producers (SALIMAR) welcomes the opportunity to comment on the draft.
Regulation (EU) 2018/848 on organic production and labelling of organic products applies to certain other products closely linked to agriculture, such as sea salt and other salts for food and feed.
In relation to item (5) of the Draft delegated regulation - Ares(2019)5658405, “It is necessary to lay down in this Regulation the exceptional production rules that may be applied in case of catastrophic circumstances for plant, livestock, aquaculture and wine production in terms of derogation and their conditions”, we would like to point out that “sea salt and other salts for food and feed” have not been included among the possible products to which exceptional production rules may apply in case of catastrophic circumstances. However, the production of “sea salt” may also be affected by catastrophic circumstances like “adverse climatic event”, “environmental incident”, “natural disaster” or “catastrophic event” in the same way as some of the products included in this item (plant, livestock, aquaculture and wine production). In case these circumstances occur, “organic salt producers” will not be able to use exceptional production rules.
To fix the terms of derogation and their conditions, it is necessary to previously stablish the Organic Salt Production Rules, which have now been deleted from the draft delegated act on Production Rules amending Regulation (EU) 2018/848. An EGTOP salt sub-group will be created in the next days and will work on the list of positive and negative production techniques and products and substances used. After EGTOP’s report, the Commission will prepare a new version of the draft delegated act defining the rules for organic salt.
If salt production is included in the supplementing Regulation (EU) 2018/848 of the European Parliament and of the Council as regards exceptional production rules in organic production, once the Organic Salt Production Rules are adopted, it could be possible to amend this supplementing Regulation by fixing the terms of derogation and their conditions in case of salt production. Thereby, salt producers would have legal certainty on the new rules that will apply in case of catastrophic circumstances like other operators have.
SALIMAR hopes the above raised concern will be taken into account.
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