European Spice Association e.V.
ESA
The European Spice Association, ESA, is a non-profit association representing the interests of its members in all matters pertaining to the processing, packing, quality assurance and food safety and/or marketing of herbs, spices and spice products (e.g.
ID: 404593641312-23
Lobbying Activity
Response to Trade rules for organic production (implementing)
9 Nov 2021
Dear Ms Panichi,
With the above-mentioned Implementing Regulation, the European Commission proposes to remove five Indian inspection bodies from the list of recognised inspection bodies in third countries.
In accordance with recital 5 of the abovementioned Implementing Regulation, several Indian control bodies should no longer be included in the list of control bodies recognised by the competent authority of India due to contamination with ethylene oxide ('ETO') detected in a number of consignments of allegedly organically produced sesame in 2020. The Commission points to the occurrence of ethylene oxide contamination in organic products and the lack of a response to the causes and thus the failure of the control system.
The ETO crisis has developed into a general food crisis affecting many different types of food and ingredients, e.g. from seeds to food additives, throughout the food chain. It is not limited to organic farming.
We welcome the Commission taking responsibility for the integrity of organic products and taking action when integrity is compromised. However, we believe there are better ways to act. The measures you propose will make it difficult for hundreds of thousands of Indian organic farmers (ETO is a post-harvest substance) to export their organic products to the EU, and the interests of the companies that sell their products in Europe and the customers who buy them will also be damaged. All these actors are not the cause but the victim of ETO contamination.
As far as we know, these five inspection bodies certify almost 80% of the organic products imported into Europe from India. And India is one of the most important countries for importing spices into the EU. This means that many EU operators who source spices from India for retail or as ingredients for food processing companies will also be affected.
In order to avoid further harm to Indian organic farmers who have already been negatively affected by the ETO case and to serve the interests of spice companies and consumers in Europe, we ask you to reconsider how best to improve the quality of ETO controls in India and, at the very least, to establish an appropriate transition period and regime when the Commission is convinced that it has taken the right step. This should allow Indian organic farmers to continue marketing their produce and ensure a smooth transition from the current, presumably exempt, inspection body to a new one. And to help importers in Europe to import the produce of these organic farmers without additional disruption.
Yours sincerely
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