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International Federation of Organic Agriculture Movements EU Regional Group

IFOAM EU Group

IFOAM Organics Europe is the leading umbrella organisation for organic food and farming in Europe.

Lobbying Activity

Meeting with Martin Häusling (Member of the European Parliament) and Bund Ökologische Lebensmittelwirtschaft e.V. and

19 Nov 2025 · Austausch über Öffnung EU-Öko-VO und NGT

Meeting with David Cormand (Member of the European Parliament) and European farmers and

19 Nov 2025 · Event: "This Land Is Our Land: Generational Renewal and Access to Land in Europe"

IFOAM Organics Europe urges targeted fix for organic trade rules

18 Nov 2025
Topic — This consultation addresses EU organic labelling rules and trade agreement deadlines.
Message — IFOAM requests amendments to allow organic logos on equivalent imports. They also propose a ten-year extension for existing trade agreements.12
Why — These changes would prevent trade disruptions and reduce certification costs for organic farmers.34
Impact — EU processors and consumers lose access to vital organic imports like coffee.5
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Meeting with Gijs Schilthuis (Director Agriculture and Rural Development)

5 Nov 2025 · Meeting with representatives of IFOAM member Green Dossier, Ukrainian environmental NGO

Meeting with Elisabeth Werner (Director-General Agriculture and Rural Development) and

29 Oct 2025 · Exchange of views on the upcoming legal proposal amending the organic Basic Regulation

Meeting with Catherine Geslain-Laneelle (Director Agriculture and Rural Development) and

14 Oct 2025 · Exchange and update regarding the CAP proposal

Organic sector urges biocontrol access without pesticide deregulation

13 Oct 2025
Topic — EU proposal to simplify food and feed safety regulations and accelerate biocontrol access.
Message — IFOAM requests an EU-wide definition of biocontrol strictly limited to nature-identical products excluding GMOs, with adjusted risk assessments and faster authorization procedures. They oppose relaxing rules for drone pesticide spraying and demand clarity on fermentation products without deregulating GMOs.1234
Why — This would give organic farmers faster access to natural pest control products while maintaining GMO exclusion.56
Impact — Conventional chemical pesticide manufacturers lose market share as biocontrol products gain approval priority.78
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Organic farming groups urge recognition in EU nature credits scheme

30 Sept 2025
Topic — EU initiative to develop framework for rewarding biodiversity and ecosystem service provision.
Message — The organization requests that organic certification be recognized as evidence of biodiversity delivery in nature credit schemes. They emphasize that organic farming already provides proven biodiversity benefits and should not require additional verification beyond existing EU certification.123
Why — This would allow organic farmers to access nature credit payments without duplicating existing certification requirements.45
Impact — Conventional farmers who haven't adopted biodiversity practices lose competitive advantage if first-movers aren't rewarded.67
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Meeting with Antonella Rossetti (Cabinet of Commissioner Christophe Hansen) and Friends of the Earth Europe and

29 Sept 2025 · presentation of and discussion about their roadmap to reduce pesticide use in Europe

Meeting with Benoit Cassart (Member of the European Parliament, Shadow rapporteur)

23 Sept 2025 · INI report on Biocontrol agents

Meeting with Klaus Berend (Director Health and Food Safety) and

22 Sept 2025 · Exchange on the Commission proposal on plants obtained by certain new genomic techniques (NGTs) and the status of negotiations.

Organic farming group calls for simpler fertiliser regulation implementation

19 Sept 2025
Topic — EU regulation harmonising rules for mineral, organic, waste-based fertilisers and biostimulants.
Message — The organisation requests clearer wording to reduce complexity, mandatory labelling for organic-compatible products, and expanded categories to include food industry streams and more microbial biostimulants. They argue the regulation is too complex and costly to implement.123
Why — This would reduce certification costs and ease market access for organic-compatible fertilisers.45
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Meeting with Esther De Lange (Cabinet of Commissioner Christophe Hansen), Maxi Espeter (Cabinet of Commissioner Christophe Hansen)

18 Sept 2025 · Exchange of views

Response to Integrated farm statistics for the period 2030-2039

8 Sept 2025

IFOAM Organics Europe is the European umbrella organisation for organic food and farming. With almost 200 members in 34 European countries, our work spans the entire organic food chain and is based on the principles of organic agriculture: health, ecology, fairness and care. IFOAM Organics Europe welcomes the European Commission's proposal to amend Regulation (EU) 2018/1091 in order to provide a legal basis for the collection of agricultural data for the period 2030-2039. Indeed, agricultural statistics are crucial for the design, implementation, monitoring and evaluation of policies and must therefore continue to be collected consistently. While a certain degree of flexibility in implementation is necessary, common baseline and variables must be defined to ensure comparability and consistency across time and space. Variables defined in Annex III of Regulation (EU) 2018/1091, notably those concerning organic and in-conversion to organic, must continue to be compiled as they are essential for understanding the social, environmental and economic aspect of agriculture and its evolution. Additional variables to monitor the evaluation of the consequences of climate change on agriculture and how farmers adapt to them are necessary. Data on agricultural technology, changing climatic conditions and shifting dietary preferences are therefore welcome. Finally, no data should be collected on the so-called regenerative agriculture as there is no definition, let alone regulation of this term, and no consensus on which agricultural practices this would cover. Such an initiative would trigger confusion and risk leading to greenwashing.
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IFOAM Organics Europe Urges Support for Resilient Farming Systems

4 Sept 2025
Topic — EU consultation on creating an integrated framework for managing European climate risks.
Message — IFOAM calls for prioritizing diverse organic systems to prevent climate risks. They demand that the Common Agricultural Policy includes a dedicated budget for environmental measures. The group argues against relying on unproven new genomic techniques for agricultural resilience.12
Why — Dedicated funding and legislative support would increase the market share of organic farmers.3
Impact — Biotech firms would lose influence if the EU rejects gene editing as a solution.45
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Meeting with Henri Delanghe (Head of Unit Agriculture and Rural Development)

4 Sept 2025 · Next EU Research and Innovation Framework Programme (FP10)

IFOAM Organics Europe criticizes farm sustainability data reporting delays

26 Aug 2025
Topic — Amending rules for the EU Farm Sustainability Data Network implementation phase.
Message — The group opposes exemptions allowing France and Germany to postpone reporting key sustainability variables. These delays weaken the completeness and comparability of data across the European Union. More transparency is needed regarding the reasoning behind these specific national exemptions.12
Why — Rigorous reporting provides data that justifies the sector's claims about environmental sustainability.3
Impact — Policymakers and researchers lose access to a complete and comparable European agricultural dataset.4
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Meeting with Maxi Espeter (Cabinet of Commissioner Christophe Hansen)

25 Aug 2025 · Position paper on Generational Renewal

Meeting with Flavio Facioni (Cabinet of Commissioner Olivér Várhelyi)

16 Jul 2025 · Priorities of the organic sector

Meeting with Eric Mamer (Director-General Environment) and

16 Jul 2025 · Meeting between IFOAM and Director-General of DG ENV

IFOAM urges EU to base animal welfare on organic standards

15 Jul 2025
Topic — The European Commission is revising legislation to modernise on-farm animal welfare standards.
Message — IFOAM wants new EU rules to use organic farming practices as a guide for measuring animal welfare. They suggest looking at the whole farm system rather than just individual small changes.12
Why — Using organic rules as a blueprint would cement their position as the industry benchmark.3
Impact — Intensive farmers face higher costs to adapt to requirements like mandatory outdoor access.4
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Organic Youth Demand Land Reform and Fairer CAP Funding

14 Jul 2025
Topic — EU initiative to address demographic challenges by attracting young farmers to the agricultural sector.
Message — The network calls for a European Land Observatory and legislation to prioritize land for sustainable farming. They demand CAP subsidies be based on ecological services rather than land size, with mandatory budgets for youth. They also advocate for integrating organic practices into agricultural education and supporting entrepreneurs across value chains.123
Why — Reform would improve the competitive position and financial viability of young organic farmers.45
Impact — Large corporate farms and land speculators would lose subsidies and face tougher regulations.67
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Response to Import into the Union of high-risk organic and in-conversion products

11 Jul 2025

Thank you for the opportunity to comment on the draft Commission Delegated Regulation amending Delegated Regulation (EU) 2021/1698. IFOAM Organics Europe is the European umbrella organisation for organic food and farming. With almost 200 members in 34 European countries, our work spans the entire organic food chain and beyond: from farmers and processors organisations, retailers, certifiers, consultants, traders, and researchers to environmental and consumer advocacy bodies.
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IFOAM Organics Europe urges organic-first EU bioeconomy strategy

23 Jun 2025
Topic — This consultation explores solutions for a circular, regenerative, and climate-neutral EU bioeconomy.
Message — The organization calls for prioritizing food production and high-value materials over bioenergy and intensive extraction. They advocate for rewarding organic practices through the CAP and phasing out pesticide subsidies.123
Why — Prioritizing organic goods in public procurement would boost market demand and revenue.4
Impact — Intensive agricultural models and pesticide producers would lose significant public financial support.56
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Meeting with Elisabeth Werner (Director-General Agriculture and Rural Development)

19 Jun 2025 · Introductory meeting

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen)

18 Jun 2025 · Exchange of views on the future Common Agricultural Policy (CAP) and the organic sector

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen)

18 Jun 2025 · to follow

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen)

18 Jun 2025 · Exchange of views on the future Common Agricultural Policy (CAP) and the organic sector.

IFOAM Europe insists on strict GMO traceability in Biotech Act

11 Jun 2025
Topic — This consultation seeks views on creating a regulatory framework to accelerate EU biotechnology innovation.
Message — The organization demands mandatory identification and traceability for all genetically modified products to protect GM-free production chains. They insist that new genomic techniques must meet the same biosafety and labeling standards as older GMOs. They also call for the polluter pays principle to prevent contamination of organic crops.123
Why — These regulations would protect the economic livelihoods and market integrity of organic farmers and processors.45
Impact — Biotech developers and patent holders would face increased liability and restricted control over seed genetics.67
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Meeting with Philippe Tulkens (Head of Unit Research and Innovation)

14 May 2025 · EU Mission on Adaptation to Climate Change, link with the Mission Soil and perspective for the Missions under the next MFF

Meeting with Christophe Hansen (Commissioner) and

30 Apr 2025 · Sustainable Protein Diversification for the Vision

Meeting with Flavio Facioni (Cabinet of Commissioner Olivér Várhelyi)

23 Apr 2025 · Organic food and farming, biocontrol, biopesticides

Meeting with Maxi Espeter (Cabinet of Commissioner Christophe Hansen)

14 Apr 2025 · Mutual introduction and follow up on the vision for agriculture and food

Meeting with Christophe Hansen (Commissioner) and

8 Apr 2025 · Grazing obligation for organic livestock producers following an EU Pilot

Meeting with Luis Carazo Jimenez (Head of Unit Agriculture and Rural Development)

25 Mar 2025 · Exchange with the IFOAM Europe Bord

Meeting with Jessika Roswall (Commissioner) and

25 Mar 2025 · Roundtable “Water, Agriculture, and the Food Supply Chain”

Meeting with Christophe Hansen (Commissioner) and

19 Mar 2025 · Prospects of Organic farming in the EU including a few technical issues

IFOAM Organics Europe urges organic focus in water resilience strategy

4 Mar 2025
Topic — The EU is developing a strategy to achieve water resilience and protect ecosystems.
Message — The organization wants organic farming recognized as a primary tool for protecting water quality and biodiversity in EU initiatives. They recommend banning synthetic pesticides in water catchment areas to protect drinking water and reduce pollution costs.12
Why — Formal recognition in the strategy would likely unlock additional EU funding and market opportunities for organic farmers.34
Impact — Conventional farmers and pesticide manufacturers would face bans and higher operational costs in water catchment areas.56
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Meeting with Fabien Santini (Head of Unit Agriculture and Rural Development) and ECOCERT SA

26 Feb 2025 · Definition of “fair” and “equitable” in the Commission’s proposal to strengthen the position of farmers in the food supply chain (CMO targeted amendment).

Meeting with Mihail Dumitru (Deputy Director-General Agriculture and Rural Development)

21 Feb 2025 · Exchange of views on: CAP simplification; ECJ ruling on Herbaria case; grazing requirements.

Response to Rules on good manufacturing practice for active substances used as starting materials in veterinary medicinal products

19 Feb 2025

The Regulation laying down good manufacturing practice for veterinary medicinal products in accordance with Regulation (EU) 2019/6 of the European Parliament and of the Council and all connected Annexes should consider in particular the special conditions in the production of herbal veterinary medicinal products, traditional herbal veterinary medicinal products and homeopathic veterinary medicinal products. Indeed, these products are not easily available in the European market, hence there is an urgent need to support the manufacturers of those products and protect them from being discontinued due to disproportionate GMP demands. Therefore we agree with the general concerns and the detailed required changes of the German pharmaceutical industry association (BPI). This answer was based on the two following points: (a) In EU-Regulation 2019/6, it is stated that There is insufficient information to date on traditional herbal products used to treat animals in order to allow the establishment of a simplified system. Therefore, the possibility of introducing such a system should be examined by the Commission based on the information provided by the Member States on the use of such products on their territory. (Preamble 12). Article 157 of Regulation (EU) 2019/6 requires the Commission to report to the European Parliament and to the Council by 29 January 2027 on traditional herbal products used to treat animals in the Union. It therefore seems possible that also in the future (traditional) herbal veterinary medicinal will be produced in the European Union. (b) Organic farming is expected to contribute to the protection of the environment and the climate, the long-term fertility of the soil, maintaining high levels of biodiversity and achieving high animal welfare standards. Consequently, herbal and homeopathic veterinary medicinal products are explicitly recommended as the first line treatment of animal diseases on organic farms (EU Regulation 2018/848 on organic production).
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Response to Uniform rules on good manufacturing practice for veterinary medicinal products and active substances

19 Feb 2025

The Regulation laying down good manufacturing practice for veterinary medicinal products in accordance with Regulation (EU) 2019/6 of the European Parliament and of the Council and all connected Annexes should consider in particular the special conditions in the production of herbal veterinary medicinal products, traditional herbal veterinary medicinal products and homeopathic veterinary medicinal products. Indeed, these products are not easily available in the European market, hence there is an urgent need to support the manufacturers of those products and protect them from being discontinued due to disproportionate GMP demands. Therefore we agree with the general concerns and the detailed required changes of the German pharmaceutical industry association (BPI). This answer was based on the two following points: (a) In EU-Regulation 2019/6, it is stated that There is insufficient information to date on traditional herbal products used to treat animals in order to allow the establishment of a simplified system. Therefore, the possibility of introducing such a system should be examined by the Commission based on the information provided by the Member States on the use of such products on their territory. (Preamble 12). Article 157 of Regulation (EU) 2019/6 requires the Commission to report to the European Parliament and to the Council by 29 January 2027 on traditional herbal products used to treat animals in the Union. It therefore seems possible that also in the future (traditional) herbal veterinary medicinal will be produced in the European Union. (b) Organic farming is expected to contribute to the protection of the environment and the climate, the long-term fertility of the soil, maintaining high levels of biodiversity and achieving high animal welfare standards. Consequently, herbal and homeopathic veterinary medicinal products are explicitly recommended as the first line treatment of animal diseases on organic farms (EU Regulation 2018/848 on organic production).
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Meeting with Thomas Waitz (Member of the European Parliament)

17 Jan 2025 · Ökolandbau

Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

16 Dec 2024 · Exchange on the judgment of the Court of Justice of the EU in case of Herbaria

Meeting with Maria Noichl (Member of the European Parliament, Shadow rapporteur)

6 Nov 2024 · Tiertransport, Saatgutrecht, Gentechnik

Meeting with Veronika Vrecionová (Member of the European Parliament, Committee chair)

6 Nov 2024 · Organic farming, strategic dialogue and CAP

Meeting with Eric Sargiacomo (Member of the European Parliament)

2 Oct 2024 · Agriculture biologique

Meeting with Benoit Cassart (Member of the European Parliament)

2 Oct 2024 · Prise de contact

Meeting with Per Clausen (Member of the European Parliament)

25 Sept 2024 · Organic and Sustainable Farming Practices

Meeting with Valérie Hayer (Member of the European Parliament)

24 Sept 2024 · Organic farming

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

27 Aug 2024 · organic farming + competitiveness

Response to Imports organic products – certification of certain operators and controls performed by control authorities & bodies

24 Jun 2024

IFOAM Organics Europe would like to take the chance to convey the view of its membership in particular related to the Commission proposal on the delegated act amending Delegated Regulation (EU) 2021/1698 applying a temporary derogation for the issuance of COIs and the validity of operator certificates until 15 October 2025 and we would like to explain in our attached letter why we ask for the expansion of the derogation period for a whole calendar year. IFOAM Organics Europe is the European umbrella organisation for organic food and farming. With almost 200 members in 34 European countries, our work spans the entire organic food chain and beyond: from farmers and processors organisations, retailers, certifiers, consultants, traders, and researchers to environmental and consumer advocacy bodies. Thank you for the opportunity and for considering our arguments!
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Meeting with Ursula von der Leyen (President) and European Coordination Via Campesina

26 Apr 2024 · Meeting with President IFOAM, Director IFOAM, Member of the Coordinating Committee ECVC, Policy Officers ECVC/ IFOAM

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

17 Apr 2024 · to follow

Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

17 Apr 2024 · State of play regarding the simplification proposal

Organic farmers urge flexible transport rules amid slaughterhouse scarcity

11 Apr 2024
Topic — The European Commission is revising animal welfare regulations for transport and exports.
Message — They request that organic facilities be eligible for exemptions allowing longer travel times. They also advocate for extended transition periods for small-scale farmers and mobile slaughterhouses.12
Why — This would protect the organic price premium and reduce financial pressure on farmers.3
Impact — Live animals suffer more if exemptions allow longer journeys and fewer veterinary inspections.4
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IFOAM Organics Europe urges stronger recognition of organic farming systems

3 Apr 2024
Topic — The EU is evaluating whether current animal health rules remain effective and proportionate.
Message — The organization advocates for the strengthening of organic and high welfare practices within the law. They request that these systems receive coherent recognition for preventing disease and resistance.12
Why — Formal recognition of their practices would promote the widespread adoption of organic systems.3
Impact — Conventional livestock producers lose competitiveness as organic models are prioritized for animal health.45
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Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

21 Mar 2024 · organic farming

IFOAM Organics Europe Urges Strict Enforcement of Nitrates Directive

8 Mar 2024
Topic — Evaluation of EU rules reducing water pollution from agricultural nitrogen sources.
Message — IFOAM suggests that supporting and expanding organic farming is an effective way to manage nutrients. They urge the EU not to open the directive and to publish the integrated nutrient management plan.123
Why — Stricter nitrate rules would incentivize farmers to switch to organic production models.4
Impact — Conventional livestock producers would face increasing pressure from strict nitrogen limits.56
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Meeting with Lukas Visek (Cabinet of Vice-President Maroš Šefčovič)

5 Feb 2024 · Sustainable food systems

Meeting with Helena Braun (Cabinet of Vice-President Maroš Šefčovič)

23 Jan 2024 · Green Claims proposal and product environmental footprint method

Meeting with Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius)

23 Jan 2024 · Green Claims proposal and product environmental footprint method

Response to Managing EU climate risks

13 Jan 2024

IFOAM Organics Europe welcomes the initiative of the European Commission to improve adaptive capacity, strengthen resilience and reduce vulnerability to climate change. The climate crisis and its consequences pose a severe threat to the agricultural systems and food production. The adverse effects of climate change, such as heat waves, droughts, heavy precipitation and other extreme weather events, will unavoidably increase in the future. There will be increased climate variability and risks to production in general. Likewise, pest and disease pressure will increase. Agricultural systems must adapt to these adverse impacts in order to ensure resilient food production. The impacts of climate change on agricultural production result in consequences for the whole food supply chain, from producers to consumers. Mechanisms to manage climate risks are absolutely necessary given the accelerating climate crisis and its impacts. However, to ensure resilient and sustainable food production on the medium and long term a transformational change is inevitable. The approach to mitigating climate risks has to shift from coping and adapting to impacts induced by the climate crisis, to preventing them as much as possible in the first place. The priority clearly has to lie on reducing greenhouse gas emissions and incentivizing the transformation to resilient and diverse farming systems. Organic farming offers pathways to more sustainable food and farming systems, which reduce greenhouse gas emissions, build crop resilience, and stabilise yields, based on decades of successful practice on the ground coupled with scientific insights. Organic farms generally cultivate a higher crop diversity, locally adapted species and sustain more biodiversity in and around their production area. Resilience and adaptability to adverse climate conditions such as extreme weather events and other environmental stressors is enhanced by species and habitat diversity. The importance of soil health, building up soil organic matter and promoting a soil rich in beneficial microorganisms allows a higher water capture and retention capacity, reduces erosion, supports plant health and makes organic more resilient to changing weather conditions. The fact that organic farming uses legumes for nitrogen fixation and organic manure and does not rely on synthetic fertilizer, makes the organic system also less dependent on external inputs of non-renewable resources which are often fossil-fuel intensive. Climate risks have to be addressed in accordance with objectives related to soil health, pesticides, biodiversity and nature protection, water and air quality. Policies must be implemented that encourage the development of systemic responses on farms. Looking at it only from the angle of carbon will not result in adequate solutions to tackle climate risks.
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Response to Revision of the plant and forest reproductive material legislation

7 Dec 2023

IFOAM Organics Europe is the European umbrella organisation for organic food and farming. For 20 years, we have been and continue representing organic in European policymaking and advocating for a transformation of food and farming. Our work is based on the principles of organic agriculture health, ecology, fairness and care. With almost 200 members in 34 European countries, our work spans the entire organic food chain. We welcome the proposal for a regulation on Production and marketing of plant reproductive material as an important piece of legislation within the context of the Green Deal and specifically, the objective of the F2F strategy to boost organic production to reach 25% of the EUs agricultural land by 2030. For organic farmers, it is paramount to have access to PRM that has been specifically bred to perform well under organic conditions, where no synthetic pesticides will be sprayed on the crop, and only a limited amount of fertilizer can be used. At the same time, organic breeders and multipliers contribute to maintaining and fostering agrobiodiversity, making sure that a wide choice of PRM is available for farmers, who will in turn be able to offer a diverse variety of products to consumers. IFOAM Organics Europe welcomes the fact that organic varieties will be tested under organic conditions and that there will be adapted DUS criteria for organic varieties. We believe it is important to involve stakeholders from organic breeding in the development of these criteria. Moreover, it is positive that also new varieties can be registered as conservation varieties. We welcome that certain activities are kept outside the scope of the regulation this is already the case for gardening activities and sale of seed lots to amateurs. But it must also apply to activities like the work of gene banks, who should stay out of the scope. IFOAM Organics Europe strongly opposes any amendments to the organic regulation 2018/848 that are mentioned in the PRM proposal. Organic Heterogenous Material (OHM), and all OHM-related provisions, must not be deleted from the organic regulation. OHM has been developed under organic farming conditions and must thus be seen as being different from HM, as it has been laid down in the PRM proposal. By no means is it acceptable to exclude certain types of crops or species from HM; this would implicate considerable financial losses to companies who are currently producing HM from these crops. Also, the organic multiplication practices as defined in 2018/848 must remain untouched and should not be extended to include other practices that are not demanded by the organic sector. IFOAM Organics Europe is sceptical of the extension of VSCU testing to all crop types (such as fruits and vegetables), because the cost of developing new varieties will increase considerably for breeders (and ultimately, farmers), while the benefits of introducing VSCU testing to these crops are negligible. Currently, VCU testing is only done for arable crops, and we believe this should not change. Moreover, the sustainability criteria proposed for VSCU testing are doubtful, since sustainability cannot be related to single crop traits, but can only be evaluated holistically, taking into account the entire cultivation system. Sustainability can best be assessed by testing all varieties under organic farming conditions. Farmers should have the possibility to exchange in kind all types of PRM, and the administrative burden to farmers must be limited. For the organic sector, it is also very important that conservation varieties, organic varieties and heterogenous material must not be derived from genetic engineering nor novel genomic techniques, and would not be covered by patent protection. A high level of transparency regarding breeding methods and patents must be publicly available on the EU Plant Variety Portal.
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Meeting with Anne Sander (Member of the European Parliament) and ECOCERT SA and Coöperatieve Vereniging Bionext UA

6 Dec 2023 · NGTs

Meeting with Norbert Lins (Member of the European Parliament, Committee chair)

6 Dec 2023 · Discussion with MEPs on NGTs

IFOAM Organics Europe urges stronger enforcement of fair trading rules

29 Nov 2023
Topic — Evaluating the effectiveness of EU rules protecting farmers from unfair trading practices.
Message — The group demands better enforcement of rules and awareness for vulnerable operators. They want to prohibit below-cost selling and turn grey practices into black ones.12
Why — Stronger rules would provide organic producers with fairer prices and reduced retaliation risks.3
Impact — Large buyers would lose the power to exploit suppliers through market concentration.4
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Meeting with Norbert Lins (Member of the European Parliament, Committee chair)

23 Nov 2023 · NGTs, gemeinsame Veranstaltung

Meeting with Christophe Clergeau (Member of the European Parliament, Rapporteur for opinion)

15 Nov 2023 · Nouveaux OGMs et semences

Meeting with Beatrice Covassi (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and

15 Nov 2023 · Public Hearing - Soil Monitoring Law

Meeting with Ulrike Müller (Member of the European Parliament)

7 Nov 2023 · NGT

Meeting with Maroš Šefčovič (Executive Vice-President)

6 Nov 2023 · Transition towards sustainable food systems

IFOAM Organics Europe urges binding targets for healthy soils

3 Nov 2023
Topic — This consultation concerns a proposal for a Directive on Soil Monitoring and Resilience.
Message — The movement requests legally binding targets and new indicators for synthetic pesticides and biodiversity. They want organic farming recognized as a primary tool for achieving soil health.123
Why — Recognition would validate organic methods and grant farmers access to vital monitoring data.45
Impact — Agrochemical companies lose as the directive targets reductions in synthetic pesticides and fertilizers.67
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Meeting with Maria Noichl (Member of the European Parliament, Rapporteur for opinion)

31 Oct 2023 · Soil health

Organic farming movement demands full traceability for gene-edited crops

24 Oct 2023
Topic — EU regulation on plants produced using new genomic techniques in food and feed.
Message — The organization demands mandatory traceability throughout the supply chain for all gene-edited crops to protect organic production. They request Member States retain authority to implement crop-specific coexistence rules and ban cultivation where necessary. They urge postponing commercialization until patent issues are resolved.123
Why — This would protect organic producers from contamination and maintain consumer trust in their products.45
Impact — Biotech companies lose streamlined market access and face stricter oversight requirements.6
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Meeting with Lukas Visek (Cabinet of Vice-President Maroš Šefčovič)

14 Sept 2023 · sustainable food systems: organic farming

Response to Revision of EU rules on textile labelling

12 Sept 2023

IFOAM Organics Europe thanks the Commission for the publication of the EU strategy for sustainable textiles. We would like to make two points: (1) the current fast fashion production of textiles has important environmental & social impacts, and (2) organic textiles production has much fewer environmental & social impacts, but current EU rules allow for greenwashing as the term organic is not protected for textiles. (1) Organics Europe carried out an overview of the literature regarding the environmental & social impacts of textile production. Current synthetic, fossil fuel-based textiles and the associated fast fashion industry are a great source of environmental pollution. Also, the fast fashion sector has been associated with inhumane working conditions. It is crucial for policymakers to enable alternative, more sustainable paths to produce textiles. The organic textile label is evidenced to have a positive environmental and social impact. However, the credibility of the organic term when it comes to textiles is put at risk by the threat of greenwashing. The insufficient protection of organic for textiles allows making ambiguous claims about a certain product being organic although the raw material may be conventional, is not certified, or has not undergone third-party verification. Other imprecise terms such as eco, green or conscious are also used to refer to the alleged sustainability qualities of certain products, without legal substantiation. (https://www.organicseurope.bio/content/uploads/2023/08/IFOAMOE_Textiles_Social-Env_202211.pdf?dd ) (2) Various initiatives are being developed on the topic of sustainability in the EU - i.e. the Ecodesign Directive, the Green Claims Proposal, & the Empowering consumers in the green transition directive. By conducting the attached legislative analysis, Organics Europe concludes that none of these initiatives would help preserve the integrity of the organic textile value chain. Regarding the Ecodesign Directive: Organic textile production meets and exceeds many of the product parameters. However, various components, e.g. further environmental, social, & animal welfare provisions, do not fall within the narrow scope of these parameters. Even though the Digital Product Passport might create more transparency to supply chain actors and consumers, operators can still use the term organic textile without a recognized, independently set organic textile scheme/certification. Self-regulation measures - This only implies the justification of the organic product in terms of its compliance with the environmental parameters set out in the Ecodesign regulation, rather than if subject to a recognized, independently set organic textile scheme and certification. Regarding Green Claims: Even a revision of the Green Claims Initiative and an improved methodology of the PEF (which is currently unfit to substantiate the environmental impact of bio-sourced products) would not help in the protection of organic for textiles. This initiative is a tool to measure a products environmental footprint, whereas organic textiles have ecological as well as social dimensions. Regarding the empowering consumers Directive: The concepts underlying this Directive, namely the concepts of environmental claim and sustainability label are not workable to protect the integrity of organic textile production, since organic textiles would not fall within the scope of their definitions. Organic textiles are not an overarching sustainability label but rather a distinct private standard. Organic textiles are also not an environmental claim, because they are not only ecological dimensions but also social and economic ones. Hence, Organics Europe reiterates the need to amend existing Regulation 1007/2011 by laying down requirements for a garment to be labelled organic(https://www.organicseurope.bio/content/uploads/2022/08/IFOAM-OE_Position-paper_Organic-textiles_2022.pdf?dd)
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Meeting with Christophe Clergeau (Member of the European Parliament, Shadow rapporteur)

7 Sept 2023 · Nouveaux OGMs et agriculture bio

Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur)

6 Sept 2023 · staff-only: SUR, pesticide reduction

IFOAM Organic Europe Demands Stronger Agri-Food Labeling Standards

30 Jun 2023
Topic — The EU initiative requires companies to substantiate environmental claims using specific footprinting methods.
Message — The organization calls for integrating biodiversity and animal welfare into environmental assessments, as current methodologies fail to capture systemic impacts. They also demand uniform enforcement to prevent companies from seeking verification from lenient national regulators.12
Why — This approach protects organic producers by ensuring that greenwashing does not disadvantage truly sustainable farming practices.3
Impact — Producers using simple efficiency scores lose the ability to market products that ignore broader ecological impacts.4
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Meeting with Frans Timmermans (Executive Vice-President) and Greenpeace European Unit and

27 Jun 2023 · New genomic techniques

Meeting with Kurt Vandenberghe (Director-General Climate Action) and European farmers and

27 Jun 2023 · Fit for 55

Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and Greenpeace European Unit and

27 Jun 2023 · New Genomic Techiniques.

IFOAM Organics Europe urges separate targets for agricultural emissions

23 Jun 2023
Topic — The European Commission is establishing a climate target for 2040.
Message — The organization requests separate targets for carbon removals and emission reductions. They argue agriculture must reduce emissions directly rather than using forestry offsets.12
Why — This policy would promote organic methods and progress toward the EU's organic land goal.3
Impact — Intensive farmers would lose the ability to use forestry offsets to cover their emissions.4
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Meeting with Sarah Wiener (Member of the European Parliament)

22 Jun 2023 · staff-only: Saatgut

Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

6 Jun 2023 · New Genomic Techniques and Organics.

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

5 Jun 2023 · To discuss on NGT file

Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

26 May 2023 · New Genomic Techniques

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

26 May 2023 · New genomic techniques

Response to Ecodesign for Sustainable Products - Product priorities

18 Apr 2023

IFOAM Organics Europe welcomes the Commissions product-by-product approach reflected in the new product priorities under the proposed Ecodesign for Sustainable Products Regulation (ESPR) and the consideration of textiles as a priority product, as laid out in the preliminary JRC study. The study identifies the Textiles and Footwear category as a key priority due to its high environmental negative impact, for instance on waste, climate change, and material use, but also given its untapped improvement potential, especially in terms of circularity. IFOAM Organics Europe also welcomes the studys recognition of the positive environmental impact of organic production as opposed to industrial, intensive textile production and processing methods. For example, the report states that organic farming uses less water and pollutes less (p. 163). Regarding textiles specifically, the study points out that organic cotton production has less pressure on land use and better preserves soil health (p. 165). Attached, there is a literature overview further documenting the environmental and social impact of organic textile production and processing. Consumer interest in organic products of all types, including organic textiles is increasing every year. Organic textiles represent a credible and popular alternative to the fast fashion industry, as well as a promising market that addresses the environmental and social dimensions of sustainability. However, the organic textile sector is under threat of greenwashing given the misuse of the term organic in the context of textiles. Indeed, in the European Union, the use of the term organic in relation to textiles is not protected the same way as it is for the food chain via the provisions in the Organic Regulation (EU) 2018/848. The poor protection of the organic label for textiles allows operators to make unclear and ambiguous claims about a certain product being organic although the raw material may be conventional and is not certified and/or has not undergone third-party verification, for example. Following a corporate screening in various business sectors including garment, cosmetics, or household equipment, the Commission estimated in January 2021, that 42% of the analyzed claims were exaggerated, false or deceptive. While IFOAM Organics Europe welcomes the aim of the ESPR, we believe that the current provisions therein do not suffice to address greenwashing in terms of misuse of the term organic textiles. The product parameters set out in Annex I, the Digital Product Passport, and the self-regulation measures set out in Article 18 might create higher standards overall and increase supply chain integrity, but it will not prevent stakeholders from misusing the label organic. Firstly, organic textile production meets and exceeds many of the product parameters, however, various components related to further environmental, social, and animal welfare provisions do not fall within the narrow scope of the Product Parameters. Secondly, Article 18 only implies the justification of the organic product in terms of its compliance with environmental parameters set out in the ESPR, rather than a justification of a product to be deemed a legitimate organic textile, that is certified and/or has not undergone third-party verification. IFOAM Organics Europe does not believe that other recent Commission proposals, e.g., the Substantiating Green Claims Proposal, and the Empowering Consumers in the Green Transition Directive, cover this aspect at the moment. In light of the above, we ask the Commission to ensure that the misuse of the term organic when referring to textiles will be covered by the ESPR, with the aim of ensuring that organic textiles enjoy the same legal protection as organic foods. We remain at your disposal for any questions or clarifications you may have.
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IFOAM Urges Carbon Certification to Reward Organic Farming Frontrunners

23 Mar 2023
Topic — The European Commission is proposing a new regulatory framework for certifying carbon removals.
Message — They want management-based certification that rewards ecological practices rather than just carbon results. The framework should promote biodiversity and ensure frontrunners like organic farmers are not penalized. Social safeguards must also be included to prevent land price inflation and land grabbing.123
Why — Organic farmers would receive financial recognition for maintaining existing soil health and carbon.45
Impact — Industrial sectors lose access to easy carbon offsets used to delay emissions reductions.67
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Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

21 Mar 2023 · New Genomic Techniques (NGTs)

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

21 Mar 2023 · New genomic techniques

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

7 Mar 2023 · Consumer protection and the green claims proposal

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

15 Feb 2023 · Sustainable Use of Pesticides Regulation (SUR)

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

14 Feb 2023 · To give an introductory remark on the occasion of the networking reception organised under the EU Promotional Project: BEING ORGANIC.

Meeting with Janusz Wojciechowski (Commissioner) and

18 Jan 2023 · To discuss organic and new breeding technology

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides) and Eurocities and

16 Dec 2022 · VTC Meeting: Sustainable Food Systems/Procurement

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans), Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

18 Nov 2022 · European Green Deal, sustainable food and the preparation of the green claims initiative

Meeting with Jan Huitema (Member of the European Parliament, Shadow rapporteur)

8 Nov 2022 · Sustainable use of plant protection products

Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

10 Oct 2022 · Exchange of views with J. Plagge, President of IFOAM, on the current organic development in the EU

Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur) and Bund Ökologische Lebensmittelwirtschaft e.V.

19 Sept 2022 · staff only: Sustainable Use Regulation, Indicators, Targets, Sensitive Areas

IFOAM Organics Europe urges holistic farm sustainability data collection

8 Sept 2022
Topic — Expanding the EU farm data network to include environmental and social sustainability metrics.
Message — The organization requests that organic agriculture be fully taken into account when composing farm samples. They also propose collecting a comprehensive set of environmental and social variables.12
Why — This would highlight the benefits of organic farming to secure more targeted policy support.3
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Response to European common agricultural policy network, governance

27 Jul 2022

IFOAM Organics Europe welcomes that the future CAP network also covers the European Green Deal which integrates the Farm to Fork (F2F) Strategy as well as cross-cutting CAP objectives such as environmental care, preservation of landscapes and biodiversity, and climate change action. The ENRD’s thematic groups covered relevant topics to boost sustainable farming practices such as the sustainability agreements (CMO’s Art. 210), carbon farming and solutions to strengthen the involvement of farmers within organic supply chains. To reach the F2F target of 25% of organic farmland in Europe by 2030, continuing knowledge exchange on organic farming and building organic agricultural knowledge and innovation systems (AKIS) are key. Strong farm advisory services and promotion of knowledge exchange are crucial for both conversion to and maintaining organic farming, as is capacity building along the supply chain for using organic practices, the adoption of which depends on farmers having access to contextualised knowledge and innovations that are applicable to the local conditions. Technical advice and information must be readily available for farmers, including in very remote areas. Building on the new Horizon Europe call "Developing EU advisory networks on organic agriculture", the Commission should provide support for a European network of organic advisory services, strongly embedded in national or regional AKIS. This network would, inter alia, aim to improve production methods of organic farms and generally increase the standard of living of the farmers and their families and the economical sustainability of their farm operations. It should be complemented with online knowledge exchange. The new EU Farm Book project will continuously map knowledge flows between actors and connect national AKIS through a network of facilitators/ambassadors covering 27 Member States and main production sectors at EU level, including the organic sector represented by IFOAM OE. Ongoing capacity building and training of key actors is needed, also with regards to differences at Member State level in understanding and capacity to implement the CAP approach, in order to address asymmetries. IFOAM OE should again get a seat in the Advisory Board/AGRI Subgroup on Innovation (assumed that it continues to exist). With almost 200 members in 34 European countries, our work spans the entire organic food chain. For 20 years we have been and continue representing organic in European policymaking, based on the principles of organic agriculture: health, ecology, fairness, and care. In view of the next (6th) SCAR-AKIS mandate and rolling out of the new European R&I Partnerships, collaboration with SCAR-AE and SCAR Food Systems on partnership development (in particular of the Agroecology and Sustainable Food Systems Partnerships) and implementation should be intensified. The Organic Action Plan provides Member States with the tools to leverage the potential of organic farming. The involvement of national, regional, and local actors is vital for actions related to public procurement and the promotion and implementation of bio-districts. National capitals should implement the OAP through their national CAP Strategic Plans. As part of the CAP SPs (art. 13 & 72), Member States should set up a dedicated budget to strengthen or set up advisory services that support existing organic farmers, new entrants, and conventional farmers willing to convert to organic agriculture by promoting knowledge exchange through farmers’ networks and on-farm research and assisting in market development. In addition, training of consultants is crucial. The new Horizon Europe call "Organic farming thematic networks to compile and share knowledge ready for practice", relating to EU OAP Actions 9 and 19, will establish and strengthen demo farm networks, with the future CAP network promoting best practices and synergies with the EIP-AGRI projects.
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Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

13 Jul 2022 · staff only: Discussion on the Harmonised Risk Indicator 1 (SUR proposal)

Response to Sustainable Products Initiative

22 Jun 2022

IFOAM Organics Europe welcomes the opportunity to provide feedback on the proposal for a regulation establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC, as part of the Sustainable products initiative. Please find in the attached file our suggestions in reaction to the proposed regulation.
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and Greenpeace European Unit and

3 May 2022 · New genomic techniques

Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and Greenpeace European Unit and

3 May 2022 · New Genomic Techinques

Response to Carbon Removal Certification

29 Apr 2022

While climate mitigation should clearly prioritise absolute emissions reductions, carbon sequestration in the land sector can contribute to long-term climate objectives. Carbon sequestration should be additional to reduction efforts and not disincentivise them. However, the adoption of beneficial management practices for biodiversity protection and carbon sequestration in the agricultural sector should be encouraged and farmers should be remunerated for their efforts. We would like to take the opportunity to highlight points we consider important for carbon removals: 1. Organic farming as carbon farming solution Practices that are standard in organic farming can contribute significantly to soil carbon sequestration, as shown by significantly higher soil organic carbon stocks in land under organic management compared to land under conventional management. Organic farming offers a systemic approach to carbon farming and through synergies it can contribute to carbon sequestration in soils, while also bringing important benefits, such as improved system resilience, maintaining biodiversity on farmland, conserving soil fertility, reducing eutrophication and water pollution, and improving farmers’ sovereignty. Organic farming should therefore be recognized as a carbon farming practice, given its holistic approach to climate and nature and the benefits it provides for climate mitigation, adaptation and ecosystem health. 2. Biodiversity safeguards The strong interlinkage between biodiversity and climate objectives requires them to be addressed together. It is therefore essential that carbon farming does not only deliver on increased carbon sequestration, but also provides at the same time benefits for biodiversity and other environmental objectives. Biodiversity is not simply a “co-benefit” of carbon sequestration in soils; well-functioning ecosystems and biodiversity are a necessary condition for agriculture ecosystems resilience, climate mitigation and adaptation. Carbon farming should target the systemic transitions of farming systems through the adoption of a multi-dimensional approach (beyond a carbon-focused one). Focusing solely on GHG emissions could lead to incentives counteracting biodiversity, animal welfare objectives and the aim to the use and risk of synthetic pesticides. The organic movement believes that all negative impacts of agriculture have to be addressed together. 3. Past efforts must be recognised Common organic farming practices led up until now to significantly higher soil organic carbon stocks and sequestration rates compared to conventionally managed soils. This reduces the potential of organic farmers to store additional carbon in their soils until saturation levels are reached. The efforts of first movers, like organic farmers, have to be recognised and they should not be penalised by a carbon farming scheme which rewards those who have failed to take action in the past. The long-term nature of soil carbon sequestration and its reversibility require adequate management practices over a long period of time in order not to lose the sequestered carbon to the atmosphere. 4. Public money for public goods Carbon markets should not be a way for other sectors to reduce their net GHG emissions by climate action in agriculture. Carbon neutrality should be aimed for within the agricultural sector itself and compensation should not be possible across sectors. The organic movement therefore doubts that carbon markets are the right policy tool to provide funding for carbon farming practices. Instead, the focus should lie on how new and existing public funds, like the CAP, can be used to best incentivise beneficial management practices and support a transition towards agroecology. To maximise the climate potential of organic farming beyond the scope of organic standards, Member States should prioritise organic farming under agri-environmental-climate schemes targeted at carbon farming and environmental goals.
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IFOAM Organics Europe urges prioritizing organic farming in nutrient plan

26 Apr 2022
Topic — The EU is developing an action plan to manage nutrients and reduce environmental pollution.
Message — The plan should recognize organic farming as a key tool for nutrient management. They call for strong support in national strategies and nutrient budget tools. They also want recycled fertilizers to meet organic production standards.123
Why — This would expand organic farming and protect farmers from fertilizer price volatility.4
Impact — Synthetic fertilizer producers lose business as the EU shifts toward organic farming alternatives.5
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Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

25 Apr 2022 · Exchange on current development of organics in EU

Meeting with Janusz Wojciechowski (Commissioner) and

22 Apr 2022 · Farm to Fork Strategy for food security

Meeting with Janusz Wojciechowski (Commissioner)

24 Mar 2022 · Organics

Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

16 Mar 2022

IFOAM Organics Europe welcomes the European Commission’s initiative to develop a soil health law to make sustainable use of soils the norm. Soil health is a corner stone of organic farming and common organic farming practices contribute actively to improved soil quality. Healthy soils are fundamental to produce nutritious and sustainable food, but intensive agriculture is one of the main drivers for soil deterioration. A holistic approach is therefore needed to restore and protect agricultural soils. IFOAM Organics Europe would like to take the opportunity to highlight points we consider important for the upcoming soil health law: • Recognize organic farming as a sustainable use of agricultural soils Transitioning to organic agriculture can contribute to restoring and protecting agricultural soils by strengthening soil carbon sinks, increasing biodiversity and avoiding undesired effects by prohibiting the use of synthetic pesticides and fertilisers. Common organic farming practices that are beneficial for soil health include the use of organic fertilizer like composted waste from livestock husbandry, improved crop varieties, crop rotations including legumes, reduced tillage, planting of cover crops and maximizing the duration of soil cover. Organically managed soils show significantly higher soil carbon sequestration rates and soil organic carbon stocks compared to conventionally managed soils and hence contribute to soil protection and climate mitigation. Soils on organic farms tend to have an improved soil porosity and aggregate stability and an increased water retention capacity. This makes soils under organic management more resilient against extreme weather events such as droughts and flooding, decreases the risk of soil erosion and overall contributes to climate adaptation. Organic farms show on average 30% more biological diversity and the increased abundance of earthworms, insects and soil microorganisms further contribute to a better soil structure and quality. The multiple positive effects that organic farming has on soil health and soil functions should be recognized within the legislative proposal. • Contribution to Farm to Fork - targets The European Green Deal and the Farm to Fork strategy include several soil related targets and policy coherence is needed between the different initiatives. IFOAM Organics Europe therefore urges the Commission to ensure that the Soil Health Law delivers on the implementation of those targets, namely the reduction of fertiliser use by at least 20% and the reduction of nutrient losses by at least 50% and that it supports the objective of at least 25% of the EU’s agricultural land under organic farming by 2030. Organic farming practices such as crop rotations incorporating legumes, improve soil organic matter, and consequently build soil fertility and reduce nutrient losses. • Holistic approach to define healthy soils The full range of soil functions and features must be analysed and taken into consideration. The importance of agricultural soils ranges from production of food and feed to habitat, supporting ecosystem functions and climate mitigation and adaptation. Surface sealing has to be strictly limited to protect fertile soils and valuable farmland. The Horizon Europe mission “A Soil Deal for Europe” lies out 8 specific objectives covering a variety of aspects for soil protection and restoration which should be taken forward by the Soil Health Law as well.
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Meeting with Janusz Wojciechowski (Commissioner) and

15 Mar 2022 · Agriculture impacts from situation in Ukraine

Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

23 Feb 2022 · Organic farming and the draft national strategic plans, future sustainability standards and organic farming as well as the governance regarding the adoption of opinions in the area of organic farming

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Institut de l'agriculture et de l'alimentation biologiques

16 Feb 2022 · Sustainability labelling and the PlanetScore

Meeting with Stella Kyriakides (Commissioner) and WWF European Policy Programme and

31 Jan 2022 · VTC Meeting on the framework legislation on sustainable food systems

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Karolina Herbout-Borczak (Cabinet of Commissioner Stella Kyriakides)

15 Dec 2021 · VTC meeting: sustainability labelling, in the context of the Farm to Fork strategy

Response to Land use, land use change and forestry – review of EU rules

8 Nov 2021

IFOAM Organics Europe welcomes a revision of the current LULUCF regulation to ensure its contribution to the EU climate goals. While climate mitigation should clearly focus on absolute emissions reductions, carbon sequestration in the land use sector has also a crucial role to play to meet the long-term climate objectives. Common organic farming practices can contribute significantly to soil carbon sequestration and higher soil organic carbon stocks compared to conventionally managed soils, and in synergy deliver benefits for soil health and biodiversity protection. Increased soil carbon content also contributes to resilience and climate adaptation, through an improved soil structure, increased water retention capacity and decreased risk of soil erosion. However, carbon sequestration in the land use sector should not be a means to reduce emissions reductions ambition in other economic sectors. IFOAM Organics Europe would like to take the opportunity to highlight important points: 1. Flexibility mechanism and prevent masking of agricultural emissions by forestry removals Climate mitigation should prioritise absolute emissions reductions, and offsetting GHG emission accounted under the ESR with non-permanent sequestration under LULUCF is problematic and emissions reductions and sequestration should not be considered interchangeable. However, residual agricultural emissions that remain after ambitious reductions, e.g. CH4 from livestock or N2O emissions from soils, could be compensated by carbon sequestration in agricultural soils. Compensation should, however, be limited to carbon sequestration in agriculture soils, landscape elements and agroforestry, and exclude pure forestry offset. Agricultural emissions should not be hidden by forestry removals. All sectors have to ambitiously reduce emissions, and carbon neutrality should be reached within every sector itself. Compensation should therefore not be possible across sectors. Priority should be given to the restoration of peatlands, the protection of semi-natural pastures and expansion of biodiverse permanent grassland. IFOAM Organics Europe welcomes an incentive to increase the LULUCF sink and to go beyond the current no-debit rule if the measures are in accordance with biodiversity safeguards. 2. Biodiversity safeguards The strong interlinkage between biodiversity and climate objectives requires them to be addressed together. Climate action, such as enhancing natural carbon sinks, should not lead to further threats to biodiversity and ecosystem services. Focusing solely on GHG emissions could lead to incentives counteracting biodiversity and animal welfare objectives and the aim to reduce the use of pesticides. Only solutions that also deliver benefits for biodiversity and other environmental objectives should be supported. Explicit safeguards for biodiversity, ecosystem services and animal welfare are needed. Therefore, there should be policy coherence between the Commission’s initiatives for reducing GHG emissions from agriculture and increasing carbon sequestration, initiatives aimed a biodiversity protection and ecosystems restoration and the evaluation of the national CAP Strategic Plans.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Plant-Based Foods Europe

4 Nov 2021 · Organics (lithothamnium)

Response to Sustainable food system – setting up an EU framework

25 Oct 2021

IFOAM Organics Europe welcomes the opportunity to provide feedback on the Inception Impact Assessment (roadmap) on the Sustainable Food System Framework Initiative, a key text in meeting the aspirations of the Farm to Fork Strategy and the European Green Deal. Please find in the attached file our suggestions in reaction to the roadmap. IFOAM Organics Europe advocates for this overarching umbrella law to provide for all-embracing principles, but also for more concrete objectives.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Friends of the Earth Europe and

18 Oct 2021 · Presentation of their assessment of the working paper on new genomic techniques +next steps

Response to Restoring sustainable carbon cycles

7 Oct 2021

IFOAM Organics Europe welcomes the initiative to develop a vision for sustainable carbon cycles and kick-start nature-based solutions, such as carbon farming. Carbon sequestration in the land use sector has a crucial role to play to meet the long-term climate objectives. Common organic farming practices can contribute significantly to soil carbon sequestration and higher soil organic carbon stocks compared to conventionally managed soils, and in synergy deliver benefits for healthy soils and biodiversity protection. Increased soil carbon content also contributes to resilience and climate adaptation, through an improved soil structure, increased water retention capacity and decreased risk of soil erosion. IFOAM Organics Europe would like to take the opportunity to highlight points we consider important for the initiative: - Biodiversity safeguards The strong interlinkage between biodiversity and climate objectives requires them to be addressed together. Climate action, such as enhancing natural carbon sinks, should not lead to further threats to biodiversity and ecosystem services. Focusing solely on GHG emissions could lead to incentives counteracting biodiversity and animal welfare objectives and the aim to reduce the use of antimicrobials. Only solutions that also deliver benefits for biodiversity and other environmental objectives should be supported. Therefore explicit safeguards for biodiversity, ecosystem services and animal welfare are needed and a systemic approach, at field, farm and landscape levels, is required to deliver synergistic benefits for biodiversity, adaptation, soils and mitigation. There should be policy coherence between the Commission’s initiatives for reducing GHG emissions from agriculture and increasing carbon sequestration, initiatives aimed a biodiversity protection and ecosystems restoration and the evaluation of the national CAP Strategic Plans. - Soil carbon storage compensating agricultural emissions Climate mitigation should clearly prioritise absolute emissions reductions. Residual agricultural emissions that remain after ambitious reductions, e.g. CH4 or N2O, could be compensated by carbon sequestration in agricultural soils. Compensation should, however, be limited to soil carbon sequestration, landscape elements and agroforestry and exclude pure forestry offset. All sectors have to ambitiously reduce emissions and compensation should not be possible across sectors. Priority should be given to the renaturation of peatlands, the protection of unimproved pastures and expansion of permanent grassland. Common organic farming practices led up until now to significantly higher soil organic carbon stocks and sequestration rates compared to conventionally managed soils, while sustaining 30% more biodiversity. These already existing high carbon stocks have to be recognised and a carbon farming initiative should not favour those who have failed to take action in the past. - Risks of carbon markets Carbon markets should not be a way for other sectors to reduce their net GHG emissions by action in agriculture, but carbon neutrality should be reached within every value chain itself. Instead of carbon markets, which entail issues concerning monitoring and verification, the focus should lie on how new and existing public funds, like the CAP, can be used to best incentivise favourable management practices. Supporting the 2030 target of 25% agricultural land under organic farming will positively impact the carbon stocks in soils. To maximise the environmental and climate potential of organic farming beyond the scope of organic standards, the EU must ensure that Member States prioritise organic farming under agri-environmental-climate schemes targeted at carbon farming and environmental goals. When certifying carbon removals, the high uncertainty of natural sinks, the long-term and non-permanent nature of soil carbon storage, and the levelling off of sequestration rates have to be considered carefully.
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Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

6 Oct 2021 · Exchange of views on organics and CAP Strategic Plans

Response to Organics - Details on records to be kept and declarations to be communicated by operators

1 Oct 2021

Thanks for the opportunity to comment this draft regulation. In relation to Article 1 of the draft regulation and with the intention to have all the certificates centrally issued by TRACES, IFOAM Organics Europe would like to stress that: - we are in favour of a collection of data at EU level, if this is done consistently, interoperability among the different IT systems is guaranteed. A EU central information system where organic certificates are consultable is good as it would simplify and make the checking of certificates more efficient. - We are not in favour of a central issuing of certificates. Certification is a process and the certificate is integrated in the process. That is the main reason why it is not ideal to have two IT systems to manage the certification (Control Bodies’ IT systems and TRACES) - Control bodies have already their own IT systems in place that are working well and invested a lot of resources on those. Those IT systems at the moment are not aligned with the new system proposed by the Commission. To be considered that there are around 270 control bodies and authorities in the EU and around 70 in Third Countries. The certificate is the result of a process that starts with a notification to the designed National Competent Authority and continues with the evaluation and the issuing of the certificates made by designed National Control Authorities or Bodies. Therefore, the certificate is the result of the certification process and shall be issued in the system where the certification process takes place. Additionally, so far, Control Bodies operating in the EU have been in regular exchange and dialogue with their National Competent Authority. This possible new approach would make a direct communication between the Control Bodies and the Commission and skip the National Competent Authorities exclusively for the last part of the certification process (the issuing). We consider it not coherent, not efficient and will make the system much more complex. Finally, the system proposed by the Commission is still in an early stage and it needs a significant number of adaptations before it can be applied. In particular, the uploading and downloading functionalities of data and/or certificates need to be still developed. IFOAM Organics Europe thinks that a much longer period of consultation and exchange between the Commission, the Member States and the Control Bodies is necessary before putting in place such new system. If such process of consultation goes well and the outcomes are satisfactory for all the interested parties, a central IT system for certificates should not be in place before 1 January 2023. After that date, a further period of transition, as well as tests and trainings will be needed. In relation to articles 2 and 3, we consider them superfluous as it is already mentioned in Article 39.1 that operators shall ”keep records to demonstrate their compliance with this Regulation”. In general, it should be avoided the creation of too many documents, it is more important that inspectors focus on checking how things are handled in practice and in the fields, instead of checking (too many) documents.
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Meeting with Giorgos Rossides (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

29 Sept 2021 · VTC Meeting: New Genomic Techniques

Response to Organic food: production and use of non-organic, in-conversion and organic seedlings

15 Sept 2021

IFOAM Organics Europe would like to thank the Commission for drafting this Delegated Regulation regarding seedlings, which was necessary. The prohibition to use of non-organic seedlings in organic systems will ensure that seedling production under organic conditions is maintained. As it is currently, non-organic seedlings are not used in organic production and this is for a good reason, as seedling producers can both use organic seed and derogated non-organic seed (if no organic seed available) to produce seedlings under organic conditions. This system works quite well and seedling producers meet the demand of organic producers. Nevertheless, there is also a problematic aspect to the DA under discussion. With the introduction of the new categories of ‘in-conversion seedlings’ and ‘may be used in organic’, next to ‘organic seedlings’, the situation is becoming overly complex. What this means in practice is that seedling producers that were previously certified organic, would in the future only be able to produce seedlings ‘may be used in organic’, without organic certification of the seedling. This applies if untreated non-organic seed is used as a starting material to produce seedlings under organic conditions. We fear that this will take away the inventive to produce seedlings organically, because the producer has to apply the regulation throughout the process but doesn’t get the reward (in form of the ‘organic’ label) in the end. Further clarification is also needed on who can request an authorization to use non-organic seed for seedlings production. To avoid an administrative overload and costs, it should be possible for both kinds of ‘users’ to do so, meaning either the farmer or the seedling producer. In the context of evaluating this draft Regulation, a much wider set of urgent problems have become clear and these suspicions were solidified when exchanging with currently organic producers about the implications of 2018/848 on their production. In general, the organic sector is very much behind the goal of 100% organic PRM and as much organic as possible from the start. However, there are big differences regarding the status of where we are in relation to this goal. For seed production, we are much further advanced than for other types of crops – this includes fruit trees, other vegetative material (soft fruit, ornamentals) and grapevine. The new rules threaten to put organic producers of these planting materials out of business. It appears that all propagation material (not only planting material) will need to comply with the provisions of organic PRM to be labelled organic. However, in the example of fruit trees and many perennials, the propagation material (grafts) has to be produced non-organically due to mandatory phytosanitary standards. The planting material is then produced organically, using the graft and (organic) rootstocks. Due to these requirements, there is no timeframe by which this could happen organically, at least for fruit trees. For other perennials like soft fruits and ornamentals, there is usually an in-vitro or pot stage involved to produce the planting material, due to phytosanitary reasons. There, it might be feasible that more organic propagation material is produced in the future, but currently only a few producers are in the starting phase to do a part of the process in organic and a lot of research is necessary. In summary, the sector is far away from achieving 100% organic PRM for these crops, which is why incentives to move step by step towards more organic are so important. If there’s no reward for producing the planting material under organic conditions, there is no incentive for producers to do so and further development will come to a halt. To avoid this, we don’t need provisions that are impossible to adhere to but pragmatic solutions to enable and incentivize organic producers to continue their engagement towards more organic throughout the whole process.
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Meeting with Janusz Wojciechowski (Commissioner)

3 Sept 2021 · organics

Response to Animal welfare labelling for food

23 Aug 2021

IFOAM Organics Europe welcomes this opportunity to provide feedback on the Inception impact assessment (roadmap) on the revision of EU legislation on animal welfare. The European organic movement welcomes this initiative and hopes it will contribute to elaborate a future EU legislation improving animal welfare. Organic farming practices are based on the four principles of organic farming (ecology, health, care, and fairness). Therefore, the EU organic regulation – stating “the observance of high standards for health, the environment and animal welfare in the production of organic products is intrinsic to the high quality of those products”- pays close attention to animal well-being and should be regarded as an animal welfare best practice for other types of agriculture (see specific feedback to “five domains”). Therefore, the integrity of animals should be respected as much as possible, and farmers should select species and breeds that do not require mutilations. Exceptions can only be allowed when suffering can be kept to a minimum. Surgical treatments should only be used for reasons of safety, mitigation of suffering and the health and welfare of the livestock. IFOAM Organics Europe supports the creation of an animal welfare labelling system that puts forward adequate and species-specific animal welfare practices, in which the organic standard is clearly identifiable. For instance, a model like the egg label, which was implemented by the European Union in 1999 under the method of production (MOP) labelling option, uses an easy-to-understand and to implement ranking system where 0= organic, 1= free range, 2= barn, 3= cage. This system clearly shows which agricultural practice contributes most and least to the welfare of the animal. The implementation of this label did not put too much extra costs or burdens in the system, it has led to tremendous change in consumer behaviour in some member states, and consumers have the guarantee that organic is controlled and certified. IFOAM Organics Europe believes that this labelling system is a relevant model for other agricultural products. Please find in the attached file our suggestions for the different options.
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Response to Review of the EU school fruit, vegetables and milk scheme - EU aid

22 Jul 2021

Kindly view the attached document for IFOAM Organics Europe's feedback. We remain at your disposal for any question you may have.
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Response to Revision of the plant and forest reproductive material legislation

13 Jul 2021

IFOAM Organics Europe would like to thank DG SANTE for starting the process to assess the options to update the existing legislation with the objective to make the Seed Directives more comprehensive and to align them with goals of the F2F and Biodiversity strategies, including the aim to facilitate the registration of seed varieties for low-input systems like organic farming. As mentioned in the study, coherence with the New Organic Regulation is key and options to modify the seed legislation must not conflict with provisions defined in Regulation (EU) 2018/848.  To improve the conditions for the development of varieties suited for organic, more flexibility and adapted criteria for the registration of organic varieties are crucial and the results from the Temp. Exp. should be streamlined into the Seed Directives on a continuous basis. We should not wait until 2028 to implement adaptions. This is especially relevant since PRM that contributes to species diversity, genetic diversity and on-field genetic diversity helps lowering the environmental impact of agriculture and increase resilience to weather events or pests. In view of rules for variety testing, more flexibility is needed for VCU protocols as they are currently do poorly justice to low(er) input conditions. A VCU adapted to organic input conditions would greatly improve the situation as yield is still given too high importance and the thresholds are currently a limiting factor to bringing new varieties on the market. In addition, costs of variety testing are economically significant and differences within the EU regarding costs create an uneven playing field. Regarding PRM exchange between farmers, it has to be acknowledged that there is a lack of certified seeds available to (organic) farmers in many parts of the EU, which is currently cushioned by member state rules that allow farmer seed exchange. Ad-hoc rules that take account of the national and regional context and that provide the option for seed exchange are therefore essential to avoid gaps in seed supply and to strengthen farmers rights. This highlights also the need to adequately consider social factors in the impact assessment. The Inception Impact Assessments defines the objective of lighter requirements for conservation varieties (for all PRM sectors) and amateur varieties (when appropriate). In this context, its important to consider that in current practice, amateur & conservation varieties are also used by professional (organic) operators, since they are often well-adapted to local and regional conditions. Moving them out of the scope of the professional marketing rules without a readily available registration pathway for these niche varieties would seriously limit the number of varieties available to (organic) farmers. For professional marketing, we should therefore be careful to not exclude options and pathways that are available now (conservation & amateur variety pathway). The use of BMT in the registration process must remain optional. While the application might be useful in some contexts and for some operators, the possibility to conduct the registration process as its currently done (based on phenotype) is essential. Also, BMT must remain optional to not put additional financial burdens on breeders and small operators during the variety registration process. Regarding coherence with the plant health and official controls regulation, a risk-based assessment is needed, considering the scale (size of the seed lot). The IA should take into account that only a risk-based assessment would reduce burden for operators. Overly strict rules should not impede PRM exchange among breeders.
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Response to Conversion to a Farm Sustainability Data Network (FSDN)

2 Jul 2021

IFOAM Organics Europe welcomes the Commission’s initiative to review the FADN Regulation to transform it into a FSDN. Economic data collected at farm-level needs to be completed with data on the environmental and social components of farms, whether for policy monitoring and evaluation or for research. Such a holistic approach will help to understand the economic, social and environmental impacts of agricultural practices, and to identify which of these practices should be supported to achieve the targets set by the Farm to Fork and Biodiversity strategies. This should ultimately contribute to a wide uptake of sustainable practices. The following points are of particular importance to IFOAM Organics Europe: 1. Data on organic production Organic agriculture should be fully taken into account when composing the farm samples for the future FSDN, in order to have a sufficient number of farms to obtain statistically significant results on organic production. Currently, the organic production is only one component of the surveys carried out in the FADN farm samples, which means that farmers are only asked to indicate whether they apply organic production methods or not. This may lead to an insufficient number of organic farms in the final sample, making a reliable statistical analysis of organic farming data impossible. With the EU target of 25% of agricultural area under organic farming by 2030, organic agriculture will become increasingly important and it is therefore necessary to have sufficient data to analyse the environmental, social and economic performances of organic farms in the EU. 2. A comprehensive set of environmental and social variables As mentioned by the roadmap, the conversion of FADN to a FSDN will consider adding key variables on the environmental and social dimensions of farming. The environmental variables should cover at least the following domains: climate change (GHG emissions, carbon sequestration), soil quality (erosion, compaction, organic matter), water quality (N and P surplus, pesticide contamination, scarcity index), air quality (ammonia), energy (usage and production), biodiversity (landscape, genetic diversity on farm (seeds, animals), pollinators, birds). The social variables should cover at least the following domains: quality of life (stress, physical condition, health), working conditions, information and knowledge (access to advisory services, trainings). Some data is already or will soon be available (due to EU rules on data collection), others will require an extra effort to collect. But this effort is advisable to provide the EU with a solid database on farm performances. 3. Data on farming practices In addition to environmental and social variables, it would be relevant to collect data on agricultural practices at farm level in order to identify correlations between agricultural practices and social/environmental performances. This is necessary to provide a solid evidence base for farmers, farm advisors and policymakers to identify and implement sustainable farming practices. This is especially important in organic agriculture, where farmers implement a large range of indirect preventing measures that increase biodiversity on the farm and allow for an effective plant and animal health strategy while using no or minimal external inputs. With this respect, it is important to collect all the data on the same farm, as the idea is to understand the ecosystem of the farm and how farming practices influence environmental, economic and social indicators. Data on farming practices should cover at least: land management (permanent grassland, ecological focus area, semi-natural farmland areas, land fragmentation, crop rotation, crop diversification), plant protection (use of PPP, adoption of biocontrol, seed genetic diversity, indirect protection measures), plant nutrition (nutrient balance, use of legumes, use of recycled fertilisers, irrigation practices), animal health and welfare.
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Response to Organic food: certificate for operators located in third countries and list of control authorities

9 Jun 2021

IFOAM Organics Europe welcomes the possibility to express its opinion on this draft act. Firstly, we would like to stress that, for consistency reasons, the model of certificate for operators in Third Countries should be identical to the one for operators in the EU. Therefore, the directory of products (point 7, part I in the Annex) should be moved to the optional part of the certificate. Further, we would like to comment the following points: - Article 1 (a): double work should be avoided. With the system proposed in the draft act, control bodies should issue the certificates twice, in their own system and in TRACES. Instead, there should be the possibility to directly export the certificates in TRACES: the certificate would be issued in the Control Body’s system and then transferred in TRACES. - Point 10, part I in the Annex: The list of the names and the addresses of all the members of a group of operators is not necessary and not feasible as it does not reflect a clear identification of the small-scale farmers. In some context in Third Countries, many members might have the same name and surname and might not have an official address. It would be better to use the wording “identification of the members”. A certificate which includes 2000 members can require dozens of pages, and also needs to be updated every time a member goes out or a new one enters. The important requirement is that the Internal Control System of the group and the Control Body/Authority have such list updated in their systems. - Point 6, part II in the Annex: The part referring to subcontractors is not yet clear enough. The indication should refer to the activities for which the certified operator offers a subcontracting service (for example a processing activity). It is not possible to make public the list of subcontractors that the operator uses, because it is a confidential information not supposed to go to the public and to the competitors. - Points 2, 3, 4, 5, Part I in the Annex: it is not clear why “exporter” is explicitly mentioned, as “exporter” is already included in category “operator”.
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Response to Organic production - Requirements for keeping records

11 May 2021

IFOAM Organics Europe asks the Commission and the Member States to pay particular attention on this draft regulation which can have a potential huge impact on the level of paperwork for organic operators. The aim should be to keep or - even better - reduce the level of records keeping of the current regulation so that conversion to organic farming is not hampered by bureaucratical burden. One of main driver of the revision of the current organic regulation (EC) No 834/2007 was the need for simplification and for a decrease of bureaucracy and paperwork for operators, control bodies & authorities and Member States. In the draft regulation on record keeping, IFOAM Organics Europe still sees - on the contrary - an increase of bureaucracy and paperwork, in particular for small farmers and operators. We should try to keep the level of administration as low as possible and avoid further information which are not necessary or that are easily deductible from the information already requested. There are still duplications, not only with horizontal legislations, but also repetitions of documentation requirements within the individual chapters (the same requirements in the general and special rules). Indefinite general requirements such as "records of any other external input" or "documentary evidence on any derogation", which could duplicate the already existing documentation requirements should be deleted: Point (1) (d) on Annex II Part I, Point (2) (a) on Annex II Part II and Point (3) (a) on Annex II Part III. Please find in the attached document other points where we consider excessive and unnecessary burden is requested and our recommendations in Track Changes and comments.
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Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

11 May 2021 · To discuss the ‘New Genomic Techniques’ (new-GMOs)

Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and Greenpeace European Unit and

11 May 2021 · VTC Meeting - New Genomic Techniques and Gene drives

Response to Agriculture - List of products and substances authorised in organic production

22 Apr 2021

IFOAM Organics Europe acknowledges the improvements in this final version of the annexes. Please find our detailed input attached. In particular we welcome that Quassia is on Annex I. The continuous availability of Quassia amara is of great importance for organic fruit and hop growing. On the other side, we still have some concerns on the following points, details can be found on the attached document: On Annex I: It is crucial that ethylene stays available as it is today for both EU and non-EU producers of organic lemons and organic pineapples. Lemons are not subject to attacks from the fruitfly and in the EU ethylene is used instead for the degreening of lemons. Ethylene is also used for floral induction of organic pineapple production. There are many ongoing projects for organic pineapples in Africa and Latin America which risk to be stopped. If ethylene would not stay available in the Annexes, then its use will be only allowed in Costa Rica, making it unfair to other producing countries. As an established list for products and substances to be used in Third Countries seems unlikely from the 1 January 2022. Therefore, IFOAM OE asks to keep the status quo and to avoid adding additional conditions in the organic regulation to the ones of the horizontal regulation for the use of ethylene. On Annex II: The introduction of Annex II is still unclear regarding the possibility to use fertilisers that are nationally authorised (and not CE-marked) and the current wording leaves too much room for interpretation. The introduction must clearly state that fertilisers listed in Annex II can be used (as single products or as a mixture) in organic farming if they are authorised by national legislation or as CE-marked fertiliser products, complying in this case with the EU legislation - Regulations (EC) No 2003/2003 and (EU) 2019/1009. Therefore, the first bullet point of the introduction should be modified as follow: “the relevant Union OR national legislations on fertilising products, in particular, where applicable, Regulations (EC) No 2003/2003 and (EU) 2019/1009” On Cleaning and Disinfection Products In Article 13 of the draft Implementing Regulation it is stipulated that Article 5(1), (2) and (3) and Article 7 shall apply from 1 January 2024. The proposed transitional period to establish completely new lists for cleaning and disinfection products in processing and storage facilities and in plant production seems ambitious and not realistic, even more for the processing sector, where there have been no national or EU regulations to date. We ask to consider extending the deadline for a new regulation on cleaning and disinfection in processing and storage facilities until the end of 2025. In addition, two corrections are necessary in Annex IV, Part D, details in the attached document.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

19 Mar 2021 · Organic farming Action Plan

Response to Information and promotion measures for agricultural and food products in the internal market and in non-EU countries

9 Mar 2021

Kindly see the attached document for IFOAM Organics Europe's feedback to this roadmap.
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Response to Setting of nutrient profiles

3 Feb 2021

Thank you for the opportunity to provide feedback; please see attached file.
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Meeting with Frans Timmermans (Executive Vice-President)

27 Jan 2021 · Ramping up organic agriculture in the EU

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides) and European Environmental Bureau and

20 Jan 2021 · VC Meeting - Discussion on minimum sustainability criteria for public procurement.

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and

20 Jan 2021 · Discussion on minimum sustainability criteria for public procurement

Meeting with Stella Kyriakides (Commissioner) and Greenpeace European Unit and

15 Jan 2021 · VC Meeting - Farm to Fork Strategy and GMOs

Meeting with Janusz Wojciechowski (Commissioner)

7 Jan 2021 · To discuss the Action plan on Organic farming.

Response to New EU Soil Strategy - healthy soil for a healthy life

8 Dec 2020

IFOAM Organics Europe, the European umbrella organisation for organic food and farming, has positively received the initiative by the European Commission to develop a new overarching framework on Soil. As rightfully stated in the roadmap, healthy soils are indeed essential for the provision of food and other vital ecosystem services, such as water purification and biodiversity, but furthermore will be crucial to achieve the ambitious goals set out recently in the European Green Deal and its accompanying strategies. In line with the holistic approach of these initiatives, systemic solutions and coherent policies are needed to counteract the ongoing land degradation. As highlighted in the European Court of Auditors’ special report on combating desertification in the EU (2018), there is currently a range of strategies, action plans and spending programmes, like the Common Agricultural Policy (CAP), that are relevant to combating desertification while none of them specifically focuses on it. This, however, is not the case for equally important environmental resources, such as air or water, that are governed under various EU directives and regulations. A similar integrated EU legislation on soil, that also covers threats that are not addressed in existing EU legislation, such as salinisation, will be required to achieve land degradation neutrality by 2030. A strategy will not be sufficient, and should be complemented with legally binding acts that provide the Commission with a legal basis to ensure that in particular CAP Strategic Plans contribute to improving the situation. Hence, to ensure an improved new Soil Strategy, the current one first must be thoroughly evaluated, and shortcomings must be identified. Likewise, a full assessment of land degradation at EU level needs to be done. For this, as well as for the consistent monitoring that should complement the new strategy, an appropriate methodology and relevant indicators must be established to be able to yield and analyse relevant data on desertification and land degradation. This, and a detailed vision on how to achieve land degradation neutrality will be imperative to the effectiveness of the strategy. For the farming sector, this means to a great extent which practices are being incentivised by the CAP. As mentioned in the EU Biodiversity Strategy, certain agricultural practices are a key driver for deteriorating soil fertility, increasing erosion and loss of biodiversity, as well as decreasing levels of soil organic matter. However, it is not clear how the next CAP will significantly address the underlying drivers of these processes. Yet, the Biodiversity Strategy clearly mentions that poor land management, such as deforestation, overgrazing and other unsustainable farming practices, must be substituted with sustainable systems, such as organic farming, low-intensive permanent grassland, and stricter animal welfare standards. Organic farming in particular holds great potential for farmers and consumers to provide healthy food while maintaining productivity, increasing soil fertility and biodiversity, and reducing the footprint of food production. It does so by laying the focus on healthy soils and applying agroecological practices, such as cover crops, crop rotations, and on-farm nutrient cycling. Practices like these must be actively promoted by the CAP through various ways: First of all, beneficial practices must be clearly communicated to Member States as examples of best practices and fully integrated into national CAP Strategic Plans. Secondly, farmers must be appropriately incentivised to apply these practices, and the CAP should allow payments at levels beyond those calculated with the concept of income-foregone. Systemic approaches like organic farming, which entail an agroecosystem re-design of the whole farm, should get higher level of payments than less ambitious single practices. Finally, National Strategic Plans should contribute to the targets...
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Meeting with Janusz Wojciechowski (Commissioner) and

3 Dec 2020 · To discuss the future of EU Agriculture and the role that organic movement can have.

Response to Rules governing the production and marketing of plant reproductive material of organic heterogeneous material

27 Nov 2020

---The absence of at least six generations to several decades of on-farm practices (Art. 4, (2)(b) is problematic and threatens the integrity of OHM.--- The New EU Organic Regulation (EU) 2018/848 represents a great opportunity to diversify the types of seeds that can be marketed and that farmers can use on their fields. The recognition of organic heterogeneous material (OHM) had therefore been greatly welcomed as it increases the availability of plant genetic resources for organic farming. However, we are concerned that the draft Delegated Regulation, which is now in public consultation, represents a step backwards. In its current state, the Draft Delegated Regulation lacks an adequate definition of what exactly constitutes the ‘organic’ in OHM. Clearly, introducing a new category of plant reproductive material and giving it the qualitative adjective ‘organic’ must be followed by some intention. OHM should be developed for at least 6 generations (or 3 years for annual crops and 5 years for biennial/perennial crops) of on-farm management practices under certified organic conditions prior to its marketing. This would ensure the integrity and the traceability of the development process. Regulation (EU) 2018/848 defines the organic production process and specifies a certain number of years in which these production rules need to have been abided by, controlled and certified before a product can be marketed as organic. It would be coherent to do the same for OHM. However, in the current wording of the Draft Delegated Regulation, the possibility seems to remain open that only the final reproductive cycle of OHM would have to be under organic conditions. Without reference to at least 6 generations under organic conditions, OHM that is not suitable for organic production systems could be placed on the market. The promise that OHM would be better adapted to organic farming systems and have a better capacity to adjust to climate change seems to be threatened. We would therefore like to ask you to make use of the last opportunity to reconsider the deletion of this minimum quality requirement. According to our assessment, the Commission does have the competence to propose the mentioned minimum requirements for organic heterogeneous material and to ensure a coherent implementation across all member states. Article 13(3) of Regulation (EU) 2018/848 unmistakably states that this delegated act is intended for “…setting out rules governing the production and marketing of plant reproductive material of organic heterogeneous material of particular genera or species, as regards: (a) the description of the organic heterogeneous material, including the relevant breeding and production methods and parental material used”. ---The absence of the reference to the organic principles (Art. 4, (2)(b)) is problematic.--- The deletion of the reference to the organic principles from Art. 4(2)(b) is an issue. In line with the definition of organic breeding (in point 1.8.4 of Annex II Part I of Regulation (EU) 2018/848), it should be specified that ‘any other technique’ used for breeding or production of OHM should follow the organic principles. ---Clarification of Field inspection requirements for identity and purity (Art. 6, (12); Art. 9) necessary.--- Notification should be with low administrative and financial burden for the operators. Certification of requirements for identity and purity should be possible via internal control systems as well.
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Response to Revision of the EU geographical indications(GI) systems in agricultural products and foodstuffs, wines and spirit drinks

25 Nov 2020

IFOAM Organics Europe welcomes the Commission’s initiative to revise the EU geographical indications, especially as it considers citizens’ sustainability concerns and ways to incorporate more sustainability within the GI scheme. IFOAM Organics Europe also welcomes the Commission’s efforts to increase sustainability in all aspects and encouraging producers to do so. However, IFOAM Organics Europe disagrees with the expressed opinion of the Commissions’ inception impact assessment that “GIs are under-exploited for the purpose of promoting sustainability characteristics” and more specifically that there is an intrinsic link between GIs and environmental sustainability and animal welfare as stated in the inception impact assessment. GIs should contribute to fulfilling the goals of the new European Green Deal and the Farm to Fork strategy by pushing GI label users to move to more sustainable farming and manufacturing practices such as organic. This would lead to a strengthened connection of valorising local products, while at the same time contributing to holistically sustainable production. IFOAM Organics Europe is not in favour of using GIs as an indicator to promote sustainability, because as they are currently, GI labels have no link to more environmentally sustainable practices or higher animal welfare standards. Indeed no GI, except for the category of protected designation of origin (PDO), makes any reference to the origin of the raw materials used to manufacture a certain product. In this light it is questionable to what extent GI “products [are] intrinsically linked to the natural factors”, as per the inception impact assessment of the Commission. Further, it must be noted that GIs do not follow any specific regulation that would ensure environmental sustainability or greater animal welfare than any other product on the market. Thus, contrary to the statement above, GIs are not “under-exploiting” their promotion of sustainability. But GIs should indeed provide more clarity about the specific practices they include, in order to decrease consumer confusion. If claims about implications of GI products are to be made, specific rules and regulations need to be in place and enforced to ensure that such claims do not mislead consumers. Otherwise, consumers need to be alert to the fact that GI labels are mainly labelling the place of manufacturing of a good and do not make any reference to the production of the raw material in terms of origin or quality. Thus, it would be paramount to substantiate any claims about better environmental practices or animal welfare in relation to GI products. IFOAM Organics Europe supports the expressed need to better communicate to the consumer what GIs stand for precisely. As pointed out on the Commission’s website, only the PDO has a link between both the origin of raw material and manufacturing. It must be highlighted though, that also these products can only claim “shorter value chains” in terms of sustainability, as the origin is otherwise not necessarily linked to more sustainable practices. Thus, a substantiated claim about sustainable production for any GI product can only be made if these are also enforced by further standards such as the organic label.
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Response to Production rules concerning feed and veterinary parasite treatments in aquaculture and sprouted seeds

17 Nov 2020

The EU Federation of Organic Farming & Production IFOAM Organics Europe would like to provide the Commission with the following comments on the proposed amendments to point (1)(3)(a) on sprouts of Part I Annex II of Regulation (EU) 2018/848 : - The newly inserted reference to components authorised in compliance with Article 24 contradicts the restriction to an inert medium. The only relevant category of authorised substances according to Article 24 could be the list of fertilizers, soil conditioners and nutrients, but these materials are not inert as they provide nutrients to the plant. Therefore, the reference to Article 24 shall be deleted, unless a specific annex for allowed inert materials is planned. - All sprouts (seed and vegetative propagating material including bulbs) should be allowed. It is crucial to include also bulbs - such as tulips - which are also cultivated in an inert medium and only use the reserves in the bulbs. Organic ornamental sector is growing and should be allowed to do so. The production of tulips is very similar to the production of chicory or other bulbs, which also need to be covered by these rules. - Cress should be deleted because cress seedlings are sprouted seeds or cress should be mentioned only as an example. Otherwise, other sprouted seeds such as rape, beetroot, beans etc. would be excluded.
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Response to Action plan for the development of EU organic production

20 Oct 2020

Please see the attached document.
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Response to Labelling of organic products and certain feed and mixtures of fodder seeds that may be used in organic production

27 Aug 2020

- Seed mixtures are widely used today and are becoming ever more important to deliver a variety of benefits such as soil fertility, nitrogen fixation and functional biodiversity (through flower strips etc.), not only as fodder crops. - The explicit specification of fodder plants does not do justice to the growing and increasingly diversified use of seed mixtures, which includes mixtures for intermediate and subsidiary crops and flowering strips. Therefore, the scope of the Delegated Act should make explicit reference to non-fodder plant mixtures, in line with Article 13 of Directive 66/401/EEC. - A minimum percentage of 70% by weight of organic and in-conversion seeds in seed mixtures has the potential to stimulate the production and use of organic and in-conversion seed across all Member States. However, it needs to be clear what a harmonized threshold of 70% (Point 2.1.3. of Annex II) means in practice. If the threshold is met, it should be possible for the producer of the mixture or a national seller (of a seed mixture produced in another Member State) to apply for an authorization (for the non-organic components of the mixture) at the national authority directly. If farmers must apply for authorizations for single components of seed mixtures individually, then this administrative burden would likely decrease the use as well as complexity and performance of the mixtures. - A listing of organic, in-conversion and non-organic components on the label should be possible independently of the total percentage of organic and in-conversion seeds, as suggested in Point 2.1.3. of Annex II. This is important because certain seed mixtures that are used in organic farming don’t reach the 70% threshold due to (currently) limited availability of organic seed for specific crops, for example in the case of seeds for flower strips. For these mixtures as well, a listing of the organic and in-conversion species on the label facilitates the process to request an authorization for non-organic components for farmers and competent authorities. In addition, this listing stimulates producers of seed mixtures to include organic & in-conversion components in the mixtures as much as possible. - The reference in the draft delegated act to the required conformity with the authorisation issued under point 1.8.5 of Part I of Annex II to Regulation (EU) 2018/248 is essential to guarantee consistency with national authorization procedures.
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Response to Control rules in organic production

20 Aug 2020

IFOAM Organics Europe, after exchanges and discussions with its organic experts in different EU Member States, would like to contribute to the public consultation with the attached file.
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Response to Control rules in organic production

20 Aug 2020

IFOAM Organics Europe, after exchanges and discussions with its organic experts in different EU Member States, would like to contribute to the public consultation with the attached file.
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Response to Environmental claims based on environmental footprint methods

20 Aug 2020

IFOAM Organics Europe (IFOAM OE) welcomes the Commission's initiative on the "Environmental performance of products & businesses – substantiating claims", as it aims to increase trustworthiness of environmental claims. Similarly, IFOAM OE welcomes that the Farm to Fork strategy stipulates that “the Commission will (…) examine ways to harmonise voluntary green claims”. While we welcome that the European Commission is working towards increasing visibility of environmental impacts of production and consumption, we would like to raise some concerns. IFOAM OE is not in favour of any of the options proposed in the roadmap, even if on a voluntary basis, as they seem to only take into account the PEF to substantiate environmental claims. Existing labels such as the organic label and the EU ecolabel should be considered and the potential coexistence of claims with these labels should not be a source of confusion for consumers. Introducing claims in a way that does not take into account the benefits of organic agriculture would greatly undermine the good work that the Commission has done to protect the term “organic” and the products it covers. Organic agriculture has positive impacts on the environment and society at large, by e.g. protecting and managing biodiversity, increasing soil fertility, cleaner air and water, and by resulting in the creation of more jobs. For products to be labelled organically they have to respect several provisions. The roadmap presented by the Commission includes an impact assessment which will “analyse the interactions [of the PEF and OEF] with existing labels regulated at EU level”, but seems to otherwise focus entirely on the PEF and OEF methods, without considering a substantiation of claims based on existing labels such as the organic label. Relying exclusively on the PEF and OEF methods for the substantiation of claims would not be a desirable outcome. Attached to this feedback you will find a 2018 letter sent to Mr. Schally (then HoU of DG ENV B1) which highlights some of our concerns regarding the PEF. The main reason for concern in this context is that most life cycle assessment (LCA) methods do not put forward the benefits of organic agriculture because (1) they are often based on yields (which are slightly lower for organic in the short-term), (2) they do not take into account elements such as the impact on biodiversity, or the impact of using of synthetic fertilisers, and (3) LCAs are based on non-existent or average approximated data, which is hard to come by and potentially misleading for conventional products and even more so for organic products. In addition, there is a risk that claims will create confusion regarding organic products. Consumers might not be able to pick the more sustainable product between a product that makes a green claim on e.g. preserving biodiversity and an organic product that does not make any claims, but that inherently has a positive impact on biodiversity. In short, a truthful and comprehensive LCA is difficult to implement, and it is even harder to explain to consumers what exactly it entails.
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

5 Jun 2020 · Organic agriculture

Meeting with Stella Kyriakides (Commissioner) and European Environmental Bureau and

5 Jun 2020 · VC Meeting - Farm to Fork

Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski), Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

5 Jun 2020 · New organic regulation and upcoming European Action Plan

Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

3 Jun 2020 · Exchange of views on Farm to Fork strategy, CAP, EU recovery plan, EU organic action plan and new organic regulation

Response to Organic food - use of in-conversion and non organic plant reproductive material

13 May 2020

The organic movements have committed to the goal of 100% organic seed. However, if organic seed is not available or not available in sufficient quantity, clear rules are essential to enable farmers to use non-organic untreated plant reproductive material (PRM). In this context, IFOAM EU welcomes the inclusion of point 1.8.5.6, which establishes that competent authorities of the member-states shall create a ‘positive’ list of species, subspecies or groups of varieties for which it is established that organic or in-conversion material is available. While the DA and its annex put organic and in-conversion PRM by and large on the same level, point 1.8.5.1 suggests that organic seed is still prioritized above in-conversion seed. This is pertinent, as preferably organic PRM should be used. However, this raises some practical questions about how the (delegated) competent authorities (often certifiers) should handle this. It should be clear that no authorisation is required to use in-conversion PRM. In addition, IFOAM EU wants to make you aware that there is apparently still some unclarity among seed producers regarding the marketability of in-conversion PRM and there are reports from seed companies avoiding the production of PRM on in-conversion fields since it is perceived as difficult to market. It is therefore crucial that the situation arising from the New Organic Regulation is clarified to seed producers. Regarding the terminology used, varieties should be replaced by ‘groups of varieties’ in the delegated act and the annex. This concerns: DA point (6) as well as points 1.8.5.6 & 1.8.5.7 of the DA annex. This is important since we cannot have a list of non-derogation for a specific variety but only for subspecies or groups of varieties. In general, it is crucial to emphasize that while the purpose of the database (referred to in Art. 26(1) or Art. 26 (2)(a)) is to list varieties, the needs for a ‘non-authorization’ list (point 1.8.5.6) or a ‘general authorization’ list (point 1.8.5.7) are different in that they should list species, subspecies or groups of varieties and NOT single varieties. Following from this, also point 1.8.5.7 (b) should be changed, as there should be no general authorizations for single varieties. In point 1.8.5.1 (d), reference to the quality can only be relevant for vegetative PRM, as the quality of seeds is strictly defined by the horizontal legislation. In point 1.8.5.3, a transition period exclusively for vines would be helpful to find adequate solutions that are compatible with organic products. This relates to the current practice in some Member States of vine plants being treated before they are stored over winter and which would require changes in procedure from non-organic producers of grape. Simply cutting the treatment might result in substantial loss of newly planted vines for organic farmers in some Member States.
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Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski), Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

3 Apr 2020 · Organic Regulation and Farm to Fork Strategy

Response to Farm to Fork Strategy

13 Mar 2020

IFOAM EU, representing the organic food and farming movement, welcomes the Farm to Fork strategy. It should build on the success of organic farming and its potential to transform agriculture to provide EU citizens with a credible and engaging vision for a EU sustainable food production system by 2030. Organic farming is well known by citizens all over the EU, it is a legally-defined and certified sustainable production system with proven benefits for the environment and animal welfare, and a well-established and profitable business model for farmers, processors and retailers. A strong dynamic around organic farming should be part of a broader transition of the whole agriculture sector, half of which should be managed according to principles and practices of agroecology by 2030. As part of this ambition to transition agriculture towards agroecology, the F2F strategy should include quantitative targets to increase both organic land and consumption of organic products in the EU, and to reduce the use of pesticides and antibiotics. IFOAM EU calls for: - a EU target for 20% organic land by 2030. To make this target achievable, it is crucial to link it to the CAP e.g. through an article in the CAP Strategic Plans Regulation requiring Member States to set up their own national target for organic land and to provide the adequate support for organic conversion and maintenance. Overall 70% of the CAP budget across the two pillars should be earmarked for environment and climate action to allow full use of agri-environmental measures under rural development and of innovative mechanisms like eco-schemes. The CAP should move away from direct payments to remunerate farmers for the public goods they provide. Further measures should be taken to improve the impact of agriculture on biodiversity. - an EU target of 20% of organic products in public kitchens by 2030. The example of Denmark has proven that policy has a key role to play to ensure a balanced growth of both organic production and demand and to develop the whole organic supply chain through a push-pull approach,using Green Public Procurement (GPP) and promotion policies, and giving a prominent role to local authorities in the F2F strategy. Barriers in EU competition law should be identified and eliminated so that GPP could also contribute to develop community-supported agriculture, short supply chains, and increased use of fair trade products. Organic farming also contributes to the re-vitalisation of rural areas, as organic farms sustain on average 59% more jobs than conventional farms (according to French Agence Bio), and to the development of a strong network of SMEs. IFOAM EU also suggests to recommend MS taxation measures (VAT) to make organic products more affordable. To leverage the potential of organic and agroecology, systemic, transdisciplinary research & innovation as well as effective advisory services are needed. Research must be conducted into organic approaches to plant health and animal production. It is essential to establish well-funded farm advisory services independent from economic interests (e.g. companies selling inputs) and aimed at helping farmers to transition to agroecological production systems, which are knowledge intensive rather than input intensive. Agriculture Knowledge and Innovation Systems (AKIS) for organic farming must be strengthened and better connected across Member States. To accelerate the uptake of best practices and research results, social, organisational, knowledge and governance innovations must be promoted alongside technological ones. Technologies must be open source and socio-economically sustainable for farmers. IFOAM EU is part of the EU food policy coalition and supports shifts to more sustainable diets, less intensive animal production, and innovative governance models for the F2F strategy, which should give a prominent role to civil society at all levels, and to local authorities.
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Meeting with Virginijus Sinkevičius (Commissioner) and

4 Mar 2020 · Organic farming in the view of Biodiversity and Farm to Fork strategies

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

4 Mar 2020 · Organic agriculture and Green Deal

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and

20 Feb 2020 · Sustainable food systems

Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski), Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski)

7 Feb 2020 · CAP, Green Deal, Farm to Fork

Response to EU 2030 Biodiversity Strategy

20 Jan 2020

In order to meet farmers and citizens' expectations, the Farm to Fork strategy and the biodiversity strategy must develop a coherent transformative vision for our food system, adopt clear and ambitious targets and actions and create a robust monitoring and evaluation framework that includes corrective measures when targets are missed. A dynamic target for organic farmland and consumption of organic products would be big step to halt biodiversity loss caused by agriculture. Organic farming is a set of methods of food production that combine optimal environmental practices, a high level of agro-biodiversity and the preservation of natural resources. The respect for the environment is an intrinsic part of organic farming and farms have between 46 and 72 % more semi-natural habitats and host 30 more species and 50 more individuals than non-organic farms. Organic breeders aim for broader genetic diversity as it is essential for the adaptability of plants to local conditions and changes in weather patterns, and the basis for natural disease and pest resistance. The strategy should also ensure that new genetic engineering techniques remain regulated under the European legal framework on GMOs (Directive 2001/18/EC). To ensure a successful implementation and adaptation of the Biodiversity strategy, it is crucial that it includes targets and measures that Member States will have to enforce through their national CAP strategic plans. The new delivery model of the Common Agricultural Policy (CAP) will only deliver for the environment if the increased flexibility for Member States is balanced with safeguards, including a more ambitious ringfencing: IFOAM EU encourages to set a 70% ringfencing over the two pillars for the climate and environment. . A minimum percentage of green agro-ecological infrastructures should be applied in all Member States. Given the drastic decline of insects (including pollinators), an ambitious target for pesticides reduction is also needed. The strategy should also include the further development of indicators subsequently the definition of quantitative use and risk reduction targets of chemical-synthetic pesticides and fertilisers as one of the main sources of environmental pollution. Setting-up a system of taxes/levies and other incentives to shift from chemical-synthetic inputs towards preventive and indirect pest control and natural occurring substances, needs to be prioritised. Currently the SUD 128/2009/EC remains a key instrument to reduce the risks and impacts of pesticide use on people's health and the environment and the Biodiversity strategy offers a good opportunity to develop it further. IFOAM EU strongly believes that agricultural activity and biodiversity conservation can and need to go together. Rather than a division between areas with intensive agricultural activity and areas of nature conservation, biodiversity should be safeguard and restored everywhere and develop diverse agricultural landscapes and good soil quality. We need a legal framework to address land degradation. The new strategy needs to oblige member states to protect their soils as healthy soils are the basis for sustainable food production, and can contribute to soil carbon sequestration. Safeguarding biodiversity needs to go hand in hand with measures halting climate change in order to cope with the complex problems we are currently facing
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Response to Organics production rules

3 Dec 2019

Good evening, Please find attached the input from IFOAM EU (International Federation of Agriculture Organic Movements - EU Office) Thanks in advance for consideration.
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Meeting with Anne Bucher (Director-General Health and Food Safety)

27 Nov 2019 · - Implementation of the ECJ ruling, with an emphasis on the development of detection methods and strategies; - Work with EFSA on EU risk assessment methodologies for SDN1 and 2; - Work with the European Group on Ethics in Science and New Technologies.

Response to Rules for organic production (supplementing rules)

8 Oct 2019

The International Federation of Organic Agriculture Movement - EU Office (IFOAM EU) would like to recommend the following points: - First of all, it is crucial that the organic status of products is never affected when the products are produced under officially acknowledged catastrophic circumstances. - On Recital (7): the proposed regulation does not cover the situation when - due to animal diseases as African Swine Fewer - the availability of young organic animals is affected by biosafety rules. Those circumstances should be also mentioned. - On Recitals (9) and (10): the proposed regulation does not cover the situation when permanent grassland is temporary flooded for many weeks in such a way that the area is not covered by water, but soaked, and the animals cannot access the area and the grass can not be mown with the use of tractors and relevant machines. Those circumstances should be also mentioned. - On Recitals (9) and (10): the proposed regulation does not cover the situation when the area has slid after heavy rainfall and the farmer practically loosed his/her field or a part of the field. Those circumstances should be also mentioned. - On Article 2: the situations indicated for Recitals (9) and (10) should be taken into account in Article 2 in relation to minimum access to outdoor areas. In case of biosafety rules implemented in ASF zones, the access to outdoor area is very limited or impossible. The same applies for poultry during the periods of high risk of Avian Flue. Those circumstances should be also mentioned. - Finally, in order to correct an inconsistency in the Basic Text regarding the derogation for use of in conversion Plant Reproductive Material, it would be necessary to amend Article 3 of this proposed Commission Delegated Regulation as follows: 1. By way of derogation from point 1.8.1. of Part I of Annex II to Regulation (EU) 2018/848, for the production of plants and plant products other than plant reproductive material, non-organic plant reproductive material may be used when the use of organic or in-conversion plant reproductive material is not possible, provided that point 1.8.5.3. of Part I of that Annex are complied with.
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Response to Amendment of products and substances allowed in organic production

16 Aug 2019

IFOAM EU (International Federation of Organic Agriculture Movements - EU Regional Body) would like to give some input on Annex II - Plant Protection Products: - For clarity reasons and considering their growing number, the list of basic substances should be in a separated sub-chapter within Annex II, as proposed by in point 3.9 of EGTOP report on Plant Protection IV - For sodium chloride the following restrictions should be included: ‘only sea and rock salt’. Subsequently, for reasons of consistency, sodium chloride in Annex I should also be changed to ‘only sea and rock salt’. This is also proposed in point 3.4 of EGTOP report on Plant Protection IV - For Deltamethrin and Lambda-cyhalothrin, which can only be used in traps and only against Bactrocera oleae and Ceratis capitate Wied, alternatives exist and should be explored as much as possible as also the need in the different Member States should be properly evaluated . In any case, it is important to keep the medium-long term objective of phasing out these two substances. To be considered also the horizontal legislation. This recommendation is in line with point 3.7.3 of EGTOP report on Plant Protection IV.
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Response to Detailed production rules for certain organic products

8 Aug 2019

IFOAM EU (International Federation of Organic Agriculture Movements - EU Regional Group) would like to propose an addition to point (b) of point 1.9.6.2 of Annex II Part II : "Feeding of bees should be possible with the aim of multiplying the colony. In this case, honey shall not be harvested during that period" This would favor the breeding of organic bees and would lower the use of derogation referred to in point 1.3.4.2 of Annex II Part II.
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Response to Enhancing Market transparency in the agri-food chain

19 Jun 2019

IFOAM EU would like to thank the European Commission for the work it is carrying out in view of improving fairness in the food supply chain and more specifically for the legislative proposal on market transparency. IFOAM EU particularly welcomes that this legislative proposal makes a clear distinction between organic and conventional production systems. The separate price and data collection for organic production and organic products in annexes II and III will indeed be paramount in improving the collection and presentation of specific data on organic. While we welcome this proposal, we’d like to hereby provide some elements in order to improve it: • Buying prices should be collected for all commodities, just as it is stipulated in the implementing regulation that selling prices should be collected for all products listed. For some of the products in annex I and annex II it is stipulated that only selling prices are to be collected while for other products both selling and buying prices will be collected. The rationale for making this distinction is unclear. In annex II specifically, focused on organic products, buying prices are not mentioned at all. However, processor and retailer buying prices are important in order to have a better picture of the (organic) supply chain and it would therefore be important to also collect buying prices for all products. • It should be possible to extrapolate margins from the price data collected. The proposed implementing regulation aims to collect data related to producers’ selling prices, processors’ buying prices, processors’ selling prices, and retailers’ buying prices. Although not for all commodities, we understand that it should be possible to extrapolate margins from the data that will be collected. Linked to the bullet point above, it is important that buying prices are asked for all commodities listed in addition to only selling prices. Without knowing the buying prices, extrapolating margins will not be possible for e.g. organic commodities. In any case, IFOAM EU believes that margins should be readily available to the public and should therefore appear as a separate entry among the collected data. • Market transparency goes beyond collecting price data and some quantities, cost-related data is important. IFOAM EU agrees with the Agricultural Market Task Force (AMTF) report “improving market outcomes” with the following points: (1) market transparency is currently not sufficient along the supply chain and (2) market transparency is composed of many dimensions in addition to prices, which include weather, production, trade, consumption and stocks. IFOAM EU understands the complexity of collecting data related to e.g. production costs but would like to underline the importance of collecting this additional data in order to have a more transparent supply chain. While we understand that collecting data related to production costs may currently be difficult to implement, we would like to suggest to include this issue in the larger debate of the true cost of food and the need for a framework on true cost accounting. Indeed, differences in production methods can have vastly diverging impacts but are currently not reflected in the price. For example, IFOAM EU recently commissioned the study “taxation as a tool towards true cost accounting” (attached) which revealed that the cost of pesticide use on ground water pollution alone was 1298 €/ha for conventional potatoes, while it decreased to 0.4 €/ha in the case of organic potatoes. As such, a framework developed by the Commission on the true cost of certain products would increase knowledge and awareness about the impact on the environment and society of these products, which would ultimately result in full market transparency, accounting also for those costs that are currently borne by nature and society. We would be grateful if you could consider the above-mentioned issues and we remain available for further information.
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Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

12 Jun 2019 · Implementation of the organic reform

Response to Establishment of Harmonised Risk Indicators to measure the reduction in risks and adverse impacts from pesticide use

20 Dec 2018

IFOAM EU welcomes the setting up of harmonised risk indicators according to Article 15.2 of the Sustainable Pesticide Use Directive 128/2009/EC (SUD). Currently the SUD remains a key instrument to reduce the risks and impacts of pesticide use on people's health and the environment. Prioritisation of organic farming in National Action Plans implemented under the SUD could further help to better meet the objectives of the Directive. Setting up an indicator to measure the implementation of IPM farming would be an important step. The percentage of organically managed farmland should serve as a basis for calculating this indicator. The number of authorised naturally occurring active substances allowed under the organic regulation (EC) 834/2007 should be included in the calculation and monitoring, as it is a crucial criterium and urgently needed for the development of IPM farming. The uptake of agro-ecological practices and prioritising the development of organic farming under the Common Agricultural Policy, including knowledge transfer and innovation as well as market development, will also contribute to reach the goals of the SUD. From the development of indicators subsequently the definition of quantitative use reduction targets of chemical-synthetic pesticides needs to be developed. Setting-up a system of taxes/levies and other incentives to shift from chemical-synthetic inputs towards preventive and indirect pest control and natural occurring substances, needs to be prioritised. Hereby the support for the development of a registration process suitable for the special characteristics of naturally occurring/nature-identical substances is key. This need is also expressed clearly in the ‘Study supporting the REFIT evaluation of the EU legislation on plant protection products and pesticides residues (Regulation (EC) No 1107/2009 and Regulation (EC) No 396/2005)’: The criteria for approval for active substances in the Regulation (EC) 1107/2009 need to be adapted to substances with an existing natural background in order to further promote the uptake of IPM practices like organic farming and to ensure coherence with the objectives of the SUD. In the 2017 report from DG SANTE regarding an evaluation of the SUD it is stated that although the number of non-chemical pesticides authorised by MSs has increased in recent years, there is significant variation between MSs, with the proportion of these products ranging from less than 1 % to over 13 % of all authorised pesticides. Further, the report acknowledges that ‘these products provide an alternative to chemical pesticides for growers.’ The evaluation of the SUD by the European Parliaments Research Service published in October 2018 mentioned an increased difficulty in particularly for non-chemical PPPs to develop and place on the market because of high costs, in particular when compared to potential returns. According to this study, different stakeholders confirmed that Regulation (EC) No 1107/2009 does not adequately promote IPM in agriculture, and in this regard, is incoherent with the SUD. Therefore, we call on the European Commission to include organic farming in the development of the harmonised risk indicators and to further encourage the development of suitable naturally occurring active substances in the future work on the SUD.
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Response to Evaluation of the impact of the CAP on habitats, landscapes and biodiversity

6 Dec 2018

IFOAM EU, the European federation for the European sector, sees a direct link between the rapid decline of biodiversity across the EU and the bulk of CAP support. Although certain measures under Rural Development have positive effects on biodiversity, most of the CAP support has been detrimental to the level of biodiversity. IFOAM EU stresses the necessity for the new CAP to: • move to an effective, transparent and fair results-based system that attributes public money to farmers for the delivery of public goods; • have an ambitious ring-fenced budget across the whole CAP (pillar 1 and 2) for the 3 environmental objectives, including article 6 (f) on biodiversity • require MSs to support under CAP’s green architecture voluntary interventions that provide multiple benefits for the environment; single agricultural measures should not be supported under eco-schemes (article 28) nor under Environmental, climate and other management commitments (article 65). The following five areas should be covered in the European Commission’s Evaluation of the impacts of the CAP on habitats, landscape, biodiversity: 1. Impact of CAP on drivers of biodiversity loss, covering impact on: a. direct land-use change and habitat conversion b. water use c. agricultural run-off d. pesticide use e. synthetic fertiliser use f. direct persecution of wildlife g. destruction/maintenance/restoration of landscape features h. intensification of farming (livestock density, increased inputs, increased mowing of grasslands and increased tillage). i. use of standardised high yielding varieties across vast areas, often grown as monocultures. 2. Impact of individual CAP tools: a. Direct payments b. Greening payments c. Coupled supports (broken down by sectors) d. Rural development investments 3. Impact of eligibility conditions: the impact of definitions (or the lack of sufficient detail) such as on permanent grassland and arable land. 4. CAP and data gathering: a. Whether and to what extent the CAP is contributing to appropriate gathering and use of biodiversity-relevant data and evidence (such as on protected areas, monitoring land use changes), including LPIS, IACS and monitoring and evaluation of agri-environment schemes. b.The coherence with, and the contribution of CAP measures to the implementation of the Sustainable Use Directive on pesticides should also be analysed. In particular it should be assessed how to ensure better and more detailed data collection on which active substances are used on which crops, and in which ecosystems. 5. Evaluation process, methods and transparency: a. Ensure that Scientists and experts are properly and separately consulted on the Fitness Check. Use studies and data available where possible. b. Use of peer-reviewed science as much as possible e. Ensure full transparency of sources of data and full referencing of all sources of evidence and conclusions. f. Ensure to engage EU citizens g. Ensure that environmental NGOs and civil society are adequately consulted in the analysis h. DG Environment of the European Commission should be co-leading on this study, as they are the responsible DG on reaching the Biodiversity objectives.
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Response to Commission Implementing Regulation amending the criteria of low risk substances

29 Nov 2016

IFOAM EU Input to the Draft Commission Implementing Regulation amending the criteria of low risk substances Ares (2016)6239720 November 2016 IFOAM EU supports the aim of the Implementing Regulation amending the criteria of low risk substances to improve the availability of plant protection products in EU which present low environmental and toxicological risks. We appreciate very much that in the definition of the criteria in some points the special situation of naturally occurring substances was taken into account. We hope that this amendment of the criteria may lead to an increase of the availability of such naturally occurring substances as PPP that fulfill the criteria and cover a market segment in integrated and organic farming systems which is sufficient that a return of investment of the cost of registration can be expected. Particularly we appreciate that the explicit indication of baculoviruses as a host specific family,will facilitate the availability of such PPP to farmers. However, we had also to realize that the criteria for “low risk” are limited to the determination of higher standards for some of the existing criteria for the registration of PPP. Other risks are not addressed. If newly designed molecules are introduced into complex ecosystems remains always a probability that effects occur that are not covered by the models used during registration. The risk of such “unknown effects” is not considered in the “low risk” criteria. For substances that are naturally occurring in these ecosystems the risk that “unknown effects” occur is lower than for newly designed “synthetic” molecules. The more common the substance is in these ecosystems the more the probability of unknown effects is reduced. Several natural substances common in ecosystems are used traditionally in organic farming. Most of these substances will not profit from the amendment of the low risk criteria for the main reason that the market segment for these substances is rather small and companies donot expect a return of investment of the cost of registration. Other solutions (under Art. 23 of EU Regulation EC 1107/2009) must be explored to ensure the availability of these substances in plant protection. For more information see IFOAM EU Position Paper on Plant Health Care in Organic Farming (http://www.ifoam-eu.org/sites/default/files/ifoameu_policy_position_paper_plant_health_201604.pdf)
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Meeting with Karmenu Vella (Commissioner)

19 Nov 2015 · CAP Implementation, Organic Farming, GMOs, Aquaculture

Meeting with Vytenis Andriukaitis (Commissioner) and

28 Sept 2015 · New breeding techniques, GMO

Meeting with Vytenis Andriukaitis (Commissioner) and

30 Jan 2015 · The Food Chain, Innovation and Challenges, Food Information to Consumers, Nutrition, and Food Waste, Animal Health, Animal Welfare and Plant Health

Meeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan)

3 Dec 2014 · Meeting with IFOAM (Stephen Meredith)