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Research Institute of Organic Agriculture in Europe

FiBL Europe

FiBL Europe, founded in 2017 and based in Brussels, acts as the European office for the four national FiBL institutes—FiBL Switzerland, FiBL Germany, FiBL Austria, and FiBL France—as well as the Hungarian organic research institute, ÖMKi, and the Luxembourg Institute for Organic Agriculture and Agroecology - IBLA.

Lobbying Activity

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

13 Mar 2025 · Presentation of FiBL and IBLA’s ongoing research work on biocontrol, and research insights on benchmarking systems. And exchange of views on upcoming policy priorities, alternatives to pesticides, and biocontrol solutions.

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

19 Feb 2025

Based on the both 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). the COMMISSION IMPLEMENTING REGULATION (EU) /...of XXX laying down good manufacturing practice for active substances used as starting materials in 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. To prevent a further reduction of such available products on the European market, there is an urgent need to prevent the manufacturers of those products from being discontinued due to disproportionate GMP demands. We therefore agree with the general concerns and the detailed required changes of the German pharmaceutical industry association (BPI) which represents manufacturers from this sector in particular.
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Response to Uniform rules on good manufacturing practice for veterinary medicinal products and active substances

19 Feb 2025

Based on the both 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). the COMMISSION IMPLEMENTING REGULATION (EU) /... of XXX 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. To prevent a further reduction of such available products on the European market, there is an urgent need to prevent the manufacturers of those products from being discontinued due to disproportionate GMP demands. We therefore agree with the general concerns and the detailed required changes of the German pharmaceutical industry association (BPI) which represents manufacturers from this sector in particular.
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Response to Rules governing the production and marketing of plant reproductive material of organic heterogeneous material

27 Nov 2020

FiBL Europe is member of IFOAM EU and we support the feedback provided on "Organic crops-Boosting resilience through a genetically diverse planting mix": ---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 Amendment of products and substances allowed in organic production

13 Aug 2019

Comment to Draft Annex 1 Fertilisers, soil conditioners and nutrients referred to in Article 3(1) and Article 6d(2) A: authorised under Regulation (EEC) No 2092/91 and carried over by Article 16(3)(c) of Regulation (EC) No 834/2007 A Stone meal, "clay minerals" and clay Proposal FiBL Germany proposes to include “clay minerals” in Annex I. Reasoning • Clay minerals are the predominant part of clay. • It was always the intention of the organic sector to authorize all clay minerals, and not only clay. • Many certifiers assume that clay minerals are authorized under the listing of clay. • However, some national fertilizer laws (e.g. the German fertilizer law) make a distinction between “clay” and “clay minerals”. In countries where this is the case, only clay is authorized, and not clay minerals. • As a result, there is uncertainty among certifiers whether clay minerals are authorized or not, and unequal interpretations across Europe.
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