Tea & Herbal Infusions Europe
THIE
Tea & Herbal Infusions Europe (THIE) is the European association representing the interests of producers and traders of tea (Camellia sinensis) and herbal infusions as well as extracts thereof in the EU.
ID: 389995329101-55
Lobbying Activity
Response to Trade rules for organic production (implementing)
18 Nov 2021
With the presented implementing regulation, the EU Commission proposes changes for India in the list of recognised third countries, which, from the point of view of the European tea and herbal infusion industry, will have a considerable impact on the procurement of certified organic tea and herbal raw materials from India. This measure is justified by numerous cases of high contamination with ethylene oxide in corresponding products of Indian origin in the past, to which the Indian authorities and control bodies have not reacted adequately or have not taken adequate corrective measures.
In principle, we appreciate that the EU Commission is taking measures to better ensure the safety and integrity of organic imports from India. At the same time, we do not consider the deletion of the five control bodies concerned to be an appropriate measure, as the consequences of this deletion for the supply of the European market with certified organic plant raw materials in general will be affected severely. In our opinion, a transparent and comprehensive clarification is required in order to solve the problem of ethylene oxide in the future.
It must be ensured that those operators who have not infringed the regulations of organic law are able to continue to produce organic products in India and to be certified for export to the EU. Otherwise, many growers in India will be endangered in their existence. But also the buyers or manufacturers in the EU, who are particularly dependent on Indian products such as tea, dried herbs and fruits as well as spices for the production of teas and herbal infusions, would suffer massively from the consequences, since a short-term switch to other origins is not possible in most cases.
We therefore urge the EU Commission to reconsider its decision. Should the EU Commission see no other option than the de-listing of the five control bodies, which we would very much regret, we would nevertheless like to urgently suggest that suitable transitional solutions be guaranteed for the affected businesses. Furthermore, a provision is also needed that allows products certified and shipped before January 1, 2022 to retain their organic status even after the control bodies have been de-listed.
Read full response19 Jan 2018
Tea & Herbal Infusions Europe (THIE) fully supports provisions that intend to protect the consumer from being misled in terms of food information including those on the true origin or place of provenance. Indications of origin are one example of a large number of denominations used on packages of tea and herbal infusions products which contain geographical terms due to a variety of reasons. It should be noted that such geographical terms do not always indicate the origin of the respective products. Especially with regard to customary and generic names as well as scientific / botanical names of plants, THIE is of the opinion that these types of denominations are not appropriately covered by the latest draft version of the Implementing Regulation on Art. 26(3) of Regulation (EU) No 1169/2011. Please refer to the uploaded file for more information.
Read full response