The european federation of hand-harvested sea salt producer
Artisanal Sea Salt Europe promotes and defends the interest of its members who are hand-harvested sea salt producers.
ID: 032169118568-82
Lobbying Activity
Response to Detailed production methods for organic salts
14 Dec 2022
European traditional sea salt producers cannot accept nor subscribe to the proposed text, as it would allow many salt production techniques to be considered as organic, ignoring the principles and main objectives of the EU organic regulation 2018/848. Recital 1 of regulation 2018/848 states: « Organic production is an overall system of farm management and food production that combines best environmental practices, a high level of biodiversity, the preservation of natural resources, and a production method in line with the preference of certain consumers for products produced using natural substances and processes. » It is staggering to note that in its proposed delegated act, the European Commission: does not prohibit the production of organic salt from salt mines The first general principle of organic farming (Article 5 of the Regulation) is "to respect natural systems and cycles and to maintain and improve the condition of the soil". It is obvious that mining does not respect any natural cycle and deteriorates the soil and subsoil. To consider mining practices as organic is the same aberration as considering coal as a renewable energy. The text only foresees to prohibit rock salt mining that uses explosives, but it does not prohibit the use of "continuous grinding". Drilling and cutting extraction systems would be considered environmentally friendly despite the fact that they create cavities and destroy underground areas. Moreover, it is puzzling to consider that organic salt could be based on the extraction of salt which is among the sectors included in the carbon leakage risk category in the EU ETS system. requires that renewable energy should only be used for the production of organic sea salt The text proposed is completely inconsistent. It allows the practice of obtaining salt by heating salty water, without any constraint on the energy used, even though this is the most energy-intensive technique. There are also no energy constraints in the extraction/processing of mine salts that have a high carbon and water footprint. In contrast, for sea salt, which evaporates naturally, thanks to the sun and the wind, the Commission requires that the salt drying phase be carried out with renewable energy. This makes no ecological sense and creates a distortion of competition, which will seriously affect the smallest and environmentally-friendly producers. It would not contribute to the "development of rural areas", as organic farming should do, but to its weakening. The use of renewable energy should therefore be a requirement for all production processes or for none. allows for techniques that change the nature of salt The text would allow for the leaching of salt after harvesting. Such technique depletes salt of minerals such as Magnesium and Calcium. It is contrary to the fundamentals of organic farming which requires to guarantee the integrity of organic production at all stages of production, processing and distribution (Article 5 of the Regulation). It should be banned. Provides an unfair advantage to salt produced from mining over sea salt with regard to the access to the market. The delegated act does not provide for a date of for putting organic salt on the market. As you know, the production of sea salt is seasonal, as it depends on good weather conditions, whereas mine salt is produced continuously throughout the year. In the absence of a fair cut-off date for the marketing of organic salt, sea salt will probably be penalised as they will not be able to put their certified organic production immediately on the market. The delegated act introduces a significant distortion of competition between operators at the advantage of major industrial salt mining operators.
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