The Organic Inputs Evaluation project

1. The Organic Inputs Evaluation project Bernhard Speiser, Otto Schmid & Lucius Tamm, FiBL Brussels, 12 March 2007

2. Contents Introduction to the project and its aims Main results of the project • evaluation process & review by an expert panel • new evaluation criteria Implementation in the new Organic Regulation • evaluation criteria in Article 11 • test with case studies > suggestions for amendments Conclusions, research needs

3. Acknowledgements • Administrative co-ordination: DARCOF (Lizzie M. Jespersen) • Scientific input from project partners and many external experts • Funding from: Commission of the European Communities, 5th Framework Programme of RTD, contract QLK5-CT-2002-02565and from: Swiss Federal Office for Education and Science (BBW)

4. The Organic Inputs Evaluation project • Concerted Action • Duration: January 2003 – December 2005 • 12 partners and many external experts • Website: www.organicinputs.org Objectives • To develop harmonized and standardized procedures for evaluation of plant protection products, fertilizers and soil conditioners for use in organic agriculture.

5. Considerations on objectives • Evaluation of inputs should be based on scientific evidence and on principles of organic farming. • Progress must be possible. It should be possible to authorize new inputs, but the principles of organic farming must be conserved. • The evaluation process should be transparent and involve stakeholders. • International harmonization is desirable, especially with the Codex Alimentarius guidelines.

6. Support from Organic Inputs Evaluation Plant protection Dir. 91/414 New Council Regulation What can be used 4th stage re-evaluation Support from REBECA New Regulation Inputs: overlap with other legislation Organic farming Reg. 2092/91

7. Download: www.organicinputs.org Two inventories of the existing system Main findings • Large variability between EU Member States concerning allowed products. • Inclusion of new plant protection products on Annex II B is impossible in most cases (non-contact clause). • If inclusion is possible, the process is very slow.

8. advice by EU expert panel proposed present Request Request Review Evaluation Discussions Final recommendation Decision Decision The evaluation process

9. Why review by an EU expert panel ? • Homogeneity across requests- order of presentation of facts- degree of detail- line of argumentation • Completeness of facts • Adequate interpretation Applicant and expert panel should try to reach consensus, to avoid contradictions in the dossier.

10. EU expert panel • Is, or is part of, the independent expert panel for technical advice cited in Action 11 of the EU Organic Action Plan. • Acts in the public interest. • Permanent members, to ensure continuity over time and consistency with other organic farming legislation. • Ad-hoc members to provide additional expertise for individual inputs.

11. Composition of the EU Expert panel • 1 chair • 6 organic farming experts, covering wide range of animal and crop husbandry and broad geographic spread • 1 expert for - marketing, policies, standards, consumer expectations- organic inspection and certification- soil science- biochemistry or inorganic chemistry- ecotoxicology- human health- plant protection and/or plant nutrition • Can one expert cover more than 1 field of expertise ? • This is the composition suggested for evaluation of inputs. For other tasks, composition of the panel might have to be enlarged (see proposals of the Organic Revision project).

12. The Criteria Matrix • The Criteria Matrix was developed as a tool for the evaluation process. • It contains all information necessary for the evaluation process. • It makes the evaluation process transparent. • It is a systematic collection of arguments, which allows to compare the Member State views in a simple way. • Two case studies illustrate its use • Matrix has been used to evaluate potassium bicarbonate

13. How to define ? Synthetic products > NO Natural products of low concern > YES Products of high concern > NO New «candidate» substances ? Criteria … must allow the «right products»

14. Project‘s assumptions for the criteria • They should reflect the current consensus on which inputs are allowed. > Products currently listed in Annex II should pass the criteria. • Organic evaluation should not duplicate efforts from pesticide registration (risk assessment for environment, human health, residues …). • They should be harmonized with the Codex Alimentarius guidelines for organically produced foods. • Emphasis on criteria, not ontraditional use. • Products must fulfill all criteria to pass.

15. Present criteria (Article 7) allowed contact: not allowed • Traditional use • Non-contact (for pesticides only) • Necessity • Environment must be essential no unacceptable effects

16. Codex Alimentarius no no yes yes yes yes yes partly yes Criteria proposed by the project (delete) (delete) existing existing new new new new new • Traditional use • Non-contact (pesticides only) • Necessity • Environment • Origin • Manufacture • Human health • Socio-economic impact • Organic farming principles

17. Implementation After the end of the Organic Inputs Evaluation project, a New Organic Council Regulation was proposed. • Article 11 (current numbering) contains evaluation criteria. • Last version considered here: 22 Dec 2006 Note: Because this was after the end of the Organic Inputs Evaluation project, the following slides represent the authors‘ view, not that of the project.

18. Criteria in the new Organic Regulation (Article 11) • Organic farming principles • Environment • Human health • Necessity • Origin (rule & 2 exceptions) • Traditional use • Manufacture • Socio-economic impact new (part of objectives) (part of objectives) existing new existing not included not included

19. Origin, the rule Art. 11, 2. (b) «all products shall be of plant, animal, microbial or mineral origin …» Examples • Plant: compost, pyrethrine • Animal: farmyard manure • Microbial: Bacillus thuringiensis • Mineral: clay

20. Origin, the exceptions Art 11, 2. (b): «… except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available» Art 11, 2. (c) (ii): «if products are not of plant, animal, microbial or mineral origin and not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop» and, for plant protection products:

21. Plant protection products fertilizers Case study 1 Farmyardmanure 2. The authorization […] is subject to the objectives and principles laid down in Title II … 2. (a) Their use is necessary for sustained production and essential for its intended use; 2. (b) … shall be of plant, animal, microbial or mineral origin except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available; 2. (c) (i)... is essential for the control … 2. (c) (ii)if products are not of plant, animal, microbial or mineral origin and are not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop; 2. (d) … is essential for […] fertility of the soil … 3. (c) Products and substances used before the adoption of this Regulation […] may continue to be used after said adoption… allowed

22. Art. 4. (b) (iii) low solubility mineral fertilizers Plant protection products fertilizers Case study 2 Chileannitrate 2. The authorization […] is subject to the objectives and principles laid down in Title II … 2. (a) Their use is necessary for sustained production and essential for its intended use; 2. (b) … shall be of plant, animal, microbial or mineral origin except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available; 2. (c) (i)... is essential for the control … 2. (c) (ii)if products are not of plant, animal, microbial or mineral origin and are not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop; 2. (d) … is essential for […] fertility of the soil … 3. (c) Products and substances used before the adoption of this Regulation […] may continue to be used after said adoption… not allowed

23. Plant protection products fertilizers Case study 3 Pheromones for mating disruption 2. The authorization […] is subject to the objectives and principles laid down in Title II … 2. (a) Their use is necessary for sustained production and essential for its intended use; 2. (b) … shall be of plant, animal, microbial or mineral origin except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available; 2. (c) (i) ... is essential for the control … 2. (c) (ii) if products are not of plant, animal, microbial or mineral origin and are not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop; 2. (d)… is essential for […] fertility of the soil … 3. (c) Products and substances used before the adoption of this Regulation […] may continue to be used after said adoption… allowed

24. Art. 4. (c) (iii)… unacceptable environmental impacts ? Plant protection products fertilizers Case study 4 Spinosin 2. The authorization […] is subject to the objectives and principles laid down in Title II … 2. (a) Their use is necessary for sustained production and essential for its intended use; 2. (b) … shall be of plant, animal, microbial or mineral origin except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available; 2. (c) (i) ... is essential for the control … 2. (c) (ii) if products are not of plant, animal, microbial or mineral origin and are not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop; 2. (d)… is essential for […] fertility of the soil … 3. (c) Products and substances used before the adoption of this Regulation […] may continue to be used after said adoption… allowed (?)

25. Art. 4. (c) (iii)… unacceptable environmental impacts ? Plant protection products fertilizers Case study 5 Glyphosate herbicide 2. The authorization […] is subject to the objectives and principles laid down in Title II … 2. (a) Their use is necessary for sustained production and essential for its intended use; 2. (b) … shall be of plant, animal, microbial or mineral origin except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available; 2. (c) (i) ... is essential for the control … 2. (c) (ii) if products are not of plant, animal, microbial or mineral origin and are not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop; 2. (d)… is essential for […] fertility of the soil … 3. (c) Products and substances used before the adoption of this Regulation […] may continue to be used after said adoption… allowed !

26. general except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available; 2. (c) (ii) if products are not of plant, animal, microbial or mineral origin and are not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop; 2. (c) (ii)if alternatives are not available, products which are not of plant, animal, microbial or mineral origin may be approved, if they are identical to their natural form, or if they are used in traps and dispensers; Plant protection products «traps and dispensers»: Codex Alimentarius Proposed amendments … 2. The authorization […] is subject to the objectives and principles laid down in Title II … 2. (a) Their use is necessary for sustained production and essential for its intended use; 2. (b) … shall be of plant, animal, microbial or mineral origin except if products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available; 2. (c) (i) ... is essential for the control … 2. (c) (ii)if products are not of plant, animal, microbial or mineral origin and are not identical to their natural form, they may be approved only if their conditions for use preclude any direct contact with the edible parts of the crop;[…]

27. Art. 4. (c) (iii)… unacceptable environmental impacts ? Plant protection products fertilizers Case study 5 repeated Glyphosate herbicide 2. The authorization […] is subject to the objectives and principles laid down in Title II … 2. (a) Their use is necessary for sustained production and essential for its intended use; 2. (b) … shall be of plant, animal, microbial or mineral origin; 2. (c) (i) ... is essential for the control … 2. (c) (ii)if alternatives are not available, products which are not of plant, animal, microbial or mineral origin may be approved, if they are identical to their natural form, or if they are used in traps and dispensers; 2. (d)… is essential for […] fertility of the soil … 3. (c) Products and substances used before the adoption of this Regulation […] may continue to be used after said adoption… not allowed

28. Evaluation now based on scientific evidence and on principles of organic farming More progress is now possible International harmonization The problem explained for glyphosate herbicides applies to all substances - applied outside the growing season or - applied to non-edible crop parts or to the soil - and also to substances other than plant protection products! For cleaning and disinfection agents, the same exceptions as those proposed for plant protection products should be allowed. Conclusions A lot has been achieved in the New Organic Regulation! What remains to be done: • Expert panel: should be installed. • Criteria: some amendments are needed.

29. Research needs Topic no 1: «right input on the right occasion» • Optimization at regional / crop level with specific conditions for use (instead of «need recognized …») • Replacement of currently allowed inputsby new inputs or alternative methods Topic no 2: new technologies • Compliance of upcoming new technologies such as nanotechnology with organic farming principles Thank you for your attention !