The aim of the meetings was to inform the UK’s negotiating position, expected to be finalised in the autumn. A summary of the legal proposal was followed by discussion of key points likely to impact on the organic sector in the UK, such as the proposed removal of all exceptional rules which was seen as unworkable and the overuse of delegated acts which would give the Commission power to write the detailed rules. For many areas there remains uncertainty as to what the proposal really would mean in practise remains.
To start with some participants challenged Defra’s current position of working with the Commission to negotiate improvements, but the opportunity for consultation was very clearly welcomed. The proposed removal of all exceptions is of concern for the UK. The general feeling was that exception needs to be considered on a case-by-case basis, but a complete removal was not workable or justified. Some (e.g. non-organic pullets) could be achievable but others (e.g. non-organic seeds for all species used) remain problematic. Concerns were also expressed on the overuse of Delegated Acts, which gives the Commission the power to set the detailed rules. It was interesting to hear that Defra is consulting with its legal team on the extensive use that is proposed. The Delegated Acts also leaves much detail of the proposal open to uncertainty making it difficult to assess some of the likely impacts. There was no support for the introduction of a general requirement for decertification if any non-authorised products or substances are found. This provision would move the basis for organic standard more towards testing the final product rather than defining practises that are permitted. The impact of this in practise is also uncertain, including the question, who would have to pay for any additional testing. The proposal to have entire holdings to be under organic management was not welcome and the current UK implementation was felt to be working well, so no need for change.
On many other issues the prevailing theme was uncertainty what the provisions would mean in practise. For example, evaluating the impact of changes to the permitted substances for processing is problematic without knowing the detail of what substances will be affected. Similarly, the impact of increase in percentage of feed required being from the holding/region remained uncertain because of the lack of a proposal to define ‘region’, even if goal of feeding organic animals from the farm/region should be welcomed in principle. There was some support for the introduction of an environmental management system for non-farming operators, but also here uncertainty prevails.
One of the few areas where proposed changes are supported is the move to a risk based approach to controls, but on other proposed changes to the control rules no clear consensus was reached. Finally, it was suggested that Defra also needed to consider what is not in the proposal – a number of areas had been missed out e.g. EU wide implementing rules for greenhouse production.
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