Multiple challenges in organic certification: Marian Blom @European Organic Congress, Cordoba
European Organic Congress 27 September 2023 Cordoba, Spain.
When I received the invitation to join this panel discussion to give my view on certification from the side of the operators first I thought it was easy. But when I started preparing I realized I had no idea! Because when we speak about operators we do not only speak about farmers but about every operator in the whole supply chain: farmers, processors, traders, shops. And for operators in 27 member states. And also in third countries.
And the other thing I realized is that there is the risk when we speak about the organic regulation it often ends in bashing the European Commission. And that would not be fair. Because it is not the Commission that makes the rules. The regulation is agreed by the legislators which are the European Parliament and the Council. Than the Commission adds elements, and the member states have to execute it. Even though a regulation has direct effect in Member States there is always need for some sort of explanation. And than there are also the control bodies, most often more than 1 per country that also will differ in their approach.
So maybe we should look at it the other way around; how should a good regulation be for an organic operator. I thought about this for a while and concluded it should be WASP:
Operators should be Proud to be part
When I take that list, I can think of some challenges for the operators. Just some examples;
- The long lasting discussion about lithotamnium is for an operator not workable. We are fighting over the issue whether it is a fresh organic algae that can be used as an ingredient in plant based drinks or a not allowed calcium fortification? And in the meantime young mothers breastfeeding are advised not to drink organic plant based drinks because this substance cannot be added.
- The positive list for cleaning and disinfection for processing locations will be not sensible. What to do if you have a mixed organic -non organic processing plant? Luckily the Commission has given themselves (and us) more time, hopefully to work out a better system.
- The increased administration and hour input that operators need to invest to proof they are organic and, in some countries, the increased cost of certification. This makes organic certification more and more often non affordable.I see though that in some national action plans governments support operators somewhat by reimbursing certification cost.
- The 100% organic shop that has to do a mass balance calculation, although it sells almost uniquely to final consumers is not sensible. The risk of fraud there is quite low, why this burden?
- And proud; well I know vegetable growers that would really like to be organic and like to operate under a group certificate. They are proud of the way the farm and they want to show it with the help of the green leaf. But I fear that the new rules for group certification wil not work for many of them. So in the end not workable.
And there is something that is really sensible and that is the strengthened idea of risk based inspections. Where, if it works well, an operator has the responsibility to learn and know where the risks are and he has to show that he does something to prevent fraud. And an inspector should ideally focus on that system and not on the details.
Overlooking these challenges it may be time to carefully look ahead and see how we can improve the certification system. From my side I think that at least the following five things should be considered when looking at how to improve:
- Details versus framework
- Proof versus trust
- Smart use of data and technologies
- Malus.. where is the bonus?
- System approach
In every revision more details are added to the production rules, because we want more clarity and a level playing field. But I question if we will ever reach that level playing field and that clarity. There will always stay some details unsolved and people start asking about it and in a next revision round they end up in the regulation. Never ending detailisation.(not an English word I think). I fear we are more and more getting into a situation where people who want to produce organic in a way that really contributes to the societal benefits, get stuck, because of the details. We should really consider if we want to continue this way with the regulation.
And in every revision the amount of articles dedicated to the control has increased. So how will it be in the next regulation: more rules on control? Or should we invest in working with the risk based system, where the operator gets more responsibility? And where he is controlled on his ability to show he knows where risks are and how to handle them.
There is much more possible than we use now. I know about a project that Wageningen University is doing together with Skal Biocontrole (Dutch CB) to see if it would be possible on the basis of available data to make an automatic mass balance. Especially if a farm or operation has a relatively simple input- output model like a pig farm with one or a few suppliers of feedand a long-term contact with the same slaughterhouse, it is very well possible that all the data needed is already available with the business partners. More of these solutions are possible.
I will give an example. If an operator is classified as a high-risk operator, he will be inspected twice a year, at his own cost. The criteria are set in such a way that even if the operator does everything perfectly right, it is virtually impossible to change its status to a normal risk operator. This is the case with for example importers and mixed operations. So there is a malus , an extra punishment in the system, but there is no reward, no bonus if you do it right.
And finally I think we should acknowledge, also in the regulation, that it is the system approach that brings the benefits of organic to society. And it is what makes organic organic. And this should also, more that now, be reflected in the regulation.
If we take these five things in consideration and start discussion about it, we may end up with a regulation that looks quite different from the current one.
Thank you for you attention. Marian Blom, firstname.lastname@example.org