However, their November paper lays out clearly what they see as problematic in the proposal. “Without substantial changes, IFOAM EU would have no choice but to reject the proposal,” is the latest, stark statement from the EU branch of IFOAM.
According to IFOAM EU, the proposal “ignores many of the recommendations offered by the sector throughout the Commission’s regulatory review and revision process.” The federation, an umbrella for 160 European organisations involved in organic farming and food, are concerned that the new proposal will present “new obstacles and will add even more burden than before, without offering any real benefits, over and above the present regulation”.
They warn that there could be “a massive decline in organic production across Europe, in particular at the expense of small organic farms and businesses, and less developed regions”.
The three main issues for IFOAM EU are:
(1) Mixing up implementation problems with regulation: “One of the main misunderstandings in the process of drafting a new, organic EU regulation has been the assumption that there is a problem with the ‘regulation’ and with consumer trust.”
IFOAM EU say this assumption is unproven, and contradicts the mandatory impact-assessment external evaluation report, which states: “In many cases, the rules are adequate, but there is a lack of a harmonised interpretation and enforcement in member states.” There is a real challenge to “improve implementation and harmonisation, not the regulation itself”, say IFOAM EU.
(2) An incomplete impact assessment: “The proposed regulation is based on an incomplete impact assessment, which lacks essential data and includes problematic assumptions that lead to questionable conclusions and inadequate provisions.”
They point to an overemphasis on a “flawed” public consultation, when compared to the stakeholder consultation and evaluation. “The public consultation was based on a self-selected and unrepresentative sample, so the results cannot reliably reflect consumer opinion,” say IFOAM EU. They claim the questions were too technical, too unclear, and too partial/loaded.
“As a result, the Commission’s proposal risks creating an artificial conflict between producers and consumers, by trying to make a regulation for organic production in an “ideal world”, but not fit for purpose,” they say.
Stakeholders, on the other hand, have not been heard, says IFOAM. So, despite growth in demand, the new regulation would place the burden of “risk on farmers, who may be forced out of organic production, because they are unable to comply with the new provisions.”
(3) Unambitious European Organic Action Plan: the Commission is strong on rhetoric, but poor on goals, roadmaps and financial supports for organic, IFOAM EU say. “IFOAM EU welcomes the publication of a new EU Organic Action Plan in 2014... but, whereas the launch of a strong action plan has been a longstanding demand of the organic movement, the proposed plan lacks clear commitments”. So, while demand is rising, the number of farmers converting year-on-year is declining, “because organic farmers face extra costs and administrative burdens that often outstrip the added value they receive for their products.”
Elsewhere, at an Agriculture Council of Ministers meeting, it emerged that east European countries have also raised concerns. The Visegrád group — Czech Republic, Hungary, Poland and Slovakia — plus Bulgaria, Romania and Slovenia, are concerned about “the large number of delegated acts”, which would give too much power to the Commission; and about the elimination of mixed production and a uniform approach to agricultural that is unrepresentative of varying conditions across Europe.