This is a slight rise on 2014, when, says the Department of Agriculture: “22 derogations were granted for intake of female mammals, and 48 for poultry, one derogation in respect of conversion period and 708 in respect of the use of conventional seed or propagating material.”
The department adds: “In 2015, the number of derogations under the same headings were 21, 45, 7 and 837.”
Notably, they add: “In all cases, of course, the animals or seed brought on-farm must now be managed completely in accordance with organic production rules.”
When queried on the process of granting derogations, the department gave this response: “As the production base of the organic sector in Ireland is still small, representing just over 1% of total farmed area, derogations are sometimes required where sufficient inputs from organic sources are simply not available.
EU Regulation 834 of 2007 lays down rules for these exceptional production derogations. Derogations cover a very wide range of activities and inputs, including farming practices, and intake of animals and seed.
Except where specific provisions stipulate otherwise, derogation requests are submitted to the Department by the Organic Control Bodies acting on behalf of licensed operators. These are assessed by the department and decisions relayed back to the Organic Control Bodiess.”
This means the Organic Control Bodies — more commonly known as the organic certification bodies, primarily IOFGA and the Organic Trust — are the main source of information on the need or otherwise for derogations.
Here’s how the system works for livestock, states the department: “Livestock derogation requests are examined individually. The application is via the organic operator’s Organic Control Body with support, or not, for the derogation. The control body has already screened the request based on their detailed knowledge of the availability of organic inputs.
"The department is aware via its own knowledge of the organic sector, liaising with Teagasc, the Organic Bodies, organic stock for sale at dedicated organic marts and consulting trade information on availability of organic stock.”
How timely is this process? How up to date is the department’s analysis of what’s available on the market, when they make a decision on granting a derogation?
The department replied: “The assessment for livestock is done on a case-by-case basis and there is no significant time-lag between that assessment and the granting or refusal of a derogation request.”
In relation to organic seed, the Organic Control Bodies also assess what is available and decide on whether to grant or refuse the request.
The department states: “The single biggest area for derogations is for use of non-organic seed which can be very difficult to source. In order to improve that, the department is introducing a state-of-the-art, online organic seed-database which will put suppliers and operators into direct communication with each other, creating an effective online market place for organic seed producers, and a means for farmers to rapidly assess what seed from organic sources is available.”
When queried about whether derogations been refused, the department replied: “In 2014 five applications for derogations were refused, one in respect of conversion periods and four in respect of ‘catastrophic circumstances’. In 2015, seven were refused, all in respect of the intake of non-organic female mammals.”
There is always a balance between growing new areas and allowing the organic sector, as is, to function.
However there has to be an incentive for producers to make organic inputs available. Is there a motivation to develop an organic seed market, when this level of exemptions are being granted?