EUROPEAN COMMISSION
DIRECTORATE-GENERAL FOR AGRICULTURE AND RURAL DEVELOPMENT
Directorate H. Sustainability and Quality of Agriculture and Rural Development
H.3. Organic farming
Brussels, 12 June 2013
ORGANIC FARMING POLICY REVIEW
ADVISORY GROUP ON ORGANIC FARMING – MEETING 26 JUNE 2013
CONSULTATION DOCUMENT – PART III: IMPACTS OF POLICY OPTIONS
This document follows two documents presented to the AGOF in its meeting of 11 April:
– Consultation document - Part I: Issue Paper
– Consultation document – Part II: Policy options
The note presents the content of the policy options in details. Identified impacts are
outlined in a table in Annex against the baseline scenario (= how would the problem
evolve without a change in policy?).
Stakeholders are invited to give their views on this analysis and if possible to provide
data to improve the quality of the impact assessment by 26th June at the latest or at the
meeting of the Advisory Group on the same day.
Data is missing in particular on the following:
– Number of holdings converted to organic farming per year per MS and corresponding
area (Eurostat does not distinguish conversions from farms with parallel conventional
production),
– Data on organic farms with parallel conventional production (number, areas, main
features),
– Number and main features of retailers selling organic products,
– Reasons why small farms (below 5 ha) are underrepresented in the organic sector,
– Small enterprises (SME) active in the organic sector: number, size, main economic
activity,
– Indication of the availability in organic form of the ingredients of agricultural origin
listed in Annex IX of regulation 889/2008.
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
1.
DETAILED CONTENT OF POLICY OPTIONS
Based on orientations suggested during the hearings and the public and stakeholder
consultations, three broad policy options are being analysed:
1.1.

Option 1: improved status quo

Option 2: market-driven option

Option 3: principle-driven option
Policy option 1: improved status quo
This option is based on improvements and better enforcement of the current legislation. It
is considered as a minimum to address the identified issues; therefore the proposed
measures are also included under options 2 and 3. The instruments proposed are the
following:
 A Regulation of the European Parliament and the Council to replace Council
Regulation (EC) No 834/20071:
-
to clarify and to marginally extend the scope of the legislation,
-
to clarify provisions of the standard to avoid ambiguities,
-
to slightly amend the labelling rules, notably by removing the indication of place
of farming when it can cause confusion with the origin labelling under other
legislations and by expanding the limit of 2% for ingredients of agriculture origin
not coming from the mentioned area to 5% for the "EU" or "non-EU" indication,
-
to streamline the articulation with the general rules for the accreditation of
private control bodies,
-
to remove the possibility of recognition of control bodies for the purpose of
compliance (Article 32),
 Measures to reinforce coherence and synergies with horizontal legislation in particular
on traceability and market controls and to increase coordination of the different
authorities in charge of market surveillance within the MS.
 Revision of the process for the technical examination of the introduction of new
substances and practices in organic farming.
 A system of electronic certification integrated in an EU web-based database with
adequate implementing provisions.
Possible sub-option:
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Commission Regulation (EC) No 834/2007 of 28 June 2007 on organic production and labelling of
organic products and repealing Regulation (EEC) No 2092/91 (EU OJ L 189, 20.7.2007, p. 1)
2

The end of the exception for retailers to be included in the control system is
presented as a sub-option.
1.2.
Policy option 2: market-driven option
This option aims at providing the conditions to respond dynamically to further market
developments. A less stringent standard allows producers benefitting from current
exceptions to continue to produce organically, and newcomers to join. It is compatible
with the control system and the import regime as stated in option 1. The instruments
proposed are the following:
 A Commission Communication on a strategy for organic farming (Action Plan),
putting forward recommendations and an appropriate coordination with EU policies
and MS in order for the organic sector to develop as required by the market. It would
include recommendations to MS on targets for market development, accompanying
measures to improve and increase controls on final products, and information and
promotion actions aiming at supporting conversion to.
 A Regulation of the European Parliament and the Council to replace Council
Regulation (EC) No 834/2007:
-
to integrate current long-lasting exceptional rules granted by MS as provisions in
the EU Regulation,
-
to draft a more readable and stand-alone organic standard,
-
to include the measures presented in option 1.
 Measures to reinforce the control system ( as in option 1)
This option can be combined with sub-options:
A.Introduction of a lower GMO labelling threshold for organic food. Current
labelling rules remain for feed.
B. Re-introduction of import authorisations under the responsibility of MS.
1.3.
Policy option 3: principle-driven option
This option aims at re-focussing organic farming on its principles. It strengthens the
standard by removing any flexibility, considering that it had been introduced to make
easier the conversion of holdings when the organic sector was embryonic, but that it is
not justified any more in the light of the development of the sector. This does not require
any additional amendment of the control system; however, the introduction of specific
measures for small farmers, in particular group certification, is presented as a sub-option.
On the import side, considering potential difficulties to upgrade the standards applied by
the Control Bodies (CBs) under the equivalence regime, this regime is replaced by
compliance. A regime of equivalence with third countries remains, with peer evaluation.
The instruments proposed are the following:
 A Commission Communication on a strategy for organic farming (Action Plan),
putting forward an adequate use of existing tools and an appropriate coordination with
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other EU policies in order for the organic sector to develop while remaining close to
its values and principles. It includes appropriate instruments to increase information
on the sector in the EU (market, production, added value, trade) and develop a specific
export policy for organic products.
 A Regulation of the European Parliament and the Council to replace Council
Regulation (EC) No 834/2007:
-
to remove all exceptional rules from the organic production standard, except
where temporary measures are necessary in order to allow organic production to
continue or recommence in the case of catastrophic circumstances,
-
to oblige organic holdings to be entirely managed in compliance with the
requirements applicable to organic production,
- to put an end to the retrospective acknowledgement of conversion,
-
to end the use of non-organic ingredients in processed products,
-
to draft a stand-alone organic standard addressing the issue of readability and
making imports possible under a compliance regime,
- to remove the possibility of recognition of control bodies for the purpose of
equivalence (Article 33 (3)) (+ transition),
- to adapt the possibility of recognition of control bodies for the purpose of
compliance (Article 32), notably by removing the possibility of such recognition
of CBs acting in recognised third countries,
- to include measures presented in option 1, except removal of Article 32.
 Measures to reinforce the control system ( as in option 1)
- Delegated Acts to reinforce the risk-based approach notably to abandon annual
inspection for each operator, e.g. less frequency in inspections for low risk operators
with proven clean records and concentration of controls on high-risk areas and
operators,
- to include provisions as in Option 1.
 Possible sub-options:
A. Introduction of an obligation of measuring environmental performance for
non-agricultural companies,
B. Phasing out of national logos,
C. Simplified requirements for small farmers and/or introduction of group
certification,
D. Recognition of third countries for their control systems only, provided they accept
to supervise the application of the EU organic standard on organic products
exported to the EU.
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1.4.
Options discarded at an early stage
Options defined by the use of alternative legal instruments have been considered but have
been discarded at an early stage:

The use of a framework directive would not meet the objective of more
simplification. Unfair competition issues could arise. Equivalency arrangements
with third countries would probably be put into question.

The introduction of "organic farming" as an optional reserved term under Council
Regulation (EU) No 1151/20122 on quality schemes for agricultural products and
foodstuffs would not acknowledge the holistic approach of organic farming which
is not only a quality scheme but also a specific way of farming/processing.

The change of legal basis in order to cover products (textiles and cosmetics) other
than food, feed, live or unprocessed agricultural products, vegetative propagating
material and seeds for cultivation has been considered but organic farming should
remain focussed on agriculture since it is a crucial instrument to deliver
environmental services and to boost development, innovation and employment in
rural areas.
The co-Regulation and self-Regulation options could result in difficulties for the sector to
develop a high and harmonised EU standard accepted by society all over the EU. It could
also undermine consumer confidence, since the EU Regulation and the official control
system are important reasons for consumers to trust organic products. For these reasons,
self-Regulation has been envisaged but not retained as a sub-option of option 2, for the
process of authorisation of new substances and new practices in organic farming and for
the authorisations of non-organic ingredients that can be used to produce organic
products.
The Codex Alimentarius guidelines for the production, processing, labelling and
marketing of organically produced foods3 include a standard on organic farming.
However, it is not designed to be directly applied in WTO Member countries. In
particular, the decision-making process is heavy and long and would not be appropriate
to decide on implementing rules.
The no-EU action option would bring the EU organic sector in a weak position on the
global market, where there is a general trend towards more harmonisation in standards.
2.
IMPACT ANALYSIS
The baseline scenario is developed for the period from 2011 (last year with available
statistics) to 2025, based on trends observed during the decade 2000-2010 (or 2000 –
2011) when data is available.
2
Regulation (EU) No 1151/2012 of the European Parliament and of the Council of 21 November 2012
on quality schemes for agricultural products and foodstuffs - OJ L 343, 14.12.2012, p. 1.
3
GL 32-1999
5
Impacts of the policy options are evaluated for the period 2016 -2025. 2016 is considered
the first year when the reviewed policy applies. Between 2011 and 2016, the baseline
applies.
The sources used are:
– Eurostat annual statistics for the organic land area and the number of operators,
– FADN data for indications on farm income and employment. However, since organic
farming is not a sampling criterion in FADN, the possibilities of using FADN data for
analyses of organic farming are very limited.
The table presents:
– the evolution of the organic market,
– socio-economic impacts on the main stakeholders
– organic farmers,
– organic processors,
– organic importers,
– the sector "organic inputs" (organic seeds, pullets, etc) and organic ingredients
– impacts on small farms
– environmental impacts.
The administrative burden for national competent authorities and for stakeholders is
analysed separately.
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ANNEX 1 – SHORT PRESENTATION OF THE ORGANIC SECTOR IN THE EU
Agricultural holdings in the EU
The EU organic land area more than doubled in the decade 2000/2010. It increased
on average by around 500.000 ha per year and reached 9 million ha in 2010. (9.5 million
ha in 2011).
The number of organic farms increased from about 132.000 to 226.000 between
2000 and 2011, while the general trend in agriculture is downwards. A recent strong
development is observed in some MS like Belgium, France, Poland or Spain.
FADN data shows that Fieldcrops farms applying organic practices are smaller than
conventional ones, in economic terms as well as from in physical terms, in Germany,
France, Austria and Poland, but not in Spain. The data could not be analysed at EU level.
But organic farms are generally more labour intensive than conventional ones and for
comparable structures the income per AWU (Agricultural Working Unit) is in general
higher on organic farms.
The smallest farms (below 5 ha) are under-represented in the organic sector (6%
against 69%). Average size of an organic farm in the EU is 33,6 ha, average size of a
conventional farm in the EU is 14 ha.
Organic processors in the EU
33.000 organic processors were registered in the EU in 2011, against 18.000 in 2000.
The number increased regularly until 2007 (32.500). Since then, the increase is marginal
and mostly concentrated in the new MS.
Organic importers in the EU
1.560 organic importers were registered in the EU in 2011 against 620 in 2000. Their
number increased regularly until 2007 (2.400), but then sharply decreased in 2008
(1.600). Since 2008, the increase is marginal.
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