xx May 2013
João Onofre,
Head of Unit, DGAGRI H3
DG Agriculture and Rural Development
European Commission
Brussels
Animal Protein Feed and Organic Farming
Dear Mr Onofre,
The IFOAM EU Group would like to express its concern about the end of derogation to use up to 5%
of non-organic protein feed for porcine and poultry species under Regulation (EC) No 505/2012 and
calls for a prolongation of the derogation until 2018.
We remain strongly committed to the principle of 100% organic feed with significant progress made by
organic operators, however, the protein shortage is far from being solved. Many operators are still
strongly dependent on imports from other regions and third countries and this situation is not going
to change significantly in the short-term. An extension of the derogation would provide the organic
sector with more time to further develop effective solutions for producing organic protein.
Recently efforts have been made to increase protein feed supply in Europe, through for example,
national actions plans that promote local protein feed production. As many of these action plans are
only in their infancy any significant impact cannot be expected before 2018. Farmers also continue to
confront challenges with protein cultivation, which are being tackled in research projects, but still
need time to be developed and implemented at farm level. Furthermore the need for protein feeds
has accelerated due to the growing demand from new poultry and pork operations with insufficient
own feed production. As a result, there are simply no realistic possibilities for the organic sector to
fulfill the 100 % organic feed standards by 2015 under current conditions. Instead we suggest the
standard should be phased in gradually after 2018 in order to ensure a smooth adaption to new
organic protein sources.
IFOAM EU also sees animal sources as one solution to increase supply. While the use of synthetic
amino acids is unacceptable as it does not comply with the organic standards under the Regulation
(EC) No 834/2007 one promising option are natural amino acids from organic sources generated by
enzymatic fermentation. Such techniques are ready to be implemented in practice but remain small
in scale. Slaughter-by-products from organic animals and the growing of worms for protein could
serve as another option but would need to be authorised as feed within the EU and accompanied by
practical solutions for implementation. These options, however only offer solutions in the short to
medium-term.
Finally we welcome the Commission’s plans to explore this year the potential for increasing the
supply of protein-rich crops production in the EU, taking in account the 2011 resolution of the
European Parliament on the EU protein deficiti. The implementation of protein strategies at EU level
and national level can be the only precondition for reaching 100 % organic feed for monogastric
animals. The CAP can be also exploited for developing long term solutions and we see a lot of
promise in the Commission’s proposals to set up focus groups on protein crops and the optimisation
of yields in organic arable rotations under the European Innovation Partnership. It is critical that any
measures under the new CAP and an EU protein strategy are closely linked to the development of a
new EU Organic Action Plan.
i
Official Journal of the European Union, 2012/C 199 E/07, EU Protein Deficit: European Parliament resolution of 8 March 2011 on
the EU protein deficit: what solution for a long-standing problem (2010/2111(INI))