EU-China Organic Food
Standards Comparison
1. Comparison of EU and Chinese
organic standards
• Notable similarities and differences between the two
systems
• Information derived from Annex IV of Regulation (EC)
No. 1235/2008
• Seven categories of substantial importance
A. Unprocessed Plant Products
• Includes products such as peat, mushroom
culture wastes, composted bark and wood ash
• China regulations less stringent than EU
regulations
• Products are specifically legislated to be from
their natural origin
Similarities:
• Chinese regulations on wood products (bark, wood ash)
similar to EU law
Differences:
• More unprocessed plant products used in fertilizers, soil
conditioners and nutrients under Chinese law
• Chinese regulations state products should not contain
synthetic chemical substances or receive chemical treatment
• Plant ash (product of fuel-wood) allowed for fertilizers under
Chinese law but not under EU law
EU Legislation
Chinese Legislation
Sawdust/ woodchips
Wood not chemically
treated after felling
Sawdust/ woodchips
Obtained from wood not
chemically treated
Composted bark
Wood not chemically
treated
Composted bark
Obtained from wood not
chemically treated
Peat
Use limited to horticulture
(floriculture, arboriculture)
Peat
Contains no synthetic
additive. Only used as
potting medium and not to
be applied to soil
amelioration
No regulation
Borax
Obtained without chemical
treatment or synthetic
chemical substances
No regulation
Pulp
Obtained without chemical
treatment
B. Live Animals/ Unprocessed Animal
Products
Legislation relating to wool and fur less stringent under Chinese
law than EU law – no adherence to official guidelines under
Chinese regulation
Similarities:
• Minimum surface areas indoors, outdoors and characteristics of housing
Differences:
• Wool, fur, hair and dairy products used in fertilizers, soil conditioners and
nutrients under Chinese regulations
• No indoor or door space regulations in China for fatting pigs over 110 Kg
• In China regulations there is:
• No difference in minimum indoor space required for guinea fowls while
fattening in fixed housing
• No specific square meter per 100 KG space required for bovine and
equidae over 350 Kg while breeding and fattening
• No minimum perch length given for laying hens (poultry)
• No Regulation in Chinese organic legislation for maximum number of
animals per ha equivalent to 170 Kg N/ha/year
EU Legislation
Chinese Legislation
Breeding and
fattening
bovine
Up to 100 Kg
< 100 Kg
Equidae
Up to 200 Kg
< 200 Kg
Piglets
Over 40 days and up to 30 Kg
> 40 days or <30Kg
Fattening
poultry in
movable
housing
6 in mobile poultry houses not
exceeding 150 m2 floor space with a
maximum of
30 kg liveweight/ m21
16 (Live weight ≤30kg/m2)
Class/species
Maximum no of animals per ha equivalent to 170 kg N/ha/year
Equines over 6
months
2
No regulation
Calves for
fattening
5
No regulation
Female
breeding
rabbits
100
No regulation
Table chickens
548
No regulation
Laying hens
230
No regulation
Poultry
C. Aquaculture Products and Seaweeds
• EU law more comprehensive than China
regulations
• State clearly requirements for aquaculture
products and seaweeds
Similarities:
• Seaweeds and Seaweed products – must be obtained from
physical process including dehydration, freezing and grinding
Differences:
• No Chinese legislation on production and use of fish and
other aquaculture species i.e. organic production of salmonids
in sea water
EU Legislation
Seaweed/ seaweed
products
Chinese Legislation
As far as directly
obtained by physical
processes including:
dehydration, freezing and
grinding; extraction with
water or aqueous acid
and/or alkaline solution;
fermentation
Seaweed/ seaweed
products
Obtained only by physical
processes including:
dehydration, freezing and
grinding;
Extraction with water or
acid and (or) alkali
solution;
Fermentation
Organic production of salmonids in freshwater
Brown trout (Salmo trutta), Rainbow trout
(Oncorhynchus mykiss) etc.
Production system
On growing farm systems
must be fed from open
systems. Flow rate must
ensure a minimum of 60
% oxygen saturation for
stock
No particular regulation in Chinese legislation
Maximum stocking
density
Salmonid species not
listed below 15 kg/m 3.
Salmon 20 kg/m 3
Brown trout and
Rainbow trout 25 kg/m 3
No particular regulation in Chinese legislation
D. Processed Agricultural Products for
use as feed
• Regulations between EU and China same with
some dissimilarities
• Few Chinese regulations that correspond to
EU law regarding some products
• Chinese law less stringent than EU law
Similarities:
• Regulations relating to vitamins added to feed as nutritional
additives
Differences:
• Few Chinese regulations control the use of processed agricultural
products for use as feed
• No Chinese regulations relating to use of antioxidants in feed for
animal nutrition
• Emulsifying and stabilizing agents, thickeners and gelling agents
(Lecithin) only derive from organic raw materials in EU
• No Chinese regulation governing flavoring compounds and where
they can be derived from
• Chinese regulations state what additives can be used, unlike EU
EU Legislation
Chinese Legislation
A. Emulsifying and stabilizing agents
ID Number
Substance
Conditions for use
1 E 322
Lecithin
Only if derived from
organic raw
material
No regulation
Flavoring
Compounds
Only extracts from
agricultural
products
No regulation
Sensory additives
2b
B. Feed materials of agricultural origin
Substance
No regulation
Propionic acid
Used only when weather
conditions fail to meet
sufficient fermentation
No regulation
Citric acid
Used only when weather
conditions fail to meet
sufficient fermentation
Use restricted to
production of silage
when weather
conditions do not
allow for
fermentation
No regulation
C. Silage additives
Yeasts and bacteria
E. Processed Agricultural Products For
Use As Food
• Chinese legislation less stringent
• Note – instances where Chinese legislation
articulated in clear and definite terms
Similarities:
• Products for processing ingredients of agricultural origin (hazelnut
shells, rice meal) not regulated in China nor EU
Differences:
• All gums, locust, guar, Arabic and Xanthan have specified uses
under China Regulations but not EU regulations
• Other additives (vegetable carbon) have no corresponding Chinese
legislation
• Products for production of yeast and yeast products (potato, starch)
not regulated in China
F. Vegetative Propagating Material and
Seeds for Cultivation
No reference to vegetative propagating material
and seeds for cultivation within current Chinese
legislation
G. Pesticides
Products allowed for pesticide under Chinese
Regulations highlight key differences between
EU and China
Similarities:
• Regulations regarding micro-organisms use for biological pest
and disease control,
• Substances used in traps/ dispensers
• Preparations to be surface-spread between cultivated plants
Differences:
• Significant amount of crop or animal origin permitted in
China, more limited in EU
• They include: osthole, berberine, emodin monomethyl,
natural acids…
• Of 26 substances for traditional use in organic farming
permitted for use in pesticides, only 14 used in EU
• Copper salts (copper sulfate, oxychloride) only used as
fungicides under China regulations
EU Legislation
Chinese Legislation
1. Substance of crop or animal origin
Hydrolyzed proteins
Only in authorized
applications in combination
with other appropriate
products
Hydrolyzed Proteins
Used in combination with
proper products stated in
this Appendix only under
the approved application
conditions
No regulation
Osthole
Insecticide and
bactericide
No regulation
Emodin
Bactericide
No regulation
Milk
Bactericide
2. Micro-organisms used for biological pest and disease control
Spinosad
Only where measures are
taken to minimize the risk to
key parasitoids
No regulation
3. Substances to be used in traps and/ or dispensers
Diammonium
phosphate
Only used in traps
Diamonium phosphate
Only used in traps
4. Other substances from traditional use in organic farming
No regulation
Calcium hydroxide
Fungicide
No regulation
Carbon dioxide
Insecticide
No regulation
Ethyl Alcohol
Bactericide
2. Control systems
• China and EU have equivalent procedures for
accreditation and certification of control
bodies and operators
• China’s procedures are in places more
stringent and detailed
Supervision of Control Bodies
• EU Competent Authorities carry out audits or
invite external audits, subject to external
review
• CNCA in China
– performs annual site audits market supervision
– Entry Export Inspection and uarantine Services
(CIQs) check product quality and labelling in the
market
– Same inspector cannot visit same unit more than
3 consecutive years
Risk-based Control Systems
• EU in addition to annual checks, further
checks on risk basis
– 10 percent minimum units receive random
additional inspections
• China after annual inspections further checks
according to risk profile
– 5 percent minimum units receive random
additional inspections
Non-compliance and Sanctions
• EU: non-compliance results in disqualification
of complete production run
– Severe infringement control body and competent
Authority agree to suspend for an agreed period
– Sanctions ‘effective, proportionate and dissuasive’
• China: detailed list of reasons for cancellation,
suspension and revocation of certificate
– Sanctions operators fined from rmb10,000 –
rmb30,000
Traceability
• EU traceability for organic food follows EU
traceability regulations for all food
– Operators must be able to trace and follow a food
. . through all stages of production, processing and
distribution
• China has, as of I July 2012, implemented a
17-digit electronic traceability system for all
organic food packaging that traces from origin
to distribution.