One step forward, one step back. That is how OPTA Europe assesses the latest developments in the revision of the EU Organic Regulation as negotiations move into the final phase.
Last year, the European Commission proposed a targeted revision of the Organic Regulation with the stated objective of strengthening the competitiveness of the organic sector. At the time, OPTA Europe—the Organic Processing and Trade Association—welcomed the Commission’s efforts to simplify the regulatory framework. However, it also warned that key elements of the proposal, particularly those affecting international trade, represented a significant step backwards.
Where Does the Revision of the Organic Regulation Stand? Now that both the Council and the European Parliament have adopted their respective positions, the legislative picture has become clearer.
Positive developments for smallholder farmers
OPTA Europe welcomes the improvements introduced by both institutions regarding the eligibility criteria for groups of operators. The revised provisions will help safeguard the participation of smallholder farmers in the EU organic market by expanding the alternative eligibility criteria.
OPTA Europe welcomes the improvements introduced by both institutions regarding the eligibility criteria for groups of operators.
Trade provisions raise fresh concerns
Both the Council and the European Parliament have endorsed the Commission’s proposal to extend the duration of the existing organic equivalence agreements, although the length of the extension remains to be agreed. While welcoming this important step, OPTA Europe is concerned by the more restrictive approach both co-legislators have taken on trade. The Council and the Parliament have supported the Commission’s proposal to introduce additional conditions for imported products and ingredients to qualify for the EU organic logo under the existing equivalence arrangements.
In addition, they have removed the proposed 5% tolerance that would have allowed the use of non-compliant ingredients sourced from equivalent third countries in processed organic foods bearing the EU organic logo.
For OPTA Europe, the contradiction is difficult to ignore. While all three EU institutions seek to preserve the existing equivalence agreements by extending their duration, they are simultaneously proposing unilateral changes to the conditions under which those agreements operate, apparently assuming that trading partners will accept the revised terms.
For OPTA Europe, the EU institutions’ efforts to preserve the existing equivalence agreements by extending their duration are contradicted by their proposal to unilaterally alter the conditions under which those agreements operate, apparently assuming that trading partners will accept the revised terms.
The implications could be far-reaching. The proposed changes risk undermining long-standing trade arrangements with key partners such as Japan, Canada and the United States, and could expose EU organic exports to retaliatory measures. “If major export markets such as the United States consider these changes to be a unilateral modification of the organic equivalence arrangements agreed with the EU, there is a real risk of retaliatory measures against EU organic products,” said Aurora Abad, Secretary General of OPTA Europe. The United States alone imports around €1.1 billion worth of European organic products each year, resulting in a substantial trade surplus for the EU. It is therefore in the EU’s interest to preserve stable and predictable trade relations with its key trading partners.
Traceability challenges and transitional measures remain overlooked
Beyond the trade implications, OPTA Europe also regrets that none of the EU institutions has fully addressed the practical consequences that these changes would have for certification, traceability and controls. Whether the permitted share of non-compliant imported ingredients is set at 5% or reduced to zero, operators throughout the supply chain will still need to distinguish between ingredients that meet the additional EU requirements and those that do not. This will require changes in the traceability systems and the continuous transmission of relevant information from the origin of the ingredient through to the final food manufacturer. Such obligations will inevitably require adjustments to secondary legislation governing certification and controls, as well as a sufficient transitional period for EU and third countries’ operators to comply with the new rules. Yet, this essential implementation work and transitional measures have received little attention during the legislative process.
Looking ahead to Trilogue
As trilogue negotiations between the European Commission, the Council and the European Parliament begin, OPTA Europe hopes that the final text will preserve the positive progress while minimizing unnecessary disruption to international organic trade.
At present, however, the outlook remains mixed. The revision contains genuine improvements, but also introduces new uncertainties for international trade and significant implementation challenges for operators. Unless these concerns are addressed during trilogue, the final outcome risks delivering exactly what the sector sought to avoid: some steps forward—and some steps back.
Author: Aurora Abad, Secretary General of OPTA Europe.
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