To:
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Environment
& Sustainability Committee
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Date:
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24 October
2014
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Ref:
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Circulation:
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Contact:
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Rachel
Lewis-Davies
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Tel:
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01982
554200
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Fax:
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Email:
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Rachel.lewis-davies@nfu.org.uk
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NFU
Cymru response to Environment & Sustainability Committee
Inquiry -
Organic
Production and Labelling of Organic Products
- NFU Cymru
welcomes the opportunity to respond to the Environment &
Sustainability Committee Inquiry into Organic Production and
Labelling of Organic Products. We have serious concerns about
the legislative proposals for the new organic regulation and
organic action plan which, we believe, will have negative
consequences for organic farmers in Wales.
The impacts of proposals on the organic sector in Wales
- NFU Cymru has a
number of concerns with proposals. These include:
- The ban of
mixed farms;
- The ban on the
use of conventional seed and plant reproductive
material;
- Changes to the
origin of animal feeds;
- Ending the
possibility of using non-organic animals for breeding
purposes;
- The ban on
dehorning;
- The plans to
introduce residue thresholds;
- Abandoning the
requirement to have yearly controls;
- The use of
delegated acts to define essential aspects of the regulation
including authorised plant protection products.
- Under
proposals, farmers will no longer be able to grow both organic and
conventional produce and the whole farm business will have to be
100% organic before any produce can be marketed as such. We
believe this rule will discourage new entrants to the organic
sector as operating a mixed holding and converting gradually
enables farmers to remain commercially viable during the
challenging period of conversion.
- Statistics show
that presently approximately 25% of organic farms in the UK also
produce conventional produce so proposals will potentially force
out a significant number of existing organic farmers who currently
operate mixed holdings. We would highlight that both parts of
mixed farms are inspected by UK organic certification bodies so we
can be confident that mixed holdings do not increase the risk of
fraud.
- No figures have
been provided by the Commission on the proportion of farms across
the EU who currently operate mixed holdings (organic and
conventional). We believe that the full impact of this
proposal on the organic sector has, therefore, not been fully
considered.
- Proposals to
ban the use of conventional seed and plant reproductive material
mean that organic farmers will have to use 100% organic seed.
Proposals assume that sufficient organic seed will be available in
the varieties that organic farmers want. This is not the case
and there is a need to recognise that as organic seeds are more
susceptible to disease, supply is limited as few seed producers
risk producing them.
- At present it
is possible to use untreated conventional seed and this activity is
overseen by the certification bodies. Disabling organic
farmers from doing this could potentially result in no crops being
planted, in seasons where disease is an acute problem. We
would highlight that issues over organic seed supply will be
exacerbated by the new proposals to ban mixed holdings as seed
producers are typically mixed to offset risk.
- Setting a
higher obligation to source 90% of animal feed for herbivores and
60% for pigs and poultry from the holding itself or the region is
of concern to NFU Cymru. The current levels are set at 60%
and 20% respectively. We would highlight that proposals do
not take into account the consequences of adverse weather
conditions, nor do they recognise that certain regions, including
many areas of Wales, are not suited to the growing of protein
crops.
- We would also
highlight that the proposals do not make it clear what is meant by
the local region and, we understand, that Member States currently
use different interpretations.
- NFU Cymru would
highlight that there has been significant progress towards sourcing
100% of organic inputs in recent years and we believe many organic
producers in Wales would like to grow more or source more feed
locally. However, this is often not possible given farming
practicalities and these obligations, therefore, appear
unachievable. They also challenge standards of nutrition and
animal health and welfare, especially in areas where it is not
possible to grow quality protein crops or in areas affected by poor
harvest through flooding or drought for example.
- Ending the
possibility to use non-organic animals for breeding purposes
present organic producers with similar supply problems to those
experienced with sourcing organic seed. Current rules allow
for producers to source a small proportion of non-organic animals
for breeding purposes.
- NFU Cymru
believes proposals will have particularly severe impacts in Wales
where livestock production systems predominate. Poultry
producers will also be unable to introduce less than 3 days
non-organically reared poultry. The proposal will lead to a
dramatic fall in the supply of genetic material available to
organic holdings and we understand that proposals may impact on
organic producers being able to utilise common grazing over the
summer months.
- The proposed
ban on dehorning cattle is of concern to NFU Cymru. Dehorning
is currently allowed in the UK and is carried out with great care
and under conditions that respect animal welfare. It is an
effective method of preventing livestock harming themselves, each
other and those who work on or visit farms. A ban would
compromise animal welfare, worker and public safety as well as
deter organic producers from using certain breeds. We seek
clarification from the Commission as to whether this includes
banning the practice of de-budding also.
- Clarification
is also needed on other practices such as tail docking, spur
removal etc and whether such practices will be permissible under
the new regulation.
- Proposals seek
to introduce residue thresholds meaning that where organic products
exceed a certain residue threshold of a prohibited substance they
lose their certification and subsequent premium
price.
- NFU Cymru would
highlight that there are a range of reasons to explain the presence
of residues of plant protection products including drift from
neighbouring fields, substances remaining in the soil, presence in
storage installations, during transport or at the processing
line. Organic farmers could, therefore, be significantly out
of pocket for issues that are outside their
control.
- Given that
organic farming in Wales is limited to approximately 8% of land
area, the risk of plant protection residues being detected cannot
be ruled out, despite the best efforts of organic
farmers.
- NFU Cymru
believes that the current regulatory system for testing and
investigating the presence of non-authorised residues is a thorough
approach that does not accept the presence of any unauthorised
substances. Where unauthorised substances are found, at
whatever level, an investigation is carried out to find the
cause.
- NFU Cymru would
highlight that, at present, organic certification is an assurance
against the use of unauthorised pesticides. We do not believe
the presence of non-authorised products or substances in organic
systems should be threshold targeted.
- NFU Cymru
recognises that an annual inspection regime offers a number of
significant benefits, not least maintaining a level of consumer
confidence. We also accept that, in reality, even if the
Regulation did not specify the need for annual inspections, the
major retailers would demand this. Annual inspections can
help to maintain a regular link between certification bodies and
producers which is not only important in facilitating effective
knowledge exchange but is also vital for organic farmers to show
consumers that they meet the organic standards.
- NFU Cymru
believes there may be opportunities within the inspection regime to
adopt an ‘earned recognition approach’ whereby those
producers that run low risk operations and regularly update their
records online get recognition for this through the adjustment of
risk category and less frequent inspections as a
result.
- NFU Cymru is
concerned that the current legislative proposal does not provide a
clear picture of how the regulation will be implemented leading to
considerable uncertainty for organic producers.
- A case in point
is Article 19 – Authorisation of products and substances used
in organic production. The list of authorised plant
protection products and list of fertilisers, soil conditioners and
nutrients are currently unknown as the proposal seeks to deal with
this via delegated act. It is our view that this part of the
regulation should not be dealt with by delegated act.
Recommendations for changes to the legal proposals
published
- NFU Cymru would
recommend the following changes to the legal proposals published by
the Commission for the new organic regulation:
- Mixed farming,
correctly defined and monitored, should continue to be allowed
under the new Regulation.
- The current
derogation, which allows the sector to use conventional seed
especially during times of limited supply should be
maintained. The development of the organic seed market should
be supported and this could be achieved through charging a levy on
sales, paid by those purchasing non-organic seed into the
sector.
- As it is not
presently feasible to increase levels of locally sourced feed to
90% for herbivores and 60% for pigs and poultry in Wales, the
current levels of 60% and 20% respectively should be
retained.
- The possibility
to bring a proportion of non-organic animals for breeding purposes
onto a farm must be retained
- The practice of
dehorning and de-budding should continue to be permissible under
the new regulation
- NFU Cymru is
not in favour of the introduction of residue thresholds for
non-authorised products or substances
- The requirement
for yearly controls through annual inspection should be retained so
consumer confidence in organic produce can be maintained and
consideration should be given to less frequent inspections based on
the concept of ‘earned recognition’.
Future organic production in the EU
- NFU Cymru would
highlight that during the last decade demand for organic produce
from EU consumers has quadrupled while land under organic
production has only doubled, imports from outside the EU have been
required to make up the shortfall.
- Globally, the
organic market has seen growth of 25% in the past three years with
a significant increase in spend on organic products by the under
35’s age group
- In this
context, NFU Cymru believes that there are opportunities in Wales
to achieve a viable, profitable market for Welsh organic produce,
however, the development of the sector must be market-led and a
premium for organic produce must be realised in the market place in
order to offset the increased cost of production.
- In Wales,
organic producers have been hindered by a period of uncertainty
which has led to a lack of confidence in the sector. Some 20%
of farmers surveyed by the Organic Centre Wales in 2013 indicated
their intention to cease farming organically. Levels of
uncertainty have subsided in the short-term following the
introduction of the Glastir Organic Scheme recently which has
offered the sector a degree of stability. However, the new
legislative proposals put forward by the Commission can only serve
to escalate levels of uncertainty and undermine confidence in the
sector going forward.
- NFU Cymru has
expressed concern with respect to the requirements for the
preparation of an Organic Business Plan to support the application
to Glastir Organics. We would also highlight that, given the
current Farming Connect programme is under review and coming to an
end at 31st March 2015, the expectation to complete business plans
by the end of 2015 may not be possible. With the new
programme still in the early stages of development, we would ask
what provision has been considered to support farmers in the
preparation of business plans through this period of transition,
should they wish to access this type of advice.
- We would
further highlight that given the current review of Farming Connect,
NFU Cymru strongly believes that farmers should be permitted, in
fact encouraged, to formulate their own business plan without the
need to involve a consultant if they so wish. This requires
Welsh Government to supply very clear guidance and a template of
what the requirements are and also an acknowledgement of the value
of engaging farmers fully in the business planning
process.
- We also note
that other areas of RDP support such as Sustainable Production
Grant will be conditional on submission of a business plan.
The situation whereby farmers have to complete multiple business
plans to access various aspects of RDP funding is onerous, time
consuming and inefficient. We note that the business planning
requirements for Glastir Organics are currently under consideration
and we wonder what consideration there has been of designing this
so that it meets the range of other requirements and
demands.
- Overall, NFU
Cymru believes the legislative proposals will lead to increases in
costs of production and challenge the ability of organic farmers to
continue to farm organically. Conventional producers are also
likely to be discouraged from joining the sector. The outcome
is likely to be a sharp and sustained decline in organic production
which runs contrary to the aims of the Commission which is
primarily focussed on helping to grow organic production and
consumption levels across the EU.
- We note the
invitation to submit oral evidence to the Committee on Thursday
13th November. NFU Cymru look forward to giving
evidence at this event.