Memorandum submitted by the Provision
Trade Federation (F 33)
1. Provision Trade Federation (PTF) members
are companies of all sizes involved in supplying bacon and ham;
chilled and processed meats; dairy products of all kinds, including
milk powders, cheese, butter, yogurt and other dairy desserts;
and canned foods. Our members include importers and exporters
of these products, as well as UK processors.
2. We are aware that the volume of organic
products handled in the UK is currently relatively small but the
market is expanding rapidly. The growing demand for organic products
cannot be satisfied by UK products and the shortfall is being
met by imported products.
3. An increasing number of PTF members are
involved in importing or processing organic meat and dairy products.
The areas in which these members are experiencing particular difficulties
are in the variations in standards across EU Member States and
the delays in obtaining approval from certification bodies.
4. EC Regulation 2092/91 on organic production,
as amended by EC Regulation 1804/99, introduces minimum standards
for organic production of livestock and livestock products marketed
in the EU, but permits each Member State to impose, on producers
in its own territory, conditions on organic livestock production
which are stricter than those specified by the EC Regulation.
5. A number of Member States intend to take
advantage of the opportunity to impose stricter standards when
the amendment to the Regulation comes into force in August 2000.
Thus, for example, UK producers of organic livestock will be required
to ensure that all meat animals are born and bred on the organic
farm. In contrast, the EC Regulation permits the conversion of
meat animals, for example conventional dairy cows and pigs may
be "converted" to organic over a 6-month period. Meanwhile,
other Member States will be introducing the minimum standards
with minor, but different, alterations. Thus, we understand that
the German standards will impose more strict requirements in terms
of animal feed than those set by other Member States.
6. Under EC Regulation 2092/91, in order
that a product may be described as organic, it must be approved
by a certification body. Each of the six UK organic certification
bodies has a set of standards which are based on the UK standards,
as a minimum, but to which they may add extra specifications.
Most notably, the Soil Association Certification Limited has very
stringent requirements which must be met before suppliers can
use the Soil Association logo.
7. There is no requirement for importers
to the UK, from other EU Member States, to be approved by one
of the UK certification bodies if they are to be sold direct to
the consumer without further processing in the UK and if the product
has already been approved by an equivalent inspection organisation
in another Member State. However, the differing standards could
create barriers to trade in organic livestock and livestock products
that are imported to the UK for further processing. For example,
the differences between conversion periods for dairy cattle could
hinder trade in imports of organic milk for further processing
to cheese and yogurt in the UK.
8. The differing standards cannot be in
the interests of the consumer who will become confused about the
true definition of an organic product, particularly as some of
the differences appear to be arbitrary. It is hard to imagine
that consumers will be able to appreciate the subtle differences
in standards that may actually be very costly to the producer.
This situation will inevitably lead to tensions between national
producers and importers, each claiming that they are suffering
a competitive disadvantage because they have to meet stricter
9. For these reasons, we believe that an
EC Regulation to which all Member States must adhere would be
preferable to minimum standards that may be gold plated by individual
10. In order to sell "organic"
products in the UK, approval must be sought from one of six approved
organic inspection bodies. The Soil Association, which is the
largest of the certification bodies in terms of membership, appears
to have been overwhelmed by the increased demand for organic foods,
and the resultant need for inspections and approvals. This has
led to considerable delay in achieving Soil Association approval
for organic products, particularly those that are imported.
11. A recent example involved a PTF member
who wanted to import organic pigmeat from Denmark for further
processing in the UK. The company achieved Soil Association approval
for the UK factory within a month, but they are still waiting,
five months after the original application, for Soil Association
approval of the Danish pigmeat. The Soil Association has submitted
the application to "the next Committee stage" for further
consideration of the acceptability or otherwise of nose rings.
In the meantime, the company approached another
certification organisation (Organic Farmers and Growers), who
approved the product and forwarded the certificate to the company
within 12 days.
Although efforts have been made to encourage
co-operation between these certification bodies, some have argued
that a more unified certification scheme, with one inspection
body, would bring considerable benefits to the sector as a whole,
in terms of efficiency in inspections and approvals.
13 June 2000