Organic Certification Organisations are strange things; not unpleasant, far from it, but strange nevertheless. Organic Certification Organisations are civil not state structures, it varies from country to country, some are charities, others companies, some associations. They all have one thing in common, their primary income is their clients, that is us organic producers, transformers and resellers, in other words the people they control.

In most other situation this would be called a conflict of interests. The people who police the rules are literally in the pay of those that must obey the rules. In some cases it goes beyond that, the people who are paid by those they monitor actually set the rules. Should the role of organic control be run by an independent state structure rather than the present system. Would it be better for consumer confidence?

How does organic regulation  work?

Well the basis of organic rules in Europe are set by the European Union, proposals by the European Commission are debated and agreed by the agricultural Council Ministers, that is a Committee of all the national members Agricultural Ministers; then debated and approved by the European Parliament. This sets the basic rules for organic. If you obey these rules, and are certified by an authorised Organic Certification Organisation then you have the right to display the EU organic leaf logo on your produce, as well as the AB logo used here in France. The present rules for the EU logo guarantee that 95% of all the content of processed organic food is, by it’s definition organic.

Organic farming and production has been regulated at EU level since 1991. Today the European requirements for organic production are set by Council Regulation (EC) No 834/2007 defining the official aims, objectives and principles of organic farming and production, and by two implementing regulations (No 889/2008 and No 1235/2008) detailing the organic production, labelling and import rules. For the last three years there has been on an_going negotiations at a European level of an update to these regulations, a provisional text has been agreed and is now out for debate in member states and the European Parliament. It is rather controversial, see the UK’s Soil Associations take on it here To keep up to date the European Organic Trade Association IF OAM has a regular up date and commentary on developments.

The EU rules are the base line. And here is the key issue, organic regulations and organic farming should not be confused. Regulations are a product of the political process, and as Bismark once remarked “To retain respect for sausages and laws, one must not watch them in the making.”.  Organic regulations are a result of the Commission juggling the interest of the individual members states, the various industrial lobbies, from farmers, through transformers to resellers, consumer interests with the basic ideas of organic. Of course in the face of opposition from those who dismiss the very foundations of organic farming and production, like the large chemical companies, the “life science” lobby of the biotech companies, and last but not least the industrial farming lobby.

The regulations that this sauage factory throws out are therefore not compeletly conherent, and tend to be the lowest common denominator and no where near detailed enough to provide a compete guide to organic farming, transformation or reselling.

This is where the authorised Organic Certification Organisations come in. The European Union itself has no presence on the ground, it does not enforce the rules it sets. That is up to member states. In the organic field this usually farmed out to the government authoritzed Organic Certification Organisations, over seen by the relevant Ministry or regulatory body, here in France that is Agence française pour le développement et la promotion de l’agriculture biologique, usually, and thankfully, shorten to Agence bio.

The Organic Certification Organisations have a difficult job on their hands, namely how to transform the EU rules into a coherent regulatory regime that organic producers can follow;

For most this is an on-going process. The UK Soil Association, for example, has a number of standing Expert Standard Committees which report into a Standards Board, that in return report to the Association’s Board of Trustees. These Expert Standard Committees comprise of organic experts, soil association producers, researchers, as well as consumer representatives and are chaired by an independent chair.

Their role is to maintain a coherent organic regulatory regime for their sector, engage with and deal with new regulations emerging from Brussels. As the range of organic produce increase they also have to create the regulatory environment for these new sectors of production. Particularly in the case of the Soil Association they do not just see their role as interpreting the EU rules but augmenting them. The animal husbandry rules of the Soil Association are way in advance of thse minimal European rules and are often claimed to be the most humane in Europe.

A good example of the development of a new organic standard is my friend Gilles Roquefort. Gilles is an old director of the Port Authority at Porte Vendre. He had a dream about raising organic snails, the Catalans love snails. So he invented an entire system for raising snails in an organic manner in polytunnels. His system is completely new and is a major departure from traditional snail growing systems. He called in EcoCert to go through the system; They were completely out of their depth, never having controlled such a system. They took the basic organic rules, and working with Gilles, they went through his production from start to finish to verify that it obeyed the spirit of the regulations, which it did in buckets. There is now a new set of guidelines for organic snail production here in France, primarily developed not by the authorised Organic Certification Organisations, but by Giles.

In each country there are a number of authorised Organic Certification Organisations, some stick to the EU regulations, others like the UK’s Soil Association are EU regulations plus, another is Demeter, which take the EU regs as a base point but concentrate on biodynamic techniques. A combination of more hard core organic practices and voodoo science.

As an organic producer you can choose which organisation controls your production, so you can pick one that simply applies the EU regulations or you can pick one that goes beyond the regulation and is closer to what organic agriculture really is. Of course as a producer the regulations represent the base line, you can choose to go way beyond the rules, or you can decide just to stick to the baseline.

So what does that mean, well simply put cost. The closer you get to using pure organic techniques the more costs you incur, so the more expensive your final produce. For farmers these costs are not necessary a question of materials, though they can be. Take water, a rather crucial element in agriculture. Unless you are completely isolated from industrial farms there is a high chance that your water contains traces of herbicides, pesticides and fungicides, not from your activities but from your neighbours. Chemicals have a habit of migrating. Take the rules here in France for organic wines, an organic vineyard needs to keep thee rows of vines between the organic crop and an industrial neighbour. Three rows? Given that with a wind chemicals that are sprayed can travel up to 12 kilometers you have both air born contamination and water born contamination to deal with. Water contamination can be dealt with bu installing a filtering system, which cost but air born contamination is impossible to control. The other key cost the closer you get to real organic production is labour. We have an expression here in France, it is Getting off your tractor. The chemicals used in industrial production partial replace work, they do other things as well, like pest control that in organic farming you try and counter with crop rotation, companion planting, soil management, and natural solutions all of which take time and labour.

So we have a problem; organic labelling can mean a range of production, some more organic than others depending on the regulations decided by the Organic Certification Organisation. Some have done a lot of work on consumer education, both the Soil Association and Demeter can put in a huge effort to win the arguments on Organic plus. But it is a drop in the water and the debate does not travel much beyond the already converted. The key argument is still the advantages of organic over industrial production, and that is still an uphill battle.

Let’s get back to the issue of certifier’s role as controllers of organic production.

I will use our control as an example of how it works. As you may already know here at the Domaine de Montrouch for the last seven years we have been producing organic herbs in pots, which we sell in a various weekly markets here in the Languedoc and across the border in French Catalonia, and at a number of organic festivals. For the last seven years we have been controlled by EcoCert, one of the world’s largest authorised Organic Certification Organisation. When we started out we did not pass through the usual three year transition period, the Domaine land had not been worked for 40 years before we started so we were able to pass direct to organic production. Our production is pretty straight forward, we buy organically certified soil from agricultural suppliers, the plants themselves are either grown from seeds, which we buy from certified organic suppliers, or from tip or root cuttings from mother plants, these mother plants were originally bought from fellow organically certified plant growers. A few plants I found on our land growing wild. Our water comes from a marsh above us on Mont Tauch. We are two kilometers away from the nearest vines below us and have no neighbours apart from the sangliers; wild pigs.

To start with the controller from EcoCert visited our land, asked a number of questions about our project and the history of the land. Once they were satisfied with our answers they agreed that we could go direct to organic production without any transition period. No soil or water tests were made, no proof of what we were saying was asked for. However one look at our forest and over grown land is sufficient to see what we were saying was true.

Now every year we are controlled in situ by an EcoCert controller, the control itself is a simple enough affair. First we sit down and the we hand over all our receipts for the soil and seeds we buy every year along with a copy of the organic certification of the various suppliers. Any new mother plants we have acquired that year also have to be documented along with a copy of the organic certificate of the various suppliers. After going through the paper work we then do a tour of the plants, with the controller checking the list of plants we grow against the list of certified plants on our organic certification, though we do have a line on our certificate that says “et autres” which is a sort of get out of jail free card for any plants not on the list. Though to be fair any “autres” still need proof of origin and the appropriate supplier organic certificate.

That is our annual in situ control. We are a pretty simple producer, and the control is simple but comprehensive.

EcoCert also control organic producers in markets. We do three markets a week, Lezignan-Corbieres on Wednesday, and Narbonne Organic market and the local producers market in Perpignan on Saturday. Twice a year an EcoCert controller passes by each market, they check that you are displaying the correct signs and logos for organic production, they also check that our organic licence is on display, and most important that the produce you are selling as organic are actually on your list of produce you produce. We are allowed to sell non organic produce, or organic produce we have not produced. However non organic produce should not exceed 5% of sales, and needs to be clearly marked as not certified organic. If we sell third organic production we should also display a copy of the producers organic certificate.We don’t sell any third party products but for vegetable producers, who have holes in their annual production cycle this right can be a life saver.

In my opinion this helps ensure that consumers can have confidence in the organic supervision of our production.

As I said our control is a simple matter, for others it is much more complicated. Caroline has a lovely colleague who has the stand next to her in the market in Narbonne, Elizabeth. Elizabeth is an ex Michelin star chef who ran a starred restaurant in Brittany. Sadly her husband died, she is convinced it was the stress of the Michelin system that did him in. Anyway she has come down to the Languedoc to look after her aging Mum. To keep her sanity, and because she lives to cook, she rattles pans in the kitchen all week and comes to the market with a range of delicious produce, from home made smoked organic salmon, Foir Gras, to jams, rice pudding and Spice cake. Every week she has to send of the recipes to EcoCer along with the organic certication of every ingredient that goes into the food, EcoCert then confirm what she can sell as organic and what she can’t. Now that is complicated and time consuming, but it means that her customers can have total confidence that they are buying organic.

Compare that to the controls in markets by the Veternairy service charged with food safety. In the seven years I have been doing markets I have seen them control prepared food stands precisely once.

Or for that matter the anti Fraud controllers.I have never seen an anti Fraud controller in any market. I have colleagues in markets who sell a range of produce, some organic some not, the organic produce is clearly marked organic, the other has no signs. The implicit inference is that all the produce on the stand is organic, it isn’t. There have been a number of TV consumer programmes about organic produce in markets, and how some unscrupulous resellers pass off non certfied produce as organic. We need more anti Fraud controls to restore consumer confidence.

So here is the rub. Should we be regualted by the existing bodies or by a totally independent state body?

Well there will always been things that can be done better, I strongly believe that water supplies should be tested annually, as should soil. Soil is memories, you can lie to an organic certifier but the soil can’t. Saying that we are regularly controlled both at source and in markets.

The state organications responsible for food safety and anti Fraud are nowhere near as rigorous, or regular.

In this period of huge cut backs in state funding at all levels there is no indication that the levels of control will improve. Ask any Food and Standards officer in the UK is they are confident they are on top of the situation in their area and an honest one will throw up their hands in dispair, there are not enough resources to do the job.

The present system is not perfect, but it is a lot better than anything else available.

Useful Links

IFOAM – European Organic Trade Association

Agence bio – Agence française pour le développement et la promotion de l’agriculture biologique

Soil Association – the UK’s leading organic certification body

Demeter – biodynamic organic certification

EcoCert Our Organic certification controller

Domaine de Montrouch Organic Certification – our organic certificate