APPENDIX 5
Memorandum submitted by Mr John Hassett,
Edward Billington & Son Ltd (F 6)
CREDENTIALS
1. My company has been involved in the processing
and distribution of organic food for the past 17 years.
2. Billington's is now the largest importer,
processor and distributor of organic cane sugar in the EU, and
supplies organic food manufacturers and retailers throughout the
Community.
3. I was a founder member of the UKROFS
Board and sat on it until early last year when I was "Nolanised".
4. I was chairman of the UKROFS Processors'
Committee which wrote the UKROFS organic processing standards
prior to the UK's adoption of EU Regulations 2092/91.
5. I was chairman of the UKROFS R&D
Committee for six years.
6. I continue to serve UKROFS as a member
of the Certification and Technical Advisory Committees.
COMMENTARY
7. Regulation 2092/91 is concerned principally
with the growing of organic food. Almost all organically grown
produce is processed to some extent before it is offered for sale
to customers. At its simplest this includes activities such as
washing and drying, often conducted on farm. At its most complex
it covers the transformation of raw organic produce into multi-ingredient
finished products using approved processing aids, additives and
other non-organic ingredients.
8. The Regulation deals adequately with
simple processing, but apart from supplying approved lists of
processing aids, additives and non-organic ingredients, and establishing
the principle of separation of organic from conventional processing,
it is largely silent on the subject of complex processing. How,
for instance is separation to be achieved in a plant used to make
both organic and conventional foods using a continuous (as opposed
to batch process)? I understand the Commission is aware of this
weakness in the Regulation and plans to introduce more comprehensive
processing standards at some stage.
9. Many food manufacturers in the EU have
spotted a marketing opportunity in the organic sector, and have
started to produce organic versions of their regular offerings.
The majority want to use their conventional plant to make their
organic products, but unfortunately the process is often unsuited
to organic production because it requires processing aids or additives
not approved by the Regulation.
10. Under pressure from manufacturers the
Commission has approved a growing number of processing aids and
additives for use in organic production, including several substances
about which there is consumer concern.
11. After representations on behalf of the
German sugar beet processing industry, the Commission approved
the use of Sodium Hydroxide and Sulphuric Acid for processing
beet suger. Beet sugar can, and has been produced in the past
without these substances, but not in today's large plants, and
not to the same degree of clarity and "whiteness" as
conventional refined sugar. Incidentally, organic cane sugar is
produced without recourse to any processing aid other than lime.
12. Under pressure from several meat processors
UKROFS approved Sodium Nitrate, a known carcinogen, for making
bacon and ham. The traditional curing aid, Saltpetre was already
on the approved list, but processors do not like working with
it because its performance is less certain. Unfortunately, this
approval gave rise to adverse comment in the national press.
13. Relatively few processors subscribe
fully to the organic ethos, and as the market grows they will
become an ever shrinking minority. The Commission should not dilute
organic processing standards any further for the convenience of
mainstream food manufacturers rather than necessity.
14. There is evidence already that the Commission
and UKROFS have given processors an easier ride than farmers.
They have steadily tightened farming standards while adding to
the list of approved processing aids and addictives to help food
manufacturers get round their processing problems.
CONCLUSIONS
15. The Commission should take great care
not to undermine the integrity of organic food in the consumers'
eyes by permitting the use of inappropriate processing aids and
additives in order to help processors. The three-part test should
be: is this substance essential (rather than helpful) to the process.
Could the end product be produced in another way without it, and
finally does it use accord with organic principles?
16. The Commission should review its processing
standards and introduce more detailed rules for complex processing.
1 June 2000
| 
