Select Committee on Agriculture Appendices to the Minutes of Evidence


Memorandum submitted by Mr John Hassett, Edward Billington & Son Ltd (F 6)


  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.


  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.


  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

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