Memorandum submitted by Mr Geoffrey Hollis
This memorandum is submitted in response to
the Committee's press notice No. 25, dated 5 May 2000. I am particularly
concerned about the methods used to market organic food, which
are often very misleading, and can be illegal. In my view they
damage public health and increase health inequalities.
My interest stems from 1989-91, when I was the
head of Pesticides Safety Division in the Ministry of Agriculture.
My task was to ensure that food produced using pesticides was
safe. Currently I am a non-Executive Director of East & North
Herts Health Authority, which gives me some insight into public
EU law prohibits claims which suggest that organic
food is somehow better than conventionally produced food. Article
10, paragraph 2, of Council Regulation No. 2092/91 states "No
claim may be made on the label or advertising material that suggests
to the purchaser that the indication "organic" constitutes
a guarantee of superior organoleptic, nutritional or salubrious
quality." ("Salubrious" is not a good translation
of the French original"wholesome" is nearer the
meaning). The intention of the Regulation is to make clear that
the description "organic food" is a definition of origin,
not a guarantee of any kind of quality. This Regulation is directly
applicable in the UK.
Increasingly advocates of organic food are overstepping
this line, and much publicity material now suggests that organic
food is somehow good for consumers, and definitely superior to
conventionally produced food.
As an example, I enclose details [not printed]
of a recent complaint which I made against a [not printed] booklet
by Tesco supporting its range of organic foods. Enclosed are the
verdict of the Advertising Standards Authority [not printed],
which upheld all three elements of my complaint, and extracts
[not printed] from The Independent newspaper of 10 May which reported
Since then I have also complained to the Authority
about a similar brochure put out by Sainsbury's, which is if anything
worse than the Tesco one. It makes similar misleading claims about
the use of chemicals in organic food, and its "slightly increased"
price. In addition, it claims that organic livestock farming does
not use veterinary medicines, which is untrue. Most damagingly
it contains the allegation that organic foods are "good for
you". This is contained in a paragraph written by the Director
of the Soil Association, and is clearly illegal. My understanding
is that the Authority has written to Sainsbury's asking them to
change all these claims.
I have considerable evidence of other attempts
by the Soil Association and supporters of organic food to suggest
that conventional food is less safe than organic food. Also attached
is a piece headed Right of Reply [not printed] from the Independent
of 12th May, written by the Director of the Soil Association.
Mr Holden asserts that there is "growing evidence of cost
to public health" from "intensive chemical farming".
He also mentions "NHS costs". This is completely without
foundation. If necessary I can provide similar claims to the Committee.
Supermarkets have a commercial interest in puffing
organic food, since independent surveys show that a typical organic
shopping basket costs around 70 per cent more than a conventional
one. This gives a much higher cash flow, which boosts their profits,
and probably increased gross margins too.
The Soil Association also have a vested interest
in misleading consumers into believing that organic food is somehow
better for them. Although the Association is a charity, it has
a commercial subsidiary which gains revenue from certificating
organic farmers for a fee.
These attempts to persuade consumers that organic
food is "safer" and more desirable than conventional
food are, in my view, extremely damaging. There is no proof that
consumers benefit from eating organic food. Indeed there have
been suggestions that the use of animal manure on organic farms
presents a risk of contamination with E.coli 0157. My concern
is that consumers will be conned into believing that organic food
is better for them and will therefore eat less fruit and vegetables
than they otherwise would do, because of the increase in cost.
This is especially true for poorer consumers, who tend to eat
less well than richer people, and who have worse health as a consequence.
The Ministry of Agriculture and the Department of Health have
both stressed the importance of fruit and vegetables in the national
diet. Attempts to mislead consumers about the benefits of organic
food are therefore likely to hurt public health, and increase
9 June 2000