Select Committee on Agriculture Appendices to the Minutes of Evidence


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 standards.

  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 Member States.


  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

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