No C 182/12 Official Journal of the European Communities 23. 7. 90 
previous season. This consideration emphasizes the fact 
that freight transport is different from passenger 
transport, 
— the Committee suggests that, while transparency in 
aircargo rates is a worthy objective, it should be 
achieved by reference to the base price, similar to the 
reference tariff in road transport. This could be 
supplemented by periodic checks on the part of Member 
States to establish the level of airport-to-airport rates 
being charged. 
4.6.3.3. The Committee therefore suggests that this sub­
paragraph should be amended so as to avoid the 
introduction of new restrictions and maintain flexibility in 
pricing, while at the same time ensuring that safety 
standards are maintained by the appropriate methods. 
1. Introduction 
1.1. Organic agriculture is defined in the dictionary as: 
'Agriculture which does not use chemical fertilizers or 
pesticides'. 
1.2. Terms like organic, biological, environmental etc. 
were applied to their methods of production by committed 
groups of alternative producers who evolved detailed rules 
of production and sold their produce mainly directly or 
through specialized 'health' shops. 
1.3. In recent years however these products have been 
marketed very much more widely to consumers in general 
(!) OJ No C 4, 9. 1. 1990, p. 4. 4.6.4. Sub-paragraph 4 
4.6.4.1. In view of the amendments proposed for sub­
paragraph 3, the Committee considers that sub-para­
graph 4 is unnecessary. It therefore suggests that sub­
paragraph 4 be deleted, as its provisions would hamper the 
commercial development of airlines. 
Done at Brussels, 30 May 1990. 
The Chairman 
of the Economic and Social Committee 
Alberto MASPRONE 
who do not know the detailed rules of production but 
believe organic food is produced strictly in accordance with 
the dictionary definition. 
1.4. Organic, biological, ecological etc. have thus 
become excellent marketing terms, suggesting that the 
products are more wholesome, natural and healthy than 
normal ones and that the latter are somehow inferior. 
1.5. There is generally no detectable difference sufficient 
for control purposes, between organic and normally grown 
foods. However, since many consumers believe that 
organic foods are more wholesome and are therefore 
prepared to pay the appreciably higher costs which are 
required to produce them. 
1.6. The higher costs arise because organic methods of 
production reduce yields considerably, increase visual 
defects and result in higher waste because pests cannot be Opinion on the proposal for a Council Regulation (EEC) on organic production of agricultural 
products and indications referring thereto on agricultural products and foodstuffs (*) 
(90/C 182/04) 
On 16 December 1989 the Council decided to consult the Economic and Social Committee, under 
Article 198 of the Treaty establishing the European Economic Community, on the abovementioned 
proposal. 
The Section for Agriculture and Fisheries, which was responsible for preparing the Committee's 
work on the subject, adopted its opinion on 15 May 1990. The rapporteur was Mr Kenneth 
Gardner. 
At its 277th plenary session (meeting of 30 May 1990) the Economic and Social Committee adopted 
the following opinion unanimously. 
23. 7. 90 Official Journal of the European Communities No C 182/13 
combatted as effectively. Organic production should 
benefit several objectives of the Common Agricultural 
Policy, though to an extent which is always likely to be 
small. Organic production is always likely to be attractive 
and possible to a minority of farmers only. 
1.7. In these circumstances where higher prices have to be 
charged for differences which cannot be verified by 
independent tests, it is essential to have a proper system of 
control and labelling to protect those consumers who 
believe in the benefits of organic food and are therefore 
prepared to pay the extra costs. 
1.8. Given the single market of 1993 such control has to 
be organized on an EC basis. The Committee therefore 
welcomes the Commission proposal in principle though it 
would want to see some changes in the detail, as shown 
below. 
2. General comments 
2.1. This proposal has a number of defects which will be 
addressed in detail: 
a) It does not cover animal product though livestock is an 
essential part of organic rotation. Many units have 
mixed production of crops and animals and both need 
to be covered. 
b) Finished and processed products are only partly 
covered. A proposal covering all foods is much more 
preferable. 
c) The Regulation is too lax in allowing crops to be 
designated as organic; at least 24 months should have 
elapsed from the last application of artificial fertilizers 
and pesticides to land on which they have been grown. 
d) Permitting both an effective and an ineffective control 
system is unsatisfactory. 
e) The provisions are largely negative. Instead there 
should be positive lists of what is and what is not 
allowed. This is normal in all organic farming systems. 
f) — Consumers who believe in the benefits of organic 
foods think that they are buying completely 'natural' 
products. This proposal however allows the addi­
tion of varying amounts of synthetic material 
without adequate labelling to inform the consumer. — In fact most current practice permits a number of 
synthetic fertilizers and phytosanitary products in 
organic agriculture. This practice should continue 
but with adequate labelling to inform the consumer. 
3. Specific comments 
3.1. Article 1 (a) 
3.1.1. The reference to animal products is vague. 
Detailed provision should be made for these at the outset 
and not be left for later inclusion by administrative 
procedure. 
3.2. Article 1 (b) 
3.2.1. It defines products composed 'essentially' of one 
or more ingredients of plant origin. 'Essentially' needs to be 
defined. 
3.3. Article 2 
3.3.1. Since 'organic' has quite a different meaning in 
other contexts, the second indent should be changed to 
clarify that the terms 'organic', 'biodynamic', 'ecological', 
'biological' or similar must not be used in the labelling and 
advertising of foods unless such terms clearly refer to the 
method of production covered by this Regulation. 
3.4. Article 4.1. 
3.4.1. 'Advertisements' to be added in the second line. 
3.5. Article 4.6. 
3.5.1. The first indent corresponds to the normal 
definition of a synthetic chemical. 
3.5.2. The second indent, however, does not and needs 
revising. Apparently the word 'specific' in the second 
indent is intended to forbid only controlled chemical 
changes while allowing uncontrolled ones such as those 
that produce wood ash or basic slag, both of which are used 
in current organic practice. To avoid ambiguity the text 
should be changed to: 
'... one or more specific as opposed to generalized 
modifications ...'. 
No C 182/14 Official Journal of the European Communities 23. 7. 90 
3.6. Article 5 
3.6.1. The term 'organic' constitutes a powerful 
marketing claim implying that synthetic products or 
ingredients have not been used. Any use or presence of 
synthetics therefore must be declared on the label to inform 
the consumer. 
3.7. A new Article 5.1 d) should therefore be added: 
'where permitted synthetic fertilizers or pesticides have 
been used, this must be clearly indicated on the 
labelling.' 
We suggest the words: 
'Produced with permitted synthetic plant protection 
product and/or fertilizer'. 
3.8. Article 5.3. 
3.8.1. To ensure proper labelling the following phrase 
should be added at the end: 
'The presence of these ingredients must be clearly 
indicated on the label.' 
3.9. Article 6 (b) 
3.9.1. The intention is to forbid synthetic chemicals for 
the five uses mentioned but not for other purposes. For 
instance quarternary ammonium compounds or chlorine 
would remain permitted for cleaning and sterilizing. To 
make this clear, the next therefore should be completed by 
the following: 
'Synthetic chemicals may however be used for other 
purposes such as cleaning and sterilizing'. 
3.10. Article 7 
3.10.1. As noted before, all groups of organic producers 
have detailed lists of what can and what cannot be done. 
3.10.2. Most of these detail farming practices and give 
permitted lists of both natural and synthetic fertilizers and 
plant protection products that can be used. 
3.10.3. It would be best therefore to revise this Article 
completely to take account of this. 
3.10.4. Failing such a revision, provision must be made 
within the existing framework. For this we suggest giving a 
list of natural plant protection products in Annex I and 
adding an Annex II A containing a list of permitted synthetic fertilizers and plant protection products. The lists 
shown in our comments below were taken from existing 
national lists but would obviously have to be completed in 
discussion with national experts. 
3.10.5. These lists should be in the regulation from the 
start, including the compounds in Annex II and any 
additions should be publicized where the consumer has 
access to them. Also labelling for synthetics should be 
mandatory. 
3.11. Article 7.1 should therefore have the following 
addition: 
'Certain other synthetic or inorganic fertilizers or 
pesticides may be used providing their use is labelled on 
the final product. These are given in Annex II A'. 
3.12. Article 7.5 then has to read: 'Annex II and II A'. 
3.13. Article 8 
3.13.1. This covers products labelled 'Organic Farming 
— EEC Control System'. 
3.13.2. An effective inspection system is essential 
because there is no detectable difference in the final 
product. 
3.13.3. The present proposal is in line with the best 
inspection systems currently established in some Member 
States. However, to ensure transparency, the enforcement 
authorities should form part of the inspection mechanism. 
Also there needs to be some EC body to act as arbiter and to 
act as certification body for imports from third countries. 
3.14. Article 9 
3.14.1. This covers a much more superficial inspection 
system and gives the right to call the product 'organic'. 
Since this is the claim for which the consumer is prepared to 
pay the extra money and this procedure is simpler and 
cheaper for producers, they will inevitably be driven to use 
it. 
3.14.2. The provisions in this Article are not sufficiently 
rigorous to protect the consumer and it should be deleted. 
23. 7. 90 Official Journal of the European Communities No C 182/15 
3.14.3. If it is retained there must at least be one 
standard and one random inspection per year plus all the 
provisions for separation of organic and traditional 
produce required under Annex III. Also the labelling must 
identify the name and address of the producer and 
processor as provided in Article 10 for products made 
under Article 8. 
3.14.4. Finally, there should be a provision stating: 
'No reference to organic production may be made for 
products produced in accordance with this Article.' 
3.15. Article 11 
3.15.1. Both for fairness of competition and consumer 
protection, organic claims for imports should only be 
allowed if the product has followed an inspection system 
identical to that under Article 8, administered by the 
authorities in the third country and verified by the EC body 
mentioned in our comments under Article 8. 
3.16. Annex I 
3.16.1. One year should be changed to 'at least two 
years unless the land has been fallow for the previous three 
years' to build up organic soil fertility and to allow a 
meaningful reduction of residues introduced as inorganic 
fertilizers, pesticides, etc. into the soil. 
3.16.2. First indent: 'In the Spanish text replace 
'hortalizas' by 'leguminosas'. 
Also there should be a list of natural mineral fertilizers in 
line with existing practice (see comments on Article 7). 
3.16.3. The last sentence should be replaced by: 
'The following natural plant protection products are 
permitted: 
Pyrethrum (without synergist) 
Derris 
Quassia 
Kotenone.' (List to be completed in accordance with existing practice 
in Member States.) 
3.17. Annex II 
Add: 
'Metaldehyde used as a tape or in a trap Pheromones.' 
3.18. Annex II A 
[See comment on Articles 7 and 5.1 d)]. 
The following synthetic products may be used as plant 
protection or fertilizers: 
— Pyrethrum with synergist 
— Bordeaux and Burgundy mixture 
— Bicarbonate of soda 
— Sulphur 
— Inorganic copper compounds 
— Sulphate of potash 
— Sodium silicate 
— Borax 
— Magnesium. 
(List to be completed in accordance with existing practice 
in Member States). 
3.19. Annex III 
3.19.1. General 
3.19.1.1. The provisions in this are adequately tight. All 
those relating to separation of organic and traditional 
material should also apply to products produced under 
Articles 9 and 11. 
3.19.1.2. B 2. Unit needs defining to enable farms to 
make both types of product. 
3.19.1.3. B 4, first indent: the word 'premises' should be 
'places' to correspond to the original French text. 
3.20. Annex V 
3.20.1. A symbol would be helpful as an alternative. 
Done at Brussels, 30 May 1990. 
The Chairman 
of the Economic and Social Committee 
Alberto MASPRONE