Opinion of the European Economic and Social Committee on the ‘Communication from the Commission to the Council and the European Parliament: European action plan for organic food and farming’(COM(2004) 415 final)
Date: 2004-12-16
Institutions: European Economic and Social Committee
Subjects: action programme, common agricultural policy, foodstuff, marketing, organic farming, organic product, rural development

28.6.2005

EN

Official Journal of the European Union

C 157/167

Opinion of the European Economic and Social Committee on the ‘Communication from the
Commission to the Council and the European Parliament: European action plan for organic food
and farming’

(COM(2004) 415 final)

(2005/C 157/30)

On 15 October 2004 the Commission decided to consult the European Economic and Social Committee,
under Article 262 of the Treaty establishing the European Community, on the abovementioned communi-
cation.

The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing
the Committee's work on the subject, adopted its opinion on 16 November 2004. The rapporteur was Mr
Voss.

At its 413th plenary session, held on 15 and 16 December 2004 (meeting of 16 December), the European
Economic and Social Committee adopted the following opinion with 70 votes in favour and two absten-
tions.

1. Introduction

of the action plan took place at an event that was well attended
by European governments and organisations and members of
the general public.

The number of organic farms in the European Union
1.1
has increased sharply in the last fifteen years. Between 1985
and 2002 the number of organic farms in the EU-15 rose from
6,300 to 150,000 and the area farmed by them from 100,000
ha to 4.4 million ha. This is equivalent to these farms' share of
agricultural land rising from 0.1 % to 3.3 %. Organic food sales
are worth EUR 11 billion in Europe and EUR 23 billion world-
wide.

1.2
The development of organic farming, which was mainly
due to farmers supported by consumers, began in the 1920s.
Sustained consumer demand in specialised markets became
established in the 1970s. A variety of socio-economic players
started to expand, promote and monitor organic production
and marketing in the 1980s.

1.3
Council Regulation (EEC) No. 2092/91 was the first
piece of legislation on organic farming to be drawn up by the
EU, on the basis of the preparatory work carried out over a
period of many years by the leading organic farming associa-
tions. EU support was first provided in 1992, when this type of
farming became part of agri-environmental policy.

1.5
The action plan represents a crucial contribution to the
further development of the common agricultural policy and
gives a good picture of the special role to be played by organic
farming in future agri-environmental policy. This enhanced role
depends on the cooperation of economic stakeholders and
especially producers. The economic interests of the farms must
therefore be taken into account. The early involvement of
national and regional government bodies in the Member States
will be decisive for the success of the plan.

The EESC welcomes the European action plan for
1.6
organic food and farming. It would point out, however, that
sufficient human and material resources are required within the
EU administration to perform the related tasks satisfactorily. In
this connection, the Committee is pleased to note that at its
first reading the European Parliament decided to include the
action plan under the budget headings for support measures,
including measures for improving the quality of agricultural
production.

2. Content of the Commission document

The Agriculture Council called on the Commission in
1.4
June 2001 and again in December 2002 to present an action
plan for organic food and farming.
In the meantime the
Commission has conducted a consultation exercise on the
Internet in which 1,136 citizens and organisations have taken
part. The results have, inter alia, been used for the Commission
staff working document on the feasibility of a European action
plan for organic food and farming. A European Parliament
hearing was held in July 2003, and in January 2004 the launch

2.1
The Commission notes that organic farming makes a
major contribution to various EU policy measures which are
designed to provide a high level of environmental protection.
The problem areas listed are: pesticides, plant nutrients, soil
protection, biodiversity, nature protection, animal welfare, and
food safety.

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2.2
The Commission's main aim is to expand the organic
farming sector steadily and exploit market potential. Special
attention is to be paid in this connection to farm incomes. This
is to be done with due regard to the dual role of organic
farming, namely a) to produce organic produce which has to
fetch higher prices because of the non-use of environmentally
important inputs and the lower yields resulting therefrom, and
b) to deliver public goods which have no market price and
therefore have to rely on public funding.

2.3

The action plan has three priorities:

— to make the development of the organic food market infor-

mation-driven and increase consumer awareness;

— to make public support for organic farming more effective;

and

— to improve and reinforce EU standards and import and

inspection requirements.

2.4
The plan makes provision for 21 actions, two of which
have budgetary implications and are subject to the availability
of funding. Implementation of the action plan depends on the
availability of Commission staff. Subject to these provisos, the
Commission intends to introduce the requisite measures as
indicated without delay. The action plan makes no specific
provisions for targets and timetable.

Member States are under no obligation to promote this agri-
cultural reform. The EESC notes that in European countries and
regions that do promote organic food and farming, this sector
of the economy is particularly extensive and very stable. The
pace of development and implementation of the new European
Agricultural Fund for Rural Development
in the
Member States should be carefully monitored.

(EAFRD)

3.1.2.1
The Committee is following the forthcoming deci-
sions on the Union's financial perspectives with great concern.
Rural development resources, in particular, are threatened with
cuts. The EESC points out that these resources are of crucial
importance for the stabilisation and innovative development of
Europe's rural regions. The Committee has already set out its
views on this subject in its own-initiative opinion on future
rural development policy (1) and is currently working on an
opinion on the proposal for a regulation on the European Agri-
cultural Fund for Rural Development. (2)

3.1.3 More and more stakeholders are interested in receiving
rural development funding, and numbers are increasing further
with the accession of ten new countries. Even if 80 % of the
funds earmarked for modulation have to be used in these
funds' country of origin, the additional financing available here
is very limited.

3.1.4
Organic farming, even more than other agricultural
practices, has vast potential for delivering public goods. The
Committee would urge the Commission, Council and Parlia-
ment to ensure that changes to the CAP agreed upon in June
2003 should not jeopardise good land management practices.
Furthermore, the funds allocated to the second pillar (rural
development) should be sufficient to fulfil Community priori-
ties.

3. General comments

3.1 Reform of the CAP

4. Specific comments

4.1 The organic food market

The Luxembourg agricultural reform decisions of June
3.1.1
2003 stipulate for many products a cutting back of administra-
tive price controls and an erosion of the safety net. However,
thanks to a large-scale decoupling of direct payments from
production, which is a new cornerstone of the agricultural
reform decisions, the Commission anticipates a stabilisation of
prices and even an increase in prices for agricultural produce.
Because producer price levels for organic produce depend on
the general level of producer prices, new opportunities to earn
a living can arise on the market for organic farmers. The
Committee would stress that this will only be possible if the
Community preference is maintained at an adequate level for
all agricultural produce .

3.1.2
The promotion of organic farming depends, inter alia,
on the total funds available in the second pillar of the CAP.

4.1.1 Consu me r s' p e r c e p t i on of or g a ni c p r odu ct s

4.1.1.1
The stakeholders involved in organic farming, and
especially producers, have already won an appreciable share of
the food market to the point where the EESC considers that the
term ‘niche market’ can no longer be used in every Member
State to describe this market share. In many EU regions and for
some products, the proportion of organic farms and foods is
for
already very high. Many raw materials for baby food,
example, are already organically produced.

(1) Own-initiative EESC opinion on The CAP second pillar: outlook for
change in development policy for rural areas (follow-up to the Salz-
burg conference)

(2) EESC opinion currently in the pipeline on the Proposal

for a
Council Regulation on support for rural development by the Euro-
pean Agricultural Fund for Rural Development (EAFRD)

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4.1.1.2
Europe has regional and product-specific concentra-
tions in production, processing and market development, as
well as in research and initial and further training in the
organic foods sector. The reason for this may be either natural
regional specificities or a dynamic interaction of local economic
players. The Committee calls on the Commission to pay par-
ticular attention in this action plan to this clustering in organic
farming that is common in Europe.

3). However, in collecting and processing this additional data,
care must be taken to ensure that the partners involved in this
market (a small number of large trading firms on the demand
side and a large number of small and medium-sized farms on
the supply side) are able to benefit equally from such data or at
least that farmers do not suffer any serious disadvantages. The
collection and prompt publication of this sector's statistical
data in the new Member States is still something to work
towards.

4.1.1.3
Organic food has safeguarded the livelihood of
many enterprises, especially on the production side but also in
processing and marketing.

4.1.2 M a r ke t me c h a ni sms

The higher marketing costs for organic produce certainly
contribute in part
to the higher prices in the production,
processing and retail sectors. Therefore the Committee strongly
welcomes initiatives on regional processing and marketing
structures, because this can bring producers and consumers
closer together and make it possible to understand how prices
are formed. On the other hand, the food retail sector is now
extremely concentrated in some Member States, and this exerts
considerable pressure on producer prices in the organic sector,
too.

4.1.3 A n i nfor ma ti on-le d de ma nd

The Committee expressly welcomes the measures proposed in
Action 1 for supporting the promotion of information and
sales. They should, however,
incorporate individual Member
States' experiences, since special pressure on purchasing prices
is exerted by industrial kitchens, canteens, schools and the like.
Industrial kitchens which feed children, the elderly and the sick
represent an important market.

4.1.4 M a r ke t p r oble ms du e to va r i a ti ons be tw e e n

standar ds

The envisaged establishment of an Internet database for
comparing differing regional and national regulations can be a
useful instrument for promoting trade in goods in the single
market. However, the demand for all differences to be comple-
tely eliminated would be going too far. These differences often
have regional, sectoral and cultural roots and are a driving
force for innovation and for developing standards and product
quality further.

4.2 EU policy on organic farming

4.2.1 O r g a ni c

fa r mi ng
c ommon a g r i c u ltu r a l p o li c y

i n th e

fr a me w or k of

t h e

The Committee would query whether the European model of
multifunctional agriculture, to which organic farming with its
environmental services makes an important contribution,
is
being given sufficient prominence in the WTO international
negotiations in order to ensure the viability of the CAP and,
more especially, in order to ensure that aid under the second
pillar of the CAP continues to qualify as ‘green box’ aid.

4.2.2 R u r a l de ve lop me nt

In addition to the development of a web-based menu of all EU
measures (action 5), it is suggested that, in order to promote
the local production of organic food, the hygiene and health
standards applicable to small and medium-sized food proces-
sing and marketing firms be geared to their special risk poten-
tial. The standards laid down for bulk processors are frequently
not applicable to small firms with restricted regional processing
and marketing volumes and often impede investment and
therefore hamper job-creation in rural areas. The Committee
stresses in particular the need for appropriate standards for
small-scale regional
firms processing and marketing both
organic and conventional produce. For this reason, they should
benefit
from the derogation framework for the processing
sector. For the EESC, the absolute priority remains of course
compliance with the principles of food safety laid down in the
White Paper on food safety and hygiene and in recently
adopted legislation.

4.1.5 M on i tor i ng a nd a na lysi s of su p p ly a nd de ma nd

It makes sense to improve the collection of statistical data on
organic production and the market in organic products (action

4.2.2.1 With regard to the initiative proposed under action
6 for targeting the establishment of organic farming in environ-
mentally sensitive areas, care should be taken to ensure that
this does not lead to an imbalanced supply situation and subse-
quently to politically-driven distortions of competition within
organic farming. The difficult arable farming conditions in
these areas must be adequately described.

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4.2.2.2
In the EESC's view, the action programme does not
take account of the great significance of the organic farming
and foodstuffs sector for employment, particularly in rural
regions. Surveys in EU Member States have shown that organic
farming is almost exclusively responsible for new start-ups in
farming and its upstream and downstream sectors. The
Committee would also stress
that all quality agricultural
produce bearing an indication of regional origin will have a
positive impact on rural development.

4.2.2.3
Training, education and advice are described in
Action 6. A clearer emphasis on delivering information and
knowledge in the rural development context is needed in order
to strengthen these farming production methods and the
marketing and processing of organic products.

organic farming. An understanding should be reached here, to
be followed by a definition of
the principles (action 8).
Account should be taken of the experiences of the IFOAM (1).
The Committee particularly wants the historical development
in the new Member States to be taken into account.

4.4.1.1
It should also be borne in mind that in the view of a
number of national organic farming organisations, the concept
should encompass not only environmental criteria but also
socio-economic principles, such as the creation of valuable jobs
offering social stability in rural areas. The adaptation of the
regulations on organic farming should then take place on a
case-by-case basis, stressing the need to comply with the basic
principles, and the granting of transitional periods with fixed
end dates should be reviewed stage-by-stage (action 9).

4.3 Research

4.3.1
Organic farming is a type of farming which specifi-
cally uses and develops methods, instruments and techniques
that have the least possible impact on the environment.

4.3.2
The Committee sees publicly financed research for
organic farming as a particular challenge. Research fields which
have little private-sector investment and which are of major
importance for society must be made key areas of publicly
supported research. Both organic farming and technology
impact assessment should be given priority status in the EU's
Framework Programme for Research.

4.3.3
The Committee welcomes more research into organic
farming. The aims of this research must be distinguished more
clearly, and their consistency with other areas of the common
agricultural policy checked. Education, knowledge transfer and
the importance of interdisciplinary science are the premise for
the successful development of an organic food sector and
should be given greater weight — including financial — in the
Commission's action plan.

4.3.4
There is an urgent need for organically-oriented
research into plant cultivation and livestock breeding. This
includes further development of modified breeds and species to
ensure market viability.

4.4 Standards and inspection — safeguarding integrity

4.4.1 T h e r e g u la tor y conce p t

4.4.2 T h e scop e of or g a ni c p r odu c t i on sta n da r ds

Apart from calling for simplified and harmonised plant and
animal husbandry rules, care should be taken to ensure that
small and medium-sized farms continue to influence develop-
ments in husbandry so as to obviate monopolistic structures
similar to those to be found, for example, in the case of many
crops and in chicken farming. In chicken farming it is already
impossible to supply farms with organically suitable breeds.
Investment subsidies should be contemplated for the imple-
mentation of improved animal welfare standards, since expen-
sive new or converted premises can frequently be required to
house the animals. In the arable farming sector there are still
no rules on trade in traditional plant varieties or old crop vari-
eties no longer listed in the register of varieties. The Committee
finds this regrettable and urges the Commission to take the
necessary steps to introduce the required measures.

In action 10 (last indent) it is necessary to clarify
4.4.2.1
whether ‘biodiversity’ means crops and livestock or whether it
has a broader meaning and refers to all fauna and flora. The
EESC would also point out, however, that according to the
objectives of the CAP, preservation of biodiversity cannot be
the responsibility of organic farms alone.

Although energy- and resource-saving practices are
4.4.2.2
at the heart of organic farming, the EESC rejects introducing
special standards. The priorities here are effective general agri-
cultural and economic provisions.

Despite the existence of a regulation on organic farming, no
basic principles have been laid down hitherto. The only
possible explanation for this is historical. Basic principles have
long existed in some Member States with a long tradition of

The creation of

4.4.2.3
the first-ever EU standards for
organic wine and aquaculture products is expressly welcomed.
In particular, the Committee also sees the positive effects on
conventional practices in the sectors.

(1) International Federation of Organic Agriculture Movements

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4.5
The establishment of an independent expert panel for
technical advice, as proposed under action 11, is welcomed by
the Committee provided that stakeholders, i.e. farmers, proces-
sors and consumers, are suitably involved so that such a panel
enjoys the public's confidence. However, there is a lack of
specific provisions concerning the timetable, goals and budget
resources needed to make a success of this initiative.

4.6 Genetically modified organisms

4.8 Imports

4.8.1 When the rules governing imports of organic produce
are refined, account should be taken of the growing risk of
GMO contamination.

The Committee recommends looking at the promotion
4.8.2
of
the Mediterranean economic area when considering the
possibilities of organic farming. The point is to strengthen the
centres of organic cultivation and to promote their networking.

4.6.1
The Committee regrets that on this point the action
programme deals only with thresholds and does not propose a
comprehensive approach to ensure co-existence as a prerequi-
site of organic farming in Europe.

Organic products must not be granted more far-
4.8.3
reaching concessions than conventional
imports in interna-
tional trade agreements. This is necessary for reasons of compe-
tition and, in particular, in order to ensure that organic farming
in Europe continues to have a chance on the market.

4.6.2
The ban on the use of GMOs in organic farming is of
particular importance in the context of the ongoing discussion
on co-existence rules. The recommendations proposed under
this point can be accepted to a large degree. The non-GMO
farming sector (conventional and organic) should not have to
bear any of the costs or loss of income arising from the release
of GMOs.

The general thresholds for seed in organic farming
4.6.3
must be the detection limit (action 12). In the Committee's
opinion, the detection limit should also be the threshold for
conventional non-GMO seed. Otherwise, it is to be feared that
the presence of GMO components in organic products, too,
might rise rapidly, thereby jeopardising the foundations on
which organic farming in Europe is based. Because of the free
movement of goods and the presence of vast areas of agri-
cultural land on both sides of national borders within the EU,
harmonisation is necessary here, too.

4.7 Inspection systems

5. Summary

The Committee welcomes the proposed action plan for
5.1
organic food and farming. It is a fitting response from the
Commission not only to the call of the Agriculture Council,
but to the expectations of many citizens. With the implementa-
tion of cross-compliance and the definition of conditions of
good agricultural and environmental practice, the environmen-
tally-friendly development of European agricultural policy has
to face higher demands.

5.2
The EESC welcomes targeted marketing campaigns and
consumer information. It does not, however, expect existing
imbalances in the food industry and in processing to be
increased.

5.3
This important sector for employment prospects and
production of public goods must get the attention it merits in
the EAFRD programme,
in connection with the measures
linked to the quality of agricultural produce.

Implementation of the risk-based approach to improve inspec-
tions (action 13) is to be endorsed. The EESC points out that
the German version of the action plan, unlike the English,
states that agricultural producers present the highest risk in
terms of fraudulent practices. The EESC urgently requests this
to be corrected. The inspection system's risk analysis and risk
management should take account, rather, of the exposed flanks
in sectors further upstream and downstream such as processing
and trade. The inspection systems must be improved by cutting
red tape and costs. An efficient networking of inspection orga-
nisations could be helpful.

5.4
Efforts to harmonise norms and inspections must not
overburden businesses and must allow for regional specificities.
In the case of both EU- and third-country goods, the EU logo
should not prevent identification of origin.

5.5
On the matter of co-existence with GMOs, the question
of how Europe-wide organic production can be guaranteed in
the future remains unanswered. For this reason,
the GMO
contamination limits for all seeds should be set at the detection
threshold.

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5.6
Organic farming must be given a higher priority in the
EU's research plan. This prioritising is justified by the great
importance for society as a whole and the meagre private
research resources available to this sector.

5.7 With the European Parliament's decision to make funds
from the budget heading for improving the quality of agri-
cultural production available to the action plan, European deci-

sion-makers have begun to combat the shortcomings in staffing
and materials resources referred to above.

The EESC is monitoring discussion of

5.8
the financial
perspectives with great concern. A cut in resources for rural
development would also set back organic farming and the
organic food sector in Europe.

Brussels, 16 December 2004.

The President

of the European Economic and Social Committee

Anne-Marie SIGMUND