Origin ingredients, guarantees only on organic. Revolt


Label ingredient origin. In 15 years of debates-since Coldiretti launched its proposal ‘
origin of raw materials on the labels of all food products
‘ – the talk and farce have far outweighed the reforms. (1) With the result that today there are partial guarantees only on organic, with paradoxical effects on information to the consumer, who in turn is completely bewildered. We are ready to file an appeal in the EU Court of Justice, against the OPT (Origin Planet Earth) regulation, in support of those who really want transparency on labels.

Primary ingredient origin, the farce of EU Regulation 2018/775

The European Commission – in adopting the reg. EU 2018/775, laying down modalities for the indication on the label of theprimary ingredient origin of products bearing a different origin (understood as the country of its last substantial processing) – has in all evidence committed an excess of power. In introducing a number of exceptions, not provided for in the basic regulatory act, (2) which allow operators to continue to conceal the origin of the primary ingredient.

EU Regulation 2018/775
in fact allows for secrecy about the origin of the prevailing raw material in a wide range of cases, such as those where the origin of the product is disclosed to the consumer:

  • Through a registered trademark (e.g. Canadian lentils from ‘Colfiorito‘. Rather than ‘
    Valsugana polenta
    ‘, with what corn?),

  • with a ‘generic geographical indication’ (e.g. ‘
    pesto alla genovese
    ‘, ‘
    ragout Bolognese
    ‘, from ingredients from where?),

  • Through a Protected Geographical Indication, PGI. Where it is sufficient for part of the process to be located in the designated place, without the need for the raw material to originate there (and so, for example, the origins of the meat of Speck from Alto Adige and Bresaola from Valtellina remain concealed).

Also excluded are from the scope of the regulation are flavored wines, liqueurs and spirits, products covered by international agreements (CETA, JEFTA, etc.).

OPT, ‘

Origin Planet Earth

is the name that best suits the reg. EU 2018/775. Since this is the level of precision allowed for designating the origin of the primary ingredient, ‘
‘. European rules thus precede the start of food production on Mars, already mandating that the terrestrial origin of foods from this globe be specified. A real success also for the information of Venusians (!).

Quality wines, 100% guaranteed origin only in organic. Alien sugars hidden in conventional bubbles


, controlled and guaranteed designation of origin, introduced since Presidential Decree no. 930/1963, è reservedfor wines already

recognized as DOC and expressly delimited areas or types of a DOC for at least ten years, which are considered to be of particular merit, due to their intrinsic qualitative characteristics and the commercial reputation they have acquired

is granted only if the viticultural and oenological regulations are more restrictive than those of the AOC of origin. The grapes come from (it is ‘
) exclusively from the geographical area referred to in the appellation. (4) Indeed, they generally come from a
historical subzone
within the area where the DOC wine is produced.

Vineyards that comply with the specification
of production must come registered in the Register of Vineyards of the respective appellation. The specification defines the maximum number of vines per hectare and the maximum yield of grapes that can be derived from them, as well as the specific characteristics that the wine must meet, in order to be released for consumption. Color, odor, flavor, minimum alcohol content, total acidity and other parameters. The specification also stipulates label claims and bottle type.

DOCG wines undergo chemical and physical analysis at authorized laboratories and organoleptic examination by a tasting commission composed of members of the lists of
‘technical tasters’
and of the
‘expert tasters’
maintained by the Chambers of Commerce and appointed by the relevant region.

A complex procedure
is thus established to ensure that the DOCG actually corresponds to ahigh-quality product at the top of the national wine pyramid. As a result of a strict control ofcompliance with a scrupulous and restrictive specification, aimed at identifying a product that actually represents the best productive expression of that territory.

However, the organic DOCG stands out. for additional information requirements that, paradoxically, are discriminatory against the conventional product. Take for example an organic classic method sparkling wine. A Franciacorta DOCG, an Oltrepo pavese DOCG.

In the margin of the

European logo
of organiccompliance (the stylized leaflet surrounded by the 12 EU stars) we can in fact find the indication ‘EU/non-EU farming

. But how, aren’t these still grapes grown on the gentle slopes of the hills of Franciacorta or in the pleasant hills of Treviso? Of course it does! So what does the disturbing ‘EU/non-EU agriculture’ claim imply?

It is certainly not a


Of EU and non-EU wines. No Spanish or Chilean grapes were vinified, it is clear, as the origin must be strictly guaranteed. And sugaring, which is banned in Italy, is likewise to be ruled out.

The mystery unravels with the
sparkling wine
. A process step that involves the legitimate addition of anamount of sugar, the so-called
liqueur de tirage

Two to three grams of sugar per 100 ml, depending on the pressure to be achieved, with possible addition of yeast. Since the days of Dom Perignon, it is this second transformation that gives rise to the so-called ‘froth taking’.

To date, the sugar
employed In sparkling wine, in almost all cases, it is not derived from grapes. Sparkling wine could actually be made from grapes alone, using crystalline rectified solid must (MCRS). But instead, ‘alien sugars,’ from beet or cane, are predominantly used. In conventional ‘bubbles’ as in ‘organic’ ones.

And yet, the presence of ‘alien sugars’
can only be guessed from a careful reading of ‘organic bubbly’ labels. As organic beet sugar production in Europe is still in an experimental stage. And the only European ‘organic’ cane sugar is that which comes from the French Overseas Territories (e.g., Martinique). Thus, outside of the rare hypotheses just mentioned, organic sparkling wine carries the indications ‘EU-non-EU agriculture’ because its sparkling took place with the use of organic (beet or cane) sugar that is almost inevitably non-EU.

Non-organic bubbles
, conversely, can be made sparkling with cane or beet sugar of any origin without the consumer knowing anything about it. They may contain Polish, Russian or Peruvian sugar and yet show themselves as more authentic, more intimately linked to the
respect to the corresponding organic products. A discrimination-and indeed, a mockery endorsed by European regulations-of no small significance (!).

An opportunity for all the Italian wineries
more forward-thinking, organic and non-organic, is in any case to distinguish their sparkling wines – against competition from other countries – with
‘revolutionary’ claims such as ‘
100% from grapes
‘, o ‘
without sugars other than those from grapes
‘. Deciding to use only solid concentrated crystallized must, which by the way is produced only in Italy, instead of alien sugars of various origins (botanical and territorial).


, guarantee of origin only on organic products

The discrimination between ‘organic’ and ‘non-bio’
– regarding the indication of the origin of ingredients-is not limited to wines. In fact, the European regulation on organic production (EC Reg. No. 834/07), on closer inspection, suffers from a generality and inconsistency that extends to several production sectors.

EU rules on organic production
are generic in merely requiring that the origin of ingredients may be disclosed in the terms of ‘
EU – non-EU agriculture
‘. Without claiming more details that would be well worth circumscribing the extent of supply chains, nor focusing on primary or otherwise significant (as characteristic) ingredients.

Labels of organic products
must thus state ‘EU Agriculture’ if the agricultural raw material is entirely grown in the European Union, ‘
EU farming – non-EU farming
‘ if partly from non-EU countries, otherwise ‘non-EU’. And only when
agricultural materials were grown in a single country if their names can be given.

‘Organic’ PGIs (Protected Geographical Indications)
must therefore report news of the origin of both the primary ingredient and any others. To cite one example, organic bresaola della Valtellina PGI made from Swiss beef must be marked ‘
Non-EU Agriculture.
‘. Although 22 municipalities in the province of Sondrio border Switzerland and are therefore 0 km supply chains.

Conventional PGIs
, conversely, are exempt from the requirement to indicate the origin of the primary ingredient. And so, the producer of bresaola della Valtellina IGP ‘
‘ may decide to use Brazilian zebu meat, (5) carefully keeping quiet about its origin. Thanks to the regulation-farce on the origin of theprimary ingredient, reg. EU 2018/775.

EU Regulation 2018/775, excess of power

The OPT (Origin Planet Earth) Regulation.
misrepresents the spirit of the European legislator, as well as the limits of the delegation it gave to the European Commission.(6) Suffice it to recall the general objectives of EU Regulation 1169/2011, The provision of food information tends to a high level of protection of the health and interests of consumers, providing end consumers with the basis for making informed choices and using food in a safe manner, respecting in particular health, economic, environmental, social and ethical considerations).

Reg. EU 2018/775 introduces a number of exceptions-mentioned in the first paragraph of this article-that the regulation it is supposed to implement nowhere provides for. The European Commission-with the consent of almost all member countries, including Italy then represented by Paolo Gentiloni Silveri as acting minister of agriculture-came to deny that a PGI represents a geographical indication. From which must flow the obligation to specify the origin of the primary ingredient, if different.

Excluding PGIs
from the requirement to indicate the origin of the essential ingredient means continuing to hide from the consumer that the vast majority of bresaolas in Valtellina are made from Brazilian zebu legs, other Italian PGI cured meats from pigs raised in Holland, Denmark, Brazil, Romania or Poland.

Italy is the European country with the largest number of

of agri-food products with designations of origin and geographical indications recognized by the European Union.
‘further demonstration of the great quality


of our

productions, but above all of the

strong link that binds excellence
Italian agribusiness to its territory of origin.

The EU Geographical Indications system,
in fact, it promotes the production system and the economy of the area; it protects the environment, because


the indissoluble link with the territory of

origin requires the preservation of ecosystems and biodiversity.

supports the social cohesion of the entire community


At the same time, thanks to the community certification

more guarantees are given to consumers with a level of traceability.


and food safety than other products.
‘ (7)



has not demanded any transparency in Europe about the origin of the primary ingredient, nor has it demanded any action from its puppets Maurizio Martina and Paolo Gentiloni (in the role of minister

ad interim

of agricultural policies). The agricultural organization seemed distracted by the controversy against traffic lights on labels, which so disturbed the group


, but he has not yet done anything concrete:

– nor against JEFTA, the EU-Japan Agreement that will give the green light to the


and many other counterfeits of our PDOs. Coldiretti after all had already ignored CETA, which is equally dangerous for our PDOs and PGIs,

– nor against the OPT (Origin Planet Earth) regulation.

is our goal, entitlement our weapon. If the yellow flags or other organizations-private, collective or even public-really intend to pursue these battles, please contact us to move as soon as possible. The deadline for appealing the OPT regulation to the EU Court of Justice expires in early August 2018.

Dario Dongo


  1. The full picture of the obligations to mention the origin on the label is described in the previous article. The only concrete change in the past three decades is therequirement to indicate the countries of raising and slaughtering only meat-and not also meat products-of sheep, goat, pig and poultry species

  2. Cf. reg. EU 1169/11, Article 26, paragraph 3

  3. See Legislative Decree 61/2010

  4. Thus reg. EU 1308/2013, Article 93

  5. In fact, the specification for Bresaola della Valtellina IGP merely defines the age of the cattle (between 18 months and four years), without prescribing anything about its origin

  6. Cf. reg. EU 1169/11, Article 26.3

  7. Ministry of Agriculture, Food and Forestry, MiPAAF, at.