Organic controls in Italy, the ABCs and data

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Organic productions are often the subject of misinformation, by the mainstream media. We have already debunked some
erroneous reports about breeding conditions
and the
animal welfare
. And it is time for clarity on the inspection regime in organic production. The ABCs of rules and numbers leave no room for chatter.

Organic production, distinguishing features

Organic production is characterized by the following distinctive features:

– conforms to a technical canon associated with quality systems,

– Is governed by cogent rules,

– is guaranteed by institutions through a system of controls,

– is identified by a unified logo that summarizes its values,

– pursues
objectives
with environmental and social values,

– provides for the indication of
origin of the raw materials
(e.g. Agriculture Italy, EU, non-EU, near the logo).

The system of controls-understood as the set of activities, methods and tools to ensure product conformity-involves the synergy of control authorities (public bodies) and Control Bodies (CBs, public or private entities entrusted with a public service). The latter carry out inspection and certification activities under the authorization of the public authority on which the supervisory function rests.

The declaration of compliance with the requirements of the organic scheme can only come from an accredited body authorized to carry out inspection and certification activities in the specific field. Authorization is granted by the Ministry of Agriculture, Food, Forestry and Tourism (MiPAAFT), accreditation by a guaranteeing body (‘Accredia’ for Italy). Both are called upon to supervise the activities of certification bodies in order to ensure compliance with the rules. The accredited body must be outside the company’s production system and have characteristics of independence, impartiality and competence. In other words, he must be a ‘declaration professional’ in accordance with the law and international standard (ISO 17065:2012).

Organic, what guarantees. The system of controls

All stages of production and marketing – including via ecommerce,
as clarified by the EU Court of Justice
– must be subject to the control system established by European rules. (1) That is, every operator involved in any stage of the process-‘from farm to fork‘ and ‘from stable to table‘-must adhere to the control system.

Compliance of the product designated as ‘organic’ is ensured through self-control of the operator, control of the Certification Body, supervision of the Control Authorities. Product conformity is attested by documentary declarations and is verified by management and analytical controls. With guaranteed traceability of the two essential elements:

– compliance with the method,

– The origin of all materials used.

The system of controls, in detail, is broken down as follows:

– ‘On-site’ inspection by technical inspectors (TIs) commissioned by Control Bodies (CBs), at all operators, at least annually,

sampling and analysis. Technical inspectors (TIs) take samples, in the number and under the conditions prescribed to ensure representativeness, and transmit them to laboratories authorized by the Competent Authority (CA) for analytical verification,

certification by the BODs, through validation of the results of inspections and analytical findings. The frequency of annual inspections and sampling at each operator’s premises are defined according to the risk analysis prescribed by the regulation, as outlined in a technical document of the National Accreditation Body (RT16 Rev. 05 Accredia).

Biological Information System (SIB), public online registry of all operators adhering to the method. The roster, which is constantly updated, is available at www.sinab.it.

Effectiveness, efficiency and tertiary nature of the control system are ensured through application of the following procedures:

– selection and training of TIs, with regard to competencies and potential conflicts of interest on the part of CCOs,

– Monitoring of the work of the TIs, by the BODs,

– Authorization of CBs by the Competent Authority (CA),

– IT authorization to operate on behalf of the BOD by the Public Authority (CA),

– Supervision of the work of the CBs by the CA and the Accreditation Body. Activity involving:

(a) Exhaustive inspections at the premises of the CBs on an annual basis,

(b) inspection and analytical audits (the latter by the CA only), every year, at a representative sample for each individual CB,

– Information exchange-both between CAs and CBs and among different CBs-with the frequency and content required by the regulations,

The competent authority (CA) must organize regular inspections of the BODs. With the power to withdraw the delegation of controls if inspection reveals deficiencies and the delegated party fails to take appropriate and timely corrective action. The CA is also required to:

(a) Ensure objectivity and independence of the checks performed by the CB,

(b) verify the effectiveness of controls,

(c) record any irregularities or infractions found and corrective measures applied,

(d) revoke the authorization of the CB that does not meet the requirements of the standard.

Inspections of Control Bodies (CBs) involve the following steps at a minimum annual frequency:

– Verification of certification pre-requisites,

– Inspection of facilities,

– Verification of good operating practices and processing records,

– Possible sampling.

BODs as mentioned above are public service officers, yet lack the power to impose administrative sanctions and the role of judicial police. In case of nonconformities detected during inspections, they shall take the following measures:

warning (a written reminder that provides time limits to rectify the situation), in the case of noncompliance (i.e., a minor noncompliance that does not compromise the conformity of the production process or the company’s self-control system, without substantial changes in the company’s status (e.g., delay in sending documents that are otherwise regular),

– farm suspension for six months, with return to land conversion for 24/36 months, up to

Exclusion from the control system, in cases of infringement. That is, of failures of a substantial nature that compromise product compliance and operator reliability (e.g., use of impermissible plant protection products).

All nonconformities must be recorded and reported to the CA and the region where the operator is located. It will be the competent authority, after verification in the company, to impose administrative sanctions and notify the judicial authority of any reports of offenses. The region in turn will order the repayment of any contributions made to the operator under the Rural Development Plans. (2)

Organic inspections in Italy, the data

Organic controls can be distinguished into two moments, the activity of Control Bodies (CBs) and the supervision of the competent public authority (CA).

1) OdC checks. The latest available data show that in 2016, CBs performed an average of 115 inspections per 100 operators, 15 percent of which were unannounced. Twelve percent of the activities involved sampling. A total of 4,166 ‘Non-Conformities’ (5.8%) were opened, and 7.5% of the samplings conducted were positive. The latter figure, moreover, is not statistically representative because samples are taken selectively on sectors, companies and products with the highest criticality in terms of contamination risk. However, the level of investigative attention and professionalism, aimed at intercepting anomalies before the products reach the consumer, is highlighted.

2) Vigilance of the CA. The supervisory activities of the Central Inspectorate of Quality Protection and Fraud Repression of Agri-food Products (ICQRF) department have increased significantly (+35%) over the past three years. And while there has been a proportionate increase in administrative and crime reports, at the same time there has been a sharp decline in irregular analytical findings (down 50 percent). As well as the number of seizures (-42%) and the value of seized goods (-77%, 0.01 of the market value in 2018). It is, moreover, worth noting how the ICQRF almost always carries out checks ‘on the spot,’ following precise reports of nonconformities detected by CBs during their daily inspections.

ICQRF, controls in the organic sector, 2018

Control Activities

Change 2015/2018

2018

2017

2016

2015

Inspection checks (no.)

33,6%

2771

2738

2690

2074

Operators audited (no.)

37,3%

2297

2250

1956

1673

Irregular operators (%)

22,8%

11,30%

6,60%

7,40%

9,20%

Products checked (no.)

36,9%

3689

3476

3121

2695

Irregular products* (%)

22,2%

8,80%

5,60%

5,70%

7,20%

Irregular analytical outcomes (%)

-50,0%

3,20%

3,80%

5,40%

6,40%

Operational results

Crime news (no.)

183,9%

88

19

37

31

Administrative disputes (no.)

35,5%

187

106

107

138

Seizures (no.)

-42,5%

23

25

32

40

Quantity of products seized (t)

238,9

1209

*

*

Value of seizures (ml. €)

-77,9%

0,58

1,08

1,56

2,62

Warnings (no.)

103,7%

110

75

49

54

Market value (ml. €)

111,0%

5612

5381

4936

2660

Incidence on total market value

-89,5%

0,01%

0,02%

0,03%

0,10%

* data not available. Sources: elaboration on Bio in Figures data (2017), Bioreport (2016-2018), Nomisma for Assobio (Brand Presentation 2018), ICQRF (Activity Report 2017 and 2018)

The violations alleged are largely attributable to consumer information and administrative-accounting failures. In particular:

– Violations of regulations on product labeling and presentation (37 percent),

– administrative-accounting infractions (irregular record-keeping, inaccurate or irregularly completed business records, etc., 28%),

fraudulent acts (marketing conventional products as organic, pesticide residues not allowed in organic farming, 17%),

– commodity irregularities (13 percent),

– Administrative violations related to the geographical indications system (evocation of registered names, use of false or misleading indications of origin, 5%).

Organic, why trust

The rules and data expressed above demonstrate-above all suspicion, misinformation and doubt propagated by different stakeholders-how the system of public-private controls on organic production is tetragonal, effective and efficient. Although perfectible, like any anthropogenic activity. And it should be noted that all of the above controls are in addition to those to which organic processes and products are subjected on a par with conventional production.

Accredia then adopted a technical regulation (RT16) that requires each Inspection Body to maintain an updated database where they are registered:

– operators and products (operator code, company name, address and VAT number, certified products and their coding, certification status),

– Bulk product transactions (quantities, documents, recipients).

Databases are shared among control bodies-and made available to the competent authority-so as to enable cross-checks. The database, once completed with the average yields that can be expected in different territories for different crops at different elevations, will allow automatic validation of the yields declared by producers. The next step will have to be to make the database accessible to operators as well, so that they can more readily qualify suppliers. By verifying their status, the adequacy of quantities produced in relation to farm area, mass balances (quantities bought and sold or processed).

Italian consumAtors are right , therefore, to favor the purchase of organic products, since the controls on them are actually superior. But also and especially because through their choices, as FAO itself recently suggested, they help to preserve biodiversity and the ecosystem. With respect to climate change and pesticide contamination that still poisons the environment and people.

Choosing organic and equitableagriculture , as closely linked to the territories as possible, means contributing to the good of the community and participating in progress. Thanks to the determination and cohesion toward such a choice moreover, as true masters of the market, we can impose a wider and better offer, at fair prices even for those who decide to buy healthy, good and fair food. Natural for real. In fact, the coveted democratization of organic is the best of what can be aspired to, in the Italian food supply chain.

#Égalité!

Donato Ferrucci and Dario Dongo

Notes

Cf. reg. EC 834/07 (Title V, Controls), Leg. 20/2018

(2) Cf. D.M. 15962, 20.12.2013 (Provisions for the adoption of a list of ‘nonconformities’ concerning the organic qualification of products and corresponding measures to be applied by Control Bodies to operators under Reg. EC 889/2008 as last amended by EU Implementing Regulation 392/2013)

Bibliography

BioReport years 2016-2017-2018. Organic farming in Italy,

Bio in Figures 2017, at www.sinab.it,

Nomisma for Assobio. Brand 2018 presentation. The Italian market for organic products,

SINAB. http://www.sinab.it/content/rese,

SIAN. https://www.sian.it/consRese/paiRicerca.do (Public consultation rendered)

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Agronomist, master in food law. He deals with certifications and quality systems in the agri-food chain. He collaborates with institutions and universities and is a member of the editorial board of rivistadiagraria.org.

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Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.