Organic, reg. EU 2018/848


Organic. The new EU regulation, reg. EU 2018/848. Yet another skeleton still lacking vital organs. A basic text, which lacks all technical annexes-fertilizers, plant protection products, feed, sanitation products, additives and adjuvants, minimum livestock space, etc. – to work on in the coming two years.

Other people’s pesticide residues, the threshold unavoidable

The threshold of
Accidental and technically unavoidable contamination
of plant protection products in organic agriculture‘ (1) does not at all authorize the use of synthetic pesticides in organic production, as Italian conventional farmers’ organizations instrumentally claim. Indeed, this threshold serves only to provide uniform criteria for evaluation in the conduct of inspection activities.

Above the threshold of 0.01 ppm-equivalent to 1 gram of pesticide per 100 tons of product-‘organic’ certification cannot be granted, even if inspections show that the operator is completely unrelated to the contamination. Below this threshold (e.g., at a residue of 0.003 ppm, 1 gram of pesticide in 333 tons of product), the inspection body must conduct a specific investigation to ascertain that the contamination is due to factors beyond the operator’s control. (2)

The National pesticide monitoring in the waters‘ published by ISPRA in 2015 reveals the presence of 259 phytochemicals in Italian rivers, with concentrations above environmental quality limits in 23.9 percent of surface water monitoring points and 8.3 percent of deep water monitoring points. ‘For some substances, contamination by frequency, spatial spread, and exceedance of legal limits, constitutes a real problem, in some cases of national dimension‘, comments the Institute.

Glyphosate (or glyphosate) in nearly 50 percent of surface water samples. But also atrazine, a herbicide banned since 1992-more than a quarter century ago (!)-is found in more than half of the groundwater samples. E


, an insecticide banned since 1969 – half a century ago (!!) – in 15 percent of surface water samples.

EU rules onorganic farming, after all, require operators not to use synthetic chemicals. Also not to guarantee the absence of residues (certification is process, not product). Nor, on the other hand, could they guarantee the absence in the water of pesticide residues whose use ceased decades ago and certainly cannot be attributed to them. All the more so since environmental pollution phenomena, as European regulations themselves attest, are ‘technically unavoidable‘.

A uniform approach at the EU level is also indispensable. To avoid grotesque situations, such as the case of an Italian processor being forced to reject an Italian agricultural product with accidental and technically unavoidable contamination to the extent of 0.011 ppm. And cannot instead reject, according to the principle of free movement of goods, a product with accidental and technically unavoidable contamination, perhaps 0.018 ppm, from another EU country that has instead established a legal threshold of 0.02 ppm.

In any case, there is no point in claiming an unrealistic absolute zero. If organic farming were relegated only to areas that are already completely uncontaminated-assuming there is no background contamination in these areas anyway-the development of such a system could not be promoted. Which is instead necessary precisely for the ‘reclamation’ of areas previously devastated by conventional agriculture.

In fact, the organic method is based on the interaction of best environmental practices with the preservation of natural resources and a high level of biodiversity. Thus fulfilling at the same time a shared public interest of contributing to environmental protection and rural development. Therefore, organic farming is a model for the conversion of agrifood production under the banner of sustainability, not to be relegated to the gardens of Eden.

Paradoxically, the greater the water and soil pollution in some areas, the more urgent it is to start organic production right there. Before it is too late, and assuming it is not already. So if the exceeding of environmental quality indices affects Piedmont, Lombardy, Veneto, Emilia Romagna and Friuli Venezia Giulia (and at times alsoTuscany, Latium and Sicily), it is precisely there that the agricultural model needs to be rethought. We need to relieve the ecosystem of a chemical load that has led it to collapse. Rather than confining ‘clean’ agriculture to pristine areas only, letting the pollution of other parts of Italy and Europe continue.

In Italy in 2016, 4.515 million tons of synthetic fertilizers were distributed per hectare of UAA, with a total use of 124.1 thousand tons of ‘phytosanitary’ products. That is, more than 350 kilograms of fertilizers and nearly 10 kilograms of herbicides, fungicides and insecticides per hectare.

If this bad land use is not drastically reduced, indeed, the question remains whether in fifty years we can still discuss how to solve the environmental disruption caused by conventional agriculture.

Comments from Italianconventional farmingorganizations

Italianconventional farming organizationsare lashing out at EU Regulation 2018/848, which, it is reiterated, still lacks the technical annexes necessary to define its concrete scope of application. They are thus distinguished from Copa Cogeca, the ‘confederation of agricultural and cooperation organizations in the EU,’ which instead welcomed the new text.

Coldiretti, Confagricoltura and CIA. They particularly challenge the tolerance threshold on accidental and technically unavoidable contamination. Forgetting, however, that it is precisely their members who first employed DDT, then atrazine, and still employ glyphosate (or glyphosate), along with more than 100 thousand tons of other agrotoxics each year in the country. However, the memory of this use is found in the levels of increasing water contamination, punctually updated by ISPRA (as well as in ‘
Unintentional and technically unavoidable contamination

The confederations thus have the courage to claim that ‘the approved regulations are a green light to products certified as organic but contaminated with plant protection chemicals.’ Or, ‘the measure waters down the quality of Italian and European organic agricultural production,’ or ‘it penalizes our country, putting us at a competitive disadvantage in Europe.’ Consistency, in short, is not at home.

On closer inspection, the ministerial decree introducing the decertification threshold for Italy dates back to May 2011. For seven years now, therefore, ‘organic’ companies have been investing substantial sums to curb the pollution caused by their ‘conventional’ neighbors. By hedgerow planting, exclusion of rows near boundaries from the organic market, and further analysis. Precisely because the same labor organizations-in pursuing an opposite interest in the development of organic production, which is still too far removed from their cultural and economic model-have succeeded in convincing the ministry on the theorem that the organic farm is responsible for the contamination caused by their conventional farmer members (perhaps with agrotoxics purchased from the warehouses of the consortiums that also belong to the same organizations).

The principle polluter pays‘, which European environmental policies have theoretically been inspired by for years, is thus turned upside down for the use and service of those same confederations that – it is worth remembering – have supported Big Ag in the opaque lobby In favor of glyphosate. (3)

So, if an organic operator works with utmost diligence, implements every reasonable measure to avoid contamination, while his ‘conventional’ neighbor sprays his soils on windy days, with poorly calibrated sprayer nozzles, and ‘rains’ unwanted contaminants onto organic soils, who pays for the damages?

According to internationally shared logic, the polluter pays. But no. In this upside-down system, it is the organic farm that pays for any damage caused by others. To the point of having its certification withdrawn for an’alien’ contamination of 0.1 gram of pesticide per 10 tons of its product. Even if it is an active ingredient whose use is devoid of technical sense on its crop and instead stems, in all evidence, from ‘exuberant’ use on the neighboring conventional farm.

Coldiretti, Confagricoltura and CIA extoll the decline of ‘organic quality,’ ‘Green light tocontaminated organic,’ keeping silent that their own members are responsible for accidental contamination in Italy. Alleging that ‘the fruit and vegetables we import from Germany and Sweden could theoretically have contamination above the Italian organic threshold, so it is better to buy conventional Italian produce.’ (4) A completely unrealistic scenario, for at least a couple of reasons:

– How many oranges and lettuce arrive in Italy from Scandinavia and Central Europe?

– the level of contamination allowed at the European level, however, is very low (e.g., 0.15 grams of residues per 10 tons of product).

Above-ground cultivation. The agricultural confederations then challenge the transitional arrangement granted to a handful of Danish, Swedish and Norwegian organic farms. Which will be able to grow mushrooms, strawberries and vegetables in earthen boxes in greenhouses, instead banned at the European level by reg. EU 2018/848. A controversy based on nothing, since the derogation covers a total area of 20 hectares (already identified, constrained and not subject to any possible enlargement), i.e., 0.00016% of the12.1 million hectares cultivated organically in the EU.

GMO? No, thank you

Theconventional farming confederationsthen evoke the ‘GMO monster,’ alleging that the regulation would open the door to GMO contamination. False. Instead, EU Regulation 2018/848 specifies the following.

Theuse of ionizing radiation, animal cloning and artificially induced polyploid animals or genetically modified organisms (“GMOs”), as well as products derived or obtained from GMOs, is incompatible with the concept of organic production and consumersperception of organic products.

GMOs, products derived from GMOs and obtained from GMOs shall not be used in food or feed or as food, feed, processing aids, plant protection products, fertilizers, soil conditioners, plant reproductive material, microorganisms or animals in organic production‘.

The threshold of accidental or technically unavoidable contamination with GMOs authorized in the EU is not even mentioned in the Organic Production Regulation. Instead, it was defined as 0.9% by reg. EC 1829/03 and applies to all production, conventional and organic. Provided that operators are able to demonstrate to the competent authorities that they have taken all appropriate measures to avoid its presence.

Instead, conventional Italian agricultural organizations demand that GMO contamination within the 0.9 percent threshold be considered a priori ‘technically unavoidable’ on their products, and intolerable on ‘organic’ ones.

Hypocrisy reigns,where it should be remembered that 15 years ago both Confagricoltura (still true to the line) and CIA (which has since turned around) were in favor of GMOs. Coldiretti claims to be against GMOs, but counts among its members the agrarian consortia that are still the top sellers of foreign-sourced GMO feed (as well as glyphosate) in Italy.

Not surprisingly.

, never was the voice of any of its representatives heard, in the PDO and PGI protection consortiums, to propose theexclusive use of ‘GMO free‘ feed

And ban the GMO ones. As did the Fontina AOC Consortium, however, of its own volition.

Dario Dongo


(1) Threshold introduced in Italy by DM 309/2011.

(2) A phenomenon classified as ‘technically unavoidable’ may occur, for example, in the event of the presence in the soil or irrigation water of pesticides not used by organic producers, but by conventional ones, perhaps even in the past. European regulations acknowledge that ‘some pesticides contaminate theenvironment, so you can find their residues‘ in food

(3) See in this regard the positions expressed by Copa-Cogeca, the European confederation representing the confederations of conventional agriculture, of which the president of Coldiretti holds the vice-presidency

(4) Instead, the national figure, beyond slogans, reveals that 42% of products have residues (Legambiente elaboration on data from Arpa, Asl, Izs 2015)