HomeProgressOrganic, reg. EU 2018/848

Organic, reg. EU 2018/848

Biological. The new EU regulation, reg. EU 2018/848. Yet another skeleton still devoid of vital organs. A basic text, which lacks all the technical annexes - fertilizers, phytosanitary defense products, feed, sanitation products, additives and adjuvants, minimum space for livestock, etc. - to work on in the next two years. 

Pesticide residues of others, the threshold unavoidable 

The threshold of 'Accidental and technically unavoidable contamination of plant protection products in organic farming'(1) does not at all authorize the use of synthetic pesticides in organic production, as the Italian organizations of conventional farmers instrumentally claim. Indeed, this threshold only serves to offer uniform evaluation criteria in the performance of the control activity. 

Above the threshold of 0,01 ppm - equal to 1 gram of pesticide per 100 tons of product - the 'bio' certification cannot be granted, even if the inspections show that the operator is absolutely not involved in the contamination. Below this threshold (for example, in the presence of a residue of 0,003 ppm, 1 gram of pesticide per 333 tons of product), the control body must conduct a specific investigation to ascertain that the contamination depends on factors beyond beyond the control of the operator. (2)

Il 'National monitoring of pesticides in the waters'published by ISPRA in 2015 reveals the presence in Italian rivers of 259 pesticides, with concentrations above the environmental quality limits in 23.9% of surface water monitoring points and in 8.3% of deep water ones. 'For some substances, contamination due to frequency, territorial diffusion and exceeding legal limits is a real problem, in some cases of a national dimension', comments the Institute.

Glyphosate (or glyphosate) in nearly 50% of surface water samples. But also atrazine, a herbicide prohibited since 1992 - more than a quarter of a century ago (!) - is found in over half of the groundwater samples. And DDT, insecticide banned since 1969 - half a century ago (!!) - in 15% of surface water samples.

The EU rules on'organic farmingmoreover, they require operators not to use synthetic chemicals. Not even to guarantee the absence of residues (the certification is process and not product). Nor, on the other hand, could they guarantee the absence in the waters of pesticide residues whose use has ceased for decades and certainly cannot be attributed to them. All the more so since the phenomena of environmental pollution, as the European regulations themselves attest, are 'technically unavoidable'.

A uniform approach at EU level it is, moreover, indispensable. To avoid grotesque situations, such as the case of an Italian processing company that is forced to refuse an Italian agricultural product with accidental and technically unavoidable contamination to the extent of 0,011 ppm. And it cannot refuse, according to the principle of free movement of goods, a product with accidental and technically unavoidable contamination, perhaps of 0,018 ppm, from another EU country that has instead established a legal threshold of 0,02 ppm.

In any case, it makes no sense demand an unrealistic absolute zero. If organic farming were relegated only to areas that are already completely uncontaminated - assuming that in these areas there is no background contamination - the development of this system could not be promoted. Which is instead necessary precisely for the 'reclamation' of areas previously devastated by conventional agriculture.

The organic method in fact, it is based on the interaction of best environmental practices with the protection of natural resources and a high level of biodiversity. Thus fulfilling at the same time a shared public interest, contributing to environmental protection and rural development. Organic farming therefore constitutes a model of conversion of agri-food production in the name of sustainability, not to be relegated to the gardens of Eden.

Paradoxically, the greater the pollution of water and soils in some territories, the more urgent it is to start organic production right there. Before it's too late, and if it's not already. If therefore the overcoming of the environmental quality indices affects Piedmont, Lombardy, Veneto, Emilia Romagna and Friuli Venezia Giulia (and at times also Tuscany, Lazio and Sicily), it is precisely there that we need to rethink the agricultural model. The ecosystem must be relieved of a load of chemicals that led to its collapse. Instead of confining 'clean' agriculture to uncontaminated areas only, allowing the pollution of other areas of Italy and Europe to continue.

In Italy in 2016 4,515 million tons of synthetic fertilizers per hectare of UAA were distributed, with a total use of 124,1 thousand tons of 'phytosanitary' products. That is, over 350 kg of fertilizers and almost 10 kg of herbicides, fungicides and insecticides per hectare.

If it doesn't shrink drastically this bad use of the land, indeed, it remains to be asked whether in fifty years it will still be possible to discuss how to resolve the environmental damage caused by conventional agriculture. 

The comments of the Italian organizations of the'conventional agriculture

The organizations of the'conventional agriculture Italians lash out against the EU regulation 2018/848 which, it is reiterated, is still lacking the technical annexes necessary to define its concrete application scope. They thus distinguish themselves from Copa Cogeca, the 'confederation of agricultural organizations and cooperation in the EU', which instead greeted the new text with joy.

Coldiretti, Confagricoltura and CIA in particular they contest the tolerance threshold on accidental and technically unavoidable contamination. Forgetting, however, that it is their members who first used DDT, then atrazine and a still use glyphosate (or glyphosate), together with more than 100 thousand tons of other agrotoxicants every year on the national territory. The memory of this usage lies however in the increasing levels water contamination, promptly updated by ISPRA (as well as in theinvoluntary and technically unavoidable contamination').

The confederations thus have the courage to affirm that 'the approved standards are a green light for products certified as organic but contaminated by phytosanitary chemicals'. Or again, 'the measure waters down the quality of Italian and European organic agricultural production", or 'our country is penalized, placing us at a competitive disadvantage in Europe'. In short, consistency is not at home.

On closer inspection, the ministerial decree which introduces the decertification threshold for Italy dates back to May 2011. For seven years now, therefore, 'bio' companies have invested large sums to stem the pollution caused by their 'conventional' neighbors. By planting hedges, excluding rows near the borders from the organic market, and further analysis. Precisely because the same trade unions - in pursuing an opposite interest in the development of organic production, still too distant from their cultural and economic model - have managed to convince the ministry on the theorem according to which the organic farm is responsible for the contamination caused by their members conventional farmers (perhaps with the agro-toxic products purchased in the warehouses of the consortia which also belong to the same organizations).

The principle 'the polluter pays', which for years have been theoretically inspired by European environmental policies, is thus overturned for the use and service of those same confederations which - it should be remembered - they argued Big Ag in the opaque LOBBY in favor of glyphosate. (3) 

So what if an organic operator works with the utmost diligence, takes all reasonable measures to avoid contamination, while his 'conventional' neighbor sprays his land on windy days, with badly calibrated sprayer nozzles and 'rains' unwanted contaminants on organic soils, who pays for the damages ?

According to logic shared internationally, the polluter pays. But no. In this reverse system, the organic farm pays for any damage caused by others. To the point of undergoing the withdrawal of certification for an 'alien' contamination of 0,1 grams of pesticide per 10 tons of its product. Even if it is an active principle whose use is devoid of technical sense on its crop and instead derives, in all evidence, from the 'exuberant' use in the neighboring conventional farm.

Coldiretti, Confagricoltura and CIA praise the decline of 'quality of organic','Green light to contaminated organic', not mentioning that their own associates are responsible for the accidental contamination in Italy. He argues that 'the fruit and vegetables we import from Germany and Sweden could theoretically present a contamination above the threshold of Italian organic, so it is better to buy a conventional Italian product'. (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 European level is in any case very low (eg 0,15 grams of residues on 10 tons of product).

Above ground cultivation. The agricultural confederations then contest the transitional regime 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 prohibited at European level by reg. EU 2018/848. A controversy based on nothing, given that the derogation concerns a total area of ​​20 hectares (already identified, restricted and not subject to any possible expansion), that is 0,00016% of the 12,1 million hectares cultivated according to the organic method in the EU .

GMO? No thank you

The confederations of'conventional agriculture they then evoke the 'GMO monster', asserting that the regulation would open the door to GMO contamination. False. EU regulation 2018/848, on the other hand, specifies the following.

'L'use 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 with the perception that consumers have of organic products',

'GMOs, products derived from GMOs and obtained from GMOs are not used in food or feed or as food, feed, processing aids, plant protection products, fertilizers, soil improvers, plant reproductive material, microorganisms or animals in organic production'.

The threshold for accidental contamination or technically unavoidable with GMOs authorized in the EU is not even mentioned in the regulation on organic production. It was instead defined, in a share of 0,9%, by reg. CE 1829/03 and applies to all conventional and organic productions. Provided that operators are able to demonstrate to the competent authorities that they have taken all appropriate measures to avoid their presence.

The Italian conventional agricultural organizations instead they claim that GMO contamination within the 0,9% threshold is considered a priori 'technically unavoidable' on their products, and intolerable on 'organic' ones.

L'hypocrisy rules, where it is recalled that 15 years ago both Confagricoltura (still faithful to the line) and CIA (which instead turned around) took sides in favor of GMOs. Coldiretti declares itself against GMOs, but counts among its members agricultural consortia which are still the first retailers of GMO feeds of foreign origin (as well as glyphosate) in Italy. 

Not by chance, the voice of any of its representatives has never been heard, in the Consortia for the protection of PDO and PGI, to propose theexclusive use of feed 'GMO free' and ban GMOs. As the Consorzio della Fontina DOP did instead, of its own free will.

Dario Dongo 


(1) Threshold introduced in Italy with Ministerial Decree 309/2011

(2) A phenomenon classified as 'technically unavoidable' can occur, for example, in the hypothesis 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. The European regulations acknowledge that 'some pesticides contaminate the'environment, whereby their residues can be found'in food

(3) In this regard, see the positions expressed by Copa-Cogeca, the European confederation that represents the confederations of conventional agriculture, of which the president of Coldiretti has the vice-presidency.

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

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

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