Organic productions are often subject to disinformation by the mainstream media. We have already disproved some erroneous news about the breeding conditions and animal welfare. And the time has come to clarify the control regime in organic production. The ABCs of rules and numbers leave no room for chatter.
Organic production, distinctive features
La organic production is characterized by the following distinctive elements:
- conforms to a technical canon associated with quality systems,
- is governed by mandatory rules,
- is guaranteed by the institutions through a control system,
- is identified by a single logo that summarizes its values,
- pursues goals with environmental and social value,
- provides for the indication of origin of raw materials (eg Agriculture Italy, EU, non-EU, near the logo).
The control system - understood as the set of activities, methods and tools to guarantee the conformity of products - provides for the synergy of control authorities (public bodies) and Control Bodies (CBs, public or private entities in charge of public service). The latter carry out inspection and certification activities, with the authorization of the public authority responsible for the supervisory function.
The declaration of conformity the requisites envisaged by the organic regime can only be issued by an accredited body, authorized to carry out control and certification activities in the specific sector. The authorization is granted by the Ministry of Agriculture, Food, Forestry and Tourism (MiPAAFT), accreditation by a guarantor body ('Accredia' for Italy). Both are called upon to supervise the activities of the certification bodies, in order to ensure compliance with the rules. The accredited Body must be extraneous to the company 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, which guarantees. The control system
All stages of production and marketing - also through ecommerce, as clarified by the EU Court of Justice - must comply with the control system established by European rules. (1) That is to say that every operator involved in any phase of the process - 'from farm to fork' is 'from stable to table'- must adhere to the control system.
Product compliance designated as 'organic' is guaranteed through self-control by the operator, control by the certification body, supervision by the Control Authorities. The conformity of the product is certified through documentary declarations and is verified through management and analytical checks. With the guarantee of traceability of the two essential elements:
- compliance with the method,
- the origin of all the materials used.
The control system, in detail, is divided as follows:
- inspection 'on site' by technical inspectors (IT) appointed by the Control Bodies (CB), at all operators, with minimum annual frequency,
- sampling and analysis. The technical inspectors (IT) take the samples, in the number and under the conditions prescribed to ensure their representativeness, and send them to the laboratories authorized by the Competent Authority (CA) for analytical verification,
- certification by the CBs, by validating the results of the inspections and analytical findings. The frequency of annual inspections and withdrawals from each individual operator are defined on the basis of the risk analysis prescribed by the regulation, according to the procedures indicated in a technical document of the National Accreditation Body (RT16 Rev. 05 Accredia).
- Biological Information System (SIB), on-line public register of all operators participating in the method. The register, constantly updated, is available on the website www.sinab.it.
Effectiveness, efficiency and impartiality of the control system are guaranteed by applying the following procedures:
- selection and training of IT, as regards competences and potential conflicts of interest on the part of the CBs,
- monitoring of the work of IT by the CBs,
- CB authorization by the Competent Authority (CA),
- authorization of IT to operate on behalf of the CB by the Public Authority (CA),
- supervision of the work of the CBs by the CA and the Accreditation Body. Activity that includes:
a) exhaustive audits at the CB offices, on an annual basis,
b) inspection and analytical checks (the latter only by the CA), every year, on a representative sample for each individual CB,
- exchange of information - both between the CA and the CB, and between the different CBs - with the frequency and content provided for by the legislation,
The competent authority (CA) must organize regular inspections at the CBs. With the power to withdraw the mandate for controls, if following an inspection there are deficiencies and the delegated party does not take appropriate and timely corrective actions. The CA is also required to:
a) ensure objectivity and independence of the checks carried out by the CB,
b) verify the effectiveness of controls,
c) note the irregularities or infringements found and the corrective measures applied,
d) revoke the authorization of the CB that does not meet the requirements of the standard.
Inspections by Control Bodies (CBs) provide, with a minimum annual frequency, the following phases:
- verification of the certification pre-requisites,
- inspection of facilities,
- verification of good operating practices and processing records,
- possible sampling.
The CBs as mentioned above, they are in charge of public service, however without the power to impose administrative sanctions and the role of judicial police. In the event of non-conformities found during inspections, they take the following measures:
- beware (a written warning that provides for the terms to remedy the situation), in the case of non-compliance (i.e. a slight non-compliance that does not compromise the conformity of the production process or of the company self-control system, without substantial changes in the status company (e.g. delay in sending documents which are otherwise regular),
- Suspension of the company for six months, with return in conversion of the land for 24/36 months, up to
- exclusion by the control system, in cases of infringement. In other words, breaches of a substantial nature that compromise the conformity of the products and the reliability of the operator (e.g. use of non-permitted plant protection products).
All non-conformities they must be registered and reported to the CA and to the Region where the operator is based. It will be the competent authority, after verification in the company, to impose administrative sanctions and communicate any news of the crime to the judicial authority. The Region in turn will order the return of any contributions paid to the operator as part of the Rural Development Plans. (2)
Checks on organic in Italy, the data
Checks on the bio they can be divided into two stages, the activity of the Control Bodies (CB) and the supervision of the competent public authority (CA).
1) Controls by the CBs. The latest available data show that in 2016 the CBs carried out an average of 115 audits per 100 operators, of which 15% without notice. 12% of the activities involved sampling. 4.166 'Non-conformities' (5.8%) were opened and 7,5% of the samples carried out were positive. However, this last data is not representative, from a statistical point of view, since the samples are taken selectively from sectors, companies and products that present the highest criticality in terms of contamination risk. Furthermore, the level of attention and investigative professionalism is highlighted, aimed at intercepting anomalies before the products reach the consumer.
2) Supervision of the CA. The supervisory activity of the Central Inspectorate Department of Quality Protection and Fraud Repression of agri-food products (ICQRF) has increased significantly (+ 35%) in the last three years. And if on the one hand administrative disputes and crime reports have increased in proportion, at the same time there has been a sharp decrease in irregular analytical results (-50%). In addition to the number of seizures (-42%) and the value of the goods seized (-77%, 0,01 of the market value in 2018). It is also worth noting how the ICQRF almost always carries out the checks 'without fail', following precise reports of non-conformities detected by the CBs during their daily inspections.
ICQRF, controls in the organic sector, 2018
|
Control activity |
Variation 2015/2018 |
2018 |
2017 |
2016 |
2015 |
|
Inspection checks (no.) |
33,6% |
2771 |
2738 |
2690 |
2074 |
|
Controlled operators (no.) |
37,3% |
2297 |
2250 |
1956 |
1673 |
|
Irregular operators (%) |
22,8% |
11,30% |
6,60% |
7,40% |
9,20% |
|
Controlled products (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 reports (n.) |
183,9% |
88 |
19 |
37 |
31 |
|
Administrative complaints (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 (n.) |
103,7% |
110 |
75 |
49 |
54 |
|
Market value (ml. €) |
111,0% |
5612 |
5381 |
4936 |
2660 |
|
Impact on total market value |
-89,5% |
0,01% |
0,02% |
0,03% |
0,10% |
* date not available. Sources: processing of Bio data in figures (2017), Bioreport (2016-2018), Nomisma for Assobio (Presentation of the Brand 2018), ICQRF (Activity Report 2017 and 2018)
The violations disputed they are largely attributable to consumer information and administrative-accounting failures. In particular:
- violations of the rules on labeling and presentation of products (37%),
- administrative-accounting offenses (irregular record keeping, inaccurate or irregularly compiled commercial documentation, etc., 28%),
fraudulent acts (marketing of conventional products such as bio, pesticide residues not allowed in organic farming, 17%),
- commodity irregularities (13%),
- administrative violations linked to the system of geographical indications (evocation of registered names, use of false or misleading indications of origin, 5%).
Organic, why trust
The rules and the data expressed above demonstrate - above any suspicion, misinformation and doubt raised by different stakeholders - how the system of public-private controls on organic production is tetragonal, effective and efficient. Even if it is perfectible, like any anthropic activity. And it is good to note that all the aforementioned controls are added to those to which organic processes and products are subjected on a par with conventional productions.
Accredia it then adopted a technical regulation (RT16) which requires each Control Body to keep an updated where they are registered:
- operators and products (operator code, company name, address and VAT number, certified products and related codes, certification status),
- transactions relating to bulk products (quantities, documents, recipients).
The databases they are shared between the control bodies - and made available to the competent authority - in order to allow for cross-checks. The , once completed with the predictable average yields in the different territories for the different crops at the various altitudes, will allow the automatic validation of the yields declared by the producers. The further step must be to make the database accessible also to operators, in order to allow them a more immediate qualification of suppliers. By checking their status, the congruity of the quantities produced in relation to the company surface, the mass balances (quantities purchased and sold or transformed).
Italian consumers are doing well therefore a favor the purchase of organic products, as the controls on them are actually superior. But also and above all because thanks to their choices, like the same FAO recently suggested, contribute to preserving biodiversity and the ecosystem. Respect to climate changes and the pesticide contamination that still exists today poison of the environment and people.
Choose organic farming ed equivalent, linked as much as possible to the territories, means contributing to the good of the community and participating in progress. Thanks to the determination and cohesion towards this choice, moreover, in that 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. Really natural. The coveted democratization of bio it is in fact the best of the results that can be aspired to, in the Italian food supply chain.
# Égalité!
Donato Ferrucci and Dario Dongo
Footnotes
See reg. CE 834/07 (Title V, Controls), Legislative Decree 20/2018
(2) See Ministerial Decree 15962 of 20.12.2013 (Provisions for the adoption of a list of 'non-conformities' regarding the organic qualification of products and the corresponding measures that the Control Bodies must apply to operators pursuant to reg. EC 889/2008 last amended by EU Implementing Regulation 392/2013)
REFERENCES
BioReport years 2016-2017-2018. Organic farming in Italy,
Bio in figures 2017, on www.sinab.it,
Nomisma for Assobio. Brand presentation 2018. The Italian market of organic products,
SINAB. http://www.sinab.it/content/rese,
SIAN. https://www.sian.it/consRese/paiRicerca.do (Public consultation made)
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.
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
