Sveriges Konsumenter i Samverkan 
Commission of the European Communities
Madame Isabelle Putz
Madame Danielle Tissot
Mr Per Ahle
DG Agri B.3 Agriculture Product Quality Policy
Rue de la Loi 200 B-1049 Brussels
Re: Customs regulation 1788/01






The Association of European Consumers, AEC, would like to express our concerns regarding the customs regulation, EC 1788/01

The interest for organic products is growing among consumers, as stated in our Special Report on Food Quality (Dec 2001) and in our Opinion Paper on the Organic Action Plan (May 2002), available on www.consumer-aec.org. We have identified availability and price as being the major constraints for the rapidly devloping market. Products imported to the European Union constitute an important part of the organic market, both as non processed and as part in processed organic food.

AEC fears that the implementation of EC 1788/01 will result in difficulties for imported goods to reach the market, hence negatively affecting the consumer who wish to purchase organic foods.

The International Trade Centre at UNCTAD/WTO has made the case strongly that developing countries should be given better access to developed countries' markets. Currently, the WTO Doha Development Round promises among other things, better market access to developing countries. It seems to us that the EC 1788/01 will be a trade barrier that will not contribute to this aim.

In the last years several frauds in the organic market inside Europe have been revealed. As we understand there is no database or collected knowledge of the frauds that have occurred. In the future, this kind of database should also be made public, and form the analytic base for any new regulation aiming at increasing credibility and consumer confidence of the organic market. We have not been able to find any ananlys of the consequences of implementation of the EC 1788/01 regulation. If the goal of EC 1788/01 is to eliminate fraud on the market, there are also important problems connected with administration, and resources for the customs authoroties. Especially worrying is the harmful effect on small scale organic farming in exporting developing countries.

We ask you to reconsider the regulation EC 1788/01 in light of the consequences for the development of the organic market, the cost and the influence on exports from developing countries.

Yours sincerly, Ceri Lewis Co-ordinator
Upp