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REMISS
          2003-02-28


Till: Europeiska Unionen
Kommissionen för jordbruk, Bryssel


SKIS synpunkter på EUs aktionsplan för
ekologiska livsmedel och odling

Towards a European Action Plan for organic food and farming
To take part in this consultation, you simply have to download the Consultation Document, take time to read it, then fill in the answering form below and return it to us (by clicking on the "Submit" button) before 16 March 2003.

Your replies will be analysed and used in developing the Action Plan. A summary of the input received will be published on the European Commission's Agriculture web site in the course of the summer. The final Action Plan will be published at the end of 2003.


Reply of the Swedish Consumer Coalition:

1. Marketing: Developing and facilitating various systems for organic produce sales. Do you think this is ...

"Very important" - Marketing efforts should be very personal, with farmers and consumers meeting more directly face-to-face than in conventional sales. This should emphasise that the organic food production chain is about real values, not marketing slogans. For consumers in cities, it is very important to understand the conditions of rural development and sustainable farming and to learn about the food quality directly from the people who produce the food.

2. Targeting: Targeting organic farming to environmentally sensitive areas. Do you think this is ...

"Very important" - To explain the benefits of organic farming, it could be positive indeed to show that efforts are made to protect water (by targeting farmers in areas near rivers) or to develop biodiversity (by targeting farmers who try to rescue and develop rare breeds and landraces). Targeting should not be a process that excludes those who have already made efforts to change their farming systems to organic.

3. Adviser service: Encouraging the exchange of technical information between farmers. Do you think this is ...

"Very important" - It is very important that adviser service is available to all who may want to convert to organic farming, and also that this is a sustained effort (not only a short-term effort).

4. CAP: Ensuring that the Common Agricultural Policy supports the development of organic farming. Do you think this is ...

"Very important" - We think CAP should support the development of organic farming, with a focus on environmental protection, animal welfare and real food quality.

5. Traceability: Ensuring traceability and organic food authenticity. Do you think this is ...

"Very important" - Traceability is important not only as you mention for "authenticity" but to transmit the value-based holistic essence of organic farming methods all the way to the consumer. Traceability should mean that information is available in the shop, for example through bar-codes and truthful labelling. It is also good to see the name of the farmer on the product, as well as other important information regarding any special treatment during farming or in the factory. Related issues such as Fair Trade and/or Corporate Social Responsibility can also be communicated through traceability systems for the organic food sector. It is very important that someone is responsible for the information and that consumers can ask questions about the organic food. We identify traceability as the key to creating real links between farmers and consumers.

6. Logo: Reinforce the use of the EU logo. Do you think this is ...

"Very important" - The EU logo should not be made mandatory unless there has been a debate about it and a consensus has evolved around this issue. It could take ten years or longer. Conflicts should be avoided by open exchange of ideas and an increased effort to include farmers and consumers in the rule-making. The Article 14 Committee, for example, is not seen as functioning very well today as it is not transparent and not accountable. Also, the EU logo would have to be made well-known through extensive (and expensive) campaigns in all languages. We think the current EU logo needs to be re-designed as it is difficult to understand. One possibility would be to use the EU logo in conjunction with a national or private logo. We think efforts should be made to avoid too many organic logos on the package.

7. Private standards: The access to information (common database) on additional standards and inspection requirements where they exist. Do you think this is ...

"Very important" - Open consultations are important to make the rules for private standards better. Information should be made available on the Internet. The work should be done together with IFOAM as they have the global perspective. Also, Codex Alimentarius should be given funding to put this important work on its agenda, for example by making a special Codex Task Force for Organic Food, hosted by a EU country and with funding for developing countries to participate.

8. Testing methods: The harmonisation of testing methods, control procedures, supervision and accreditation together with efficient co-operation between all actors involved in the inspection system, including Community inspections. Do you think this is ...

"Not important"

9. Import: The implementation of appropriate standardised procedures to ensure that imported products respect both fair competition with EU products and EU commitments regarding developing countries. Do you think this is ...

"Very important" - Both EU standards and private standards must become more open to organic foods from developing countries. Organic standards should avoid becoming seen as trade barriers. Especially organic foods from Least Developed Countries must be given better access to the EU market.

10. Standards: The establishment of a body for delivering independent, excellent and transparent advice on which production methods, substances etc. can be accepted in order to assure conformity with the principles of organic farming. Do you think this is ...

"Important" - Consumer organisations should be able to participate in the work.

11. Statistical data: The collection and communication of official statistical data on production, consumption, and trade (EU imports and exports) on a more permanent basis. Do you think this is ...

"Important"

12. Research: The effective funding of research in organic farming from the point of view of food safety and quality, including expanding research into the development of new products and processing methods and the environmental sustainability of organic farming, and into comparison studies between organic and conventional food. Do you think this is ...

"Important"

Apart from the proposals listed above, what else do you think could be done in order to facilitate organic farming in Europe?

We do not agree that "all or at least almost all food products should indeed be available as organic" (2.1.2 Processing). On the contrary, organic foods should maintain a specific identity and be seen as more natural, less processed than the ordinary large-scale mass-produced food. Organic foods must be an alternative, to avoid large agro-business that only has profit as its motive. If this means conventional food production changes to become more similar to the organic food production (with no GMO, no additives etc), then we have achived real sustainable development and created a better model for healthy food production. The Organic Action Plan should set a specific target to achieve this goal. Thus, we propose that the OAP should set an ambitious target aiming for 20 percent organic food farming in ten years in Europe. Thank you for this opportunity to make our voice heard.