Description of the EU Regulation requirements and main differences
The Regulation (EEC) 2092/91 has detailed requirements for the conversion of animal husbandry. Where a production unit is converted, the whole area of the unit used for animal feed must comply with the rules on organic farming, using the conversion periods established in relating to plants and plant products (Annex I B 2.1.). All livestock on one and the same production unit must be reared in accordance with the rules laid down in this Regulation (Annex I B, 1.5.) If livestock products are to be sold as organic products, the livestock must be reared according to the rules laid down in this Regulation for at least: 12 months in the case of equidae and bovines six months in the case of small ruminant and pigs; six months in the case of animals for milk production; 10 weeks for poultry for meat production, brought in before they are three days old, six weeks in the case of poultry for egg production (Annex I B, 2.2.1.).
International standards such as Codex Alimentarius and the IFOAM Basic Standards require more or less the same conversion periods for the various animal categories (according to product type) as the Regulation (EEC) 2092/91, although these two international standards are less detailed concerning derogation possibilities. IFOAM deviates from the Regulation (EEC) 2092/91as concerns the conversion period for dairy cows, as it is only 3 months for the milk of conventional dairy cattle (milking cows) brought onto an organic farm, while it is six months according to the Regulation (EEC) 2092/91 and Codex.
The US NOP requires animals to be from livestock under continuous organic management from the last third of the gestation period. There are exemptions for breeder stock, poultry and dairy animals where continuous organic management beginning no later than 1 year prior to the production of the milk is required.
Soil Association standards and the SE KRAV standards require breeding animals (with the exception of poultry) to be under organic management for several months and all the offspring to be reared as organic from birth. in order for their offspring to be considered ‘organic’.
Several private standards and one governmental rule require full farm conversion for all livestock categories as well as for the plant production (AT Bio Austria, CH Bio Suisse, CH Demeter, DE Bioland DE, Naturland, DK Governmental Rules).
Regarding the use of in-conversion feed; little differences could be found. FR Nature et Progrès allow only 20% instead of 30 % in conversion feedstuff or 60 % if from own farm land as the EU Regulation.
DIFFERENCES No. of diff.
Description of main differences Main differences on which level:
Justification MAIN AREAS Details: Int. Nat.gov. Nat. priv.
Conversion animals
40 Conversion period Full farm conversion
= =/+ + + +++ ++ Credibility
Discussion of potential impact and conflict areas
Consumers/public perception:
The length of the conversion period for different animal categories is generally not an issue for the consumers, except in countries where BSE has been a major topic, and the origin and feeding of the animals therefore has been an issue of importance, e.g. in the UK.
Trade implications:
Longer conversion periods result in higher costs and more bureaucracy for the farmers, as conventional, in-conversion and certified organic products must be kept strictly separated. However, within Europe there are no major differences between the national governmental and standards (with the exception of the UK).
Organic Principles:
An adequate conversion period to prevent transfer of potential residues/contaminants in animal products to the consumers is in line with the organic principle of health and care.
Discussion of harmonisation, simplification and regionalisation potential
DIFFERENCES No. of diff.
Impact on Potentials for
IN MAIN AREAS Cons Trade Org P Harm Simp Reg
Conversion animals 40 - + + yes yes yes
Harmonisation:
The conversion periods for the various animal productions within the EU member states are quite similar to the Regulation (EEC) 2092/91. However there are differences in the
requirements of full farm conversion, which is required by a several standards (see section 5.4.1). It is recommended that full farm conversion should be the rule at EU level as the integrity of the farm is a basic organic requirement. Full farm conversion also reduces the risk of fraud. However, it may be that some animal productions should have a longer time to be converted (e.g. pigs) than others (e.g. dairy and beef cattle). It is recommended to reconsider and harmonise the rules for in conversion-feed., in particular with regard to the difficulties to achieve 100 % organic feed.
Simplification:
The database does not provide indications for simplification of the animal conversion periods. However, the existence of several different conversion periods depending on whether it is a full farm conversion ,whether the land is converted, whether the livestock is being fed in-conversion feed materials or have received certain kinds of veterinary treatments one or more times is not easy to understand, and it indicates that there is some potential for simplification and clarification.
Regionalisation:
If a requirement on full farm conversion is introduced in the Regulation (EEC) 2092/91 it may be relevant to give the flexibility to introduce different time limits for the conversion of the various animal productions on the farm to obtain full farm conversion on a regional basis, since some markets are not yet developed and some productions, e.g. pig and poultry production may be more difficult to convert than others (beef and dairy production).
Main conclusion for revision process of Regulation (EEC) 2092/91:
It is recommended to consider harmonisation and simplification of the different conversion periods related to land and to livestock in relation to the feeding rules and veterinary rules as well as the use of in-conversion feed materials and the possibility of simultaneous conversion of the whole farm. Further it is recommended that the Regulation (EEC) 2092/91 is harmonised in a medium-term concerning the requirement of full farm conversion of all animal categories accompanied with the possibility of making regional variation (specific animal productions difficult to be converted, may be excluded from the requirement of full farm conversion).