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Disposiciones que las especiales circunstancias de Galicia exigen para la

Responding via this conference to the draft document on the EISfOM ‘Framework for a European Information System for Organic Markets’ it is important to be clear about who we are and on whose behalf I am speaking.

The Soil Association was founded in 1946 with a mission to research, develop and promote sustainable relationships between the soil, plants, animals, people and the biosphere, in order to produce healthy food and other products while protecting and enhancing the environment. There are two distinct parts to our organisation:

1. The Soil Association is a public and business membership charity whose activities include:

ƒ Educational campaigns reaching out to consumers, farmers and the food industry, opinion formers and policy makers.

ƒ Policy research into targeted areas of agriculture and the links with health, environment and animal welfare.

ƒ Promoting local food and community supported agriculture.

ƒ Representing organic farmers and serving their needs through providing information, training, conferences, demonstration farms, policy representation, supply chain facilitation and market intelligence.

ƒ Setting private standards for organic production and processing (compliant with EU regulations). 2 The Soil Association also has a wholly owned subsidiary company (Soil Association Certification Limited) which inspects and certifies farmers and processors using Soil Association standards. It has two main programmes:

ƒ The symbol programmes using Soil Association standards. ƒ The global partnership programme accredited by IFOAM.

In addition, SA Certification also holds equivalent standards and inspects to general UK farm assurance schemes in order to give improved marketing opportunities.

So when responding to the draft paper, I am considering:

ƒ Our role as a certification body where we contribute to collection of data. ƒ Our role as a policy organisation where we are often reliant on data.

ƒ Our role as a farmer and business support and development organisation where we are involved in carrying out both generic and very specific market intelligence.

1 Head of Food and Farming, Phil Stocker, Soil Association, 40-56 Victoria Street, UK-Bristol BS1 6BY, Internet www.soilassociation.org

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ƒ And finally, our role in representing farmers and organic businesses where we try to ensure appropriateness, relevance and simplification of data collection and market intelligence.

I believe it would be useful to reflect on the purpose of market intelligence and information around the organic market. The need for market intelligence (based on good data collection) can be identified at several levels – EU policy and regulation, member state governmental policy, NGO/development activities, business and trading activities, but its value is in enabling good decision making at all or any one of these levels. Our experience shows that, as you might expect, the broader and more generic the information is the less value it has at a local business decision-making level (even though it may still be of interest). A 100 hectare beef and sheep farmer in upland Northumbria may not be able to use to his advantage the knowledge that there are six million hectares of organic land in the EU and that this has increased by 1.6 percent over the year1

. He may, though, be very interested that the area of land in the north east of England has increased and that the majority of recently converted land is in arable lowlands from which he might access his feed and where he might find an outlet for finishing store lambs. He may be even more interested to know that over the last year there has been an increase in the number of consumers wanting to buy a wider range of regional lamb based products, and that there is an absence of these products available.

The Soil Association has produced the Organic Food and Farming report since 1998, and during that time we have been aware that the information is sometimes of more value to policy makers and journalists rather than businesses – although its impact ultimately benefits businesses. In the UK the report has been an absolute necessity and has informed many decisions taken by governments, RDAs and others, which ultimately feeds down to help those on the ground. In producing our annual report we have often struggled to get accurate baseline data, so we would value an improvement in the range and quality of statistics available and indeed have been working with Defra to achieve this. In addition to organic statistics the Soil Association is also working with Defra on its Whole Farm Approach2, an initiative to

centralise and co ordinate data and information.

Working with organic businesses, the Soil Association believes our next steps in terms of providing market intelligence and information are to look in detail at what is happening on a regional or devolved nation basis, and to investigate specific production lines including retail statistics, supply chain relationships, regional and local import / export levels, seasonal production trends and so on. Indications are that this detailed information will start to provide organic businesses with the type of information they need to make sound business decisions, and therefore improve the effectiveness of market intelligence and information across the board.

The Soil Association’s view of the framework outlined in the draft paper is that it is of value and we offer the following response:

1 Relevant Data Collection and Processing Systems as starting points

We agree that Farm Structure Survey (FSS) data are not particularly useful for continuous observation due to infrequency and differences in methodology. However FSS does provide an ‘extra check’ so we would recommend an ongoing facility to identify organic activities within the FSS. Collection of data from the organic certification bodies is probably the most suitable for baseline data, however harmonisation will not be easy, updating all certification bodies information systems may be costly, and certification bodies will need to be recompensed for the work involved.

1 Soil Association (2005). Organic Market Report

2 For Further information on the Whole Farm Approach, contact Kathryn Wood at Department of Environment, Farming and Rural Affairs, [email protected]

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Proceedings of the Second EISfOM Seminar, Brussels, November 2005 Recording movement of organic products between actors in the supply chain will be complex and add a significant amount of processing time, and we need to remember that many products are traded between actors certified by different certification bodies and across Member States. We should also consider that many businesses feel strongly that trading information is commercially sensitive and, indeed, the certification bodies are bound by data protection. This area of data collection is likely to be difficult and should not hold up the overall plans for the framework.

Overall we need to focus on who wants what information and in what format - broken down into what do farmers want, what do traders want, and what do policy makers/development agencies want. Then we need make sure the information gathered by the certification bodies delivers this. As an example, if you look at the tables on the last two pages under the livestock heading, a farmer may want to know what the value of organic livestock is or whether availability of store cattle is up or down. A processor may want to know whether he can switch to all UK sourced beef and whether that beef is within his specifications. The policy maker may simply need to know the total number of stock compared to last year, to see if policies are working.

2 Recommended Classification Systems and Procedures

In the UK Defra should be the responsible body. This should not prevent areas of work being sub- contracted, but statutory information should be reliant on a statutory body.

We would not be opposed to legislation requiring certification bodies to use a classification system based on the Eurostat database. However legislation must be supported by financial compensation and support for as long as legislatory requirements last.

If this system is put in place it should be a requirement for all countries to comply immediately, i.e. we should not be using two different systems.

3 Recommended Reference Systems

Piloting and modelling systems could be valuable, although as suggested above, once the system is implemented all Member States should comply. In addition all stakeholders should play a part in defining reference systems.

4 Timing, cost frames and funding

Costs need to be broken down into system implementation, investments previously made and operation. Real costs must be met.

We agree that a combination of legal requirements and financial compensation is the key to effective EU statistics.

5 Actions Recommended on the European Level

Define a classification system to be used by all Member States and certification bodies (via Eurostat/ZMP)

The classification and codes in the proposed tables do not seem particularly appropriate for the UK - grass should be broken down into LFA/SDA and lowland permanent pasture, then rotational grass. Whether the grass is 1st year conversion, 2nd year conversion or fully organic should also be identified. The crops

look fine but it would be useful to identify whether the crops were intended for feeding livestock on the farm, intended for sale, and either as feed or for human consumption. The vegetable categories generally

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look suitable although it may be worth breaking them down more, such as salad crops, and a ‘catch all category’ is needed to ensure everything is captured. However it may be best to get a system working and then add categories later on. The livestock categories looks as though they need more work or at least some good guidance notes - numbers of cows sold and numbers of heifers coming into the breeding herd would be useful, and these figures always seem to ignore what has been sold during the year and for what (heifers slaughtered, steers slaughtered etc) but this would need the certification bodies to collect significantly more information than they currently do. Livestock with a short cycle such as lambs, pigs and poultry need to be on the basis of the total number sold during the year or the highest number at any one point. The aim should be to identify what the production levels have been during the year. Monthly or quarterly sales would be useful so seasonal trends can be identified, for example what proportion of turkeys are for the Christmas market and what for Easter.

Introduce a legal requirement for certification bodies to collect and provide detailed data

Consideration needs to be given to how long this may take.

Provide financial compensation to certification bodies

This needs careful analysis. The certification bodies need to be stakeholders and involved from an early stage, and all costs need to be considered including set up costs, compensation for systems already in place, and operation costs.

Investigate the Polish system for its success and whether it could be implemented in other countries

Again, the certification bodies need constant involvement: they need to be stakeholders rather than having something imposed on them.

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Eurostat and ZMP Codes and Classification systems–

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