Description of the EU Regulation requirements and main differences
The Regulation (EEC) 2092/91 provides basic requirements for assurance of the stability of natural habitats used for collection of plant and fungus products. The same is true for the US NOP Regulation. Codex Alimentarius regulates this area more precisely than the Regulation (EEC) 2092/91 by additionally demanding that the operator is familiar with the collection area. The IFOAM Basic Standards are slightly more detailed. All these international standards or ‘standards for standards’ are providing only rough rules, not going into detailed requirements. Several private standard setters give very precise criteria according to which collection of wild plant products etc. may take place. Eight private standards cover the area of collection from natural habitats in detail (CH BIO SUISSE, CZ KEZ, DE Bioland, DE Naturland, Italian Organic standard, SE KRAV, SI rules, UK Soil Association). In general they require detailed information on the collection areas (maps etc.), on the collection intensity and on the training of the person in charge of the collectors, as well as buffer zones to cultivated land to prevent contamination. Most detailed in the requirements are the private standard setters, which have a long history in organic farming. These are mainly standard setters from the UK, Germany and Switzerland. Though the Western European countries have the most detailed standards for collection of wild plants etc., most of the collection of wild plants and fungi in Europe takes place in the Eastern European countries: Romania, Russia, Bulgaria, Serbia and Montenegro, Bosnia and Herzegovina and Albania (Censkowsky et al, 2007) except for Finland, which reportedly has the biggest areas for collection of wild plants etc. From an international point of view, the main collection areas are in China and in the developing countries. From there most of the goods are exported to Western European Countries or the USA.
Rationale for the differences:
Most private standards experts mention as justification for their detailed requirements compared to the Regulation (EEC) 2092/91 the objective of minimising the risk of damage to (or extinction) of the species harvested or damage to other species in the same habitat.
DIFFERENCES No. of diff.
Description of main differences Main differences on which level:
Justification MAIN AREAS Details: Int. Nat.gov. Nat. priv.
Collection of wild plants
Discussion of potential impact and conflict areas
Consumers/public perception:
In most European countries, environmental concern is a motivation for buying organic food (Zanoli et al, 2004, page 58). The motivation to support the protection of the environment by buying organic food is also relevant for collection of plant products from natural habitats.
Trade implications:
Stricter requirements for labelling of wild plant products from natural habitats will result in increased costs for such products (costs for training of collectors, registration of habitat area, inspection, etc.) and thus may lead to unfair competition if not applied consistently.
Organic principles:
Prevention of over-exploitation of natural resources is a major concern according to the ecological principle of organic farming. More precise standards in the revised EU Regulation on organic production may support a more sustainable approach for the collection of wild plant products from natural habitats.
Discussion of harmonisation, simplification and regionalisation potential
DIFFERENCES No. of diff.
Impact on/conflict with Potentials for
IN MAIN AREAS Cons Trade Org P Harm Simp Reg
Collection of wild plants 14 ++ + ++ yes no yes
Harmonisation:
The significance of collection of wild plant products from natural habitats is often underestimated in the organic food sector – which is reflected in the rather general requirements mentioned in the international standards. The global value of organic wild plant products in 2005 is reported to have been between 630 - 830 million Euros. However, not all certified organic wild products are sold as organic. Apart from the certified organic market for wild products there is also a big market for products collected in natural habitats which are not certified organic. The most important countries providing produce from registered wild collection are Romania, Kenya, Zambia, Finland, Azerbaijan, China, South-Africa, Russia, Namibia and Bolivia (Censkowsky et al. 2006). The community of environmentalists and the organic movement under the umbrella of IFOAM still discuss the criteria which will allow a sustainable collection of wild plant products. The monitoring of the sustainability in organic wild plant collection projects was judged as sufficient in 60% of the projects and as good in 40% of the projects by the respective certification agencies (Censkowsky et al, 2006). Since collection from natural habitats is a highly sensitive area of organic certification, it is recommended to mainstream the requirements on collection of wild plant products etc. at a more detailed level to increase the sound management of vulnerable ecosystems.
A harmonisation at the international level is recommended to obtain more sustainable collection of wild plant products. This could be achieved by amending criteria regarding:
- knowledge or training on sustainable collection techniques for the collectors and the person in charge of the collection activities, requirements for registration of the collection zone (maps, potential sources of contamination, etc.), and
- requirements on the documentation of the quantity and parts of the plants to be collected, criteria on how to judge parallel collection of the same product as certified organic and non- organic.
When doing so, regulations valid among environmental movements should be considered (IUCN, WHO and WWF).
Simplification:
The Regulation (EEC) 2092/91 expresses in a general way the concerns regarding sustainable collection of plant products from natural habitats, so there is no need for further simplification. On the contrary it is recommended that the requirements are made more detailed by setting up more specific criteria for the collection.
Regionalisation:
Regionalisation is not recommended in the field of wild collection requirements, since the core points in granting protection to vulnerable natural ecosystems is a global concern which has a broad consensus among countries and certifiers. However for some regional aspects there is a need for some specific criteria as some habitats might be vulnerable than others. This should be handled on a national/regional level.
Main conclusion for revision process of Regulation (EEC) 2092/91:
It is recommended to further specify the requirements on collection of wild plant products from natural habitats in the Regulation (EEC) 2092/91 by defining criteria for sustainable collection including requirements concerning registration and monitoring of the natural habitats and the education of the collectors. Regional aspects should also be considered.