Management of Organic Agricultural Inputs in Germany

Management of Organic Agricultural Inputs in Germany

Chang-Ju Huang-Tzeng

Professor, Department of Applied Economics,
National I-Lan University

Abstract

Most countries' current organic agriculture regulations list those inputs that may be used, and the inputs are uniformly expressed as raw materials or elements. Nevertheless, while farms actually often purchase many sorts of commercial production inputs sold on the market, governments still neglect to regulate those commercial inputs.

The commercial organic inputs must comply with the relevant input regulations before they may be sold. However, the inputs are not required to indicate that they may be used to produce organic products. Organic product producers must select inputs in accordance with organic standards. Therefore, they must bear responsibility for wrong choices. As a consequence, some private organizations, such as organic farmers associations, organic certification units, and even some local governments, have begun attempting to list commercial inputs and that may be used to produce organic products.

While Germany regulates pesticide-type plant protection preparations,it also permits the use of plant protection and plant health protection inputs produced on the farm. The government has produced lists of the latter two items for farmers' reference; organic farmers may use any of the products on these two lists.

This study alsosurveys the review standards used by various German authorities for organic agricultural inputs, and examines how the GermanResearch Institute for Biological Agriculture (FiBL) has compared and assessed various organic input review standards and review procedures under commission by the German Federal Government. This information may serve to guide the future management of organic inputs in Taiwan.

1.Forward

The "organic inputs" (or materials) referred to in this study mean those "elements (substances) or raw materials" used to produce organic agriculture products or foods, and those mixed (or formulated) "commercial production inputs" sold as branded products. Organic inputs include fertilizer, soil conditioners, plant protection agents (disease/pest/weed damage prevention agents), animal feeds, animal drugs, animal pen cleaning and disinfecting agents, and additives or auxiliaries used in processing.

Organic agriculture should, in principle, involve the use of inputs such as fertilizer or animal feed that are produced on the farm where they are used, or that are recyclable. However, under real production conditions, organic farmers typically need to purchase those inputs that cannot be produced on the farm, and this is especially true for inputs used for plant and animal protection. In addition, since organic processed products have gradually become important parts of the organic food industry, additives and auxiliaries used in the processing and preservation of organic products have also become major subjects of attention.

Generally speaking, most countries' organic agriculture regulations list those inputs that may be used. However, it is typically not easy for the government or organic association to determine which inputs should be included in organic standards. The elements and raw material items listed in major countries' or organizations' current organic standards are different. Schmidt et al. (2003, p.2) found after comparing the IFOAM (International Federation of Organic Agriculture Movement), UN, EU, Japanese, and US organic standards that each contained different input use regulations. Table 1 shows the numbers of identical and different inputs used for crop production in different organic standards. The various standards contain a grand total of 165 permissible inputs, of which 36 types are contained in all standards. However, 42 types are permitted by at least one set of standards but are not permitted by IFOAM. This shows that judgment standards for organic inputs are by no means entirely consistent.

Table 1 Differences Between Permissible Crop Production Inputs in Various Organic Standards

Category / Number of
input types
Permitted by all organic standards / 36
Permitted by IFOAM and at least three other standards / 68
Permitted by IFOAM and at most two other standards / 19
Not permitted by IFOAM but permitted by other standards / 42
Total / 165

Source: Schmidt et al., 2003, p.2

Furthermore, most countries' organic standards specify organic inputs only as raw materials or elements, and do not specify which commercial production inputs sold on the market may be used. This leaves organic product producers (including farmers and processors) uncertain of what to do when they need to purchase commercial production inputs, and they may even unknowingly violate organic standards. For their part, input producers and dealers are eager to have their products included among inputs permitted in organic product production.

Because of this, in recent years the assessment of organic inputs, especially commercial inputs, has become one of the most important issues in those countries that have drafted organic standards.

Countries' or organizations' organic standards once usually classified organic inputs as permissible, restricted or forbidden. But with the improvement of technology and institution of more thorough legal explanations, countries and organizations now use positive lists to enumerate permissible inputs.

The Taiwan "Organic Agricultural Product Production Standards -Crops" contains positive and negative lists of organic inputs. But because this leaves a grey area between what is permitted and what is forbidden, this isn’t an ideal approach. According to online data (8/23/2004) posted by the Council of Agriculture (COA), Executive Yuan, the COA had issued a total of 4,984 valid pesticide permits, but there was no indication of which of those pesticides could be used in organic agriculture. In addition, according to organic agriculture production standards, only those fertilizers classified under COA organic fertilizer item number 5-01 (plant waste fertilizers), 5-02 (byproduct matter fertilizers), 5-03 (fish waste processed fertilizers), 5-04 (animal waste residue fertilizers), 5-07 (nitrogenous seabird guano fertilizers), 5-08 (poultry and livestock manure processed fertilizers), and 5-09 (poultry and livestock manure composts) can be used in organic agriculture. However, apart from 111 fertilizer product brand names listed under item number 5-09 (poultry and livestock manure composts), the COA website does not contain a list of permissible fertilizers. There are no other guidelines concerning inputs that may be used for crop or livestock production.

As a consequence, organic input review criteria should be drafted first when organic agriculture regulations are revised in the future. These criteria should be used to compile positive lists of inputs, and afterwards compile lists of permissible commercial organic input products.

The main purpose of this study is to examine the organic input management guidelines and methods prescribed by relevant German standards or used by German organizations. This information may serve to guide the future drafting of organic input standards in Taiwan.

2.German Organic Agricultural Input Standards

Since Germany is a member of the EU, organic product production in Germany must comply with EU organic standards. But Germany has also drafted its own organic agriculture laws, including the Organic Agriculture Act, Organic Agricultural Product Labeling Act, and Organic Agricultural Product Labeling Usage Statute. In addition, Germany also has a Product Marking Act, Plant Protection Act, Plant Protection Input (Pesticide) Act, Fertilizer Application Statute, and Fertilizer Statute. The production, marking, and use of all pesticides, fertilizers, and other production inputs has been regulated, and organic inputs must also comply with the foregoing general laws and regulations.

Figure 1 shows the relationships between the different standards regulating organic inputs. All inputs used to make organic products must pass vetting by different legal standards or requirements. Only those inputs that meet all requirements can be sold and used in Germany. In other words, production inputs must first comply with the laws of Germany and then comply with EU organic standards before they may be used in organic product production. If the use of an input permitted by EU organic agriculture standards is prohibited in Germany, then it may not be used by German organic producers.And those organic producers who are members of organic associations must also uphold the relevant rules of those associations.

2.1.EU Standards (EC, 2004)

Inputs that may be used in accordance with EU organic standards are listed in Parts A – E of Annex II, which govern fertilizers and soil conditioners, pesticides, animal feed raw materials, animal feed additives, substances used for animal nutrition and auxiliaries used in animal feed processing, and products that may be used to clean and disinfect animal pens or equipment. Parts A and B list the names of permissible inputs in tables together with their descriptions, composition requirements, and use conditions. Parts C, D, and E list permissible inputs.

Annex VI regulates raw materials that may be used in processing.Parts A, B, and C respectively list raw materials with non-agricultural sources, processing auxiliaries and other products, and raw materials from agricultural sources but not produced organically. Parts A and B also list special use conditions. Although Annex VII is not directly concerned with organic inputs, this annex regulates the numbers of animals that may be raised for each hectare of land per year. The purpose of this annex is to ensure that no more than 170kg of nitrogenous fertilizer is used on each hectare of land each year and thereby avoid pollution of soil and water by nitrogenous fertilizer.

Any member state or organic product importer that wishes to recommend the addition or deletion of any inputs may submit its recommendations to the EU. The EU authorities will then request member states in writing to express their views. After receiving such a request, Germany's Department of Consumer Protection, Nutrition and Agriculture will commission its subordinate “Consumer Protection and Food Safety Administration” (Bundesamt für Verbraucherschutz und Lebensmittelsicherheit) to collect the views of relevant agencies, such as the "Federal Biological Research Centre for Agriculture and Forestry" (BBA) and private groups concerning the inputs to be added or deleted. The collected information is used to produce a response indicating acceptance or refusal of the addition or deletion proposal. Member states generally make such decisions based on their own domestic needs, such as whether they must use the input in question or whether the input is harmful to food or the environment. An application may be made to delete an input if an original input can be replaced by a newer and more effective input, or if the assessment of an input has changed.

2.2.German Standards

Production inputs that are permitted by EU organic standards are not necessarily all permissible in Germany. For instance nicotine and

For instance,because nicotine and rotenone are toxic to humans, fish, and bees,pesticides containing these substances may not be imported into or transported in Germany.

Taking plant protection inputs as an example, all plant protection inputs used in Germany must comply with the following positive list regulations (Kuehne et al., 2001, p.6):

1. Government-Licensed Plant Protection Preparations

So-called government-licensed plant protection preparations refer to commercial pesticide products. Applying for a pesticide license in Germany is an extremely lengthy and difficult process. The Federal Consumer Protection and Food Safety Bureau (Bundesamt fur Verbraucherschutz und Lebensmittelsicherheit – BVL) under the department of consumer protection, nutrition, and agriculture (Germany's original "Department of Agriculture," now renamed the Bundesministerium für Verbraucherschutz, Ernährung und Landwirtschaft – BMVEL) is in charge of this process, while the BBA, Institute for Risk Measurment (Bundesinstitute fuer Risikobewertung, BFR), and Department of Environment (Umweltbundesamt, UBA) are responsible for assessment. Each type of pesticide license must specify which crop it is meant to be used on and which pest or disease it is meant to combat; if the pesticide has two kinds of effects, a license must be obtained for each one. Apart from assessing biological, food, and environmental safety, the determination of whether a pesticide may go on the market must of course also include an assessment of its effectiveness; and a new pesticide may not be less effective than a pesticide already on the market with the same purpose.

Nevertheless, pesticides on the market do not bear markings stating whether they can be used to produce organic products. Farmers must therefore select from those pesticides that licensed for sale in Germany and also specified as permitted inputs by EU organic standards. While farmers are often unclear about which pesticides may be used on organic products, they can use the on-the-market pesticides listed by their association if they are association members.

2. Permitted Farm-Made Plant Protection Inputs

Some natural substances, such as Quassia (or their bitter fluids), are important inputs in organic agriculture in spite of their relative lack of effectiveness. Since pesticide manufacturers perceive the market for this type of natural product to be small, and licensing costs are very high, the pesticides are considered unprofitable and not sold on the market. Germany consequently revised its Pesticide Act on May 14, 1998 in order to allow farmers to meet their need for these substances or raw materials. Chapter 6a of the revised Act regulates those plant protection inputs made by farmers themselves from substances or raw materials not consisting of pesticides purchased on the market. BBA announced pursuant to this revision a list of substances that may be purchased and mixed or processing oneself for use on one's own farm. Although the listed substances may not be used on household gardens, they have great significance for organic farm use.

Criteriafor assessing the listed substances include the following:

(1) The substances have no harmful effects on humans, livestock, groundwater or natureduring reasonable use and after use.

(2) When used in organic agriculture, the substances or their mixed preparations fundamentally meet the requirements of Annex II-B of the EU organic standards.

Because a dossier need not be submitted when applying to use these substances,and because farmers are permitted to prepare and use the inputs themselves, BBA must take extreme care when examining the substances and deciding whether to allow them. Neither agricultural substances and raw materials (for instance dry protein and Diammoniumphosphate, etc.) not permitted in Germany nor pesticides or microbes whose sale is permittedare included on this list. However, those plants or other basic substances (inorganic substances) that can be obtained on a farm or nearby, that can be prepared by oneself in the form of plant protection inputs for use on one's own farm, and that are not purchased, are not subject to the regulations of the Pesticide Act concerning self-prepared plant protection inputs.

3. Plant Health Protection Inputs

In Germany, apart from the foregoing on-the-market pesticides and plant protection inputs self-prepared by farmers, the new regulations in Chapter 2, Point 10 of the 1986 Pesticide Act regulate so-called" pflanzenstaerkungsmittel"(plant health protection inputs); these plant health protection inputs, which are not employed in other EU countries, are defined as follows:

(1) Inputs able to improve plants' ability to resist pests and diseases.

(2) Inputs able to protect plants from the effects of parasites.

(3) Inputs able to protect cut ornamental plants and thereby avoid need for cultivation inputs.

Whileplant health protection inputs are not listed in Annex II of EU organic standards, and may be used by organic farmers, the approval of an organic association or certifying organization must sometimes be obtained before they may be used.

The review of plant health protection inputs addresses whether they may cause harm to human beings, animals, groundwater or nature. However, plant health protection inputs may not directly kill pests or disease-causing organisms, since that would result in their classification as pesticide plant protection inputs.

Plant health protection inputs include:

(1) Inorganic substances including SiO2, Silikate(gesteinmehl), CaCO3, Al2O3, and NaHCO3, etc.

(2) Organic substances including plant extracts, preparations and fats and oils, "Algenextract", and compost extracts, etc.

(3) Homoeopathic substances including the foregoing organic or inorganic substances.

(4) Microbial preparationsincluding fungi (Trichoderma, Pythium oligandrum) and bacteria (Bacilus spp., Pseudomonas spp.) etc.

4. Inputs Specified in Organic Association Regulations:

Where regulations with legal force do not regulate on-the-market commercial inputs, organic associations may, in addition to listing permissible substances and raw materials subject to their regulation, also list on-the-market inputs as a reference for organic farmers.

The foregoing overview of permissible inputs indicates that the organic inputs that may be used by German organic farmers must comply with EU organic regulations governing permissible substances and raw materials. In fact organic farmers may purchase those commercial agricultural inputs sold in accordance with domestic laws and complying with EU regulations. However, since officials have not listed which on-the-market inputs may be used in organic agriculture, the members of an organic association may purchase and use those inputs listed as permissible by their association. Apart from on-the-market commercial inputs, officials have also compiled a list of those substances and raw materials that may be purchased for the self-production of plant protection agents and a list of plant protection inputs for organic farmers' reference.