Amending certain production, labelling and certification rules and certain rules on trade with third countries

The requirements for waiting times for synthetic allopathic products and for the origin of animals have a strong negative impact on the organic milk sheep sector. There are many inconsistencies in these points with the fundamental principles of organic agriculture: animal welfare, grazing as soon as time allows, reduction of inputs.

Filed in French · English published by the European Commission

Thank you for giving us this opportunity to participate in the consultation. It is very important for me to extend the extension so that 5 % of protein raw materials can continue to be used in the feeding of young birds in order not to harm animal welfare due to an increase in amino acid shortages that already suffer especially in warmer climates in Europe, as this reduces feed consumption and amplifies shortcomings…

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Biopartner is an association that manages the fair label and 100 % organic eponymous since 2002. In 2025, BIOPARTENAIRE represented more than 85 organic and fair sectors, both in France and internationally. The association brings together 74 French operators: producer groups, importers, processors, all brands of SMEs rooted in their territories and engaged in organic, fair and responsible CSR practices.

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On behalf of the Austrian Chamber of Agriculture, BIO AUSTRIA, and the IG-Bio-Control Bodies, I would like to submit the following concise proposals within the framework of the simplification process for Regulation (EU) 2018/848. These proposals would lay the foundation also for a restructuring of the secondary legislation system and could contribute to greater clarity on specific interpretive issues.

COPA and COGECA enthusiastically welcome this initiative, and the willingness of the Commission to apply very targeted updates to the Organic Legislation. We highlight that the Organic Legislative Framework functions and establishes a system that is unique and offers added value to the European Union.

Opinion on the simplification of the EU Organic Regulation for organic poultry production Objective: Simplify certain rules to make organic production in the EU more competitive and reduce the administrative burden. 1. In future, open-air areas and full feathering will be provided on each organic poultry house for pre-breeding, even if the animals are not yet able to use it physiologically.

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The Latin American Association of Small Producer Organisations in Cocoa is a regional group that currently brings together producer organisations and national cocoa farmers from 4 producing countries. In general terms, the product of the various measures contained in Regulation (EC) No 2018/848 and the details laid down in Regulation (EC) No 2021/279, and almost one year of the entry into force of the Regulation…

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Contribution of the paysanne Confederation on the targeted revision of the biological regulations: The Confederation of Farmers supports organic farming as a coherent framework for a demanding agro-ecological transition, free of pesticides and synthetic inputs, rooted in the regions and delivering a social model based on many of its peasants, fairly remunerated and protective of life.

Filed in French · English published by the European Commission

I have been an organic farmer since 2018. The reason why we have made this choice is that the strict specification corresponds to strong consumer demand and allows us to truly differentiate our dairy products from our colleagues in conventional farming; The reopening of the EU organic regulation should be limited to clarifying the labelling of products imported from outside the EU, in order to provide consumers with…

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— position the deadline for anti-parasitic diseases at 0 – Stop down on purchases of BIO animals through the database – Delete lobligation dutilisation of milk powder Bio – permit the use of vegetable oil in slab feed (allow the tariff to be tempered) – Prolong the derogation of 5 % of non-organic feed for young pigs, young poultry, and ALSO for unproductive animals

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In the context of the reopening of EU Regulation 2018/848, ECOCERT supports a limited revision of the basic act and targeted amendments in secondary legislation in a second step. After four years of application in Europe and one in third countries, it appears that the implementation of certain requirements reveals limits with significant consequences for both operators and control bodies.

Our position on the reopening 1- A misunderstanding of this reopening approach The GAB85 Board of Directors would first like to mention its incomprehension in the face of a revision of the Regulation which seems very premature. A revision of such an important regulation, drawn up following a lengthy consultation process, only 3 and a half years after its implementation, is very premature.

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Agronomes and Véinaires Sans Frontières (AVSF) is a French association of international solidarity which has been operating for more than 40 years with certified organic farmers’ organisations in developing countries.

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1. Pig farming: Place the weaned piglets for the weight section up to 20 kg, half of the space required = 0.5 m² per animal. Justification: The small piglets do not heat up the previously demanded berthing area and are above each other in order to heat themselves, as well as boiling the too large lying area and making the air in the house very poor.

Filed in German · English published by the European Commission

Dear Commissioner for Agriculture Hansen, ladies and gentlemen of the Commission, as a pure organic feed producer (Meika Biofutter GmbH) located in Germany (Bavaria), please see our comments in the annex. Thanks.

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The Spanish Federation of Associations of Producers Exporters of Fruit, Vegetables and Live Plants (FEPEX) has identified the following points (detailed in the attached document): Only organically certified plant material should be considered – making full use of the TRACES system for the management of imports from third countries – Standardisation of organic production requirements for all Member States –…

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The Union of perfume, aromatic and medicinal plant professionals (PPAM of France) welcomes the opportunity to comment on the application of Article 29 of Regulation (EU) 2018/848 on the presence of non-authorised products and substances in organic products. PPAM DE FRANCE fully supports the objectives of the biological regulation.

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90 % of the open-air areas of organic pigs should remain covered. As 50 % of the open roof area is a reasonable assumption for pigs and farmers (rain, snow, fog and permanent wet open-air areas), it would be a huge additional workload for the farmer. (Sun and heat) stress for pigs and the risk of sunburn.

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Coverage to improve the welfare of organic pigs and better N-circulation while preserving the open-air nature Theme: Annex II, Part II, 1.6. Housing and husbandry practices, 1.6.5: Open-air areas may be partially covered. [...] Proposal for improvement: The entire Part II of Annex II should be separated into rules for individual livestock species.

Filed in German · English published by the European Commission

Copenhagen, November 17th, 2025 Dear Commission Thank you for initiating this consultation and for giving stakeholders the opportunity to provide input on the proposed changes to the organic regulation. We wish to draw attention to the significant challenges posed by the requirement in Annex II, part II, section 1.5.2.5 for an additional and long withdrawal period for organic egg producers.

I have given myself my say as an organic tree for almost 20 years. If you are touching our label, open the door to organic production without any interest. I will be the first to leave it. Our customers come to consume at home because they know that their labelling seriously checks and controls our practices.

Filed in French · English published by the European Commission

At the level of the poultry sector represented in the Committee of Producers, simplifications are considered important for the future of farms in Wallonia, given the pressure on farmers and the economic impact on their incomes. The following points for simplification are listed: food 100 % organic, anti-parasitic, organic parents, duration of removal, size of buildings, size of pullets, perches.

Filed in French · English published by the European Commission

Swedish Eggs are pleased for the opportunity to comment on how Regulation (EU) 2018/848 can be amended and simplified. We see a great need and opportunity to simplify the rules for organic production, without watering down the rules, or changing the principles of organic production. Organic rules are perceived as difficult to understand, expensive to apply and very detailed.

Filed in Swedish · English published by the European Commission

The grazing regulation from month 4 onwards is particularly problematic for me and many other holdings, as these animals are mostly kept without direct access to grazing areas because they often still receive milk and are kept close to the dairy chamber. In addition, organic holdings are still to be regarded as organic even though they cannot comply with the Grazing Regulation.

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Trade Equitable France, a national group of fair trade players, stresses that the simplification of the regulation is an opportunity to remove obstacles that could disturb the import of organic products, which affects more than 80 % of fair products, and to increase prices on the European market. Imported organic products have a significant weight in the EU agri-food sector.

Filed in French · English published by the European Commission

I have been an organic producer since 1994 on a farm with dairy cows, poultry and a processing and direct sales plant. 5 people are working on these 140 ha and this is the first time that the entry into force of a new regulation is so disruptive that my children who need to follow up raise a lot of questions about the future of organic farming on the farm... I have several issues that seriously question us.

Filed in French · English published by the European Commission

The AGRIAL goat milk branch brings together 42 organic goat farmers for an annual organic milk production of 6 million litres. The reopening of the European Organic Regulation allows us to raise several issues that penalise organic goat farmers. These points severely hamper the development of the organic goat dairy sector.

Filed in French · English published by the European Commission

We believe that it is not appropriate to simplify the organic regulation in this way. The current rules are not just constraints, but the foundation of organic farming, and the guarantee of consumer confidence. As an association to raise awareness among the general public, we meet people every day for a variety of reasons to consume or not to consume organic.

Filed in French · English published by the European Commission

With the switch to 100 % organic food, we face more food-related problems. Maintaining the derogation of the 350 m length of journeys is, for us, the essential content of the configuration of our land. Review the 48-hour withdrawal period for medicines with zero withdrawal period. Study the feasibility of increasing the density inside buildings, without affecting the outdoor range for the lack of egg production.

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AVEC the Association of Poultry Processors and Poultry Trade in the EU and ELPHA the European Live Poultry and Hatching eggs Association - represents the EU poultry meat sector from breed to meat. We welcome the possibility offered by the Commission to provide feedback on the call for evidence aiming at updating the rules on organic production. Our proposal is available in attachment.

Hi, I have a small farm all organically certified in France, where I breed egg-producing chickens and grow berries. The reason I can today pay myself, is because my production is certified as organic, and can guarantee me better prices than if I was not.

In the context of the revision of the Regulation on organic production of laying animals, we would like to draw attention to a number of key issues in order to maintain the technical, economic and health viability of farms while ensuring animal welfare.

Filed in French · English published by the European Commission

In the case of fattening pigs and cattle fattening, covering the open-air area must be possible up to 90 %. The 50 % target is a danger to the animals, with up to 90 % possible for fattening pigs and cattle fattening and covering the open-air area. The 50 % target is a danger to animals, increasing the proportion of wetlands and increasing the risk of disease.

Filed in German · English published by the European Commission

I am writing to you to draw your attention to important aspects of the planned simplification of the EU Organic Regulation. The proposed changes concern in particular organic poultry farming and have a significant impact on animal welfare, economic viability and the future of many farms.

Filed in German · English published by the European Commission

ODNV is a French cooperative of egg packing centres which pack and package eggs of hens born and reared in France, including organic eggs collected from almost 200 farmers. The latest EU legislation, which was implemented in 2022, had a disproportionate negative impact on organic laying and egg production due to a large number of constraints. In this context, farmers are increasingly abandoning production.

Filed in French · English published by the European Commission

Problems relating to the application of the BIO Regulation 848/2018 in Madagascar and proposals for adaptation 1. Certification of vulnerable cooperatives Problems: Peasant groups do not have the administrative capacity to formalise themselves and manage the required documentation (register, CTL, TRACES). CTLs are expensive and heavy for small volumes.

Filed in French · English published by the European Commission

Hello! I am an organic nut tree grower in Sweden. Simplification is welcome, but strictness is necessary. Some of the "simplification" proposals are just weakening the protection of our soils and our citizens. Stand up for a better future, don't agree to this! As a final recommendation: I would welcome a minor change, to allow for using humanure in organic tree agriculture. Peace, Göran

Recent developments in organic regulation create several significant difficulties in livestock farming. The shift to 100 % organic feed in laying hens, and soon in pullets, leads to nutritional imbalances, digestive disorders and a weakening of animal welfare, especially among young people. Since this transition, we have also seen a significant fall in production, with significantly worsening economic results.

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BioForum welcomes the Commissions initiative to safeguard international trade relations by providing clarity about organic goods imported under the equivalence scheme and by postponing the deadline to conclude on new trade agreements. We also appreciate the Commissions intention to reduce unnecessary burdens and simplify the organic regulatory framework.

It is important not to change the maximum size and rearing unit thresholds in order to continue to have a clear difference with conventional standards. The rules concerning the non-use of plant protection products should not be relaxed. Some of the natural origin for use in AB are, moreover, relatively toxic. Do not move towards the reintroduction of plant protection products under the pretext of competitiveness.

Filed in French · English published by the European Commission

We are an organic dairy farm. Guaranteeing certification in line with our values is based on the European Organic Regulation and must continue to defend a demanding organic environment. The addition of points to the Regulation should bring social, environmental and animal welfare improvements. Under no circumstances should this lead to relaxation or loss of requirements.

Filed in French · English published by the European Commission

I am a producer of Bio Quand laying hens I started, we were entitled to 5 % of the feed ration of conventional cereals. This made things much simpler because there were fewer variations in quality, and it was easier to raise lots... less picking, more homogeneity, less refusal and sorting

Filed in French · English published by the European Commission

Minimum total area and functional areas instead of minimum indoor area and minimum outdoor climate area! Themes: EU Implementing Regulation 2020/464 laying down detailed rules for the application of Regulation (EU) 2018/848, Annex I, Part III, specifies stocking densities, minimum indoor areas and minimum outdoor areas for pigs referred to in Article 10.

Filed in German · English published by the European Commission

In the context of the consultation on the simplification of the organic regulation, Interfel stresses the need for a harmonised regulatory framework between Member States in order to avoid distortions of competition in the organic fruit and vegetables market.

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Revision of the BIO Regulation Opinion of the backing ingredients association e.V.: The Back/71 Association e.V. (BZV) represents 42 member companies of the manufacturing supply industry in Germany and Austria. In doing so, we represent most of the companies in our industry. Our members supply bakeries, confectors and other processors.

Filed in German · English published by the European Commission

I am a farmer of organic laying hens and therefore concerned by the various laws. I am in favour of the proposal to simplify Regulation (EU) 2018/848 on biological production. With the implementation of the various regulations I encounter great difficulties: the switch to 100 % organic food is one of them; problem of regularity and quality of the food (which causes picking and behavioural problems).

Filed in French · English published by the European Commission

In principle, I am also of the opinion that the same rules should apply to organic farms worldwide. In my view, this is not the case now! Compared to other Länder, Germany again implements 150 % of the requirements for organic farms. For 28 years, we have managed our farm in accordance with the Demeter guidelines and would like to continue to do so.

Filed in German · English published by the European Commission

Feed back on: Organic production targeted updates and simplification There are these points how it would help Danish ecologists to benefit animal welfare and climate more: 1. when ecologists need to treat flies or worms with medication, the milk is discarded as organic for two days due to double retention rules.

Filed in Danish · English published by the European Commission

Adaptation of production rules: In poultry farming, several production units (e.g. 3000 laying hens) on one holding should be possible. Otherwise, supplying small businesses will be difficult for trade. Providing open-air areas for chicks that are not feather-proof is not useful and incomprehensible. Open-air cover for pigs and calves should remain flexible.

Filed in German · English published by the European Commission

Hello, in order to save the Bio sector, there is an urgent need to simplify its rules. The latest amendments now bring technical performance and thus economic losses for laying hen farmers. This means that many of them will stop farming where possible. Here are the options to be put in place to respond to ANIMAL ETRE BIEN: — Organic food containing 95 % and anti-parasitic treatment without waiting time.

Filed in French · English published by the European Commission

I am writing to you to draw your attention to important aspects of the planned simplification of the EU Organic Regulation. The proposed changes concern in particular organic poultry farming and have a significant impact on animal welfare, economic viability and the future of many farms.

Filed in German · English published by the European Commission

There must be exemptions from full grazing for dairy cattle and cattle holdings. The word ‘full’ must be removed from the law. Holdings which, for structural reasons, cannot carry out grazing or which individual groups of animals cannot graze, need a perspective. The grazing principle should be interpreted as follows: Grazing, where possible, otherwise access to open-air areas and roughage.

Filed in German · English published by the European Commission

We have spent on a food of 100 % AB in laying hens, which poses real problems, is it possible to reverse this constraint? In addition, the same trend is planned for the supply of pullets at the end of 2026. This constraint will have an even greater impact on the feeding of young animals and will result in the risk of digestive disorder and thus deterioration of animal welfare.

Filed in French · English published by the European Commission

Full grazing is hardly feasible for most farms. The Regulation should therefore be designed in such a way that it remains workable for both animals, farms and humans. We are a suckler cow holding with bull and heifer fattening, where the suckler cows and calves are on the pasture from spring to winter. The animals can decide on a daily basis whether they go to pasture or prefer to stay in the house.

Filed in German · English published by the European Commission

Grazing for organic cattle animal species should continue to be compulsory. However, farmers should be given more flexibility in implementation. For example, young calves of around 4 months should not be forced to graze, or only proportions of groups of animals (e.g. 80 %) should have to be grazed.

Filed in German · English published by the European Commission

The Pays de la Loire Region has taken note of the initiative presented by the European Commission for a targeted amendment of Regulation (EU) 2018/648 and wishes to contribute to the development of the microalgae sector, which has been supporting it for many years in its role as leader in economic development.

Filed in French · English published by the European Commission

Arla Foods expresses serious concern that implementing an approval procedure or maintaining a positive list for cleaning agents and disinfectants in organic production could result in considerable administrative and economic challenges for manufacturers. We suggest that management of products of cleaning and disinfection shall be guided by a potential negative list with exclusive criteria instead.

hi. This is about using painkiller without having to get the vet. on the farm first. Both with cows and calfs. Especially with small one s. Giving painkiller in and early stage of infection, this could bring down the numbers of pneumonia that actually need antibiotics. Also cows with a swollen leg that we hometreat with saopy water. Here in combination with some painkiller it would shorten of the treating period.

Hello, with regard to the rules for organic laying hens since 2022, too many changes have been made, which have had a negative impact. The fowls lose their feathers and do not respect animal welfare. Hens eat more and see an economic disaster. The same applies to anti-parasitic treatments, which require the declassification of eggs, which is also economically negative!

Filed in French · English published by the European Commission

Hello, Eleva of laying hens since we spent 100 % organic in 2022 shameful of my hens, because they are all poor, have seen what is lacking. JAI took particular care to enrich their surroundings, both later and indoors (lucerne bio), but no results. Since 2022, I’ve been able to visit my farm because it is afraid that my hens are being treated poorly.

Filed in French · English published by the European Commission

There must be exceptions for (dairy) holdings which cannot comply with the grazing requirement for structural reasons! For the other holdings, it should also be sufficient if each group of animals has access to grazing for a few weeks in the course of a year.

Filed in German · English published by the European Commission

As a French organic market garden since 2009, I wish to contribute to the planned updates and simplification. I would like to maintain all of the following claims: the preservation of the link to the soil, the stability of the rules for conversion to lobjective AB of having 100 % organic seeds and plants dici 2036 prohibiting OGMs and New Genomic Techniques into AB, consolidated a traceability system for products…

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Opinion on the simplification of EU ÖKO Regulation (ECO Regulation) on organic poultry farming 1. Grassed open-air areas and full featuring: It is entirely sufficient if the open-air area has to be present in the house only when the animals are fully fidered for broilers, the 28th day of life should be defined here.

Filed in German · English published by the European Commission

Dear Agriculture Commissioner Hansen and dear Commissioners, I am writing to draw your attention to important aspects of the planned simplification of the EU Organic Regulation. The proposed changes mainly affect organic poultry farming and have significant implications for animal welfare, economic viability and the future of many farms.

Filed in Danish · English published by the European Commission

We have spent on a food of 100 % AB in laying hens, which poses real problems, is it possible to reverse this constraint? In addition, the same trend is planned for the supply of pullets at the end of 2026. This constraint will have an even greater impact on the feeding of young animals and will result in the risk of digestive disorder and thus deterioration of animal welfare.

Filed in French · English published by the European Commission

It is the implementation of the rules that should be simplified, in particular through: 1-reducing bureaucracy for small farms and producer organisations. 2-A number of audits proportionate to turnover, the volume of activity therefore at the risk of one sector. 3-It is not normal that the concept of risk leading to the multiplication of audits should be at the sole discretion of the certification body.

Filed in French · English published by the European Commission

As an organic farmer and processor, I would like to draw attention to vigilance that should not be simplified at the expense of food security and understanding by all stakeholders. Consumers confuse labels: organic and local, organic and ‘untreated’. Care not to take the quality of the organic label down. It would probably be appropriate to prohibit fanciful or misleading designations.

Filed in French · English published by the European Commission

Hello, I am a market garden ab, I am worried about the degradation of our environment, the ab specifications are the guarantee that we do the most to limit our impact on the environment. It must remain strong at European level to ensure the sustainability of our agriculture, with climate change challenges. We are chairs and bones, we need to preserve the resources of our environment.

Filed in French · English published by the European Commission

Proposal to amend Implementing Regulation (EU) 2020/464 splitting the minimum indoor area and the minimum outdoor area for rearing piglets into two sections of weight to date: In accordance with Annex I to Implementing Regulation (EU) 2020/464, after weaning up to 35 kg live weight piglets have at least 0.6 m² of indoor area and 0.4 m² of outdoor surface available.

Filed in German · English published by the European Commission

Less rigid rules for blending or preparation with. In view of future consumer trends towards more convenience food, it is blended or prepared with a wish that lives. This was also the case in our investigation. Obviously appropriate within (eu) organic legislation. And ensuring that there is no confusion with the consumer as to the reliability of bio.

Filed in Dutch · English published by the European Commission

In my opinion, synthetic amino acids should be authorised. This serves to improve the supply of poultry and thus to improve animal welfare. Methionine is the limiting factor in poultry nutrition. In order to compensate for the poor qualities or low levels of methioning in local leguminous crops, the total crude protein content in the organic compound feed is increased.

Filed in German · English published by the European Commission

Industry demands on the EU: Ensure that organic poultry are kept in practice: see attached file Opinion on the simplification of the EU Organic Regulation for organic poultry production Objective: Simplify certain rules to make organic production in the EU more competitive and reduce the administrative burden. 1.

Filed in German · English published by the European Commission

Why a revision without taking stock? OK for all measures towards: the preservation of the link to the ground – the stability of the rules on conversion to AB – 100 % organic seeds and plants dici 2036 – the prohibition of OGMs and New Genomic Techniques into AB, – no change on these criteria – control of harmful organisms and weeds, which do not use synthetic products – access to pastures and open air areas –…

Filed in French · English published by the European Commission

Dear Sir/Madam, regarding the revision of the Organic Regulation, I think it is important that this revision be limited to what is strictly necessary. Indeed, the latest revision is still recent and it is important to bring stability to our label. This stability is one of the key factors for consumer confidence in this quality sign.

Filed in French · English published by the European Commission

Ecology is at the heart of our farm Our family station was converted to ecology in 1998. We are very happy to be ecologists, but probably also challenged by rules that make it difficult to remain ecologists. In particular, grazing over 7 hours is very difficult to live up with a way we have built our housing over the last 20 years. I would like to say that we are doing much that is far beyond the organic rules.

Filed in Danish · English published by the European Commission

Under no circumstances should the production rules or the organic rules be changed, as a guarantee and quality guarantee for the consumer. It is the essence of organic farming, which must be demanding and not a discount. In the face of the climate and health emergency, it is not the time to decline, but rather to develop organic farming and protect its regimens that are making its quality.

Filed in French · English published by the European Commission

The organic product specification should not be further reduced, particularly as regards animal feed – and, above all, the authorisation of GMOs and NGTs should not be introduced. The basic principles of organic farming are 100 % organic food, access to the outside, and above all limit the size of farms to ensure animal welfare.

Filed in French · English published by the European Commission

— The European organic specification should not be simplified, as it has already been sufficiently drawn downwards since 2010. — Mirror clauses must be applied to organic products imported into Europe so that they comply, as a minimum, with the European organic specifications.

Filed in French · English published by the European Commission

Pullets and hens cannot be of good quality and composition if they remain on 100 % AB. The edges of the runs must be capable of extending up to 350 m from the hatches without necessarily being covered. It must be possible to adapt the light to the age of pullets as in conventional conditions. If too many constraints are imposed on AB production, this will no longer be done in France.

Filed in French · English published by the European Commission

since a 100 % organic diet, we have seen a fall in anisi ponte, as problems of more pickling and increasing food consumption in winter gardens have further isolated and even more human tejrs, especially with an investment of EUR 000 and even by doing nothing will not change for the part of the chickens why they are removed before they are laid, as they leave the laying cycle completely.

Filed in French · English published by the European Commission

The main brake is the resource to fertilisation and I think the current rules are too strict. The number of tetes per farm that is currently taken into account in order to be able to use their manure is too restrictive. And I do not see how this affects the quality of the finished organic product.

Filed in French · English published by the European Commission

1) We recommend reviewing how certification costs for smallholder supply chains can be reduced. Current situation: The new regulation will likely lead to a decline in organic production in third countriesespecially for products commonly grown by smallholders such as cocoa and coffee. Supply chains are struggling to bear the costs and administrative burden of organic certification.

Synabio is the French national trade union of organic food processors (200 members/combined CA: EUR 5.3 billion). Synabio agrees with the need to reopen the basic act of Regulation (EC) No 2018/848 in order to resolve certain problems (time limits for the introduction of trade agreements for imports, the Herbaria case and the Groupements of Operators) but in as limited a way as possible and without calling into…

Filed in French · English published by the European Commission

There is still more regulatory requirement, but no added value on the producers that allow for the financing of changes in the specifications. Agriculture is no longer a concern for any of the Union’s political representatives in view of the agreements currently being signed. I will not go further, but that would not be a trouble if there was a regulatory reduction in the ABiO.

Filed in French · English published by the European Commission

There is a general problem of too little organic livestock farming due to organic legislation. We have around 11-12 % of organic land in the EU. But we have only around 4-5 % organic livestock farming. Organic farming is largely in a 1-4 % niche (except extensive cattle rearing and laying hens with around 10 %). Organic livestock farming is therefore more than half lower than the proportion of organic land.

Filed in German · English published by the European Commission

VKS (Verband der Kali- und Salzindustrie e.V.) is the Association of the German Potash and Salt Industry. We welcome the revision of the regulation as an opportunity to remove salt (salt chloride) from the list of certified organic products. Salt is an inorganic mineral - it is not an organic or agricultural product.

The Ligue pour la Protection des Oiseaux (LPO/BirdLife France) considers that ‘organic production’ certification is the only guarantee of a production model that makes it possible to preserve biodiversity effectively through the imposition of synthetic inputs and, more broadly, through all the principles set out in Article 5 of Regulation (EC) No 2018/848 of 30 May 2018.

Filed in French · English published by the European Commission

Please find enclosed my opinion on the simplification of the EU Organic Regulation for organic poultry farming. We are poultry faters. 1. Open-air area: The planned provision for a grassed open-air area from the first day does not correspond to the physiologishcen condition of the animals of a very young age.

Filed in German · English published by the European Commission

Phytases are one of the major breaks in animal feed in the last few years. Major impact on the environment, conservation of resources, well-being and animal health. There are many difficulties in feeding organic animals. It is very damaging that they are not allowed to feed organic animals.

Filed in French · English published by the European Commission

We at Lovang Lantbrukskonsult AB work on organic crop management advice and represent our organic farmers. We are pleased to have the opportunity to comment on how Regulation (EU) 2018/848 can be amended and simplified. We see a great need and opportunity to simplify the rules for organic production, without watering down the rules, or changing the principles of organic production.

Filed in Swedish · English published by the European Commission

Managing pasture access for herbivores is complex, yet current organic rules demand almost constant access to grazing. This rigid interpretation threatens farms with certification loss, reduction of economic viability, reduced organic production, and animal welfare issues.

I am a professional in the laying sector and I would like the following points to be revised: The 100 % organic feed poses real problems in terms of performance and couts: Definition of a single 95 % organic feed obligation for all poultry (more than management of derogations) Delete the additional date period before the eggs have been placed on the market, after allopathic veterinary treatment, where the legal time…

Filed in French · English published by the European Commission

Dear Sir/Madam, my feedback relates to the subject of ‘grazing requirements for organic farms’. In this connection, I can once again urge you to withdraw the grazing obligation that goes beyond practice, or at most to limit it to one animal group per holding. A full grazing obligation for all animal groups would mean up to 70 % of dairy farms in Germany!

Filed in German · English published by the European Commission

Minimum total area and functional areas for pigs instead of minimum indoor area and minimum outdoor climate area! Themes: EU Implementing Regulation 2020/464 laying down detailed rules for the application of Regulation (EU) 2018/848, Annex I, Part III, specifies stocking densities, minimum indoor areas and minimum outdoor areas for pigs referred to in Article 10.

Filed in German · English published by the European Commission

We share the concern of many actors: the product specification for organic production is the very foundation of the BIO label and the guarantee of consumer confidence. It is therefore essential that the revision does not lead to a weakening of the technical requirements or to a simplification of the normative content of the product specification.

Filed in French · English published by the European Commission

It must continue to be possible for organic livestock farmers to comply with the requirements: The rules on grazing must take account of the fact that small holdings in town centres have no possibility of going to pasture. Keyword stock protection. Open-air areas should not be compulsory for organic chicken farmers. The use of sewage sludge must be made possible as part of the nutrient cycle principle.

Filed in German · English published by the European Commission

The requirements for 100 % feed and nutrient cycles must be harmonised for livestock farming, biogas plants and fertilisers. Everything else is imprecise and, like the constant expansion of authorised products in production and processing, leads to the dilution of eco-standards, misleading and confusing consumers and loss of credibility.

Filed in German · English published by the European Commission

The market for organic products has been developed by organic farmers. It is also the organic farmers who have worked extensively on public relations for decades, thus ensuring credibility and building consumer confidence in organic products.

Filed in German · English published by the European Commission

In our view, as organic farmers, it is for the EU Organic Regulation to lay down a binding framework for organic production within the EU and for products designated as organic within the EU, but not to regulate everything in detail. The aim of simplifying the EU Organic Farming Regulation must not be unbalanced new rules.

Filed in German · English published by the European Commission

With regard to the Commission’s recent interpretation of the grazing obligation in the EU Organic Regulation, we refer to various legal opinions which conclude that the current EU Organic Regulation does not include any grazing obligation. The Court of Justice of the European Union should ultimately see this as well. The Commission claims that it is about animal welfare and consumer protection in this matter.

Filed in German · English published by the European Commission

If something is good, you can let it be good. In this case, chicks for fattening must be pulled up to day 28 in a closed and protected area. Until the animals have a feather clamp, thus ignoring wind and weather. In addition, and this is not to be ignored, these animals are exposed by weight and size to a significantly smaller hazard from birds of prey or even predators.

Filed in German · English published by the European Commission

Our Bio Français label is much more virtuous than those of our neighbours and must remain so! Our requirement for climate and the environment is non-negotiable even if European states no longer feel too concerned! Live the farmers and farmers Bio who work for everyone.

Filed in French · English published by the European Commission

We import organic coffee into the EU. We are not interested in weakening organic regulations, however we would like to emphasize its ramifications for small producers, potentially leading to them abandoning certification. The definition of a "group of operators" includes criteria that do not align with the realities of coffee producers in Latin America and most probable also Africa and Asia and should be adjusted.

I am very committed to the principles of AB. If there must be a change, it should only be for a tightening of the rules (but certainly not for a reduction) and for a fairer recognition and recognition of this life friendly agriculture. I am a farmer.

Filed in French · English published by the European Commission

I would like the specification for agriculture to be kept unchanged, apart from labelling for products coming from outside the EU. There should be no relaxation of the product specification, it is ambitious and it is very good for biodiversity.

Filed in French · English published by the European Commission

There is a need to further stimulate the development of organic livestock production in Poland. At this point in time, we have very high barriers, hampering the development of organic livestock production due to the restrictions – in particular the conversion period – and the introduction of a non-organic flock onto the farm.

Filed in Polish · English published by the European Commission

The association agrees with the proposal setting a minimum threshold for resting poultry, i.e. at least 1 cm perch or 5 cm² of raised shelves per poultry, in order to ensure a balance between animal welfare and maintenance and assembly/dismantling time.

Filed in French · English published by the European Commission

Thanks for this opportunity by opening this portal for public consultation. Our views on behalf of our association, which consists of accredited bodies carrying out the inspection and certification of agricultural products in Türkiye, are as follows: 1. Different opinions exist regarding precisely which activities the legal personality can conduct as group of operators (GoO).

Regulation (EU) 2018/848 and its implementing rules for Regulation (EU) 2021/1165 are often drafted in a cumbersome way, but they are at least consistent. The lack of transparency and unnecessary restrictions arise in matters left to the discretion of the Member States, such as the definition of intensive livestock farming, with reference to the use of conventional manure, provided for in Annex II to Regulation (EU)…

Filed in Spanish · English published by the European Commission

I am in favour of simplification of controls under the EC Organic Regulation. A kind of bonus for holdings which come from checks free of defects will only be subject to an EC Organic Regulation check by the certification body after two or three years.

Filed in German · English published by the European Commission

Salts from France, a union of the main producers of French salt (sodium chloride), welcomes the revision of the regulation as an opportunity to remove salt from the list of certified organic products. Salt, as a mineral by nature which is non-living, does not fall within the category of agricultural products. It is therefore contradictory to want its production to comply with the rules applicable to organic farming.

Filed in French · English published by the European Commission

Hello, I am a director of a group of producers of eggs and pullets, some of which are in organic production. I am in favour of the simplification of Regulation (EU) 2018/848 on organic production. My experience leads me to see that a number of my members are about to stop Bio production because their performance is falling sharply and calls into question the viability of their holding.

Filed in French · English published by the European Commission

— Record the share of 5 % of non-organic feed allowed (no longer under temporary derogation) – reduce the size and number of perches or raised platforms to 1 cm of perchoir or 5 cm² of raised platform/poultry – Removal of BIO parenthood

Filed in French · English published by the European Commission

Ladies and gentlemen, on the one hand, I operate a poultry slaughterhouse where I slaughter 25.000 organic animals per week and, on the other hand, I have 4600 organic chickens myself. In the direction of the EU regulation, I am particularly concerned by two points: 1. Compulsory entry for young poultry. If chicks have to be provided from the first day, this is no longer feasible for many farms.

Filed in German · English published by the European Commission

I am run in organic farming and I think that there should be no concession whatsoever on the very principles of why organic farming exists. In my view, the Pandore box should not be opened up to specific cases, to the endless derogations which will ultimately only weaken this sign of quality and which will not allow us a fine to distinguish ourselves from consumers once again we need to trust research in order to…

Filed in French · English published by the European Commission

In the current state of possible alternatives, cups must all be kept usable for organic farmers and others. Exceptionally and occasionally, an alternative to the pyrevert must be authorised as part of the control of flavescence dorée cicadelle

Filed in French · English published by the European Commission

Hello, I am against this change, which is still against what is needed for humans. Organic farming, which protects the environment and human health, is demanding in terms of animal welfare, offers more sustainable solutions for the future.

Filed in French · English published by the European Commission

I am a producer of organic plants and I do not understand all this simplification. Simplification means reducing requirements. This is really not the moment. What do you want to get closer to a production method that kills us... that wants to help you? I am totally against this development. We can do otherwise.

Filed in French · English published by the European Commission

The regulation of BIO must move towards a higher requirement and not vice versa. I agree with any resolution aimed at weakening the requirements of the tender specifications. It is an important quality label in Europe and must remain coherent and credible for all consumers.

Filed in French · English published by the European Commission

The Bavarian Farmers’ Association (BBV) is the professional representative of Bavarian agriculture. Of the approximately 135.000 voluntary members, some 7,700 members operate in accordance with the organic farming guidelines.

Filed in German · English published by the European Commission

As a contact point for the Normandy Regional Association of Organic Farming for short supply chains and mass catering, I am also concerned about the downward revision of the criteria in the specification for AB within the EU. Despite its existence for many years, consumers are struggling to find themselves on all labels and the AB label remains the most identified and reliable in the eyes of the mangers.

Filed in French · English published by the European Commission

since the implementation of the new organic regulation, several problems have arisen and have penalised the development of the sector: the 100 % monogastric feed (less performance, less animal welfare, more imports) should be reviewed and 5 % re-authorised for laying hens and 5 % accepted for young animals without derogation.

Filed in French · English published by the European Commission

As a marketing specialist in organic meat, in particular for organic poultry meat, we support the position of the AöL in its proposed amendments to simplify the EU Organic Regulation. An obligation to open poultry from the first day of life does not correspond to the physiological conditions of the animals nor is it practically feasible for the majority of holdings.

Filed in German · English published by the European Commission

Simplification of the product specification for organic farming should be limited to clarifying the labelling of products imported from outside the EU, in order to provide consumers with informed information about organic products coming from countries outside the EU. Any amendment or update must under no circumstances call into question the key requirements of the product specification.

Filed in French · English published by the European Commission

The stability of production rules is clearly a guarantee of consumer confidence. It is already complex to raise consumers’ awareness of the requirements and reliability of controls. On the other hand, any revision of the requirements of the Regulation entails a risk of the organic label being declared invalid and of destabilising the market.

Filed in French · English published by the European Commission

Why a regulatory review when the previous revision is less than 4 years old is far too premature! Economic actors need stability and organic producers need more public support and remunerative prices. Consistency and the requirement of the organic regulation must be maintained in order to remain credible to consumers: Importance of the link to the soil with much of the animal feed produced on organic farms and in…

Filed in French · English published by the European Commission

Bio Centre thanks the European Commission for organising this consultation and for giving stakeholders in the organic sector the opportunity to express their position on the reopening of Regulation (EU) 2018/848.

Filed in French · English published by the European Commission

I am opposed to the relaxation of organic rules. I am a farmer of organic pigs in the open air and I think the regulation is very good. If it is relaxed, consumers will no longer make a difference with other labels and organic farming will continue to lose market share. But can it be that that is what the European Commission wants?

Filed in French · English published by the European Commission

I am in favour of a specification with strict standards to avoid all the externalities of agriculture, such as the disappearance of insects, birds, landscapes and widespread contamination of drinking resources. For animal welfare. For a carbon balance of negative farms and full autonomy. What the European Commission is proposing should be stopped by relaxing the organic specification.

Filed in French · English published by the European Commission

— Food 100 % organic: food imbalance due to lack of protein in organic food. Direct consequences in technical performance leading to problems of animal welfare (picking, deficiency, shell problem and increase in egg production in a strained sector. Simplify the rules without derogation with a single rate of 95 % of organic feed at any stage of the poultry.

Filed in French · English published by the European Commission

Hello, as a citizen and employee of an association for the development of organic farming, I am against the reopening of the organic specification. It is the guarantor of sustainable and virtuous practices for soil, biodiversity, producer and consumer health. There is already a lack of consumer confidence in the organic label, making it less demanding will be seriously damaging for the industry and the market.

Filed in French · English published by the European Commission

Ladies and Gentlemen, we have a small organic farm. Our maize and soya must be dried down to the remaining moisture needed depending on the weather conditions of the year. We save fossil fuels for drying by using the waste heat of a biogas plant in the vicinity. At an economic distance, we have the choice between 10-15 biogas plants. Which of these is used depends on the current free drying capacity.

Filed in German · English published by the European Commission

Je ne comprends pas le choix d'effectuer une révision prématurée du Règlement. Une révision dun règlement aussi important seulement 3 ans et demi après sa mise en œuvre, alors que les producteurs bio attendent des PRIX et des SOUTIENS PUBLICS.

In my view, the Commission’s approach to the need to balance the rules on imports of non-Community organic products is relevant and relevant. Since my experience of more than 15 years in the production, processing, distribution and marketing of organic products within the Spanish State, I can say that imports of raw materials and products from third countries have always been a serious problem for farmers and…

Filed in Spanish · English published by the European Commission

Opinion on the simplification of the EU Organic Regulation for organic poultry production Objective: Simplify certain rules to make organic production in the EU more competitive and reduce the administrative burden. 1. In future, open-air areas and full feathering will be provided on each organic poultry house for pre-breeding, even if the animals are not yet able to use it physiologically.

Filed in German · English published by the European Commission

The EU Organic Regulation introduced for the first time Europe-wide control rules for organic farms in 1992. I switched my farm to organic farming in 1991 and the EU Organic Regulation has seen the EU Organic Regulation as a very good basis providing clarity and certainty to our farmers.

Filed in German · English published by the European Commission

Opinion on the simplification of the EU Organic Regulation for organic poultry farming 1. In future, in accordance with the Organic Regulation, grassed open air areas should be provided at each organic poultry house for pre-breeding, even if the animals are not yet able to use it physiologically.

Filed in German · English published by the European Commission

Dear Sir/Madam, my feedback relates to the subject of ‘grazing requirements for organic farms’. In this connection, I can once again urge you to withdraw the grazing obligation that goes beyond practice, or at most to limit it to one animal group per holding. On the basis of many research, we are convinced that a full grazing obligation for all animal groups would mean up to 70 % of dairy farms in Germany!

Filed in German · English published by the European Commission

Forum Fairer Handel is a fair trade association in Germany. Its goal is to raise the profile of fair trade, formulate joint demands towards political decision makers and to achieve greater awareness for fair trade practices as well as for the demands of smallholder producers. We welcome the Commissions initiative to adapt Regulation 2018/848 to ease implementation efforts for organic producers.

We thank the Commission for opening the possibility to amend specific but important aspects of organic production through adjustments to the basic act. Below are eight areas where targeted changes can improve animal welfare, legal clarity, and economic viability. Further details are provided in the attached document. 1.

Topic chloridazon-desphenyl. Legal development: Since 2017, the new Regulation 1015/2016 amending Annexes II and III to Regulation (EC) No 396/2005 applies. Paragraph 3 provides explanations on chloridazon and a new limit value for chloridazon has been established.

Filed in German · English published by the European Commission

I would like to recall the important objectives of access to hay for poultry farms, to limit the size of the cranes in order to show a real ambition and difference from the requirements of the open air specifications.

Filed in French · English published by the European Commission

Theme Assessment of measurement uncertainty in RL_0006 in Austria The methodological uncertainty is a tool used throughout Europe to assess laboratory analysis results. It is set out in document SANTE/11312/2021.

Filed in German · English published by the European Commission

The issue of proportionality in the new EU Organic Regulation The different interpretation of the application of proportionality under Regulation (EU) 2028/848 in comparison with Regulation (EC) No 834/2007 is an incomprehensible provision The application of proportionality seems to be no longer valid in many EU Member States as a result of the deletion of Article 30(1) of Regulation (EC) No 834/2007 in Regulation…

Filed in German · English published by the European Commission

The Fair Trade Advocacy Office (FTAO) welcomes the Commissions initiative to simplify Regulation (EU) 2018/848 and related acts to ease implementation for organic producers. The EU organic sector sustains high-standard trade with third countries, with EU organic exports worth ~11 billion in 2023 and over 1,000,000 tonnes of tropical fruit, coffee, tea, cocoa and spices imported the same year.

We want to keep in mind that in countries where double cultivation can be made (summer and winter), it can be paid with a higher percentage of nitrogen, as the nutrient demand of these crops can be twice as high. We can achieve more nutrients with crop fertiliser, but it is sometimes not enough. For example, many areas in the province of Girona in Calaluña (Spain).

Filed in Spanish · English published by the European Commission

We propose that importers be permitted to directly modify Box 17 of the COI certificate, which lists the vessel used for shipment. Transport arrangements frequently change during transit due to delays or port congestion, often at short notice and across different time zones. Requiring only the suppliers control body to make these updates can lead to unnecessary administrative burden, delays, and extra port costs.

Organic farming should not be more expensive for producers than conventional farming. If we want a real transition to sustainable systems, it must also be economically viable. At the same time, it should not be more lenient either: losing demand would be to lose credibility. There is a need to balance financial support with maintaining the standards that give value to the eco-label.

Filed in Spanish · English published by the European Commission

The European Commission is preparing to reorganise the regulations on organic farming, I fear that pro-pesticides lobbyists will find a pretext for weakening the agricultural sector resulting from agro-ecological farming. I request that the current Regulation be kept as a minimum.

Filed in French · English published by the European Commission

I fully agree that it is important to put in place the rules that protect consumers from what they buy and think they buy when they buy a ‘organic’ product. However, I pose a significant risk to the original will of chicks, turkeys, canetons, etc., which should also be of organic origin, with breeders reared outside, on runs, and with organic production standards.

Filed in French · English published by the European Commission

Hello, I am a ‘bio’ farmer who has retired for a few months. I was active in the FNAB network, and the peasants I were able to work together never pleaded red tape, guaranteeing the seriousness of the act of production. Under no circumstances should the specifications be reduced, nor should checks be reduced, since consumer confidence and the success of ‘BIO’ are at this price.

Filed in French · English published by the European Commission

Organic farming based on the European specification is the only agricultural production method that has a real positive impact on the environment, biodiversity, water quality, animal welfare, consumer health, etc.

Filed in French · English published by the European Commission

In organic farming, I do not understand why to revise the regulation now, when it is not the urgency of our professions and I see only a negative interest in our professions. The urgency is that we can live dignified from our job, have fair pay, do not exhaust ourselves and be healthy. With regard to the relevance of this revision: Why review it so early?

Filed in French · English published by the European Commission

The product specification involves us in a virtuous agriculture (health/environment), which works on the autonomy of farming systems. All of this is validated by strict and guaranteed certification and the products sold are compliant. It is important not to give up to a chemical and simplification facility of systems that would jeopardise the guarantee of our image and the values that accompany it.

Filed in French · English published by the European Commission

The current regulation applied to organic production is necessary for users to credit the organic logo. As a result, the Regulation should be kept as it stands, except for amendments in accordance with the judgment in Herbaria Kräuterparadies GmbH v Freistaat Bayern.

Filed in French · English published by the European Commission

The European Commission’s decision to reopen the revision of the basic act of Regulation (EU) No 2012/848 comes only a few years after the last revision, in a context that is no longer favourable to organic production since your own departments have abandoned the Green Deal strategy and Farm to Fork in favour of growth and competitiveness.

Filed in French · English published by the European Commission

I think it is premature to revise the BIO specifications. Indeed, the last amendment is recent. The specific aspects of AB must be retained in order for the consumer to identify the real differences with conventional agriculture. (link to soil, without GMOs, 100 % organic food, etc.)

Filed in French · English published by the European Commission

Organic farming must clearly limit the impact on nature. It must therefore be clearly separated from conventional agriculture. Any weakening of standards blurs the message and, above all, increases the negative impact. Organic farming cannot be industrial and I have the impression that the proposed adjustments are in line with industrial agriculture.

Filed in French · English published by the European Commission

The organic label should not be further weakened, as this will lead to a loss of consumer confidence in the label. It is already clear that some doubts are particularly doubtful when other bidon labels, such as HVE, multiply. We need an ambitious product specification for quality farming!

Filed in French · English published by the European Commission

We need more flexibility in grazing, so that entire groups of animals, such as pregnant heifers, can be brought into the house together for calving. For example, only one group of animals must be on the pasture. There is also a need for other solutions for dairy farms with regard to grazing, e.g. during the grazing period. Organic farming is back to conventional farming.

Filed in German · English published by the European Commission

Hallo EU, my farm has an organic pig fattening. In my view, the current discussion on the interpretation of cover in % of open-air areas has nothing to do with animal welfare. It is important that I allow and make available different climate irritants for animals. With too few roofs, high roofs, a lot of wind, a lot of precipitation, orientation of the open-air area...

Filed in German · English published by the European Commission

Under its current rules, organic farming provides clear readability to consumers and consumers who wish to know the production processes. In establishing this link with European producers, this label remains a key argument for a requirement of sustainability and quality, all the more so in the wine sector.

Filed in French · English published by the European Commission

I am in a programme of Jove Farmers’ Department of Agriculture. We are pushed by the administration to play roles, as craftsmen ask us to comply with agro-industry regulations. In 3 years, just roles, we are never asked if we are producing. This is not of interest to them. In ecological processes, they still want us only to buy phytosanitary, if we do the outbreaks, if we do our subscribers, forbidden.

Filed in Spanish · English published by the European Commission

I am involved in a small organic fruit project (production and processing), I am between 2 for certification, as organic does not have the same meaning and with what is happening my interest in this label is increasingly moving away. I want to be able to continue to trust the organic environment, be sure of its quality, respect and link with nature, be it fauna or flora... Organic farming must be meaningful.

Filed in French · English published by the European Commission

I am a farmer Bio and do not want the specification for organic farming to be relaxed. It must remain meaningful, valuable, a guarantee of safety for the health of farmers and consumers and not a tool for the profits of multinational food businesses.

Filed in French · English published by the European Commission

I think it is time for the political and financial support of organic agriculture, as expressed by civil society. Easing the specifications will only contribute to deceptive and weakening the product specification by threatening its pillars: prohibition of genetically modified bodies/New genomic techniques, animal welfare and access to later food, 100 % organic food, etc.

Filed in French · English published by the European Commission

Hello, the organic product specification is the only one that guarantees a production method that minimises negative impacts on the environment: soil, air and water. It is also the guarantor of healthy products for consumers. These reasons alone must be sufficient not only to not change it, but above all to strengthen it in the face of attempts to relax within and outside the EU.

Filed in French · English published by the European Commission

Dear Sir/Madam, Food at present 100 % bio laliment is too fatty and not rich enough in protein. Because of this, the hens make very soft feelings, which salitis the eggs a lot. They also have to eat more to compensate, which increases our costs and creates stress in the lot. Ban on vermifuge. Without effective fouling, hens are quickly invaded from worms.

Filed in French · English published by the European Commission

Hello, an organic laying hen breeder, I would like to see certain points changed: — It should be possible to revert to 95 % of organic feed in order to combat the imbalance in amino acid in the ration and thus avoid animals that trap, become more vulnerable to disease and also have better technical efficiency. I do not understand why a rule increasing a waiting period of 48 hours for products with a 0-hour deadline.

Filed in French · English published by the European Commission

The Interbio Occitanie Interprofessional Association wishes to make 2 proposals to help fruit producers in southern Europe and cattle farmers to remain in organic production, taking into account the constraints brought about by climate change and market constraints: the concrete proposals are set out in the attached letter.

Filed in French · English published by the European Commission

As regards fertilisation with AB, I find it astonishing that I do not use my pullet fients (elevation of 62000 pullets in the car) and that, in contrast, I have to import feathers from Spain with a little doubt. Let’s encourage short circuits at fertilisation level. This is detrimental to the need to multiply the legal structures within the same farm in order for manure to be organic. Organic soils are depleting...

Filed in French · English published by the European Commission

In the context of the revision of the rules on the production of organic laying animals, we would like to see an evolution: — Food 100 % organic: imbalance in essential amino acids in the ration, which has serious consequences in terms of technical performance leading to problems of animal welfare (picking, etc.) and an increase in the production of eggs in a strained sector.

Filed in French · English published by the European Commission

The company Dr. Bronners is based in the USA. Our subsidiaries, which are smallholder groups in the global south, produce and export organic products to the EU. We recommend the following changes to Regulation (EU) 2018/848, as well as the implementing acts: 1. Reg (EU) 2018/848, Article 36: The restriction of the members turnover to not more than 25000 should be deleted.

The FNAB states that the stability of the regulatory framework is the essential condition for consumer confidence and the viability of the organic market in Europe. Over the last twenty years, this market has stopped growing, reaching EUR 50 billion today.

Filed in French · English published by the European Commission

I am surprised that a revision of the Regulation, which was published only 3-4 years ago, will come out so soon. Since I am a farmer and a citizen, I am of the opinion that, in the event of a revision, it is absolutely essential to maintain at its heart the basic principles of organic farming, the prohibition of genetically modified/new genomic techniques, animal welfare and access to the environment, and the 100 %…

Filed in French · English published by the European Commission

The image of organic farming has already been undermined by its ownership by the agro industry, which uses it to increase its profits, regardless of moral considerations, to the detriment of small producers, who make organic by conviction, and need a label that is true proof of genuine environmental commitment.

Filed in French · English published by the European Commission

Note that organisation represents 28 farmers of organic laying hens in France who embarked on the organic sector before the latest regulatory developments 3 and a half years ago. They are worried when in the future of their sector, given the technical and economic deadlocks they have faced since this last development, which has degraded the welfare of poultry and made it more complex, farmers are working.

Filed in French · English published by the European Commission

Feedback on Initiative 15273: Organic production targeted updates and simplification I fully support the EU's goal to increase organic production and consumption. However, for this revision to be truly successful, it must go beyond mere simplification and become a catalyst for innovation and investment. The current proposal, with its risks on animal welfare and GMOs, creates uncertainty.

The open-air area is not usable for young poultry. Only with about 30 days for chickens and after 6 weeks for turkeys, the animals are sufficiently fidered. A call for open-air areas that are not used is waste of resources, deceives consumers and poses a threat to livelihoods.

Filed in German · English published by the European Commission

I would like to express my misunderstanding and my deep concern about the prospect of a revision of the European Regulation on organic farming, just three and a half years after its entry into force. Such a review, which is so rapid, questions its real necessity and the priority given to the expectations on the ground.

Filed in French · English published by the European Commission

We can only agree on the comments by Kahls Kaffe and Arvid Nordquist about box 17 in the COI related to green coffee import. As the bill of lading is issued from origin to final destination, without stating all the feeders or truck plates, it does not make sense to list all means of the transport between POL and POD in the COI.

I do not understand that a revision of the Regulation is already envisaged, just three and a half years after its implementation. Such a premature revision of such a fundamental text seems to me inappropriate, especially at a time when organic producers primarily expect fair prices and public support commensurate with their commitments.

Filed in French · English published by the European Commission

We are committed to the following simplifications of the EU Organic Regulation. 1. Several production units per holding should be possible: If in fact only one production unit of a maximum of 1 600 m² per holding were to be allowed, this would have serious consequences for poultry fattening in Germany.

Filed in German · English published by the European Commission

We appreciate this initiative as it brings much-needed clarity and stability to the organic sector. The proposed updates will help ensure smooth trade continuity by extending recognition of non-EU equivalence, while also supporting competitiveness through simplified and practical regulatory measures.

Hello, I share my views on the latest BIO regulation. With the move to 100 % BIO, we have an imbalance in protein intake, which leads to digestive problems for farm animals. The difficulty of finding availability of raw materials = > permanent changes in formulae which also affect the digestive comfort of the animals.

Filed in French · English published by the European Commission

I think that levelling the rules down will not work in our favour. Consumers already feel harmed by large-scale organic food. Let’s set an example. Moreover, if regulation is weakened, new labels will be created. Let’s support what exists.

Filed in French · English published by the European Commission

The current regulation should be redefined as follows: It should be possible for several units of 1 600 m² of fattening poultry floor area per undertaking, with a maximum of 1 600 m² of indoor area to be used for fattening poultry.

Filed in German · English published by the European Commission

The following points are interesting and important for poultry: More than 1 production unit per farm in fattening – grassed open air area does not need to be on the house if the animals are still too young for a grassed open-air area in any case.

Filed in German · English published by the European Commission

The Danish Chamber of Commerce welcomes the opportunity provide suggestions for updating the Organic Regulation (EU) 2018/848. We support the EUs ambition for the organic sector in Europe and have suggestions that can help the further growths of the sector and help reduce the regulatory burden for businesses.

Thank you very much for the opportunity to provide feedback on the simplification of the EU Organic Regulation, which I propose here from the point of view of bi-poultry farming: — several units of 1 600 m² of broiler poultry surface per undertaking should be possible, with a maximum of 1 600 m² of indoor area for fattening poultry.

Filed in German · English published by the European Commission

Ladies and gentlemen, I am responsible for the position of the focus team leader, Schwein, at the Naturland Association. In organic pig farming, there are several points that are really pressing at the moment. — Division of piglet rearing into several weight ranges. Piglets now have a legally prescribed area from weaning to sale. However, this is too much for smaller animals.

Filed in German · English published by the European Commission

We would like to propose that importers be granted the ability to directly update the information in Box 17 of the COI certificate, which refers to the vessel(s) used for transport. In practice, changes to the means of transport often occur during shipmentfor example, due to delays or congestion in major portsresulting in the goods being transferred to different vessels.

Box 17 for COI needs to be simplified. Within the different EU countries, this is also interpreted differently, which is not good for Swedish organic imports. Today, the NFA requires all boats to be reported in this field. Since not all boats are known at departure, both as an importer and as exporter, we must monitor all boats in order to be able to update box 17.

Filed in Swedish · English published by the European Commission

Regarding the information that the responsible control body/supplier is required to provide in connection with the registration of a certificate of inspection, this needs to be changed. Currently, we as importers cannot change or update the information about which vessel(s) the goods will be transported with, this responsibility lies entirely with the control body, this should be changed so that the importer can…

The simplification of Regulation (EU) 2018/848 on organic production is an essential step in ensuring the continuity of supplies of imported organic products by European operators. It should also address the obstacles faced by organic producers established in third countries, which are often subject to compliance requirements that are difficult to meet under the current regulatory framework.

Filed in French · English published by the European Commission

As a French agricultural producer engaged in organic farming for several years, we wish to express our deep concern about this draft regulation. We have long seen a flagrant inequality in the control requirements between local organic production and imported products.

Filed in French · English published by the European Commission