IFOAM Organics Europe

IFOAM Organics Europe welcomes the European Commissions initiative to accelerate circularity in the European Union (EU) through the Circular Economy Act. We support a systemic transition towards a resilient and fair circular economy, one that operates within planetary boundaries and strengthens rural communities.

IFOAM Organics Europe, the European umbrella organisation for organic food and farming, welcomes the Commissions intention to adopt a strategy on the right to stay and its efforts to invest in concepts that work against the demographic decline and decrease in economic opportunities in Europe's rural areas and territories.

IFOAM Organics Europe reiterates its support for the European Commissions targeted amendment of Regulation (EU) 2018/848, stressing the urgent need for its rapid adoption to avoid severe disruption to international organic trade.

IFOAM Organics Europe is the European umbrella organisation for organic food and farming. With almost 200 members in 34 European countries, our work spans the entire organic food chain and beyond: from farmers and processors organisations, retailers, certifiers, consultants, traders, and researchers to environmental and consumer advocacy bodies.

While climate mitigation has to clearly prioritize absolute emissions reductions, the trend of declining carbon stocks in EU soils should be reversed and carbon sequestration should be incentivized. The organic movement believes that a certification framework for carbon removals should contribute to transition farming systems towards sustainability and prevent greenwashing.

While climate mitigation should clearly prioritise absolute emissions reductions, carbon sequestration in the land sector can contribute to long-term climate objectives. Carbon sequestration should be additional to reduction efforts and not disincentivise them.

Brussels, 30 June 2023 IFOAM Organics Europe feedback to the Commission’s proposal on green claims IFOAM Organics Europe is grateful for the opportunity to provide feedback to the Commission’s proposal on green claims. First of all, we would like to thank the Commission for this proposal, as it aims to inter alia address greenwashing, a practice that can be deleterious to truly sustainable businesses and products.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

IFOAM Organics Europe (IFOAM OE) welcomes the Commission's initiative on the "Environmental performance of products & businesses – substantiating claims", as it aims to increase trustworthiness of environmental claims. Similarly, IFOAM OE welcomes that the Farm to Fork strategy stipulates that “the Commission will (…) examine ways to harmonise voluntary green claims”.

IFOAM Organics Europe welcomes the opportunity to provide feedback on the proposal for a regulation establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC, as part of the Sustainable products initiative. Please find in the attached file our suggestions in reaction to the proposed regulation.

The organic movement welcomes the opportunity to give input to the Biotech Act. The maintenance of a system of identification and traceability for genetically modified products in agriculture is essential so that organic and conventional operators have the right and freedom to continue producing GM-free throughout the entire supply chain. Please find the full feedback attached.

IFOAM Organics Europe, the European umbrella organization for organic food and farming, welcomes this opportunity to provide feedback to the Commissions' published legislative proposal for plants produced by certain new genomic techniques. The European organic movement has significant concerns with this initiative as it will have far-reaching impact on the European agriculture and food sector.

The information submitted by a company for the purpose of verification of category 1 NGT plant status should allow the fulfilment of the objectives of Regulation (EU) 2026/1388 and its proper implementation. This includes article 5(2), article 32(3) and the possibility for organic operators, who have to comply with Regulation (EU) 2018/848, to ensure that no NGTs are used in the organic production process.

IFOAM Organics Europe welcomes the opportunity to provide feedback on the Roadmap towards Nature Credits. Nature with intact ecosystem functions and a thriving biodiversity are a pre-requisite of healthy agricultural systems and long-term food production. Farmers who are actively contributing to biodiversity protection and nature restoration should be appropriately rewarded for the benefits they are providing.

The accelerating climate crisis is one of the biggest threats to agriculture and food systems. Rising temperatures, changing precipitation patterns and increasing frequency of extreme weather events are already disrupting European farming with cascading risks for the whole food supply chain. To ensure resilient and sustainable food production on the medium and long term a transformational change is inevitable.

IFOAM Organics Europe welcomes a revision of the current LULUCF regulation to ensure its contribution to the EU climate goals. While climate mitigation should clearly focus on absolute emissions reductions, carbon sequestration in the land use sector has also a crucial role to play to meet the long-term climate objectives.

IFOAM Organics Europe welcomes the revision of the UTP Directive, as the current framework does not adequately protect farmers and other weaker supply chain actors, as also identified by the evaluation report of the European Commission.

IFOAM Organics Europe thanks the Commission for the publication of the EU strategy for sustainable textiles. We would like to make two points: (1) the current fast fashion production of textiles has important environmental & social impacts, and (2) organic textiles production has much fewer environmental & social impacts, but current EU rules allow for greenwashing as the term organic is not protected for textiles.

IFOAM Organics Europe supported the establishment of the Fertilising Products Regulation (FPR) as a central point of the European Commission's Circular Economy Action Plan. Its intention to harmonise rules among EU countries for all fertilizers products (mineral fertilisers but also organic, waste-based fertilisers and biostimulants) was welcome.

IFOAM Organics Europe welcomes the Commission’s initiative to revise the EU geographical indications, especially as it considers citizens’ sustainability concerns and ways to incorporate more sustainability within the GI scheme. IFOAM Organics Europe also welcomes the Commission’s efforts to increase sustainability in all aspects and encouraging producers to do so.

IFOAM Organics Europe welcomes the Commission’s initiative to develop an EU action plan for a better management of nutrients. This should provide the holistic approach needed to achieve the 2030 target set in the Farm to Fork and Biodiversity strategies to reduce nutrient losses by at least 50%, while ensuring that there is no deterioration in soil fertility.

IFOAM Organics Europe is the umbrella organization for organic food and farming, representing over 200 members all over Europe, all along the organic value chain, from producers to processors, certification bodies, distributors and research centers.

IFOAM Organics Europe welcomes the Commission’s proposal to review the FADN Regulation to transform it into a FSDN. Economic data collected at farm-level needs to be completed with data on the environmental and social components of farms, whether for policy monitoring and evaluation or for research.

IFOAM Organics Europe welcomes the Commission’s initiative to review the FADN Regulation to transform it into a FSDN. Economic data collected at farm-level needs to be completed with data on the environmental and social components of farms, whether for policy monitoring and evaluation or for research.

IFOAM Organics Europe welcomes the opportunity to provide feedback via this consultation on the implementation of the Unfair Trading Practices directive. IFOAM Organics Europe has been supportive of this Commissions initiative since its inception given the importance of ensuring fair prices for EU and non-EU producers as well as fairness in the supply chain.

The Regulation laying down good manufacturing practice for veterinary medicinal products in accordance with Regulation (EU) 2019/6 of the European Parliament and of the Council and all connected Annexes should consider in particular the special conditions in the production of herbal veterinary medicinal products, traditional herbal veterinary medicinal products and homeopathic veterinary medicinal products.

IFOAM Organics Europe is the European umbrella organisation for organic food and farming. With almost 200 members in 34 European countries, our work spans the entire organic food chain and is based on the principles of organic agriculture: health, ecology, fairness and care.