Thank you for giving us this opportunity to give our feedback. Both proposed inclusions and exclusions are insightful. Specifically the clarity on group of operator criteria and consideration for revising equivalence with third countries are both technically and politically sound steps. However, there is still no clarity for a few things as follows: 1. Derogation process for third countries. In case of Livestock.
POV
Parthavi Organic Vision Pvt. Ltd.
Company · IND
2
positions filed
in the 326 files tracked
1
legislative file
of 326 tracked
0
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
Parthavi Organic Vision Pvt. Ltd. filed 2 positions between 18 Nov 2025 and 30 Jan 2026, across 1 of the 326 legislative files tracked here.
2025 · 1 filed2026 · 1 filed
What they argued
Derogations in new EU regulations are not very clear for third countries. For eg., Article 25 of EU 2018/848 says 'Authorisation of non-organic agricultural ingredients for processed organic food by Member States'- which implies that it is applicable on Member States only, while its sub-point 4 talks about third countries.
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