Commission européenne, Groupe d’experts sur la production biologique, réunion du 30 novembre 2021

Niveau juridique : Union européenne

On notera la discussion sur le projet d’acte modifiant l’annexe II du règlement 2018/848 concernant les exigences spécifiques applicables à la production et à l’utilisation des plantules non biologiques, en conversion et biologiques

  • 1.1 COMMISSION DELEGATED REGULATION (EU) …/… of XXX amending Part I of Annex II to Regulation (EU) 2018/848 of the European Parliament and of the Council as regards specific requirements for the production and use of non-organic, in-conversion and organic seedlings (PLAN/2021/11440)

Following discussion occurred in previous GREX, COM presented in detail the new draft Annex of the proposal on seedlings. Such new text aims to address the problems underlined during the feedback mechanismand extend provisions on possible authorisation for producers of plant reproductive materials from seedlings to other types of plant reproductive material.

The main act has not been circulated, however, changes mainly concern memorandum and recitals to adapt to the new Annex provisions. COM confirmed a retroactive clause has been inserted so that the act will be applicable from 1 January 2022.

In particular, with respect to the previous proposal which was subject to the feedback mechanism, the new draft includes additional clear provisions for the authorisation to be issued to organic operators producing plant reproductive material to produce, place on the market and label plant reproductive material to be used in organic crops when grown under organic conditions but not originating from mother plants grown in compliance with point 1.8.2. This is necessary to address the lack of mother plants grown in conformity with requirements of point 1.8.2. in particular, in the fruit and grapevine sectors.

Other main provisions already set in the current seedling proposal are kept i.e. prohibition to derogate non-organic seedlings for species with cycle completed in one growing season and clarification on what should be considered as in-conversion seedling.

As anticipated, COM aims to adopt the proposal in January therefore experts are requested to send comments by 6 December. In any case, the act once adopted will then under scrutiny of EP and Council.

One expert asked whether such restriction on seedling would affect organic producers. COM confirmed prohibition is limited to use of non-organic seedling short cycle seedlings, farmers can be allowed to use non-organic seeds to produce their own seedlings organically. An expert expressed intention to read carefully the text which was uploaded recently in CIRCA BC in particular with respect to the use of term seedling and its national language translation but did not have immediate major remarks. Another expert asked whether such authorisations should be required only by nursery operators and not farmers. COM confirmed there will not be need for double authorisation. One expert did not agree with the proposal considered not necessary and too complex. Another expert welcomed COM to look for solutions and recommended to define the seedling in the text clearly in case in the recital to add information to clarify with examples. On label it is considered as a communication from operators to operators but in case of final consumers the statement could lead to misunderstanding. COM recalled the seedlings can be placed on the market for further transplanting and a differentiation is needed among those derived from organic seeds to the other grown organically from non-organic seeds. However, COM would be ready to examine other possible suggested statementsfor labelling. One expert referred to the absence of seedlings in database and on how to apply in this case. COM referred to the basic act which in any case does not prevent the collection of information also on seedlings and to the possibility to judge public availability of seeds from which seedlings originate. Another expert asked whether the new plant reproductive material labelled as “may be used in organic productions” should be subject to certification scheme and in such case whether to be included in certificate model. COM replied the plant reproductive material should be controlled under certification scheme as it is a product produced under organic conditions hence as such could be indicated in the certificate under “organic”, however the question of the model will be further verified.

An expert asked to have a track-changes version and COM committed to consider whether possible but in view of the short text and differences among the structures, it would be easier to compare in clean versions. COM concluded thanking for the discussion, asked experts to provide comments in track changes on the text by 6 December and committed to send the final proposal before the adoption. »

Compte-rendu de la réunion et brouillon de l’acte discuté disponibles ICI