PLANT HEALTH CARE

IN ORGANIC FARMING
THE ROLE OF NATURAL SUBSTANCES
IN A BIODIVERSITY-BASED SYSTEM
APPROACH
2 Plant health care in organic farming

MAIN MESSAGES
F rom field to farm and at landscape level, a healthy agroecosystem with a high degree of biodiversity
is essential for a successful plant health care strategy.

Conversion to organic farming entails a transformation of the entire agroecosystem and a minimisation
of external inputs, it is not only a substitution of inputs to a less harmful plant health care regime.

More than 90% of organic farmland does not need treatment with plant protection products;
plant protection products based on natural substances are a small but essential element,
mainly for organic speciality crops such as fruit, vine, vegetables and potatoes.

Protecting and increasing biodiversity must be a priority in public policies to preserve the foundation
of the organic approach to plant health and enable its widespread adoption.

To increase the availability of plant protection products suitable for organic farming, it is essential
to establish specific EU evaluation and authorisation procedures for natural substances.

 n increased number of experts on natural substances and the organic approach to plant health
A
is needed to speed up the authorisation process while ensuring a rigorous assessment of natural
substances for safety and compliance with organic principles.

 ublic funding is essential to generate data needed for the registration process of natural
P
substances of public interest, which have a low return on investment.

To reach the 25% EU target for organic land by 2030, it is also essential to increase research
and innovation budgets dedicated to organic approaches to plant health care.

PLANT HEALTH CARE IN ORGANIC FARMING – THE ROLE OF NATURAL SUBSTANCES IN A BIODIVERSITY-BASED SYSTEM APPROACH
Brussels, November 2020

PUBLISHED BY: AUTHORS: Jutta Kienzle,1 Kevin Smith-Weißmann,1

IFOAM Organics Europe Mathilde Calmels2, Isabella Lang2
Rue du Commerce 124 1
Bund Ökologische Lebensmittelwirtschaft e.V. (BÖLW)
1000 Brussels - Belgium 2
IFOAM Organics Europe
www.organicseurope.bio EDITORS: Eric Gall, Eva Berckmans
LAYOUT DESIGN: Hearts&Minds PRODUCTION SUPPORT: Eva Berckmans,
COVER PICTURE: Jutta Kienzle Mathilde Calmels, Verena Mitschke

WITH FINANCIAL CONTRIBUTIONS FROM:

This publication is co-financed by the LIFE programme of the European Union, under the Executive
Agency for Small and Medium-sized Enterprises (EASME). This publication only reflects the views of
the authors and its sole responsibility lies with IFOAM Organics Europe. EASME is not responsible
Green
Organics for any use that may be made of the information provided.
 The role of natural substances in a biodiversity-based system approach 3

INTRODUCTION
One of organic agriculture’s defining traits is its approach towards plant health care, relying mainly on
preventive and indirect measures within the agroecosystem. As a last resort, organic farmers can combine
these with direct measures, if these are based on the use of natural substances. The principles of organic
agriculture seek to prevent the introduction of new and alien substances into ecosystems. So, the use
of synthetic pesticides1 is prohibited.

More and more European citizens are concerned over synthetic pesticides use. The European Commission’s
Farm to Fork and Biodiversity strategies call for a substantial reduction of chemical plant protection
products as a priority to reach sustainable food systems. Organic farming’s unique approach to plant
protection has rightly been identified as essential to reach the Farm to Fork strategy’s target of a 50%
reduction in chemical pesticide use. Both strategies also set up a goal to reach 25% of agricultural land
under organic farming by 2030.

A successful reduction of synthetic pesticide use needs to be well-prepared. Alternative approaches like
organic agriculture can only lead the way to a truly sustainable agrifood system if the entire political
framework enables their development. In specific, policy measures should be coherent and complementary
to contribute to the objectives.

Healthy agroecosystems with a rich biodiversity are resilient and self-regulating to a large degree, making
them a prerequisite for a successful plant health care strategy in organic farming. This is why the protection
and increase of biodiversity must be the foundation for new approaches in plant health care. Improving
the availability of natural substances should complete the system.

A social and ecological transformation of our food system can be successful if farmers have alternative
tools and strategies well-adapted to their economic, social and environmental realities.

 HE LONG-TERM EFFECT OF AN ORGANIC FARMING SYSTEM:

T
STAGGERING DECREASE IN EXTERNAL INPUTS

A 21-year Swiss system comparison2 trial found that yields in the organic systems are on average
20% lower than in the conventional systems. However, in organic systems input of fertiliser and
energy was reduced by 34-53% and pesticide input by 97%. Organic plots had a more fertile soil
and higher biodiversity, likely making these systems less dependent on external inputs.

1
S ynthetic pesticides are plant protection products containing active substances, which cannot be found in nature, but which
were created through human endeavour and are newly introduced into ecosystems.
2
Mäder et al. (2002): Soil Fertility and Biodiversity in Organic Farming. Science 296, 1694 (2002).
4 Plant health care in organic farming

ORGANIC FARMING PRINCIPLES

FOR PLANT HEALTH CARE
The dynamic development of the organic sector all over Europe was possible because of a smart
combination of tradition, innovation and science. The organic principles of health, ecology, fairness and
care are its basis.

The Principle The Principle The Principle The Principle

of Health of Ecology of Fairness of Care
aims at sustaining and expresses that organic builds on relationships lays down that organic
enhancing the health agriculture should ensuring fairness to agriculture should
of soil, plant, animal, be based on living the environment and enhance productivity
human and planet as ecological systems and life opportunities. This and efficiency in a
one and indivisible. cycles, work with them, includes socio-economic precautionary and
Plant health is based on emulate them and help conditions where fair responsible manner to
preventive and indirect sustain them. Plant prices allow farmers to protect the health and
management measures health relies on the use environmentally well-being of current
and plant nutrition effective management friendly methods. The and future generations
from feeding the soil of ecological processes, principle of fairness and the environment.
and enhancing soil adapted to local also implies that Plant health care can
quality rather than the conditions, ecology, developing, producing build on farmers’ long
plant directly. Healthy culture and scale. Inputs and using natural inputs experience in natural
agroecosystems enable should be reduced by should be enabled pest management. When
farms to depend as little prioritising reuse and from an economic and it comes to science,
as possible on external recycling. regulatory point of organic agriculture
inputs. view, as well as through should prevent significant
adequate research risks by only adopting
capacities and funding. appropriate technologies
and rejecting
unpredictable ones.

© Triin Viilvere
 The role of natural substances in a biodiversity-based system approach 5

PLANT HEALTH CARE IN ORGANIC

AGRICULTURE: CHANGE THE SYSTEM -
NOT ONLY THE PRODUCTS
Organic agriculture aims at creating favourable conditions with healthy plants in a healthy agroecosystem.
Ensuring an efficient plant health care strategy relies on combining and implementing three parallel sets
of measures:

Biodiversity: Ecological self-regulation,

Management measures: Preventive approach,
Direct measures: External inputs as natural substances or energy.

Organic farming prohibits using synthetic pesticides. Living ecosystems are the basis of agriculture, and
interactions between the farm and its environment underlie the strategy.

The full use of the preventive potential of management measures and systematic use of agrobiodiversity
are at the heart of the organic approach to plant health. This approach provides enough crop protection in
arable and grassland farming – representing more than 90% of all organic agricultural land – to completely
avoid the use of natural inputs.

In crops like wine, fruit, potatoes and some vegetables, organic farmers can use biocontrol and natural
substances if diseases and/or pests occur at unsustainable levels. Since they are part of a combination strategy
with other measures, natural substances used as an input are not and do not need to be “highly efficient”.

Only the intelligent combination of these aspects makes up an efficient and resilient strategy for plant
health care.

THE FOUR COMPONENTS OF A RESILIENT PLANT PRODUCTION SYSTEM

RESILIENT AGROECOSYSTEM

BIODIVERSITY MANAGEMENT DIRECT

MEASURES MEASURES

FARM AND LANDSCAPE LEVEL

6 Plant health care in organic farming

FARM AND LANDSCAPE LEVEL: BIODIVERSITY:

LAND SHARING, NOT LAND SPARING WORKING WITH NATURE

An agricultural field is part of a broader landscape Enhancing biological diversity in organic farm
with which it interacts. Organic farmers’ approach landscapes provides a wide range of ecosystem
to plant health looks beyond their own fields, services important for plant health care, such
as pests do not stop at the farm gate. Organic as pest control and nutrient cycling. Faunal and
production is more difficult in a homogenous floral diversity plays a crucial role in making
landscape (monocultures) as the many pests habitats unsuitable for high infestations of pests
targeting crops will establish long-lasting and diseases by limiting access to resources and
populations in the ecosystem. Heterogenous increasing competition, parasitism and predation.
landscapes offer greater potential for biological
control of plant pests and diseases as they offer Combining temporal and spatial diversification
safe havens for beneficial organisms beyond in organic fields ensures an effective plant health
the productive area. To support the ecosystem’s strategy. For instance, a diversified crop rotation
natural interactions, it is essential that agricultural (temporal diversification) breaks pests’ life cycles
practices, like an intensified pesticide regime, do by removing host plants and provides nitrogen to
not affect landscape biodiversity. the soil thanks to legumes. Intercropping (spatial
diversification) provides better weed control by
By preserving semi-natural habitats and enhancing increasing competition for natural resources.
biodiversity within the production area, organic Conserving and improving natural landscape
agriculture creates multiple source areas of features, such as flowering strips or hedgerows,
biodiversity contributing to the beneficial complete the strategy by offering a refuge for
heterogeneity of landscapes. beneficial insects.

Finally, genetic diversity is of paramount

importance in the organic approach to plant
health. Organic producers seek to use appropriate,
resilient and nutrient-efficient species and varieties,
adapted to local conditions. As it is the basis for the
natural resistance of plants to pests and diseases,
organic plant breeding is key to provide organic
farmers with the varieties they need.

© Jutta Kienzle

Perennial wildflower strip

© Florian Weihrauch

Tall fescue in between rows of hops as a habitat for predatory mites

 The role of natural substances in a biodiversity-based system approach 7

MANAGEMENT MEASURES: CUTTING, Think about livestock manure and/or organic

COVERING AND OTHER PREVENTION residues from cities and food industries.

Organic farmers deploy a wide range of A system approach in risk prevention is key to
management measures to prevent pests and using inputs in organic’s plant health care strategy.
diseases on their field. Protective measures may Organic agriculture aims to be as little dependent on
include netting and coverage to keep insects away external inputs as possible, by prioritising indirect
from the crops, mostly used for vegetable crops and preventive measures (see example 2). When
and orchards. In permanent crops, cutting and necessary, external inputs like plant protection
pruning aid pest control by removing infested products and fertilisers complement the above-
parts and exposing the plant to sunlight and dry air mentioned measures. But only if they are “natural
– both fungicidal and bactericidal factors. Organic or naturally-derived substances” according to EU
farmers might prevent weed control by ploughing, Organic Regulation (EC) No 834/2007.
soil solarisation, mowing and an adapted tillage
regime. They increase soil fertility by using green Organic farmers’ self-limitation of only using
manure, legumes and, in mixed farming systems, a substances that already exist in nature is an
balanced use of farm manure. active measure of precaution. This way, organic
agriculture rejects the unpredictable risks coming
from releasing artificially designed molecules
into the environment. But this does not mean
natural substances present no foreseeable risks. An
appropriate registration process to estimate these
risks is indispensable. It could also help to better
consider the “multifunctionality” of several natural
© Markus Puffert
substances that provide more than one plant
Broccoli under netting health care service, for example plant protection
and fertilisation.
DIRECT PLANT PROTECTION MEASURES

Direct plant protection measures in organic

production can be mechanical/thermal weed
control and/or natural inputs. Organic farmers
chiefly use insecticides and fungicides as plant
protection products. Herbicides are generally not
allowed (see example 1). When organic farmers use
external inputs as fertiliser, these are materials of
© Markus Puffert
microbial, plant or animal origin.
Dispenser for onion oil to repel the carrot fly

VARIOUS CATEGORIES OF NATURAL SUBSTANCES EXIST:

Substances derived from plant

Mineral compounds, like rock
or animal origin, like plant oil
powder, sulphur and copper
and Neem extract

Semiochemicals such as pheromones

 icro-organisms such as
M produced by individuals of a species
bacteria, fungi and viruses modifying the behaviour of other
individuals of the same species
8 Plant health care in organic farming

EXAMPLE 1
WEED CONTROL: AN INTEGRATED APPROACH PREVENTING HERBICIDE USE
Herbicides are generally not allowed in organic
farming systems. To replace them, farmers apply
a set of different measures, as tillage alone is
usually not enough if a weed problem occurs.
Organic farmers establish preventative crop
rotation, use green manure and cover soils to
reduce the pressure of weed infestation. Choosing
fast-growing varieties with leaves overshadowing
the soil can help suppress weeds. The farmer
mechanically removes whatever weeds still
appear. This combination of indirect and direct
methods leads to an environmentally and
economically viable outcome.
© BÖLW

Mechanical weeding in Kohlrabi

EXAMPLE 2
COPPER MINIMISATION: STRATEGICALLY REDUCING COPPER USE

Plant protection products containing copper

are especially important in organic wine, fruit,
hops, potato, vegetables and ornamental plant
production. Still, organic agriculture is a perpetual
research process to reduce copper use, as it remains
an external input. The strategy to minimise copper
use in organic farming has two main aims. First, a
precautionary risk minimisation for copper and
other external inputs. Second, the reduction of
dependence on copper and other external inputs,
and the adaptation of plant health care strategies
to better align with the organic farming principles.

Through this strategy, organic farmers and growers

seek to increase their production system’s resilience.
They look for more than an alternative product,
by combining different measures: choosing
appropriate varieties, optimising management
measures, using alternative product with lower
© Triin Viilvere
risk and application rate.3
Grapes

3
Read more in IFOAM Organics Europe’s copper minimisation paper ‘Strategy for the minimisation of copper in organic
farming in Europe’ (May 2018) on https://www.organicseurope.bio/content/uploads/2020/10/ifoam_eu_copper_
minimisation_in_organic_farming_may2018_0.pdf?dd
 The role of natural substances in a biodiversity-based system approach 9

CURRENT LEGAL AND ECONOMIC

SITUATION FOR NATURAL SUBSTANCES
IN PLANT PROTECTION
LEGAL BACKGROUND FOR REGISTERING NATURAL SUBSTANCES

EU legislation defines the principles and practices of EU organic agriculture. Every certified organic farmer
needs to follow them or risk losing their organic certification. To ensure these rules are followed, control
bodies or authorities (supervised by national authorities) inspect every organic farmer at least once a year.

EU LEGISLATIVE PROCESS FOR AUTHORISING THE USE OF INPUTS IN ORGANIC AGRICULTURE

The EU Organic Regulation (EC) 834/2007, Art. 44 limits inputs in organic agriculture to ‘natural or naturally
derived substances’. For substances to be authorised, they have to follow two sets of regulations:

1) First, the input needs to be registered in the corresponding horizontal legislation:

a. R egulation (EC) 1107/2009 for plant protection products;
b. Regulation (EC) 2003/20035 for fertilisers, except for soil conditioners, organic fertilisers, or secondary
raw material;

2) After, it has to be added to the annexes of the Regulation for organic production (EC) 889/2008 listing
the products and substances authorised in organic production.

Increasing the availability of natural substances in line with organic’s approach to plant health remains
essential for a smooth transition to organic farming systems. But the approval process hampers this
development for several reasons.

4
T he new Organic Regulation (EC) 2018/848 repealing Regulation (EC) 834/2007 will apply from 1 January 2022. Natural inputs will
continue to follow the same registration process to be allowed in organic agriculture.
5
New Fertilisers Regulation (EC) 2019/1009 repealing Regulation (EC) 2003/2003 will apply from 16 July 2022. It will cover more
fertilising products, including materials that are traditionally used in organic agriculture.

© Liveseed
10 Plant health care in organic farming

LIMITED CONSIDERATION OF THE SPECIFIC CHARACTERISTICS OF NATURAL

SUBSTANCES IN THE EU REGULATORY FRAMEWORK ON PESTICIDES

Regulation (EC) 1107/2009 laying down the rules for the authorisation of plant protection products was
designed for synthetic substances and is not suitable for natural substances in many aspects.

Data requirements

The data to be submitted for the approval of active substances are defined for synthetic
substances. These are usually newly designed, highly efficient single molecules, released in the
environment for the first time, whereas natural substances have an existing natural background,
are often more complex in composition and present a wider range of modes of action. This creates
technical difficulties to adapt the registration criteria to natural substances and may even lead to non-
authorisation of an active substance due to technical feasibility. For instance, it may be difficult to identify
and characterize all individual compounds of a botanical active substance containing a hundred different
ones.

Propolis’ chemical composition is complex and depends on its botanical and geographical origin. In
May 2020,6 the European Commission did not approve propolis as an active substance – according
to Regulation 1107/2009 – because the information provided were not sufficient to perform a risk
assessment. Propolis was authorised in former EU organic regulation7 (1991) but was de-listed because
it is not considered a pesticide under EU horizontal legislation.

Risk assessments

Risk assessments have been designed to evaluate the predictable risks arising from releasing
newly synthesised chemicals into the environment. But this logic cannot apply to natural
substances since they are already present in nature. Their natural background should serve as reference in
risk assessment to assess the additional risk of the proposed use. This approach would avoid the detection
of “level of concerns” at concentrations close to, or theoretically even below, those levels already present
in nature.

This is particularly true for ubiquitous mineral substances such as copper, which can – and should – be
found everywhere. Copper is also an essential micro-nutrient that is present in small quantities in the
human body. Synthetic molecules, however, should not be found everywhere, especially not in humans.

Furthermore, many of these substances already have a long history of safe use in plant protection, so that
any adverse effects are well-known and mitigation measures can be applied.

6
Commission Implementing Regulation (EU) 2020/640 of 12 May 2020 concerning the non-approval of propolis extract as a
basic substance in accordance with Regulation (EC) No 1107/2009 of the European Parliament and of the Council concerning
the placing of plant protection products on the market.
7
Council regulation No 2092/91 of June 24, 1991 on organic production of agricultural products and indications referring
thereto on agricultural products and foodstuffs.
 The role of natural substances in a biodiversity-based system approach 11

Progress in the registration process

Still, EU institutions have made some progress to better adapt the registration process for
plant protection products to natural substances.

There are individual guidance documents for several categories of natural substances. These include
microorganisms, semiochemicals and botanicals (plant extracts), which substantially contribute to a better
adapted evaluation of these substances. Yet improvements are still needed on updating or developing of
new guidance documents.

Regulation (EC) 1107/2009 recently introduced the ‘basic substances’ category. It describes substances
useful in plant protection but not predominantly used for this. For instance, vinegar, stinging nettle extract,
or sucrose are registered as basic substances. The registration process is supposed to be easier, cheaper
and faster than for ordinary pesticides. But the practical implementation of this process is challenging.
Basic substances are a useful category, allowing farmers, farming organisations and research institutions
to apply for the substances and indications required on the field. However, due to a lack of data, many
substances are authorised with only few uses needed in organic farming.

Establishing natural substances as their own category

Beyond these developments, it is key to establish natural substances as a category of their

own in regulation (EC) 1107/2009. This is the legal pre-requisite for a dedicated authorisation
process taking into account the specific characteristic of these substances while stringently
assessing their risks. Establishing natural substances as category will ensure only natural substances that
are necessary and safe for farmers, consumers, and the environment will find their way into EU markets.

© Berenika Sikora
12 Plant health care in organic farming

A NECESSARY BUT LENGTHY TWO-STEP APPROVAL PROCESS

Once authorised under EU horizontal legislation, a substance must still be approved under the EU Organic
Regulation for use in organic production. This double approval process can take several years.

Member States should submit any request to add a substance to the list of substances authorised under
organic production to the European Commission. The independent Expert Group for Technical advice
on Organic Production (EGTOP) assists the Commission by assessing the compliance of the substances
with the objectives and principles of organic production. The EGTOP also provides non-binding
recommendations if a substance should be authorised for organic production. The European
Commission generally follows the EGTOP’s opinion.

Including these substances in the EU Organic Regulation causes a time lag between introducing an input
in agriculture and its legal use in certified organic agriculture. Regular EGTOP meetings – at least once a
year – could reduce this time lag while ensuring inputs are rigorously assessed against organic’s principles.

Garlic extract has been added to the list of substances authorised for plant protection in organic
agriculture in 2018, while it was authorised as active substance in the EU horizontal legislation for
pesticides since 2009.

A GROWING NEED FOR EXPERTS ON NATURAL SUBSTANCES

Finally, a further bottleneck is the lack of experts in national and EU authorisation and risk management
bodies about natural substances and organic farming. Targeted hiring and training programmes at all
levels are urgent to contribute to this kind of expertise.

© Triin Viilvere
 The role of natural substances in a biodiversity-based system approach 13

ECONOMIC BACKGROUND OF APPLYING FOR REGISTRATION OF NATURAL SUBSTANCES

Registering an active substance / plant protection product, whether natural or not, requires time and
money. Risk assessment is needed, but studies required for risk assessment can cost millions.

Public support for the registration of natural substances in plant protection in organic farming systems is
key – especially for authorising niche products – to reach the Farm to Fork strategy’s goal of increasing the
EU’s organic land to 25% and reducing chemical pesticide use and risk by 50% by 2030.

(RE-)AUTHORISING NEW & EXISTING SUBSTANCES

Newly designed synthetic substances can be patented and offer a high potential of return on investment
as they are used in high-intensity production systems with large acreage. The market segment for natural
substances is small because they have lower efficacy, and their use relies on an integrated and systemic
approach towards plant protection not requiring large quantities of inputs. Moreover, it is not possible
to get intellectual property rights for most natural substances, resulting in a very limited return on
investments for the producers.

The financial aspect and the time and resources it takes to register a natural substance make the introduction
of new natural substances or even re-authorisation of registered substances highly unattractive and/or
unfeasible for private companies.

Bacillus thuringiensis is the longest known and most widely used microbial biocontrol agent in agriculture.
In April 2019, EU approval for the active substance Bacillus thuringiensis ssp. tenebrionis expired. Organic
farmers use this strain of Bacillus thuringiensis to control potato beetles. Despite a long history of safe
use, no application for renewal of approval was submitted, mainly because the market was too small to
make it financially attractive. Novodor®, the only registered plant protection product using this active
substance, was withdrawn from the market, and organic farmers were left in a technical impasse.

So public money is essential to:

• Finance the registration process of natural substances of public interest when there is little to no return
on investment for a private company;
• Ensure natural substances with a long history of safe use remain available for farmers;
• Contribute to the increased availability of natural substances that will allow a smooth transition to
organic farming.

BASIC SUBSTANCES

The same logic applies to basic substances. They cannot be marketed as plant protection products or
formulated with other components – other than water or other basic substances. This makes application
for registration unattractive for companies as they would finance an expensive authorisation for a single
substance product anyone can copy and sell.

As of today, authorisations of basic substances relevant for organic agriculture have usually been
introduced by organic farming associations or research institutes. In some cases, they have been financed
by public money. However, widespread public funding of basic substance applications for substances
needed in organic farming is still necessary.
14 Plant health care in organic farming

EXAMPLES OF PLANT PROTECTION PRODUCTS AUTHORISED

FOR ORGANIC PRODUCTION ACCORDING TO ANNEX II OF REGULATION
FOR ORGANIC PRODUCTION (EC) 889/2008

NAME DESCRIPTION
Substances of plant or animal origin
Azadirachtin extracted from Azadirachta Plant extract (neem oil) used as insecticide.
indica (Neem tree)
Pheromones* Semiochemicals naturally produced by insects that modify
the behaviour of other individuals within the same species
(attractant, sexual behaviour disrupter…);
To be used only in traps and dispensers.
Pyrethrins* Substances naturally occurring in chrysanthemum flowers,
used as insecticide.
Equisetum arvense (Field horsetail) A decoction in water of dried edible aerial sterile stems is
(Basic substance) used as fungicide.
Chitosan hydrochloride* Obtained by hydrolysis of chitin from crustacean shells;
(Basic substance) Elicitor, having a fungicide and bactericide effect via the
stimulation of natural defence mechanisms.
Micro-organisms or substances produced by or derived from micro-organisms
Micro-organisms (not from GMO origin) E.g. Bacillus Thuringiensis, a naturally occurring soil
bacterium, with insecticidal properties.
Spinosad Natural substance produced by a soil bacterium,
used as insecticide.
Other substances
Carbon dioxide Used for the control of stored product pests.
Calcium hydroxide* Substance of mineral origin, obtained from lime;
(Basic substance) Used as a fungicide, only in fruit trees.
Copper compounds Used as fungicide to control downy mildew on grapevine;
The organic strategy to minimise the use of copper in
organic agriculture is detailed on page 8 (example 2).
Ferric phosphate Iron and phosphate ions are ubiquitous in nature;
(iron (III) orthophosphate)* Ferric phosphate is used as molluscicide.
Paraffin oil Natural constituent of petroleum (purified);
Used as insecticide and acaricide.
Sodium hydrogen carbonate (also Commonly used as an ingredient in the food market
known as sodium bicarbonate) (e.g. as the major ingredient of baking powder);
Used as fungicide.

* Substances with more restrictive conditions for use for organic production than those specified in EU horizontal legislation.
 The role of natural substances in a biodiversity-based system approach 15

POLICY RECOMMENDATIONS

MAKE THE ORGANIC APPROACH TO BIODIVERSITY THE BASIS

OF ALL PLANT HEALTH CARE STRATEGIES

E nsure the Common Agricultural Policy protects the environment, biodiversity and environmental
services provided by ecosystems. The CAP should fully contribute to the implementation of the EU Farm
to Fork and Biodiversity strategies to achieve a transition to more resilient and sustainable agricultural
production systems by 2030;

 romote organic plant breeding by supporting research and development of plant varieties suitable
P
for organic production. Ensure fair access to the EU seed market by adapting the variety registration
protocols to organic varieties;

Invest in research addressing indirect measures of plant protection and beneficial insects. These
aspects should be key components of EU research programmes;

 upport Member States to promote the use of less harmful pesticides. National contexts should
S
indicate which measures would be most effective in this respect, for example, introducing an excise
tax on plant protection products (PPPs), introducing standard VAT rates on PPPs and lower VAT rates on
substances allowed in organic products.

IMPROVE THE AVAILABILITY OF NATURAL SUBSTANCES ACCORDING

TO THE ORGANIC APPROACH TO PLANT HEALTH

I ntroduce a definition and separate category for natural substances in Regulation 1107/2009 –
the EU horizontal legislation for placing plant protection products on the market. This is the legal
pre-requisite for a dedicated authorisation process taking into account the specific characteristics
of natural substances while stringently assessing their risks;

 nsure coherence of horizontal and organic regulation and accelerate approval processes. Introduce
E
a non-binding, ex-ante assessment procedure to predict the compatibility of inputs with the organic
standard. The assessment could for example be carried out by the Expert Group for Technical advice on
Organic Production (EGTOP). To speed up the process, the EGTOP needs to be further professionalised in
terms of funding and procedures;

 xpand expert knowledge on natural substances and organic agriculture in all authorities relevant for
E
the authorisation process at national and EU level. Set-up and/or fund initiatives to find more adequate
methods of risk assessment for microorganisms, botanicals and minerals;

 ommit public money to finance the authorisation of natural substances of public interest. Public
C
funding should support the generation of the data needed for the registration of natural substances
with a low return on investment, as long as they contribute to improve the food system’s sustainability;

Improve and develop participatory research at national and European level to enable common
applications for registration of natural substances, in close collaboration with farmers organisations
and related stakeholders.
 © Eva Wolf

IFOAM Organics Europe

Rue du Commerce 124
1000 Brussels - Belgium
+32 2 280 12 23
www.organicseurope.bio
[email protected]