EU-China Organic Food Standards Comparison

1. Comparison of EU and Chinese organic standards

• Notable similarities and differences between the two systems

• Information derived from Annex IV of Regulation (EC) No. 1235/2008

• Seven categories of substantial importance

A. Unprocessed Plant Products

• Includes products such as peat, mushroom culture wastes, composted bark and wood ash

• China regulations less stringent than EU regulations

• Products are specifically legislated to be from their natural origin

Similarities:• Chinese regulations on wood products (bark, wood ash)

similar to EU law

Differences:• More unprocessed plant products used in fertilizers, soil

conditioners and nutrients under Chinese law• Chinese regulations state products should not contain

synthetic chemical substances or receive chemical treatment • Plant ash (product of fuel-wood) allowed for fertilizers under

Chinese law but not under EU law

EU Legislation Chinese Legislation

Sawdust/ woodchips Wood not chemically treated after felling

Sawdust/ woodchips Obtained from wood not chemically treated

Composted bark Wood not chemically treated

Composted bark Obtained from wood not chemically treated

Peat Use limited to horticulture (floriculture, arboriculture)

Peat Contains no synthetic additive. Only used as potting medium and not to be applied to soil amelioration

No regulation Borax Obtained without chemical treatment or synthetic chemical substances

No regulation Pulp Obtained without chemical treatment

B. Live Animals/ Unprocessed Animal Products

Legislation relating to wool and fur less stringent under Chinese law than EU law – no adherence to official guidelines under Chinese regulation

Similarities:• Minimum surface areas indoors, outdoors and characteristics of housing

Differences: • Wool, fur, hair and dairy products used in fertilizers, soil conditioners and

nutrients under Chinese regulations • No indoor or door space regulations in China for fatting pigs over 110 Kg• In China regulations there is: • No difference in minimum indoor space required for guinea fowls while

fattening in fixed housing • No specific square meter per 100 KG space required for bovine and

equidae over 350 Kg while breeding and fattening • No minimum perch length given for laying hens (poultry) • No Regulation in Chinese organic legislation for maximum number of

animals per ha equivalent to 170 Kg N/ha/year

EU Legislation Chinese Legislation Breeding and fattening bovine

Up to 100 Kg < 100 Kg

Equidae Up to 200 Kg < 200 Kg

Piglets Over 40 days and up to 30 Kg > 40 days or <30Kg

Poultry

Fattening poultry in movable housing

6 in mobile poultry houses not exceeding 150 m2 floor space with a maximum of30 kg liveweight/ m21

16 (Live weight ≤30kg/m2)

Class/species Maximum no of animals per ha equivalent to 170 kg N/ha/year

Equines over 6 months

2 No regulation

Calves for fattening

5 No regulation

Female breeding rabbits

100 No regulation

Table chickens 548 No regulation Laying hens 230 No regulation

C. Aquaculture Products and Seaweeds

• EU law more comprehensive than China regulations

• State clearly requirements for aquaculture products and seaweeds

Similarities: • Seaweeds and Seaweed products – must be obtained from

physical process including dehydration, freezing and grinding

Differences: • No Chinese legislation on production and use of fish and other

aquaculture species i.e. organic production of salmonids in sea water

EU Legislation Chinese Legislation Seaweed/ seaweed products

As far as directly obtained by physical processes including: dehydration, freezing and grinding; extraction with water or aqueous acid and/or alkaline solution; fermentation

Seaweed/ seaweed products

Obtained only by physical processes including: dehydration, freezing and grinding; Extraction with water or acid and (or) alkali solution; Fermentation

Organic production of salmonids in freshwater Brown trout (Salmo trutta), Rainbow trout (Oncorhynchus mykiss) etc.

Production system On growing farm systems must be fed from open systems. Flow rate must ensure a minimum of 60 % oxygen saturation for stock

No particular regulation in Chinese legislation

Maximum stocking density

Salmonid species not listed below 15 kg/m 3. Salmon 20 kg/m 3 Brown trout and Rainbow trout 25 kg/m 3

No particular regulation in Chinese legislation

D. Processed Agricultural Products for use as feed

• Regulations between EU and China same with some dissimilarities

• Few Chinese regulations that correspond to EU law regarding some products

• Chinese law less stringent than EU law

Similarities: • Regulations relating to vitamins added to feed as nutritional additives

Differences: • Few Chinese regulations control the use of processed agricultural

products for use as feed• No Chinese regulations relating to use of antioxidants in feed for animal

nutrition• Emulsifying and stabilizing agents, thickeners and gelling agents

(Lecithin) only derive from organic raw materials in EU• No Chinese regulation governing flavoring compounds and where they

can be derived from • Chinese regulations state what additives can be used, unlike EU

EU Legislation Chinese Legislation A. Emulsifying and stabilizing agents

ID Number Substance Conditions for use

1 E 322 Lecithin Only if derived from organic raw material

No regulation

Sensory additives

2b Flavoring Compounds

Only extracts from agricultural products

No regulation

B. Feed materials of agricultural origin

Substance

No regulation Propionic acid Used only when weather conditions fail to meet sufficient fermentation

No regulation Citric acid Used only when weather conditions fail to meet sufficient fermentation

C. Silage additives

Yeasts and bacteria Use restricted to production of silage when weather conditions do not allow for fermentation

No regulation

E. Processed Agricultural Products For Use As Food

• Chinese legislation less stringent • Note – instances where Chinese legislation

articulated in clear and definite terms

Similarities: • Products for processing ingredients of agricultural origin (hazelnut

shells, rice meal) not regulated in China nor EU

Differences: • All gums, locust, guar, Arabic and Xanthan have specified uses

under China Regulations but not EU regulations• Other additives (vegetable carbon) have no corresponding

Chinese legislation • Products for production of yeast and yeast products (potato,

starch) not regulated in China

F. Vegetative Propagating Material and Seeds for Cultivation

No reference to vegetative propagating material and seeds for cultivation within current Chinese legislation

G. Pesticides

Products allowed for pesticide under Chinese Regulations highlight key differences between EU and China

Similarities: • Regulations regarding micro-organisms use for biological pest and

disease control,• Substances used in traps/ dispensers• Preparations to be surface-spread between cultivated plants

Differences: • Significant amount of crop or animal origin permitted in China, more

limited in EU • They include: osthole, berberine, emodin monomethyl, natural

acids… • Of 26 substances for traditional use in organic farming permitted for

use in pesticides, only 14 used in EU• Copper salts (copper sulfate, oxychloride) only used as fungicides

under China regulations

EU Legislation Chinese Legislation 1. Substance of crop or animal origin

Hydrolyzed proteins Only in authorized applications in combination with other appropriate products

Hydrolyzed Proteins Used in combination with proper products stated in this Appendix only under the approved application conditions

No regulation Osthole Insecticide and bactericide

No regulation Emodin Bactericide

No regulation Milk Bactericide

2. Micro-organisms used for biological pest and disease control

Spinosad Only where measures are taken to minimize the risk to key parasitoids

No regulation

3. Substances to be used in traps and/ or dispensers

Diammonium phosphate

Only used in traps Diamonium phosphate Only used in traps

4. Other substances from traditional use in organic farming

No regulation Calcium hydroxide Fungicide

No regulation Carbon dioxide Insecticide

No regulation Ethyl Alcohol Bactericide

2. Control systems

• China and EU have equivalent procedures for accreditation and certification of control bodies and operators

• China’s procedures are in places more stringent and detailed

Supervision of Control Bodies

• EU Competent Authorities carry out audits or invite external audits, subject to external review

• CNCA in China– performs annual site audits market supervision– Entry Export Inspection and uarantine Services

(CIQs) check product quality and labelling in the market

– Same inspector cannot visit same unit more than 3 consecutive years

Risk-based Control Systems

• EU in addition to annual checks, further checks on risk basis– 10 percent minimum units receive random

additional inspections• China after annual inspections further checks

according to risk profile– 5 percent minimum units receive random

additional inspections

Non-compliance and Sanctions

• EU: non-compliance results in disqualification of complete production run– Severe infringement control body and competent

Authority agree to suspend for an agreed period– Sanctions ‘effective, proportionate and dissuasive’

• China: detailed list of reasons for cancellation, suspension and revocation of certificate – Sanctions operators fined from rmb10,000 –

rmb30,000

Traceability

• EU traceability for organic food follows EU traceability regulations for all food– Operators must be able to trace and follow a

food . . through all stages of production, processing and distribution

• China has, as of I July 2012, implemented a 17-digit electronic traceability system for all organic food packaging that traces from origin to distribution.