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Conversion to Organic Agriculture - by Niccolo 'Bartoli

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Company conversion to the principles of organic agriculture - Introduction

The decision to convert a company or part of the company's production to the principles of organic agriculture implies the need to face a certain bureaucratic path. The obligations related to this process can be divided as follows:

- Admission procedures to the control system

- Certification procedures

- Maintenance of the qualification of controlled operator

- Control bodies and authorities.

- The procedures discussed below are valid within the Tuscan territory.

Admission procedure to the control system

1. The producer (operator) sends the NOTIFICATION of production activities with biological method, subjecting itself to the chosen control body and formally committing to compliance with the rules established by EEC Reg. 2092/91 and subsequent amendments and additions. In addition to the notification, the operator is required to draw up a declaration (tab. 15) containing:

- a complete description of the production unit, the plants and the activity;

- a description of the concrete measures that need to be introduced to ensure compliance with the provisions on organic farming.

2. LARSIA, within 30 days from the arrival date of the 1st, carries out a formal investigation by:

- evaluate the completeness of the data and the regularity of the documentation;

- ask the operator for any additions;

- register the biological operator in a pre-list.

3. The control body, after evaluating the documentation presented by the operator, carries out a first inspection visit in order to establish whether the structural and managerial aspects of the company comply with the provisions of the EEC Reg. 2092/91 and subsequent additions and modifications.

4. The control body, more precisely the Certification Commission, having acquired the information contained in the company documentation and in the inspection report, assesses (within 60 days) the company's eligibility for the control system. If the result is positive, the control body must send the CERTIFICATE OF CONFORMITY to the ARSIA, within 120 days from the date of sending the first notification, as well as to the operator himself. In the event of a negative ruling, the reasons and corrective measures to be implemented for overcoming the non-compliance are communicated, as well as the times within which they must be performed. The Certificate may only be used by the company in compliance with the following:
- the operator can inform its customers of the entry into the control system in the manner deemed appropriate and make the Certificate of Conformity public;
- the operator cannot in any way make believe that the Certificate of Conformity is valid for the purposes of product certification.

5. Following the transmission by the control body of the Certificate of conformity, ARSIA registers the operator in the regional list of biological operators, communicating this registration to the operator within 30 days.

6. The operator must present, within 30 days from the date of communication of admission to the control system, the annual production program of the company conducted according to the organic farming method, referring to the current year. In the case of conditioning / transformation activities, the annual processing program must be submitted within the same deadline.

When entering the control system, the companies are in the process of converting to organic farming.

The conversion is the period between the date of first notification of biological activity and, in the case of herbaceous crops, the date of sowing of the product which will be certified by organic agriculture, while for perennial crops other than meadows, the reference is the date of the first harvest; this period is normally set in two years for herbaceous crops and in three years for perennial crops other than lawn (see table).

Waiting times for the qualification of organic product
or in conversion to organic agriculture

CONVERSION qualificationORGANIC qualification
Arable areaAfter 12 monthsAfter 24 months
SuperficiarboreeAfter 12 monthsAfter 36 months

The control body may decide, upon request of consent to ARSIA, that in certain cases the periods in question are prolonged or shortened taking into account the previous use of the plots.
The situations in which it is possible to request a reduction of the conversion period are:

- mountain pasture areas where unauthorized products have not been used under organic farming;

- plots destined for set-aside and no longer cultivated until the moment of application of the organic method;

- plots of land uncultivated for at least 3 years prior to the application of the organic method and in which unauthorized products have not been used under organic farming;

- plots cultivated for fodder for at least 3 years prior to the application of the organic method and in which unauthorized products have not been used under organic farming;

- uncultivated land.

For the plots on which the techniques provided for in Measure A.1 of the Regional Implementation Program of the EEC Reg. 2078/92 and Action 6.2 of the PSR 2000/2006 of the Tuscany Region have been applied and on which products not allowed in In the organic farming regime, the inspection body may, subject to agreement with ARSIA, retroactively recognize a maximum period of three years immediately prior to notification as part of the conversion period.
The conversion process can also be carried out not simultaneously on the entire company surface, in which case parallel production is forbidden (presence of the same variety in both organic and conventional cultivation) with the exception of perennial crops if specific conditions are met.

Certification procedure

The company under control has the right to request, by forwarding the appropriate forms to the control body, the issue of the following types of certificates:

- CERTIFICATE OF CONTROLLED COMPANY

- PRODUCT CERTIFICATE

- AUTHORIZATION TO PRINT THE LABELS.

After examining the company file to verify that the documentation is complete and compliant, the control body may consider it appropriate to integrate the documentation and / or an inspection visit to the company for the collection of samples to be sent to the analysis laboratory.
The issue of certificates or authorizations, subject to the successful outcome of the investigations carried out on the documentation and samples collected (residues of plant protection products not allowed by the legislation on biological activities in an amount equal to or less than 0.01 mg / kg or 0.01 ppm) , takes place within 15-30 days of the request.

of Bartoli Niccolò

Since 1 January 2009, the EU regulatory framework relating to agri-food production obtained with the organic method has profoundly changed. The EEC Reg. 1804/99 was repealed by the EC Reg. 834/07


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