Plant protection substances/active ingredients
In order to know if a certain input can be used, it must be clarified whether the organically produced product shall be sold on the national market, or on the export market. If the product is to be sold on the national market, the national regulatory framework must be complied with. If the product is to be sold on the export market, the regulatory framework of the target country must be complied with. In many cases, an agricultural product that is exported must comply with both the regulatory framework of the target country, as well as the regulatory framework of the country of origin.
Considerations in case of marketing in the country of production
Products that are to be sold on the national market as certified organic must be produced under the provisions of the national regulatory framework on organic agriculture or, alternatively, under the provisions of a private standard or other guideline (such as the IFOAM Norms). Inputs must consequently consist of substances allowed in the relative national or private regulatory framework.
Considerations in case of export
If products shall be exported to a EU country, the inputs must be assessed against the provisions of the EU Regulation 848/2018. For export to the USA, the input must be assessed against the provisions of the USDA National Organic Program 2. For export to other countries with a proper regulatory framework on organic agriculture, the input must be assessed against the provisions of that regulatory framework. For example, for export to Japan, the provisions of the Japanese Organic Agriculture Standards (JAS) must be met. If the product shall be labelled with the brand of a private label organisation with a proper standard, such as Naturland, Bio Suisse or Demeter, the provisions of the respective private standards must be complied with in addition to the legal requirements. As the rules and regulations can change, or can be updated, it is important that farmers are aware of any changes in the requirements and act accordingly and avoid problems with compliance.
National regulations
Almost all countries in the world have a regulatory framework on the use of plant protection agents in agricultural production. This regulatory framework includes lists of substances that are registered for use in national agricultural production. Substances that are not listed may not be used, neither in conventional nor in organic agriculture.
This means, that if a substance is allowed in organic agriculture, e. g. in the EU or the in the USA, this substance can only be used in the national context if it is listed as a plant protection agent in the relative national regulatory framework. If, e. g. pyrethrum, a substance allowed in most regulatory frameworks on organic agriculture, is not registered as a plant protection agent in a specific country, its application in production in that country in both organic and conventional agriculture is prohibited, even if the product is not to be exported.
Regulation of pesticides according to the East African Organic Products
Standard
The following are the specifications on pest, disease (and weed management) according to the East African Organic Products Standard of 2007 (www.kilimohai. org/.../Standards/East_African_Organic_pr):
1. Physical, cultural and biological methods for pest, disease and weed management, including the application of heat, may be used.
2. Inputs for pest, disease, weed or growth management approved for use in organic agriculture according to the IFOAM Basic Standards and CAC/GL 32 may be used. Active ingredients of natural origin in inputs for pest, disease, weed or growth management may be used unless listed in Annex C of the standard.
3. Active ingredients of synthetic origin may be used if listed in the standard.
4. Non-active ingredients, such as carriers and wetting agents, shall not be carcinogens, teratogens, mutagens or neurotoxins.
Regulation of pesticides according to the Organic Regulation of the EU
Since 2022, plant protection products for organic farming need an explicit authorisation. The authorised active substances and their conditions of use are listed in Annex I of the Implementing Regulation (EU) 2021/1165. Active substances that are not listed there may not be used.
The approved active substances for plant protection are divided into four subcategories:
Basic substances
Low-risk active substances
Microorganisms
Active substances not included in any of the above categories
Basic substances
Basic substances are substances and mixtures from food production that are not primarily intended for crop protection but can be used in home-made preparations with water to regulate harmful organisms on the farm. Basic substances include products such as vinegar, fructose, sunflower oil, beer and lecithins.
Basic substances are not plant protection products and may not be marketed as such. The use of basic substances is regulated in Annex I of the Implementing Regulation (EC) No. 2021/1165. Basic substances may not be used as herbicides, but only to regulate pests and diseases.
Low-risk active substances
Microorganisms and active substances with least negative effects on human and animal health and on the environment can be approved as a low-risk substances if they meet the regular approval criteria and the low-risk criteria as specified in Annex II, point 5 of the Regulation (EC) 1107/2009. Because of their favourable properties, low-risk products should be preferred by farmers and other users in their approach to manage pests.
Plant strengthening agents
In contrast to plant protection agents, plant strengthening agents are regulated differently in different EU member states. Plant strengthening agents are substances, mixtures and microorganisms that increase the resistance of plants to parasitic infestation and non-parasitic effects. These agents serve exclusively to keep the plant healthy, and do not aim to control disease pathogens or pests.
Such substances my be used for organic farming in the EU. Guidelines of private associations may define stricter requirements. Marketable plant fortifiers are listed in FiBL’s farm input lists for individual European countries. For easier identification, they are divided into inorganic-based, organic-based, microbial and homeopathic products, according to FiBL.
Availability of lists of authorised products
Uncertainty on the authorisation of substances that can be used in organic farming are often a barrier for the development of organic agriculture. The publication of lists indicating the products available with an indication whether they are approved according to the EU, US or other regulations brings clarity for all parties involved. Such a list is best managed by a certification body, an NGO, or a governmental institution, and farmers are encouraged to refer to such lists for specifications if they intend to sell their organic products in export markets.
Farm-made inputs and their use in organic agriculture
Although most regulatory frameworks do not specifically address the use and legal status of farm-made inputs, such as plant extracts for pest and disease control, in most cases these inputs can be used without restrictions. However, whether a specific farm-made input can be used is decided by the Certification Body (CB). Therefore, it is recommended, prior to application, to always verify with the CB whether the product (farm-made or commercially sourced) can be used in organic production.
An example of the ambiguous situation is the use of commercially produced plant extracts that contain substances that have been banned by the EU from usage in organic agriculture, such as rotenone or nicotine. Such products may not be used for organic production. However, farm made plant-extracts containing these substances may nevertheless be authorised by the CB.
Decision-making for the use of plant protection products
Before using an input, farmers should always verify with the CB, or consult the national input list / the input list of the target country, to be sure that a product can be used for a specific context. In case the CB denies authorisation, or in case the product is not listed in the input list, the operator or his organisation can appeal the decision to the CB or urge the provider of the input to apply for inclusion in the input list. There are several steps to follow in making a decision about using a certain input or substance.
Step 1: Verification if the substance is formally registered as a plant protection agent or fertiliser
Verify if a given substance (e. g. pyrethrum) is registered as a plant protection agent in the country where it shall be applied. If the substance is not registered, the substance, or the product containing such a substance, cannot be used, neither in organic, nor in conventional agriculture.
Step 2: Verification if (a) a substance or (b) a product can be used in national organic agriculture
a) Can the substance be used in national organic agriculture?
If registered for use in the country, the next step is to verify if the substance can be used according to the national framework on organic agriculture. If not, the substance cannot be used on organic produce for the national market.
If the substance is allowed by the country’s regulatory framework on organic agriculture to which the agricultural product shall be exported, the substance can be used, but only if the exporting country does not require certification against its own regulatory framework on organic agriculture as a condition for export from that country.
b) Can a product containing the allowed substance be used in organic agriculture?
If a substance is allowed for use in the national organic agriculture framework, it is important to then verify if a product containing that particular substance (i. e. all the materials present in the product – the active substance(s), co-adjuvants and inert materials - can be used according to the national framework on organic agriculture or the framework of the country of organic export.
Examples of products that contain a permitted substance but are not allowed for use in organic agriculture:
i) Pyrethrum as a substance is permitted for use in the EU. However, the EU regulation does not allow pyrethrum products containing the co-adjuvant piperonyl butoxide (PBO). Regulatory frameworks of other countries, however, do not have this restriction. Organic produce treated with a product containing pyrethrum and PBO can, therefore, not be exported as organic to the EU.
ii) The product Mankocide contains both an allowed substance, copper hydroxide, and a banned substance, Mancozeb. The product can, therefore not be used in organic agriculture.
Step 3. Verification if the substance is allowed in the country of export
Verify if the substance in the product that is used is allowed in the regulatory framework on organic agriculture of the country of export.
If the substance is not allowed, the substance, or the product containing the substance, cannot be used for produce that is to be exported.
For instance, some national regulatory frameworks on organic agriculture allow the use of the insecticide matrine (an extract from Sophora species). However, the EU Regulation on organic agriculture does not allow the use of matrine and organic produce treated with matrine cannot be sold as organic on the European market.
Step 4: Evaluation if the substance is allowed by the private label standard
If the produce shall be exported and branded with the label of a private standard-owner (e. g. Naturland, Bio Suisse, Demeter), it is necessary to verify if the private label standard allows or limits the use of substances that are applied even though the legal regulatory framework might permit the use of such substances (e. g. copper).