Government Must Make Organic Certification Accessible For All, Before Making it Mandatory – Other Better Ways of Weeding Out Fake Organic Should Be Adopted.
With effect from July 1, 2018, Food Safety & Standards Authority of India (FSSAI) is making certification mandatory for organic foods, and hence effectively for organic farmers.While it might limit fake organic to an extent, it will also throw out common consumers and small farmers from the organic market, which will have deleterious effect on the health of the public and the environment.
These consequences will follow because both the available systems of organic certification – third party certification as well as Participatory Guarantee System (PGS) of quality assurance – are beyond the reach of a common farmer, especially those farmers who do not have any NGO, or government agency or private company supporting them. Individual certification is very expensive. Group certification is possible only if there is an external facilitator who is collectivizing the farmers. The expenditure involved is not affordable for an ordinary farmer. Governments are spending on such certification only if a farmer is covered under their schemes, that too usually for a 3-year period during which the scheme is run. There is also the tedium of paperwork and records to be maintained which is not in the capabilities of most farmers. The PGS system requires organic farmers to form themselves into groups of at least 5 farmers each, and committing to monitor each other’s farms. This is not always possible, and therefore is not a solution for farmers who are plodding ahead all alone, on the path of organic farming.
Meanwhile, with only 29 accredited certification bodies in the country and hundreds of Regional Councils of the PGS-India system suspended or inactive, it is clear that there is no institutional readiness to support the growth of organic movement in India with mandatory certification.
There are other reasons why many organic farming enthusiasts are concerned. Organic farming has been adopted by thousands of farmers as an uphill task they had to undertake. This did not receive much support from governments, while a destructive, chemical-and-water-intensive paradigm receives large subsidies from governments. It is indeed ironical and unfair that a paradigm that is beneficial to human beings and their environment, a paradigm that will conserve and revive our natural resources for the next generation is being forced to spend more monies to prove itself to be that, while there is no certification being asked from a paradigm that is polluting and poisoning our resources, to show that it is indeed complying with regulations.
Further, it is not out of place to point out that certification is not a fool-proof mechanism to ensure that something is organic. In fact, there is an inherent shortcoming in the revenue model adopted by certification bodies, in that they need to certify more and more farmers as organic for raking in revenues – this then leaves scope for bad quality work, including willful inclusion of non-organic farmers in their certification process. It is well known that Transaction Certificates issued by certifiers are being misused, with the certifiers not ascertaining whether the amount paid by an organic food procurer is actually going to the so-called certified operation, or someone else in the open, non-organic market on the same TC. PGS, while being more facilitative, while building informal institutions of organic farmers for mutual learning and peer collateral for quality assurance, suffers from the fact that it too has a similar inherent shortcoming. It also does not provide any solutions to individual farmers struggling to turn organic on their own. In fact, PGS in India had evolved in the civil society-led organic farming movement, and a voluntary code of conduct, overseen and coordinated by PGS-OC (PGS-Organic Council) did not find any recognition in the FSSAI regulations.
We are aware that FSSAI has exempted “organic food which is marketed through direct sales by the small original producer or producer organisation… to the end consumer”. However, this relief is not enough because as per usual official definition, a farmer with more than 5 acres is not considered a small farmer. Even for a farmer owning 6-7 acres, the cost of certification is prohibitive. When quality assurance is being made effective through the direct relationship that a farmer and consumer have in a direct sales transaction, then it is unclear why non-small-farmers are being excluded from the exemption clause. Moreover, it is generally not possible for farmers to sell all their produce directly, without the help of an intermediary – whether a retail shopkeeper or an institution – to the consumer. Farming operations are adversely affected by concentrating on direct selling. Therefore, without exemptions being provided for sales that are one step away from the end consumer, through a retailer, the exemption provided to a small farmer is also meaningless.
We also believe that “fake organic” is not something that makes our food any more unsafe than the conventionally-produced food out there. There are existing laws for cheating consumers, like the Consumer Protection Act. In fact, it is worth remembering that organic food is less than 0.1% of total food consumption in India. The fact that FSSAI, which has not taken up any effective regulation of truly unsafe foods like GM foods and pesticides-laden foods is in fact worrisome, while it is over-zealous in regulating organic foods.
It is not out of place to point out that Seed, which is an “Essential Commodity” as per an Indian statute, when sold commercially, is not required to be certified, and that seed certification is only voluntary. An overwhelmingly large proportion of seed trade in India is “truthfully labeled”. If the regulatory approach to an essential and critical commodity like Seed can be that of voluntary certification, it is unreasonable that organic foods should be mandatorily certified.
It is apparent that organic farming will not spread the way it should, if marketing avenues are not available to organic farmers. It is such marketing opportunities that are directly and adversely affected by this new FSSAI regulation. Under these circumstances, by making organic certification mandatory, organic farming movement will wither away before blooming, which in turn will deprive ordinary consumers of safe food; organic produce will become all the more expensive and hence much more elitist.
Some of the best and pioneering organic farmers of India, the ones who have inspired hundreds of others to shift to organic farming, are in fact un-certified. There is no way that they can get certified by July 1st2018, if one were to follow the rule book related to certification. The FSSAI notification did not take into consideration any of these implementation issues either.
The organic farming movement in India believes that we need win-win solutions for both organic producers and consumers, and therefore, opposes the new notification of FSSAI. The new regulations brought in do not protect the interests of organic farmers or consumers, and instead favour organic industry interests, certification bodies as well as big organic food brands. This article should not be misinterpreted as one that seeks to counter any regulation of organic foods.
Prior to making certification mandatory for all organic foods, governments should have made organic certification easily accessible by making it free, time-bound and simple. Until this happens, all organic farmers should be exempted from mandatory certification and allowed to sell directly to consumer or through one step away shopkeepers/intermediaries (who procure directly from farmer and are willing to maintain traceability of the organic produce).
When government provides adequate infrastructure for separate storage, processing units and retail outlets for organic foods, regulation will be easier in terms of ensuring traceability and therefore, verifying the organic production practices as and when needed.
FSSAI/Government should also ensure that all food products, whether they are organic or not, should be safe. All food sold to consumers, whether organically produced or conventionally produced, should meet safety standards. To ensure this, there should be facilities provided where any farmer or consumer can get any food product tested for free or at nominal charges. This will be more effective in ensuring safe food to all.
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