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19.2 Organic Regulations

4 months ago

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19.2.1 Organic Rules in Horticulture

The hydroponic production technology in the absence of an organic growth media cannot be certified as organic, which has proven to be a long-time effective barrier for the conversion of existing greenhouse vegetable producers to organic farming schemes (König 2004). For horticultural products, the specific EU regulation preventing products produced under 'classical' aquaponics systems to obtain an organic certification are the following:

834/2007 Regulation (12): ....Plants should preferably be fed through the soil eco-system and not through soluble fertilizers added to the soil

889/2008 Article. (4): Organic farming is based on nourishing the plants primarily through the soil ecosystem. Therefore hydroponic cultivation, where plants grow with their roots in an inert medium feed with soluble minerals and nutrients, should not be allowed.

Since aquaponics is based on using fish sludge as a source of fertilizing the plants, the absence of mineral fertilizers would at first seem like a step towards organic production. However, the 'classical' aquaponics production systems started using components from the soilless hydroponic technology, and therefore the plants produced under such a system cannot be certified as organic. In order to understand this prohibition in organic regulation, it is helpful to remember that hydroponics was developed and adopted by growers as a response to the challenges greenhouse growers met in intensive soil-based vegetable cultivation systems, e.g. enrichment of the soil with soil-borne pathogens. In contrast, the organic horticulture approach departs from the question of how greenhouse farming has to look like in order to avoid these challenges. Their starting point is instead to change the management of the soil rather than inventing a production technology without soil.

In addition to this general principle of soil-based production, organic horticulture can be considered a specialized niche within organic farming offering a considerable variety of crops. The legislation for fruit vegetables, such as tomato, cucumber, pepper, eggplant, etc. prescribes cultivation in natural soil. Plants sold with the soil, such as seedlings or potted herbs, can be certified as organic. The prerequisite is that the plant could continue growing at the customer's greenhouse or kitchen window. This means, that herb bunches, salads cut off from the roots need to be grown in soil in order to qualify for organic certification. Inputs allowed for organic production are regulated in the implementing regulation. For Germany, Switzerland and the Netherlands, the testing and approval of inputs for organic production is maintained by FiBL (Research Institute of Organic Agriculture), who are currently aiming at developing a European List on inputs certified as suitable for organic status.

The nutrient supply in organic greenhouse production is a challenge. Not only are mineral fertilizers common in hydroponic production systems not allowed but, in the special case of the German organic farmer associations (going beyond EU legislation), also hydroxylates that are of animal origin (interview with organic extension service). Greenhouse growers who have invested in infrastructure sealing the natural soil with permanent greenhouse flooring, have faced a long-time effective barrier for the conversion of existing greenhouse infrastructure to organic farming schemes, except for potted herbs (König 2004). New investments in greenhouse infrastructure have contributed to the increase of organic fruit and vegetable production in the last years, e.g. in Germany. However, for these modern organic growers, aquaponics does not yet provide any solution as they are looking for answers into the areas of suitable soils, improved crop rotation, effective microorganisms, compost and the like.

Horticulture is facing the general challenge that the organic EU regulation is not very detailed in this area. Theoretically, this leaves room for new production approaches such as aquaponics. However, at this stage of development within both commercial organic horticulture and aquaponics, the start-up costs for the producers are immensely high let alone the search for information on production management, prohibitions, potential yields, etc. In the end, the suitability of innovative production systems is left to the decision of the local certification authority on a project-byproject basis (König et al. 2018).

However, since the starting point in organic agriculture is about soil-based production and the fact that horticulture, aquaculture and aquaponics are small sub-sectors; the EU regulation regime on organic production may not be something that is expected to change in the near future.

19.2.2 Organic Rules in Aquaculture

For organic aquaculture, the production is regulated by Commission Regulations of 889/2008 and 710/2009. In parr. 11. Commission Regulation (2009), recirculating technologies are clearly prohibited in organic aquaculture, except for the specific production in hatcheries and nurseries making and selling fingerlings for further growth in open-air pond systems.

Parr. 11.

Recent technical development has led to increasing use of closed recirculation systems for aquaculture production, such systems depend on external input and high energy but permit reduction of waste discharges and prevention of escapes. Due to the principle that organic production should be as close as possible to Nature, the use of such systems should not be allowed for organic production until further knowledge is available. Exceptional use should be possible only for the specific production situation of hatcheries and nurseries.

Since recirculating technology is at the core of the aquaponics production system, it is at present not possible to get a complete organic certification of an aquaponics system, if all of the finishing produces is to be sold for the consumer market.

Likewise, the organic regulation on fish density in open ponds and marine cages are mainly made to secure a minimal discharge of fish manure to the aquatic environment. Questions on fish welfare are therefore an indirect matter related to their well-being based upon the level of freshwater exchange in the ponds. The stocking density in organic aquaculture systems is often 1/4 to 1/3 of that in modern RAS systems, and therefore from an economical aspect, not very cost-effective for this technology. At the same time, we need research and development on animal welfare indicators as well as on feasible and meaningful animal welfare monitoring tools as a prerequisite to discussing specific stocking densities. Only then will we be able to assess the potential economic viability of the aquaculture part of an organic aquaponics system (Ashley 2007; Martins et al. 2012).

19.2.3 Aquaponics and the USA Organic Regulation Regime

As in Europe, there is an ongoing discussion in the USA about how to handle soilless or soil replacement approaches for nutrient provision to plants as a mean of a resource-efficient food production and their inclusion or exclusion from the organic certification scheme. Despite these discussions, the state of the art is somewhat similar undecided to that in Europe, but practices differ: recently, the Crops Subcommittee of the National Organic Standards Board provided a suggestion to make aeroponics, aquaponics and hydroponics prohibited practices under Sect. 205.105 of the USDA Organic Regulations (NOSB 2017). This decision was rejected with 8:7 votes, yet not achieving 10 votes to make the decision a recommendation of the NOSB to USDA. Only the rejection of aeroponics found sufficient votes (14 out of 15, NOSB 2017). Therefore, the USDA Agricultural Marketing Service is only reviewing the recommendation to exclude aeroponics from organic certification (AMS 2018, p.2). This NOSB decision had been forced due to non-harmonized practices in the past among accredited organic certification agencies, whereby some of them certified hydroponics as organic under the National Organic Program (NOP) while others did not. These differing practices can be seen as a result of a long discussion process with no clear conclusions, ending with eight certifiers certifying hydroponic operations as organic in 2010 and a 33% increase of organic certified hydroponic producers (NOSB 2016: Hydroponic and aquaponics subcommittee report). Already back in 2010, the NOSB had received recommendation for a federal rule concerning greenhouse production systems, indicating basically that 'Growing media shall contain sufficient organic matter capable of supporting natural and diverse soil ecology. For this reason, hydroponic and aeroponic systems are prohibited.', yet this explicit prohibition did not enter current law (NOSB 2010, 2016:122). Instead, the more open definition of organic production from 2002 was in place, where organic production is '[a] production system that is managed in accordance with the Act and regulations in this part to respond to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity' (NOSB 2016, p. 7). The hydroponic and aquaponics subcommittee concludes that 'Under current law and clarification from NOP/USDA, hydroponic and aquaponic production methods are legally allowed for certification as USDA Organic as long as the producer can demonstrate compliance with the USDA organic regulations.' (NOSB 2016, p. 10—11). However, the difficulty is that organic production is about management of the soil, whereas hydroponics is a system managing fertilizers. By not addressing this difference could lead to some ambiguity and potential negative consequences for the support of organic certification by farmers and consumers (AMS 2016). In the (NOSB 2016, Alternative Labeling Subcommittee Report), other experts presented a range of ideas as to how labels within the USDA organic scheme or outside could appear. Because of a lack of standards and norms, which is a necessary basis for labels, the group did not arrive at a consensus. The opinion was that, if aquaponics were included, or an extra label added, among the already existing great diversity between the different organic productions systems, it would both challenge the certification process as well as being a source of confusion for consumers. Interestingly, the suggestions of label alternatives under the USDA organic umbrella, or in addition to it, highlight the anecdotal evidence that the principle of aquaponics farms seems to be appealing to consumers, and that they do not need to be certified organic to be viable (NOSB 2016, Alternative Labeling Subcommittee Report, p.5).

In summary, the NOSB (2016) provides a detailed process description from the early 1990s until today, which reflects also different opinions of stakeholders involved in this discussion. The Organic Foods Production Act of 1990 (OFPA) builds on this basis for the development of federal US organic certification for the NOSB, and since then the discussion about allowing greenhouse production systems for organic certification or not has been in place (NOSB 2016). By now, there is agreement in the discussion which recognizes that the roots of organic farming lie in the concern about soil fertility and soil quality. All organic farming practices and standards developed are based upon this premise, and any discussions about its further development have to start from this point of view.

In the discussion, there are more open questions involved as to whether hydroponics could be called organic or not. The comparison of conventional and organic farming, in the case of horticultural greenhouse crops, hinges on some poorly researched or still controversially discussed issues (NOSB 2017):

The type of farming practice may also explain the differences found in organic and conventional products, e.g. lower content of secondary plant metabolites of conventionally grown greenhouse vegetables compared to organic vegetables from field farming. Allowing hydroponics to be certified as organic, this currently communicated added value of organic products could not be communicated to consumers anymore as added value unambiguously.

An important source of nutrients in hydroponic systems is hydrolysed soybean meal, which US growers import from Europe in order to ensure GMO-free sourcing compatible with organic standards. This impinges negatively upon the overall sustainability.

One principle of organic farming is dealing with resilience, which is doubted for hydroponic and aquaponics farming systems as they are highly dependent on an external energy supply (anecdotal observations). Opponents state that organic farms are likewise not 'resilient' against severe natural disasters, yet both groups remain somewhat unclear about their resilience concept when applied to these production systems.

A comparison of processes at the root surface, i.e. the microbial environment in soil versus water and the nutrient uptake, is an open question and opponents argue that literature on this topic is perceived as not sufficient.

In contrast, all the arguments that can be found in Europe as to why hydroponics or aquaponics should be certified as organic are also brought into the discussion in the US. The most remarkable point is, however, the lack of data on the direct comparison of systems in order to be able to evaluate the mentioned impacts and advantages systematically. In summary, the NOSB rejected to label hydroponic or aquaponics systems as organic in general because (NOSB 2017, p. 70—71):

§ 6513 Organic Plan: "An organic plan shall contain provisions designed to foster soil fertility, primarily through the management of the organic content of the soil through proper tillage, crop rotation, and manuring...An organic plan shall not include any production or handling practices that are inconsistent with this chapter."

  • § 205.200 General: " Production practices implemented in accordance with this subpart must maintain or improve the natural resources of the operation, including soil and water quality."
  • § 205.203 Soil fertility and crop nutrient management practice standard: (a) "The producer must select and implement tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of soil and minimize soil erosion." (b) "The producer must manage crop nutrients and soil fertility through rotations, cover crops, and the application of plant and animal materials." (c) "The producer must manage plant and animal materials to maintain or improve soil organic matter content..."

Later, in the year 2016, definitions were given for hydroponics, aquaponics and aeroponics, stating for aquaponics that (NOSB 2017, p. 82):

Aquaponic production is a form of hydroponics in which plants get some or all of their nutrients delivered in liquid form from fish waste. Aquaponics is defined here as a recirculating hydroponic system in which plants are grown in nutrients originating from aquatic animal waste water, which may include the use of bacteria to improve availability of these nutrients to the plants. The plants improve the water quality by using the nutrients, and the water is then recirculated back to the aquatic animals.

The NOP has strict standards for handling animal manure in terrestrial organic production, but no such standards exist to ensure the safety of plant foods produced in the faecal waste of aquatic vertebrates. Also, the NOP has not yet issued standards for organic aquaculture production, upon which aquaponics plant production would be dependent. 'The Crops Subcommittee is opposed to allowing aquaponic production systems to be certified organic at this time. If aquaculture standards are issued in the future, and concerns about food safety are resolved, aquaponics could be reconsidered.' (NOSB 2017, p. 82).

In there is the 'Naturally Grown' certification, a peer-review, grassroot certification, which explicitly includes aquaponics (https://www.cngfarming.org/ aquaponics). This certification involves a catalogue with criteria from January 2016. Only the vegetable produce is certified, not the fish part because at the moment it (e.g. fish feed) does not meet the general criteria for livestock certification. The criteria regulate the following aspects: System Design and Components, Materials for Main System Components and Growing Media/Root Support, Water Sources, Monitoring, Inputs for pH Adjustment, Waste Use & Disposal, Crop Production and Management, Fish Management, Location and Buffers, Energy and Record Keeping. The scheme is based on peer inspection schemes and does not allow the usage of synthetic pesticides and fungicides, copper-based pesticides, petrochemical-based pesticides or fungicides. It does not regulate the components on the plant part, but assesses its functions: water regulation, aeration, degassing, biofiltrations and removal of fish waste solids.

In summary, there are individual organic certification bodies in the US certifying aquaponics (parts) as organic production, but there are also cases reported of farmers claiming organic production without being certified (Friendly Aquaponics 2018). After this chapter goes to press there may be new developments affecting the organic certification topic. In addition, the issue of urban farming being declared as farming, and hence being eligible for agricultural funds might get a clearer status with the pending new US Farm Bill.