Assessment of irregularities in organic imports from Ukraine to the EU in 2016, notified in OFIS

Summary in the original language of the document

The underlying study of this report set out to improve the understanding situation concerning residues found in organic food products exported from Ukraine, and to formulate guidelines for identifying and reducing risks for contamination through non-permitted substances based on the results of an in-depth analysis of those residue cases notified in the European Commission’s Organic Farming Information System (OFIS) in 2016.
Not surprisingly, the combination of various factors such as (i) the additional sampling required by the new EU import guidelines, (ii) the growing number of exported organic lots from Ukraine, and (iii) the improved analysis technology, led to an increased total number of cases of irregularities notified in OFIS in comparison to previous years. Nevertheless, the number of irregularities in Ukraine in 2016, notified in OFIS, is moderate (affecting estimated < 1% of all exported consignments from Ukraine). Of the lots affected, two thirds were ultimately released as “organic” after additional investigations had been carried out by the respective export CB.
Yet, if analysis results of samples taken by the CB’s prior the export, i.e. from crops during the growing season and from lots before they are released for export are included in the risk assessment, Ukraine and its neighbouring countries do need to be considered as relatively high risk countries in terms of contamination and irregularities. It is further interesting to note that the likeliness of residue findings vary a lot among different CBs. The reasons why some CB’s have a high share of residue findings whereas for others proportionally much less residues are found are unclear and should be the subject of further assessments. One assumption is that some CBs took risk-oriented samples whereas others did not.
Sampling during the production process (field/leafs and dust) effectively supports organic integrity. Most CB nevertheless focus on residue free final products. The way a CB responds on detected irregularities, i.e. investigates a case and derives “lessons learnt” is very important.
A majority of OFIS cases from Ukrainian exports seems to be linked to insufficient management of handling procedure during the storage processes and the transport. However, drift on the field or the intentional use of unauthorised substances are also potential sources of irregularities related to exports from Ukraine.
Apart from those cases for which likely root causes have been identified, no clear explanation for discrepancies between lab results between export and import countries could be found for nearly one third of the Ukrainian OFIS cases. Further investigations should be carried out to help identify the reasons for the relatively large differences between the lab results of samples taken from the same trade lots. It is important to better understand these discrepancies in sample measurements because these may lead to significant negative economic impacts for everyone involved in the value chain, even though no rules may have been broken.
Another recommendation resulting from this study is to focus more on detecting potential contaminations on the field during the period of crop cultivation. Special attention should be given here to the testing of leaf sample of crops in which contamination has been detected in the past: rapeseeds, sunflower seeds or high quality milling wheat. CB’s should have guidelines on how and when leaf samples should be best taken.
Ukrainian organic operators often complain that all Ukrainian operators are put in the same basket and treated as high-risk suppliers. In response to the stricter regulations imposed on them, operators and experts participating in the International Conference “Improving Integrity of Organic Supply Chains” in Odesa 2017 called for an amendment of the inspection policy. Instead of labelling entire countries as high-risk, focus should rather be placed on risky value chains. Supply chains considered high-risk should be relieved from extra measures, once they have demonstrated consistent compliance.