A study tour of organic poultry production in France - current & future implementation of standards & EU legislation

Summary

Introduction
There have recently been major changes in the regulations governing the production of organic poultry products in the EU. Member States have been required to set Standards for production that meet the minimum set in Regulation (EC) 1804/99 if products, including poultry, are to be sold as organic within the EU. This has raised concerns over consistency of implementation in other Member States, and whether, directly or through derogation, this might lead to competitive advantage over the UK.
MAFF were aware that France had drafted derogations in accordance with Regulation (EC) 1804/99, and intended to implement some aspects of the Regulation which were claimed to be more stringent than the basic requirements.
The aim of this project was to establish any differences between France and the UK in the interpretation of Regulation (EC) 1804/1999 and the application of derogations within the standard, and to assess whether there was likely to be an effect on the competitiveness of UK organic poultry production.
The project comprised a study tour of organic poultry production in France, and was undertaken by an experienced ADAS poultry consultant. Arrangements for the study tour were made in December 2000 and the study tour was undertaken between the 8 January 2001 and 14 January 2001.
Results
While for the most part the application of organic standards in France results in no competitive disadvantage to UK organic poultry producers, there are three aspects, related to laying hens, in which they do. These are detailed below.
1) Derogations under 8.5.1 of the French Standards stipulate that the effective date for “production units already notified for the purposes of organic farming” is before the 30 August 2000, not the 24 August 1999 as in Regulation (EC) 1804/99, the the UKROFS Standards, and in the 22 May 2000 French authorities draft organic standards for transmission to the EU. It is difficult to see how the French authorities can justify the adoption of this later date which appears to contravene Regulation (EC) 1804/99.
2) Application of French organic Regulations to laying hens appears to contravene Regulation (EEC) 1274/91 on Special Marketing Terms relating to free range production. Regulation (EEC) 1274/91 requires that in order to use the term free range (or in French ‘plein air’) hens must have continuous daytime access to open-air runs, whose grounds must be mainly covered with vegetation. Secondly, the maximum permitted stocking density in the run is one hen per 10m2. The accepted practise of keeping hens in the house until 28 weeks of age in order to meet the requirement to rest outside runs for at least two months, and then stocking them in the runs at a high density (only 3 to 4 m2 of run/hen), would appear to breach Regulation (EEC) 1274/91. Eggs from hens kept in this way should not therefore be sold as free range or organic in France, or exported to the UK.
3) The debeaking of pullets at eight to ten weeks of age as practised systematically in France would be unacceptable in the UK where beak trimming is allowed only up to 10 days of age. It is questionable whether eggs from French debeaked hens should be acceptable for export to the UK.
Details relating to Standards, derogations, certification bodies, breed choice and suitability, house design and stocking density, outside runs and pasture management, feeding issues (in particular, the ban on the use of synthetic amino acids), cereal production , manure usage , marketing, economics, pullet rearing and organic research are reported more fully in the attached Scientific Report.
There is a more comprehensive summary at the start of the main report.