No

Issue

Text

1

Aims

Define the conditions, under which wild collection operations can be certified as "organic", according to (EEC) 2092/91, NOP, and JAS.

2

Background

The above-mentioned regulations on organic farming include the possibility of certifying wild crafting activities of plants and mushrooms. Especially in (Central-) Eastern Europe, the Balkans, and Russia, but also in other parts of the world. We believe that certification of these activities allows, on the one hand, the organic industry to purchase raw materials that would otherwise not be available from organic sources, and on the other hand gives producers in the source countries access to premium markets.

Unfortunately, standards of the above-mentioned regulations, regarding wild crafting, are not very specific. For this reason, we have decided to establish our own policy.

3

Normative framework

EU-Regulation

Annex I A. 4

The collection of edible plants and parts thereof, growing naturally in natural areas, forests and agricultural areas, is considered an organic production method provided that:

•     Those areas have received no treatments with products other than those referred to in Annex II for a period of three years before the collection.

•     The collection does not affect the stability of the natural habitat or the main­tenance of the species in the collection area.

Annex III A.1

The full description of the unit referred to under point 3 of the General Provisions of this Annex must

•     Be drawn up even where the producer limits his activity to the collection of wild plants,

•     Show the storage and production premises and land parcels and/or collection areas and, where applicable, premises where certain processing and/or packaging operations take place and

•     Specify the date of the last application on the parcels and/or collection areas concerned of products, the use of which is not compatible with Article 6 (1) (b).

•     In case of collection of wild plants, the practical measures referred to under point 3 of the General Provisions of this Annex must include the guarantees given by third parties which the producer can provide to ensure that the provisions of Annex I, section A, point 4, are complied with.

NOP

§ 205.207 Wild-crop harvesting practice standard.

(a) Any area from which a wild crop that is intended to be sold, labelled, or represented as organic is harvested must have had no prohibited substance, as set forth in § 205.600, applied to it for a period of 3 years immedi­ately preceding the harvest of the wild crop.

(b) A wild-crop must be harvested in a manner that ensures that such harvesting or gathering will not be destructive to the environment and will sustain the growth and production of the wild crop.

JAS

Notification 59, Art. 2.2:

In collection fields (…for collecting the … products growing spontaneously…), to collect the … product by such methods as affecting no damage for preserving the ecosystem…

4

Terms, clarifi­cations, ab­breviations

•       Wild or natural: Plants and mushrooms that grow spontaneously on agricultural land (segetal flora and fungus population) and are not taken care of (no weeding, transplanting, etc.) can be considered as "wild" or "natural" and thus wild crafted. Plants, that are transplanted or otherwise taken care of, should not be considered among wild collection, but rather in the category of low input fruit orchards (German: "Streuobst").

5

Policy

5.1

Areas, which can (not) be certified

5.1.1

Collection from farmland

·         In case, that products from farmland can be considered as wild crafted (see 4), it must be assured that no fertilisers or plant protection agents, that are not allowed in organic farming, have been applied on the respective plots during the last three years. This may be obvious in the case of remote rural areas, where farmers don't have means to buy such products. On grassland with a high biodiversity, high population of legumes and low productivity, it is obvious that no nitrogen fertilisers or herbicides have been applied. Nevertheless, it should be taken into account, that even in such remote areas, farmers often apply pesticides on certain crops (e.g. potatoes, vegetables, fruits).

·         If separation between wild crafted products from organic (or low input) and conventionally managed plots cannot be assured, the respective product cannot be certified. This is, e.g., often the case for typical weeds that may be collected from cropping areas (like Fumaria officinalis, Viola tricolor or Equisetum arvense, under European conditions) or from grassland (like Taraxacum offici­nalis).

5.1.2

Collection close to farm­land

·         Certified organic wild products must not be harvested from field margins of con­ventionally managed crops, where pesticides are applied. This applies, e.g., for hedgerows along fields (Rosa canina, Prunus spinosus, etc.). As a general rule, a distance of at least 20 meters between this kind of crops and collection places must be maintained. 50 meters must be considered in the case of fruit orchards, where high-pressure sprayers are used. These dis­tan­ces can differ, according to spraying intensity, main wind direction and equip­ment used.

5.1.3

Forest areas

·         Collection can take place in forest areas, where no applications of forest insecti­cides and herbicides have taken place during the previous three years.

·         In case that some woodland inside the collection area has received such appli­cations, the operator must establish a plausible system to exclude collection from such places. Usually, this system consists in excluding from purchase all collection points within a 10 km distance from the treated area (in regions where collectors do not have cars) or 20 km (where some of the collectors do have cars). In case that collectors are paid higher prices for certified products, these distances have to be considerably longer.

5.1.4

Polluted areas

·         Certified organic wild products must not be collected from regions with a high general level of environmental pollution, from industry, traffic, mining, or nu­clear facilities. This can in most cases be assessed by the inspector through the geographical location of the collection area, but may in some cases re­quire additional research, e.g. on heavy metal residues, persistent organic pollutants (POPs, like e.g. DDT or PCB) or radiation levels of soils and/or plant or mushroom samples. Certain areas may be excluded from certification for such reasons.

·         As a general rule, organic products must not be collected:

o      Inside urban areas.

o      Close to roads, according to the following scheme:

Vehicles per 5 minutes

< 3

3 – 15

16 – 50

51 – 100

> 100

Distance to be kept (m)

5

25

50

100

200

Along dust roads: as far as dust is visible on plants.

o         In a 5 km circle around air polluting industrial centres and mines.

o         In a 50 km circle around nuclear facilities.

o         20 m from railways.

o         20 to 100 m from litter dumps, according to the size of the dump.

5.2

Sustainability, nature protection

5.2.1

Sustainability

·         All operators dealing with potentially "critical" species concerning sustainability must do some kind of resource assessment, in order to establish maximum har­vest quantities. Methods and results of the resource assessment must be docu­mented. Local companies often tend to see a lower risk of over collection, as compared to external certifiers. In case of disagreement, CERES defines, for which species the resource assessment is required.

·         In some cases, in-depth research may be required for assessment of maxi­mum harvest quantities. It must be taken into account, e.g., that not only vegetative, but also sexual reproduction of plants and mushrooms is neces­sary, to assure the level of intraspecific biodiversity required for the species' survival. Assessment by local scientific institutes is very helpful in these cases, but double-checking through international experts may be requested sometimes.

·         Rules on good collection practice (GCP, see 5.3) must include clear guidelines concerning sustainability of collection and nature protection. For each species, maximum harvest quantities and sustainable harvesting techniques must be de­fined in these rules.

·         As a general rule, not more than:

o      60% of flowers and leaves

o      70% of fruits

o      20% of roots or barks

in the respective region must be collected. This refers not only to the region as such, but also to each single collection place. For example, care must be taken that not more than 60% of flowers at a given place are collected, when local in­sect populations during a certain period of the year rely strongly on a single species (e.g. Sambucus).

·         For some plants considered as "ecological weeds", this percentage can be much higher. This is especially the case for neophytes (exotic species), but also for some native species, which's populations tend to increase due to hu­man intervention (e.g. Urtica dioica in the European context).

·         Plants or mushrooms mentioned in national or international red lists as endan­gered species for the respective region must not be collected at all.

·         Collectors must not use scoops for collection of blueberries, lingonberries and similar wild fruits. As far as possible, harvesting should be limited to the part of the plant, which is really collected (no cutting of major tree branches for col­lection of Tilia flowers, no destruction of trees for Pinus kernel collection, to mention two examples).

5.2.2

Damage to the environ­ment

·         Collectors must not leave inorganic garbage in the collection areas.

·         The certificate holder is responsible, that collectors don't contribute to forest fires and other kinds of environmental damage. It must be safeguarded, that sensible animal species are not disturbed, especially during their breeding pe­riods, e.g. through excessive and long lasting noise.

5.3

Training and control procedures

5.3.1

Good collection rules and training

·         The operator must establish clear rules for good collection practice, which contain all relevant points of the present document, focussing on the issues, which are really important under the respective local circumstances. Usually, particular rules for each species should be established.

·         These rules must be written in a way, which is easily understandable for collectors, and handed out to all of them.

·         Collectors must receive practical training.

5.3.2

Internal con­trol

·         Collectors often:

o         Do not benefit directly from certification

o         Have only a loose relationship with the company that buys the products

o         Have only a low level of awareness of rules of GCP.

For this reason, we can usually not assume that they will voluntarily follow the established rules, and must have a stricter control, as compared to farming or processing units.

·         Since external inspections in most cases take place only once a year, the certified operator must take care of a permanent supervision of the collectors.

o         The easiest way to safeguard this, is collection in groups, which are directly organised and accompanied by the responsible company.

Otherwise, one or several persons on behalf of the operator must visit regularly the collectors in the field, to supervise fulfilment of rules on GCP, and standards established in this policy. These visits must be documented in simple forms (see Internal Inspection Report Wild Collection). Frequency of these visits will be established on a case-to-case basis, depending on the collected species, type of landscape, and level of collectors' training.

5.3.3

External con­trol of collec­tion sites

·         CERES inspectors must visit a certain number of collecting sites, according to the following scheme:

y = r * vx   

(y = collection sites visited by our inspector,

 r = risk factor,

 x = total number of collection sites).

The minimum number of collection sites to be visited is 5.

·         The risk factor “r” varies from 1 to 4, according to:

o      Number of collected species, especially "critical" species in terms of sustain­able use

o      Collectors' training

o      Type of landscape

o      Quality of documentation

o      Quality of internal control system

o      Sources of pollution