PuraNatura Foundation promotes sustainable organic greenhouse practices towards a more inclusive organic. This presentation replaces an earlier one thanks to dialogue with other interested stakeholders.

1. Some observations on
EGTOP Final Report
Organic Greenhouse Production
The PuraNatura project is co-financed by
the European Regional Development Fund
v5

3. „Kenelm Chillingly asks, "Does it not prove that no man,
however wise, is a good judge of his own case? Now, your
son's case is really your case —- you see it through the
medium of your likings and dislikings, and insist upon
forcing a square peg into a round hole, because in a round
hole you, being a round peg, feel tight and comfortable.
Now I call that irrational.”

4. ”The farmer responded, "I don't see why my son has any
right to fancy himself a square peg ... when his father, and
his grandfather, and his great-grandfather, have been
round pegs; and it is agin' nature for any creature not to
take after its own kind.’
—Edward Bulwer Lytton, Kenelm Chillingly, His Adventures and Opinions 1873

5. Our opinion on EGTOP Final Report
A good body of work, but only half work as containerized
cultivation of adult plants is not yet considered. Organic vegetables
grown in
&
containers and substrates are valued highly by
the majority of “organic” customers and this production method is
accepted by organic growers around the world. Thanks to
equivalency agreements European consumers already enjoy this
type of veggies graced with
, the organic leaf, and not just
originating from Nordic European countries.
The wealth of knowledge and expertise of EGTOP experts should
be used for technical and scientific input for robust regulations that
include containerized (grow bag) cultivation of adult plants as well.

6. Our opinion on EGTOP Final Report
The EGTOP subgroup valiantly but misguidedly tries to force a
square peg in a round hole with its political “adult-plant-roots-cangrow-into-the-subsoil” requirement without a technical rationale.
Its Final Report –if turned into regulation- leads to convoluted,
unenforceable regulation at best; in the hands of the less scrupulous
to environmental damage and loss of consumer trust at worst.
The Group‟s primary requirement will also exclude potential organic
greenhouse operators in colder, darker European metropolitan areas
where ample, affordable space is hard to find. It will further increase
costs, excluding more customers and may be bad for good business.

7. The „square peg‟ being greenhouse cultivation, with its technical
inputs of money, glass, aluminum, plastics and its intensified
cultivation.

8. The „round hole‟ maintaining a cosy pastoral image and a belief
that processes within in a greenhouse can be fully „natural‟, despite
structures and technical systems designed specifically to keep
“nature” out...
(No worries, involved vegetable lovers understand technical challenges!)

9. Pathways for European Regulation
• Prohibit organic cultivation in any permanent structure, with or
without heating, covered by glass or plastic or other material
that lets daylight through, in which crops are cultivated, and
prohibit seedlings and transplants grown in growing media.
or
• No specific greenhouse regulation at all, just a clear,
unambiguous interpretation of the “hydroponics”-definition
throughout the European Union
or
• Offer growers the regulatory freedom of choice to physically
protect subsoil and groundwater under the greenhouse and
not just the crops in it.

10. Pathways for European Regulation
1. Prohibit organic cultivation in any permanent structure, with or
without heating, covered by glass or plastic or other material
that lets daylight through, in which crops are cultivated.
This because this type of cultivation is not respecting nature‟s
systems and cycles‟.
EGTOP: “Greenhouse production extends the growing season for crop production
and allows production in regions where outdoor cropping is not normally possible.
While this is not entirely consistent with Art. 3(a)(i) of Reg. 834/2007 (‘respect
nature's systems and cycles’), greenhouse production is an accepted part of
organic farming.”
It is possible to be a little bit pregnant…

11. Pathways for European Regulation
1. Prohibit organic cultivation in any permanent structure.
EGTOP: “Excessive increases in production intensity threaten the sustainability of
greenhouse production, and this is also true for some organic greenhouse
productions. The Group is therefore concerned about this trend and recommends
a more efficient use of external inputs to maintain the public trust in the
sustainability of organic greenhouse production. Organic greenhouse production
should be consistent with the organic principles.”
“…a more efficient use? PuraNatura believes that the most
efficient use of external inputs (sustainable intensification) must
be mandatory!

12. Pathways for European Regulation
2. No specific greenhouse regulation at all, just a clear,
unambiguous interpretation of the “hydroponics”-definition of
889/2008 title I Art 2 g) throughout the European Union, or an
additional definition of what is exactly meant by soil, including
arrangements for seedlings and transplants in growing media.
This pathway speaks for itself and it may already be considered
in the General Review by the European Commission of the
European policy on organic agriculture and its subsequent
Roadmap.

13. Pathways for European Regulation
3. Offer growers the regulatory freedom of choice to physically
protect subsoil and groundwater under the greenhouse and not
just the crops in it, and accept –regulatory- seedlings and
transplants to be grown in proper growing media.
This pathway may require or a new Mandate to the EGTOP sub
group; a revised Final Report, or steps by the EC.
Some suggestions:

14. Novel organic greenhouse regulation that:
1. Keeps current organic equivalence agreements in mind;
2. Includes containerized substrate cultivation in its scope;
3. Adheres to Smart Regulation for Europe;
4. Uses the wealth of knowledge of EGTOP and other experts.

15. 1. Keep organic equivalence agreements in mind
European and North American Organic regulation has a bearing
on producers and consumers worldwide. It also influences other
governments and last but not least- properly regulated organic
practices will positively influence conventional practices.
European regulations must therefore not be decided upon in
“splendid isolation”, especially not from our equivalency partners.

16. Organic Europe is not an island.
Source FIBL

17. 1. Keep organic equivalence agreements in mind
Because of novel and empirical scientific insights and evolving
societal needs equivalent systems tend to converge over time.
EGTOP suggestions –if turned into law- may cause current
equivalent systems to diverge. We do not know if that is “good”
or “bad”, but they will diverge.
We can learn from our Equivalency Partners; set examples and
together we can make organic a truly relevant sector for the have
less‟, not just a niche market for the have mores.

18. 1. Keep organic equivalence agreements in mind
Transatlantic solutions?
The Final Report does not refer to Canadian or American
regulations. Yet we can learn from the advice of the American
National Organic Standards Board on January 23, 2010 to the
National Organic Program exactly on some issues in the
Mandate:
Where EGTOP asked: When should growing plants in substrate
be authorized?- it answered in four convoluted paragraphs- most
lacking technical arguments.
The NOSB asked:

19. 1. Keep organic equivalence agreements in mind
Transatlantic solutions?
“Should container culture based growing media (typically utilized
in greenhouse systems) that are predominately compost and
compostable plant materials be considered „soil‟?
It answered:
“Since all typical soil dwelling organisms, such as earthworms,
protozoa, fungi, bacteria, actinomycetes, etc. can thrive in a
properly designed compost based growing media, producing the
beneficial symbiotic ecological relationships found in soil, such
growing media should be rightfully considered soil”

20. 1. Keep organic equivalence agreements in mind
Transatlantic solutions?
“such growing media should be rightfully considered soil”
brings containerized growing media in line with both the spirit and
letter of current European organic legislation and is a constructive
basis of new regulations as well.
834/2007/EC article 8: The development of organic production should
be facilitated further, in particular by fostering the use of new
techniques and substances better suited to organic production.
834/2007/EC article 12: Organic plant production should contribute
to maintaining and enhancing soil fertility as well as to preventing
soil erosion.

21. 1. Keep organic equivalence agreements in mind
Transatlantic solutions?
The NOSB also thought about the role of the organic farmer:
The organic farming method derives its name from the practice
of maintaining or improving the organic matter (carbon
containing) content of farm soil… based on the importance of the
organic matter to the living organisms that inhabit soils,
particularly for its positive influence on proliferation of diverse
populations of organisms that interact in a beneficial way with
plant roots. In practice, the organic farmer is not just a tiller
of the soil, but a steward of the soil ecology on the farm..
(including stewardship of containerized soil and growing media!)

22. 1. Keep organic equivalence agreements in mind
Transatlantic solutions?
With all this the National Organics Standards Board advised the
National Organic Program simply to add guidelines and
standards for § 205.209 Terrestrial Plants in Containers and
Enclosures.
The dissenting opinion of CCOF California Certified Organic
Farmers on this subject is also relevant to the discussion in
Europe. It wonders if greenhouses need specific regulations at
all and makes a case for even more sophisticated practices.
We advise EGTOP to learn from the discussions and dialogues
in North America and elsewhere.

23. 2. Include containerized cultivation in regulation
This type of cultivation for adult plants in grow bags can look like:

24. 2. Include containerized cultivation in regulation
• Regulators can have stricter and enforceable environmental
demands towards this than towards root-in-subsoil cultivation;
• Makes organic greenhouse practice accessible to more
growers in urban/metropolitan areas, reaching more people;
• Reduces harvest risks, reduces overhead-costs, increases
availability of more local product and attracts new customers;
• Drives innovation towards sustainable intensification, plant
resilience and resource efficiency.

25. 2. Include containerized cultivation in regulation
• Reduces “parallel” production as organic greenhouses may
become a more robust stand alone operation.
• Harmonizes current very different “conversion” periods
• Easier to measure environmental performance of greenhouse
cultivation;
• Upon inclusion of containerized cultivation sector can take
responsibility for authorisation of substances and techniques.

26. 3. Adhere to Smart Regulation for Europe
Adherence to findings of COM (2010) 543 on “Smart Regulation
in the European Union”
Findings that translate into: Regulations that are necessary and
effective; coherent; feasible and maintainable; simple, clear and
accessible; legitimate; permanently relevant and with the
necessary support and following consultation.
The Final Report lacks several of these traits.

27. 3. Adhere to Smart Regulation for Europe
Smart regulation is also effective and carefully considered. It
contributes to social prosperity and welfare and achieves the
objective that it sets out to achieve at the lowest possible social
cost and minimises undesired side effects.
The Final report did take this insufficiently into consideration
when inserting its socio-economic paragraphs. That can be
remedied with a new Mandate.

28. 4. Use the knowledge of EGTOP experts or
continue the European quagmire?
EGTOP experts can contribute significantly to the development
of all kinds of growing media and cultivation techniques where
roots of adult plants can not enter the subsoil. Greenhouse
techniques for growers in all their geographical & climatological
diversity.
We reviewed the line-up of EGTOP experts and are confident
that when the Commission instructs EGTOP to come up with
regulations for containerized cultivation of adult plants too, many
of the experts can provide valuable insights that can help make
the exclusive good into an inclusive better.

29. Example of promising research into growing media for containerized production, 25l/plant, from Kuwait.

30. Properly regulated greenhouse cultivation lifts the
entire organic market into higher relevance.
(And…. accept it for what it is!)
Best way to lift…

31. About PuraNatura Foundation:
check out www.puranatura.tv or
http://tinyurl.com/from-exclusive-to-inclusive
The PuraNatura project is co-financed by
the European Regional Development Fund

32. Due to our extending
reach we will use
different logo‟s from
2014 onwards.