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Proposed Amendments to European Council Regulation on Organic Feed Sourcing

You may be aware that in October 2015 the EU proposed changing the law regarding sourcing of raw materials for organic livestock production.

We, at Hi Peak, disagree with the proposed amendments calling for 30% of feed used on organic pig and poultry farms must be sourced from within a radius of 150km of the organic farm.

This coming Tuesday (22nd March) there is a trilogue meeting wherein the Organic File will be discussed.

In advance of this meeting we have written to a number of MEPs (Members of the European Parliament) to voice our concerns and have also been in contact with the National Farmers’ Union on the issue.

We are inviting you to raise your own concerns by contacting your local MEP.

The NFU has prepared a letter that you can use to contact your local MEP.

Please find the details of the NFU’s draft letter by clicking here.

 

Hi Peak’s Position on the proposed Legislation change

Impact on Hi Peak Organic Feeds

A significant proportion of our business is dedicated to supplying organic pig and poultry producers. We are therefore extremely concerned by the proposed amendment which would require 30% of feed for pig and poultry to come from farm or be produced in cooperation with other organic farms established within a radius of 150 km of the farm itself. This is totally impractical as those sectors are largely reliant on supplied compound feed. Therefore, whilst the amendments call for 30% of feed to come from farm, or be produced within 150km of the farm, in reality it would relate to 100% of the feed.

Hi Peak is very centrally located for servicing the length and breadth of the UK with excellent transport links nearby. However in practical terms we simply could not service all of our customers within 150km of their farms. To do so, at least 9 organic certified mills would be needed to cover the country and if producers can only source feed from within 150km of their farm, they may be limited to sourcing from one mill, which would create an unfair trade restriction.

Contamination Risk

As stated, Hi Peak is a dedicated organic mill. Part of the decision to switch to a completely organic operation was based on the risk of contamination between organic and non-organic. If the change in Regulation goes ahead, more conventional mills will have to become certified, for the organic pig and poultry sectors to continue. As such, they will not be dedicated mills which could increase the risk of contamination, particularly where GM ingredients are being used on the conventional side of the business. Non-GM is an important component of the organic standard and so there is a requirement for feed to be tested to 0.01% contamination. It will therefore be very difficult for mills using both kinds of ingredients, to ensure that feed being sold to organic customers is not contaminated with GM, which would jeopardise the certification of both the animals and the land.

Ingredient Sourcing

As with all livestock, pig and poultry require a balanced diet, which meets their nutritional requirements in terms of animal health and welfare, as well as performance. Many of the ingredients currently used in pig and poultry feed are sourced outside of the UK, because there is simply not the range of organic crops grown locally that are needed to ensure a balanced diet, as the climatic and growing conditions of the UK do not favour the different kinds of protein needed in many livestock diets.

The two most essential amino acids (building blocks of proteins) needed in poultry diets are methionine and lysine. Without careful balance of these two amino acids, the birds will not thrive and will feather peck, which can lead to cannibalism. In conventional feed, synthetic amino acids are used to ensure a balance, but this is not allowed in organic farming and so we must resort to using a range of proteins to ensure we get the balance of methionine and lysine right. Therefore we import soya expeller, Palm Kernel expeller, rape expeller, sunflower expeller and rice protein. Unfortunately, none of these ingredients are available in the UK and some have to be brought in from as far away as India, China and Columbia. This is not ideal, but at the moment we have little choice.

We are very supportive of encouraging UK farmers to grow new and novel crops to improve the local content of feed, although unfortunately the UK organic arable sector remains small and does not appear to be showing much growth. In addition, most of the arable production in the UK is not located near the livestock regions.

The National Farmers’ Union are calling for a review of the EU organic feed market to be undertaken by 2020 to determine the viability of any feed proposals, as no consideration has been given to whether the feed market in each Member State can facilitate what is being proposed. We would support this approach.