Last Rounds for Organic Heterogeneous Material (“OHM”)
While the lead for the Organic Regulation in the European Commission is with the Directorate General for Agriculture (DG AGRI, Unit Organic), the technical work on the new notification regime for the marketing of OHM is done by Directorate General for Health and Food Safety (DG SANTE, Unit Plant Health).
The Expert Group on Organics which negotiates the Delegated Act will meet virtually on the 15th June 2020, and discuss the outcome of the “InterService Consultation”, i.e. the feedback mechanism between the different Directorate Generals of the European Commission. There is thus very little time left to influence the content of the Delegated Act carving out the new notification regime, which contains positive aspects, but maintains quite a restrictive approach to the description and definition of OHM (especially with regards to historical material that needs to have been gone through on-farm management for at least six generations in different regions), and imposes burdensome maintenance obligations, amongst others.