EURO COOP is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 15 of the 25 EU Member States and in 2 EU Candidate Countries,. Created in 1957, EURO COOP today represents over 3,200 local or regional co-operatives, membership of which amounts to 22 million consumers in Europe.

EURO COOP welcomes the European Commission Communication: "European Action Plan for Organic Food and Farming" (COM (2004) 415). EURO COOP believes that organic products are an important and efficient tool towards achieving sustainable development for the future.

However, EURO COOP would like to stress that the market forces alone cannot overcome all the obstacles as long as organic production is too small to be part of the conventional production supply chain. It is therefore necessary to increase organic production to an optimal level by facilitating the development of the market. EURO COOP believes that the Commission Action Plan can contribute to this.

EURO COOP proposes that the Action Plan also addresses how public services can contribute to the process in terms of public procurement, and public support for organic farming and innovative projects on ecology. EURO COOP believes that a yearly evaluation of the Action Plan should take place in order to indicate Member States' implementation of the Plan and to see if any adaptations are needed. The yearly evaluation should not only be done by the Commission but also by the individual Member States themselves.

Furthermore, EURO COOP recommends that the Commission evaluates the impact of the organic farming regulation (EEC) No 2092/91 on the Common Agricultural Policy (CAP) in order to establish guiding principles to further develop organic production. A revision of the organic farming regulation should take place at the same time as the revision of the CAP in 2007 in order for organic agriculture to play a more important role in the future CAP. EURO COOP believes that it would be important to address, in particular, problems related to the environment and health, small and big scale production, and raw versus processed and synthetic products.

In terms of the actions outlined in the Action Plan, EURO COOP has the following comments to those where we believe particular priority should be given.

Action 1

EURO COOP can only welcome and strongly support the launch of a multi-annual EU-wide information and promotion campaign to inform consumers, public institutions' canteens, schools and other key actors in the food chain, such as retailers and food industry, about the merits of organic farming, especially its environmental benefits, and to increase consumer awareness and recognition of organic products, including recognition of the EU logo. In particular, there is a need to increase overall knowledge of organic production's environmental benefits. Consumers need information about organic products in order to be able to make an informed choice in favour of sustainable consumption.

In the long run, EURO COOP believes that the most appropriate way forward would be to introduce a price policy that takes account of a product's negative environmental impact, so that consumers see the true price and can choose accordingly.

Action 2

EURO COOP finds it a good initiative but would like to know who is to establish and maintain the Internet database. EURO COOP suggests that the action is linked to Action 20.

Action 4

Although EURO COOP agrees that it is important to support organic producers and producer organisations, this should be done with some caution in order to avoid distortions of competition. Since there have been negative examples in the past in some EU Member States in the field of conventional agriculture.

Action 6

EURO COOP fully supports the recommendations that Member States should make full use within their rural development programmes of the instruments available to support organic farming, for example by developing national or regional Action Plans focussing on, among others, stimulating the demand side, and training and education for all operators in organic farming, covering production, processing and marketing. EURO COOP believes that the last action point regarding targeting organic farming as the preferred management option in environmentally sensitive areas is a very important one, and should therefore be moved up on the list of action points.

Action 7

EURO COOP proposes that processing measures should also be included as part of the research.

Action 8

EURO COOP would welcome a thorough discussion on the definition of organic production's basic principles, and not only on organic agriculture as suggested. EURO COOP should be happy to contribute to such a discussion given our experiences as consumer co-operatives.

Action 10

EURO COOP agrees that the standards for organic agriculture should be completed and further harmonised as proposed. EURO COOP suggests that the last action point concerning the need for improving standards relating to the environment should be linked to Action 6.

Action 11

EURO COOP should like to offer its expertise as consumer co-operatives to the independent expert panel for technical advice that is to be established. EURO COOP would therefore welcome further information about when and how the expert panel is to be established.

Action 12

In respect of GMOs (genetically modified organisms), EURO COOP is concerned about the difficulties maintaining organic products' integrity when it comes to co-existence. It is not acceptable that organic products should be penalised by the costs that could arise elsewhere along the supply chain. Contamination is a real threat; it is therefore necessary to establish procedures and financing in order to avoid organic production being hampered in this way.

Action 13

EURO COOP welcomes the possibility to develop the inspection systems in order not to increase the costs but still to focus on maintaining the level of security for the consumer.

Action 17

EURO COOP would caution against this action leading to a European body. Rather, EURO COOP recommends building on what already exists in order to maximise efficiency and effectiveness.

Action 19 and 20

EURO COOP welcomes the intention to facilitate the trade of organic products from third countries and the work on global harmonisation, where the IFOAM standards could serve as a good basis.