Background
The European Commission's action plan outlining the overall vision for the contribution of organic food and farming to the common agricultural policy in Europe was adopted in 2004, and an Expert Group for Technical Advice on Organic Production (EGTOP) was established in 2017 to advise on the authorisation of the use of products, substances and techniques in organic farming and processing.
Regulation 2018/848 on the organic production and labelling of organic food provides the Commission the authority to restrict or prohibit substances in cleaning and disinfection products used in the production and processing of organic food. According to Article 24 of the Regulation, chemicals for cleaning and disinfecting agents approved for organic production and processing should be listed in an annex to the Regulation. EGTOP has set of draft criteria for the incorporation of these substances in this 'positive list', and advises the Commission in taking the decisions related to Article 24 and its annex.
Substances for cleaning and disinfection of organic food and farming
A.I.S.E. published a first position paper in January 2021 on this positive list of authorised substances, and experts from the professional cleaning and hygiene sector of A.I.S.E. continue working to contribute to this list.
On 14 July 2021, A.I.S.E. together with the Association of Manufacturers and Formulators of Enzyme Products (AMFEP), jointly published a letter on the EGTOP draft report on the criteria for evaluation of products for cleaning and disinfection.
The Draft Report proposes that enzymes be listed as 'unwanted other components' for inclusion in the Commission Regulation. However, the organic food legislation contains certain criteria that enzymes specifically help to fulfill - these include the responsible use of energy, resources, and maintenance of water quality.
The role of enzymes
Enzymes have properties which allow them to work effectively in low concentration, at low temperatures, mild pH and minimising water use. In addition, these ingredients are readily biodegradable. A study on enzyme exposure created for REACH Chemical Safety Assessment showed that enzyme exposure to the environment is negligible.
The enzyme and the detergent industry have over 40 years of experience on the safety of enzymes. Much work has been taken to ensure the responsible use of these products in consumer and industrial products and mitigate any risks associated with the hazard classification. Enzymes have also been accepted within Ecolabel products, and thus it is proposed that enzymes also be derogated from the organic food regulation prohibition. The ban of these ingredients could in practice result in an inconsistency with the environmental goals of the organic food and farming legislation.
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