July 11, 2005
Standards Information Service
International Trade Division
Economic Affairs Bureau
Ministry of Foreign Affairs
2-2-1 Kasumigaseki, Chiyoda-ku
Tokyo 100-8919 Japan
RE: Draft Revision of JAS for organic agricultural products and processed foods (WTO: G/TBT/N/JPN/143)
These comments are submitted on behalf of the Organic Trade Association (OTA.) The Organic Trade Association represents 1600 businesses in the United States and Canada directly engaged in organic agricultural production, processing, distribution and sales. I would like to thank the Japan Ministry of Agriculture, Forestry and Fisheries (MAFF) for these improvements and clarifications of Japan Agricultural Standard (JAS) for organic agricultural products and processed foods. Although the draft revisions do not appear to create any significant additional Technical Barriers to Trade for US organic products exported to Japan, there are some statements and references, as well as missing sections that may be potential Technical Barriers to Trade.
Of most importance is the absence of criteria used to determine the materials listed in the Tables for both organic agricultural products and processed foods. Without such criteria it is difficult to understand how the materials listed in the Tables were determined. For instance, are the materials included or excluded from the Tables based on organic principles or justifiable reasons of environmental concern? Without this information, the determination of the materials included or excluded from the Tables may be Technical Barriers to Trade.
Specific comments on JAS of Organic Agricultural Products:
- Article 4: Criteria of Production Methods, Manuring Practice in Fields: The criteria states that “…in cases where the soil fertility cannot be maintained by methods…(cited above)…only fertilizers and soil conditioners listed in attached Table 1 may be used.” The criterion does not contain any parameters for determining “cannot be maintained”.
- The terms “slag”, “mixed crude drug extract”, “chlorella extract” and “lentinus edodes mycelium extract liquid” in the Tables are not easily understood and need further clarifications or definitions.
- Table 1: Fertilizers and soil conditioner, which can be used in only the case where the soil fertility cannot be maintained and enhanced with substances above. The explanation provided is difficult to understand and therefore to determine how to comply and if this would be a Technical Barrier to Trade.
Specific comments on JAS of Organic Agricultural Product Processed Foods
- The terms “slag”, “perfume”, and “extract from chlorella” in the Tables are not easily understood and need further clarifications or definitions.
- Although Potassium Carbonate is listed in Table 1, Potassium Bicarbonate is not included. OTA requests that MAFF consider the inclusion of Potassium Bicarbonate because of its similar structure, use and safety or provide an explanation for the exclusion of Potassium Bicarbonate.
Katherine DiMatteoExecutive Director