AMS Should Require Handler Reporting on Organic Raisins:
Comments of the Organic Trade Association
on Docket Number FV01-989-2 PR
Federal Register, Tuesday, March 27, 2001, Vol. 66, No. 59, pp. 16621-24
Agricultural Marketing Service, USDA
Submitted by Tom Hutcheson,
Associate Policy Director
May 29, 2001
The Organic Trade Association (OTA) strongly supports requiring handlers to report to the Raisin Administrative Committee (RAC) information on acquisitions, shipments, and inventories of organic raisins.
Organic raisins have a substantially different market compared to conventionally grown raisins. They are produced differently and their pricing in the marketplace reflects the value consumers put on those production methods.
This means that demand for organic raisins can be rising at the same time demand for conventionally grown raisins is falling. Any limitations on the production of organic raisins, including set-asides, based on the demand for conventional raisins, is therefore unreasonable, and any information which can be collected towards the end of demonstrating the particulars of this situation are most welcome.
Collecting this information is of course only the first step in differentiating these two kinds of raisins in relation to the Federal marketing order for California raisins. When the information collected shows that there are indeed differences in pricing and volume, as OTA expects, the Federal marketing order should be revised to take this information into account. Two options are 1) to exempt organic raisins from the Federal marketing order and 2) to establish a marketing order solely for organic raisins, which OTA trusts would only be done with the full consent of the producers involved.
OTA believes that the small reporting burden placed on handlers of organic raisins will be more than worthwhile in the long run, as the information collected will allow USDA to demonstrate that organically-grown raisins have a substantially different market from conventionally-grown raisins. This in turn will allow handlers of organic raisins more flexibility in bringing their product to market.
OTA recommends that due to the new landscape of organic regulation caused by the establishment of a National Organic Program (NOP), that instead of limiting certification organizations to those “currently registered with the California Department of Food and Agriculture”, the certification organizations to be recognized be those “currently registered with the California Department of Food and Agriculture, or, after April 21, 2002, any certification organization accredited by the National Organic Program”. April 21, 2002, is the date on which NOP will announce the first round of USDA-accredited certification agents.
OTA greatly appreciates the flexibility demonstrated by AMS in proposing that organic raisins be separated through the mechanism of declaring them, for the purposes of this rule, a separate varietal type, but questions whether a further policy change might be useful which would allow organic commodities to be recognized by their production standard, rather than requiring this degree of flexibility in regulatory language. Likewise, the authority provided to the RAC under section 989.60(c) was not meant for the case of organic production, which has been recognized by AMS as a particular production method. OTA would like AMS to review its programs thoroughly so that organic production can be incorporated into these and similar programs as a new, well-defined production method, without having to stretch existing definitions or use special rules provided for the case of unforeseen circumstances.