PuraNatura Foundation Opinion on EGTOP Greenhouse Final Report

Some observations on EGTOP Final Report

Organic Greenhouse Production

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The inclusive Organic

‘Kenelm Chillingly asks, "Does it not prove that no man, however wise, is a good judge of his own case? Now, your son's case is really your case —- you see it through the medium of your likings and dislikings, and insist upon forcing a square peg into a round hole, because in a round hole you, being a round peg, feel tight and comfortable.

Now I call that irrational.”

”The farmer responded, "I don't see why my son has any right to fancy himself a square peg ... when his father, and his grandfather, and his great-grandfather, have been round pegs; and it is agin' nature for any creature not to take after its own kind.’

—Edward Bulwer Lytton, Kenelm Chillingly, His Adventures and Opinions 1873

Our opinion on EGTOP Final Report

A good body of work, but only half work as containerized cultivation of adult plants is not yet considered. Organic vegetables grown in & containers and substrates are valued highly by the majority of “organic” customers and this production method is accepted by organic growers around the world. Thanks to equivalency agreements European consumers already enjoy this type of veggies graced with , the organic leaf, and not just originating from Nordic European countries.

The wealth of knowledge and expertise of EGTOP experts should be used for technical and scientific input for robust regulations that include containerized (grow bag) cultivation of adult plants as well.

Our opinion on EGTOP Final Report

The EGTOP subgroup valiantly but misguidedly tries to force a square peg in a round hole with its political “adult-plant-roots-can-grow-into-the-subsoil” requirement without a technical rationale.

Its Final Report –if turned into regulation- leads to convoluted, unenforceable regulation at best; in the hands of the less scrupulous to environmental damage and loss of consumer trust at worst.

The Group’s primary requirement will also exclude potential organic greenhouse operators in colder, darker European metropolitan areas where ample, affordable space is hard to find. It will further increase costs, excluding more customers and may be bad for good business.

The ‘square peg’ being greenhouse cultivation, with its technical inputs of money, glass, aluminum, plastics and its intensified cultivation.

The ‘round hole’ maintaining a cosy pastoral image and a belief that processes within in a greenhouse can be fully ‘natural’, despite structures and technical systems designed specifically to keep “nature” out...

(No worries, involved vegetable lovers understand technical challenges!)

Pathways for European Regulation

• Prohibit organic cultivation in any permanent structure, with or without heating, covered by glass or plastic or other material that lets daylight through, in which crops are cultivated, and prohibit seedlings and transplants grown in growing media.

or• No specific greenhouse regulation at all, just a clear,

unambiguous interpretation of the “hydroponics”-definition throughout the European Union

or• Offer growers the regulatory freedom of choice to physically

protect subsoil and groundwater under the greenhouse and not just the crops in it.


1. Prohibit organic cultivation in any permanent structure, with or without heating, covered by glass or plastic or other material that lets daylight through, in which crops are cultivated.

This because this type of cultivation is not respecting nature’s systems and cycles’.

EGTOP: “Greenhouse production extends the growing season for crop production and allows production in regions where outdoor cropping is not normally possible. While this is not entirely consistent with Art. 3(a)(i) of Reg. 834/2007 (‘respect nature's systems and cycles’), greenhouse production is an accepted part of organic farming.”

It is possible to be a little bit pregnant…


1. Prohibit organic cultivation in any permanent structure.

EGTOP: “Excessive increases in production intensity threaten the sustainability of greenhouse production, and this is also true for some organic greenhouse productions. The Group is therefore concerned about this trend and recommends a more efficient use of external inputs to maintain the public trust in the sustainability of organic greenhouse production. Organic greenhouse production should be consistent with the organic principles.”

“…a more efficient use? PuraNatura believes that the most efficient use of external inputs (sustainable intensification) must be mandatory!


2. No specific greenhouse regulation at all, just a clear, unambiguous interpretation of the “hydroponics”-definition of 889/2008 title I Art 2 g) throughout the European Union, or an additional definition of what is exactly meant by soil, including arrangements for seedlings and transplants in growing media.

This pathway speaks for itself and it may already be considered in the General Review by the European Commission of the European policy on organic agriculture and its subsequent Roadmap.


3. Offer growers the regulatory freedom of choice to physically protect subsoil and groundwater under the greenhouse and not just the crops in it, and accept –regulatory- seedlings and transplants to be grown in proper growing media.

This pathway may require or a new Mandate to the EGTOP sub group; a revised Final Report, or steps by the EC.

Some suggestions:

Novel organic greenhouse regulation that:

1. Keeps current organic equivalence agreements in mind;

2. Includes containerized substrate cultivation in its scope;

3. Adheres to Smart Regulation for Europe;

4. Uses the wealth of knowledge of EGTOP and other experts.

1. Keep organic equivalence agreements in mind

European and North American Organic regulation has a bearing on producers and consumers worldwide. It also influences other governments and last but not least- properly regulated organic practices will positively influence conventional practices.

European regulations must therefore not be decided upon in “splendid isolation”, especially not from our equivalency partners.

Organic Europe is not an island.Source FIBL

1. Keep organic equivalence agreements in mind

Because of novel and empirical scientific insights and evolving societal needs equivalent systems tend to converge over time. EGTOP suggestions –if turned into law- may cause current equivalent systems to diverge. We do not know if that is “good” or “bad”, but they will diverge.

We can learn from our Equivalency Partners; set examples and together we can make organic a truly relevant sector for the have less’, not just a niche market for the have mores.

1. Keep organic equivalence agreements in mind Transatlantic solutions?

The Final Report does not refer to Canadian or American regulations. Yet we can learn from the advice of the American National Organic Standards Board on January 23, 2010 to the National Organic Program exactly on some issues in the Mandate:

Where EGTOP asked: When should growing plants in substrate be authorized?- it answered in four convoluted paragraphs- most lacking technical arguments.

The NOSB asked:


“Should container culture based growing media (typically utilized in greenhouse systems) that are predominately compost and compostable plant materials be considered ‘soil’?

It answered:

“Since all typical soil dwelling organisms, such as earthworms, protozoa, fungi, bacteria, actinomycetes, etc. can thrive in a properly designed compost based growing media, producing the beneficial symbiotic ecological relationships found in soil, such growing media should be rightfully considered soil”


“such growing media should be rightfully considered soil” brings containerized growing media in line with both the spirit and letter of current European organic legislation and is a constructive basis of new regulations as well.

834/2007/EC article 8: The development of organic production should be facilitated further, in particular by fostering the use of new techniques and substances better suited to organic production.

834/2007/EC article 12: Organic plant production should contribute to maintaining and enhancing soil fertility as well as to preventing soil erosion.


The NOSB also thought about the role of the organic farmer:

The organic farming method derives its name from the practice of maintaining or improving the organic matter (carbon containing) content of farm soil… based on the importance of the organic matter to the living organisms that inhabit soils, particularly for its positive influence on proliferation of diverse populations of organisms that interact in a beneficial way with plant roots. In practice, the organic farmer is not just a tiller of the soil, but a steward of the soil ecology on the farm..

(including stewardship of containerized soil and growing media!)


With all this the National Organics Standards Board advised the National Organic Program simply to add guidelines and standards for § 205.209 Terrestrial Plants in Containers and Enclosures.

The dissenting opinion of CCOF California Certified Organic Farmers on this subject is also relevant to the discussion in Europe. It wonders if greenhouses need specific regulations at all and makes a case for even more sophisticated practices.

We advise EGTOP to learn from the discussions and dialogues in North America and elsewhere.

2. Include containerized cultivation in regulation

This type of cultivation for adult plants in grow bags can look like:


• Regulators can have stricter and enforceable environmental demands towards this than towards root-in-subsoil cultivation;

• Makes organic greenhouse practice accessible to more growers in urban/metropolitan areas, reaching more people;

• Reduces harvest risks, reduces overhead-costs, increases availability of more local product and attracts new customers;

• Drives innovation towards sustainable intensification, plant resilience and resource efficiency.


• Reduces “parallel” production as organic greenhouses may become a more robust stand alone operation.

• Harmonizes current very different “conversion” periods

• Easier to measure environmental performance of greenhouse cultivation;

• Upon inclusion of containerized cultivation sector can take responsibility for authorisation of substances and techniques.

3. Adhere to Smart Regulation for Europe

Adherence to findings of COM (2010) 543 on “Smart Regulation in the European Union”

Findings that translate into: Regulations that are necessary and effective; coherent; feasible and maintainable; simple, clear and accessible; legitimate; permanently relevant and with the necessary support and following consultation.

The Final Report lacks several of these traits.

3. Adhere to Smart Regulation for Europe

Smart regulation is also effective and carefully considered. It contributes to social prosperity and welfare and achieves the objective that it sets out to achieve at the lowest possible social cost and minimises undesired side effects.

The Final report did take this insufficiently into consideration when inserting its socio-economic paragraphs. That can be remedied with a new Mandate.

4. Use the knowledge of EGTOP experts or continue the European quagmire?

EGTOP experts can contribute significantly to the development of all kinds of growing media and cultivation techniques where roots of adult plants can not enter the subsoil. Greenhouse techniques for growers in all their geographical & climatological diversity.

We reviewed the line-up of EGTOP experts and are confident that when the Commission instructs EGTOP to come up with regulations for containerized cultivation of adult plants too, many of the experts can provide valuable insights that can help make the exclusive good into an inclusive better.

Example of promising research into growing media for containerized production, 25l/plant, from Kuwait.

Best way to lift…

Properly regulated greenhouse cultivation lifts the entire organic market into higher relevance.

(And…. accept it for what it is!)

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PuraNatura Foundation Opinion on EGTOP Greenhouse Final Report

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