Hello Grace,
A few comments on your SANET statement:
What is the authority and what is the logic for not allowing an accredited
organic certifying agent to use their logo to indicate "performance standards"
other than the USDA/NOP?
Grace states:
"To characterize the requirement that products labeled as
*organic* comply with the USDA*s regulations as giving the agency a
*monopoly* on the word is idiotic, as is the claim that it would either limit
free speech rights or *criminalize dissent.* The preamble to the
proposed rule clearly states that individual producers or processors can
continue to make any truthful label claims they wish, and that any
accredited certifier can verify that these claims are accurate. Any
organization that wishes to establish *higher* standards for its members,
owners, or products can do that, and market this claim as it sees fit."
....... And then you accurately note: "Under the proposed regulations,
however, the USDA accredited certifier could not market its logo as a claim of
*no detectable pesticide residues* if that is not a requirement of the federal
organic program."
And as Grace states, the USDA/NOP wrote this in the Proposed Organic Rule
issued December, 1997:
§ 205.301 General requirements for accreditation states:
(b) A private person or governing State official accredited as a certifying
agent under this subpart may establish a seal, logo or other identifying mark
to be used by farms, wild crop harvesting operations, and handling operations
certified by the certifying agent to denote affiliation with the certifying
agent, Provided, That the certifying agent:
(2) Does not require as a condition of use of its identifying mark compliance
with any farming or handling requirements other than those provided for in the
Act and the regulations in this part.
On a second issue Grace is correct in the following statement.
The CFR 205 does not provide for a prohibition against "eco-labeling" or other
labels.
Grace states correctly:
"The so-called *eco-labeling* prohibition is also a case of
interpreting a request for public comment as an intent to do something
that nobody wants. The examples we gave of phrases that may
possibly imply that a product was organically produced was included so
that people would know what we were talking about, in hopes that they
would give us specific terms that should or should not be considered the
same as making an organic claim."
Best Regards,
Eric Kindberg, certified organic farmer