Aims :

Define the conditions, under which wild collection operations can be certified as “organic”, according to NPOP, Govt. of India and National Organic Program of USDA and COS.

Background :

The above-mentioned regulations on organic farming include the possibility of certifying wild crafting activities of plants and mushrooms. We believe that certification of these activities allows, on the one hand, the organic industry to purchase raw materials that would otherwise not be available from organic sources, and on the other hand gives producers in the source countries access to premium markets.

Normative framework :

NPOP :

12.  INSPECTION AND CERTIFICATION OF WILD PRODUCTS

The responsible operator shall be dealt with as any other certified party. The operator shall issue instructions to the collectors, that at least:

• defines the area of collection
• informs them about the standards and other requirements for certification The collectors shall sign statements that they have followed the instructions. The operator shall have records of all collectors, and the quantities bought from each collector. The area of production shall be properly identified on appropriate maps, which shall be large and distinct enough to reduce the risk of mixing up with non-certified production. Any local agents (middlemen) must be properly contracted by the operator. The inspection regime shall, apart from normal inspection, visit to the operator and the facilities, including:
• interviews with the collectors.
• visit to an appropriate portion of the certified area.
• visits to and interviews of any local agents.
• interviews of landowners and other parties (environment agencies, NGOs etc.) supplying relevant information about the area of collection.

3.2.8  Collection of Non Cultivated Material of Plant Origin

General Principles

The act of collection should positively contribute to the maintenance of natural areas.

1.1.1.2  Recommendations

When harvesting or gathering the products, attention should be paid to maintenance and sustainability of the ecosystem.

Standards

3.2.8.1 :

Wild harvested products shall only be certified organic if derived from a stable and sustainable growing environment. Harvesting or gathering the product shall not exceed the sustainable yield of the ecosystem, or threaten the existence of plant or animal species.

3.2.8.2 :

Products can only be certified organic if derived from a clearly defined collecting area, which is not exposed to prohibited substances, and which is subject to inspection.

3.2.8.3 :

The collection area shall be at an appropriate distance from conventional farming,pollution and contamination.

3.2.8.4 :

The operator managing the harvesting or gathering of the products shall be clearly identified and be familiar with the collecting area in question.

NOP :

§ 205.207 Wild-crop harvesting practice standard.

a) Any area from which a wild crop that is intended to be sold, labelled, or represented as organic is harvested must have had no prohibited substance, as set forth in § 205.600, applied to it for a period of 3 years immediately preceding the harvest of the wild crop.

b) A wild-crop must be harvested in a manner that ensures that such har-vesting or gathering will not be destructive to the environment and will sustain the growth and production of the wild crop.

COS :

7.6.3 Wild products can only be deemed organic, in accordance with this standard, if they are harvested in relatively undisturbed or stable natural settings. A wild plant shall be harvested or picked in a way that promotes its growth and production and that does not destroy the environment.

7.6.2 The operator shall

a. draw up a detailed description of harvested areas and the history of compliance with this standard over the past three years,
b. draw up a description of harvest methods used,
c. propose protection measures for wild species that will prevent disturbance of the environment.

Terms, clarifications, abbreviations :

Wild or natural : Plants and mushrooms that grow spontaneously on agricul-tural land (segetal flora and fungus population) and are not taken care of (no planting, weeding, transplanting, etc.) can be considered as “wild” or “natural” and thus wild crafted. Plants, that are transplanted or otherwise taken care of, should not be considered among wild collection.

Policy :

Areas, which can (not) be certified:

Collection from farmland:

• In case, that products from farmland can be considered as wild crafted, it must be assured that no fertilisers or plant protection agents, that are not allowed in organic farming, have been applied on the respective plots during the last three years. This may be obvious in the case of remote rural areas, where farmers don’t have means to buy such products. On grassland with a high biodiversity, high population of legumes and low productivity, it is obvious that no nitrogen fertilisers or herbicides have been applied. Nevertheless, it should be taken into account, that even in such remote areas, farmers often apply pesticides on certain crops (e.g. potatoes, vegetables, fruits).
• If separation between wild crafted products from organic (or low input) and conventionally managed plots cannot be assured, the respective product cannot be certified.

Collection close to farm land:

• Certified organic wild products must not be harvested from field margins of conventionally managed crops, where pesticides are applied. This applies, e.g., for hedgerows along fields. As a general rule, a distance of at least 20 meters between this kind of crops and collection places must be maintained. 50 meters must be considered in the case of fruit orchards, where high-pressure sprayers are used. These distances can differ, according to spraying intensity, main wind direction and equipment used.

Forest areas:

• Collection can take place in forest areas, where no applications of forest insecticides and herbicides have taken place during the previous three years.
• In case that some woodland inside the collection area has received such appli-cations, the operator must establish a plausible system to exclude collection from such places. Usually, this system consists in excluding from purchase all collection points within a 10 km distance from the treated area (in regions where collectors do not have cars) or 20 km (where some of the collectors do have cars). In case that collector are paid higher prices for certified products, these distances have to be considerably longer.

Polluted areas:

• Certified organic wild products must not be collected from regions with a high general level of environmental pollution, from industry, traffic, mining, or nu-clear facilities. This can in most cases be assessed by the inspector through the geographical location of the collection area, but may in some cases require additional research, e.g. on heavy metal residues, persistent organic pollutants (like e.g. DDT or PCB) or radiation levels of soils and/or plant or mushroom samples. Certain areas may be excluded from certification for such reasons.

• As a general rule, organic products must not be collected:

1. Inside urban areas.
2. Close to roads, according to the following scheme:

Vehicles per 5 minutes	< 3	3 – 15	6 – 50	51 – 100	> 100
Distance to be kept (m)	5	25	50	100	200

Along dust roads: as far as dust is visible on plants.

1. In a 5 km circle around air polluting industrial centers and mines.
2. In a 50 km circle around nuclear facilities.
3. 20 m from railways.
4. 20 to 100 m from litter dumps, according to the size of the dump.

• For areas, which have been affected by nuclear fallout, we have established the following rule: Wild harvested products may only be sold as organic, provided their accumulated radioactive level for Cs 134 plus Cs 137 remains below 370 Bq/kg, which is the maximum established by Regulation (EC) 616 / 2000 for baby food (as opposed to 600 Bq/kg for foodstuff in general). In case of operations, which sometimes or frequently reach levels close to this figure, the organic condition can only be approved lot wise. ADITI may take samples for cross checking. This rule applies especially for those regions, which have been affected by the Chernobyl accident of 1986.

Sustainability, nature protection :

Sustainability:

• All operators dealing with potentially “critical” species concerning sustainability must do some kind of resource assessment, in order to establish maximum harvest quantities. Methods and results of the resource assessment must be documented. Local companies often tend to see a lower risk of over collection, as compared to external certifiers. In case of disagreement, ADITI defines, for which species the resource assessment is required.
• In some cases, in-depth research may be required for assessment of maximum harvest quantities. It must be taken into account, e.g., that not only vegetative, but also sexual reproduction of plants and mushrooms is necessary, to assure the level of intraspecific biodiversity required for the species’ survival. Assessment by local scientific institutes is very helpful in these cases, but double-checking through international experts may be requested sometimes.
• Rules on good collection practice must include clear guidelines concerning sustainability of collection and nature protection. For each species, maximum harvest quantities and sustainable harvesting techniques must be defined in these rules.
• As a general rule, not more than:
  o 60% of flowers and leaves
  o 70% of fruits
  o 20% of roots or barks
  in the respective region must be collected. This refers not only to the region as such, but also to each single collection place. For example, care must be taken that not more than 60% of flowers at a given place are collected, when local insect populations during a certain period of the year rely strongly on a single species.
• For some plants considered as “ecological weeds”, this percentage can be much higher. This is especially the case for neophytes (exotic species), but also for some native species, which’s populations tend to increase due to human intervention.
• Plants or mushrooms mentioned in national or international red lists as endan-gered species for the respective region must not be collected at all.
• Collectors must not use scoops for collection of blueberries, lingonberries and similar wild fruits. As far as possible, harvesting should be limited to the part of the plant, which is really collected (no cutting of major tree branches for collection of Tilia flowers, no destruction of trees for Pinus kernel collection, to mention two examples).

Damage to the environment :

• Collectors must not leave inorganic garbage in the collection areas.
• The certificate holder is responsible, that collectors don’t contribute to forest fires and other kinds of environmental damage. It must be safeguarded, that sensible animal species are not disturbed, especially during their breeding pe-riods, e.g. through excessive and long lasting noise.

Training and control procedures :

Good collection rules and training :

• The operator must establish clear rules for good collection practice, which con-tain all relevant points of the present document, focussing on the issues, which are really important under the respective local circumstances. Usually, particular rules for each species should be established.
• These rules must be written in a way, which is easily understandable for collectors, and handed out to all of them.
• Collectors must receive practical training.

Internal control :

• Collectors often:

o Do not benefit directly from certification
o Have only a loose relationship with the company that buys the products
o Have only a low level of awareness of rules of GCP.

For this reason, we can usually not assume that they will voluntarily follow the established rules, and must have a stricter control, as compared to farming or processing units.

• Since external inspections in most cases take place only once a year, the certified operator must take care of a permanent supervision of the collectors.

o The easiest way to safeguard this, is collection in groups, which are di-rectly organised and accompanied by the responsible company.

Otherwise, one or several persons on behalf of the operator must visit regu-larly the collectors in the field, to supervise fulfilment of rules on GCP, and standards established in this policy. These visits must be documented in sim-ple forms (see Internal Inspection Report Wild Collection). Frequency of these visits will be established on a case-to-case basis, depending on the collected species, type of landscape, and level of collectors’ training.

External con-trol of collec-tion sites :

• ADITI inspectors must visit a certain number of collecting sites, according to the following scheme:

y = r * √x
(y = collection sites visited by our inspector,
r = risk factor,
x = total number of collection sites).

The minimum number of collection sites to be visited is 5.

• The risk factor ―r‖ varies from 1 to 4, according to :

o Number of collected species, especially “critical” species in terms of sustainable use
o Collectors’ training
o Type of landscape
o Quality of documentation
o Quality of internal control system
o Sources of pollution

Examples:

Critical species	Collectors training	Type of landscape	Records	Internal Control System	Sources of pollution	Risk factor	Total number of collection sites
							5	10	20	50
							Sites to be visited
Many	Poor	Many farming areas	Poor	Poor	Many	4	5	10	20	28
Many	Medium	Some farming areas	Poor	Medium	Many	3	5	10	13	21
Few	Reasonable	Some farming areas	Reasonable	Reasonable	Many	2	5	6	9	14
Few	Good	Forest	Good	Good	Few	1	5	5	5	7

• We are aware, that the definition of “collection site” may be a subject of dis-cussion, since in some cases, a collection site may be a clearly defined area of only some hundred square meters, while in the case of berry collection in huge forest areas, a “collection site” may have the size of several square kilometres, or, in other situations, single plants may grow scattered over a large, diverse area. Nevertheless, we believe that we have to leave the selection of geographically and ecologically representative sites up to the inspector.

External con-trol of whole-sale points :

• Generally, all wholesale points have to be subject to external control.
• Only in the case of very big projects, with a high number of wholesale points, the inspector can select a number of representative wholesalers, following the same scheme explained in 5.3.3. Risk factors for wholesalers are:

                      o Quality of records, labelling, traceability.
o Risk of post-harvest pollution.
o Risk of post-harvest commingling.

Documentation :

• Concerning maps and other documentation, please see our Standard Control Program Wild Collection