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> It’s not “hundreds of pages” as you originally claimed

The regulation itself is about 60 pages, and references numerous other regulations itself. It most certainly adds up to hundreds of pages of regulation. Not that that changes anything, usage of the word in this way still precludes the possibility of any sort of concise definition.

> and the interpretation does not vary substantially among certification bodies, as you implied.

Then why are inter-jurisdiction equivalence programs so complex? Typically only including a short list of equivalent countries, with all other imports requiring recertification. Oh, except with USDA Organic. That doesn’t have an equivalence program.

> Do you have an alternative to the current system to suggest?

Come up with a label that doesn’t unduly prejudice consumers, and doesn’t strip another word of its meaning. The word organic did used to have a very clear meaning before “organic” farming came about. If you were to ask an average consumer whether they knew their organic food was allowed to be treated with chemical pesticides and synthetic opioid painkillers, I bet they’d be pretty surprised by that.

GDPR is a complex set of regulations. People understand this when they talk about it, even if they don’t understand all of the rules. Thankfully it’s not called Privacy Certified, with a restriction preventing any non-certified business from using the word “privacy” to describe their product.



>The regulation itself is about 60 pages, and references numerous other regulations itself. It most certainly adds up to hundreds of pages of regulation. Not that that changes anything, usage of the word in this way still precludes the possibility of any sort of concise definition.

Most of those references are to other parts of the same document. As I said before, the world is complex, biotechnology is complex, and agriculture is complex. If you have any suggestions on what parts of the 60-odd pages are unnecessary or superfluous, feel free to share.

>Then why are inter-jurisdiction equivalence programs so complex? Typically only including a short list of equivalent countries, with all other imports requiring recertification. Oh, except with USDA Organic. That doesn’t have an equivalence program.

The US does, in fact, have an equivalency program with the EU. [0] earlier you claimed that certification bodies had different, unique definitions. That’s not true. Why is it complicated to meet the standards from different countries? Because you’re meeting standards from different countries, stuff has to be legal to produce, legal to export, legal to ship, legal to import, and legal to sell. Lots of people think there is too much regulation in the modern world, perhaps you are one of them, can you suggest something constructive that meets the goals of the program?

>Come up with a label that doesn’t unduly prejudice consumers

Can you show that consumers are unduly prejudiced by the current system?

>and doesn’t strip another word of its meaning. The word organic did used to have a very clear meaning before “organic” farming came about.

“Organic” had several clear meanings and has not lost any, however it has gained another clear meaning and people who use it don’t seem to see a problem.

>If you were to ask an average consumer whether they knew their organic food was allowed to be treated with chemical pesticides and synthetic opioid painkillers, I bet they’d be pretty surprised by that.

In general, they would be right to be surprised about the chemical pesticide and the synthetic opioid because 1) pests are systematically controlled with non-chemical means and 2) chemical pesticides and synthetic opioids are only permitted to be used as a last resort, when other means of controlling pesticides and ensuring the health and welfare of animals are found to be insufficient. Organic farmers are not permitted to routinely dope up their cattle or spray their crops. [1]

>GDPR is a complex set of regulations. People understand this when they talk about it, even if they don’t understand all of the rules. Thankfully it’s not called Privacy Certified, with a restriction preventing any non-certified business from using the word “privacy” to describe their product.

If people were generally mistaken about the way organic food is produced, I could agree with you that there was a problem. However most of the misinformation I see comes from people who are critical of the organic food program. I agree that the term isn’t perfect, I had a person tell me “there’s no difference between organic and inorganic food” and that was funny. But since there’s not really any such thing as “inorganic food” I’m still not sure what problem you see with the term. It’s not as though consumers of organic food are confused about the general principles. They buy organic food because they want to minimize their exposure to pesticides and to minimize their impact on the environment[2], organic regulations are written in order to achieve this goal while still permitting the producers to stay in business. If you want to criticize the organic program because it’s not strict enough when it comes to limiting these substances, that’s fine. But it already requires that the farmers use these substances as a last resort when other methods have failed, and the evidence suggests that it’s effective at achieving the goals, at least to some degree. [3]

[0]https://www.usda-eu.org/trade-with-the-eu/trade-agreements/u...

[1]https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=f1419426e5... (See §205.238 Livestock health care practice standard, part (b) and §205.206 Crop pest, weed, and disease management practice standard, entire section)

[2]https://www.sciencedirect.com/science/article/abs/pii/S09503...

[3]https://ehp.niehs.nih.gov/doi/full/10.1289/ehp.8418

[4]https://www.nature.com/articles/330370a0

[5]https://ehjournal.biomedcentral.com/articles/10.1186/s12940-...


> “Organic” had several clear meanings and has not lost any, however it has gained another clear meaning and people who use it don’t seem to see a problem.

Well putting aside the fact that the new meaning is anything but clear, this is just demonstrably untrue. There’s no such thing as an inorganic carrot, but you can not describe a carrot as being organic unless it is certified as such by the USDA (or whatever other certifying body), according to their unique criteria that have no relation at all to the carrots organicness.

> Can you show that consumers are unduly prejudiced by the current system?

Try googling a simple definition of “organic”. Google will tell you “produced or involving production without the use of chemical fertilizers, pesticides, or other artificial chemicals.” Everything about that definition is false according to any organic certification program (regardless of what you think an “artificial chemical” is...)


"Organic" with respect to agricultural goods is a term of art defined by law.

"Inorganic" is not a legally defined term with respect to agricultural goods, nor is it a scientifically meaningful term because carrots are made of organic materials (as "organic" is used scientifically). Thus, calling a food product "inorganic carrot" would either be fraudulent or deceptive under US and EU laws.

On the other hand, it is possible to have a "meat carrot" like Arby's did this summer, which consisted of carrot-shaped meat.

And it's certainly possible to have an iron carrot or a plastic carrot. Just not as a food product.

Context matters.




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