The draft plans include limiting the size of grower groups to 2,000 members, each required to register as a legal entity. A minimum of 5% of the members, but not less than 10, shall be externally inspected each year and finally be subject to a minimum of 2% percent to sampling (lab tests). 
The planned changes will not have the desired effect, but may destroy livelihoods of thousands of small-scale farmers
We from Organic Services are fully in favour of tightening rules for group certification – one of the most powerful market access tools for small-scale farmers. The fact that group sizes worldwide vary between less than a hundred to tens of thousands of members obviously raises compliance concerns – but the EU’s approach does not solve the problem. Combining the restriction of group and farm size with a high external inspection rate would merely add bureaucracy and a lot of cost – without automatically improving compliance. Instead, digital systems are key for transparency.
Digitalisation and professionalisation must be the focus – not “keeping the small ones small”
Still today, grower groups work mainly with paper or complicated excel-sheets. This will not improve if the amount of their members is limited to 2,000 whilst administrative costs are rising. On the contrary: funds urgently needed for hardware, software and IT training will instead be spent on increased external certification and administration (for example, for dividing groups of 20,000 members into 10 different legal entities). Rather than artificially forcing grower groups into smaller structures and thereby “keeping the small ones small”, they should be proactively empowered to advance, to professionalise, to digitise. Many businesses and certifiers worldwide already use ERP-Systems and certification management solutions – why shouldn’t grower groups use professional software to manage and document their compliance with international organic regulations? What matters is that a group is functioning, well structured, transparent, and reliable. These factors should determine a group’s conditions for certification – not the number of its members.
If the EU’s regulatory changes will be pushed through, the software Group Integrity could be an option to minimize the damage in developing countries
Group Integrity is the multi-standard software solution for grower groups and for companies contracting farmers with small holdings. The tool provides them with a secure data platform, comprehensive data analysis functions, and brings internal audit and inspection workflows including multi-standard checklists to a professional level.
Thus, if the EU’s proposed changes will be implemented against all odds, our software Group Integrity might be an answer to the arising challenges. Already today, it can be applied via Implementation Partners who can create member clusters for certification purposes. Taking the example of a group that today has 20,000 members, its ICS manager can create 10 groups of 2,000 members in Group Integrity, each in a multi-client setting separated from each other. The ICS manager organises the use of Group Integrity, managing each ICS workflow providing full transparency of the process.
The software is well-tested, affordable, and ready to be implemented. Grower groups and businesses sourcing from smallholders, who already work with the tool, find it much easier to meet administrative requirements of national and international clients and confirm that Group Integrity eases external certification, streamlines administrative procedures and allows them to save on expenses and to improve economics.
We still hope that the EU’s plans will not be implemented. Independent from that, we from Organic Services are here to help.
Please get in touch if you would like to learn more about how Group Integrity can efficiently manage Internal Control Systems across thousands of members, whether below or above 2,000 members and independent of what the EU will decide.
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 Other regulations, e.g. on restricting the maximum size to 5 hectares and annual turnover to € 25,000, were already defined in the new basic organic regulation (EU) 2018/48 and must be assessed together with the new proposals.
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