1.Revision overviewThe Italian Ministry of Agriculture ( Ministero dell 'Agricoltura, della Sovranità Alimentare e delle Foreste ) was recently amended by a decree signed by the Secretary of State, Luigi D 'Eramo, regulating Ministerial Decree No. 309 of 13 January 2011 ( DM 309 / 2011 ). The content of this revision is concise but of great significance : the deadline in points 2 and 3 of Annex 2 is changed from ' December 31,2025 ' to ' December 31,2027 '. This marked a two-year transition period for Italy 's exemption policy for the limit of phosphite residues in organic products.文章源自FOFCC-http://fofcc.org.cn/en/36494/
2.Regulatory differences : Italy 's ' grace ' and the EU 's ' zero tolerance ' coexistIn particular, it should be noted that this amendment is a unilateral arrangement under Italian domestic law. At the level of the European Commission, there has been no similar exemption for phosphite, and the baseline logic of ' detection triggers investigation or even cancels organic identity ' is still strictly maintained.文章源自FOFCC-http://fofcc.org.cn/en/36494/
Hierarchy Time File / Caliber Core position The EU level 2018.05.30 Reg. (EU) 2018/848 Prohibited substance residues in organic products trigger three-stage consequences : 1 official investigation 2 temporary suspension of sales 3 if no anti-pollution measures are takenRevocation of Certification Qualification EU level ( Association Guide ) 2017–2022 German BNN Guide / EOCC Guide BNN : 1-year-old 0.05, perennial 0.1 mg / kg ; eOCC : 0.2 mg / kg, only as the survey threshold, andnon-cancellation certification limit requirements Domestic Italy 2011.01.13 DM 309/2011 Baseline : In principle, 0.01 mg / kg is the cancellation of certification status. Domestic Italy 2020.07.10 DM 7264/2020 First opening exemptionHerbs 0.5 mg / kg woody 1.0 mg / kg to cancel the organic state, originally scheduled to the end of 2022 Domestic Italy 2022.12.22 DM 658304/2022 Extend to 2025.12.31 Domestic Italy By the end of 2025 This Amendment Order Further extension to 2027.12.31
Italy 's ' 0.5 mg / kg or 1.0 mg / kg ' threshold for cancelling certification is currently the most relaxed standard among EU member states - only one-fifth to one-tenth of the German BNN guideline value, or one-half or one-third of the EOCC guideline value. Italy 's ability to incorporate this standard into ministerial decrees is based on the legal framework of its domestic law DM 309 / 2011 on ' accidental and technically unavoidable pollution ' and subsequent extensions of administrative orders.文章源自FOFCC-http://fofcc.org.cn/en/36494/
3.Delay motivation : to be supported by empirical researchAccording to the original text of the ministerial decree, the extension is intended to wait for the final data of the scientific research project BIOFOSF-CUBE ( source of phosphite in organic cultivation : accidental pollution and man-made pollution system research ). The project was initiated by the Italian Ministry of Agriculture, Food Sovereignty and Forestry ( Mipaaf ) in April 2022 and is expected to be completed by October 31, 2026. Italian authorities say the current threshold will remain unchanged until the Agricultural Research and Economic Analysis Commission ( CREA ) submits conclusive evidence to prevent a ' one size fits all ' treatment of ' real pollution ' and ' environmental background drift '.文章源自FOFCC-http://fofcc.org.cn/en/36494/
4. Compliance warning : valid in the territory, exit is not guaranteedThis information is essential for Chinese farms and export organic companies in Italy : Geographical limitations : The requirement of 0.5 mg / kg for herbaceous crops and 1.0 mg / kg for woody crops is only applicable to the Italian domestic certification system ( DM 309 / 2011 Annex 2 ). Once the goods cross the border to the ports of other member states, the competent authorities of the other party still have the right to initiate a complaint investigation, which will lead to the revocation of the certification qualification in serious cases. EU baseline remains unchanged : The European Commission has never legally recognized compliance with phosphite residues. The European side insists that phosphite is a pesticide ( or aluminum triethylphosphonate degradation ) prohibited by the ( EU ) 2018 / 848 regulation, and any level of detection theoretically constitutes a sufficient reason for the cancellation of organic certification. Italy 's DM 309 decree is only based on the domestic buffer mechanism under the framework of " unintentional pollution, " which has no extraterritorial effect and does not bind other member states.文章源自FOFCC-http://fofcc.org.cn/en/36494/
SummaryThe European Commission 's ' zero tolerance ' policy on phosphite has not been loosened. This adjustment only involves the statute of limitations clause in Italian domestic law DM 309 ( extended from 2025 to 2027 ). Agricultural products regulated by Italian certification bodies in Italy can get a two-year buffer period ; however, for products in cross-border circulation, changing ports or attached to the EU uniform logo, Italy 's grace standard should not be misjudged as the EU common standard.文章源自FOFCC-http://fofcc.org.cn/en/36494/
July 2, 2026文章源自FOFCC-http://fofcc.org.cn/en/36494/
