I. Revision OverviewThe Italian Ministry of Agriculture, Food Sovereignty and Forestry (Ministero dell'Agricoltura, della Sovranità Alimentare e delle Foreste) recently issued a revision decree, countersigned by Undersecretary Luigi D'Eramo, amending Ministerial Decree No. 309 of 13 January 2011 (DM 309/2011). The revision is concise but significant: 📌 The deadlines set out in Annex 2, points 2 and 3, have been uniformly changed from “31 December 2025” to “31 December 2027.” This marks a further two-year transitional period for Italy's exemption policy regarding phosphonic acid residues in organic products.บทความมาจากFOFCC-http://fofcc.org.cn/th/36494/
II. Regulatory Divergence: Italy's “Grace Period” Coexists with the EU's “Zero Tolerance”It should be particularly noted that this revision constitutes a unilateral arrangement under Italian domestic law. At the European Commission level, no similar exemption has been established for phosphonic acid to date, and the baseline logic of “detection triggers investigation, and even revocation of organic status” remains strictly maintained.บทความมาจากFOFCC-http://fofcc.org.cn/th/36494/
Level Time Document / Position Core Stance EU Level 2018.05.30 Reg. (EU) 2018/848 Residues of prohibited substances in organic products trigger a three-stage consequence: ① official investigation ② temporary suspension of sales ③ if contamination prevention measures are not taken,revocation of certification. EU Level (Association Guidelines) 2017–2022 German BNN Guidelines / EOCC Guidelines BNN: 0.05 mg/kg for annual crops, 0.1 mg/kg for perennial crops; EOCC: 0.2 mg/kg, serving only as an investigation threshold, whilenot constituting a limit for certification revocation. Italian Domestic 2011.01.13 DM 309/2011 Baseline: in principle, 0.01 mg/kg triggers revocation of certified status. Italian Domestic 2020.07.10 DM 7264/2020 First exemption introduced: organic status is revoked only at 0.5 mg/kg for herbaceous crops and 1.0 mg/kg for woody crops, originally set to expire at the end of 2022. Italian Domestic 2022.12.22 DM 658304/2022 Extended to 31 December 2025. Italian Domestic End of 2025 This Revision Decree Further extended to 31 December 2027.
The threshold of “0.5 mg/kg or 1.0 mg/kg” for revocation of certification set by Italy is currently the most lenient standard among EU Member States—only one-fifth to one-tenth of the German BNN guideline values, or one-half to one-third of the EOCC guideline values. Italy's ability to enshrine this standard in a ministerial decree relies on the legal framework concerning “accidental and technically unavoidable contamination” in its domestic law DM 309/2011 and subsequent administrative extension decrees.บทความมาจากFOFCC-http://fofcc.org.cn/th/36494/
III. Rationale for the Extension: Awaiting Scientific EvidenceAccording to the text of the ministerial decree, this extension aims to await the conclusive data from the research project BIOFOSF-CUBE (Study on the Sources of Phosphonic Acid in Organic Cultivation: Accidental Contamination and Anthropogenic Contamination Systems). 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 31 October 2026. Italian officials have stated that, pending the submission of conclusive evidence by the Council for Agricultural Research and Economics (CREA), the current thresholds will remain unchanged, in order to prevent a “one-size-fits-all” approach to distinguishing “genuine contamination” from “background environmental drift.”บทความมาจากFOFCC-http://fofcc.org.cn/th/36494/
IV. Compliance Warning: Valid Domestically, Not Guaranteed AbroadThis information is crucial for Chinese-funded farms in Italy and organic exporters to Italy: Territorial Limitation: The requirements of 0.5 mg/kg for herbaceous crops and 1.0 mg/kg for woody crops apply only to Italy's domestic certification system (DM 309/2011 Annex 2). Once goods cross the border to other Member States“ ports, the competent authorities of those states still have the right to initiate complaint investigations, which in serious cases may still result in revocation of certification. EU Baseline Unchanged: The European Commission has never legally recognized the compliance of phosphonic acid residues. The EU side maintains that phosphonic acid is a pesticide (or a degradation product of fosetyl-aluminium) prohibited under Regulation (EU) 2018/848, and that detection at any level theoretically constitutes sufficient grounds for revoking organic certification. Italy's DM 309 decree is merely a domestic buffer mechanism under the ”unintentional contamination" framework; it has no extraterritorial effect and does not bind other Member States.บทความมาจากFOFCC-http://fofcc.org.cn/th/36494/
💡 SummaryThe European Commission's “zero tolerance” policy on phosphonic acid has not been relaxed. This adjustment concerns only the temporal provisions in Italy's domestic law DM 309 (extended from 2025 to 2027). Agricultural products within Italy under the supervision of Italian certification bodies may benefit from a two-year buffer period; however, for products circulating across borders, transiting through ports, or bearing the EU unified logo, Italy's grace standards must not be misconstrued as EU-wide standards.บทความมาจากFOFCC-http://fofcc.org.cn/th/36494/
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