This text is public.
Today 31st December 2023 I solemnly declare to interrupt any kind of
professional consultancy services concerning biodynamic agriculture and
Demeter certification, that is managed by Biodynamic Federation –
Demeter International (or so abbreviated: BFDI), due to the fundamental
differences in ethics and scopes I have with this international
organization.
I expect also to be applied the Appendix 4 of the Demeter international
standard in case of use of “not permitted” fertilizer in a Demeter
certified field, as happens due the use of the fertilizer “Biosol”
produced by Sandoz/Novartis if applied in Demeter certified fields. I
expect to see published the list of the “de-certified” fields
(according to the standard) and the list of the “de-certified” products
obtained from the same fields. Details are reported below.
Thirty years ago I was a student in Italy and I was searching how to
know and respect the Life that is contained in every human, or
“άνθρωπος” / anthropos (in ancient Greek, meaning “a living soul in a
terrestrial body”), studying what means the human “health”, and I found
out that food may be a cure for the anthropos, as explained by
Hippocrates a long time ago. Hippocrates taught to respect the human
life since the conception (before the birth), taught to respect the
human dignity, taught to cure without surgery.
Depending on the kind and the quality of food there is the capacity to
cure or to make sick the people. Knowing this, I started searching how
to produce crops without toxic substances that were making the farmers
sick, and studied how to obtain a food that will have no residues of
toxic substances (independently if allowed in any kind of organic
regulation or standard).
The biodynamic agriculture and the Demeter certification have been a
“branch” of my personal and professional life since the year 1996, but
today I see that this “branch” in the garden of my life and I see is
dead, despite all my attempts to keep it alive in the last two years as
international biodynamic advisor for the Greek farmers and operators. I
started a service of advisory for my clients in Greece because they
asked me to offer this service, and because I’m professionally able to
do it.
(https://www.biodynamic-advisors.org/en/directory-advisors?tx_pxpconsultants_pi1%5Baction%5D=show&tx_pxpconsultants_pi1%5Bconsultant%5D=8&tx_pxpconsultants_pi1%5Bcontroller%5D=Consultant&cHash=f252cdef66c394a552725b93013d09e4
)
Today I stop these services, and I put an end to the biodynamic farming
advisory I did and to any matters of services involving Demeter
certification, cutting off this dead “branch”. End.
“New branches” will grow and will be fruitful thanks to the new
sunlight left free to enter after the necessary pruning, “new branches”
ethically in accord with my ethics, scopes and conscience.
Examples and teachers indicating the ethics of my conscience are, for
example:
– Jesus Christ (heal people, respect the Life, respect human dignity,
respect the living soul in the terrestrial human body of the
“anthropos”, do not kill),
– Moses (10 commandments, including: not commit “homicide”, not tell
lies, don’t steal, don’t make commerce of the human body, etc),
– Hippocrates (respect the human Life, don’t kill, heal people and
respect the dignity of the human being, use the food to heal the
anthropos).
My ethics and scopes are in good part mentioned in this “CHARTER OF
FUNDAMENTAL RIGHTS OF THE EUROPEAN UNION”, 2012/C 326/02 that is an
higher rule in force in the European Union
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:12012P/TXT .
This Charter have been already violated many times by various European
governments, institutions and private organizations in the last years,
but nobody in the BFDI organization noticed it.
Talking about biodynamic advisory experience an technical matters, in
the last two years I past months to explain to the BFDI certification
office that a “soluble seaweed extract” (Acadian) and a “copper input”
(Kocide 2000) are conform to the Demeter international standards in the
last 25 years, despite these commercial inputs were not in the
“approved by FiBL (Germany)”. These inputs were mentioned and conform
to the standards while the word “Fibl” was never present in the Demeter
International standards, until the end of the year 2023. Only since the
1st January 2024 the term “approved by FiBL (Germany)” enters
officially in the Demeter International standard, for the first time,
so I pronounce the term ‘END” about my biodynamic agriculture
professional services for the first and definitive time.
The explanations I gave about the inputs in the year 2022 have been
necessary due to the risk of monetary sanctions that the BFDI
certification office may ask to the biodynamics farmer in cases of “non
conform” input. Are there sanctions that will be asked to the
certification office when this office does not respect the Standard in
force? No.
Copy of the “agreement” between the farmer and the BDFI is available
here, showing who is responsible of what and who may be sanctioned.
https://organicgarden.gr/documents/54918_Licensee-BFDI_LicenseAgreement_20-12-2022.pdf
And a summary of the quality management manual were sanctions are
reported is available here
https://demeter.net/wp-content/uploads/2022/11/5.0_EN_ICOQualityManualPublicSummary_PID_22-11-03.pdf
I also warned various times that the responsibility of the
certification is upon the BFDI certification office, including to
understand when a input is conform or not to the Standard in force,
while is not possible to delegate this responsibility about conformity
to an external private institute such as Fibl, that has got also
matters of conflict of interests.
Errors made by Fibl Germany have been seen, such as when Fibl
“approved” an agricultural input that never existed: the “Kodice opti”.
See copy here:https://organicgarden.gr/documents/Kodice.pdf . Despite
the insistence of the head of the certification office, Kodice opti
never existed. It never existed because “Kodice” was a typing error of
“Kocide”, as I told from the beginning to the BFDI certification head
of the office. Today, again, Kocide opti is present as “approved” input
in the web site https://demeter.net/services/approved-inputs/#/ ,
while the “Kodice opti” approval remains as historical evidence of this
error.
My time and energy have been spent to explain also this facts to the
BFDI certification office, that more easily should understand the
error, but did not want to admit it.
In the last year, then, I’ve seen the BFDI certification office to
insist to avoid any inspection at the first year of conversion period,
for all farms (including one client of mine too), in open violation of
the chapter “6.4.4.2.Semi-fast and fast conversion” of the standards in
force. I spent months to explain to the BFDI certification office and
to the BFDI board and general secretary that a first inspection must be
done at the first year of conversion, according to the standard in
force. Damages have been done, due this retard. Months have been
spented to explain what is obvious for other people.
The insisted disrespect of the standard made by the BFDI certification
office violate the dignity of the farmer too, who signed an agreement
with BFDI where he is obliged to respect the standard in force, while
the certification office did not respect it.
For these reasons too, I put the “end” to my professional activity in
matters that involves biodynamic agriculture and Demeter certification.
After that, already explained to the BFDI certification office and to
the BFDI board the problems connected with the insistence to consider
“approved by fibl =conform to the standard” and “not-approved by fibl =
not conform to the standard”, while Fibl Germany has got no list of
“not approved” inputs. This is because the manufacturers pay fees to
Fibl in order to obtain an “approval”, and they continue to pay annual
fees to maintain the “approval”, while no manufacturer pays to maintain
a list of “non approved” inputs. As logic consequence of this, the list
of “approved inputs” is unable and unsuitable to be used as evidence
that the other inputs are not conform to the standard, because may be
no manufacturer never paid for an “approval”, or stopped to pay the
annual fees and “lost the approval” for its standard-conform input.
There are matters of responsibility in certification that are exclusive
of the certification office, such as to understand if a input is
conform to the standard, because is the certification office that emits
the certificate.
The farmers cannot register a new agricultural input in the Fibl list
of “approved” inputs, because they are not allowed to do it.
There are matters of conflict of interest because the “Fibl (Germany)
list of approved inputs” is made after payment of annual fees by the
manufacturers to Fibl, who has an agreement with BFDI. Biodynamic
Federation (of BFDI) is owner of the trademark “Demeter” also for
agricultural inputs (fertilizers
https://euipo.europa.eu/eSearch/#details/trademarks/W10780726 and
pesticides
https://euipo.europa.eu/eSearch/#details/trademarks/W01283171 ) and may
ask for “intellectual rights” for the use of the word “Demeter” in
every “confirmation” of “approval” emitted by Fibl.
Is weird that Fibl declares to Ifoam to be only a research institute
(https://directory.ifoam.bio/affiliates/512-forschungsinstitut-fur-biologischen-landbau-deutschland
), not a certifier of agricultural inputs, while Demeter International
declares to Ifoam that makes also the service of certification of
agricultural inputs (fertilizers and plant protection inputs
https://directory.ifoam.bio/certification_bodies/78 ) while the BFDI
certification office insists with me that is Fibl (Germany) responsible
for input “approvals” . So, I wonder, may be somebody wrote something
including errors, or may be somebody is telling lies. Who knows.
Knowing that, I see that an agricultural input “approved” by Fibl
Germany for use in organic agriculture according to the EU regulation
is in fact “not conform” but have been “approved” by Fibl for many
years.
This fertilizer is called “Biosol” , it is “approved” by Demeter/Fibl,
(https://demeter.net/services/approved-inputs/#/result/b01ff360-8f9b-441c-a971-efdf8ce8e18f/3bbeaa3b-92cf-4630-b80d-3e0b69790d45/en_GB
) who declare that is made of “fungal biomass” and the manufacturer is
SW- Düngesysteme. In fact SW- Düngesysteme is the German distributor
and the product is made by Sandoz Austria (Novartis group).
https://www.biosol.com/usa/002/sales_partners.html
https://graniteseed.com/storage/2017/04/Biosol.pdf see “manufacture of
penicillin, a fungal biomass (mycelium)”
Happens that this material is not conform to the EU regulation of
organic agriculture (https://eur-lex.europa.eu/eli/reg/2008/889/oj ).
Sandoz founded Novartis, and produce penicillin antibiotics:
https://www.novartis.com/news/media-releases/sandoz-announces-plans-joint-investment-help-strengthen-future-antibiotics-manufacturing-europe
I asked to the head of the BFDI certification office (on 23 Oct 2023)
the name of the species of the “fungal biomass” of the approved
fertilizer “biosol”, in order to understand if it is conform to the EU
organic regulations. She answered that I have to ask to the
manufacturer. This is because Fibl has a “confidential policy” in order
to avoid to show all the ingredients contained in the “approved”
inputs: Fibl approves the input, then is a matter of faith to believe
that the evaluation is right.
What happens if makes a huge error? Let’s see.
The fungal biomass, in fact, is made of wastes from mycelium of
Penicillium chrysogenum (probably genetically modified) from the
Sandoz/Novartis antibiotics pharmaceutical industry, and is
transforming the organic certified and the biodynamic fields in
pharmaceutical waste dump. See official label here
https://organicgarden.gr/documents/biosol-sandoz.pdf showing the kind
of mycelium “pilzmycele der Penicillium chrysogenum” = “fungal mycelium
of Penicillium chrysogenum”
(https://www.biogard.gr/wp-content/uploads/2022/07/Full-page-photo.pdf
)
The EU organic regulation approves as some kind of mycelium fertilizer:
“Mushroom culture wastes – The initial composition of the substrate
shall be limited to products of this Annex” …. (reg: EU reg 2008/889
https://eur-lex.europa.eu/eli/reg/2008/889/oj ). Mushroom is cultivated
for food production, while Penicillin is a mold fermented for
antibiotic production.
The “approval” given by Fibl Germany to “biosol” is not only for use in
EU organic and Demeter standard, but also for Naturland Germany,
Bioland Germany and other certification systems (see
https://www.input-list.com/search.html#/result/b01ff360-8f9b-441c-a971-efdf8ce8e18f/3c57d0fe-64d5-4aae-8471-b3e9746b7086/en_GB
), including Easy-cert Austria
(https://www.biosol.com/auto_cms/original/mationofeuregulationorganicproduction_2.pdf
). All them shall have a talk with Fibl about this fault. The consumers
of organic certified food may pretend some explanations too.
In Italy the fertilizer “biosol” by Sandoz is registered to the
Ministry of agriculture to be used exclusively in conventional fields,
not in organic fields. It is evident in the printing of the page
reporting “uso convenzionale” about the registered fertilizer “biosol”
by Sandoz (see here :
https://organicgarden.gr/documents/biosol%20uso%20convenzionale%20Registro%20Fertilizzanti%20-%20Fertilizzante%20Dettaglio.pdf
)
In the international label reported here
https://www.biogard.gr/wp-content/uploads/2022/07/Full-page-photo.pdf
is evident that in the Italian part of the label there is no indication
to be conform to be used in organic agriculture, because in Italy may
be used only in conventional fields.
Adding some more problems to the “Penicillium” mycelium material, we
may consider that some nitrogen source in the substrate during the
fermentation is not completely organic, but also form conventional
forms of nitrogen. It is just very probable. See in this linked
document about “penicillin industrial process”: “Nitrogen source is
generally supplied in the form of ammonium sulphate or ammonium acetate
or ammonium nitrate”.
https://www.biotechnologynotes.com/antibiotics/penicillin/penicillin-biosynthesis-structure-fermentation-process-and-uses/13843
There is also a very serious probability that all the strains of
Penicillium spp. used in the process of production of penicillin
antibiotics are also “Genetically Modified”, or “Genetically
engineered”, because it is normal in such industry to use very
productive microbial strains. The penicillin percentage in the
fermented material increased of about 2000% in the last seventy years,
due to the genetic modifications of Penicillium strains. See in the
liked documents: “Penicillin production in industrial strain
Penicillium chrysogenum P2niaD18 is not dependent on the copy number of
biosynthesis genes” https://pubmed.ncbi.nlm.nih.gov/27072635/ and see:
CRISPR/Cas9 Based Genome Editing of Penicillium chrysogenum ,
https://bmcbiotechnol.biomedcentral.com/articles/10.1186/s12896-017-0335-8
)
So, seems, that this “approved by Fibl Germany” input is in fact “non
conform” to the EU organic regulation due to the nature of the first
matter (Penicillium spp . wastes from antibiotic industry), very
probably during the fermentation are used conventional sources of
nitrogen during the fermentation process (ammonium) and very probably
the strains used of Penicillium spp are also GMO. This is the input
that the Fibl Germany approves and Demeter International approves too,
despite is not conform to the EU regulation for organic agriculture.
What happens if a manufacturer pays for “research services” Fibl
Germany and then again pays for “approval” in the Fibl Germany list
despite the material is not conform to the EU organic regulations?
Happens that the input becomes “approved”, but in conditions of
conflict of economical interests of Fibl
(https://www.fibl.org/en/contact-site-information ).
Sandoz financed Fibl on 2004 for a research program on spinach about
Agro-biosol (Agro-biosol is synonymous of “biosol”)
https://www.biosol.com/auto_cms/original/bericht-spinat-agrobiiosol_2004.fibl.pdf
It happened again on 2004 on lettuce (Effect of AGRO BIOSOL® on the
Long-term
Nitrogen Supply and Health of Lettuce , By order of: Sandoz GmbH, A-
6250 Kundl, Austria )
https://www.biosol.com/auto_cms/original/bericht_salat__1.pdf
It happened on 2011 on vineyards and wine production
https://www.fibl.org/en/themes/projectdatabase/projectitem/project/106
Knowing that Sandoz/Novartis is paying Fibl at least since the year
2004 for various services, and seeing that a not conform material is
“approved” by Fibl Germany to be used in various organic standards, I
understand that Fibl Germany is not in accord with my personal ethical
standards. Due to this knowledge I’m avoiding any professional
relationship with this institute, and with anybody is giving importance
to the same institute, including BFDI.
Demeter International and Biodynamic Federation (BFDI) are declaring
sometimes to be against the genetically modified seeds and to be
against the conventional antibiotics (see the contents in the Demeter
standards too), while approves the use as fertilizer a waste coming
from probably GMO Penicillium used to produce antibiotics. It sounds
not coherent.
An organization that gives the “approval” to an agricultural input that
is “not conform” to be used as fertilizer in EU organic certified
fields makes the following conseguences:
1 – betrays the good faith of organic and biodynamic farmers putting
them in face of a very probable de-certification of the fields where
this not permitted fertilizer have been used, the same fields start
again from the beginning of the conversion period, and the yields and
product obtained by those fields must be de-certificate and considered
“conventional”,
2 – betrays the good faith of the consumers of organic food and organic
products,
3- betrays the good faith of the distributors of organic agricultural
inputs,
4 – shall be considered as unfair concurrence by the producers,
distributors and manufacturers of fertilizers really suitable to be
used in organic certified agriculture, because a non-conform fertilizer
have been distributed in the market in concurrence with their “conform”
fertilizer, reducing the possible selling potentiality of their
“conform” fertilizers.
In the Demeter International standard 2023 (in force until today) and
in the standard 2024 is written:
“Appendix 4: Permitted/restricted fertilisers and soil conditioners
…………….
Any use of a material not permitted by this Standard leads to
decertification of the farm, or at
least of the treated crops and areas. See also chapter 3.7.
…………………
At this point, I officially expect that the BFDI certification office,
and to the BFDI board, will apply the Demeter International Standard in
cases of use of fertilizers “not conform” to the EU organic regulation,
and consequently “not permitted” to the Demeter International Standards
either.
The action to be taken, according to the standard, is the “de-
certification” of the fields where the fertilizer “Biosol” have been
used, and the de-certification of all the products obtained from those
fields. The same fields must start again from the point “zero” of the
conversion period.
As consumer of organic products, as organic agriculture operator and as
professional agronomist involved in matters of organic agriculture I
officially ask to be officially published online (possibly on
www.demeter.net ) the list of the fields and the farms that used the
not permitted fertilizer “Biosol” (produced by Sandoz / Novartis and
sometimes distributed by SW- Düngesysteme ) in the last three years and
I expect to be published the list of the products obtained from those
de-certified fields in the last three years and their lot numbers in
order to to avoid to buy these specific products as “organic” while
they are in fact “conventional” and in order to request to be de-
certified those lots by the competent certification bodies.
I expect to be immediately informed when these lists will be published,
in order to be able to consult them and avoid any further damage in the
organic agriculture system.
This text is public and may be used by any concerned consumer,
institution, company or other concerned entities.
In faith
Harald C. Letizi
(Dr. Agronomist / Dottore Agronomo)
www.organicagriculture.gr/biodynamiki
….
—
Harald C. Letizi (dr. γεωπόνος)
ΒΙΟΣΠΟΡΟΣ
Αγ. Σπυρίδωνος , 57500 Επανομή , Θεσσαλονίκης
Harald C. Letizi (dr. agr.)
Biosporos
Ag. Spyridonos, 57500 Epanomi (Thessaloniki, Greece)
tel.+30 2392301152 mob: +30 6979221718
harald@biosporos.gr
www.biosporos.gr – www.organicgarden.gr