Justification Letter for the Detection of Phosphonic Acid in Organic Products
To the attention of the interested parties,
Subject: Justification for the Detection of Phosphonic Acid of Alleged Natural or Residual Origin in Organic Strawberries.
In response to the detection of phosphonic acid in the organic products certified below, and based on the scientific background and technical reports compiled, we justify that the presence of this substance may have a natural origin or may be derived from authorized agricultural practices or environmental contamination.
Grounds for Natural and Residual Origin
The presence of phosphonic acid, in the absence of the pesticide Fosetyl-Al, does not necessarily constitute a nonconformity due to the following scientific and regulatory considerations:
-
Biological and Microbial Origin (Natural Synthesis):
- Scientific evidence suggests the hypothesis that phosphonic acids may come from the activity of microorganisms present in the soil, such as actinomycete fungi.
- High biological activity in the soil can generate concentrations of phosphonic acids that are absorbed by plant roots and translocated to plant tissues.
- Phosphonates are organophosphorus compounds that are present in all living organisms, which reinforces the possibility of biological synthesis.
-
No Detection of Fosetyl-Al:
- In all batches analyzed by our certifying company, the Fosetyl Aluminum parameter was reported as Not Detected (ND).
- The phosphonic acid is the metabolite resulting from the degradation of Fosetyl-Al. However, the detection of phosphonic acid without the direct detection of fosetyl is not sufficient grounds to suspect the unauthorized use of Fosetyl-Al.
-
Cross-Contamination and Permitted Inputs:
- The presence may be due to the existence of impurities in phosphorated fertilizers or crop-protection products that are indeed permitted in organic (ecological) agriculture.
- The use of potassium phosphonate (the potassium salt of phosphonic acid) in plant fortifiers was permitted in organic farming in many EU countries until September 30, 2013.
- There is a possibility that the contamination is due to an allowed organic practice in the supply chain, even if it is not the direct use of a prohibited pesticide.
Conclusion and Decision of the Certifier
Based on the scientific literature and the analytical results presented (Detection of Phosphonic Acid with No Detection of Fosetyl-Al), the certifier concludes:
- The presence of phosphonic acid is attributed to natural biological processes of synthesis in the soil or to the possible existence of residual residues or contamination in permitted inputs in organic farming.
- Consequently, the detection of phosphonic acid at these levels and in these circumstances does not constitute a violation of the applicable organic regulations.
- The lots of Strawberry/Fragaria mentioned maintain their organic quality and can continue to be marketed as biological products.
We remain at your disposal for any clarification that may be necessary.
Scan to open the official clarification page