We don't even know what to call them anymore: fake food, fake foods, junk food archetypes, highly processed foods have invaded the supermarkets. Too sweet, too fatty, full of chemical and synthetic products, they increase the risk of cardiovascular and cerebral diseases, but also of diabetes and cancer. They make up more than half of the calories of an average American and in France, the High Council of Public Health has set a target of reducing their consumption by 20 % by 2022. However, the concept of highly processed food (TUE) does not exist in food law. The only "ultra" currently taken into account is ultra high temperature. This may seem regrettable in many ways, but it may in fact be an opportunity. An analysis for UP' Magazine by Florence ARNAUD, Senior Lecturer in Private Law at the University of Paris-Sud, Paris-Saclay, Researcher in Food Law.
Legally, food is defined as "any substance or product, whether processed, partially processed or unprocessed, intended to be, or reasonably expected to be ingested by humans. »1
If he has suffered an "action resulting in a significant change to the initial productincluding by heating, smoking, curing, salting, maturing, drying, pickling, extraction, extrusion, or a combination of these processes".2it is called processed food. The fact that the food is organic3 or not is irrelevant here, except in terms of substances authorised "for their manufacture or to impart specific characteristics".4which are much less numerous in organic, we'll come back to that later.
According to this definition, are legally categorized as "processed products", for example, without distinction, commodities as different as :
- maple syrup, which is only heated maple water, to concentrate the sugars;
- the buckwheat flower bread®, made by extrusion of buckwheat seeds, with a little salt and sugar ;
- slices of poultry "ham" that have required multiple processing operations and whose formulation would be "Turkey fillets, salt, poultry broth and vegetables (water, chicken pieces, salt, sugar, carrots, onions, spices and herbs (garlic, thyme, bay leaf, lovage, turmeric, paprika, black pepper, nutmeg, cloves), chicken fat, antioxidant: rosemary extract), sugar, natural flavour, antioxidant: ascorbic acid".
The number of ingredients or processing steps, whether ingredients are fractionated or denatured, the impact of the processing on the matrix effect of the final product.5The law, in particular, ignores all this.
The concept of highly processed food does not exist in law. However, they are not foods like any other.
There is a very wide variety of TUEs, as signified by classification proposals such as NOVA or, more finely, SIGA. We propose here to consider with the Fonds Français pour l'Alimentation et la Santé (FFAS)6 that "two distinct and not overlapping (and not to be confused) major criteria characterize the category of highly processed: the processing of raw food and the processes it uses on the one hand, and the formulation of the final product after the addition of various substances on the other hand, whose effects interact on the characteristics of the final product. »7 It should be added that the packaging of TUEs, for example, is also a complex matter, both from the point of view of consumer health and its environmental consequences (which we will not go into here as the subject is so vast).
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On the transformation side, it must be recognized that not all are to be put on the same level. However, in the mass production of many industrial products, complex technologies that are "not well known to the public and not very transparent" are used.8 are used, such as extrusion cooking, separation techniques, ultra high temperature, hydrogenation or hydrolysis, and the consequences of these recent technologies" on the overall nutritional value of foods have not been sufficiently studied. » 9
The law has little concern with the transformation of non-bio TUEs10with the exception of processing aids.11 and hygiene because, requiring handling, it poses a risk of health insecurity and toxicity. It has, on the other hand, been dealing with their formulation for several decades. Fortunately, this is even less transparent than the technologies used, particularly for reasons of industrial secrecy.
Take the case of additives12. The law regulates more than 300 of them, divided into 27 functions or technological roles, and the rules differ according to 174 categories of maintenance. In organic farming, only about 50 additives are used. Acceptable Daily Intakes (ADIs) are imposed when science establishes that they are necessary and the consumer can identify them on the label, in the list of ingredients, under their E code followed by 3 to 4 digits and/or by name.
To be authorised for use in food, additives must necessarily and cumulatively fulfil at least three criteria13 :
1. the additive must not, on the basis of the scientific evidence available, pose any safety concern for the health of the consumer at the levels proposed ;
2. there must be a sufficient technological need which cannot be met by other economically and technologically feasible methods ;
3. its use does not mislead the consumer.
The Act provides that "where appropriate, other relevant criteria, including environmental criteria"...14 may be used to decide whether or not to authorise an additive. In addition, "a food additive must be of benefit or interest to the consumer".15. Furthermore, when an additive is recognised as an allergen (which is the case for sulphites), or when it is obtained from foods recognised as allergens (cereals containing gluten, crustaceans, soya, etc.), then it must, unless an exception is made, also appear on the label.
One of the main concerns for the consumer today is that the toxicity, alone or indeed as a cocktail (with interactions between them), of the more than 300 additives authorised in conventional medicine is still poorly known. Re-evaluations of authorised additives are currently underway at the level of the European Food Health Authority (EFSA).16which are expected to be finalised in 202017...but there are those who object to the official findings. The interactions of each additive with other ingredients of the food into which it may be incorporated (cocktail effect) will not be better taken into account, nor will the fact that a consumer might want to eat 6 products each containing the maximum level of the same additive in a single day.
TUEs labeled organic are not TUEs like any other.
Bio TUEs differ from non-bio TUEs in terms of both processing and formulation.
Indeed, the law lays down among the principles specific to the processing of organic foodstuffs, principles which by definition do not apply to conventional food processing:
- restricting the use of food additives, non-organic ingredients with primarily technological or organoleptic functions, as well as
micronutrients and processing aids, so that they are used as little as possible and only when there is an essential technological need or for specific nutritional purposes ;
- to exclude substances and processing methods which may be misleading as to the true nature of the product ;
- to process organic foodstuffs carefully, preferably using biological, mechanical and physical methods ;
- to exclude food containing or consisting of engineered nanomaterials18.
Specific rules for the production of processed foodstuffs shall be laid down precisely19. The use of flavouring substances or flavouring preparations which are neither natural nor organic is prohibited and the European Commission may decide on authorised techniques in the processing of foodstuffs.20.
Only certain products and substances are allowed in processed foods that can be labelled organic.21and their use is subject to several conditions:
- there must be no alternative products or substances or techniques that can replace them ;
- it would be impossible to produce or preserve the food or to comply with specific dietary requirements without recourse to such products or substances ;
- they exist in the natural state and have undergone only mechanical, physical, biological, enzymatic or microbial processes, unless such products or substances are not available in sufficient quantity or quality ;
- the organic ingredient is not available in sufficient quantities22.
The use of chemical products and substances is prohibited in principle23 as well as the use of GMOs24.
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Finally, the use of products, substances and techniques which make it possible to restore properties lost during the processing and storage of organic foodstuffs or to correct the effects of faults in the processing of such foodstuffs, or which are likely to mislead as to the true nature of the products to be marketed as organic foodstuffs, is prohibited.25.
The concept of highly processed food is not ignored by public authorities.
Public authorities have already taken numerous initiatives in relation to the evolution of our modern food, its impact on our health, the environment, employment and territories. I invite you to read Articles L1, L2 and L3 of the Rural and Maritime Fishing Code, which list the objectives of the policy in favour of agriculture, food and maritime fishing, to get an idea of the commitments made, in theory26.
The French parliament has taken up the issue of industrial food. In 2018, it created a commission of inquiry on industrial food with the aim of assessing industrial food from several angles: nutritional quality, role in the explosion of chronic diseases, social and environmental impact. The president of this commission, the deputy Loïc Prud'homme, has even recently mobilized in a personal capacity, denouncing the inaction of politicians in relation to junk food.
However, it is mainly in terms of their nutritional composition that processed and highly processed foods are nowadays distinguished from others, as it is considered by public authorities that "the nutritional composition of the average overall diet of an individual or population is one of the best documented markers of its potential health effects (even if there are still uncertainties)".27.
The affixing of a nutrition declaration on foodstuffs packaged in particular forms shall be compulsory28. This declaration shall indicate at least the energy value, the quantity of fat, saturated fatty acids, carbohydrates, sugars, proteins and salt.29. The quantities of monounsaturated fatty acids, polyunsaturated fatty acids, polyols, starch, dietary fibre and all vitamins and minerals listed by law may also be mentioned, but without obligation.30.
In addition, the Nutri-Score logo is now offered free of charge to all companies that wish to use it, "in order to facilitate the consumer's choice with regard to the energy and nutrient content of their diet".31. The government is encouraging its adoption.
The Limit of Nutritional Information
The problem is that this so-called "nutritionist" approach to food, rather than a "holistic" one, is not satisfactory, and the public authorities or similar bodies recognise that "the more or less detailed description and quantification of the nutrients contained in a food is obviously not enough to take account of the multiple dimensions that make up its value and make it considered "good to think" and therefore "good to eat" in its entirety ...": In addition to the pleasure it provides, its socialising (sharing), cultural and symbolic functions, which have been analysed for a long time but are difficult to quantify, questions about its origin, production methods, industrial transformations it has undergone, its cost, availability, environmental impact, etc. are added to the pleasure it gives. These are modern problems, not devoid of meaning, which deserve to be studied in greater depth in scientific terms. »32.
Researcher Anthony Fardet33 has been well established for several years now: a healthy food is one that has health potential, i.e. a combination that is beneficial to the body in both its nutritional and structural dimensions. The composition of the food is not enough, and besides, we don't eat nutrients but food!
Because of this focus on nutrient profiles, the legislative proposals currently under discussion before the Senate do not seem to me to target the specific issue of TUEs.
They certainly advocate "the reduction of salt, sugar and saturated fatty acid content in industrial foods, the limitation of authorized additives to those authorized in organic foods, the control of advertising aimed at young people and food education in schools", but they do not consider the impact of food processing and formulation, whether industrial or not, the synergies between additives, the raw/cooked balance of the contents of our plates, seasonality, the correspondence of body and soil needs, and many other considerations.
The subject of TUEs is complex, the economic interests at stake are colossal, and there are profound differences of opinion on the very notion of healthy eating. Yet the law is fundamentally a management tool that reflects the political positions of the ruling power. Moreover, food law is mainly of European and economic origin. It is therefore not in its nature, so to speak, to curb the industry.
TUE, a dangerous food?
No TUE is, taken in isolation and consumed under "normal" conditions, a toxic food, unless fraud or misconduct occurs at some point in the food chain, possibly including the consumer. It can be consumed without immediate adverse reaction, unless one is allergic to one of its components, which is independent of its TUE status.
Otherwise, the TUE would be withdrawn from the market, as the law prohibits the marketing of a dangerous food product.34i.e. food which, under "normal conditions of use of the food by the consumer at each stage of production, processing and distribution" and taking into account the information provided to the consumer, inter alia through the labelling of the product35is either injurious to health or unfit for human consumption36.
In determining whether a food is unsafe, account must be taken of the normal conditions of use of the food and "the information provided to the consumer, including information on the label, or other information generally available to the consumer, concerning the prevention of adverse health effects specific to a particular food or a particular category of food. »37
In the event of failure to comply with food safety rules, the responsibility will lie first and foremost with the economic operator. However, a secondary responsibility is placed on the State and its services, which must ensure the application of food law, control and verify the correct application of the law at all stages of production, processing and distribution. Within this framework, they must communicate publicly on the safety and risks of food.38.
The National Agency for Food, Environmental and Occupational Health Safety (ANSES)39 has been carrying out food vigilance, or nutrivigilance, since 2010.40.
The aim of this work is to improve consumer safety through the rapid identification of adverse reactions linked to the consumption of novel foods and novel ingredients within the meaning of European law.41foods or beverages fortified with substances for nutritional or physiological purposes (which are TUEs), products intended for use in the feeding of special populations (infants, young children, special medical needs, weight control substitutes) or food supplements42. An undesirable effect according to the law, in this context of nutrivigilance, is "a harmful reaction occurring under normal conditions of use of a foodstuff in humans".43. A portal for reporting adverse health events44 has been established by the Ministry of Social Affairs and Health for the reporting of adverse reactions. Health professionals (doctor, pharmacist, dietician...), producers and distributors45 are the main actors46 of these reports that can be made online47.
It is also worth noting that, in a more abstract way, food law must comply with the principles of precaution, transparency (consultation of citizens on food law and information of consumers on risks), risk analysis and protection of consumer interests, as well as the implicit principles of prevention and food safety and health protection and the underlying principles of proportionality, reasoning and consistency of rules and practices.48.
In addition, all producers and distributors, particularly food producers and distributors, are under a safety obligation, according to the Consumer Code.49 the products and services must, under normal conditions of use or under other conditions reasonably foreseeable by the professional, be as safe as can reasonably be expected and not be harmful to the health of persons. "This safety obligation requires producers and distributors to take "all appropriate measures to contribute to compliance with all the safety obligations laid down".50 by law.
The limit of this obligation is that a product will be legally qualified as a safe product if it "complies with the specific regulations applicable to it for the protection of the health or safety of consumers".51. Furthermore, in the case of innovation, if the scientific data do not allow a complete assessment of the risk, the innovation should be "presumed innocent".52 and enjoy the benefit of the doubt.
It's the snake that dies its tail! Only the safety criteria retained by the law are valid, so if they are, as is the case with TUEs, incomplete or unsatisfactory, neither the producer nor the distributor of the product will have to take responsibility for them. These efforts made by the public authorities and the fact that the consumer has the list of ingredients at his disposal should be considered, therefore the indication of allergens and additives in particular, a nutritional declaration and, where appropriate, a Nutri-Score type logo, exonerates all upstream economic players, as well as the public authorities, from their responsibility if this consumer has made one or more choices that are detrimental to his or her individual health? Is it basically on each of us that the law, individually, places legal responsibility for the impact of our food choices on our health?
In fact, if this is the case, it is to be seized as an opportunity!
A great opportunity to take back the reins of his diet!
Increasingly, food decision aids are prescriptive rather than descriptive in nature, while our eating behaviours are tracked and exploited when we buy processed products.
Today, the non-allergic or intolerant consumer no longer really needs to read the labels of the processed foods he or she buys and may not even think about the quality of his or her choices in relation to his or her individual needs: he or she may rely on the opinions of third parties who claim to have done this work for him or her. Logos such as the Nutri-Score, applications such as Yuka or WW, all sorts of labels and marketing claims to which the law gives free rein, choose for him what is good or bad to eat and in what quantity.
In insidiously, "the state extends its power to our plates."53 It is a paradigm shift in the role of the state in food but also in the nature of the people who consume it.54.
By the summer of 2021, public authorities and food industries will offer Num-Alim, a digital database dedicated to food products, which is presented to us as "reliable and exhaustive", with data "open to all those who want to analyze, interpret and publish them (scientists, startups, citizens ...)".55.
Directly informed by French food companies but also by consumers via "dematerialized augmented labels", this Num-Ali will store the digital reproduction of all the food labels that the manufacturers will communicate, as well as all useful information on food and on our individual and collective consumption.
It will create a digital identity card for each food.56 The information provided by the distributors will include: the elements that make them up, the methods of cultivation or breeding of the raw materials, their origins, the labels, the Nutri-Score rating, the environmental footprint, etc., from which distributors will be able to choose the foodstuffs they wish to offer for sale.
It will also include information on purchases and eating habits, via the sales receipts or loyalty cards of certain brands, as well as information on the nutritional status of the population.
All these data will be cross-referenced and analysed, not only to give them value but also to create artificial intelligence, while the platform will serve as a basis for creating new mobile applications and could become European.
On the consumer side, Num-Alim's goals according to the Ania57 There are many "food shopping" services, including the availability of a multitude of personalized digital decision-support services that can guide them in their purchasing or consumption practices (assistance with food shopping, food associations and the preparation of balanced meals, healthy culinary practices, etc.).
Tomorrow you'll be able to find out where the peas in your can come from, how they were grown and processed... Consumers will be able to find out what other foods they can combine them with to make a balanced dish...".58.
From another angle, we could read "filing, loss of freedom, loss of responsibility, abandonment of sovereignty over our food. And we are the ones who, with our taxes, finance this in part "... Without giving in to a painful food anxiety, which I call alimenxiété...".59I think it's important for each of us to understand the extent to which it is up to us to choose to be an accomplice to this change.60 or not to be61.
There is no escaping the need for in-depth reflection on the regulations applicable to TUEs in particular, this particular category of processed foods, or at least to those of them that are furthest removed from a simple diet that guarantees our vitality. The above developments are by no means exhaustive. I have left aside, for example, the question of the impact of TUEs on the environment, such is the breadth of the subject.
The agri-food industry cannot be expected to spend as much money on research into the health and environmental impact of TUEs as it does on the development of new technological aids or new markets. Nor can we expect the State not to support this industry, which has a turnover of almost 180 billion euros and employs more than 427,000 people.
It is therefore important, in my opinion, that each one of us is aware that eating well is first and foremost a personal responsibility and that it is dangerous to let others, be it apps, logos or any other support, determine what is good to eat for oneself, individually, day after day or even meal by meal.
Finally, I would like to make it clear that it is also important to think about the unprocessed products we consume.
Unprocessed food, from a legal perspective, is that which has not undergone "any treatment resulting in a significant change in the original state of the food".62. Seen from this angle, the unprocessed food may have been the subject of several operations such as "dividing, separating, slicing, boning, chopping, grinding, skinning, peeling, milling, cutting, washing, trimming, freezing, deep-freezing, chilling, grinding, shelling, packing or unpacking".63. In organic, preparation is defined as "any other operation performed on an unprocessed product without changing the original product, such as slaughtering, cutting, cleaning or milling, as well as packaging, labelling or labeling changes related to organic production. »64 These actions are not considered to result in a significant modification of the food.
Unprocessed food is therefore not just raw food just out of the ground or still alive. A kilogram of carrots, a vacuum-packed burger is unprocessed, frozen green beans, or a salad washed, cut and packed in a modified atmosphere are all types of unprocessed food. It is easy to understand that the vitality of each of these foods and their impact on health and the environment, in particular, are not at all the same.
Florence ArnaudLecturer in private law at the University of Paris-Sud, Paris-Saclay, Researcher in food law attached to the CERDI.
Certified speaker, consultant and coach in Integrative Nutrition. Her websitesound, its blog.
1 Art. 2 Regulation (EC) No. 178/2002 of 28/01/2002. The law considers food and foodstuffs as synonymous and gives them the same definition whether they are conventional or organic (Art. 3, point 45 R. (EU) 2018/848.
2 R. (EC) No 852/2004 on the hygiene of foodstuffs, Article 2(1)(m). Emphasis added. The regulation of organic products uses the same definitions but expressly excludes packaging and labelling operations: see Art. 3, points 71 to 73 R. 2018/848 on organic production and labelling of organic products.
3 See then Regulation (EU) No. 848/2018 of 30/05/2018 on organic production and labelling of organic products.
5 V. on this subject, the work of Anthony Fardet, including "Halt ultra-processed foods! Mangeons vrai. 3 règles d'or pour manger sain, éthique et durable ", éd. Thierry Souccar, 2017.
6 " Réflexions sur la classification des aliments selon leur degré de transformation ", Fonds Français pour l'Alimentation et la Santé (FFAS), work coordinated by Pr B. Guy-Grand, Dec. 2018.
7 Id. Emphasis added.
10 For organic, see below.
11 V. Art. 2 R. (EC) No 1333/2008 on food additives. A processing aid is defined as "any substance not consumed as a food ingredient per se; intentionally used in the processing of raw materials, foodstuffs or their ingredients to fulfil a certain technological purpose during treatment or processing and which may result in the unintentional but technically unavoidable presence of residues of that substance or its derivatives in the finished product, provided that such residues do not present a health risk and do not have any technological effect on the finished product. "(Art. 2, b)) Food enzymes are covered by R (EC) No 1332/2008.
12 R. (EC) No 1333/2008 of 16 Dec. 2008 on food additives. Food additive is defined in law as any substance not normally consumed as a food in itself and not used as a characteristic ingredient in food, whether or not it has nutritional value, the intentional addition of which to food, for a technological purpose, at the stage of its manufacture, processing, preparation, treatment, packaging, transport or storage results, or may reasonably be expected to result, in it becoming itself or its derivatives becoming, directly or indirectly, a component of that food. "In organic farming, the same definition is used (art. 3, 61) R. (EU) No. 848/2018 on organic production and labelling of organic products).
13 Art. 6, 1, points a, b and c R. (EC) No 1333/2008 on food additives.
14 Art. 6, 1st R. (EC) No 1333/2008.
15 Art. 6, 2 R. (EC) No. 1833/2008.
16 V. https://www.efsa.europa.eu/fr/topics/topic/food-additive-re-evaluations
17 V. Commission Regulation (EU) No 257/2010 of 25 March 2010 establishing a programme for the re-evaluation of approved food additives.
18 Art. 7, R. (EU) No. 848/2018 on organic production and labelling of organic products. Organic feedingstuffs comply with similar, albeit attenuated, principles: Art. 8 of the same regulation.
19 Art. 16 and Annex II, Part IV R. (EU) No. 848/2018. It is important, however, to read this Regulation in its entirety as there are many exceptions and attenuations to the rules of principle.
21 Annex II, Part IV, 2.2.2, R. (EU) No. 848/2018.
22 Art. 24, 4 R. (EU) No. 848/2018.
23 Art. 24, 5. R. (EU) No. 848/2018.
24 Art. 11 R. (EU) No. 848/2018.
25 Annex II, Part IV, 1.6, R. (EU) No 848/2018.
26 These articles are easy to read online at legifrance.gouv.fr.
27 FFAS, "Reflections on the classification of foods according to their degree of processing", supra, p. 5.
28 V. art. 30 et seq. R. (EU) No 1169/2011.
29 Art. 30, 1 R. (EU) No. 1169/2011. Derogations exist.
30 Art. 30, 2 R. (EU) No. 1169/2011.
31 Art. L3232-8 C. Public health.
32 "Reflections on the Classification of Foods by Degree of Processing", supra, p. 6.
34 Art. 14, 1. of Regulation (EC) No. 178/2002, which is valid for France.
35 Art. 14, 3 R (EC) No. 178/2002.
36 Art. 14, 2. R (EC) 2002/178 It is not indicated in the text that the conditions are cumulative and the National Food Council considers that "the alternative form is necessary for a reason of common sense, even if it does not appear formally in the text" (Opinion No. 48 of the National Food Council on the preparation of the entry into force on 1 January 2002).er January 2005 of certain provisions of Regulation (EC) No 178/2002, 9 Nov. 2004).
37 Art. 14, 3 R. (EC) No. 178/2002.
38 Art. 17, para. 2 R. (EC) No. 178/2002.
39 https://www.anses.fr/fr/content/inca-3-evolution-des-habitudes-et-modes-de-consommation-de-nouveaux- enjeux-en-mati%C3%A8re-de
40 V. art. R1323-1 et seq. C. public health.
41 This includes foods and ingredients not traditionally consumed within the Union before 1997, such as chia seeds, shiitake mushroom extract or guar gum. R.V. (EU) No 2015/2283 on novel foods or novel food.
42 Art. R1323-1 C. health pub.
43 Art. R1323-3, 1°, C. santé pub.
44 Signalement-sante.gouv.fr : https://solidarites-sante.gouv.fr/soins-et-maladies/signalement-sante-gouv-fr/
45 As part of their security obligation under Art. L423-3 C. consom.
46 Art. R1323-2 and R1323-4 C. santé pub.
48 Opinion No. 48 of the National Food Council on the preparation of the entry into force on 1 January 2010.er January 2005 of certain provisions of Regulation (EC) No 178/2002, 9 Nov. 2004.
49 Art. L421-3 et seq. C. consom.
50 Art. L421-4 C. consom.
51 Art. L421-5 C. consom. Article L421-7 of the same code completes this rule.
52 Bernard Chevassus, questioned on the topic "Should the precautionary principle be applied to food", in August 2015. https://alimentation-generale.fr/video/faut-il-appliquer-le-principe-de-precaution-a-lalimentation/
53 L. Muller, " En imposant le Nutri-Score, l'Etat étend son pouvoir à nos assiettes ", Slate, 27 August 2019, http://www.slate.fr/story/181128/alimentation-sante-nutrition-nutri-score-yuka-prescriptions.
54 L. Muller, prec.
55 According to the ANIA press release on Num-Alim, 23/11/2018. Num-Alim would be one of the pillars "Creation of Num-Alim, the identity platform for food products", LSA and Consommation, published in line on 23/11/2018
56 V. ANIA press release on Num-Alim, 23/11/2018.
59 V. F. Arnaud, L'alimenxiété, http://bit.ly/2nQV6em
60 L. Muller, prec.
61 See also my article on the subject of invisible risks in food, https://fr.calameo.com/read/005049066fa9bf1a01289, p. 138 ff.
62 Art. 3, 2, d., R. (EC) No 1333/2008 on food additives. Emphasis added.
63 Art. 3, 2, d., R. (EC) No 1333/2008 on food additives .
64 Art. 3, 44) R. (EU) No. 848/2018 on organic production and labelling of organic products.