1. Production rules for bees Organic reform Delegated act
Expert Group

2. Empowerments Delegated act Derogation origin of bees, treatments apiaries, fight against Varroa
Article 14 Livestock production rules 2. The Commission is empowered to adopt delegated acts in accordance with Article 54 amending: (a) points (renovation of apiaries), and of Part II of Annex II by reducing the percentages as regards the origin of animals, once sufficient availability on the Union market of organic animals has been established; (c) point (b) of Part II of Annex II as regards the feeding of bee colonies; (d) points (b) and (e) of Part II of Annex II as regards the acceptable treatments for the disinfection of apiaries and the methods and treatments to fight against Varroa destructor; Need to activate IA Art 14(2)(c) to add pollen

3. Scope
ANNEX I
OTHER PRODUCTS REFERRED TO IN ARTICLE 2(1)
Beeswax included in the scope
Comment change from current rules

4. Livestock production rules Derogation non-organic animals
Annex II Part II Livestock production rules Use of non-organic animals By way of derogation from point 1.3.1, for the renovation of apiaries, 20 % per year of the queen bees and swarms may be replaced by non-organic queen bees and swarms in the organic production unit, provided that the queen bees and swarms are placed in hives with combs or comb foundations coming from organic production units. In any case, one swarm or queen bee may be replaced per year by a non-organic swarm or a queen bee. Comment changes compared to Art 9 (5) Reg 889/ %

5. Annex II Part II Livestock production rules 1.9.6 For bees
Livestock production rules Additional general rules for bees Origin of animals
Annex II Part II Livestock production rules
1.9.6 For bees
Origin of animals
For beekeeping, preference shall be given to the use of Apis mellifera and their local ecotypes.
Comment no change compared to Art 8(2) Reg 889/2008

6. Livestock production rules Additional general rules for bees Nutrition
Annex II Part II Livestock production rules
Nutrition
With regard to nutrition, the following rules shall apply:
(a) at the end of the production season hives shall be left with sufficient reserves of honey and pollen for the bees to survive the winter;
(b) bee colonies may only be fed where the survival of the colony is endangered due to climatic conditions. In such case, bee colonies shall be fed with organic honey, organic sugar syrups, or organic sugar.
Comment no change compared to Art 19(3)
ES dearth period instead of winter
ES to insert adverse conditions
Com no need to add adverse conditions neither dearth

7. Basis for technical discussions Feeding of bee colonies
No Implementing acts for bees
Empowerment Reg 2018/848
Delegated act Article 13(2) amending point (b) of Part II of Annex II as regards the feeding of bee colonies
With regard to nutrition, the following rules shall apply:
(b) bee colonies may only be fed where the survival of the colony is endangered due to climatic conditions. In such case, bee colonies shall be fed with organic honey, organic pollen, organic sugar syrups, or organic sugar.

8. Comments DA feeding of bee colonies
Comments received from AT, ES, NO to add organic
ES possibility of administering other organic protein sources such as beer yeast or chickpea flour could be considered
SE does not see a major benefit to allow organic pollen as feed during “normal” years. However, in case the flowering decreases drastically when the bees have many larvae, we would welcome the possibility to use pollen from organic apiculture so the larvae do not starve. There is a risk that the pollen contains spores of American foul brood, which could be an argument to use pollen replacements instead. We are a little reluctant to open up for pollen replacements, but if all raw material is organic, we could accept it in case of catastrophic circumstances.
Com pollen replacements problematic for organic production

9. Comments DA disinfection of apiaries
SE proposes to add caustic soda to point (b) using the empowerment of Article 14(2) of Reg 2018/848 The Commission is empowered to adopt delegated acts in accordance with Article 54 amending points (b) and (e) of Part II of Annex II as regards the acceptable treatments for the disinfection of apiaries and the methods and treatments to fight against Varroa destructor; Caustic soda for disinfection of apiaries shall be permitted;
COM easier to use (a) appropriate products and substances authorised pursuant to Articles 9 and 24 for use in organic production

10. Clarifications Reg 2018/848 Conversion (1)
SE practical issues to consider for both beekeeper and inspector. If no organic wax were available on the market, a good choice from bee health point of view would be to let the bees build up new wax foundations during the conversion period. For beekeepers with top bar hives this is the only alternative, since they do not use “human made” wax foundations. Question 1 for clarification: Does this mean that top bar hives cannot be used in organic production even if a colony is placed in a new hive and build up all wax during conversion?

11. Clarifications Reg 2018/848 Conversion (2)
SE practical issues to consider for both beekeeper and inspector.
Conventional wax is usually a mixture of wax from cap and other wax and not all beekeepers separate broken foundations from cap-wax. If you know you will convert, you can separate it, of course. In Sweden we have not solved how to verify that purchased non-organic wax originates from cap only.
Question 2 for clarification (to the committee): Is it possible to distinguish bees wax that only originates from cap from mixed wax?
COM to check with JRC and apiculture sector working on quality of wax

12. Clarifications Reg 2018/848 (3) Use of non-organic animals
SE do we understand correct that it is possible for the beekeeper to include up to 20% non-organic queens/swarms/nutes per apiary even if the beekeeper has several apiaries?
By way of derogation from point 1.3.1, for the renovation of apiaries, 20 % per year of the queen bees and swarms may be replaced by non-organic queen bees and swarms in the organic production unit, provided that the queen bees and swarms are placed in hives with combs or comb foundations coming from organic production units. In any case, one swarm or queen bee may be replaced per year by a non-organic swarm or a queen bee.