RESPONSE FROM THE SOIL ASSOCIATION

What gardener of sound mind would destroy a beloved tree, one that had sweetened the air of a hundred summers, solely to capture its scent in a bottle for the pleasure of moments?

The following is a copy of an email from Francis Blake, Standards and Technical Director of the Soil Association. The recipient of the email is a supporter of the Green Pen campaign. Although he wishes to remain anonymous, he is keen to make public the Soil Association’s reply in defence of their Wild Crafting Standards policy.


EMAIL DATED 4th MARCH, 2004


Dear Mr XXX

I apologise for not getting back to you sooner but our standards department is extremely short staffed at present and I have been tied up or abroad for much of the last month or so.

Chrissie Wildwood seems to be waging a vendetta against the Soil Association and try as we might, I cannot get to the bottom of it.

First, the EU 'organic' regulation, which defines the legality of what farming and food products can (and cannot) be sold as organic, allows wild harvested products to be labelled as organic provided there has been no use of prohibited inputs (fertilisers and pesticides) for the last 3 years and the harvesting activities are sustainable - a total of 6 lines in the 50 page document. That is what all certification bodies in the EU operate to.

Recognising that this was totally inadequate the Soil Association decided to develop its own additional standards for wild crafting to ensure that there was proper control of such operations, coordination with any other harvesting going on in the area, etc and therefore to be assured that sustainability could be genuinely assured. We set up a special committee with all the experts we could muster to do this and spent at least a year formulating these standards. They were sent out for consultation to all stakeholders and the finally approved standards are now incorporated into our general standards for organic farming and production, taking up 4 pages.

Wild crafting certified by the Soil Association is now inpected against these standards and our certification department is now working on extending this to wild crafting certified by other bodies who wish their products to be used in Soil Association certified processing. However this is a slow and complicated job and is taking time as we are having to work 2 and often more steps removed from the actual growing.

So what Chrissie Wildwood has seemingly failed to grasp is that the Soil Association has actually been honest enough to acknowledge the problem, to put its head above the parapet and do something about it, whereas all other certification bodies have just been carrying on as before. For this, we get our heads bitten off and everyone else gets away scott free.

I don't doubt Chrissie's integrity - she is fulfilling an important function as whistle blower in what is clearly an area that needs the whistle blown. But this is exactly what we are trying to address too (contructively not destructively).

I hope this allays concerns and that you can restore your faith in what the Soil Association is doing. Of course please feel free to contact me again if you wish for any further clarification.

Best wishes
Francis Blake


Francis Blake
Standards & Technical Director
Soil Association
Bristol House, 40-56 Victoria Street,
Bristol BS1 6BY
T: 0117 914 2402
F: 0117 925 2504
E: fblake@soilassociation.org

Campaigning for organic food and farming and sustainable forestry
If you would like to join or make a donation please visit: http://www.soilassociation.org


RELEVANT PARTS OF AN EMAIL SENT BY CHRISSIE WILDWOOD TO FRANCIS BLAKE, 6th MARCH, 2004


Dear Francis,

Perhaps you'd be kind enough to answer the following questions.

1. As the Soil Association is now advising other European organic inspection bodies on the practice of wildcrafting, do you intend to advise these same organisations to de-certify essential oils from threatened wild forest trees felled for the purpose such as sandalwood, rosewood and cedar?

2. Please forward a list of all the wildcrafted herbs and essential oils SA Cert Ltd certifies. You've ignored this request in the past, so this time I trust you will kindly comply.

3. Please forward names of all the experts who helped put together the SA's wildcrafting standards. It's important to include each person's specific area of expertise, as well as the name of his or her respective company or organisation. For it's essential to satisfy the public that the SA's chosen experts are indeed experienced in assessing exactly what constitutes a sustainable yield for the many individual plant species collected from the wild and certified by SA Cert Ltd.

Further Comments:

As SA Cert Ltd is clearly 'learning on the job', then the organisation is hardly in a position to be overseeing wildcrafting standards - at least not, if they continue to charge a full professional fee for a novice service. Mistakes would be more easily forgiven if they were a charity or group of well-meaning volunteers.

The Soil Association's area of expertise is organic agriculture. This is where your organisation should have remained focused. The Soil Association would do better to engage in a concerted effort to promote the cultivation of popular herbs that have become threatened in the wild due to over-exploitation by the herb and essential oil trades. If the practice of wildcrafting is to continue, then it needs to be monitored by independent botanists, conservationists and ecologists, not SA Cert Ltd whose main purpose is to support trade interests.

As for my so-called vendetta against the Soil Association, presumably you must believe the same of Plantlife International, the World Wildlife Fund (WWF) and the Natural Medicines Society as well? Each of these organisations has expressed concern over your organisation's impracticable wildcrafting standards.

Your remark about my having ‘let others off Scott free’ is ridiculous. It echoes the same pass-the-buck attitude of the Aromatherapy Trade Council who, when confronted with the issue of essential oils extracted from the heartwood and roots of rosewood and sandalwood, responded with a defensive, ‘Blame the perfume industry, not us’. The ATC should be setting a good example since they represent a supposedly caring industry. Several members of the ATC are also key members of the Soil Association, and yet they continue to trade in threatened botanicals despite my repeated attempts to educate.

Another point, just because wild-harvesting is legal under EU rules for organic standards, this does not make it an entirely good law. Governments throughout the world constantly make bad laws, such as a belief in the legality of warfare, GM and capital punishment. Bad laws are there to be challenged through peaceful civil disobedience.

How any law maker could possibly deem as 'sustainable practice’ the destruction of wild trees for essential oil production beggars belief. Such desk workers need to know that sustainable practice is that which can carry on indefinitely without ever creating an imbalance, as in organic farming and related systems like permaculture.

I look forward to hearing from you soon.

Chrissie Wildwood



If a reply to the above is received, it will be posted here. Previous emails have been ignored, almost certainly because awkward questions were being asked. The SA is particuarly sensitive about Atlas cedar essential oil (Cedrus atlantica), which they re-certify from Ecocert. Both Ecocert and the SA refuse to accept the findings of botanists and conservationists who confirm that the tree and its habitat are endangered.


Below is a link to a paper on the threatened status of Atlas cedar and its fragile forest habitat. This information (and several other research papers on the subject) was sent to Francis Blake at his request. Indeed, I raised the subject at the SA's Health Products Standards Committee meeting on the 4th June, 2003. I'd been invited to discuss my concerns about the SA's wildcrafting standards policy.


Needless to say, the Committee soon realised that I would not give way, and thereafter adopted the immature tactic of stonewalling. Nonetheless, I do hope Francis Blake will have the decency to reply to the above points. Of course, I'm still awaiting acknowledgement of receipt of the research material. But then it's the age-old story: it's difficult for such a person to accept the truth when his salary depends upon his not accepting it.

Click here for a study on threatened Atlas cedar and desertification of its natural habitat

A concise report on Atlas cedar from the WWF

A study on endangered North African medicinal plants which the Soil Association were requested to purchase

It takes two to speak truth: one to speak and another to hear - Henry David Thoreau

If we desire respect for law, we must first make the law respectable - Louis D. Brandeis

Here is the reply from Francis Blake dated 25th March 2004. As it's so detailed, I've responded to different points within each section of the letter to make for easier reading

FRANCIS BLAKE

I did not say that the Soil Association is advising other inspection bodies - I am not sure how you came to that conclusion. Our only sphere of influence is the standards we produce and that which Soil Association Certification (SA Cert - our wholly owned certification subsidiary) certifies, either by direct inspection or indirectly by assessing the equivalence of ingredients certified by other bodies that our licensees are wanting to use. When SA Cert finds that such an ingredient is not produced to equivalent standards then naturally they inform both the licensee and the certification body concerned that they cannot (re-)certify it.

Of course as we believe that our standards are sound, we do like to see them (or something equivalent) adopted more widely and we work in various ways to try and achieve this - through Defra, the EU and IFOAM (International Federation of Organic Agriculture Movements). However standards development, especially on an international level, takes many years. We hope to be starting that process with our wild crafting standards later this year when our standards department is back up to full strength (we are at half strength at the moment and there is no spare capacity).


CHRISSIE WILDWOOD

You may not influence other organic inspection bodies directly. Nonetheless, you certainly imply that your organisation has a significant influence over other organic inspection bodies as confirmed in your statement:
“…we do like to see them (or something equivalent) adopted more widely and we work in various ways to try and achieve this – through Defra, the EU and IFOAM”


FB

SA Cert would like to comply with your request [to supply a list of all the wildcrafted herbs and essential oils certified by the SA] but at the moment this is not possible. The list of herbs and essential oils that may be wildcrafted potentially runs into the several hundreds and is further complicated by the long supply lines some of these go through and further still by the multiple sourcing that may be in any one essential oil. SA Cert is working through all of these to identify the exact situation and feels it would not be helpful to provide either an incomplete list or an inaccurate one. So please bear with us. I should also point out that any information SA Cert releases is likely to be generic in nature as they are bound by a strict code of confidentiality. In the meantime they are concentrating on those that are 'higher risk' and in that connection when you met us we asked for more specific information about the herbs you had identified - ie from which countries or regions, which particular species and, if you have any information on specifically organic certified herbs, which ones. You sent us some generalised information (mostly available on the internet) but this is not that useful, and some that was more specific - more of that nature would greatly assist SA Cert's work.


CW

Surely SA Cert must know exactly which wildcrafted herbs and essential oils they currently certify? I didn’t request a list of wildcrafted botanicals that might be certified some time in the future! The only way I was able to establish that the SA certified Atlas Cedar oil (from Cedrus atlantica) for example, was by reading a Neal’s Yard Remedies mail order catalogue. When I informed you of the threatened status of the tree and its natural habitat, I was told that the SA re-certifies the oil from Ecocert and that the wood ‘is from a sustainable source’. Curiously, you were happy enough to take Ecocert’s word for this, and yet in the same breath admitted that Ecocert’s wildcrafting standards were wanting! Indeed, you say as much again in your email of the 4th March 2004 (as reproduced above).

As I informed you at the time, the tree grows wild only in the Atlas Mountains of Morocco. However, since a number of SA’s trade members were citing France as the country of origin, I felt obliged to explain that although the oil is distilled in France, the wood is imported from Morocco. At least one supplier (a member of the SA) corrected their marketing literature as a result. You asked me to provide research material to confirm that the Cedrus atlantica and its habitat were threatened. I duly complied in June 2003. Having waited months for a reply, only since making this issue public have you taken the trouble to respond.

If you don’t wish to heed my advice about Atlas cedar, then do please contact the WWF and discuss the conservation issues with them.


FB

The following are or have been on our health products standards committee (whose first task was to draw up the wildcrafting standards, then to move on to standards for the manufacturing of health and beauty care products): Mike Brook (Organic Herb Trading Company), Rene Burrough (independent - herbalist), Anthony Daniels (Herbal Apothecary), Alison Denham (independent - wild crafting expert), Gaye Donaldson (Organic Herb Trading Company), Darren Edwards (Dewhurst Toiletries), Sato Liu (Natural Medicines Society), Josephine Fairley (independent - journalist), Romy Fraser (Neals Yard Remedies), Elearnor Gallia (independent - herbalist), Pauline Hilli (Neals Yard Remedies), Arun Kapil (Organic Village), Jan Kusmirek (Genera Consultancy), Cyril Lombard (Phytotrade Africa), Peter Malaise (Ecover), Nigel McFetridge (independent - GP), Marian Morley (Tesco), Anne Smith (independent - aromatherapist), Christine Steward (independent - herbalist), Charlotte Vohtz (Green People Company).


May I also clarify a few misconceptions behind your question:
1. Committee members serve as individuals not representatives of companies, though of course the expertise they have built up (in or out of a company) and the resources behind them are to some extent what makes them useful members of the committee.
2. The committee's role is advisory - their recommendation goes out for consultation to all licensees and Soil Association members (we are a membership charity with some 25,000 members, only about 4000 of which are licensees, the rest being consumers and other members of the public interested in supporting our work). The final standards are approved by the Council which is elected by the members.
3. The committee is not involved in making certification decisions, only drawing up the standards. Certification decisions are taken by SA Cert according to procedures that are approved by the UK Accreditation Service (UKAS). The committee may consider precedent issues referred to it by SA Cert and may review relevant aspects of SA Cert's work, but it is part of the charity, not the certification subsidiary.


CW

As I suspected, not a single person on your committee can possibly claim to have experience in assessing exactly what constitutes a sustainable harvest for all the herbs and essential oils the SA currently certifies. Not one appears to be a botanist, an ecologist or a conservationist. So how can they possibly be providing appropriate advice for the SA’s wildcrafting standards? Moreover, it’s impossible to estimate sustainable yields without working closely with the plant gatherers in the field. Certainly such work cannot possibly be monitored by moving pieces of paper around.

I note that many of the above committee members happen to trade in wildcrafted herbs and essential oils – a few also trade in IUCN Red Book threatened species such as sandalwood (Santalum album). Therefore, contrary to what you imply, these individuals do have a vested interest in the SA’s wildcrafting standards policy. It’s also important to mention that several of the non-trade individuals named above resigned from the SA’s health products standards committee in the spring of 2003. They felt that their concerns about the SA’s standards for health products were being ignored or overruled.

By the way, Josephine Fairley (named above) is not just an ‘independent journalist’ - she’s also the founder of Green & Black’s chocolate, certified organic by the Soil Association! Exceedingly good chocolate it is too, albeit beside the point in this instance. What is relevant, she’s yet another trade member of the health products standards committee. And let's not forget, her husband Craig Sams, founder of Whole Earth Foods (popular with supermarket chains) happens to be Chairman of the Soil Association as well!


FB

SA Cert is the most experienced certification body (not only organic) in the UK having been at the forefront of inspection and certification since the early 70s. Upon the introduction of a new standard it takes time to assess previously certified products against the new standards. As explained in my reply to Mr XXX this is particularly difficult where products are certified just to the EU regulation by other EU certifiers with perhaps several intermediary steps in between. However I stress that as far as we are aware SA Cert is the only organic certification body in Europe trying to progress better standards for wildcrafting.


CW

If SA Cert is so experienced, then why on earth did I have to persuade them not to certify the essential oils of rosewood (Aniba rosaeodora) and sandalwood (Santalum spp.)? An account of this episode is included in my article, ‘Spotlight on the Trade in Wild Plants’. Of course, I’m greatly relieved that SA Cert heeded my advice with regards these particular oils. However, the incident hardly engenders confidence, which is why I requested a list of all the wild-harvested botanicals certified by the SA. Indeed, it’s essential to know whether your organisation has awarded organic status to any other threatened botanicals, in addition to the Atlas cedar oil mentioned above.


FB

As I mentioned in my reply to Mr XXX, wild crafting and agriculture are often intimately mixed, especially in the small, diversified farms that were frequently the pioneers of organic agriculture. As these farmers were using wild crafted ingredients in their organic processing it became necessary to define the criteria under which they could be called organic and hence they became a part of the early organic standards of IFOAM and following that the EU 'organic' regulation. So actually wild crafting in organic agriculture has a long standing pedigree and predates by some years the much more recent problems with wild crafting for the herb and essential oil trades. The Soil Association felt that these latter problems were no reason to withdraw but rather to address the critical issues and strengthen the standards accordingly.

We agree that cultivation is important but our conclusion from looking at this issue very carefully was that it was equally important to ensure that the wild crafting we could influence through our certification should be carried out correctly, ie sustainably, so as to safeguard its continued productivity, not only for the benefit of the species in question but also for the whole of that ecosystem and also for the, often desparately [sic] poor, local people who depend on this work for their livelihoods.


CW

First, the felling of slow-growing wild forest trees for essential oil production plays no part in traditional organic agriculture. The SA has scant knowledge of the complexities of the essential oil industry. Moreover, very few studies into the sustainability of commercially wildcrafted botanicals for the herb market have ever been carried out. Even less is known about sustainability of wild-harvested aromatics exploited by the essential oil industry. So it's hardly surprising that numerous medicinal and aromatic species have become endangered in recent decades, coinciding with the burgeoning interest in wildcrafted ingredients for herbal remedies and natural cosmetics.

As for helping desperately poor people, the truth is these folk are paid a pittance for gathering wild plants for wealthy traders, and few (if any) rely on this as a sole source of income. In any case, since many commonly traded species are being over-exploited from the wild, the plants will soon be gone (as confirmed by Plantlife International and other conservation agencies). And until such time the Soil Association adopts a fair trade policy, the altruistic argument holds no water.


FB

Our standards require an ecological survey to be carried out for a wild crafted species that is to be certified and clearly SA Cert would expect this to be done by competent professionals. SA Cert would also consult relevant experts if it felt it did not have sufficient expertise in-house (though it has a number of ecologists on its staff).


CW

Clearly, you are talking of some future scenario. Yet the SA is already certifying wildcrafted botanicals! Also, an ecologist working for the Soil Association is hardly likely to have specific knowledge of all the individual plant species the SA certifies (or will certify in future), for such plants are gathered from diverse parts of the globe. Ecologists, like other specialists, are usually only knowledgeable in one (maybe two) defined fields – for example, the ecosystem of a tropical forest, or a semi-arid region, or coral reef.


FB

Another conclusion you seem to have made, which is totally inaccurate and extremely serious (not to say libellous), is that SA Cert's main purpose is to support trade interests. SA Cert's main purpose is to certify to the standards as set and directed by the Soil Association, which as I have said above, is a registered charity controlled by its elected Council.


CW

Well since SA Cert Ltd is the trading arm of the Soil Association and receives much of its income from the trade (i.e. the fees charged for certification) and because many of the SA’s committee members are also traders, then my assumption is easy to understand. SA Cert Ltd itself is not a charity. Rather, it's a "fully owned trading company of the Soil Association charity", as stated in your own literature. Please don’t threaten me with words like ‘libellous’ and ‘extremely serious’. This is a gross over-reaction and does no favours whatsoever for the reputation of your organisation.


FB

We have no problems with the views of these three organisations [the WWF, Plantlife International and the Natural Medicines Society] which are balanced and reasonable. Here, to the best of our knowledge, are their views (from their own publications) - though we would obviously be keen to know if you have any other information:

The recommendations in the Plantlife report 'Herbal Harvests with a Future' state the following:
A certification scheme, identified by a generic 'kite' mark, for products known to be collected in sustainable ways could help to promote an ecologically responsible market in medicinal plants. A start has been made by the Soil Association with its Organic Wildcrafting Standards, but as yet these are only applicable in specific contexts, for instance where there is assured tenure of collection areas, and are often not fully suitable either for developing, or developed countries. The use of a generic 'kite' mark will be of great help to consumers concerned with making socially and environmentally ethical purchases. A generic certification system for medicinal plants is, however, a major undertaking and will take time to evolve. It will have to include third party verification to ensure that standards are being upheld throughout the supply chain.

The WWF Factsheet 5 'What Can Consumers Do' states:
There are organisations working to establish guidelines for best practice in the sourcing and manufacturing of herbal medicine and cosmetics, in line with existing guidelines and standards such as those of the Soil Association (www.soilassociation.org) and the Forest Stewardship Council (www.fscoax.org).

And in the WWF-UK comments to EUROPAM's GAP and GWP guidelines (dated 17 May 2002), they state:
EUROPAM may wish to consult the following documents and organisations to gain a fuller perspective on wild harvesting issues:
Soil Association Non-Timber Forest Product Standard (www.soilassociation.org)
Soil Association Organic Wild Crafting Standard (www.soilassociation.org)

Regarding the Natural Medicines Society, chief executive, Sato Liu, was an active and valued member of our standards committee during the time the wildcrafting standards were developed. The only negative comments about the Soil Association that I have found appear in their autumn 2002 newsletter in an article by ... Chrissie Wildwood.

CW

As a reminder to readers, the article Francis Blake refers to is ‘Spotlight on the Trade in Wild Plants’. As Plantlife International points out:

“A start has been made by the Soil Association with its Organic Wildcrafting Standards, but as yet these are only applicable in specific contexts, for instance where there is assured tenure of collection areas, and are often not fully suitable either for developing, or developed countries.”


I’m surprised you think the above conclusion is acceptable. The point is SA Cert Ltd is already certifying a number of wildcrafted botanicals and customers are paying a premium for such products. Yet, even your President Jonathan Dimbleby admits that the wildcrafing of medicinal and aromatic botanicals (also the certification of essential oils from cultivated crops) has put your organisation in ‘uncharted territory’.

In personal communication with the WWF, it was made clear to me that the SA’s wildcrafting standards will be extremely difficult to implement, particularly in remote regions of the globe. For instance, every harvesting region will need an ecological expert with local knowledge - not only of the individual plant species harvested, but also of the impact of continual harvesting upon the respective ecosystems with their myriad interactions.

I know from inside information that the Natural Medicines Society, along with the other non-trade members referred to earlier, felt they were being ignored and so resigned from the SA’s health products standards committee. All the remaining committee members have trade interests - that is to say, unless the SA has since recruited a few non-trade members to redress the balance. As you well know, the NMS did not withdraw its support lightly. Remember, too, the Society’s HerbAlert campaign, spearheaded by the well-known botanist David Bellamy who is passionate about the conservation of endangered medicinal and aromatic plants.


FB

The Soil Association has no 'pass-the-buck' attitude. That is why we have developed these additional standards and are now implementing them - no it is undoubtedly not perfect (nobody has done this before) and no we have not completed the process, so yes we have some considerable way to go. But I think we can justifiably claim that we are setting a good example, even if we haven't completed it yet. What I still don't get is why you seem to be constantly gunning for the Soil Association, which is doing all this work, whilst I have not heard any criticism from you about other organic certification bodies who are completely ignoring the issue. Surely they are the ones you need to put pressure on. Of course you have every right to keep up the pressure on us, and being an open and democratic organisation we welcome this, but please do so in a balanced and constructive way, and respecting what we have done. This will enhance your credibility and our respect for your views, whereas your current sweeping criticisms do the opposite (rather as, I suspect, your 'repeated attempts to educate' don't seem to have the positive effect you, and we, would like to see).


CW

Actually, I’ve criticised Ecocert as well, as can be seen from other articles and features on this website. Common sense should tell you that because Ecocert does not have a base in the UK (it was founded in France), then of course I am going to focus mainly on the flaws of the principal organic inspection body in my own country! And considering the SA's high standing in the EU (and elsewhere), your organisation cannot afford to make too many mistakes.

The reason I had no choice but to put extra pressure on your organisation, by going public on this website, was because you and your colleagues stonewalled me for months in the hope that I'd go away quietly.

My repeated attempts to educate are being ignored by certain influential members of the herb and essential oil trades because, tragically, making money is far more important to such people than any concerns for the Earth and its poorest people. If you regard this as an unbalanced perspective and one that lessens my credibility, then clearly you and I are living on different planets!


FB

You say that 'several members of the ATC are also key members of the Soil Assocation'. I'm not sure what you mean by that. We have no control over who joins what organisation and there is no affiliation between the two organisations. If you mean our health products standards committee, then looking at the ATC website, I note that our committee includes individuals from two ATC members. I cannot see the significance in that.

CW

Yes, I do mean your health products standards committee. The two individuals you refer to are very important to the Soil Association, for they helped draw up the SA’s wildcrafting standards. Significant input indeed! Through their respective companies, alas, both individuals trade in threatened botanicals. And remember, you also invited two influential figures from the Aromatherapy Trade Council (ATC) to attend the same health products standards committee meeting attended by myself in June 2003 (one of whom is a seller of endangered aromatics from Asia and the Amazonian rainforest). Clearly, then, the ATC is meaningful to the aims of your organisation.


FB

Of course wild-harvesting being in the EU regulation doesn't make it a good law. We have lots of criticisms of the EU 'organic' regulation which is why we defend vehemently our right to make and uphold our own higher standards.

The definition of sustainable practice does not preclude the felling of trees - of course you appreciate it is not that simplistic. The point about sustainable practice, as you go on to say, is that whatever harvesting or other practices are carried out can continue indefinitely without imbalance. This may involve felling trees but obviously only as much as a) can be replaced by the natural regeneration, and b) does not adversely affect the rest of the ecosystem.


CW

The problem is, as I’ve oft repeated, no one has yet established exactly what constitutes a sustainable harvest for the different species of slow-growing wild trees felled for essential oil production. If we did have such knowledge, then sandalwood and rosewood, for example, would not have become threatened. In truth, you are paying lip service to an ideal rather than recounting reality.

A step in the right direction would be for SA Cert to de-certify Atlas cedar oil. Awarding organic status to botanicals from such fragile wild sources gives everyone the wrong message and undermines the integrity of the organic movement.

See latest report from New Scientist (Oct 2005) which dispels the Soil Association's (and others) notion of 'sustainable' selective logging of old-growth forest.