Aquaponics As A Sustainable Farming Practice In The European Union: New EU Regulations For Organic Aquaponics

Under the new Commission Regulation (EU) 2018/848 which will enter into law in January 2022, aquaponics produce cannot be certified as organic in the European Union. Given the multiple components of an aquaponic system, which involve growing plants in hydroponic conditions, recycling fish waste, and raising fish in artificial conditions, the achievement of organic certification for aquaponics produce is a complex matter dictated by many parameters.

Introduction

Today, more than 820 million people do not have enough food, with more than one in every five children under the age of five being stunted (United Nations 2019). Our food systems are failing, and the COVID-19 pandemic is making things worse: UN Secretary-General António Guterres said on 9 June 2020 that the world is on the brink of its worst food crisis in 50 years (The Guardian 2020).

Better social protection for poor people is urgently needed as the impending recession following the COVID-19 pandemic puts basic nutrition beyond their reach (United Nations 2020b). This is resulting in the global food industry searching for more sustainable and accessible systems for the production of healthy food, particularly fresh vegetables, and fruit.

Vertical farming techniques such as hydroponics and aquaponics that maximize output and minimize the use of resources (space, soil, and water) emerge as the best candidates to address this problem. Aquaponics is an innovative food production method that involves the farming of fish and other aquatic animals and plants – mostly vegetables and herbs – together in either coupled (closed-loop) or decoupled1 systems.

In coupled aquaponic systems, the waste from the fish is converted by bacteria that occur naturally in the water into nutrients for the plants, which absorb them, thus cleaning the water for the fish and thereby forming a full recirculation cycle (Somerville et al. 2014:4). Due to its integrative character, aquaponics is a complex food production technology that can address the three pillars of sustainability: environmental, economic, and social (König et al. 2016).

In 2015, the European Parliament included aquaponics as one of the ten technologies that could change people’s lives, praising the innovative technology based on its waste recycling and circular economy principles (van Woensel et al. 2015). The European Parliament also pointed out that aquaponic systems can contribute to growing local food sustainably, given the reduction in resource consumption that is associated with coupled fish farming and vegetable cultivation (Sanders 2013).

The reputation of aquaponics as a way to produce food sustainably has quickly spread in the past decade, with European Parliament resolution 2017/2118 (INI) calling on the Commission and the Member States to ‘promote innovative and environmentally friendly technologies in aquaculture, such as aquaponics, in order to produce food in a sustainable and resource-efficient way and to avoid negative impacts on the environment.

Aquaponics is also mentioned as a research and funding priority in the ‘Report on technological solutions for sustainable agriculture in the EU’ (McIntyre 2016) and is considered as a new revolution in food production in the 2014 European Commission amended budget (European Commission 2014b).

In spite of such recognition, research in aquaponics is still in its infancy, which is reflected by the significantly lower number of peer-reviewed publications on aquaponics compared with aquaculture, hydroponics, and green roofs. By contrast, aquaponics maintains its popularity amongst the general public, boasting a high number of results on Google – in this regard, aquaponics has been termed an emerging technology and science topic (Junge et al. 2017).

Although aquaponic technology is considered to be a sustainable way of producing plants and fish (Somerville et al. 2014), its position in the market is seen to be hindered by EU regulations. These regulations make it difficult for producers to market their products effectively and thus maximize profits, which would create a stable and sustainable future for aquaponics (Kledal et al. 2019).

Given the steady growth and popularity of organic produce in the EU, it is speculated that organic certification of aquaponic produce could help with its marketability and commercialization (Kledal et al. 2019). This would occur by using the organic price premium as one way to reimburse the high capital investments required for commercial aquaponics (Kledal et al. 2019).

In fact, a 2015 consumer report notes that organic produce is 47% more expensive (Marks 2015). Whilst this additional cost does not necessarily equate to profit, as organically produced yields may be lower and production costs higher, there is the assumption that at least some of this 47% would be additional profit.

Furthermore, the organic certification label seems like the natural choice for a market positioning, given the environmentally friendly and sustainable characteristics of aquaponics. This is also in light of what most people understand an organic label to mean: high standards of animal husbandry and free from pesticides and inorganic fertilizers (Denver et al. 2019; Lee et al. 2019; Thøgersen et al. 2019).

There are many advantages of using aquaponics from the perspective of sustainability, most notably: low water usage, little to no chemical usage, no use of synthetic fertilizers or pesticides, and recycling of waste (Goddek et al. 2015), the latter presenting a potential solution to the environmental problems caused by the eutrophication of aquatic ecosystems (Kledal et al. 2019).

Given these attributes, it would seem logical, at least from the point of view of the general public, for aquaponic produce to be certifiable as organic. However, two aspects of the technology currently prevent this. The first aspect is the integration of two distinct production methods, namely horticulture and aquaculture, both of which come with their respective regulations for organic production.

This is exacerbated by the fact that crop production and aquaculture are administered by two separate Directorates-General of the European Commission, DG Agriculture and Rural Development (AGRI) and DG Maritime Affairs and Fisheries (MARE). The second aspect is the agro-industrial set-up aimed at using technological advances in order to increase production, as opposed to the organic agro-ecological one which aims to accommodate such advances for the progression of ecological principles (Kledal et al. 2019).

Aquaponics is not included in the EU organic agriculture certification scheme, as it is considered a type of hydroponic technology, and hydroponics is not allowed in organic farming. Furthermore, from January 2022 a key prerequisite for organic agricultural production is for plants to be grown in soil that has a direct connection with the subsoil and bedrock.

Additional rules that prevent aquaponic produce from being certified as organic include the exclusion of raw fish waste (‘manure’) used as fertilizer for crops and the use of recirculating aquaculture systems (RAS) which is a core component of coupled aquaponics. Laws that prevent organic certification of aquaponic products in the European Union are not shared by countries such as the USA and Canada, where hydroponic/aquaponic products can be certified as such.

This review explores the new rules implemented in Regulation (EU) 2018/848, their relationship with the underlying principles of organic production, the perceived reasoning behind each rule, the apparent inconsistencies in the rules, and potential ways forward which could be taken in order to lobby for organic certification for aquaponic produce.

We argue that aquaponics already possesses all the qualities and features needed to be included in organic certification and that the few obstacles that currently prevent this are either based on bad science or are unsupported by any solid scientific proof. Although further research is needed, amendments to conventional aquaponics systems could potentially solve most of these barriers. Modifications such as the addition of soil and the use of environmental enrichment practices in recirculating aquaculture systems could in fact bring aquaponics closer to organic certification, even with the current rules.

The organic movement and EU regulatory frameworks

Organic agriculture, whilst still occupying a niche sector within agricultural production, has gone through different stages in its evolution. Organic 1.0 has been defined by Rahmann et al. (2017) as the period during which the organic agriculture vision first developed. The organic movement began in the early 20th century in reaction to increasingly intensive farming methods and the growing use of synthetic fertilizers.

As a holistic, ecologically balanced approach to farming, the pioneers of organic agriculture focused on finding natural ways to improve and maintain the health of the soil. The movement grew in the 1970s as more people became interested in their own health and that of their environment, and in the 1980s and 1990s, production and consumption increased, official standards defining organic produce were formulated, and grant aid for organic farming was introduced in the European Union.

Organic 2.0 has developed in the last three decades, and during its fast growth, it has brought the establishment of organic research institutions, associations, and regulations. Organic 3.0 refers to the current period, in which organic agriculture has diffused globally and contributes to solving global challenges of agri-food systems (Rahmann et al. 2017).

In the EU, the organic sector is worth approximately €27 billion – an increase of 125% compared with 20 years ago – with a land expansion rate at around 400 000 hectares per annum (European Commission 2017); in 2018, organic farming covered 13.4 million hectares of agricultural land, which corresponds to 7.5% of the total utilized agricultural area of the European Union (Eurostat 2020).

The rapid diffusion of highly intensive organic production systems over the last decade has sparked discussion on the principles of organic farming amongst producers, consumer associations, and policymakers of the organic sector (Tittarelli 2020).

Whist organic agriculture standards vary around the world, they are all based on several underlying principles, namely the health of the soil, conservation of biodiversity, and minimization of resource use, as defined by the International Federation of Organic Agriculture Movements (IFOAM 2014:13)2 :

Organic Agriculture is a production system that sustains the health of soils, ecosystems and people. It relies on ecological processes, biodiversity and cycles adapted to local conditions, rather than the use of inputs with adverse effects. Organic agriculture combines tradition, innovation and science to benefit the shared environment and promote fair relationships and a good quality of life for all involved.

In the EU, the current regulatory framework in place for organic fish and vegetable production is regulated by Council Regulation (EC) No. 834/2007, whereas more detailed regulation standards are addressed by Commission Regulation (EC) No 889/2008 and Commission Regulation (EC) No 710/2009.

The newly published Council Regulation (EU) 848/2018 is a long-awaited update that will enter into force on 1 January 2022. These rules effectively repeal Council Regulation (EC) No 834/2007 and all the regulations based on it, including Commission Regulations (EC) No 889/2008 and (EC) No 710/2009.

The European Commission maintains that the new rules reflect the major changes that have taken place in the EU organic sector in the last twenty years, offering a simpler and more harmonized approach (European Commission 2017).

The drafting of new rules is based on a process of consultation and before making any regulatory decision the European Commission must consult with all EU countries, which happens through regulatory committees. Such committees provide the European Commission with updated information on the opinions of citizens and experts in the sector. Regarding organic production and certification, the main regulatory committees are the Expert Group for Technical Advice on Organic Production (EGTOP), the Committee on Organic Production, and the Civil Dialogue Group (CDG).

EGTOP was established in 2008, taking the place of several temporary ad hoc expert groups as a permanent group advising European institutions on various aspects of organic production, thus making sure that EU rules are proportionate and effective, whilst simultaneously keeping up with the rapidly advancing sector.

EGTOP also produces organic yield reports on a regular basis as well as assessments of EU countries’ requests for technical annex amendments of EU regulations and assists the European Commission in preparing policy initiatives and legislative proposals. Additionally, EGTOP coordinates activities and exchanges view with the EU member states. The views of EU countries on current and upcoming organic legislation are represented by the Committee on Organic Production, which serves as a connection point between the EU and the individual countries that constitute it.

The committee comprises representatives from all EU countries and, like EGTOP, it meets regularly to discuss suggested changes regarding regulation. The CDG is made up of representatives from a variety of different groups, such as environmental charities, NGOs, producer and consumer cooperatives, and trade unions. The CDG helps advise and monitor the organic policy developments of the EU Commission, whilst assisting the Commission in the formulation of legislative proposals and policy initiatives (European Commission, Co-operation and Expert Advice).

In 2013, EGTOP published a report titled ‘Final Report on Greenhouse Production (Protected Cropping)’, where the group reviewed Council Regulation (EC) No 834/2007 and proposed some specific production rules for organic greenhouses. Many of these recommendations have been included in the new Commission Regulation (EU) 2018/848.

The ones most relevant to aquaponics include the recommendation that soil fertility is provided mainly through slow-release fertilizers, the preservation of soil health by preventive means, the encouragement of the use of natural enemies, the recommendation of efficient water and energy use including restriction of artificial light use and maximization of renewable energy, the restriction of peat use and the prohibition of the use of containers for the cultivation of organic fruits and vegetables (EGTOP 2013; Schofield 2013).

The influence that the report had on the amendments that followed and were implemented in the new Commission Regulation (EU) 2018/848 is indicative of the need to evaluate and discuss the rules in place for amendments to be made in the future and to bring change that could allow aquaponics to be recognized as an organic food production technology.

The ‘organicness’ of aquaponics

The rules in Commission Regulation (EU) 2018/848 are based on the underlying principles of organic production, where every rule is based on one or more principles. These principles can be subdivided into three categories:

1. Environment
2. Plants & Animals
3. People

The environment category includes principles that deal with environmental protection, preservation of natural processes, and sensible energy usage. The plants and animals category deals with the high standards required for animal welfare and the preservation of good plant and animal health. The people category deals with the effects of organic farming on human beings, such as the effects on rural development, food safety, and product quality.

Overall, aquaponic produce is environmentally sustainable, respects natural cycles, employs high standards of health and welfare for the farmed organisms, is safe to eat, and can support rural and social development; this means that aquaponics embodies the true spirit of the principles of the organic regulation.

Besides fulfilling all the organic principles laid out in Commission Regulation (EU) 2018/848, with the exception of the principle of the preservation of soil function and long-term fertility which can be fulfilled with the adoption of soil, aquaponics fulfills the majority of the production rules, with the exception of six rules layers out in section 4. In fact, aquaponics minimizes environmental contamination (rule 1.6) through the recycling of waste, limits the use of fertilizers (rule 1.9.3), does not use mineral nitrogen fertilizer (rule 1.9.8), and encourages the use of natural enemies (rule 1.10.1) because of the impossibility of pesticide use that would harm the fish.

Furthermore, the optimal use of RAS in aquaponics guarantees a variety of advantages over aquaculture systems such as cages, which remain certifiable under Commission Regulation (EU) 2018/848. The escape of non-local species mentioned in rule 3.1.5.7 could have tremendous environmental consequences (Naylor et al. 2001; Thorstad et al. 2008), hence the rule for farming only locally present species (rule 3.1.2.1b).

The chance of an escapee is, however, only an issue when open aquaculture systems such as ponds or sea cages are used. In RAS, the chance of an escapee is effectively zero (Jeffery et al. 2011), thereby making the local species rule irrelevant. Whilst there are ways that some species may escape, for example through cleaning operations, the risk can be avoided through appropriate management and maintenance systems.

Besides the possible introduction of alien species, open aquaculture systems have other constraints, such as water resource use, a localized reduction in benthic biodiversity, changes in water flow, pollution, significant dredging of water bodies, and physical modification of land (European Commission 2016). In RAS, most of these issues are either absent or mitigated.

Aquatic organisms grown in RAS are separated from the aquatic environment and cause no damage to wild populations. An aquaponic system that employs optimal farming practices provides organisms with suitable and specifically tailored environmental parameters, and poses little to no risk to wild populations is completely in line with organic principles. The use of RAS in coupled aquaponics guarantees the impossibility of escape incidents (Jeffery et al. 2011). Whilst we believe that there are no 100% guarantees, these small risks can be managed through appropriate management practices.

According to rule 3.1.4.1(a), disease prevention shall be based on keeping the animals in optimal conditions, and the closely related rule 3.1.5.4 states that aquaculture systems must provide flow rates and physiochemical parameters that safeguard the animals’ health, welfare, and behavioral needs; both these rules are based on the principle of high animal welfare and reproduction standards. Such a position recognizes the importance for aquatic animals to express normal behavior and is in line with the principles of the ‘Five Freedoms’ concept stated by the Farm Animal Welfare Council (FAWC 1979).

In fact, there is substantial etiological, neuroanatomical and physiological evidence that fish are sentient creatures, although it remains controversial whether they experience feelings or emotions and are conscious of pain and fear (FAO 2019:2). RAS allows the farmer to closely monitor the fish for signs of diseases, as well as guaranteeing optimal water quality, flow, and exchange rates. In a closed system, all the relevant parameters that ensure fish health are checked for, and cleaning and disinfection of the premises are paramount to the success of the operation whilst also preventing potential disease outbreaks.

One of the advantages of using a RAS is the ability to guarantee that the farmed animals are kept in optimal conditions throughout the rearing process; this way, disease prevention is based on keeping the animals in good health. Whilst diseased fish grown in ponds, for example, can easily go unnoticed, thereby extending their suffering and increasing the risk of spreading the disease, fish grown in RAS can clearly be monitored for signs of disease, thus allowing for prompt response and treatment.

The use of RAS in coupled aquaponics provides the possibility of frequent health checks, application of optimal husbandry principles, and the complete control of welfare, feed delivery, and disease prevention (Nazar et al. 2013). Through RAS, good quality water, adequate temperature, and light conditions can be ensured, as required by rule 3.1.5.3.

Despite fulfilling both the organic principles of Commission Regulation (EU) 2018/848, with the exception of preserving soil function and long-term fertility and the majority of the production rules, aquaponics remains unable to produce food that can be certified as organic in the EU. The situation is different in Canada, where produce from aquaponic systems is currently certifiable as organic under standard CAN/CGSB-32.312-2018, which defines an aquaponic cultivation method as a system that ‘combines the cultivation of crops and livestock in a symbiotic relationship’.

Such types of multitrophic cultivation methods based on the recycling of nutrients are encouraged under Canadian standards, as stated in paragraph 6.1.4: ‘Nutrient cycling through practices such as Integrated Multi-Trophic Aquaculture is encouraged’. In the United States, the USDA National Organic Program (NOP) does not prohibit hydroponic and aquaponic crops from being labeled as organic and is granted the USDA Organic Status (USDA National Organic Program). This does not apply to aquaculture products, which remain excluded from organic certification, although, as reported by the USDA National Agricultural Library, the NOP is in the process of developing organic practice standards for aquaculture products (USDA National Agricultural Library).

Rules preventing organic aquaponic production

Although aquaponics is a highly sustainable system for food production (Goddek et al. 2015), several rules from Commission Regulation (EU) 2018/848 make the organic certification of aquaponic produce challenging (Table 2). In this section, these rules will be reviewed, their scientific foundations discussed and their relationship with aquaponics outlined. Given the hybrid nature of aquaponic systems, rules concerning aquaponic production are found in both the standards on crop production and aquaculture.

Rules on crops

Crop-related rules are listed in Annex II of Commission Regulation (EU) 2018/848; major stipulations which impact aquaponic produce are the use of living soil, the need for the soil in which the plants are grown to be in contact/association with the bedrock and subsoil and the maintenance and enhancement of soil fertility.

As stated in rule 1.1, the presence of a living soil connected with the subsoil and bedrock is a requirement for the organic certification of crops. This is the first time that a connection with the subsoil and bedrock is clearly stated in an EU regulation. Previous regulations, including Council Regulation (EC) No 834/2007 and Commission Regulation (EC) No 889/2008, do not mention such a connection.

It is, however, stated in the 2013 report from EGTOP ‘Final Report On Greenhouse Production (Protected Cropping)’ that in both regulations soil means ‘upper soil in contact with the subsoil, so that roots can grow into the subsoil’ (EGTOP 2013:30). Such definitions leave considerable room for interpretation and as a consequence, Commission Regulation (EU) 2018/848 clearly specifies the required connection, meaning that any soil-less production method or culturing technique in which soil is taken out of its natural origin and then used alone or mixed with something else cannot be used in organic farming.

Thus, soil effectively went from being considered a compositional entity to a spatial one, where the soil location and connection is, in part, what matters, rather than only its composition. The organic argument for the use of soil is that the vast majority of plants evolved to grow in soil, and the presence of soil in agriculture is thus one of the foundations of organic farming, where plants are grown in soil benefit from deep and complex biological processes that soil organisms provide through symbiosis and nutrient transformations (Magdoff & van Es 2009).

Such definitions of soil based on its direct connection with the bedrock rather than its composition are seen to be in line with the principle of respecting natural systems and cycles. This is because the vast majority of plants found in nature grow in soil that is in connection with the subsoil, although this does not offer any relevant farming advantages and is not based on any scientific principles. It is the topsoil section itself that stores the most organic matter and provides a highly fertilized environment for plants to grow in.

The subsoil, on the other hand, generally has low organic matter content, low oxygen, and can have high clay concentrations, although for perennial plants it can prove beneficial where the roots can reach deeper to absorb minerals over a longer period of time. This, however, is not the case in most standard farmed crops, which have short roots that are unable to reach the subsoil layer (Fan et al. 2016). The mandatory connection of soil with subsoil and bedrock also clearly excludes any method of production involving soil-less media from organic certification, as well as any soil, is taken out of the site where it naturally formed.

Sanders (2013) criticized the 2007 EU Commission Regulation for allowing certain countries to produce crops in raised/demarcated beds. According to the study, crops produced with such systems should not have been allowed to be certified as organic, as they render intensive production of vegetables in greenhouses permissible, which is claimed to be a production method that fails to respect natural systems.

The new Commission Regulation (EU) 2018/848 reflects this claim, forbidding the use of raised/demarcated beds in organic farming, as well as adding the connection with the subsoil and bedrock as a requirement for the organic certification of crops (rule 1.5). It appears that not only is the composition of the soil not taken into account as long as the required connection with the subsoil and bedrock is fulfilled but that the regulation offers no specification on its living part either.

In fact, whilst crop farming must take place in living soil to be organic (rule 1.1), a definition of living soil is not given in the whole regulation, and it could be argued that virtually all topsoils on earth are living soils, since virtually all topsoils host some organisms and exhibit some kind of biological activity. Whist in Annex II, part 1 of the regulation soil needs to be living, in Article 3 (70) soil can also be non-living, as long as it is fertilized with materials and products that are allowed in organic production and connected with the subsoil and bedrock.

This can be a cause of a great deal of confusion since without a clear definition of what living soil is and with differing points of view regarding the regulation, recreating a living soil that is allowed to be considered organic can be a difficult challenge. As coupled aquaponic systems do not use soil and have no complex soil ecosystem providing the plants with most of the nutrients they need, rule 1.1 excludes aquaponic produce from organic certification.

Even if soil-based aquaponics were to be used, it would be de facto impossible to realize a coupled aquaponic system without containers detached from the soil where plants grow, except for growing herbs and ornamental plants (rule 1.4); this is assuming that fish waste was allowed to be used as a nutrient for the plants, which it is not. This makes all produce from coupled aquaponic systems, where water from the plants is returned to the fish units and that do not grow herbs or ornamental plants, automatically excluded from organic certification.

One of the obvious benefits of using soil detached from the subsoil and bedrock layers is the possibility of cultivating produce away from rural areas and closer to population centers where the technology offers a highly scalable means of food production which can take place close to or within the city boundaries. Producing food near to or within cities greatly reduces the carbon and ecological footprints of food production create a city food identity and enhances the connection that people have with food and the way it is grown (Hui 2011; Ackerman et al. 2014). This rule thus hinders the development of food production systems away from rural areas, in line with the principle of rural development.

Whilst the principle may be laudable in some cases, it contradicts current attitudes and policy, where agricultural land needs to be used not only to produce food but also to provide public goods and services, and in some cases, this means rewilding the land and not producing food. On the other hand, food still needs to be produced and it does appear arbitrary that unproductive peri-urban and urban land cannot be used for organic production because rural landscapes are prioritized.

An exception to rule 1.1 as noted previously is given to ornamental plants and herbs, which can be sold in pots to the end consumer, and for growing seedlings or transplants, which can be grown in containers for further transplanting, as specified in rule 1.4. This topic was addressed by EGTOP (2013) in their report years before the new mandatory connection with the subsoil and bedrock and its exceptions were introduced.

In the report, the authors made the claim that growing plants in a ‘horticultural substrate’ should be authorized for ornamentals, herbs, seedlings, and transplants. This claim was consequently added to the new Commission Regulation (EU) 2018/848. Based on the EGTOP report, the principle behind this exception is that the consumer cannot be misled about the production method of potted herbs and ornamentals, which can be bought in pots. This way, consumers are sure that the plant that they are buying was grown on a substrate.

Another practical reason is that the consumer can grow such plants at home, keeping them in the pots that came with the plants on purchase. This is in contrast to produce that is harvested out of sight of consumers, in which case EGTOP adds that it ‘should always come from plants grown in soil, and not from horticultural substrate cultures’ (EGTOP 2013:30). Such practical reasons effectively seem to supersede the principle of respecting natural systems and cycles, which effectively goes from being a pillar of organic farming, as found in Article 5 of Commission Regulation (EU) 2018/848, to a statement that can be supplanted by any reason that can make the selling of produce more practical.

The inclusion of seedlings or transplants in the exception is likely to be a way of facilitating the production of plants in systems that would maximize their production in their early stages. This is similar to the aquaculture rule that prohibits the use of RAS (Recirculating Aquaculture Systems) with the exception of hatcheries for the production of fingerlings that are then transferred to grow-out facilities (rule 3.1.5.1 – see below).

Culturing seedlings in containers makes the process of transplanting them much easier, given the possibility of transplanting the root system encapsulated in the container to a grow-out system. An equivocal point is that the exception does not add any specifications on the type of culturing methods that can be used to grow herbs, ornamentals, seedlings, and transplants. In the EGTOP report (EGTOP 2013) the term ‘horticultural soil’ is used, which leaves room for interpretation as there is no clear definition of horticultural soil given in the report.

Furthermore, in Commission Regulation (EU) 2018/848 there is no mention of the type of culturing methods or substrates allowed for producing these horticultural varieties. Whilst it is uncommon to see aquaponic produce that has been grown in pots, coupled aquaponic technology does allow the production of plants in pots filled with soil or other media, as shown by Palm et al. (2019), who successfully grew ornamental plants (Hedera helix) in the soil in an aquaponic system. It is most likely that the effects that such systems would have on the growth and well-being of plants and fish will be benign, but this has yet to be investigated.

This principle not only allows the organic certification of herbs and ornamental plants grown in pots, which constitutes an exception to the necessary connection with the bedrock and subsoil (rule 1.1), but it also allows these plant categories to be grown in inert media. In fact, following a request for clarification, the European Commission responded that ‘ornamentals and herbs can be produced not only in living soils as laid down in point 1.1. but also in pots to be sold in pots to the consumer with or without soil’ (Nathalie Sauze-Vandevyver, pers. comm., 2020).

This would indeed mean that for such plant types soil would not be needed and that any type of substrate material that is allowed in organic farming could essentially grant herbs, ornamentals, seedlings, and transplants organic status. Since the organic culture of these varieties can take place with or without soil, it would appear that hydroponic technology should be allowed for growing herbs and ornamental plants. Hydroponic technology is, however, clearly not allowed (rule 1.2), and herbs and ornamental herbs are only exempt from rule 1.1, but not 1.2. Further clarifications are needed on the type of substrates that are allowed for the culturing of such varieties, as well as whether a substrate is needed at all.

Conventional soil-less aquaponic systems are based on hydroponic farming, which is prohibited and not certifiable as organic (rule 1.2). Hydroponics is a highly controlled food production method (FAO 2020) that relies entirely on the continuous supplementation of artificially sourced inorganic nutrient solutions and on tightly controlled water parameters (Jensen 1999). As such, hydroponic technology goes against the organic principle of respecting natural systems and cycles, as plants that do not grow naturally in water are cultivated with their roots in/partially in the water.

The nutrients that are added to the solution are not present in that form in the farming environment. Whilst aquaponics is not directly mentioned in the regulation, conventional soil-less aquaponic systems are based on hydroponic technology, and their products cannot, therefore, be granted organic status. Besides the link between the two technologies, they are, however, based on entirely different principles.

In contradistinction to hydroponics, in aquaponics, there is no need for any mineral nitrogen fertilizer, the use of which is not allowed in organic production, as reported in rule 1.9.8. In aquaponics, all the nitrogen needed by the plants is supplied through the fish waste, which is converted by the bacteria which form naturally in the system into forms readily absorbable by the plants (Somerville et al. 2014).

According to the definition of Francis et al. (2003) on sustainable agricultural production being achieved through the design of systems that close nutrient cycles, aquaponics is a highly sustainable technology that not only respects natural systems and cycles but is based on, and works by, applying principles found in nature. Effectively, aquaponics mimics nature by making use of naturally occurring processes and the cycling of nutrients that occur in water ecosystems. Therefore, whilst aquaponics is based on hydroponic technology, the exclusion of aquaponics from organic certification is unjustifiable under the principle of respecting natural systems and cycles.

From the mandatory use of soil introduced in rule 1.1, further specifications on its management arise. As stated in rule 1.9.2, the fertility and biological activity of the soil must be maintained and increased in organic production in all cases by the application of livestock manure and organic matter from organic production and in the case of greenhouse crops, by the use of short-term green manure crops, legumes and plant diversity.

This rule is based on the principle of respecting natural systems and cycles, thus relying on naturally occurring processes such as the use of legumes for the production of nitrogen (Shah et al. 2003) and the use of livestock manure to increase soil fertility. Organic greenhouse production is characterized by extreme nutrient demands within short growing periods (Zikelia et al. 2017). Through this rule, the nutritional needs of plants are intended to be fulfilled by substituting off-farm synthetic inputs, which are generally used in conventional agriculture, with off-farm organic inputs.

This substitution of synthetic fertilizer with organic fertilizer has been considered as an imitation of conventional agricultural practices (Contreras et al. 2014). Zikelia et al. (2017) have criticized this input substitution approach, stating that all soil fertility approaches in organic greenhouse production lead to high element imbalances, especially the ones based on compost and farmyard manure. Observed imbalances, such as a high accumulation of phosphorus, and increased soil pH, salinity, and organic matter concentration, all negatively affect the long-term sustainability of the system. Since solid livestock manures and composts exhibit an unbalanced nutrient composition, it is impossible to achieve a balanced system by their application.

Suggested practices in organic regulations, such as soil tillage practices, crop rotations, organic amendments, and agro-ecological services crops are only effective when applied to less intensive systems (Tittarelli 2020). Additionally, the use of any fertilizers – on the land, organic or inorganic, within and outside greenhouses – can threaten underground as well as surface water quality, where these nutrients end up in streams and rivers. Aquaponic technology is based on the use of fish waste (‘manure’) as a source of nutrition for plants.

In Commission Regulation (EU) 2018/848 some fertilizers can be used as an input in organic production, provided that they are authorized in accordance with Articles 9 and 24 and listed in an implementing act provided for by Article 24(9). The use of manure in Commission Regulation (EU) 2018/848 is restricted to livestock manure, as there is no mention of fish manure.

In fact, following a request for clarification, the European Commission responded that ‘fish raw manure is not mentioned in Annex I to Regulation (EC) No 889/2008, therefore, its use is at present allowed in organic production (Nathalie Sauze-Vandevyver, pers. comm., 2020).

However, as fresh fish manure is similar in its chemical composition to other livestock manures, it is suitable for use as a fertilizer (Naylor et al. 1999), and its use should be allowed in organic farming. The use of fish manure as nutrition for the plants is also in line with the principle in Commission Regulation (EU) 2018/848 (article 6c): ‘the recycling of waste and by-products of plant and animal origin as input in plant and livestock production.

Rules on aquaculture

Aquaculture-related rules are listed in Part III of Commission Regulation (EU) 2018/848. The main stipulations which impact aquaponic produce are the prohibited use of recirculating aquaculture systems (RAS), the contained use of energy, and the implementation of measures that render the culturing environment as close as possible to the natural environment of the cultured species.

Perhaps the biggest constraint to the certification of aquaponic produce as organic, at least from the point of view of aquaculture, is the prohibited use of recirculating aquaculture systems, or RAS, as stated in rule 3.1.5.1; the rule however contains the exception of the use of RAS in hatcheries and nurseries or facilities for the production of species used for organic feed organisms. This rule is based on two main principles: firstly, RAS are artificial systems that do not resemble natural environments, and secondly, these systems are highly energy-dependent.

Whilst this is often true, closed recirculation aquaculture facilities provide several advantages over traditional and extensive culturing methods. Complete environmental control and optimal parameters for the growth of many different species can be set and monitored for the well-being of the animals. Aeration, water current, temperature, pH, salinity for saltwater and brackish species and light can in fact all be tailored based on the biological needs of the farmed animals and with much more control than in pond and raceway farming systems.

The principle of responsible use of energy and natural resources also underpins rule 3.1.5.2, which prohibits the artificial heating or cooling of water, except for hatchery and nursery facilities. Whilst RAS generally require a higher energy cost in order to ensure that the animals are grown at the highest standards possible, the rule fails to acknowledge that such cooling and heating can be produced using renewable sources.

In fact, for small greenhouses, solar energy can be readily harnessed in order to run climate control systems or to provide passive heating. In countries such as Iceland or Japan, near-surface geothermal energy can be used to sustainably heat or cool water (Goddek et al. 2015). In fact, in Iceland geothermal energy is used to grow many varieties of vegetables in greenhouses, which would otherwise be impossible to grow (Butrico & Kaplan 2018). A further option is to use wastewater heat from combined heat and power units to heat up or cool down greenhouses.

Such units are generally found in combination with agricultural biogas plants, where surplus heat is plentiful (Goddek et al. 2015). If renewable energy for the manipulation of water temperature is used, the principle of responsible use of energy is fulfilled, and there is indeed no reason why artificial heating or cooling of water for grow-out aquaculture operations should not be allowed. Especially given the permitted use of natural borehole water to heat or cool water for all stages of production, there is no logical reason why geothermal borehole water should not be allowed to be used for controlling the water temperature through the use of heat transfer pump.

By manipulating the water temperature artificially, optimal conditions for the growth of any species can be achieved, thereby minimizing temperature fluctuations that are observed in extensive aquaculture systems that are currently allowed in the regulation, such as ponds and sea cages, thus contributing to the well-being of the farmed animals. In conclusion, artificial heating and cooling of water for the grow-out phase of aquatic organisms should be allowed, depending on the nature of the energy production method.

A categorical exclusion of all kinds of artificial cooling or heating of water, regardless of the amount of energy consumed and the way that energy is produced, is based on general principles that fail to take account of the developments in sustainable energy provision in the modern world, including photovoltaics (solar power), solar water heating, wind power, ground source heat pumps, geothermal heating, and CHP (Combined Heat and Power) plants. The use of RAS in coupled aquaponics provides the option of readily controlling water parameters, including water temperature (Nazar et al. 2013).

In order to limit or avoid expensive cooling or heating of the system’s water, aquaponic growers should consider culturing fish and plant species that are suited to the local climatic conditions. In fact, by farming species that better conform to the available parameters, energy consumption can be lowered. Forbidding the artificial heating and cooling of water for juvenile and adult aquatic organisms greatly limits the possibility of produce from aquaponic farms being certified as organic. In fact, a stable water temperature is essential in aquaponics, as fluctuations in temperature can harm not only the fish but also the plants and nitrifying bacteria (Goddek et al. 2015).

Whilst stable conditions are achievable in equatorial areas without additional technology, the artificial heating and cooling of water are vital for aquaponic farms in regions with seasonally changing climatic conditions, as well as in hot and arid areas (Goddek et al. 2015). Controlling the water temperature through artificial means can guarantee optimal welfare for the aquatic organisms and reduce stress in both aquaculture and plant species by limiting temperature fluctuations. If done sustainably, the artificial control of water temperature can result in a ‘green’ method of food production that respects the health of the farmed organisms.

Another rule that hinders the organic certification of aquaponics produce is rule 3.1.5.3, which states that for freshwater fish the bottom type must be as close as possible to natural conditions, and in the case of ‘carp and similar species, the bottom must be natural earth. This rule also refers to the principle of respecting natural systems and cycles, as well as the principle of high welfare and reproduction standard.

Although tanks used in RAS can be modified to increase the complexity of the environment through a practice known as environmental enrichment (see section 5.2), it is assumed that ‘as close as possible to natural conditions’ means that the bottom type must be part of a natural system, rather than an artificial one. The specification of natural earth bottom for ‘carp and similar species’ is rather ambiguous.

In fact, most cultured fish species are incredibly distant phylogenetically from one another, and grouping all freshwater fish together and asserting that the bottom type should be similar to the bottom type observed in their natural environment is an unsubstantiated generalization that is based on the idea that natural surroundings provide the fish with a perfect environment at all times. In the case of tilapia, a highly territorial and potentially aggressive species, enriching the farming environment and bottom type to resemble their natural conditions increases fighting amongst individuals, as it raises the value of their territory (Gonçalves-de-Freitas et al. 2019).

Even if freshwater fish could indeed all be grouped together and assumptions could be made that bottom types that resemble natural conditions would improve their welfare, it is not clear why saltwater fish would be excluded from such a rule. In fact, many benthic and demersal saltwater fish species are cultured as well; these species, such as flatfish like halibut and sole, heavily rely on the bottom type. In the case of ‘carp and similar species, the rule adds that the bottom must be natural earth.

What ‘similar species’ the authors of the standards are referring to, and how a species is judged as being similar to carp, is unclear. The practice of modifying the bottom type and adapting it to the natural condition of the cultured aquatic organisms falls into the nature-based concept of environmental enrichment practices. This approach aims at increasing fish welfare by rendering the culturing environment as close as possible to the environment the organisms naturally live in (Näslund & Johnsson 2016).

However, this approach is most useful when the fish are conditioned to be then released into the wild, and less so for organisms that were likely not adapted to natural conditions due to domestic selection (Newberry 1995). Furthermore, whilst this assumption makes logical sense, conclusions in science must be based on experimental results, which in this case are lacking. The assumption that freshwater fish enjoy better welfare when cultured in bottom types that resemble their natural environment is yet to be proven, especially because best welfare practices differ between species, and freshwater welfare indications should not all be placed together in the same group.

This rule hinders the certification of aquaponic produce by posing a further limit to the use of RAS. Nevertheless, the high versatility of RAS can allow for tank modifications, including bottom type. In fact, the tank environment in RAS can be modified to include different kinds of substrates, tank covers, surface colors, natural lighting, objects, and even ‘toys’ (items that the fish may be interested in), in order to improve the welfare of the cultured animals.

Discussion

This analysis of the new organic regulations reveals that several wrongful assumptions have been made, which result in illogical and biased legislation that hinders the development of science-based agricultural production. In all cases, such wrongful assumptions do not seem to be based in science, but rather on an unchecked extension of the organic principles to areas that are unproven, and for which a clear explanation is often not given. An example can be found in rule 1.1 on the required connection with the subsoil and bedrock, which is based on the concept that since such a connection reflects what is often found in nature, it must promote a sustainable and ‘green’ farming approach.

Instead, this rule effectively prevents the growing of produce from truly sustainable technologies such as aquaponics, based on waste recycling and other sustainable principles, from being certifiable as organic. Sweeping generalizations are also often made throughout the regulations, which result in rules that fail to illustrate logical sense and result in unjust exclusions. With regard to organic certification and soils, it is apparent that these regulations have been made to protect the interests of the organic farming community.

Whilst this protectionism does not apply to aquaculture, the effect is the same, as the regulations stop the advance of science and technology. Examples of rules which are unverified by science include rule 3.1.5.3, in which all freshwater fish are considered to share a characteristic for which a ‘natural’ bottom type would be beneficial, and all saltwater or brackish-water fish species are excluded. Finally, several exceptions to other rules seem to contradict the principles upon which these rules are based.

Such is the case of rule 1.4, for which ornamentals, herbs, seedlings, and transplants are excluded from rule 1.1 and its mandatory connection with the subsoil and bedrock, effectively bypassing the principle of respect for natural processes and cycles in order to benefit the consumer and, of course, the producer. Such assumptions cause confusion, misinterpretation and result in innovative technologies such as aquaponics being irrationally excluded.

A revision of Commission Regulation (EU) 2018/848, taking into account the vast array of cultured species and science-based findings, and adopting clearer and further detailed rules would result in a more accessible, science-based system of certification, which would stimulate meaningful collaboration amongst scientists, producers, and consumers. Only if such a regulation were to be put in place would it then be possible for aquaponic produce to reach the organic status that it rightfully deserves.

Possible advances in aquaponic technology: an eye to the future

Soil-based aquaponics: a possible solution?

Developing soil-based aquaponics systems where plants are cultured in soil instead of inert media or water could provide a pathway to organic certification for aquaponic fruit and vegetables. To do this, the inclusion of soil in aquaponics needs to be tested in order to find the best design for this novel culturing method, taking into account the seemingly indissoluble link with soil that organic certification requires.

Whilst the use of soil would not automatically guarantee organic certification for products due to the lack of connection with the subsoil and bedrock and the forbidden use of fish waste as a fertilizer, it could fulfill the requirement for plant nutrition coming primarily from the soil ecosystem, as found in paragraph 28 of Commission Regulation (EU) 2018/848.

Whilst a definition of nutrition through the soil ecosystem is not given in the regulation, the addition of nutrients by the use of materials listed in Annex I to Commission Regulation (EC) No 889/2008 is permitted and represents the type of substances that are allowed to increase the fertility of the soil. Given the statement by EGTOP (2013:15) that ‘soil fertility and an active soil ecosystem are the basis for plant nutrition in organic systems, the addition of fertilizers allowed in organic production is aimed at providing the soil with the nutrients that the plants need and is therefore considered to be part of the fertility generated by the soil ecosystem.

Following the definition of aquaponics by Palm et al. (2018), for a culturing system to qualify as aquaponic, the majority (>50%) of the nutrients sustaining plant growth should be derived from waste originating from feeding the aquatic organisms. Therefore, in order for aquaponic produce to be given organic status nutrients should come primarily from the soil ecosystem, which can only be achieved if fish waste is recognized as a viable source of fertilizer for the soil.

On the production side, soil inclusion could play a role in solving the long-held problem in conventional aquaponics of the differing water parameters (most notably pH) between the plant and fish units, which has been argued to produce fish and plants in sub-optimal conditions (Palm et al. 2019). In fact, there is potential for soil to possibly act as a buffer, maintaining a relatively acidic environment in the plant unit, whilst maintaining a relatively alkaline environment in the fish and biofilter units.

Experiments are needed in this field, especially in order to determine the influence of soil ingress into the water on fish health in coupled aquaponic systems. Furthermore, the inclusion of soil in aquaponics would make the addition of beneficial soil organisms possible, which could, in turn, improve the overall condition of the soil, keep the plant rhizome healthy, and benefit the plants by enhancing the availability of nutrients, a practice that is allowed by Commission Regulation (EU) 2018/848 (rule 1.9.6).

Beneficial soil microorganisms include mycorrhizae (symbiotic associations between soil fungi and plant roots) and beneficial soil bacteria that are already naturally present in the soil and benefit most plants today (Adams et al. 1998). However, the impact that additions of microorganisms would have on soil-based aquaponics systems is yet to be investigated. An analysis of soil microbial community changes, when exposed to fish water, could reveal the role of such microorganisms in the production of nutrients available to the plants. The effects on the fish also need to be investigated based on the principle of high welfare standards, to ensure that fish well-being is not compromised in soil-based coupled aquaponic systems.

Environmental enrichment in RAS

A greenhouse aquaponics system can provide the farmed organisms with optimal growing parameters, high welfare standards, and lower energy consumption through the adoption of renewable energy sources, thus allowing the farming of species adapted to local water parameters. In Canada, aquatic organisms grown in RAS can be certified as organic, as stated in paragraph 6.8.3 of standard CAN/CGSB-32.312-2018: ‘Recirculation systems are permitted if the system supports the health, growth, and well-being of the species’. This is in contrast with the EU, where animals grown in RAS are not allowed to be certified as organic.

Commission Regulation (EC) No 710/2009 (paragraph 11) states that