African Organic Product Standards for the African Continent? Prospects and Limitations

Organic agriculture is a sustainable agricultural system with high environmental protection and animal welfare. In 2015, the world organic agriculture covered 50.9 million hectares with Oceania as the biggest regional producer with 22.8 million hectares and Africa as the least regional producer (1.7 million hectares). While organic agriculture may not be the only solution for African farming, it aligns with sustainable economic development and does not involve chemical inputs. Whereas there are different private standards, not all African countries have national organic standards and there are no pan-African organic standards. This paper discusses the need to address the proliferation of organic standards as a trade barrier through pan-African organic standards and inspire the development of harmonised domestic standards. It examines the prospects for pan-African organic standards, their limitations and makes recommendations for the making, the contents and implementation of such standards domestically and national measures to support African organic agriculture.


Introduction
One of Africa's biggest challenges is to feed its 1.2 billion population with worsening effects of climate change, effects of globalisation and rising food prices. 1 Feeding Africa's rapidly growing population will require sustainable agricultural systems which provide food as well as economic value. 2 Conventional and high-intensity agricultural systems while being highly productive have a price tag with non-renewable external inputs associated with greenhouse gas emissions that adversely impact on climate change, soil fertility and ecosystems. 3 In contrast, green agricultural practices use sustainable agricultural techniques which potentially avoid additional costs that may arise as a consequence of unsustainable practices. 4 Adopting a sustainable agricultural system is of utmost importance for Africa which is said to have more than 500 million hectares of degraded arable land. 5 Organic production as a green agricultural practice, targets the development of a sustainable cultivation system based on environmental protection and high standards of animal protection. 6 Organic agriculture is a relevant tool to advance the Sustainable Development Goals (SDGs) on sustainable agriculture, sustainable consumption and production, climate change and ecosystems adopted under the aegis of the United Nations (UN) in view of the "2030 Agenda for Sustainable Development". 7 In 2015, the world organic agriculture covered 50.9 million hectares with Oceania as the biggest regional producer (22.8 million hectares) and Africa as the least regional producer (with an estimated 1.7 million hectares). 8 Africa as the smallest world producer of organic products has certified organic farms for national and export markets albeit a more important share of informal organic farms for subsistence and local markets. 9 Due to consumer preferences in developed countries, there is an increasing demand for organic products 10 and there is potential for the growth of organic agriculture in Africa. 11 Organic markets nonetheless demand high quality products and farmers need to meet certification requirements.
Whereas there is no international treaty to regulate organic agriculture, the following guidelines provide guidance for standards regarding the production and marketing of organically produced foods. The Codex Alimentarius Commission Guidelines for the Production, Processing, Labelling and Marketing of Organically Produced Foods 12 (hereafter the "Codex Alimentarius Guidelines") were developed to facilitate the harmonisation of requirements for such products at the international level and assist in drafting national organic standards. 13 The United Nations Conference on Trade and Development (UNCTAD)-United Nations Environment Programme (UNEP) Best Practices for Organic Policy 14 and the Organic Equivalence Tools 15 also serve as international guidelines. Apart from such voluntary international guidelines regarding organically produced foods, there are private organic standards drafted by private certification agencies 16 worldwide as well as organic standards in more than 60 countries. 17 The main regional organic standards are currently the European Union (EU) organic standards, 18 the East African Organic Product Standards 19 (EAOPS), the Pacific Organic Standard 20 (POS) and the Asia Regional Organic  Standard 21 (AROS). The EAOPS represent the first multi-country organic standards in Africa harmonising existing organic standards and practices for five African States. 22 An African Organic Agriculture Training manual developed by the International Federation of Organic Agriculture Movement (IFOAM) and African Organic Agriculture Movements 23 aims at delivery of best farming practices to farmers and related workers. Pan-African organic standards are yet to be developed. Since not all African countries have national organic standards, there is inadequate regulation of organic products in the African continent. 24 Available literature discusses potential routes of development for African agriculture, 25 organic agriculture and its impacts on the environment 26  security, 27 and the development of African standards for biotechnological products 28 but no literature is available on the development of pan-African organic standards. After a brief overview of organic agriculture in Africa, this paper discusses the need to address the proliferation of organic standards as a trade barrier through pan-African organic standards which may inspire the development of harmonised organic standards in African States. It examines the prospects of developing such organic standards drawing inspiration from the EAOPS and other regional organic standards as an African Union (AU)-led initiative in collaboration with international partners. It identifies the limitations of such organic standards and makes recommendations regarding the making, the contents and implementation of pan-African organic standards as well as national measures to support organic agriculture in African States.

Background on organic agriculture in Africa
Africa currently produces organic food and non-food organic products 29 focusing mainly on the cultivation of olives (Northern Africa), coffee, cotton, cocoa and palm oil (sub-Saharan Africa) with the EU as the main destination for certified organic products. 30 Although Africa is the least regional producer of certified organic products, it has a more important share of informal or noncertified organic farms which are mainly for subsistence and local markets. 31 Due to the lack of an official organic agriculture data collection in many African countries, certified organic production in Africa can only be approximately estimated. 32 In 2011, Africa's certified organic agricultural land area was estimated at over one million hectares while 16.4 million hectares of land were organic beekeeping, forest and wild collection areas. 33  Informal organic farms represent an important part of African farming. For instance, in South Africa, informal organic farming by small and subsistence producers is said to feed two-thirds of the population. 36 In Nigeria, 60 to 70 per cent of farmers are traditional rural farmers producing uncertified organic foods without synthetic inputs. 37 The following viewpoints regarding organic agriculture are prevalent in Africa. Much of African agricultural production is perceived as de facto organic since African farmers are often unable to purchase synthetic inputs. 38 Organic product standards tend to be considered as designed for the developed world and may not necessarily be appropriate for the developing world. 39 Applying foreign organic standards and certification to Africa's organic agriculture is considered by some as a form of "colonisation" of trade. 40 Yet it is necessary for farmers from the developing world to comply with high-value market rules if they wish to access international organic markets with a price premium. 41 Although the price premium on certified organic products may vary depending on the commodity or the market, 42 there are opportunities for African farmers to produce organic fruits and vegetables that cannot be grown (or are out of season) in Europe or North America. In 2002 the world organic agricultural land area covered 24 million hectares with a total sale of US$23 billion, reaching 50.9 million hectares in 2015 with a total sale value of $81.6 billion. 43 The potential for Africa to invest in organic agriculture with better access to 35 Lernoud export markets can be illustrated by the Ugandan experience 44 which transformed some of its conventional agricultural production into organic farming between 2002 and 2007. Empirical literature on the economic sustainability of certified export crops in Africa found that organic certification standards that enhance yields are important for improving farm revenues and household welfare. 45 The export potential of African organic agriculture can also be illustrated by the increase of regional trade for organic products for the East African Community (EAC) through the East Africa Export Programme industrialised agricultural systems. 51 Boosting organic agriculture in Africa together with better regulation of organic food production may arguably help Africa to confront its agricultural challenges and benefit farmers with better access to premium markets for certified organic products. 52 Whereas there are different private standards, 53 not all African countries have national organic standards and there are currently no pan-African organic standards. The certified organic product sector in Africa being currently driven by private standards, 54 the following section discusses the need for pan-African organic standards to address the proliferation of different private standards and inspire national organic standards in African States with harmonised standards.

The need for African organic product standards
While the certification of organic products with a price premium is based on organic standards, not all African countries have national organic standards 55 and there are currently no regional organic standards 56 at a pan-African level.
In practice, most of the certified organic production in Africa is certified according to the EU regulatory framework for organic products whereas other producers are certified according to the United States (US) standards or the Japan Agriculture Standards (JAS). 57 There are nonetheless different voluntary private standards for sustainable agricultural systems and it is mainly the private sector which undertakes the certification of organic claims in Africa. 58 Consequently African farmers wishing to start organic agriculture strive to comply with different requirements to access regional or international markets. Complying with one standard may lead to exclusion from other markets and this constrains the organic market development in Africa. Given the existence of different private standards and current lack of regulation of organic products in Africa, would it suffice to only encourage the development of domestic organic regulation in African countries? Encouraging African States to enact organic standards may give rise to different standards across the continent. 59 In contrast, developing pan-African organic standards and then encouraging national organic standards aligned with African standards appears to be a better solution for the current inadequate organic regulation. The need for pan-African organic standards seems justified considering the following. First, pan-African organic standards that are consistent with international standards would be useful in inspiring harmonised African national organic standards. Second, pan-African organic standards would allow African countries to define organic standards that are more relevant to specific climatic, agroecological and developing country conditions. 60 Third, pan-African organic standards would allow Africa to have a unified negotiating position in regional and international organic markets. 61 While organic agriculture may not be the only solution for African farming, it aligns with sustainable economic development and may be a trade corridor for African communities for better market access for certified organic products. Developing pan-African organic standards and then encouraging national organic standards aligned with African standards appears to be a better solution for the current inadequate organic regulation. It is necessary to examine the prospects for African organic standards.

Prospects for African organic product standards
This sub-section analyses the prospects of developing African organic standards drawing inspiration from the EAOPS in particular and other regional organic standards to some extent, to make recommendations for African organic standards. It argues for the development of pan-African organic standards as an AU-led initiative in collaboration with international partners.

Mirroring the East African organic product standards experience
The 2007 EAOPS as the first multi-country organic standards in Africa represents efforts to develop standards for five East African countries while harmonising existing organic standards and practices. 62 When the initiative for East African organic standards was launched in 2005, Kenya, Tanzania and Uganda already had different organic standards while several other private organic standards were applicable in the region. 63 These different standards posed significant problems for local organic farmers having to meet different requirements to access regional or international markets. 64 The EAOPS as harmonised organic standards for East African countries could inspire the development of pan-African organic standards in their making and their contents. 65 Similar to the making of the EAOPS, African organic standards would need a multi-stakeholder process involving consultations with governments, the private sector and international partners. 66 Like the EAOPS' development process, a comparison of existing national standards in Africa and an assessment of their main similarities and differences would be necessary for the African organic standards' development process. 67 A pan-African publicprivate sector working group would also be required to work on technical aspects of the organic standards. 68 While the EAOPS were developed for five East African States in two years (2005)(2006)(2007), pan-African organic standards for 54 African States would take more time and more regional workshops as well as national consultations. 69 Similar to the EAOPS needing the approval of the main regional authority (the EAC Council) to be applicable in the region, pan-African organic standards would need the approval of the main pan-African organisation (the AU) to be applicable in the African region. 70 The African continent would also need to set up a regional working group or entity to ensure the implementation of pan-African organic standards in African States. 71 Similar to the contents of the EAOPS, it is important for African organic standards to include organic rules of production regarding plants, animal husbandry, beekeeping, wild products collection but also aquaculture. 72 Conversion requirements for land, 73 crops, 74 animals 75 and beekeeping 76 are necessary so that the integrity of an organic farm is not compromised by nonorganic operations undertaken on the same farm. Like the EAOPS, pan-African organic standards would need to prescribe a duty of care for organic operators with respect to biodiversity throughout the farm holding. 77 Culturally or legally protected primary ecosystems should not be cleared to establish agriculture including organic agriculture. 78 As in the EAOPS, the regulation of wild harvested organic products should be included in pan-African organic standards considering that Africa has an important share of wild collection areas. 79 Genetically modified organisms (GMOs) or their derivatives should not be used or introduced through negligence or oversight. 80 Similar to the EAOPS, the setting up of buffer zones as a clearly defined and identifiable boundary area bordering an organic production site and adjacent areas need to be established to avoid contact with prohibited substances. 81 It is important that pan-African organic standards such as the EAOPS require that animals be fed with 100 per cent organic feed and no use of synthetic growth promoters and antibiotics. 82 Social justice provisions are also important in African organic standards similar to the EAOPS. 83 Common labelling requirements for African 71 The EAOPS did not have any follow-up mechanism for implementation and are not yet fully reflected in the laws of the EAC Member States. Such substances would need to be listed out in the African organic standards. Section 3.3 EAOPS. 82 Where the quantity or quality of commercially available organic feed is inadequate, the daily maximum percentage of non-organic feed shall be 40 per cent, calculated on a dry-matter basis. Section 6.6.1 EAOPS. 83 Eg the respect of human rights. Sections 4.5.1 and 4.5.2 EAOPS. OJ LIM TUNG PER / PELJ 2018 (21)  12 organic products should be required with a common African organic label and a non-organic ingredients' threshold. 84 Similar to the EAOPS, African organic standards should have duties for operators regarding relevant precautionary measures to avoid the contamination of organic sites and products. 85 The integrity of organic products should be maintained throughout the phases of post-harvest handling, storage, processing and transport. Like the EAOPS, African organic standards should target the establishment of national and regional markets with standards suited for developing world conditions. 86 Together with the EAEP, the EAOPS has been pivotal in promoting organic agriculture in national trade strategies and raising regional organic exports. 87 African organic standards could mirror the EAOPS experience as discussed above with a wider African scope while drawing inspiration from other regional organic standards.

Inspiration from other regional organic product standards
At the regional level, the EU organic standards, 88 the POS and the AROS 89 could also inspire African organic standards to some extent. The following subsections provide a summary of different aspects of the above regional organic standards which African organic standards could draw on.

The European Union organic food and farming standards
Organic food and farming in the EU is regulated mainly by the Council Regulation (EC) 834/2007 on organic production and labelling (thereafter the "EC Regulation 834/2007") which represents a simplified and improved version of the first European organic standards. 90  States have individual control bodies or organic certifiers that are EU-listed, 92 provided such control bodies or certifiers demonstrate that their standards and control procedures are accredited as equivalent to the EU system.
African organic standards would gain by being aligned with the EU organic standards since the EU remains the leading export partner for African countries. In addition to the EAOPS rules of production, 93 pan-African organic standards could cover EU rules of production for organic feed and processed organic feed, 94 collection of seaweeds, 95 aquaculture. 96 Importantly, in order to maintain access to the EU organic market, African organic standards should prohibit the use of GMOs, products produced from or by GMOs 97 as well as growth promoters. 98 Pan-African organic standards could also adopt a common African logo for organic products similar to the EU 99 while allowing established logos used by African countries. 100 Moreover, the EU organic framework requires enforcement of its standards by its Member States including an inspection process supervised by national competent authorities. 101 However pan-African organic standards would be expected to be voluntary in Africa with each African State setting up its own national competent authority with an inspection system for organic products. 102  The EAOPS, the POS and the AROS are also voluntary regional standards without a verification and inspection system (see the sub-sections above on the EAOPS, the POS and the AROS respectively). Although pan-African organic standards would be expected to be voluntary in Africa, it is important that national standards in African countries be accredited according to ISO 17065 to ensure certifiers manage organic production and process correctly. the development of EU-listed individual control bodies or organic certifiers as indicated above. In the longer term with pan-African organic standards implemented domestically, African States would need to enable any certified organic product with documented evidence in line with the African organic standards to circulate freely within the AU as a certified organic product. 103

The Pacific organic standard
Oceania as indicated earlier is the biggest regional organic producer with its regional organic standards (POS) adapted to the local conditions of Oceania and aligned with international guidelines on organic products. 104 In 2008, such standards were developed for this region by a multi-stakeholder partnership with government agencies, the private sector and the IFOAM. 105 Importantly the main regional organisation for this region, the Secretariat of the Pacific Community (SPC) had an active role in assisting the development of the Pacific standards with funds provided by the International Fund for Agricultural Development (IFAD). 106 The involvement of the main regional organisation of a region in the development process of regional organic standards arguably facilitates the adoption or endorsement of such standards in their final state. The POS cover plant production, animal husbandry, beekeeping, collection of wild products and aquaculture, the processing and labelling of such products. They also include social justice provisions. These standards aim at increasing organic production and

The Asia regional organic standards
In Asia, the AROS represent more recent regional organic standards which could inspire African organic standards in their making and their purposes. Content-wise, the AROS may not be as inspiring as the EAOPS for African organic standards since they cover mainly plant production, collection of wild products and the processing and labelling of products derived therefrom. 111 Unlike Africa, the Asian region is home to ten per cent of the world organic agricultural land and hosts a range of organic sector development scenarios from early development to highly regulated. 112  Likewise, Africa would need a regional task force with a highly inclusive publicprivate partnership of stakeholders to assess the situation and explore solutions regarding organic agriculture development in this region. 115 Similar to the AROS, the main purpose of African organic standards would be to address barriers to organic trade arising from the proliferation of organic standards. 116 African organic standards would also not be expected to cover procedures for verification of products similar to the AROS. 117 A follow-up of the implementation of African organic standards would be necessary as undertaken by the international partners (FAO, UNCTAD and IFOAM) for the AROS from 2009-2012 to continue the aims of harmonisation and equivalence. 118 Like the AROS, African organic standards would gain by facilitating equivalence among organic standards in the region and certification 110 SPC 2008 http://www.ifoam.bio/sites/default/files/page/files/pacific _organic_standard.pdf 3. 111 In contrast the EAOPS cover a wider range of products, a common logo and labelling requirements and social justice provisions and may be more appropriate for African organic standards. See the sub-section above on "Mirroring the EAOPS experience". programmes within and beyond the African region 119 and being aligned with international guidelines. 120 Both the EAOPS 121 and the AROS 122 were developed as voluntary regional standards by international partners whereas the EU organic standards were developed by the EU authorities as regulations with binding effect for States Members. 123 The EAOPS were adopted at the regional level by the EAC Council 124 however there is no regional organisation representing all the countries of the East, South and South-East of Asia. 125 The development of the Pacific standards as voluntary regional standards with the assistance of the main regional organisation (the SPC) and international partners (IFOAM and IFAD) facilitated its adoption by the SPC in its final state. 126 Involving the main regional organisation in the development of regional organic standards may facilitate the adoption or endorsement of such standards in their final state by such an organisation. In contrast, not involving the main regional organisation or involving mainly sub-regional organisations in the development process of wider regional organic standards may arguably result in a lack of consensus on the adoption or endorsement of the final regional organic standards. For instance, the ASEAN Member States developed the ASOA instead of fully endorsing the AROS for the ASEAN. See Organic World 2014 http://www.organic-world.net/country-info/asia/overviews/asia-2014.html.

An African Union-led initiative with international partners
Since pan-African organic standards will be required to be adopted or endorsed by the main regional organisation (the AU) to be applicable on the continent once they are developed, it is arguably better to involve the AU in the development of such standards since the beginning. Perhaps the AU as the main African regional organisation representing 54 African States in view of better regional cooperation 128 could take the leadership for the development of African organic standards. The AU Department for Rural Economy and Agriculture (DREA) provides leadership to agriculture in Africa and has already taken the following major steps in promoting sustainable farming systems in Africa. The 2003 Comprehensive Africa Agriculture Development Programme 129 (CAADP) has been Africa's major policy framework for agricultural transformation supporting sustainable agricultural systems as an AU initiative and the New Partnership for Africa's Development (NEPAD). African Heads of State also took several important decisions regarding agriculture under the "Maputo Declaration on Agriculture and Food Security" with the commitment to allocate at least ten per cent of national budgets to agricultural development. 130 In 2010, the AU Agriculture Ministers decided to promote sustainable organic farming systems in their respective countries while the AU Executive Council endorsed the objective to promote organic agriculture in Africa in 2011. 131 The AU Commission and its NEPAD Planning and Coordinating Agency were requested to initiate and provide guidance for an AU-led coalition of international partners on the development of an African organic farming platform and sustainable organic farming systems.  However the AU as the main pan-African organisation already engaged in providing leadership to sustainable agriculture in Africa could arguably lead the African continent to develop regional organic standards in collaboration with African sub-regional organisations and international partners. 138 As discussed above, African organic standards could be inspired in their development process, their contents and their implementation by the EAOPS in particular and other regional organic standards (to some extent) in line with international guidelines. 139 After having examined the prospects of developing African organic standards, the following sub-section analyses the potential limitations to such regional standards.

Limitations of African organic product standards
The regulation of organic agriculture in African States is necessary to harmonise national organic standards and ensure the credibility of organic products brought to the market. As discussed in the previous sections, African organic standards would be an important step for the African organic sector bringing harmonised standards across Africa while inspiring national organic standards. However there would likely be limitations to overcome, such as implementation issues regarding African organic standards, high certification costs and low domestic certification capacities.

Implementation issues regarding African organic product standards
African organic standards would set harmonised standards across Africa provided African States take necessary measures to implement such standards domestically. Main implementation issues that could be identified are political will by African Heads of State to engage with a timely implementation process, adequate financial resources to domesticate African organic standards and necessary institutional support.
The development of African organic standards targeting 54 African States 140 would require well over a decade to come into existence and its implementation in respective African States, another decade or so. The EU organic regulation dates back to 1991 with several amendments over the past four decades currently fully implemented in its 28 States whereas the AROS targeting 28 Asian States were developed within a decade. 141 Not only would the political will and cooperation of African leaders to implement such standards domestically be needed but also the cooperation of national organic movements and the private sector. As stated earlier, organic agriculture is driven by the private sector and the drafting of national organic standards would require private sector cooperation. 142 A close follow-up regarding the implementation of the African organic standards in African States would also be necessary. 143  progress. 144 Despite African leaders reaffirming their strong political commitment to promote agricultural development under the 2014 "Malabo Declaration", Africa faces major challenges in terms of investment and access to finance. 145

High certification costs and low domestic certification capacity
Even if African organic standards should come into existence and harmonised domestic organic standards be implemented in African States, there would still be high certification costs for organic products. Third-party certification, considered as the most authentic and internationally recognized means of organic quality assurance is essential for export to the EU and the US. 146 Organic product certifications may require considerable transition costs, recordkeeping and traceability that may elicit a price premium. 147 The transition to organic production may take time before costs can be recouped. 148 The high costs involved in the certification of organic products by the private sector are a major barrier for the development of the African organic sector. 149 Not only is it costly to certify organic products by foreign certification agencies, there are also insufficient domestic certification capacities for such products in Africa. 150 The absence of local certification and inspection capacity is a critical bottleneck that needs to be overcome to develop the potential of African organic exports. The control of organic production will remain driven by the private sector unless African States provide State support in collaboration with the private sector to enable the development of domestic certification capacity. 151 After having examined the prospects and limitations regarding African organic standards, the following sub-section makes recommendations for the making, the contents and implementation of pan-African organic standards.
Recommendations also address limitations identified with respect to pan-144 UNCTAD African organic standards as well as the domestic regulation and support of organic agriculture in African States.

Recommendations
Pan-African organic standards are necessary to address barriers to organic trade arising from a proliferation of organic standards in the region 152 and funding opportunities for the development of pan-African organic standards needs to be sought through international partners. Main recommendations in this paper target the development process, the contents and the implementation of pan-African organic standards as well as other steps to be taken by African States domestically to support organic agriculture.
Regarding the development process of pan-African organic standards, the AU as the main pan-African regional organisation could either initiate this process in collaboration with sub-regional organisations and international partners or could be involved in this process as discussed earlier. 153 The setting up of a regional task force is necessary to take stock of existing regulation of organic agriculture and main issues regarding organic agriculture in the African region.
A highly inclusive public-private consultation and participation is required for the development process of pan-African organic standards so that local practices aligned with organic agriculture may be included in such standards. 154 Existing standards such as the EAOPS and the national standards of the biggest African organic producers must be taken into consideration in drafting pan-African organic standards. 155 Main issues identified and recommendations made by the regional task force need to be discussed at sub-regional workshops with a view to compiling a draft of the pan-African organic standards. This draft needs to be finalised at regional workshops with multistakeholder participation involved at the development process level.
Regarding the contents of African organic standards, the contents of the EAOPS could serve as a basis while additional aspects covered in other regional standards as discussed in this paper could be included. 156 African organic standards need to cover main organic rules for crops, animal husbandry, beekeeping, the collection of wild products, freshwater and seawater aquaculture, processing and labelling of such products. Common requirements to employ long-term, ecological, systems-based organic management and ensure long-term biologically-based soil fertility are 152 As discussed in this paper, the EAOPS, the POS and the AROS all had these aims for their respective regions. important for the African continent. In order to respect local biodiversity, the choice of crop species and varieties would need to be based on their adaptation to local conditions as well as pests and diseases. Common labelling requirements with a common organic label and a non-organic ingredients' threshold to regulate the use of organic labels are also necessary at a pan-African level. 157 Organic stock farming should respect high animal welfare standards with specific behavioural needs and animal health management. Social justice provisions are also important in African organic standards. 158 To ensure that the integrity of an organic farm unit is not compromised by the management of non-organic operations undertaken on the same farm, conversion requirements should be included in African organic standards. 159 Similar to the EAOPS, the POS and the AROS, African organic product standards would need to adapt to changing knowledge, production and market conditions. 160 Pan-African organic standards need to be adapted to African local practices and be consistent with international guidelines on organic products. 161 African organic products could also be marketed in combination with fair-trade labelling 162 however fair-trade labelling would add costs to the certification of such African organic products. 163 Pan-African organic standards would serve as a basis for the development of national organic standards and stimulate harmonisation where there are existing standards and practices. 164 Regional cooperation among African States as well as national organic movements would also be required to facilitate equivalence of African certified organic products and promote regional organic trade. National organic agriculture movements should be encouraged to interact through regular annual meetings and sharing of information through multimedia. A regular inventory of certified and informal organic farms in Africa is also recommended with information provided by African States and the private sector.
The coming into existence of pan-African organic standards would be a major step for organic agriculture in the continent but other steps would also be 157 A required by African States. In addition to the AU and international partners assisting in the development of African organic standards, African governments would also need to implement such standards, provide adequate institutional support and coordination to promote organic agriculture. A pan-African working group is recommended to follow up on implementation issues in different African States. Not only domestic organic standards based on African organic standards are necessary but also national organic policies and a State-supported infrastructure to implement them.
African States need to set national benchmarks for organic rules of production based on African organic standards to bring official recognition to local organic production and credibility to African producers for the export market. National organic standards enacted as legislation are recommended to regulate the coexistence between non-organic agriculture and organic agriculture, the setting up of a non-organic threshold as well as the control of organic products. 165 It is important that African States set up a domestic inspection system for organic production with sanctions in the case of an infringement, misrepresentation or misuse of the "organic" claim. It is highly recommended that African States regulate organic agriculture based on pan-African organic standards in collaboration with the private sector. 166 To address the challenge of high certification costs for organic products and low domestic certification capacities, the following recommendations are important for African States. First, affordable types of guarantee systems (such as the network guarantee system 167 and the participatory guarantee system 168 (PGS)) should be allowed for local markets in African States. However such alternative guarantee systems for organic products do not necessarily bring "organic certification" and the same price premiums as products certified by third-party certification. Second, African States need to strengthen domestic certification capacities for organic products. To that effect, a State accreditation system for local certification bodies in partnership with private certification bodies is recommended. 169  National organic policies for African countries in collaboration with the private sector will also be useful to grow domestic capacity for such farming and achieve long-term sustainability of organic production systems in Africa. 171 With many smallholders in Africa, the typical supply chain is often made up by a private enterprise organising smallholders as outgrowers to secure sufficient quantities for export or farmers working together on one supply project. 172 Small farmers require long-term intensive support to succeed, organic farming training, business and managerial training, contract farming and institutionbuilding support. 173 Smallholder participation could be facilitated by training producer groups 174 organised according to commodity lines such as cocoa, cassava, fruits and so forth. State support could comprise export facilitation (eg trade fairs), State-backed loans, subsidies for the conversion of farmland and research grants. 175 Organic agriculture could be promoted by small-scale intervention within village communities or large-scale intervention including model pilot projects organised in strategic locations in different African States. 176 African States also need to find solutions to help the sourcing of appropriate inputs such as organic seeds, bio-fertilizers and bio-pesticides which represent a main challenge in the promotion of organic agriculture. 177

Conclusion
Along with potential environmental, health and socio-economic benefits, better access to premium markets for the export of organic products are the main drivers for the development of organic agriculture in Africa. 178 As discussed in this paper, there are different private organic standards and a lack of regulation at African States' level with no pan-African organic standards. African farmers wishing to start organic agriculture currently strive to comply with different accreditation bodies recognised by the respective government which may accredit local certification bodies. requirements based on private standards to access regional or international markets. This paper discusses the need to address the proliferation of different standards through pan-African organic standards which may inspire national organic standards with harmonised standards.
African organic standards would constitute a major step to bring harmonised organic standards and inspire national organic standards in African States. Such pan-African standards could be developed through an AU-led initiative with international partners, inspired by other regional organic standards as discussed in this paper and in line with international standards. However even if African organic standards were to come into existence, there would likely be limitations such as a timely implementation of such standards in African States, high certification costs and low domestic certification capacities. African governments would not only need to implement such regional standards but also provide adequate institutional support to promote organic agriculture. Besides third-party certification for the export of organic products, other affordable guarantee systems such as the network guarantee system and the participatory guarantee system should be allowed for local markets. State regulation of organic agriculture in African States with a public-private partnership approach for certification practices in collaboration with international certification bodies is also highly recommended. 179 Whereas organic farming may not be the only solution for African farming, it is recommended to give an edge to African farming without heavy industrialisation of agriculture and external inputs. Certified organic production is a trade corridor with better premium market access yet to be fully exploited by African communities. African organic standards would arguably address the proliferation of private standards as a trade barrier while bringing harmonised standards across Africa and provide a unified negotiating position in regional and international organic markets.