Data About Organic Cotton Production in Turkey Warrants Skepticism

July 2, 2023

In its Organic Cotton Market Report (OCMR) 2022, the Textile Exchange stated in declarative sentences that that they estimated the 2020/21 global harvest at 342,265 tonnes of organic cotton fibre produced on 621,691 hectares of certified organic land. Growth from 2019/20 was estimated at 37%, and organic production represented 1.4% of all cotton grown.

The Textile Exchange prefaced those statements with pages of disclaimers that it is “purely an aggregator” of data, that it doesn’t perform certification work itself, that data is provided by external sources, that it has “done what it can” to overcome challenges, and it devoted a whole page to the ten steps it is taking to “improve traceability and prevent fraud.”

Then, after all these disclaimers, the Textile Exchange went ahead and reported 37% growth in production in 2020/21, secure in the knowledge that most readers would focus on that headline number. The publication included charts and tables, pictures of smiling farmers and stories of growth and success, all reported with amazing, confidence-enhancing, precision to single tonnes and hectares.

The Textile Exchange did not say that its estimate of production is almost surely inflated, that there are many reasons to be highly skeptical of the numbers reported by the certification agencies, and readers had to go to the next page and study a chart to realize that the Textile Exchange itself had low confidence in the data (Data Confidence one out of three) from five countries, India, Kirghizstan, Tajikistan, Turkey and Uganda, who together accounted for 76% of the certified organic total in 2020/21. (On another page, the Textile Exchange says it rates its confidence in the data for Turkey as two out of three.)

Among the reasons to be skeptical is that yields calculated from reported certified area and production are too high to be true. The Textile Exchange reported that organic yields in eight countries accounting for 307,214 tonnes of 2020/21 production (90% of the world total), were equal to or higher than overall yields in each country. Almost by definition, yields in organic agriculture are lower than yields achieved by conventional farmers, and the organic cotton yields reported for 2020/21 in and of themselves raise suspicion of fraud.

Specific information from Turkey provide a case study in why skepticism about the statistics contained in the 2022 OCMR is warranted. The organic cotton yield reported for Turkey was 2% higher than the overall yield for cotton in the country. An organic yield equivalent to conventional yields is possible, but highly unlikely. If farmers could achieve organic yields just as high as conventional yields without the use of purchased inputs, they would all do so. At a minimum, the Textile Exchange has an obligation to explain how such high yields could be achieved, and nowhere did they even address the issue.

Further, the Textile Exchange claims that production of organic cotton in Turkey rose from 24,288 tonnes in 2019/20 to 80,830 tonnes during 2020/21, a three-fold increase in one year! In contrast, the Ministry of Agriculture and Forestry, Government of Turkey, reports that production of organic cotton fell from 24,300 tonnes in 2019/20 to just 6,075 tonnes in 2020/21, a four-fold decrease during the same year! Why would the two data sets, essentially equal in 2019/20, diverge so much in 2020/21?

The Government of Turkey counts cotton as organic only if it is produced in compliance with the regulations established for the Turkish organic standard, but the Textile Exchange includes all production certified to standards recognized by IFOAM, including the EU and USDA standards. A key difference is that compliance with Turkish regulations covering organic standards requires that every farm be individually audited. In contrast, farmers seeking certification under the EU or USDA organic standards may form groups, with only a few members of each group being audited, but with all members receiving certification.

The Textile Exchange explains that organic certification is driven by demand in end markets where final goods are sold (correspondence with a spokesperson for the Textile Exchange). Since the EU and the USA are the largest retail markets for organic textile products, the Textile Exchange says that Turkish farmers chose to certify to EU and USDA standards in 2020/21, rather than to the Turkish organic standard.

However, term “organic” was not controlled in the EU with respect to textiles as of 2020/21, and cotton certified to the Turkish organic standard could have been sold in the EU as organic. Second, the ultimate end use destinations for organic products could not have changed that dramatically between 2019 and 2020. The Textile Exchange, which claims to be painting a clearer picture of the sector to give industry a starting point to recognize issues and anomalies when they arise, does not explain why the two data sets diverged as much as they did in 2020/21. It would be naive to think that the ease of certification within groups, versus the Turkish requirement for farm-by-farm certification, was not a factor.

There are two options for testing to determine the authenticity of organic cotton. The first is a DNA test to determine whether the cotton contains GMOs (whether the tools of biotechnology have been used to impart genetic traits that confer resistance to chewing pests or efficient management of weeds), and the second is a pesticide residue test. Neither test is dispositive; neither test proves that cotton was produced using organic methods. Rather, each test can only prove that the cotton is not organic.

DNA tests can determine whether the cotton was cultivated from GMO or non-GMO seeds, but since all cotton in Turkey lacks biotech traits, the absence of GMOs does not prove that cotton was produced using organic methods. Most pesticides, other than plant growth regulators, are applied on cotton prior to boll opening, and regulated pesticides in most producing countries are biodegradable within 14 days anyway. Therefore, pesticide residues are difficult to detect, even on cotton lint. After bale opening, blending in the blow room, spinning, weaving or knitting, and dyeing and finishing, finding residue from agricultural pesticides on fabric or finished fabric and clothing is nearly impossible. Therefore, not being able to detect pesticide residue does not prove much. Even if you take fibres to a laboratory and subject them to forensic scrutiny, you are not going to be able to verify the production methods used. Since conventional production practices are higher-yielding, and with premiums being paid for certified organic cotton, the temptation is great to claim organic and see if anyone catches you.

Farmers, ginners and traders around the world are aware that it is possible to make fraudulent claims of organic cotton content without much risk. Afterall, no one is ever put in jail or fined for making a false claim of organic certification. None of the five countries for which the Textile Exchange admits having low confidence in the 2020/21 data have a system of permanent bale identification numbers (PBI’s). Therefore, bales can be swapped, and once bales arrive at a spinning mill, there is no way to trace back to the farm or gin of origin. Since the bale of cotton looks the same anyway, why not try calling it organic?

A company making a fraudulent claim of organic content risks losing certification and becoming a delisted-supplier, losing the certified organic price premium, possible customs detainment, and reputational damage. None of that means much. Within the cotton industry, the most important body enforcing rules covering international trade is the International Cotton Association (ICA), headquartered in Liverpool but operating worldwide. As of this week, there are 630 companies on the ICA list of unfulfilled awards (the default list). Theoretically, these companies are prevented from trading with members of the ICA and therefore would be hard pressed to continue in business. In reality, the consequences of being on the ICA default list are ephemeral, and if the ICA default list is of little consequence, for sure no one is going to worry much about being delisted as an organic cotton supplier. (The largest merchant handling organic cotton in Turkey was just added to the ICA default list in June.)

Given that there is no objective method of proving whether cotton was produced organically or not, it is impossible to measure just how skeptical we should be of statistics. Nevertheless, it is clear that unwarranted certification occurs. Based on reasonable estimates of yields in each producing country, an estimate of world production of organic cotton of less than 200,000 tonnes in 2020/21 would not be surprising.

The Textile Exchange should not have published a quotable estimate of 37% growth in 2020/21. Instead, they could have published a range for estimated production. They could have reported that the amount certified totaled 342,000 tonnes, but that authentic production was surely far less, and no one really knows by how much. A careful country-by-country analysis indicates that despite all the hype and subsidy that goes into the promotion of organic cotton, authentic world production may not be growing at all.

The people at the Textile Exchange are well intended, and it is true that they are merely reporting what the certification agencies claim. No one ever advances their career within the community of organic enthusiasts by being skeptical of reports of growth. Nevertheless, dubious reports that stretch credulity undermine consumer confidence in all sustainability claims, discourage honest producers, ginners and traders from making legitimate efforts at compliance, and divert time and attention from industry activities that might actually work. By publishing a headline number of 37% growth in production, while shielding behind disclaimers that most readers ignore, the Textile Exchange is enabling brands and retailers to make consumer-facing claims of organic cotton content to boost sustainability credentials, while continuing their fast-fashion business models built primarily on the use of polyester.

The Textile Exchange should withdraw the Organic Cotton Market Report 2022, audit the numbers and issue a revised report with data ranges that provide a realistic picture of the industry. The organic cotton sector must look honestly at itself and ask, why, if organic is supposed to help farmers, there is so much cause for skepticism and so little compliance with organic standards in the first place.