Figure 4. The dependencies between recommendations and trust index in Russia

Nevertheless, some of the respondents point out that they pay attention to recommendations from other consumers but it strongly depends on who are these consumers. Likewise, Russian consumers also highlight that those whom they seek advice from are not just ordinary consumers but could be named as experts in the field of organic food. It is hardly possible to say whether they are really experts or not, but at least they are perceived by trustworthy sources of information mostly on the base of their professional activities somehow related to organic food. This is reflected in such statements: `I usually ask my co-workers, they are experienced in this field as well, and we help each other out!' (N); `I sometimes go to a local farm where a friend of mine works, so I have a really good trust in that and know that they meet certain standards' (A); `I have some friends, one friend particularly, who is really into organic stuff. Doing a lot of shopping at organic markets. Something like that pays a lot of value' (S); `It depends on whom I receive information. There are some people I know, which have read a lot about these topics, that is why I trust them' (S); `There are such people in my surroundings, Basically they are my friends - doctors' (L); `I trust my friends because exactly they work at “Ecological Union”. I have educational background in ecology and communicate with the right people, that's why I trust them more' (R1); `Luckily, I have a friend who works at the Ecological Union, she gave me a lot of information in this field' (AR); `In my surrounding it's me to whom people usually ask for advice, because of my professional activity' (M).

Orientation towards recommendations among Russian consumers is also supported by the fact that 66% of respondents reported about their participation in some communities in social networks, while only 22% of Germans say so. However, it is important to mention that these communities are also rather specialized in the topic. Following communities were announced by interviewees: the official group of the “Ecological Union”, eco blog ImOrganic, Ecolavka in Vkontakte, and Lookbio in Instagram. Also, pages of particular producers and shops were also mentioned by some respondents. Nevertheless, a big role of online communication for Russian consumers could be based on the fact that 36% of respondents when facing some problems with or questions about organic food would ask for advice from other consumers online, while only 25% of German consumers would do so. However, the most popular answer to this question in both countries was to ask other consumers personally: 40% in both countries would do so. At the same time, German people tend to contact directly producers more often than Russian consumers: 35% and 21% correspondingly.

Talking about recommendations as the factor that influences consumer trusts in organic food it is also necessary to keep in mind the motives for buying such commodities. As it was revealed Russian consumer usually purchase organic food follow egoistic motives, including better sensorial characteristics and the influence it has on health. In this case it is rather justified to seek for advice from other consumer when they can report about their experiences connected with organic food consumption. However, German consumers could hardly obtain some valuable information about organic food from other consumers because they have the same access to the production and processing process and do not possess more information about how these processes are going on: whether it corresponds to the rules for organic production or not.

What is more remarkable, Mass Media turned out to have quite a big influence on consumer's level of trust but in a different way in Russia and Germany. When talking about German consumers it is necessary to say that information they obtain from Mass Media has a strong positive correlation with their level of trust. Thus the correlation coefficient between these two variables is 0, 84 what could be considered as a strong dependence. Particularly consumers who pay attention to the information from Mass Media have a higher level of trust in organic food what could be observed on the figure 5 “The dependencies between Mass Media and trust in Germany”.

Figure 5. The dependencies between Mass Media and trust in Germany

Conversely, information from Mass Media in Russia has a strong negative correlation with consumer's trust. People who tend to pay attention to Mass Media more often have lower trust in organic food. It could be seen on the figure 6 “The dependence between Mass Media and trust in Russia”. The correlation coefficient is negative and it is -0, 62 what is still could be interpreted as a strong connection. It is important to mention that interviews refer to Mass Media and its coverage of the organic food topic very rare. Only one or two respondents mentioned these issues in their speeches.

Figure 6. The dependence between Mass Media and trust in Russia

Finally, when it comes to the very process of purchasing people both in Germany and in Russia based their choice on the content of a product. 52% of German respondents and 54% of Russian respondents named information about the content on the packaging of the product as the decisive factor in the choice of organic products.

To conclude, it is necessary to say that if consider consumption of organic food as a process the following stages can be distinguished in terms of trust formation: 1) inducement to start buying organic food; 2) choosing of an organic product; and 3) the very purchasing of an organic item. As it was stated at the beginning different factors (which are recommendations from other consumers, information about the content, labels, brands, mass media, and advertisement) influence consumer trust in organic products. However, as it was revealed during the research, their influence strongly depends on the stage of the consumption process. Thus, recommendations of other people serve as the initial trust impulse both in Germany and Russia on the first stage and in this sense thick and thin interpersonal trust take place at the very beginning; labels play the most important role during the process of choosing in both countries what makes institutional trust crucial at this stage, and, finally, the last step is determined by information about content on the packaging what, in turn, could be also considered as institutional trust. Thus, the process of consumer trust formation on the Russian and German market in general is similar: from an interpersonal trust, it is late transforming into institutional trust. In this way trust in other consumers and institutions transit into trust in organic food.

However, some differences could be still observed between Russian and German cases. Thus, it possible to see that during the stage of choosing a product Russian consumers tend to base their trust on the information about the content of a product more in comparison to German consumers. Moreover, during this stage Russian consumers still pay attention to recommendations from other consumers, while for German consumers this factor is important only at the very first stage. It was also figured out that labels play a big role during the process of choosing, but it is interesting that European labels with no regards to the issuing country are the most popular among Russian consumers, while German buyers usually take into consideration mostly their own national German organic food signs. What is more mass media as one of the most influential factors during the first two stages plays opposite role in Germany and Russia. If in Germany in underpins the process of organic food production and increase the level of trust, in Russian it vice versa makes consumers more suspicious and decrease their trust level. However, due to the fact that labels and mass media have the strongest influence on consumer trust it was decided to make further analysis of organic production legislation and mass media coverage of the topic in Germany and Russia. The results are presented in the next paragraphs.

2.3 Organic food issues in Russian and German mass media

As it is possible to observe from the results of the survey and interviews mass media has a significant influence on the trust consumers give to organic food in both countries. However, while in Germany it is positively correlated with the level of trust, conversely in Russian these variables are negatively connected. Mass media decrease the level of trust in organic food among Russian consumers, while at the same time increase it among German consumers. In order to understand why it is so, the investigation into the media coverage of the organic food topic was made. The main aim of this analysis was to understand what are the main rhetoric, techniques, and instruments that are used by media to cover the issues connected with the organic production and what in general these issues are. As the object of analysis, the range of federal nationwide non-specialized sources was taken from both sides. As well as some specialized editions as well.

Usually, mass media is used by different market actors for different purposes: manufacturers and retailers use these sources to inform consumers about organic food in general and products they supply in particular; representatives of ecological movements may use it to attract attention to some certain ecological problems; and the media itself might use this topic to attract bigger target audiences and rating upgrade if they see that those issues are interesting for the spectators or readers. That is why it is important to say that mass media plays a significant role in the process of consumer trust formation; it overall has an influence on their perceptions and decisions about environmental food. In fact, media can play into hands, both producer and consumer by covering different aspects of the same issue. It is reasonable to state that buyers could receive missing knowledge about organic food by means of media, while producers use it to provide favorable for them information. But, generally, the information distributed via newspapers, magazines or TV, especially connected with some scandals, could be evaluated as shaping consumer's perceptions of organic products (McCluskey & Swinnen, 2011; Kendall, 2011).

In these regards the mass media could be considered as one of the communication channels whereby interaction between producers, consumers and other stakeholders is going on. Moreover, the way this topic is reported highly depends on the country. In order to investigate the question of how organic food is presented in Russian and German mass media various sources, such as newspapers, news portals, and specialized websites were analyzed. As it was revealed at the beginning of the analysis, the topic of organic food is not covered by lots of periodicals and they are mostly federal nationwide sources, and quite rare it is a local media. That is why the decision was made to compare how this issue is presented in nationwide Russian and German mass media sources which are available online. The choice was made on the base of articles that could be found in following sources by using key words related to the topic of organic food, such as “organic food”; “organic productions”; “ecological products”; “organic standards”; “sustainable development”; “green economy”, etc. To be more precise the following sources were considered: The Local DE, Bild, Taz.archiv, Spiegel newspapers, and news portal Deutsche Welle in Germany; and Gazeta.ru, Arguments and Facts, Komsomolskaya Pravda, Izvestia newspapers, news portals RIA news and Rossiya 24 in Russia were analyzed. As the situation regarding organic production and selling regulations is slightly different in the two countries, it is necessary to examine what are instruments, techniques, and rhetoric that used to cover the topic and who are the major actors of this particular discourse in both countries. So, we are going to show how German and Russian media does frame organic food as an issue and what instruments do they use for this purpose.

It could be easily noticed that agenda-setting theory which emphasizes that mass media have a strong influence on public discourse by selecting and promoting certain topics as worth discussing is widely used both by Russian and German media. Clearly, stimulating the public's emotional response, concern and awareness is the main goal for the majority of media agents (Mc. Combs, 2003). One of the founding fathers of this approach M.E. Mc. Combs (2003, 41) highlights: “The power of the news media to set a nation's agenda, to focus public attention on a few key public issues, is an immense and well-documented influence”. Agenda setting refers to the idea that there is a strong correlation between the emphasis that mass media place on certain issues and the importance attributed to these issues by mass audiences (Mc. Combs & Shaw, 1972). According to this theory, it is possible to state that the mass media is not just a passive transmitter of current issues. It rather produces social reality; create pictures in the minds of spectators. The news media are a primary source of those pictures in our heads about the larger world of public affairs, the world that for most citizens is “out of reach, out of sight, out of mind” (Mc. Combs, 2003). This is why it is possible to state the mass media coverage create some kind of a picture of organic production in minds of the audience it brings this topic to the public discussions.

Actually, it means that quite a lot of information people know about the current state of affairs is what the media provide for them. It is especially true about organic food production. The news could be reasonably named as a powerful tool in setting certain issues about organic because an average consumer has a little possibility to have an inside view in the process of organic farming. Thus media are free in choosing those themes which could attract more attention from the public in order to gain personal benefits. But in the circumstances of scarce information mass media remains one of the few possible ways to obtain data about ecologically clean food. In this regard, it is especially important for it to stay impartial. But in fact, it is rarely the case, because it is always desirable to draw the attention of the public by focusing on sensational issues and dramatic events where equity is hardly possible. In fact, we have to do with the public agenda setting, when mass media decides which topics would be further become a topic for discussions.

However, environmental food has a different level of popularity within German and Russian mass media, agenda-setting volumes are much higher in Germany than in Russia. This conclusion is justified by the evidence that a number of articles devoted to the topic of organic food are considerably bigger if searching in German media sources than when reading Russian ones. It could be estimated that the difference in the number of articles in all analyzed sources is about 2 times bigger for Germany in comparison to Russia. Overall, around 15 articles from Russian sources, and around 25 were found in German media. All articles were published from 2015 to 2017 year.

So, it could be mentioned that the topic appears in different Russian sources just occasionally, while in German media organic food is discussed on more or less regular base. It could be explained by the level of organic food market development, which is the way better in Germany. Due to the fact that Germany represents one of the biggest markets for organic food in Europe (https://germanfoods.org/german-food-facts/german-organic-foods/), the number of consumers is reasonably bigger here; that is why German media could expect more responses from the audience and, consequently, could make more profit. On the contrary, in Russia, the market share for organic food remains rather small (http://sozrf.ru/rost_2013/) and the number of organic diet followers is also not very big, that is why the potential target audience is comparatively small. However, the issues of organic production in both countries are covered mostly by rather influential nationwide media sources, as for example, national newspapers Spiegel or Izvestia.

Nevertheless, except for agenda-setting techniques, mass media is known for using framing as a significantly different approach. If the former just brings the issues of organic food into the public arena as such, framing is used to emphasize some specific features of the subject. That is why, the way issue is covered could influence on how it is understood by audiences (Scheufele & Tewksbury, 2007). As it is known, frames are cultural structures that serve for better understanding of social reality. They are commonly used to determine what content is more relevant to a discussion; to define the roles of stakeholders, to outline relevant beliefs, actions, and values; to determine the language used to discuss the topic; and to outline the values and goals of the content area (Meyers & Chodil, 2011). It could be considered as a form of second-level agenda-setting - mass media not only tell the audience what to think about (agenda-setting theory) but also how to think about that issue.

In that case, the results of analysis demonstrate that the debates around organic food in both countries usually concentrated on a range of topics, which could be categorized as follows: comparison between conventional and organic food in terms of production specifics and impact they have on consumers; the question of organic food identification by consumers on the shelves among conventional products; economic benefits caused by organic production and organic market development; issues connected with organic food import from other countries; regulations and laws about organic food production. Surely, within these broad categories, different aspects are highlighted. However, one common feature for both types of media coverage is that this kind of food is described in the whole range of names, which are “organic”, “bio”, “ecological”, and “natural”. There is no one strictly defined term for organic products. But one distinctive feature of German media is that they usually assimilate all these terms to the notion of “local”, while in Russia it is usually opposed to the notion of “natural” food.

As for the comparison between conventional and organic food production both Russian and German media base their articles mostly on the rhetoric of health, taste, nutrition, environmental and animal friendliness. Nevertheless, articles which unveil organic food as beneficial for people (Tihmeneva, 2015; Timashova, 2013, Korobitsina, 2014; Bild, 2017; Berger, 2017 ) stay equally with those which introduce it like a myth and consequently try to demolish it (The local DE, 2010; Bild, 2016; Vesti.ru, 2013; Insider.pro, 2016). Usually, in the first case, articles reproduce organic food and its production as one that helps people stay healthier and satisfy their demands for good taste; have a good impact on the environment, treat animals better. Thus it could be named “justification” framing. The second approach could be named as “revelation” framing because it is used to present organic products as not possessing these unique traits; it emphasizes that all the benefits are just formed by concerned bodies and in reality do not exist. Interestingly the main actors of such a discourse are scientists. Intensive referencing to multifarious studies of organic food demonstrates skeptical about the advantages of such food both for health and for the land.

This implies that the rhetoric of regulation and control is one of the commonly used topics by media as well. However, this kind of rhetoric is used totally different by German and Russia media services. Thus, in Russia, the lack of official regulations is usually in the focus of attention with some articles devoted to the upcoming approval of official laws and normative standards. Absence of certification, rules, and regulations makes people feel unsure about the trustworthiness of organic food producers, what prevents them from active buying; but still some media agents look in the future by highlighting the process of regulations development to make market continue developing (Vesti.ru, 2013; Mishina, 2012; Falyahov, 2012). At the same time, in Germany, the subject of discussions not the absence of regulations, because they already exist, but their tightening; and sometimes comparison between governmental and private regulations as the latter are usually stricter (Maurin, 2016; Bild, 2017). It, on the contrary, leads to people's confidence in the organic food market, it makes them feel sure that the products they buy are controlled and really have those qualities they should possess. What is closely connected to this issue is the problem of ecological food identification on the supermarket's shelves what is discussed in quite a few articles. It is interesting to say that Russian media highlight external characteristics of a product, such as not long time of a storage and information about the ingredients as the best way to understand if the product is really organic, or in other words, it is self-checking (Plotnikova, 2016; Timashova, 2013; Kukartseva, 2012). On the contrary, German media usually writes about labels as the most trustworthy source of information about the organic origin of a product (Berger, 2017; Bild, 2017).

Economic benefits caused by organic food market development are the common topic that could be found in both countries. If German media constantly report about current goods and cash turnover increasing on the organic food market, what definitely make local economy stronger (Bild, 2017), than Russian media stresses attention more on the future benefits that could be achieved by the fast development of the market, what will allow Russian producers to enter global market and ensure better competition along with the real monetary gain (Falyahov, 2012; RIA news, 2012). However, import is still an exhilarating question for both. As can be expected the problem of third parties import invading local German market is widely discussed both in terms of the unfair competition, and the lack of necessary regulations corresponding (The Bild, 2017; taz.archiv, 2017). Conversely, in Russia import is more presented as the threat from Europe: the lack of local labels and lack of consumer trust make distributors sell imported goods from Europe, which are known to be well-checked and have organic logos (Korobitsina, 2014; Lalakina, 2014).

And finally, the rhetoric of reasoning is used to describe the most popular reasons to buy organic food. It becomes clear that in Russia egoistic motives are prevailing; people buy organic because of its better taste, health benefits, nutritive qualities and even sometimes because it is fashionable (Kukartseva, 2012; Vesti.ru, 2013). German consumers, in contrast, often buy this kind of commodities to help preserve resources and the environment in general, to protect animals and to support the local economy (The Bild, 2017). However, speaking about economic issues, Russian mass media pretty often uses, so called, the framing of “pricing” as long as it tries to justify higher prices for organic food, while German media do not pay so much attention to the issue of prices. However notable is that the actors of this particular discourse are farmers themselves, especially those with economic education. Obviously, it is explained by the fact that in Russian the price level for organic food in comparison to the conventional one is a way higher than in Germany (Korobitsina, 2014). In general, Russian media coverage of organic food is built on permanent comparison with European countries, including Germany, as the role model. Their organic food markets are usually represented as better controlled and trustful.

Thus the next type of popular framing is a “fraud” framing. This type is common both for Russian and German media agents. It is necessary to mention that focus is made mainly on sensational issues of low complexity and high possibility for dramatic events. So, when an incident of deceit occurs, it could be a good chance for newsmakers. A very famous incident has happened in 2011 when a handful of Italian firms sold conventionally produced food products under an organic label (Deutsche Welle, 2011). Although the fraud took place outside Germany it was a hot-button issue for a period of time. But relatively soon it was forgotten till the new scandal emerged. This time the problem was related to the local production and appeared when German farmers were accused of selling their eggs as organic while crowding their chickens at illegal levels (Ibid.). It entailed a big public response, but after a while focus of attention was shifted to other topics. It is important to illustrate the fact that an issue of organic food is not a long-term but rather timeliness and attract more attention when something unusual happens. In Russia “the framing of fraud” is commonly used regarding ecolabels. As there is no official body for certification a number of producers resort to the private labeling and controlling systems. In fact, this issue is currently discussed on the Internet because these private firms work in their own way and nobody can guarantee their honesty and valid estimate (http://lavkagazeta.com/otvetstvennost/podderzhi-mestnogo-fermera-0; Vesti.ru, 2013).

Up to now, we have only considered non-specializing mass media resources. But it is impossible to come by the existence of organic product-oriented sources. Thus, in Russia, there is a specializing printed media “LavkaLavka newspaper” which is fully devoted to the topic of organic farming. It was established by a farmer cooperative LavkaLavka in order to provide trustful and truthful information about the current state of affairs in Eco production. It surely could be rather impartial because the main stakeholders are farmers themselves and it is important for them to make organic food popular and highly sought. Sometimes in their article “revealing framing” could be seen, but it is used positively, authors say that in spite of those myths organic food could have a really good impact on people's health, environment and so on (http://lavkagazeta.com/ekologiya/organicheskaya-eda-mify-i-realnost). The main emphasis is made on the lack of true knowledge among consumers, but not on the organic food itself.

Besides this, producers of organic food are also the actors of the discourse. Communication between them and consumers is going on the base of the websites which belong to the particular producers. Commonly used framing, in this case, is a “utility” framing. Producers tend to aggrandize their commodities in order to gain more profit. These sources should be treated cautiously because authors use to conceal unacceptable information and bring to the forefront only positive issues (http://econet.ru/articles/2913-organicheskie-produkty-pitaniya; http://gyrlyanda.ru/news.php). Another example of specialized mass media source is LookBio magazine (http://lookbio.ru/) which main aim is ecological enlightenment. They provide people with useful information which would help them to distinguish truly organic products from forgery: how internationally accepted ecological labels look like, how can one differentiate greenwashing from official declarations, and so on.

Germany is not an exception in this regard. Thus, some specializing websites concentrate on organic food could be found (http://www.organic-europe.net/country-info/germany/news.html). However, what was mentioned by a number of interviewees, German consumers tend to pay attention to the very local specialized media, such as magazines and leaflets which are possible to be taken at the shops. It could be the case that these sources emphasize only good qualities of organic food as long as they are not impartial. And, moreover, they are aimed at ecological education of consumers; they usually provide information about labels, places of purchasing, etc.

To conclude, it is evident that Russian and German media usually follow the same rhetoric to represent the topics of organic food. However, framing differs in some aspects. Thus, according to the results of analysis, we could say that in both countries organic food could be presented simultaneously both as possessing unique features and as not having them. However, in regards to regulation, difference, economic benefits and reasoning rhetoric German and Russian media differs a lot. That is why it is reasonable to say that Russian consumers tend to be more suspicious about organic food and understand it differently from German consumers, who tend to receive more positive information about organic food and perceive it equally safely as usual food products. Consequently, German consumers tend to understand organic food as the way to preserve the environment, natural resources and treat animals in a better way; the way to support local economy if being protected from the import invasion; identifiable with the ecolabels based on permanently tightening of the organic production regulations. On the contrary, Russian consumers is known to understand organic food as more tastier and useful for the health and because of this more expensive in comparison to conventional food; the way to develop local economy since national standards allow producers to enter global market and decrease the level of import from Europe; the products which could be identified only by self-checking due to the absence of national ecological label and certification. However, consumers in both countries are aware of the possible fraud and decision cases, what make them have less confidence in organic food. In general, mass media usually emphasize all the disadvantages of the Russian market and make consumer suspicious about organic food what brakes market from further development by undermining consumer trust. In contrast, German media usually emphasizes more positive things about organic food and that's what makes people trust in them more.

2.4 The impact of governmental and private standards on building trust on the organic food market in Russia and Germany

As it was revealed from the results of the online survey and interviews conducted with organic food consumers in Russian and Germany they tend to base their trust in it on the base of the label which can be found on a product. However, it is also important to mention that not just the label but what is behind it: laws, norms and regulations and their compliance matter the most. It is necessary for a produce to comply with these norms in order to put the label on an item and if there is the label it means that this production was checked and the product is really organic. Nevertheless, despite the common ground defined by the guidelines of Codex Alimentarius and IFOAM, which are voluntary, national legislation in terms of organic production and labeling differs significantly between Russian and Germany. This part is devoted to the analysis of current legislative base for organic food and aim at revealing similarities and differences between them in order to understand why both Russian and German consumers tend to rely on labels while choosing an organic product.

Governmental standards for organic production in Russian and Germany

As we have mentioned before, there is a common base for defining the notion of organic product both for Russia and Germany. “The Codex Alimentarius” and “The IFOAM norms” contains basic guidelines for member countries, including those analyzed in this work, in case they would like to approve the production of organic food as a separate kind of food industry. It is so called “standards for standards” as they tend to guide governments and private certification organizations in the process of rules setting. However, it is just voluntary in nature and delegates a wide range of responsibilities to local authorities.

First of all, it is of crucial importance that German sector of organic food production is regulated much well than in Russia. The evidence proves that on German market it is possible to find three types of regulations which were developed at different levels. These regulations are European Union law on organic production which is common for all EU state members (Council Regulation No 834/2007/EC of 28 June 2007 on organic production and labelling of organic products and repealing Regulation № 2092/91/EEC; Commission regulation (EC) №889/2008 laying down detailed rules for the implementation of Council Regulation № 834/2007; Commission regulation № 271/2010); German law on organic production (The Organic Farming Act - ЦLG) and private standards approved by the largest organic-food association in Germany - Bioland together with some private organizations rendering services of ecological labeling, as Demeter, for example. At the same time the documents that set out rules for organic production in Russian Federation on the governmental level are GOST P 56104-2014 on organic food products: terms and definitions; GOST P- 56508-2015 on organic products: rules of production, storage and transportation; GOST Р 57022-2016 on organic production and the procedure of voluntary certification of organic production; and the standards for organic production, processing and labelling developed by non-commercial partnership “Ecological Union” in St. Petersburg as a privet initiative. In comparison to German regulations, Russian ones are not obligatory for all and could be implemented optionally by producers. It shows that in Russia any product could be labeled as organic even if doesn't meet the requirements of organic production what makes Russian consumers more vulnerable to fraud and deception in comparison to German buyers. Moreover, it doesn't guarantee the common understanding of the concept among Russian and German consumers even with the main aim pursued by all listed regulations, which is to sustain effective functioning of the market, guarantee fair competition, and ensure consumer confidence and protecting their interests.

To begin with, the Council Regulations, as the basic regulatory tool for organic production in Germany, were developed by the European Parliament and the Council in cooperation with the Regulatory Committee on organic production, comprising representatives of all EU countries and a Commission representative as chairperson (https://ec.europa.eu/agriculture/organic/eu-policy/eu-legislation/regulatory-committee_en). But in fact it does not propose the definition of organic food explicitly but states that “processed food should be labeled as organic only where all or almost all the ingredients of agricultural origin are organic” and “organic means coming from or related to organic production” (Council Regulation No 834/2007/EC, 2, 4).

With regard to Russian organic production legislation, it is necessary to mention that GOST P 56104-2014 “On organic food products: terms and definitions” was developed by the division of Chamber of Commerce and Industry of the Russian Federation which is National Fund for Protection of Consumer's Rights. These organizations have nothing to do neither with agriculture in general nor with organic production in particular, what allows to state that organic production regulation in Russia is not perceived as something special as it takes place in Germany. At the same time GOST P- 56508-2015 “On organic products: rules of production, storage, and transportation” in contrast, was developed by the Committee of State Duma on agriculture questions, what makes it more detailed and concrete. The latter also proposed a rather broad definition of organic products, which is as follows: “natural or processed product made from plant or animal raw material, grown in the zones for organic agriculture, and also forest, bee-, and fish products, grown, produced, processed, certified, labeled, stored and traded in accordance with the rules of organic production, for the purpose of further consumption in processed or not processed type” (GOST P 56104-2014). It is stated the documents was developed in keeping with basic guidelines of “Codex Alimentarius”; “IFOAM norms” and EU Council regulations, what ensure the common understanding of organic product in Russia and Germany.

Generally, GOSTs represent the same points as the European Regulations; the requirements converge with each other because of the common ground wrote in Codex Alimentarius and IFOAM norms. Nevertheless, there is a notion about labeling which tells that product could only be labeled organic if it corresponds to the requirements of the GOST, but there is no any notion about who should carry out responsibilities of controlling and checking farms to the consistency those rules and what kind of label should be used. However, GOST Р 57022-2016 “Оn organic production and the procedure of voluntary certification of organic production” reveals the procedure of organic certification for those bodies who are responsible for the realization of this activity. But what is notable, till now, there is no any official governmental authority responsible for ecological labeling (http://www.ecocluster.ru/monitoring/?ID=13728). It allows saying that even with the approval of organic production legislation in Russia people still remain unaware of whether product organic or not because of the absence of any label issued by controlling body. In this case product could be labeled as organic in producer's sole discretion; moreover, any notion of the organic or biological origin of a product could be used.

It is important to highlight that European regulations, on the contrary, prohibit the usage of terms that indicate organic food in relation to the non-organic product throughout the community and independently of the language (Ibid. 3). The implementation of EU-label is obligatory for the organic product since 1 July 2010 along with the indication of the place where the agricultural raw material was farmed; it basically means that any really organic product should be labeled, but only in case it contains more than 95% ingredients of organic agricultural origin (Ibid.). What is more “the organic logo of the EU shall only be used if the product concerned as produced in accordance with the requirements of Regulation (EEC) No 2092/91 and its implementing regulations or Regulation (EC) No 834/2007 and the requirements of this Regulation” (Commission regulation №271/2010). As for Russian producers, organic certification is not compulsory, there is no officially approved logo or certificate, moreover, and there is no one common certification and controlling authority (GOST Р 57022-2016).

However, the obligation to control and evaluate farms for consistency organic production rules remains with special controlling bodies, which are not clearly defined in both documents, and any case of mislabeling should be immediately communicated between controlling bodies in case of European regulations, but not the case when concerning Russian law (Commission regulation №271/2010; GOST Р 57022-2016). What is more, a special platform which is called “The Anti-Fraud Initiative” was created among European countries to protect the market from fraud (http://www.organic-integrity.org/). Its aims are “to analyze fraud cases, to raise awareness for the problems and to improve the processes where relevant” (IFOAM, 23). In return, Commission should be informed about the names and addresses of competent authorities (Ibid.21). Any case of fraud is considered as the punishable offense. As reported by German Federal Ministry of Food and agriculture: “Violations of the EU legislation governing organic farming are liable to one-year imprisonment or a fine of up to € 30,000. This applies especially to the fraudulent use of indications referring to organic production methods in the labeling and advertising of organic products” (BMEL).

This is not the case on the Russian market. Organic products are not included in the list of food products that must be obligatory certified (http://www.rospromtest.ru/content.php?id=14). It means that even with the implementation of governmental regulations there is still a high risk of fraud. Those producers who label their products as organic even if they do not meet the requirements written in the GOST are not the subject of punishment. The only penalty that could be implemented in accordance with the regulations is the certificate termination for those who already have one. Nor fees or imprisonment are mentioned as measures against rules violators (https://www.inventech.ru/lib/pravo/pravo-0221/). Surely, the violations of governmental regulations, in general, are subject to civil, administrative and criminal liability, but still, organic certification is voluntary there are no legal ways to restrain producers from misleading consumers.

It could be a little bit complicated in the case of European regulations as they should counteract with local laws. In Russian, no cases were documented about attempts of local governments to implement any rules for organic production. However, European Council regulations by no means prevent the implementation of local regulations, which could be even stricter than European regulations, but should not contradict with them. It follows that already mentioned “Organic farming act” was created with the aim to increase the effective implementation of the EU legislation governing organic farming, particularly in Germany. It serves to clarify and supplement the changes in EU legislation in the area of organic farming along with the strengthening the inspection system in organic farming (http://www.bmel.de/EN/Agriculture/SustainableLandUse/_Texte/OrganicFarmingInGermany.html#doc381512bodyText9). These changes are concerned with the publication of records and certificates of organic companies that are subject to the organic inspection system (Ibid). However, it doesn't propose any certificates or logos to be received by producers. The main content of this document is the allowance to delegate specific inspection tasks to the inspection bodies operating in the respective Land, what transfer the controlling tasks to even more local level; it is also allowed to delegate sovereign tasks to the private inspection bodies (Ibid.). So, the main field of regulation by the Act is the delegation of controlling authorities to the third parties.

Speaking about labeling and national standards, as it was mentioned earlier, In Russian Federation there is no common ecological sign. Conversely, on the base of Council regulations, every interested manufacturer could receive EU-logo, which looks like a leaf made of 12 stars on the light green background (Commission regulation №271/2010, 21). Another biological label which is widely spread all over Germany is Bio-Siegel. While EU-Logo is a compulsory label for organic food in Europe, including Germany, Bio-Siegel is a national German organic production logo that may be used on a voluntary basis (http://www.bmel.de/EN/Agriculture/SustainableLandUse/_Texte/OrganicFarmingInGermany.html#doc381512bodyText9). In order to receive Bio-Siegel logo, production must meet the requirements stated in EU council regulations analyzed above. This basically means that “the products are manufactured and controlled in accordance with the requirements of the EU legislation governing organic farming; as the Bio-Siegel is based on the EU legislation governing organic farming, it is fully subject to its inspection provisions” (Ibid.). The authority responsible for this logo issuance is Federal Office for Agriculture and Food (http://www.ble.de/). There are a number of local ecological labels as well, for example, BIOlokal, Lippequalitaet or Senne Original from Nordrhein-Westphalen region.

All in all, the Council Regulations and German Organic Farming Act along with Russian governmental regulations are based on Codex Alimentarius and IFOAM norms in many aspects. It indicates the implementation of international guidelines for local standards to ensure the common base for organic food concept understanding and controlling of the production process. Nevertheless, those regulations do not identify an organic product with organic labeling as the Codex does, but mostly define organic food as connected to the organic production and further provide the detailed description of organic production rules following the same order as the Codex and IFOAM rules. In general, they ensure the respect for natural system and cycles. “Biological and mechanical production processes and land-related production should be used to achieve sustainability, without having recourse to genetically modified organisms” (https://ec.europa.eu/agriculture/organic/eu-policy/eu-legislation/brief-overview_en).

Moreover, the preferential is given to the closed cycle's system, where internal inputs and resources are used instead of open cycles based on external resources (Ibid.) However, if there is no possibility to use only internal resources, external one should be: organic materials from other organic farms; natural substances; materials obtained naturally, or mineral fertilizers with low solubility; and when synthetic resources are inevitable they should be included in the list of allowance in the annexes to the council regulations (Ibid.). To summarize, the new regulation and the EU organic logo have made some significant progress in achieving “clarity for consumers throughout the Community market” (Recital 24 of Regulation (EC) No 834/2007), and in promoting “a harmonized concept of organic production” (Recital 28 of Regulation (EC) No 834/2007).

One more important issue covered by regulations is import. The Codex Alimentarius subscribe some guidelines for the organization of organic products trade with other countries in comparison with IFOAM norms where the lack of such issues is noticeable. Nevertheless, European regulations take import as a more serious issue in comparison to Russian rules. Thus, in European regulations the whole title VI, Articles 32-33 are devoted to the topic of trade with third countries and the details of this process are covered: how, from what countries, under what circumstances imported goods could be allowed to enter a local market (Council Regulation (EC) No 834/2007). In comparison, Russian GOSTs do not present any rules about the process of organic goods import from other countries. In fact, it makes Russian market flourishing with lots of imported products which are hardly possible to check. That is why import of organic food is a subject for general food import regulations implied on the food market.

Private regulatory initiatives in Russia and Germany

Till now we were considering only official standards but it is also necessary to look at the private standards concerning organic food production both in Russia and Germany as they play a similar role in the process of controlling the organic market in both countries. It is reasonable to say that they are usually stricter than governmental regulations what makes them more trustworthy for consumers. For instance, one of the most famous private certification and controlling regulations in Germany were approved by organic food association Bioland. It is known to be the leading association for organic farming in Germany united more than 6300 farmers, gardeners, beekeepers and winegrowers producers corresponding Bioland standards (http://www.bioland.de/ueber-uns/about-us.html). It promotes organic production as the one in balance with nature, supporting biodiversity and environment and climate protection for the better future of humankind (Ibid.). Based on IFOAM norms it claims to bear social responsibility by establishing sustainable jobs (Ibid.). Along with social development, it pursues the aim of sustainable economic development by creating a positive image of organic agriculture for young people and sustaining fair prices inside the partnership (Ibid.). Those who are working under the requirements of Bioland carry their label. As can be expected, requirements of Bioland are more firm than those approved by EU-legislation. There could be found a number of differences, for example, according to Bioland standards 100% of the farm must be based on organic food production, while EU regulations allow organic and traditional food production within the same household; a number of animals kept on the farms are lower according to Bioland norms; product certified by Bioland logo must contain 100% organic ingredients, while the EU-regulations allow labeling product organic when it contains at least 95% of organic ingredients (Council Regulation No 834/2007/EC; Bioland Standards).