A/HRC/43/44/Add.6 A. Criminal Activities Comments: When describing the agriculture system in Italy, the first section falls under a title called “criminal activities”, well before describing the role of the European Union Common Agricultural Policy (CAP), small holders farming or issues such as the use of pesticides and the climate crisis challenge. With regard to paragraphs 43-46, note that the Italian Ministry of the Environment is taking measures related to ‘Land of Fires’ in order to limiting or withdrawing the use of specific areas for agricultural and grazing activities. In november 2018 the Italian Minister of the Environment has also signed a Protocol (“Protocollo d’intesa per un’azione urgente nella Terra dei fuochi”) to provide a concrete response to the phenomenon of waste burning in Campania Region. 43. The infiltration of organized crime in the Italian food system is a major concern, especially for small-holder farmers and food producers. They are threatened and damaged by the infiltration of organized crime in the agricultural and food production sectors. Comments: The text suggests a total “infiltration” of criminal organizations into the agri-food system not supported by any references. Unless substantiated by objective data it should be deleted. This assertion doesn’t mention that Italy already faced the unfair trade practices in 2012 (so please, quote article 62, law decree n.1 January 24, 2012 – converted into Law n. 27 March 24 of the same year), well before the conclusion of the works in the EU, leading to Directive n. 633 only in 2019. 44. The most visible cases are the ‘Terra dei Fuochi’ (‘Land of Fires’) in Campania, where contaminating products are dumped in the rural areas, burned or poured into rivers. The severity and long-term consequences of environmental crimes concerning the illegal disposal of waste in agricultural land and the contamination of waters have a significant impact on the planet and people exposed to it. The Special Rapporteur was concerned by this situation, in particular regarding the process of remediation of contaminated land, the support to small-scale farmers who continue to be affected by criminal actions and the citizens whose health has been compromised.9 45. Also, in wholesale markets, farmers are forced to accept low prices, pay to sell their products or use monopolistic services (like parking, transport and packaging) provided at high prices. The purchase of land with the proceedings of illegal activities and the forged documents to access the resources of the Common Agricultural Policy even without title; the tens of cases of counterfeit pesticides that are imported or assembled and often sprayed by workers without adequate knowledge and safety measures; the increase in food- frauds and contamination are among the illegal activities. Reports and local realities reveal the increasing presence of criminal organizations across the food chain, from farm to fork, through the two parallel phenomena of money laundering and money dirtying, i.e. the investment of clean capitals into the rigged food system because of the highly lucrative revenues that it can generate.10 Comments: Several assertions in this paragraph remain without evidence. Please, provide detailed sources for declarations such as “purchase of land with the proceedings of illegal activities and the forged documents” (specify where this happened); “the tens of cases of counterfeit pesticides that are imported” (from which countries, indicate the areas or localities where this happened); “the increase in food fraud and contamination” (when such an “increase” 9 10 Forte I.M. et al (2019) Blood screening for heavy metals and organic pollutants in cancer patients exposed to toxic waste in southern Italy: A pilot study, Journal of Cellular Physiology, 1-10. ISTAT 2020 - Stima preliminare dei conti economici dell’agricoltura, anno 2019. 7