IN Brief:
- Recognition of organic production rules in 11 non-EU countries would be extended to 31 December 2036.
- Imported organic foods would face additional requirements before carrying the EU organic logo.
- The provisional agreement must receive formal approval before the revised measures become law.
The Council of the European Union and the European Parliament reached a provisional agreement on 20 October to revise organic food rules covering imports, certification, production and labelling. The deal would extend recognition of 11 non-EU countries’ organic production systems to the end of 2036, avoiding a potential interruption when existing arrangements expire in December 2026. Importers and food processors would retain an established route for qualifying products, but using the EU organic logo would remain subject to additional requirements.
The agreement would extend recognition of organic production systems in those 11 countries until 31 December 2036. Current recognition arrangements expire at the end of 2026. Argentina, Canada, New Zealand and the United States are among the countries covered, and an interruption would have complicated the continued marketing of qualifying imported products within the EU. The extension is intended to preserve established trade channels while the bloc applies clearer conditions to the use of its organic production logo.
Equivalence and the EU organic logo would remain separate tests for imported food. A product made under a recognised non-EU system could continue to be sold as organic and use its country-of-origin organic mark, yet qualify for the EU logo only by meeting further production and monitoring conditions. Those conditions may concern living soil, animal welfare and processing methods. The revised position follows a Court of Justice ruling on 4 October 2024 that restricted use of the EU logo on equivalence-based imports; the provisional deal seeks to clarify how the system will operate.
The negotiators also removed a proposed exception that could have permitted the EU mark on food containing less than five per cent of certain ingredients from countries that did not meet additional conditions. Ingredient provenance and certification records therefore remain central to the presentation of mixed-origin products. A processor combining imported agricultural materials with EU-produced ingredients needs to identify which certification route applies to the finished food rather than assuming that the status of an individual raw material transfers automatically to every label claim.
Small direct sellers of unpackaged organic food would face a higher threshold before certification is required. The turnover limit would rise from €20,000 to €40,000 a year, assessed as an average over the preceding five years, while the volume limit would double from 5,000kg to 10,000kg. Eligible small online sellers of prepacked organic products would receive a conditional exemption. These are limited reliefs for particular traders, not an exemption from organic manufacturing controls or traceability for larger food processors.
Organic manufacturing relies on maintaining a demonstrable separation between compliant and non-compliant materials throughout receipt, storage, transformation and packing. Batch records, incoming supplier certificates, cleaning procedures and label artwork controls help establish whether a finished product is entitled to an organic description. The proposed rules for imported products make that documentary link particularly important when raw materials pass through several businesses and jurisdictions before reaching a European factory. An incorrect claim may arise from a misunderstanding of certification scope even when the ingredients themselves are accurately declared.
Organic processors could also receive greater flexibility over cleaning and disinfection products under the proposed revision, according to the Council’s explanation of the policy. The intention is to allow standard products available on the market instead of restricting operators to a dedicated authorised list. Plants would still need to select cleaning chemicals and procedures appropriate to the equipment, contamination hazards and required hygiene standards. The proposed change to organic certification requirements would not override general food hygiene law or remove the need to prevent chemical residues reaching ingredients and finished products.
Transitional arrangements are intended to prevent unnecessary waste of labels and packaging already prepared under the existing framework. Products labelled in accordance with the earlier rules could continue to be sold until stocks are exhausted, according to the provisional agreement. This avoids an abrupt requirement to withdraw otherwise marketable food solely because a revised labelling provision enters into force. Businesses would nevertheless need to determine which products are covered by the transition and distinguish stock already labelled from future production runs.
The provisional deal also includes temporary flexibility for particular non-organic feed inputs in poultry, pig and aquaculture operations, with the derogations due to be phased out. Those provisions affect downstream manufacturing through the certification status and availability of animal-derived ingredients, although the negotiating announcement does not quantify a future increase in certified supplies. The organic sector has expanded substantially: EU organic farmland grew from 9.5 million hectares to 16.9 million hectares between 2012 and 2022, according to Council background material.
Council and Parliament approval, followed by legal-linguistic checks and formal adoption, is still required. Until then, the new turnover thresholds, conditions for the import logo and transitional provisions should not be treated as operative law. The institutions aim to finish before 31 December 2026, when the present recognition period ends. Manufacturers with imports under equivalence arrangements will need to check the adopted wording, their suppliers’ certificates and the point at which any revised labelling rules apply to new production.
