The EU Commission identified significant weaknesses in the third-country control procedures through years of monitoring. Therefore, regulations regarding imports will be tightened further and an equal playing field for EU Commission monitoring of third-country control agencies. The recognition of equivalent standards was phased out by the end of 2024 because of the difficulty of monitoring third-country standards. The new import procedure, fully effective as of January 1st, 2025, allows only compliant products to be imported. The products covered are those under the EU Organic Regulation (EU) 2018/848 (Compliance, Art. 46) and equivalent products under a formal trade deal (Equivalence in a trade accord, Art. 47). The previous systems of ‘Recognized Third Country’ and ‘Recognized Third Country Inspection Body’ have now been fully phased out.
Import and export regulations for organic products will change
Import regulations starting on January 1st, 2025
The EU Commission modified the electronic Certificate of Inspection (e-COI) form within the Trade Control and Expert System (TRACES) to allow third-country imports of organic products to conform to the new compliance procedure. This e-COI is now mandatory and comprehensively covers all necessary fields to ensure full compliance with EU standards. There have been several years of additional controls for organic imports from certain third countries, such as China, Ukraine, Kazakhstan, Turkey, Moldova, Russia, and India. These consignments have been sampled in Germany downstream, by us at the first consignee. This procedure will continue until further notice, as per agreement at the federal level. Pay attention to the following:
- The specialist organic import control of the country will fall under the jurisdiction of the state authority in which the customs clearance is performed.
- Customs will only clear customs upon import of consignments.
- The new regulations, particularly those concerning compliance and traceability, significantly impact smallholder farmers globally, requiring them to meet stringent EU standards for exports.
- Updates to the list of permitted substances for organic production, including the renewal of approvals for low-risk substances, are effective from mid-2025.
Changes to the inspection of products
The relevant regulations require that organic imports from third-country countries must be notified at least one day before arrival by the country authorities. If imports are not subject to border inspection at the destination place, it is necessary that the appropriate state authorities be informed about the import. This is done by TRACES.NT through the mandatory entry of arrival data in the appropriate fields. The system automatically informs the relevant state authority about the pending import once the e-COI is validated. Therefore, ensuring accurate and timely submission of your e-COI through TRACES is crucial.
These points should also be considered:
- For goods subject to border control, inspection is generally done at the border control point. For goods that are not subject to border controls, inspection is done at the border control point or the place of release for free circulation by the national authority.
- Organic import controls must be completed before the goods can be released as an organic consignment (or part consignment) in the Certificate of Inspection.
- The specialized organic import control was transferred to the local state authority at the beginning of the year.
- The emphasis on full compliance with EU organic standards means that all imported organic products must meet the same strict production and labelling requirements as those produced within the EU, unless a specific equivalence agreement through a trade deal is in place.
Export of organic products from EU to UK starting July 1st, 2022
Exports of organic products to the UK Organic products certified by EG-OKO–VO will continue being recognized as equivalent.
Upon export of organic products to the UK, a certificate of inspection (GB-Col) will be required.
Prerequisite is that you send an application for the issuance of the GB-Col with a completed draft of the GB-Col (incl. accompanying documents) to your certifier, who will issue the document.
