Organic products: Lists of high-risk countries and products
- Organic production
Summary
The European Commission has amended the criteria for determining which organic products should be placed on its forthcoming list of high-risk products that will require more frequent controls. This list will be based on suspicions of non-compliance, in addition to cases of non-compliance that are already established.
EU clarifies criteria for placing organic products on a high-risk list
Commission Delegated Regulation (EU) 2025/2651 of 16 October 2025 amending Delegated Regulation (EU) 2021/1698 as regards certain criteria for the establishment of the list of high-risk third countries and high-risk products
Update
The European Commission has amended the criteria for determining which organic products should be placed on its forthcoming list of high-risk products that will require more frequent controls. This list will be based on suspicions of non-compliance, in addition to cases of non-compliance that are already established.
Impacted Products
All products
What is changing?
The European Union (EU) will establish a list of organic products where there is a high risk of non-compliance with EU organic rules, and the countries in which they are produced (Regulation 2021/1698, Art. 8). Products identified as “high-risk” are subject to more frequent identity and physical checks by control authorities/bodies. The frequency of checks is risk-based, and so will depend on how high the risk of non-compliance is assessed to be.
Under this Regulation, the European Commission allows the identification of high-risk products to be based not only on established non-compliance, but also where non-compliance is suspected.
Why?
In many cases, where there is a suspicion of non-compliance of organic products, it is not possible for the control authority carrying out an investigation to establish (prove) this, due to a lack of information on the potential source or cause of contamination.
This Regulation changes the criteria for high-risk listing, allowing authorities to increase controls in cases where there is a suspicion of non-compliance.
Timeline
The Regulation applies from 26 December 2025. The European Commission is expected to publish the list of high-risk products in the first quarter of 2026.
Recommended Actions
Non-EU countries should strengthen preventive controls, traceability, and investigation of suspected organic non-compliances, as the threshold for increasing import controls has been lowered.
Background
Control authorities undertake investigations in response to EU Member State notifications in the Organic Farming Information System (OFIS), a network for information exchange between the European Commission, Member States, and control authorities.
While there is currently no list of high-risk products set out in legislation, the European Commission provides recommendations annually to organic control authorities and control bodies on products and origins regarding the percentage of consignments that should be checked. These recommendations are made in discussion with the Group of Experts on Organic Production, based on information gathered through OFIS.
Resources
Commission Delegated Regulation (EU) 2021/1698 with procedural requirements for the recognition of organic control authorities and control bodies
Regulation (EU) 2018/848 on organic production and labelling of organic products
Sources
Regulation (EU) 2025/2651 as regards certain criteria for the establishment of the list of high-risk third countries and high-risk products
Disclaimer: Under no circumstances shall COLEAD be liable for any loss, damage, liability or expense incurred or suffered that is claimed to have resulted from the use of information available on this website or any link to external sites. The use of the website is at the user’s sole risk and responsibility. This information platform was created and maintained with the financial support of the European Union. Its contents do not, however, reflect the views of the European Union.
EU clarifies criteria for placing organic products on a high-risk list
Regulation (EU) 2025/2651 as regards certain criteria for the establishment of the list of high-risk third countries and high-risk products
What is changing and why?
The European Union (EU) is establishing a list of organic products where there is a high risk of non-compliance with EU organic rules, and the countries in which they are produced. These products are subject to more frequent controls (identity and physical checks) by control authorities/control bodies.
The criteria for high-risk listing were previously based on established (proven) cases of non-compliance. However, in many cases, although there is a high level of suspicion of non-compliance, it is difficult for control bodies to prove. In this Regulation, the European Commission allows products where there is suspected non-compliance to be placed on the high-risk products list.
Actions
Non-EU countries should strengthen preventive controls, traceability, and investigation of suspected organic non-compliances, as the threshold for increasing import controls has been lowered.
Timeline
This Regulation applies from 26 December 2025. The European Commission is expected to publish the list of high-risk products in the first quarter of 2026.
Disclaimer: Under no circumstances shall COLEAD be liable for any loss, damage, liability or expense incurred or suffered that is claimed to have resulted from the use of information available on this website or any link to external sites. The use of the website is at the user’s sole risk and responsibility. This information platform was created and maintained with the financial support of the European Union. Its contents do not, however, reflect the views of the European Union.