Organic products: Recognition of control bodies

Fourth amendment: Draft Regulation amending Commission Implementing Regulation (EU) 2021/1378 as regards the recognition of certain control bodies; Draft Annex [scroll down to Downloads]

Third, second, and first amendments: Commission Implementing Regulations (EU) 2024/2794 of 31 October 2024 [and] 2024/2140 of 6 August 2024 [and] 2024/1748 of 21 June 2024 amending Commission Implementing Regulation (EU) 2021/1378 as regards the recognition of certain control bodies in accordance with Article 46 of Regulation (EU) 2018/848 of the European Parliament and of the Council as competent to carry out controls and issue organic certificates in third countries for the purpose of imports of organic products into the Union

Update

Under the new EU organic regime, from 1 January 2025 control authorities and control bodies must be listed under Implementing Regulation (EU) 2021/1378 as being officially approved (recognised) to conduct controls and certification of organic products in non-EU countries.

The EU has published a third list of approved control authorities/control bodies under Regulation 2024/2794. This follows the publication of two earlier lists, in August 2024 (Regulation 2024/2140) and June 2024 (Regulation 2024/1748). In total, 44 control authorities/control bodies have been listed.

In October 2024, the European Commission published a draft Regulation with the names of two additional control bodies it intends to add to the list.

Impacted Products

Organic products

What is changing?

The new EU Organic Regulation (EU) 2018/848 brought in a fundamental change from an equivalence regime to a compliance regime, with a 3-year transition period after it was applied on 1 January 2022 (see New EU Organic Regulation explained).

The EU currently imports organic products certified by control authorities and control bodies whose standards have been recognised as equivalent under the old equivalence regime. This recognition will expire by 31 December 2024. Before this date, control authorities and control bodies must be officially approved (recognised) to certify operators and groups of operators in non-EU countries under the new compliance regime. This process is ongoing.

The recognised bodies are listed under Implementing Regulation (EU) 2021/1378. Amendments to this Regulation will be introduced over the coming months with additional lists of the control authorities and control bodies that have been recognised.

First amendment

Regulation 2024/1748, published in June 2024, listed the following 17 control authorities or control bodies:

• bio.inspecta AG
• Caucascert LLC
• CCPB Srl
• CERES Certification of Environmental Standards GmbH
• CERTIMEX, Certificadora Mexicana de Productos y Procesos Ecologicos S.C.
• Control Union Certifications B.V.
• Ecocert SAS
• ECOGLOBE LLC
• FOOD SAFETY S.A.
• IMO Control Private Limited
• Kiwa BCS Öko-Garantie GmbH
• Mayacert S.A.
• Organic Control System LLC Subotica
• Organic Standard LLC
• Servicio de Certificación CAAE S.L.U.
• Southern Cross Certified Australia Pty Ltd
• Tse-Xin Organic Certification Corporation

Second amendment

In August 2024, an additional 15 control authorities or control bodies were listed under Regulation (EU) 2024/2140:

• A CERT European Organization for Certification S.A.
• ACT Organic Company Limited
• Agricert – Certificação de Produtos Alimentares Lda
• Balkan Biocert Macedonia DOOEL Skopje
• Beijing Continental Hengtong Certification Co. Ltd
• CERTIFICADORA BIOTROPICO S.A.S.
• COMPANY OF ORGANIC AGRICULTURE IN PALESTINE
• Ecovivendi d.o.o. Belgrade
• ETKO EKOLOJİK TARIM KONTROL ORGANİZASYONU LİMİTED ŞİRKETİ
• IBD Certificações Ltda
• LACON QUALITY CERTIFICATION PRIVATE LIMITED
• Metrocert S.C.
• Oregon Tilth Inc
• Organizacion Internacional Agropecuaria S.A.
• Organska Kontrola d.o.o. Sarajevo

Third amendment

In November 2024, an additional 12 control authorities and control bodies were listed under Regulation 2024/2794:

• ACO CERTIFICATION LIMITED
• CTR ULUSLARARASI BELGELENDIRME VE DENETIM LTD. ŞTİ.
• DQS POLSKA SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ
• Florida Certified Organic Growers and Consumers, Inc. (FOG), DBA as Quality Certification Services (QCS)
• IMOCERT Latinoamérica Ltda.
• INDOCERT
• ONECERT INTERNATIONAL PRIVATE LIMITED
• Organic Crop Improvement Association International Inc
• Organic Food Development and Certification Center of China
• Organización Internacional Agropecuaria S.A
• ORSER KONTROL VE SERTIFIKASYON ANONIM IIRKETI
• SRS Certification GmbH

The Regulation also amends the categories of products and specific non-EU countries that the listed control body Ecocert SAS may control.

Fourth amendment (proposed)

Under a further draft Regulation presented in October 2024, the Commission proposes to add the following control bodies to the list:

• Başak Ekolojik Ürünler Kontrol ve Sertifikasyon Hizmetleri Ticaret Limited Şirketi
• Bioagricert s.r.l. Unipersonale

Details on the category of products that each control authority or control body may control, and the non-EU countries in which they may carry out controls, are given in the Annexes of the draft Regulations.

Why?

From 1 January 2025, only control authorities and control bodies that are officially recognised to conduct compliance audits will be able to issue organic certificates in non-EU countries.

To be recognised by the EU, control authorities and control bodies must submit a request for recognition under Art. 46 of Regulation 2018/848, and must meet the required conditions.

Timeline

Control authorities and control bodies approved under these Regulations will be recognised from the following dates:

• Regulation 2024/1748 (first amendment): from 27 June 2024
• Regulation 2024/2140 (second amendment): from 10 August 2024
• Regulation 2024/2794 (third amendment): from 7 November 2024.

The draft Regulation under consultation (fourth amendment) is due to be adopted in the fourth quarter of 2024. The new bodies listed in that Regulation will be recognised from 3 days after the Regulation is published.

What are the major implications for exporting countries?

Control authorities and control bodies must be recognised under the compliance regime from 1 January 2025. Commercial contracts between operators and control bodies are generally conducted some months in advance, and both parties will need enough time to plan and prepare for audits in 2025. It will be particularly important for operators in non-EU countries to know well in advance if their current control body will not be recognised under the new regime.

Recommended Actions

It is critically important for organic operators in non-EU countries to monitor the recognition process over the coming months, and to liaise closely with their control authorities and control bodies.

Background

The Organic Regulation (EU) 2018/848 is the basic act that lays down the EU rules on organic production and labelling of organic products. It revises and strengthens the controls system, trade regime, and production rules that had been in place since 2007. It brought in a fundamental change to the regulatory approach, moving from the principle of equivalence to the principle of compliance. The earlier Regulation (EC) 834/2007 recognised that organic goods could be produced in ways that were different, but equivalent in terms of their outcome and alignment with organic principles. Under the new Organic Regulation, this changes to a system of compliance: producers in non-EU countries will have to conform with exactly the same set of rules as those in the EU, with no possibility to recognise equivalence. For further information see New EU Organic Regulation explained.

Resources

Sources