Simplification of organic rules

Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2018/848 as regards certain production, labelling and certification rules and certain rules on trade with third countries

Update

The European Commission proposes a series of amendments to the Organic Regulation 2018/848 to clarify and simplify the European Union’s organic rules.

The proposal includes important changes to the criteria concerning the size of farms eligible to join a group of operators. Criteria based on turnover associated with their farms’ organic sales through the group are removed, and eligible farm sizes are increased. Requirements concerning the legal personality of a group are also amended.

The Commission also proposes extending its existing recognition of non-EU countries with equivalent organic control systems from 31 December 2026 to 31 December 2036: this will provide adequate time for the negotiation of new equivalence agreements with these countries. For products coming from these countries, additional requirements are proposed in order to use the EU organic logo, such as bans on hydroponics and stricter animal welfare rules. Organic terms such as “bio” or “eco” can be used for food imported from equivalent countries without meeting these additional requirements.

Organic foods (with at least 95% of ingredients organic) processed in the EU and using imported ingredients from countries recognised as equivalent may use the EU organic logo if the ingredients meet the specific additional requirements. These requirements do not need to be met if imported ingredients constitute less than 5% of the product.

Further proposals include removing the requirement for the Commission to develop a list of approved cleaning and disinfection products; introducing specific conversion rules for organic quail meat; amending veterinary medicine withdrawal periods; and updating poultry housing and outdoor access rules.

Stakeholders in non-EU countries that are members of the World Trade Organization can submit comments on this proposal via competent authorities until 22 March 2026.

Impacted Products

All organic products

What is changing?

The European Commission has notified the World Trade Organization Technical Barriers to Trade (WTO TBT) Committee (G/TBT/N/EU/1183) that it proposes the following changes to the Organic Regulation 2018/848.

Groups of operators

The definition and rules for groups of operators are outlined in Art. 36.1. These include strict limits on the size of each group member. Currently, an organic operator can only be a member of a group of operators if (Art. 36(1b)):

• the operator’s individual certification cost represents more than 2% of their turnover or standard output of organic production or
• their annual turnover of organic production is not more than €25,000 or standard output is not more than €15,000 per year or
• their holding is less than 5 ha, or 0.5 ha in the case of greenhouses, or 15 ha in the case of permanent grassland.

The Commission proposes to amend these conditions by removing the criteria relating to organic sales and turnover. Members of a group will only have to meet the specified limits for holding size, and these limits will be increased: it is proposed that a group member must have a holding less than 10 ha, or 1 ha in the case of greenhouses, or 30 ha in the case of permanent grassland.

Currently, a group of operators must have legal personality (Art. 36(1d)). This means that the group must be recognised under national law as having a distinct identity, as well as legal rights and duties. The Commission proposes to amend this requirement so that the group can either have its own legal personality, or be part of a farmer cooperative association, operator cooperative, association, federation, or organisation that has a legal personality.

Recognition of non-EU countries as equivalent

Some non-EU countries have organic production control systems that have been recognised as being equivalent to those in the EU. These recognitions are due to expire on 31 December 2026, and negotiations have been initiated with these countries for new agreements on equivalence. However, not all these negotiations will be completed by 31 December 2026. To avoid disruptions to trade, the Commission proposes to extend the existing recognitions to 31 December 2036.

Use of EU organic logo on products from non-EU countries recognised as equivalent

Recognition of equivalence means that a non-EU country has demonstrated that it meets the EU’s organic production objectives and principles, but may do so in a different way from the EU. Equivalent organic food and feed products produced in non-EU countries are permitted to use the EU organic production logo. However, the Commission proposes that products with an EU organic label must meet the following additional requirements (to be set out in a new Annex VII).

• Hydroponic production (growing plants which do not naturally grow in water with their roots in a nutrient solution) is prohibited (referred to in Regulation 2018/848, Annex II, Part I, 1.2).
• Tethering or isolation of livestock is prohibited, except for a limited period and if justified for workers’ safety or animal welfare reasons (Annex II, Part II, 1.7.5).
• Loading and unloading of animals must be carried out without the use of any type of electrical or other painful stimulation to coerce the animals, or the use of allopathic tranquillisers (Annex II, Part II, 1.7.11).
• Minerals, vitamins, amino acids, and micronutrients may only be added to foods if their addition is required by EU or EU Member State law (mandatory fortification), or if their use is authorised in specific legislation on food for particular nutritional uses (see Background).

The use of the EU organic logo is optional for organic products imported from non-EU countries.

Use of EU organic logo on processed products using imported ingredients

If food or feed products processed in the EU contain at least 95% organic ingredients (Arts. 30(5,6)), the EU organic logo can be used if the imported ingredients:

• fully comply with EU production rules
• come from a non-EU country recognised as equivalent and comply with the specific requirements listed above (new Annex VII)
• come from a non-EU country recognised as equivalent, and where those ingredients account for 5% or less of the agricultural ingredients of the product (by weight for food and in general for feed). Compliance with Annex VII requirements is not required in this case.

Use of organic production terminology on products from non-EU countries recognised as equivalent

The proposal clarifies that terms referring to organic production (such as “bio” and “eco”) are also permitted on products from non-EU countries recognised as equivalent (amended Art. 30). Unlike the conditions for using the EU organic logo, there will be no need for products to comply with new Annex VII to make use of these terms.

Products for cleaning and disinfection

Regulation 2018/848 requires the establishment of a list of cleaning and disinfection products that may be used in processing and storage facilities producing organic food. Due to the large number of products and the variety of situations in which cleaning is required, it is not feasible for the relevant experts (Expert Group for Technical Advice on Organic Production, EGTOP) to draw up such a list. The Commission therefore proposes to delete this requirement.

Conversion periods for quail meat

Regulation 2018/848 establishes conversion periods and a minimum age at slaughter for poultry, but not for quail. The Commission proposes to introduce a conversion period of 5 weeks for quail meat production, and a minimum age of 42 days at slaughter (addition to Annex II, 1.9.4.1).

Withdrawal periods for veterinary treatments

For chemically synthesised allopathic medicines, the minimum withdrawal period (the time between the last use of a veterinary medicine and production of food) is currently twice the withdrawal period included in a medicine’s marketing authorisation, and a minimum of 48 hours (even where the normal withdrawal period is zero days). The Commission proposes to remove the minimum duration of 48 hours and align requirements with Regulation 2019/6 (change to Annex II, 1.5.2.5). (Allopathic medicines are conventional, mainstream medicines based on diagnosing and treating diseases with evidence-based methods (e.g. surgery, drugs) as opposed to traditional or alternative practices.)

Treatment of poultry

Poultry must currently be exposed to open-air access at the earliest age practically possible. As this can potentially put unfeathered birds at risk, the Commission proposes to limit this rule to birds that are sufficiently feathered to regulate their body temperature. It also proposes to limit the size of each poultry house to 1,600 m² and apply this limit per house, not per production unit, to allow farm development without harming animal welfare (changes to Annex II, 1.9.4.4).

Why?

In 2024, the European Commission undertook a series of consultations with EU Member States and stakeholders in the organic sector to identify areas where regulations could be improved. These consultations highlighted issues about the date of expiry of equivalence schemes, and the challenges for small-scale farmers (particularly in non-EU countries) to meet current eligibility rules for groups of operators. They also identified specific technical issues such as cleaning and disinfection products, and the withdrawal periods related to veterinary medicinal products (European Commission 2025).

In 2024, the Court of Justice (Case 240/23) ruled that imported products that do not fully comply with the production requirements set out in Regulation 2018/848 could not be labelled as organic or make use of the organic logo, even where the EU has recognised those countries’ production and control systems as being equivalent to those of the EU. The Commission therefore needed to propose amendments to the Regulation that would address the concerns of the Court while ensuring that the organic nature of imported foods could still be accurately communicated to EU consumers.

Timeline

In its notification to the WTO, the European Commission foresees the adoption of this Regulation in 2026.

What are the major implications for exporting countries?

Extension of equivalence schemes

The extension of existing recognition equivalence schemes beyond the end of 2026 should provide reassurance for operators in those countries.

Changes to group of operator rules

The broader definition of legal personality for groups of operators would remove a significant obstacle to group certification. The proposed amendment to criteria for membership of a group of operators would also simplify the conditions for many farmers. However, limiting membership criteria to holding size alone could exclude operators from group membership in sectors where economic viability requires areas larger than those specified (e.g. banana or sugar cane).

Recommended Actions

Stakeholders in non-EU countries that are members of the WTO can submit comments on this proposal to their competent authorities. Authorities can communicate comments to the EU by emailing the EU TBT Enquiry Point until 22 March 2026.

Background

The Organic Regulation 2018/848 lays down the EU rules on organic production and labelling of organic products. It revised and strengthened the controls system, trade regime, and production rules that had been in place since 2007. The move from the principle of equivalence to the principle of conformity marked a fundamental change to the regulatory approach.

The earlier Regulation 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 Regulation, producers in non-EU countries that do not have equivalence recognised in a trade agreement with the EU, or are not recognised as an equivalent country under Regulation 834/2007, have to conform with the same set of rules as those that apply to EU producers.

Micronutrient requirements in certain foods

Foods that have particular characteristics or effects in relation to health or nutrition or in relation to needs of specific groups of consumers are regulated by Regulation 609/2013 (foods for infants and young children, medical purposes, and weight control) and Directive 2006/125/EC (baby foods). These set mandatory nutritional requirements that have to be met to place these foods on the market. Foods where addition of vitamin and mineral supplements is mandatory are not excluded from displaying an organic logo.

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