Brexit update for organic food and drink businesses
With the current Brexit implementation period ending five months from now, we're aware that a number of businesses will soon require greater clarity regarding future trade in organic products.
As the UK’s leading organic certifier, we're here to reassure and support our clients - where possible, providing clarity on Brexit requirements, and helping you plan for business in 2021.
With the UK trade negotiations ongoing, and the possibility of a delay to the implementation of new EU Organic regulations (EN 848) next year, some of the detail regarding labelling and recognition of goods remains unclear.
Below is a brief summary of our current understanding of established changes, and changes that could come to affect businesses who export, import or label organic food and drink products after 31st December 2020.
Exporting to the EU and beyond
As of the 1st January 2021, EU organic standards will no longer apply in the UK. To ensure continued acceptance of UK certified organic food and drink products by the EU, two routes to equivalency are currently being pursued:
- EC1235 accreditation for individual UK certifiers
- Acceptance of UK organic standards as part of a Free Trade Agreement
Looking beyond the EU, the UK government progressed agreements with all 13 EU-approved third countries (e.g. US, Australia, Canada, Japan, Switzerland etc) to take us to end of the implementation period. With the exception of additional requirements for Japan and Taiwan, acceptance of UK organic food and drink by non-EU countries has remained unaffected during 2020. This is not anticipated to change significantly, but we await clarification on final renegotiations.
Importing into the UK
The UK currently accepts certified organic food and drink products from the EU without additional organic requirements or documentation. This is anticipated to continue in 2021, but remains dependent on UK government policy.
Having left the TRACES system, it's anticipated that the UK will revert to a paper-based Certificate of Inspection system, which export certifiers in third countries must endorse.
UK operators who import products from the EU, but who are either unlicensed, or do not have importation as part of their certification scope, may face additional certification requirements.
EU/UK origin statements will need to be correct for both domestic and exported products. Depending on the equivalency arrangements with the EU, the EU Leaf logo may or may not be applicable in the UK domestic market after 2020. We're not aware of any plans for a UK organic logo.
Certification codes are anticipated to remain unchanged for domestic products, but at this time, we're unable to provide clarification of new certification codes for exported goods. This will be dependent on the final equivalency arrangements with the EU.
Goods that are already in the EU after the end of the implementation period will not be expected to comply with new requirements.
What we're doing
Should the UK fail to agree organic equivalency with the EU by the end of 2020 (Free Trade Agreement route), UK organic certifiers will require EC1235 status to demonstrate that the products they certify meet EU requirements.
Soil Association Certification have applied for an extension to our EC1235 status to certify to EU regulations within the UK. We understand that all other UK certifiers have also now applied. We anticipate receiving confirmation of approval towards the end of September.
We're continuing to work closely with DEFRA, the UK Organic Certifiers Group, IFOAM EU, and our European accreditors to improve clarity on:
- Timeline for equivalence and any grace periods
- Additional requirements for importers of EU product
- Likely labelling requirements and mitigation options
Find out more on the Brexit Hub
If you'd like more detailed information relating to the above - for example: documentation or registration requirements - or would like to get the latest updates, our Brexit Hub is continually updated to include important developments that may affect organic businesses from 2021.