Changes to process eligibility for export to the EU of products ground, crushed, powdered or milled

Defra informed us last week that the process of grinding, crushing, powdering or milling will no longer be eligible for export to the EU as they do not consider such products meet the definition of ‘Processed’ and therefore fall outside of the scope of the UK-EU Trade & Cooperation Agreement (TCA).

Organic regulations use a definition of ‘processing’ found in Regulation (EC) No 852/2004 as meaning: any action that substantially alters the initial product.

Defra have stated in relation to grinding, crushing, powdering and milling that ‘These operations simply reduce the product to a smaller particle size and do not change its essential characteristics’.

We realise how disruptive this is and have urgently requested further discussion with Defra. However, the guidance issued to us by Defra instructs us that we can no longer endorse COIs for such products which have been imported into the UK and not sufficiently processed prior to export.

If you are concerned about the eligibility of your products, please contact us for further guidance via our import export team coi@soilassociation.org.

The more information you can provide regarding why you believe the processing of your single ingredient powdered, milled or granulated products substantially alters the product, the better. This can help our team further explore potential eligibility for export