Importing for organic businesses after Brexit
This information is correct at the time of publishing (21st January 2022) with the following exception:
PLEASE NOTE: Amendment to EC regulations have now been voted through and will see UK certifiers removed from the new version on EC1235 Annex IV due for implementation at the end of 2021. As such we will not be able to approve COIs for product outside the scope of the TCA for export to EU/EEA/NI in 2022. Please see updates below.
From the 1st January 2021, several things changed for organic farmers and growers, manufacturers and traders importing into the UK.
As the UK’s organic experts and the largest dedicated food and farming charity, we have compiled some key information for organic businesses who import product into the UK. We are here to support you in this period of change.
In addition to the guidance on this page, you can also watch our 25 minute video guide, created to help importers and exporters of organic food, feed, seed and livestock understand new certification and port clearance requirements for a number of differing trade scenarios. (Please note the 1st July date reference in relation to requirements for GB COI for imports from the EU/EEA countries >5:28< has now been extended to 1st July 2022)
Importing into the UK after 31st December 2020
The EU has now agreed to recognise the UK as equivalent for organics until 31 December 2023. This is on top of the already agreed equivalence recognition for UK control bodies, and the UK recognition of the EU as equivalent.
As the UK will retain EC1235/2008 in our UK organic regulation coming into force in Jan 2021, recognition of organic products where certifiers are approved under EC1235/2008 scope (Annex IV of the EC1235/2008 organic regulation1 ) should continue.
The scope of the trade deal limits products that may be imported from the EU and Northern Ireland (NI) into GB. Goods imported into the EU or NI from other third countries and not further processed (re-packing or re-labelling are not considered processed) in the EU or NI cannot be re-exported to GB.
Although GB COIs will not be required for imports from the EU, Norway, Iceland, Liechtenstein and Switzerland until 1st July 2022 , there is currently no system in place in GB to recognise EU certification bodies and enable them to issue GB COI’s for products outside the scope of the agreement.
Importing from non-EU countries into NI - If you are importing product from any non-EU country into NI, unless originating from GB and covered by STAMNI (Scheme for Authorised Movements to Northern Ireland), a TRACES NT COI will be required. For all exports into EU zone including NI, both the exporter, the importer and the 1st consignee should hold a valid organic licence.
Defra have confirmed that for the time being goods exported from GB that are travelling without a COI as part of the STAMNI retailers’ easement for Authorised Traders can continue to move as they have been. The UK Government’s standstill period continues to apply to the re-export of EU and RoW organic products from GB to NI under STAMNI. Authorised Traders can continue to move organic goods in 2022 as they did previously in 2021, until further notice.
Additional requirements for importing from non-EU Third Countries into NI - The Northern Ireland Competent Authority (NICA) have issued have issued guidance (based on EC requirements), for certain imports into NI:
- All organic product from Ukraine, Kazakhstan, Russian Federation, Moldova, Turkey and China.
- Sesame seeds imported from India not via EU . Requirements as for import into GB with the additional requirements that (1) Port Health Authority (PHA) will take samples for testing and 92) products may only be placed on the market with reference to organic after PHA have confirmed no ETO residues were detected.
Having previously applied retained Annex III and IV from EC1235/2008, at the end of October 2021 the UK published its own register of Third Countries/Territories and Third County Control Bodies/Authorities (GB1235) recognised by the UK for product imported into GB from non EU/EEA countries. This displays the countries, certification bodies and product categories that may be imported into GB.
From 1 January 2021 different exporting rules may apply in non-EU third countries where equivalency is not agreed with the UK. Businesses are advised to contact the exporting control body in the country they are importing food from if they have any questions.
Additional requirements for importing from Ukraine, Kazakhstan, Russian Federation, Moldova, Turkey and China into GB - DEFRA have issued guidance to certification bodies for import into GB of certain products from Ukraine, Kazakhstan, Russian Federation, Moldova, Turkey and China. Read more about importing in GB from these countries.
Additional requirements for importing sesame seed products from India into GB - Defra have issued guidance on additional requirements for import into GB of sesame seed product from India.
If you are importing organic food, feed or drink products into the UK, you will be required to hold an organic processor licence. 1st consignees, i.e. those who 1st physically receive the goods, where different from the importer, also require a licence. Read our standards for full details of import licensing requirements.
If you are a GB based operator and are responsible for trade of goods going directly between other non-EU countries and the EU, you will need to ensure there is an EU business licensed to import organic goods into the EU.
As of the 1st of August 2021, some of the cost incurred for certification required for movements between Northern Ireland and GB can be covered by the UK government Movement Assistance Scheme (MAS). Further guidance on gov.uk can be found here.
If you currently hold a Wholesaler licence and import from the EU or wish to export to the EU or NI, you will require a Processor licence in addition to, or instead of your Wholesaler licence. You can read more about changes for Wholesalers in our Trade News article.
If you already hold a processor licence, you should contact email@example.com to ensure that your current licence is scoped for importing from third countries and imported products are identified.
If you are importing and placing an imported product on the GB market, it will need to be listed on your Trading Schedule, either individually or as part of a product category e.g. ‘Ambient grocery products, chilled dairy products’.
If you are importer-processor who imports an ingredient for inclusion in a certified product that is already listed on your Trading Schedule, that ingredient product does not need to be listed separately on your Trading Schedule.
Whether changing your licence or extending scope, if you are not currently certified to import you'll need to have completed a Description of Importing form.
Please contact us at firstname.lastname@example.org for further details of how to change or extend scope your existing licence, how to add products to your Trading Schedule or start the application process for a new licence.
Description of Importing Document post transition period
Please complete the form if you plan on importing food, feed or drink products from 1st January 2021Download the Document
GB based operator can no longer use TRACES NT for imports. Imports of organic products into GB from the EU, Norway, Iceland, Liechtenstein and Switzerland will require GB Certificates of Inspection (COI) from 1st July 2022. Imports into GB from all other countries currently require a GB paper-based COI.
- For each consignment you import, a GB PDF CoI will need to be completed by the exporter, endorsed by their certifier and be available to the Port Health or Border Control Post on arrival of the consignment. COI’s don’t need to travel with the consignment, but do need to be with the PHA/BCP ready for when the consignment arrives. If a signed digital copy is sent to PHA/BCP this will be accepted, but an original copy must be received by PHA/BCP within 10 days of clearance. The new GB CoI and explanatory notes are available to download below.
COI's are not needed for good movements into from the EU into Northern Ireland, but operators must use the EU TRACESNT system for imports from all non-EU countries (and hold organic certification as importers). Provided businesses are registered Authorised Traders (STAMNI) COIs will not be required for goods exported from GB to Northern Ireland until October 1st 2021 at the earliest.
DEFRA are informing Third Countries Certifiers of this new requirement. However, please inform your customers there will be a new requirement for imports into GB.
GB CoI Blank Document Template
Blank GB CoI document for imports into the UK from third countriesDownload it here
GB CoI Explanatory notes
Guidance on how to complete the GB CoIRead it here
Extract GB CoI Blank Document Template
This form is to be used for operators wishing to split consignments into batchesLearn More Here
Extract of GB CoI notes
Guidance on how to complete the blank extract templateLearn More
Before you import please ensure the following:
- You hold a valid organic food and drink licence
- Your product are in scope of the TCA more details here
- Your exporter is aware of the new requirement for GB CoI’s
- The GB CoI is completed and sent for approval to the Third Country Certifiers before the good leave
- If you are the importer you have notified the Port Health Authority (PHA) /Border Control Post (BCP) ahead of the organic shipment arriving (at least 24hours in advance)
- You can use the PDF copy of your GB COI in order to clear the goods with PHA/BCP. They will sign, approved and then release the goods
It is important to ensure you are aware of the scope of TCA between UK/EU before you import into GB from the EU or N.I. You can find out more details here.
If you are importing from a Non-EU country into GB you are required to complete a GB COI before the goods leave the third country. If you import organic products without an approved GB CoI this could result in your goods being delayed or loosing organic status. There is currently a grace period for GB COI's for imports from EU, Norway, Iceland, Liechtenstein and Switzerland until the 1st July 2022.
DEFRA Step-by-step guidance on importing organic and importing FAQ's can be downloaded below:
DEFRA Step-by-step guidance on importing organicRead them here
DEFRA FAQS: Importing organic produce into Great BritainRead them here
DEFRA Guidance on importing and exporting organic foodRead them here
For more information on food importing and exporting after Brexit visit the .gov webpages
Talk to us
As the organic experts in the UK we provide a wealth of free information and guidance to our organic licensees.
- Under European Commission regulation 1235/2008 certifier, country and product category must appear in Annex IV of the organic regulation 834/2007 and the exporter must be registered on TRACES NT
- Country, certifier and product category must appear in Annex III of the organic regulation European Commission Regulation 834/2007.