Changes to EU rules for organic grower groups.

In December 2024 new EU requirements came into force which fundamentally changed the requirements for goods imported into the EU from third countries.

With the final deadline for validation of evidence provided in October this year, we explore what these changes could mean.

by Ed Palairet and Lee Holdstock

For many years the EU has employed mechanisms to establish whether imported products certified to local standards could be considered ‘equivalent’ to EU products. From October the EU will require all product to comply with EU organic regulation. This means that EU rules will need to be followed by the certifier at point of origin – a significant change that could mean disruption to some supply chains.

As part of this shift, the rules for Grower Groups in third countries supplying organic products into the EU are also changing. If grower groups wish to continue to export their organic products to the EU, then there are significant changes they need to make before October.

What are grower groups?

Also known as ‘group of operators’, grower groups are farmers and processors who are certified as a group rather than as an individual. The group is set up to carry out its own inspections and manage the compliance of its members, administered by an Internal Control System (ICS). The effectiveness of the ICS is then verified by an organic certification body.

This recognised system gives credible controls of organic integrity while limiting the cost of certification (compared to each farmer holding their own organic certification).

What’s changing?

The rules are becoming more stringent – which may significantly increase the cost of certification for some. Previously, group certification was limited to countries receiving overseas development aid, but with the arrival of the EU’s 2018/848 organic regulation, groups could also be set up in the EU. At the same time, eligibility criteria have been tightened, as smallholders in other countries need to meet the same rules as those in the EU.

Previously, production rules could be adapted to local conditions provided they were deemed equivalent to the EU rules, but now the EU rules must be met, as written, on all farms wherever they are in the world.

Grower groups will need to meet new rules if they want to continue selling as organic to the EU. If their setup does not already comply with the new rules, time is running out to:

• Restructure to meet the new limits on eligibility (size and income of farms; separate certification for the processor; set up as a legal entity)

• Understand and comply with the EU’s difficult to navigate organic production rules

• Get inspected and certified to the EU’s organic regulation – by a certification body that has received recognition under the EU’s organic compliance regime

Potential market impacts

Groups that choose to meet the export requirements to the EU are likely to face higher costs as they make changes to meet new rules. They may additionally face higher certification costs as the regulation also introduces stricter controls to be performed by certification bodies (e.g. more sampling and testing in accredited laboratories).

Those who decide they cannot meet the export requirements to the EU may choose to be certified to a different standard that allows them to export elsewhere, like directly to Great Britain, or they may cease being organically certified. Either outcome could lead to a reduced supply to the EU, or price fluctuations as the supply and demand re-balance. As organic rules require a two-year conversion period for organic farmland, any impacts on supply could prove slow to correct.

What support is available for growers?

Around 1 million smallholder farmers are benefitting nature by farming organically while benefiting their communities with better incomes by being able to reach export markets via their group certification. As their livelihoods are potentially at risk, we are grateful to organisations such as FIBL, COLEAD and NATURLAND who are currently developing technical support, simplified rule books in several languages and online courses.

Will this affect my business?

Under the Terms of the UK-EU Trade & Cooperation Agreement, if you’re in GB and the product you are importing from the EU is not of EU origin, then your business can strictly only import it as organic if it has been further processed in the EU.

Whilst this rules out the import of raw materials not of EU origin, if you are sourcing multi-ingredient finished products from the EU that contain ingredients that were originally grown by grower groups, you still might be affected. Equally, if you’re in GB and importing directly from the country of origin, general disruption – e.g. loss of certification at source - could still see your supply affected.

According to the Swiss-based organic research agency FIBL, this issue is very likely to affect ingredients such as organic coffee, cocoa, spices, rice, quinoa, coconut products, cashew, macadamia, sesame, bananas, mangoes, avocados, soybeans, cane sugar, honey and shrimp (and some pineapple, ginger, and citrus).

What can I do?

If you purchase products from the EU that contain ingredients from affected supply chains, contact your suppliers to understand if your supplies may be affected by:

• possible supply disruption resulting from reduced availability of ingredients due to a reduce supply base as some groups opt not to meet EU rules

• increased costs passed on from suppliers required to meet these new rules.

Where to get more information and updates

Soil Association Certification publish regular technical, standards, operational and regulatory updates that could affect organic businesses on our Certification Updates page. We recommend checking in periodically to ensure you are aware of the latest updates. If you’re a licensee of Soil Association Certification, the named licence holder should receive monthly updates by email.

 

Clarifying notes

• Soil Association Certification does not certify organic grower groups

• The changes to the EU regulation have not currently been adopted into the GB organic regulation

• The changes do not apply in countries listed on this page

• This information is based on experts presenting at Biofach and a webinar hosted by IFOAM Organics International (watch back the recording)