UK-EU SPS agreement

Although there could be some exceptions, for the majority of goods covered under organic regulation, Certificates of Inspection (COIs) will no longer be needed when exporting from Great Britain (GB) to the EU, EEA or Northern Ireland (NI). They will also not be required for goods imported into GB from the EU or EEA.

It also appears that products imported into GB will no longer need to be processed in GB before being re-exported to the EU, EEA or NI. However, this has not yet been officially confirmed by Defra.

UK businesses are not expected to need certification simply because they import goods from the EU, EEA or NI, or because they export goods to the EU or EEA, although the requirements for certification for wholesaling and storage will remain.

For goods imported into GB from countries outside the EU, the UK will switch to using the EU's TRACES system to manage Certificates of Inspection. The UK will also follow the EU's lists of approved third countries and certification bodies. Further guidance on how to use the TRACES system will be provided.

In short: Trade between GB and the EU/EEA is expected to become simpler, with fewer certification and inspection requirements. Organic businesses importing from or exporting to the EU/EEA are unlikely to need certification just for those activities, while imports from non-EU countries will be managed through the TRACES system.

Rules on dual certification of operators will change. An operator cannot have certification with more than one certification body (CB) for the same category of products in the same country. For example:

• an egg producer who also packs eggs could not have certification with two or more CBs, because both the production and the packing would remain within the same category (unprocessed)

• an egg producer who also processes eggs into mayonnaise could have certification with different CBs as the egg production would be an ‘unprocessed product’ and the mayonnaise a ‘processed product’

For more detail on changes to certification and inspection of business operations, please refer to our additional 848 operational certification and inspection guidance.

Operator certificates will be issued and accessible through the EU’s TRACES NT system.

For more detail on changes to certification and inspection of business operations, please refer to our additional 848 operational certification and inspection guidance.

There will be a change in the inspection frequency for low-risk wholesaler and storage operations who are currently on a 3-year inspection cycle.

848 requires all operators to have an annual inspection (physical on-the-spot inspection) at least once a year, with the exception of those assessed as low-risk, being subject to inspections up to 24 months apart.​

For more detail on changes to certification and inspection of business operations, please refer to our additional 848 operational certification and inspection guidance.

Several inputs will be allowed that are not currently permitted in the GB regulation. These can’t be used before SPS is implemented.

Some inputs will have added restrictions on use, for example ethylene. However, we are working with Defra to determine how rules are currently being implemented in the EU and if any products will be affected by the changes.

There are new definitions and requirements around plant reproduction material including new rules around the use of heterogeneous material and specific requirements for organic plant reproductive materials.

For full details on changes to inputs, please refer to our 848 input comparison guidance spreadsheet, which we will send to Soil Association Certification clients by email. 

While there are no changes to the land conversion requirements, there are more detailed requirements associated with requests for reduced conversion periods.

There are new rules for groups of operators.

These are more relevant to existing grower groups in third countries who are already required to demonstrate compliance with EU regulations (for example, those producing crops such as cocoa, coffee and bananas).

As such, these restrictions are unlikely to be directly relevant for groups of producers in GB.

As the UK will adopt the EU lists of approved third countries and certification bodies, all certification detailed as acceptable in these lists will be in compliance with EU requirements on grower groups.

Some requirements will become more detailed and prescriptive, but will not require any change of practice. These are in areas such as:

• objectives and principles

• crop rotation

• plant reproductive material

• action in the case of a residue detection

For more details on requirements applicable to your farm, please refer to current production standards for Northern Ireland.

Alongside organic requirements, other phytosanitary controls will be further relaxed. For example, movement of seed between EU and GB should become easier.

The EU has different requirements in a number of areas, some of which will require significant changes. The EU and Defra have yet to confirm transitional measures to help the UK meet EU requirements over time.

For more details on what we know at this time, please refer to the guidance provided for more information on:

• origin of stock

• housing (basic overview is provided below)

• stocking density and ranging

• pullet rearing

Please see more detailed guidance on new requirements for poultry.

The EU regulation includes detailed rules for rabbits and deer which were not included in GB regulation.

The EU requires an organic livestock database (similar to the existing GB seed database) to be used, to ensure organic stock is listed when available.

Requirements for origin of feed will change. At least 30% of feed for pigs and poultry and 70% of feed for herbivores shall come from the farm itself. This represents an increase from 20% for pigs and poultry and 60% for herbivores.

If this is not possible or such feed is not available, feed must be produced in cooperation with other organic or in-conversion production units and feed operators using feed and feed material from the same region.

The definition of "region" will be critical in determining the impact of this change, as currently, "region" is defined as within the EU.

There are several changes to origin and composition of feed as we move to EU regulation. We recommend reading the general guidance and specific guidance on permitted inputs.

For more detail on requirements related to feed, please refer to our additional guidance.

The amount of in-conversion feed that can be bought in will reduce from to 30% to 25%.

Feed materials now include a much longer list including:

• yeast and yeast extracts that do not need to be considered within the non-organic protein allowance

• algal and fish oils

• calcium stearate

Young pigs and poultry can continue to be fed up to 5% non-organic protein feed ingredients if suitable organic alternatives are not available.

For full details on changes to inputs, please refer to our 848 input comparison guidance spreadsheet, which we will send to Soil Association Certification clients by email.

There are new requirements for:

• space for pigs to lay down flat out (all at the same time)

• extra straw to be provided to nesting sows

There is more emphasis in the EU regulation on the outside areas being made attractive to pigs with preference to fields with trees, and a new restriction limiting the amount of slats being used in outside areas for pigs to less than 50%.

EU regulations have different requirements on:

• subdivision of poultry

• perching for table birds

• table chickens, turkeys, and guinea fowl perches or raised sitting levels

• verandas, pop-holes and ranging areas

• multi-tiered housing

Please see more detailed guidance on new requirements for poultry.

The scope of the EU regulation is more detailed, making it clearer that certain agricultural products are within scope. These include natural gums and resins, beeswax, and wool.

For more detail on 848 scope please refer to our additional guidance.

No longer restricted to food use only, under the EU regulation essential oils can be certified organic regardless of their final use (for example, in cosmetic products).

For more detail on the 848 scope, please refer to our additional guidance.

Under the EU regulation, salt production can be certified organic. There are currently no EU wide rules on production; these exist at member state level. There are currently no plans for UK production rules. Salt certified organic in an EU member state could be imported and labelled as organic in the UK.

Businesses may continue to use non-organic salt in their products. There is no requirement to use organic salt.

For more detail on 848 scope, please refer to our additional guidance.

Most of the ingredients previously listed in the regulation, for example dried raspberries, cola nuts, pea protein, fructose and starches, will no longer be permitted for use in non-organic form. The following are permitted, under specific conditions:

• 2 types of algae

• bark of the Pau D'Arco tree

• aquatic organisms (not originating from aquaculture)

• gelatine

• milk mineral powder / liquid

• casings

It will still be possible to obtain derogations from Defra, but under stricter conditions.

For more detail on requirements related to non-organic ingredients, please refer to our additional guidance.

All existing additives and processing aids permitted under GB retained regulations can continue to be used. However, some have additional or different conditions attached, so it is important to check if these changes will impact your products.

For example, existing permitted additives such as E335, E336, E901, E903 and E968 must be included in organic percentage calculation and both E335 and E336 must be organic from January 2027.

EU regulations also contain newly permitted additives (e.g. E267 and E337 – with restrictions) and processing aids (gelatine, pea protein and potato protein).

Ethylene is permitted for use on bananas and potatoes​ and for use on citrus for the prevention of fruit fly damage. This has implications for current use for ripening of kiwi fruit and avocados and sprout suppressant for onions.

There are new rules on the composition of pet foods.

For more detail on 848 requirements for additives and processing aids, please refer to our additional guidance.

Nutrients from yeast extract or autolysate will need to be used as fermentation activators in organic yeast production, but must not exceed 5% of the weight of the dry substrate.

Perlite, cellulose and diatomaceous earth are no longer permitted in production of wine from grapes.

EU regulations are less prescriptive on use of calcium sulphate in wine production. It permits fresh lees – provided they are from organic production.

The new EU regulation makes several changes to the rules for natural flavourings. As a result, all flavourings will need to be reviewed to make sure they still comply with the requirements. In some cases, recipes may need to be changed and product labels updated.

Non-organic natural flavourings will now count as agricultural ingredients when calculating organic content. This means that any non-organic flavourings used must make up no more than 5% of the product.

These flavourings must also be either natural flavouring substances or natural flavouring preparations and must meet the labelling requirements set out in Article 16(2), (3) and (4) of Regulation 1334/2008. In practice, this means that at least 95% of the flavouring must come from the named source. For example, if a flavouring is labelled as a natural lemon flavour, at least 95% of the flavouring must come from lemons.

The regulation also introduces new requirements for how organic flavourings are produced.

For more information on organic flavourings, natural flavourings, and the rules for using the term "natural" on labels, please refer to our additional guidance.

At least 95% of the product's agricultural ingredients, measured by weight, must be organic.

Any non-organic ingredients used in feed, including ingredients from plants, algae, animals, yeast, minerals, as well as feed additives and processing aids, must be listed as approved for use in Regulation EC 2021/1165.

Feed ingredients must not be processed using chemically synthesised solvents.

For more information about the requirements for organic pet food under Regulation 2018/848, please see our additional guidance.

Use of the EU leaf logo and statement of agricultural origin will become mandatory for pre-packed food products. The statement of agricultural origin must state whether the ingredients are from the EU, outside the EU, or a specific country or region.

For food and drink products, changes to the rules on flavourings may also affect product labelling. An increased number of additives are included in the product percentage calculations; this may mean some companies will have to amend specifications and labels to comply.

New requirements also apply to certain other product categories, including products from hunting and fishing, products that are in the process of converting to organic status, and pet food.

It is expected that businesses will be able to use either a UK or EU food business operator (FBO) address on product labels.

Ion exchange and resin absorption will only be permitted for preparation of infant formula, processed cereal-based food and baby food for infants and young children, where doing so is essential to ensure that these products meet other mandatory regulatory requirements.