Changes to processing eligibility for organic exports to the EU
This update was republished with edits on 31 July 2026.
Defra has informed us that some processes will no longer be eligible for export to the EU. Where products don't meet the definition of ‘Processed’, they therefore fall outside of the scope of the UK-EU Trade and Cooperation Agreement (TCA). We can no longer endorse COIs for these products.
What are the rules around export to the EU?
To comply, products must either be grown in GB or be ‘processed’ in GB.
Products imported into GB which do not meet the relevant requirements of the Trade and Cooperation Agreement (TCA) can't be exported to the EU as organic, as your certifier can't endorse the necessary Certificate of Inspection (COI).
What constitutes ‘processed’?
Organic regulations use the definition of ‘processing’ found in Regulation (EC) No 852/2004 as meaning: any action that substantially alters the initial product.
The Defra guidance states: “Products should be assessed on a case-by-case basis to determine if the action taken substantially alters the ingredient(s)."
Examples
Heating an ingredient slightly might not be enough to substantially alter it, but if the heating makes a substantial alteration – such as pasteurisation – this would count as processing.
Another example is flour, which is considered processed as it is produced by a carefully controlled, transformational, multi-staged process including extraction and recombination, resulting in a substantially altered end product.
Which processes may not meet the rules?
These are the processes that Defra has clarified as potentially causing a product to fail to meet the definition of processed:
grinding / crushing
blending of powders
slicing / cutting
frozen / thawed
cleaned
husked
If you are concerned about the eligibility of your products, please contact us for further guidance: coi@soilassociation.org.
The more information you can provide regarding your products the better, to help us determine their eligibility for export.
