COMMISSION STAFF WORKING DOCUMENT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2018/848 as regards certain production, labelling and certification rules and certain rules on trade with third countries
Date: 2025-12-16
Institutions: Directorate-General for Agriculture and Rural Development, European Commission
Subjects: animal welfare, consumer protection, eco-label, food safety, harmonisation of standards, import, labelling, organic farming, organic product, third country

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 16.12.2025  SWD(2025) 424 final  COMMISSION STAFF WORKING DOCUMENT   Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2018/848 as regards certain production, labelling and certification rules and certain rules on trade with third countries {COM(2025) 780 final}  
 
 
Contents 
1. 

INTRODUCTION ............................................................................................ 3 

2.  CONSULTATION STRATEGY ......................................................................... 4 

Feedback from expert and civil dialogue groups ......................................................... 4 

Feedback from the implementation dialogue on the organic policy ................................ 5 

Feedback from the call for evidence .......................................................................... 5 

3. 

ISSUES AT STAKE, PROPOSED MEASURES AND EXPECTED IMPACTS ...... 6 

3.1. 
Products and substances for cleaning and disinfection in processing and storage 
facilities ............................................................................................................... 7 

3.2.  Requirements for use of the terms referring to organic production and EU 
organic production logo on products from equivalent third countries .......................... 8 

3.3.  Conditions for exempting smaller operators from the organic operator certificate 
 ............................................................................................................... 11 

3.4.  Requirements for groups of operators and their members .............................. 13 

3.5. 

Postponing the expiry of equivalences with third countries ............................ 15 

3.6.  Conversion period and minimum age at slaughter for quails for meat production . 
 ............................................................................................................... 17 

3.7.  Withdrawal period for treatments with veterinary medicinal products .............. 17 

3.8.  Conditions for access to open air areas for poultry ........................................ 18 

3.9. 

Poultry houses per production unit for fattening poultry ................................ 19 

4.  ENVIRONMENTAL AND SOCIAL IMPACTS ................................................ 20 

5.  CONTRIBUTION TO SIMPLIFICATION AND BURDEN REDUCTION, AND 
THE DIGITAL ASSESSMENT ............................................................................... 22 

ANNEX I - Summary of cost benefits and burden reduction ..................................... 24 

ANNEX II - Summary of suggestions put forward during the consultations and not 
retained in the initiative .......................................................................................... 26 

5.1. 

5.2. 

Livestock conversion .................................................................................. 26 

Soil management and fertilisation in greenhouses ........................................... 26 

5.3.  Handling of residues in organic production ................................................... 26 

5.4.  Milk replacers ........................................................................................... 27 

5.5.  Non-organic animals grazing on organic land ................................................ 27 

Exemption of certification for web shops selling pre-packed organic products to the 
5.6. 
final consumer ..................................................................................................... 28 

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5.7. 

5.8. 

Plant reproductive material ......................................................................... 28 

Aquaculture .............................................................................................. 28 

5.9.  Non-organic protein feed ............................................................................ 29 

5.10. 

Removal of sea salt and other salts for food and feed ................................... 29 

5.11.  Access to pasture/grazing for bovines ........................................................... 30 

5.12. 

Organic ingredients naturally rich in micronutrients ................................... 30 

ANNEX III – Overview of Call for Evidence respondents’ statistics ........................... 31 

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1.  INTRODUCTION 

Organic farming is a key element of the European Union’s common agricultural policy (CAP). 
The  share  of  land  farmed  organically  has  been  growing  steadily  to  currently  around  11%. 
Consumers increasingly choose to buy organic food, recognisable through the logo on organic 
production of the European Union. The rules on organic farming are laid down in Regulation 
(EU)  2018/848  on  organic  production  and  labelling  of  organic  products  (‘the  basic 
Regulation’)1,  applicable  since  January  2022,  and  in  various  delegated  and  implementing 
Regulations adopted on the basis of that Regulation. These rules set the strict requirements that 
underpin  organic  production  to  ensure  a  high  standard  of  environmentally  sustainable 
agricultural production. 

In February 2025, the Commission adopted ‘A Vision for Agriculture and Food’2 which set out 
a  pathway  for  EU  actions  towards  achieving  an  attractive,  competitive,  resilient,  future-
oriented and fair agri-food system for current and future generations of farmers and agri-food 
operators. The document called for reducing unnecessary burdens on the farming sector and 
the entire agri-food value chain as a key step towards boosting their competitiveness. The focus 
on simplification and boosting EU competitiveness is in line with President von der Leyen’s 
Political  Guidelines  for  2024-2029  Commission  mandate,  and  the  Commission’s  broader 
commitments under the communications entitled ‘Competitiveness Compass’ and ‘A simpler 
and faster Europe’.  

To  pursue  these  goals,  in  2025  DG  AGRI  consulted  Member  States  and  stakeholders  on 
Regulation  (EU)  2018/848  and  the  delegated  and  implementing  Regulations  adopted  on  its 
basis (EU organic regulatory framework), to look at their impact on competitiveness and assess 
whether there was scope for simplification. The resulting review of some aspects of the basic 
Regulation will help make the rules more effective and easier to implement, while at the same 
time maintaining the objectives, principles and high standards of the current rules. This targeted 
review  is  complemented  by  the  stocktaking  of  the  associated  delegated  and  implementing 
Regulations,  also  aimed  at  identifying  potential  areas  of  simplification,  provided  for  in  the 
roadmap for simplifying the CAP legal framework3.  

This  staff  working  document  accompanies  the  Commission’s  proposal  for  amending 
Regulation (EU) 2018/848 and provides an estimate of costs and benefits expected to result 
from the measures proposed. Costs and benefits are quantified where the available data allows 
this; elsewhere, a qualitative assessment is provided. The available figures are summarised in 
Annex I to this document. 

1 Regulation (EU) 2018/848 of the European Parliament and of the Council of 30 May 2018 on organic production 
and labelling of organic products and repealing Council Regulation (EC) No 834/2007 (OJ L 150, 14.6.2018, pp. 
1–92, ELI: http://data.europa.eu/eli/reg/2018/848/oj). 
2 Commission Communication ‘A Vision for Agriculture and Food Shaping together an attractive farming and 
agri-food sector for future generations’, COM(2025) 75 final. 
3 Roadmap for simplifying the CAP legal framework to reduce burden on farmers and national administrations  
https://webgate.ec.europa.eu/circabc-ewpp/d/d/workspace/SpacesStore/5ce7e50b-ef31-40e4-8ba3-
be0c1696a062/download. 

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Annex II to this document lists various points raised by Member States and stakeholders in the 
context of the consultation strategy (see Section 2) that have not been included in the proposal, 
explaining the reasons for this.  

2.  CONSULTATION STRATEGY 

Feedback from expert and civil dialogue groups 

The Commission regularly exchanges information with Member States through the Group of 
Experts (GREX) on organic production, which meets on average six times a year, and with 
stakeholders  through  the  Civil  Dialogue  Group  (CDG)  on  organic  farming,  which  usually 
meets twice a year. In these meetings, the Commission gathers views on various aspects of the 
implementation of Regulation (EU) 2018/848 and the delegated and implementing Regulations 
adopted on its basis. 

In 2024, the Fit For Future platform, the high-level expert group set up to help the Commission 
simplify existing legislation and reduce the administrative burden, issued an opinion on how 
Regulation  (EU)  2018/848  and  the  delegated  and  implementing  Regulations  adopted  on  its 
basis4 could be simplified. The group proposed ways to enhance transparency and streamline 
the  EU  organic  regulatory  framework,  while  safeguarding  organic  market  integrity.  It  also 
stressed that it was necessary to speed up harmonisation and simplification to achieve agreed 
policy objectives. Issues identified by the platform and addressed with this proposal are notably 
the complexity of a list of substances authorised for cleaning and disinfection, and requirements 
for  animal  husbandry. The  opinion  was  discussed  at  the AGRIFISH  Council  meeting  of  27 
January 2025. 

The Commission consulted the GREX and CDG in the first half of 2025 to follow up on the 
opinion of Fit For Future. It was concluded that some elements of Regulation (EU) 2018/848 
and the delegated and implementing Regulations adopted on its basis could be simplified. 

Furthermore, on 24 September 2025, a combined GREX-CDG meeting was held to discuss 
how  Regulation  (EU)  2018/848  could  be  simplified  without  weakening  its  objectives, 
principles or standards. The key points raised in that meeting concerned: 

• 

the need to simplify Regulation (EU) 2018/848 and the delegated and implementing 
Regulations adopted on its basis to remove unnecessary burdens; 

•  promotion of organic products  as  a way to  stimulate demand in  a  context of market 

volatility; 
research and funding as key drivers for the development of organic farming; and 
the need to develop and reinforce supply chains of organic products. 

• 
• 

4 FIT FOR FUTURE Platform Opinion https://commission.europa.eu/document/download/25d40cdf-9e5e-4a8b-
8da6-7a72efad04ed_en?filename=fo_2024_8_organic_production_and_labeling_en.pdf&prefLang=mt. 

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The  Commission  received  additional  feedback  after  that  meeting  on  which  aspects  of 
Regulation  (EU)  2018/848  and  the  delegated  and  implementing  Regulations  adopted  on  its 
basis could be simplified. 

Feedback from the implementation dialogue on the organic policy 
An implementation dialogue on the organic farming policy5 was held on 10 November 2025, 
chaired by the Commissioner for Agriculture and Food and attended by several organic agri-
food operators and other stakeholders. Discussions focused on their experience of the rules on 
organic production and the labelling of organic products and how certain aspects of Regulation 
(EU) 2018/848 and the delegated and implementing Regulations adopted on its basis could be 
simplified. The attendees also shared their experience of and views on the action plan for the 
development of organic production6. 

As regards Regulation (EU) 2018/848, there was concern about the expiry of the recognitions 
of 11 third countries under the equivalence scheme, with attendees urging that the date of expiry 
be  postponed.  Moreover,  they  suggested  simplifying  the  rules  on  groups  of  operators  to 
facilitate the adherence to the system  of small-scale  farmers, particularly  in  third countries. 
Other aspects they felt should be adapted included the rules on products and substances for 
cleaning and disinfection, the withdrawal period after the use of veterinary medicinal products, 
the size of poultry houses and production units, as well as the derogation from the use of non-
organic protein feed. The attendees also called for further harmonisation on the implementation 
of  the  rules  on  the  presence  of  non-authorised  substances.  They  broadly  agreed  on  the 
importance  of  stability  and  giving  farmers  a  long-term  perspective,  and  on  the  need  to  run 
information  campaigns  to  educate  the  public  on  organic  farming  policy  and  the  organic 
production logo. 

Feedback from the call for evidence 
A  call  for  evidence  was  held  from  21  October  to  18  November  2025.7  A  total  of  720 
submissions were received from EU citizens (44.9%), companies/businesses (31.3%), business 
associations  (11%),  Non-Governmental  Organisations  (NGOs)  (2.8%),  public  authorities 
(1.5%), trade unions (1.3%), and others (7.4%). The feedback concerned possible amendments 
to Regulation (EU) 2018/848 and the delegated and implementing Regulations adopted on its 
basis.  

Most submissions came from France (45.1%), Germany (21.5%), Austria (16.1%), Belgium 
(4%) and Sweden (3.2%). Detailed statistics are provided in Annex III to this document. The 
main feedback is summarised below: 

5 https://agriculture.ec.europa.eu/media/events/implementation-dialogue-eu-organic-policy-2025-11-10_en.  
6 https://agriculture.ec.europa.eu/farming/organic-farming/organic-action-plan_en#legal-basis. 
7https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/15273-Organic-production-targeted 
updates-and-simplification_en.  

5 

 
 
 
 
 
•  Maintaining the high standards of Regulation (EU) 2018/848: Respondents (mainly 
citizens  from  France),  stressed  the  importance  of  preserving  core  organic  farming 
principles such as the use of natural inputs, the ban of genetically modified organisms 
and new genetic techniques, and the emphasis on animal welfare and soil health. They 
expressed concern that an amendment of the rules would water down the standards on 
which the credibility of the organic production logo of the European Union relies, and 
consumer  trust  depends.  Respondents  also  highlighted  the  need  to  prevent  adverse 
effects of the ruling of the Court of Justice of the European Union in Case C-240/23 
Herbaria II on the current equivalence trade scheme. Some others, mainly organisations 
and individuals, expressed opposition to the overall concept of equivalence and called 
for a more distinguished labelling of non-EU organic products. 

•  Simplifying administrative and technical aspects: Some respondents, in particular 
operators  and  business  organisations,  called  for  more  flexibility  and  for  practical 
adjustments to reduce the administrative burden, which currently affected the economic 
viability  of  organic  farming.  Among  other  things,  this  concerned  cleaning  and 
disinfection  products  used  in  processing  and  storage  operations,  requirements  on 
groups of operators and the handling of residues in organic products. 

•  Addressing challenges in organic livestock farming: Respondents (mainly citizens 
and  stakeholders  from  Germany  and  Austria)  highlighted  issues  related  to  organic 
livestock  production,  such  as  the  withdrawal  period  following  the  use  of  veterinary 
medicinal products and the availability of organic protein sources in view of the 100% 
organic feed requirement for poultry and pigs as from 2027. Other requirements that 
posed a challenge included access to open air areas for young poultry, the maximum 
usable area for fattening poultry in poultry houses of any production unit, indoor and 
outdoor area requirements for pigs, the covering of outdoor areas and, finally, grazing 
requirements for dairy cattle. Respondents called for the rules to be adjusted to ensure 
a more practical implementation of Regulation (EU) 2018/848 with regard to livestock, 
while maintaining current animal welfare objectives. 

3.  ISSUES AT STAKE, PROPOSED MEASURES AND EXPECTED IMPACTS 

This proposal contains targeted adjustments related to: (i) products and substances for cleaning 
and  disinfection  in  processing  and  storage  facilities;  (ii)  the  labelling  of  products  from 
equivalent third countries; (iii) the conditions for exempting smaller operators selling unpacked 
organic  products  other  than  feed  from  the  obligation  of  being  in  possession  of  a  certificate 
pursuant  to  Article  35(1)  of  Regulation  (EU)  2018/848;  (iv)  requirements  as  regards  the 
composition of groups of operators and their members; (v) postponement of the expiry of the 
recognition of third countries for the purposes of equivalence under Article 33(2) of Regulation 
(EC) No 834/2007; (vi), setting a conversion period and a minimum age at slaughter for quails 
for  meat  production;  (vii)  the  withdrawal  period  after  treating  livestock  with  veterinary 
medicinal products; (viii) conditions for access to open air areas for poultry; and (ix) poultry 
houses per production unit for fattening poultry. Details are provided in this section. 

6 

 
 
The proposal is expected to have a positive impact on the EU organic farming sector, benefiting 
farmers, businesses and consumers alike, as well as Member States administrations. It will not 
only simplify certain provisions of Regulation (EU) 2018/848 but is also expected to reduce 
costs, lighten the administrative burden and, as a result, stimulate investments. It will contribute 
both to further developing organic farming and to creating jobs, in particular in rural areas. The 
economic  impact  is  presented  in  this  section  while Annex  I  summarises  the  key  economic 
figures.  

It  should  be  noted,  however,  that  any  quantitative  estimates  of  environmental  and  social 
impacts are subject to limitations, including a lack of standardised metrics. Actual outcomes 
will depend, first and foremost, on potential synergies and on the extent to which operators in 
the  organic  farming  sector  make  use  of  the  proposed  measures. A  qualitative  assessment  is 
therefore presented in section 4. 

It  is  important  to  note  that  the  positive  impacts  are  being  achieved  while  maintaining  the 
principles and high standards of EU organic production. 

3.1.Products  and  substances  for  cleaning  and  disinfection  in  processing  and  storage 

facilities 

Regulation (EU) 2018/848 provides that products to clean and disinfect processing and storage 
facilities  used  in  organic  production  must  be  authorised  and  included  in  restrictive  lists. 
However, the drawing up of such lists poses a number of challenges. Those challenges have 
been confirmed by several  reports from  the Expert Group  for Technical Advice on  Organic 
Production (EGTOP)8.  

First, there are numerous products and substances available on the EU market that can be used 
to clean and disinfect processing and storage facilities in keeping with the EU food safety and 
hygiene standards.  

Second, organic products are processed and stored in many different types of establishments, 
involving the use of a wide range of equipment, machinery and buildings.  

Third,  any  equipment  and  machinery  used  for  processing  and  storage  must  be  cleaned  and 
disinfected as specified by the manufacturer to ensure correct operation and maintenance. The 
technical  nature  of  such  products  and  substances,  regulatory  requirements  on  chemical 
products and their many different uses and the constant arrival of new products on the market 
mean that it is technically challenging to lay down EU-wide criteria for the use of such products 
in organic production, draw up corresponding lists of products and keep the lists up to date.  

8  EGTOP,  ‘Final  report  on  the  criteria  for  evaluation  of  products  for  cleaning  and  disinfection’,  8 December 
2021, https://agriculture.ec.europa.eu/document/download/2cd40421-9a7e-432c-9818-
947cc97358c4_en?filename=egtop-report-on-criteria-cleaning-and-disinfection_en.pdf; EGTOP, ‘Final report on 
cleaning  and  disinfection  (III)’,  14  April  2025,  https://agriculture.ec.europa.eu/document/download/bc0480a6-
EGTOP, 
d269-468b-97df-3da3216f0d4d_en?filename=final-report-egtop-on-cleaning-disinfectant-iii_en.pdf; 
‘Final 
2025, 
November 
https://agriculture.ec.europa.eu/farming/organic-farming/co-operation-and-expert-advice/egtop-reports_en.  

disinfection 

cleaning 

report 

(IV), 

and 

on 

6 

7 

 
 
 
 
Any restrictive lists of the products and substances that can be used to clean and disinfect in 
processing  and  storage  facilities  place  a  burden  on  operators  handling  organic  products. 
Operators who process and store organic products in the same processing and storage facilities 
as  non-organic  products,  keeping  with  the  parallel  production  requirements  laid  down  in 
Regulation (EU) 2018/848, face increased costs because they have to buy different products 
and substances for organic and non-organic production and store them separately. They also 
face higher costs for cleaning and disinfection to be able to meet mandatory EU food safety 
and hygiene standards. 

It is therefore proposed to repeal Article 24(1)(g) of Regulation (EU) 2018/848, to simplify the 
current rules and allow operators to use any products and substances available on the market 
that are suited to cleaning and disinfecting processing and storage facilities for use in organic 
production. This will also reduce the cost of complying with the applicable food safety and 
hygiene standards for all EU operators. 

EU food and feed processors9 of organic products spend a total of EUR 68.8 million annually 
on  professional  cleaning  products  and  disinfectants  in  the  sectors  of  agriculture,  food  and 
beverages10. Restrictive lists of products that can be used in the processing of organic products 
will likely double those costs due to the higher cost of inputs11. Repealing the requirement of 
restrictive lists could therefore avoid adjustment costs for these businesses (in processing and 
storage) of EUR 68.8 million annually. 

3.2. Requirements for use of the terms referring to organic production and EU organic 

production logo on products from equivalent third countries 

In Case C-240/23 Herbaria Kräuterparadies II12, the Court of Justice of the European Union 
(ECJ)  ruled  that  Regulation  (EU)  2018/848  must  be  interpreted  as  meaning  that  a  product 
imported  from  a  third  country  whose  organic  production  and  control  systems  have  been 
recognised as equivalent to those of the EU, either through an international agreement between 
the EU and those third countries or where the third countries were recognised for the purpose 
of equivalence under Regulation (EC) No 834/2007, may not have on its labelling either the 
organic  production  logo  of  the  European  Union  or,  in  principle,  terms  referring  to  organic 
production.  The  ECJ  further  ruled  that  the  use  of  the  organic  production  logo  of  the  third 
country from which such product comes should be permitted on the product, even where that 
logo contains terms identical to those referring to organic production, within the meaning of 
Article 30(1) of that Regulation (EU) 2018/848 and Annex IV thereto.  

9  Eurostat,  2023:  https://ec.europa.eu/eurostat/web/products-key-figures/w/ks-01-24-000;  FEFAC,  2024: 
https://fefac.eu/statistics/; Farms and farmland in the European Union - statistics - Statistics Explained - Eurostat; 
OPTA, 2024: https://opta-eu.org/about-organic/organic-in-numbers/. 
10  AISE, 2024: https://aise.eu/priorities/cleanliness-hygiene/professional-cleaning/food-and-beverage/  
11 Based on organic stakeholders’ expert judgement. 
12  Judgement  of  4  October  2024,  Herbaria  Kräuterparadies  II  GmbH  /  Freistaat  BayernCase  (C-240/23) 
ECLI:EU:C:2024:852. 

8 

 
 
 
 
The  use  for  a  product  imported  from  a  third  country  whose  organic  production  and  control 
systems has been recognised as equivalent to those of the EU of the organic production logo of 
a  third  country  is  not  liable  to  harm  fair  competition  within  the  internal  market  in  organic 
products or to give rise to ambiguity that may mislead consumers. This is because such a logo 
neither places the product concerned on the same level as EU organic products from the point 
of view of competition or is liable to give the impression that the product concerned complies 
with all the requirements laid down by Regulation (EU) 2018/848. 

Terms referring  to  organic production, including their derivatives and diminutives, are used 
both  in  the  EU  and  in  third  countries  to  suggest  to  the  purchaser  that  the  product  and  its 
ingredients  have  been  produced  in  accordance  with  applicable  organic  production  methods. 
This is also the case in the Codex Alimentarius guidelines CAC/GL 3213, where terms referring 
to organic production methods such as ‘organic’, ‘biological’, ‘ecological’ or words of similar 
intent  including  diminutives  are  used  to  suggest  to  the  purchaser  that  the  product  or  its 
ingredients were produced in accordance with organic production methods. In addition, certain 
organic production rules in third countries require terms referring to organic production to be 
used for products and their ingredients product that have been produced in accordance with 
applicable organic production methods. Not every third country whose organic production and 
control systems  have been recognised as  equivalent  to  those of the  EU has  its own organic 
production  logo.  Consequently,  if  products  from  such  third  countries  could  not  bear  terms 
referring  to  organic production, this would deprive operators in those third countries of the 
possibility to indicate the organic status of such products and to suggest to consumers in the 
EU that those products originate from organic production and are produced in accordance with 
organic production methods in their countries of origin. This would also be difficult to reconcile 
with the Codex Alimentarius guidelines CAC/GL 32 because it would not be possible to refer 
to organic production methods in the labelling of such products despite them meeting all the 
corresponding  conditions  set  out  in  these  guidelines.  Those  products  should  therefore  be 
allowed to bear terms referring to organic production for the purpose of putting those products 
on the EU market as organic products. 

The recognition of the organic production and control systems of a third country as equivalent 
to those of the EU means that such a system has been assessed as meeting the same objectives 
and principles as those of the EU by applying rules which ensure the same level of assurance 
of conformity, even if that is achieved through different means. Differences between the rules 
applied in organic production and control systems of third countries recognised as equivalent 
and  those  applied  in  the  EU  are  intrinsic  to  the  equivalence  regime.  The  assessment  of 
equivalency by the Commission has shown that while some of those differences are limited in 
scope, other differences involve rules of organic production which play an important role in 
the  structure  of  organic  production  in  the  EU  and  contribute  to  achieving  the  objective  of 
satisfying consumer expectations as regards organic products whilst ensuring fair competition 

13 Guidelines for the production, processing, labelling and marketing of organically produced foods GL 32–1999: 
https://www.fao.org/input/download/standards/360/cxg_032e.pdf.  

9 

 
 
 
within  the  internal  market.  Those  rules  include  living  soil,  animal  welfare  standards  and 
processing of food using minimum artificial inputs.  

A  Eurobarometer  survey14  conducted  in  June  and  July  2024  and  entitled  ‘Europeans, 
Agriculture and the CAP’ indicated that the organic production logo of the European Union is 
the food product logo of which Europeans are the most aware. It is essential to both consumers 
and producers because it makes it easier for consumers to identify organic products and helps 
producers to market them across the Union. 

In order to ensure a level playing field between products that fully comply with EU production 
and control rules and those that comply with rules equivalent to those EU rules, and in order to 
respond to consumer expectations that products imported from third countries whose organic 
production and control systems have been recognised as equivalent to those of the EU meet 
standards as high as those of the EU, the use of the organic production logo of the European 
Union should be allowed  in the labelling,  presentation and advertising of products imported 
from those third countries, provided that, in addition to those equivalent rules, those products 
comply with certain additional production and control requirements. 

To  preserve  the  effectiveness  of  Regulation  (EU)  2018/848  as  regards  trade  with  third 
countries, such additional requirements should correspond to production and control rules that 
play  an  important  role  in  the  structure  of  organic  production  in  the  EU  and  contribute  to 
achieving the objective of satisfying consumer expectations as regards organic products whilst 
ensuring fair competition within the internal market. 

Operators  in  the  Union  that  produce  organic  food  and  feed  rely  on  the  use  of  ingredients 
imported  from  third  countries  whose  organic  production  and  control  systems  have  been 
recognised  as  equivalent  to  those  of  the  Union.  Such  ingredients  are  used  in  variable 
proportions during the processing of organic products in the Union and are necessary for a large 
variety of organic products processed in the Union. 

Processing operations in the Union, when using those ingredients, take place in compliance 
with  the  production  rules  set  out  in  Regulation  (EU)  2018/848.  The  use  of  the  organic 
production logo of the European Union should therefore be allowed by products processed in 
the  Union  and  that  contain  organic  ingredients  either  produced  in  accordance  with  this 
Regulation  or  imported  from  third  countries  whose  organic  production  and  control  systems 
have been recognised as equivalent to those of the Union and where those ingredients account 
for 5% or less of the agricultural ingredients of the product (by weight for food and in general 
for feed). Where those ingredients account for more than 5% of the agricultural ingredients of 
the product by weight (by weight for food and in general for feed), and in order to ensure a 
level playing field between processed products containing ingredients that fully comply with 
Union production and control rules and those that comply with rules equivalent to those Union 
rules,  and  in  order  to  respond  to  consumer  expectations  that  processed  products  containing 
ingredients imported from third countries whose organic production and control systems have 
been recognised  as  equivalent to  those of the  Union  meet  standards  as  high  as those of the 

14 https://europa.eu/eurobarometer/surveys/detail/3226. 

10 

 
 
 
Union, the use of the organic production logo of the European Union should be allowed in the 
labelling, presentation and advertising of processed products containing ingredients imported 
from those third countries, provided that, in addition to those equivalent rules, those ingredients 
comply with certain additional production and control requirements. As the use of the organic 
production logo of the European Union is obligatory for all organic prepacked food produced 
within  the  Union,  it  is  therefore  necessary  to  exclude  from  that  obligation  prepacked  food 
produced  within  the  Union  with  ingredients  imported  from  third  countries  whose  organic 
production and control systems have been recognised as equivalent to those of the Union and 
where those ingredients account for more than 5% of the agricultural ingredients of the product 
by weight and do not comply with certain additional production and control requirements. 

The proposed measure amends Article 30 of Regulation (EU) 2018/848, to allow the use of 
terms  referring  to  organic  production  on  organic  products  imported  in  the  EU  from  third 
countries recognised for the purpose of equivalence. This will ensure that no disproportionate 
barrier  hampers the  marketability  of such products. The measure also  amends Article  33  of 
Regulation  (EU)  2018/848,  to  lay  down  those  additional  requirements,  corresponding  to 
production rules, that are of significance in the overall structure of organic production in the 
EU for their contribution to ensuring fair competition and the proper functioning of the internal 
market in organic products and maintaining and justifying consumer confidence in products 
labelled as organic. Products imported from equivalent third countries must comply with those 
additional requirements to be able to bear the organic production logo of the European Union 
when  imported.  The  proposed  measure  also  specifies  conditions  for  the  use  of  the  organic 
production  logo  of  the  European  Union  on  processed  products  produced  in  the  Union  with 
ingredients imported from equivalent third countries. Finally, the proposed measure amends 
Article 32 of Regulation (EU) 2018/848 to exclude from the obligation of using the organic 
production logo of the European Union that prepacked food produced within the Union with 
ingredients imported from third countries whose organic production and control systems have 
been recognised as equivalent to those of the Union and where those ingredients account for 
more than 5% of the agricultural ingredients of the product by weight and do not comply with 
certain additional production and control requirements. 

3.3.Conditions for exempting smaller operators from the organic operator certificate  
Article  35(8)  of  Regulation  (EU)  2018/848  lays  down  the  conditions  under  which  Member 
States can exempt smaller operators that sell unpacked organic products other than feed directly 
to the final consumer from the obligation to hold a certificate pursuant to Article 35(1) of that 
Regulation. Those conditions are the following: ‘[…] (a) such sales do not exceed 5 000 kg per 
year’; or (b) such sales do not represent an annual turnover in relation to unpacked organic 
products exceeding EUR 20 000’; or (c) the potential certification cost of the operator exceeds 
2% of the total turnover of unpacked organic products sold by that operator’. 

The increasing costs faced by smaller operators since the entry into application of Regulation 
(EU) 2018/848 have caused their turnover from unpacked organic products other than feed to 
increase, sometimes to values considerably higher than EUR 20 000. This has created a barrier 

11 

 
 
 
preventing the operators concerned from meeting the conditions relating to turnover and has 
affected  their  eligibility.  In  addition,  variations  in  costs  each  year  mean  that  meeting  the 
conditions is affected on an annual basis. Smaller operators no longer fulfil such conditions 
due  to  the  above-mentioned  increased  costs.  Consequently,  they  may  have  to  undertake 
procedures such as inspections, checks and certification, in order to obtain a certificate pursuant 
to Article 35(1) of Regulation (EU) 2018/848. This incurs administrative costs.  

To address this, the proposed measure abolishes points (b) and (c) of Article 35(8) of Regulation 
(EU) 2018/848. These points contain the conditions for total turnover from unpacked organic 
products, which exempt smaller operators selling unpacked organic products other than feed 
from the obligation to hold a certificate pursuant to Article 35(1) of Regulation (EU) 2018/848. 

This  will  avoid  any  disproportionate  burden  on  smaller  sellers  and  make  the  marketing  of 
organic products easier. In the Member States where this exemption is already applied, smaller 
operators  that  sell  unpacked  organic  products  to  final  consumers  save  on  costs  related  to 
controls and certification. 

Certain smaller operators in specific areas and sectors, also sell more than 5 000 kg of goods 
per  year  and  therefore  benefit  from  the  conditions  related  to  the  organic  turnover  for  their 
eligibility. The proposed measure abolishing points (b) and (c) of Article 35(8) of Regulation 
(EU) 2018/848, will result in them not being able to fulfil the remaining condition related to 
the maximum amount of sales. To avoid this, the proposed measure doubles the condition set 
out in point (a) of Article 35(8) of that Regulation, and fixes it at a maximum of 10 000 kg of 
sales per year. 

The proposed measure will benefit smaller operators that sell unpacked organic products 
other than feed to the final consumer. It will help them obtain an exemption from holding a 
certificate. 

It  is  estimated  that  around  19  500  operators  will  benefit  from  the  proposed  changes  of  the 
eligibility  conditions15. Around  three  quarters  of  them  operate  in  Member  States  where  the 
costs  of  inspections,  controls  and  certification  are  borne  by  public  authorities.  The  average 
costs for that type of operators, if they are not exempted from holding a certificate are estimated 
at EUR 400 per year16. The proposed measure could therefore bring administrative cost savings 
of EUR 7.8 million annually (costs normally borne in relation to non-exempted operators), of 
which EUR 5.9 million for administrations and EUR 1.9 for the operators themselves.  

The  notification  obligation  referred  to  in  Article  34(1)  of  Regulation  (EU)  2018/848  will 
continue  to  guarantee  supervision  by  the  competent  authorities  of  the  Member  States  and 
ensure adequate transparency of the certification system in relation to the exempted operators 
and the integrity of the organic products they sell. The measure will continue to remain, in any 
case, a decision by Member States. 

15  European  Commission,  2025,  National  lists  of  organic  operators  exempted  from  certification  and  further 
elaborations based on Commission expert judgement. 
16  Eurostat  Structure  of  earnings  survey,  Labour  Force  Survey  data  for  Non-Wage  Labour  Costs  and  further 
elaborations based on Commission expert judgement. 

12 

 
 
 
3.4.Requirements for groups of operators and their members 
Article 36(1) of Regulation (EU) 2018/848 lays down provisions on groups of operators and 
their members in the EU and third countries. Members of groups of operators are farmers or 
producers of algae or aquaculture animals. They may additionally be engaged in processing, 
preparation or placing on the market of food or feed. 

As for the requirements for members of groups of operators, Article 36(1) states that “Each 
group  of  operators  shall  […]  only  be  composed  of  members:  (i)  of  which  the  individual 
certification cost represents more than 2 % of each member’s turnover or standard output of 
organic production and whose annual turnover of organic production is not more than EUR 25 
000 or whose standard output of organic production is not more than EUR 15 000 per year; or 
(ii)  who  have  each  holdings  of  maximum:  —  five  hectares,  —  0,5  hectares,  in  the  case  of 
greenhouses, or — 15 hectares, exclusively in the case of permanent grassland; and […] (d) 
have legal personality”. 

Evidence in relation to the implementing17 these provisions has shown significant difficulties 
in  setting  up  groups  of  operators  that  fulfil  the  requirements  related  to  the  group’s  legal 
personality and the annual turnover of members. The requirements related to the group’s legal 
personality result in increased administrative and certification costs. They reduce the incentive 
for  operators  to  join  and  create  a  need  to  reorganise  economic  activities  and  create  new, 
separate, legal personalities of groups of producers, which are currently grouped in cooperative 
associations, cooperatives, associations, federations or organisations. The requirements related 
to the annual turnover of members results in increased administrative costs due to a reduced 
number of potential members, which are affected by increased costs and inflation.  

Such difficulties therefore prevent smaller operators from joining groups of operators, since 
the rules in place do not appropriately reflect the needs and resource capacity of smaller farmers 
and operators, and reduce the profitability of the businesses. In third countries, reorganising 
the  producers’  activities  can  also  cause  difficulties  in  supplying  the  EU  with  products 
originating from those countries, such as spices, tropical fruits, cocoa, coffee or tea. There is 
therefore a risk of trade disruptions, as operators are obliged to redirect their goods to other 
overseas markets.  

The  proposed  measure  therefore  abolishes  point  (b)(i)  of Article  36(1)  of  Regulation  (EU) 
2018/848, i.e. the requirement on annual turnover for members of groups of operators.   

Certain smaller operators are based in specific areas and sectors characterised by lower annual 
turnover due to less profitable activities. However, they run holdings with larger surfaces than 

17 Meinshausen et al., 2024: Impact of the New EU Organic Regulation on Smallholder Value Chains and the 
European Organic Sector, Research Institute of Organic Agriculture FiBL; Meinshausen & Blanco, 2024: Case 
study  on  the  implications  for  low-  and  middle-income  countries  of  Organic  Regulation (EU)  2018/848  in  the 
Dominican  Republic,  COLEAD  and  FiBL;  Solfanelli  et  al.,  2021:  Potential  outcomes  and  impacts  of  organic 
group certification in Italy: An evaluative case study, https://doi.org/10.1016/j.ecolecon.2021.107107; Petrelli & 
Ghedira, 2020: Group certification in organic farming: a comparison of the new European rules Technical report 
2, https://hdl.handle.net/11581/459970. 

13 

 
 
 
 
the current maximum surfaces laid down in point (b)(ii) of Article 36(1). They therefore benefit 
from  the  conditions  related  to  organic  turnover  for  their  eligibility.  The  proposed  measure 
abolishing points (b)(i) of Article 36(1) of Regulation (EU) 2018/848, will mean they cannot 
meet  the  remaining  condition  related  to  maximum  surfaces.  To  avoid  this,  the  proposed 
measure revises the condition related to the maximum surface in point (b)(ii) of that Article, 
increasing it to: - ten hectares, - one hectare in the case of greenhouses, and - thirty hectares 
exclusively in the case of permanent grassland. This will help smaller operators (farmers) 
such  as  arable  crop  producers  in  the  EU18  and  coconut  producers  in  certain  third  countries 
participate in the system of groups of operators19.  

The requirements for groups of operators in the proposed measure also include the possibility 
for the group to be part of a farmer cooperative association, operator cooperative, association, 
federation or organisation that has a legal personality. This requirement will prevent groups of 
operators from being forced to set up a new, separate legal personality when they are part of an 
entity  with  a  legal  personality.  It  will  therefore  mean  administrative  cost  savings  for  those 
smaller operators that are part of a group or a cooperative, as they will not have to undergo 
individual inspections, controls and certification. 

Estimations of cost savings are performed in relation to third country operators only. In the EU, 
the system of groups of operators for the purpose of the organic certification has had limited 
application. Even if the proposed measure will, in principle, also encourage the uptake of that 
system in the EU, setting a benchmark for the costs currently incurred and calculating costs 
savings might not produce representative and reliable data. 

Geographical areas where producers are organised in cooperatives or similar entities for the 
purpose of exporting organic products to the EU are Latin America, the Caribbean, Asia, Africa 
and the non-EU Mediterranean area. There are around 1 400 groups and 1.1 million farmers in 
those areas20. Around 70% of those cooperatives or similar entities and their members would 
benefit from the proposed measure21. 

Cost  savings  represent  around  EUR  70  per  member22.  This  is  based  on  the  average 
administrative costs for certification to fulfil the current requirements of points (b)(i) and (ii) 
of Article 36(1) of Regulation (EU) 2018/848. They consist of savings due to fewer changes to 
the  governance  of  the  control  system  of  groups  of  operators  and  reduced  recourse  to  the 
external certification system (i.e. operators inspected individually), in favour of more recourse 
to a system of internal controls as referred to in Article 36(1), point (g), of Regulation (EU) 

18 Solfanelli et al., 2021. DOI: https://doi.org/10.1016/j.ecolecon.2021.107107.  
19 Meinshausen et al., 2024: Impact of the New EU Organic Regulation on Smallholder Value Chains and the 
European Organic Sector. Research Institute of Organic Agriculture FiBL. 
20 Meinshausen et al., 2024: Impact of the New EU Organic Regulation on Smallholder Value Chains and the 
European Organic Sector, Research Institute of Organic Agriculture FiBL; Meinshausen & Blanco, 2024: Case 
study  on  the  implications  for  low-  and  middle-income  countries  of  Organic  Regulation (EU)  2018/848  in  the 
Dominican Republic, COLEAD and FiBL. 
21 Ibid. 
22 Ibid. 

14 

 
 
 
2018/848. Instances of multiple certificates of inspection being issued ahead of exports will 
also be reduced. 

Such cost savings can be repeated over time (e.g. the legal and accountancy costs related to 
maintaining the legal personality or to adopting the control system of the group of operators 
instead of operators being inspected individually). Therefore, they represent administrative cost 
savings of EUR 77 million annually. Since they occur outside of the EU, they are not being 
considered in the table in Annex I of this document. 

3.5.Postponing the expiry of equivalences with third countries  
The Commission recognised 11 third countries pursuant to Article 33(2) of Regulation (EC) 
No 834/200723 for the purpose of equivalence. Article 48(1) of Regulation (EU) 2018/848 sets 
an expiry date of 31 December 2026 for the recognition of those 11 third countries. After that 
date, the existing equivalence arrangements will come to an end and will have to be replaced 
by  international  agreements  on  trade  in  organic  products,  in  accordance  with Article  47  of 
Regulation (EU) 2018/848. 

The recognition of third countries whose organic production and control systems have been 
recognised as  equivalent to  those of the  EU will expire on 31 December 2026. On 28 June 
202124, the Council authorised the Commission to open negotiations with the third countries 
recognised for the purpose of equivalence under Regulation (EC) No 834/2007 with a view to 
concluding  agreements  on  trade  in  organic  products.  On  that  basis,  the  Commission  is 
conducting  technical  exchanges  with  those  third  countries. Those  exchanges  show  different 
levels of progress due to the diversity of legal and regulatory frameworks and complexities 
linked  to  varying  consumer  perceptions  of  organic  production  from  one  organic  production 
system to the other. It is therefore necessary and urgent for those third countries to continue to 
be recognised until 31 December 2036 to avoid disruptions in the trade of organic products.  

The proposed measure postpones the date of expiry of the recognition of the 11 third countries 
laid down in Article 48(1) of Regulation (EU) 2018/848 to 31 December 2036, with view to 
allow for a sufficiently long period of time to complete these exchanges and the subsequent 
negotiations  and  ensure  a  smooth  transition  to  the  scheme  of  recognition  of  third  countries 
through international agreements. 

If  the  equivalence  arrangements  were  to  expire  on  31  December  2026,  it  would  be  more 
difficult to continue current trade with the equivalent third countries concerned. This would be 

repealing 

Regulation 

23 Council Regulation (EC) No 834/2007 of 28 June 2007 on organic production and labelling of organic products 
and 
1–23 
ELI: http://data.europa.eu/eli/reg/2007/834/oj). 
24 Council Decision (EU) 2021/1345 of 28 June 2021 authorising the opening of negotiations with Argentina, 
Australia, Canada, Costa Rica, India, Israel, Japan, New Zealand, South Korea, Tunisia and the United States with 
a  view  to  concluding  agreements  on  trade  in  organic  products  (OJ  L  306,  31.8.2021,  pp.  2–3  (ELI: 
http://data.europa.eu/eli/dec/2021/1345/oj). 

No 2092/91 

20.7.2007, 

(EEC) 

189, 

(OJ 

pp. 

L 

15 

 
 
  
 
particularly detrimental to EU operators, as the EU enjoys a positive trade balance with those 
third countries. 

In such a scenario, in fact, EU operators would need to be certified as complying with third 
countries’ national schemes (e.g. USDA organic, COR organic, JAS organic etc.) in order to 
export their goods to third countries. This would increase administrative costs for EU operators, 
e.g.  for  inspections,  controls,  audits  and  certification  by  the  accredited  control  bodies  and 
competent authorities of third countries. The increase in such costs would either reduce benefits 
or increase selling prices. In both cases, this would make EU organic operators less competitive 
on third country markets and make it more difficult for them to access those markets. 

There are estimated to be 5 000 EU operators exporting goods from the EU to the main third 
countries  with  equivalence  arrangements25.  The  four  main  third  countries  with  equivalence 
arrangements are the United States, Canada, Japan and the Republic of Korea. If equivalences 
were to expire at the end of 2026, EU operators would have to be certified against the national 
standards of third countries in order to continue accessing their markets. In addition, other EU 
organic operators in the supply chain (e.g. producers, processors) may also have to be certified 
against those national standards26. A single third country certification is estimated to cost on 
average  EUR  750  per  operator  annually27.  Total  administrative  cost  savings  for  them  are 
therefore estimated at EUR 15 million annually.  

It would also harm EU imports if the equivalences expired at the end of 2026. It would force 
third country operators to be certified against EU standards in accordance with point (b)(i) 
of  Article  45(1)  of  Regulation  (EU)  2018/848  (compliance  import  scheme).  This  would 
increase administrative costs for them, which would likely be reflected in increased costs of 
organic goods imported from those third countries and higher prices for consumers. 

There are estimated to be 2 000 equivalent third country operators involved in activities for the 
purpose  of  exporting  goods  to  the  EU28.  If  they  were  subject  to  certification  under  the  EU 
compliance import scheme, they would incur administrative costs estimated at an average of 
EUR 750 per operator annually29. Administrative cost savings for them are therefore estimated 
at EUR 1.5 million annually. Since they occur outside of the EU, they are not being considered 
in the table in Annex I of this document. 

25  FiBL-AMI  survey  2025  based  on  national  data  sources  and  Eurostat  and  Willer,  Helga  Jan  Trávníček  and 
Bernhard  Schlatter  (Eds.)  (2025):  The  World  of  Organic  Agriculture.  Statistics  and  Emerging  Trends  2025. 
Research Institute of Organic Agriculture FiBL, Frick, and IFOAM – Organics International, Bonn. 
26 Estimations of costs savings in this regard are hard to perform, in particular in relation to the number of those 
EU operators, their size and therefore the potential certification costs they would incur. 
27  Eurostat  Structure  of  earnings  survey,  Labour  Force  Survey  data  for  Non-Wage  Labour  Costs  and  further 
elaborations based on Commission expert judgement. 
28 TRACES (Trade Control and Expert System), European Commission, 2025 and FiBL-AMI survey 2025 based 
on national data sources and Eurostat and Willer, Helga Jan Trávníček and Bernhard Schlatter (Eds.) (2025): The 
World of Organic Agriculture. Statistics and Emerging Trends 2025. Research Institute of Organic Agriculture 
FiBL, Frick, and IFOAM  – Organics International, Bonn and further elaboration based on  Commission expert 
judgement. 
29  Eurostat  Structure  of  earnings  survey,  Labour  Force  Survey  data  for  Non-Wage  Labour  Costs  and  further 
elaborations based on Commission expert judgement. 

16 

 
 
 
The total administrative costs savings of the proposed measure therefore amount to EUR 16.5 
million annually. 

3.6.Conversion period and minimum age at slaughter for quails for meat production 
Point 1.2.2 of Part II of Annex II to Regulation (EU) 2018/848 lays down a conversion period 
of  10  weeks  for  poultry  for  meat  production.  Point  1.9.4.1  of  Part  II  of Annex  II  to  that 
Regulation lays down minimum ages at slaughter, where slow-growing poultry strains are not 
used. Those provisions do not lay down any specific conversion period or a minimum age at 
slaughter for quails. In Member States where organic quails are raised for meat production, 
their production cycle is shorter than the cycle of other species of poultry for meat production, 
since they are slaughtered from 42 days of age. Furthermore, their conversion period is five 
weeks, i.e. one week less than the minimum age at slaughter for these species.  

The proposed measure sets a conversion period of five weeks for quails for meat production, 
adapted to the length of their production cycle, and a minimum age of 42 days at slaughter 
where slow-growing poultry strains are not used. The proposed measure will mean that organic 
operators  (farmers)  benefit  from  an  appropriate  conversion  period  when  introducing  non-
organic  quails  for  meat  production  into  their  holdings,  and  an  appropriate  minimum  age  at 
slaughter for quails. The measure will therefore promote the expansion of organic quails for 
meat production. This is currently hindered by the rules, which are not appropriate for quails 
as a poultry species.  

3.7.Withdrawal period for treatments with veterinary medicinal products 
Point 1.5.2.5 of Part II of Annex II to Regulation (EU) 2018/848 lays down rules on veterinary 
treatments for terrestrial animals. Those rules provide that the withdrawal period after the use 
of chemically synthesised allopathic medicinal products as defined in Regulation (EU) 2019/6 
of the European Parliament and of the Council30 is twice the normal withdrawal period and 
with  a  minimum  duration  of  48  hours.  This  means  that,  even  if  the  applicable  normal 
withdrawal period of the veterinary medicinal product is zero days, the withdrawal period must 
be a minimum of 48 hours. 

For aquaculture, point 3.1.4.2(f) of Part III of Annex II to Regulation (EU) 2018/848 provides 
that the withdrawal period after the use of allopathic veterinary medicinal products must be 
twice that of an authorised veterinary medicinal product, or a minimum of 48 hours if no period 
is specified. 

The rules on the withdrawal period create a burden for the production of terrestrial animals, 
particularly in cases where the withdrawal period specified in the veterinary medicinal product 
is zero days. The proposed measure aligns the rules on the withdrawal period for terrestrial 

30 

Regulation  (EU)  2019/6  of  the  European  Parliament  and  of  the  Council  of  11  December  2018  on 
veterinary  medicinal  products  and  repealing  Directive  2001/82/EC  (OJ  L  4,  7.1.2019,  p.  43,  ELI: 
http://data.europa.eu/eli/reg/2019/6/oj). 

17 

 
 
 
  
 
animals  with  those  for  aquaculture.  It  thereby  removes  the  burden  organic  operators 
(farmers), notably in the poultry and dairy sectors, where certain veterinary medicinal products 
that are commonly used specify withdrawal periods of zero days. 

The proposed measure will also allow products originating from animals in those sectors, such 
as eggs or dairy products, to be placed on the market as organic immediately at the end of any 
veterinary  treatment  resulting  in  zero  days  of  withdrawal  period,  instead  of  only  after  an 
additional 48 hours. This will increase the earnings of the organic operators concerned and will 
allow  organic  products  to  be  marketed  that,  otherwise,  would  be  either  redirected  to  other 
supply chains, with consequent practical complications for operators, or might be destroyed.  

The proposed measure will further guarantee the integrity of organic production for consumers 
and, at the same time, simplify matters for operators in cases where the veterinary medicinal 
products used do not cause a risk to public health, their withdrawal period being set at zero 
days. 

As regards the egg sector, there are 26.4 million of organic laying hens in the EU and their 
average productivity is 90%31. They are treated an average of four times a year32 with veterinary 
medicinal  products  having  a  withdrawal  period  of  zero  days.  It  is  therefore  likely  that  190 
million  eggs  cannot  be  sold  as  organic  during  the  48  hours  following  the  end  of  those 
treatments.  They  are  either  redirected  to  other  supply  chains  under  other  labels,  sold  as 
conventional  eggs,  or,  possibly,  destroyed.  Considering  the  difference  between  the  average 
price paid  to  farmers  for organic and conventional  eggs33, the proposed  measure may bring 
adjustment cost savings of EUR 9.5 million annually for organic operators (farmers).  

3.8.Conditions for access to open air areas for poultry 
Point 1.9.4.4(e) of Part II of Annex II to Regulation (EU) 2018/848 lays down rules on housing 
and husbandry practices for poultry. Those rules provide, among other things, that poultry must 
be  provided  with  continuous  daytime  open  air  access  from  as  early  an  age  as  practically 
possible. 

In the case of split-rearing systems, poultry may be reared for the first few days of life in a 
poultry  house  of  a  production  unit  on  a  holding  that  structurally  lacks  open  air  access. 
Subsequently, poultry may be transferred to another poultry house, including in a production 
unit  of  another  holding,  with  open  air  access  for  the  following  phases  of  the  life  cycles. 
Mandatory  open  air  access  for  young,  unfeathered  birds  can  put  at  risk  their  safety  and, 
possibly, their survival. This  is  because, in  this  period of their  life-cycle, they need, among 
other  things,  stable  temperatures  to  develop  their  feeding  and  drinking  behaviours, 
immunisation against infections, and shelter from any predators. In the early phases of their 

31 https://agridata.ec.europa.eu/extensions/DataPortal/agricultural_markets.html.  
32 Based on organic stakeholders’ expert judgement. 
33 https://agridata.ec.europa.eu/extensions/DashboardPrice/OrganicPricesTrends.html#.  

18 

 
 
  
 
production  cycle,  in  fact,  their  lack  of  feathers  prevents  them  from  regulating  their  body 
temperature in outdoor conditions. 

The proposed measure makes continuous daytime open air access subject to the condition that 
birds must be sufficiently feathered to regulate their body temperature when exposed to outdoor 
conditions.  This  will  allow  organic  certification  to  be  granted  to  organic  farming  sector 
operators (farmers)  that run split-rearing systems, where the poultry  houses  structurally 
lack access to the open air since they are only used in the first weeks of life of the birds. In this 
sense, the proposed measure also reduces the risks for those animals, benefitting their health 
and welfare. 

The requirement in point 1.9.4.4(d) of Part II of Annex II to Regulation (EU) 2018/848 will 
continue to guarantee that poultry animals are given access to open-air areas for at least one 
third of their life, regardless of where they are reared during their production cycle. This will 
continue to uphold the animal welfare requirements of the Regulation. 

There are 14.3 million young poultry animals in the EU, of which 7 million  are potentially 
covered by the current requirements on access to open air areas34. One-off adjustment costs to 
comply with those requirements, e.g. adapting existing poultry houses or building new outdoor 
areas,  are  estimated  at  EUR  15.6  per  young  poultry  head35.  The  proposed  measure  may 
therefore bring one-off adjustment cost savings of EUR 109.2 million for operators (farmers).   

Amending the requirements on access to open air areas will ensure that birds are sufficiently 
feathered to regulate their body temperature when exposed to outdoor conditions before having 
access  to  open  air  areas. This  will  avoid  the  costs  linked  to  losing  young  poultry  animals, 
estimated at EUR 1.7 per young poultry head36 by reducing their mortality in their first weeks 
of  age.  The  proposed  measure  may  therefore  bring  adjustment  costs  savings  of  EUR  11.9 
million annually for operators (farmers). 

More generally, the measure will contribute to further developing the organic poultry sector, 
boosting the productivity of operators and avoiding losses in the early rearing phase.   

3.9.Poultry houses per production unit for fattening poultry 
Point 1.9.4.4(m) of Part II of Annex II to Regulation (EU) 2018/848 lays down that the total 
usable  surface  area  for  fattening  poultry  in  poultry  houses  of  any  production  unit  must  not 
exceed 1 600 m2. This limits the further development of organic fattening poultry production 
by limiting the size of any fattening poultry houses in an organic production unit and does not 
bring any additional benefits in terms of animal welfare or the environment. 

34https://agridata.ec.europa.eu/extensions/DataPortal/agricultural_markets.html,  
https://ec.europa.eu/eurostat/databrowser/view/org_lstspec/default/table?lang=en&category=agr.org  and  further 
elaborations based on Commission expert judgement. 
35 Based on organic stakeholders’ expert judgement provided in the Call for Evidence. 
36 Based on organic stakeholders’ expert judgement.  

19 

 
 
 
 
The proposed measure lays down the maximum usable surface area for fattening poultry at the 
level of the poultry houses instead of at production unit level. This will allow operators to have 
several poultry houses, each of a maximum 1 600 m2, in the production units of their holding.  
This  increase  in  the  total  maximum  usable  surface  area  for  fattening  poultry  will  allow 
operators to benefit from economies of scale, thus optimising production costs and the overall 
management  of  their  farms.  In  particular,  it  will  avoid  holdings  being  split  up  for  the  sole 
purpose  of  operating  multiple  organic  production  units  and  poultry  houses. This  will  allow 
operators to avoid the costs linked to creating multiple holdings and paying for multiple organic 
inspections and certifications.  

There are approximately  32 million  fattening  poultry in  the EU,  of which 16 million  are  in 
holdings  potentially  affected  by  the  current  requirements  on  poultry  houses  per  production 
unit37. The administrative costs of complying with those requirements, such as creating a new 
organic  certified  holding  for  the  purpose  of  operating  an  extra  organic  production  unit  and 
therefore  poultry  house,  are  estimated  at  EUR  1.56  per  head  of  poultry38.  They  are  also 
recurrent since the costs related to keeping a holding and undergoing organic inspection and 
certification are payable each year. 

The proposed measure  may therefore  give rise  to administrative cost  savings  for operators 
(farmers)  of  EUR  25  million  annually.  More  generally,  it  will  remove  market  barriers  and 
boost the growth and competitiveness of the organic fattening poultry sector.  

The presence of several poultry houses in a production unit could result in a higher number of 
fattening  poultry  reared  on  the  same  holding. Any  such  increase  in  the  number  of  poultry 
houses in production units will be subject to the requirements of Regulation (EU) 2018/848 
and  Commission  Implementing  Regulation  (EU)  2020/46439.  Those  requirements  govern 
aspects such as animal welfare, housing conditions, stocking densities and minimum surface 
for indoor and outdoor areas. 

4.  ENVIRONMENTAL AND SOCIAL IMPACTS 

Beyond the reduction in costs, removing barriers for operators in the EU and in third countries 
is  expected  to  help  preserve  organic  farming  and  stimulate  its  uptake.  The  proposed 
amendments are specifically designed to uphold the principles and high standards of organic 
production in the EU, ensuring that the environmental and social benefits of organic production 
are sustained.  

37https://agridata.ec.europa.eu/extensions/DataPortal/agricultural_markets.html,  
https://ec.europa.eu/eurostat/databrowser/view/org_lstspec/default/table?lang=en&category=agr.org  and  further 
elaborations based on Commission expert judgement. 
38 Based on organic stakeholders’ expert judgement provided in the Call for Evidence. 
39  Commission  Implementing Regulation  (EU)  2020/464 of  26  March  2020  laying down  certain  rules  for  the 
application of Regulation (EU) 2018/848 of the European Parliament and of the Council as regards the documents 
needed for the retroactive recognition of periods for the purpose of conversion, the production of organic products 
and 
(OJ  L  98,  31.3.2020,  pp.  2–25,  ELI: 
http://data.europa.eu/eli/reg_impl/2020/464/oj). 

to  be  provided  by  Member  States 

information 

20 

 
 
 
 
The  environmental  benefits  of  organic  farming  have  been  widely  documented,  and  the 
measures included in this proposal – aimed at facilitating the uptake of organic farming and 
promoting the sector’s growth – will therefore be beneficial in this regard. For instance, this is 
particularly the case for water protection, soil conservation and biodiversity enhancement40. 
Overall, organic  farming uses a number of management practices that  contribute to  climate 
change mitigation and hence, the prime objective of climate-neutrality. When assessed per unit 
of land, organic farming contributes to climate change mitigation through lower energy use and 
fewer greenhouse gas emissions  owing to the limited use of fertilisers41. Moreover, organic 
farming  has  the  potential  for  higher  soil  carbon  sequestration  compared  to  conventional 
agriculture42. These benefits derive both from the system-based approach of organic farming, 
as well as from the practices adopted by organic operators, such as avoiding the use of synthetic 
fertilisers, the mandatory application of crop rotation, and higher standards in terms of animal 
welfare and husbandry43.  

As  the  targeted  adjustments  and  the  amendments  regarding  trade  of  organic  products  are 
designed  to  promote  the  organic  sector’s  growth,  and  due  to  the  abovementioned  overall 
contribution  of organic agriculture  to climate change mitigation, the proposed measures  are 
expected  to  result  in  no  increase  in  greenhouse  gas  emissions.  Therefore,  the  proposed 
measures  are  consistent  with  the  climate-neutrality  objective  set  out  in  Article  2(1)  of 
Regulation (EU) 2021/111944 (European Climate Law), as well as the EU 203045 and 204046 
climate  targets.  Moreover,  thanks  to  its  higher  species  diversity  and  the  better  capacity  of 
organic  fields  to  hold  water,  organic  farming  practices  can  strengthen  resilience  to  weather 
extremes47, thereby contributing to the EU’s efforts in climate change adaptation, provided for 
in Article 5 of Regulation (EU) 2021/1119. 

As  regards  the  social  benefits,  the  proposal  aims  to  increase  the  profitability  of  organic 
operators. Research suggests that increased income predictability can lower farmer stress levels 
and  lead  to  improved  mental  health  outcomes  and  overall  well-being  for  farmers  and  farm 

40 Sanders, J. et al., Benefits of organic agriculture for environment and animal welfare in temperate climates. Org. 
Agr. (2025) 15:213–23. https://doi.org/10.1007/s13165-025-00493-w. 
41  Seufert,  V.  and  Ramankutty,  N.,  Many  shades  of  gray—The  context-dependent  performance  of  organic 
agriculture. (2017) Sci. Adv. 2017;3: e1602638. https://doi.org/10.1126/sciadv.1602638. 
42 A. Gattinger, A. Muller, M. Haeni, C. Skinner, A. Fliessbach, N. Buchmann, P. Mäder, M. Stolze, P. Smith, 
N.E. Scialabba, & U. Niggli, Enhanced top soil carbon stocks under organic farming, Proc. Natl. Acad. Sci. U.S.A. 
109 (44) 18226-18231, https://doi.org/10.1073/pnas.1209429109 (2012). 
43 Sanders, J. et al., Benefits of organic agriculture for environment and animal welfare in temperate climates. 
Org. Agr. (2025) 15:213–23. https://doi.org/10.1007/s13165-025-00493-w.  
44 Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing the 
framework for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999 
https://eur-lex.europa.eu/legal-
(‘European  Climate  Law’) 
content/EN/TXT/?uri=CELEX:32021R1119). 
45 https://climate.ec.europa.eu/eu-action/climate-strategies-targets/2030-climate-targets_en. 
46 Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending 
neutrality 
Regulation 
https://climate.ec.europa.eu/document/download/e1b5a957-c6b9-4cb2-a247-bd28bf675db6_en. 
47 N. Scialabba, M. Müller-Lindenlauf, Organic agriculture and climate change, Renewable Agriculture and Food 
Systems, 25 (2), pp. 158 – 169 (2010) 10.1017/S1742170510000116. 

establishing 

framework 

2021/1119 

achieving 

9.7.2021, 

(OJ  L 

climate 

1–17, 

(EU) 

243, 

pp. 

the 

for 

21 

 
 
 
workers48. This can foster better working conditions and social cohesion. It can also help to 
mitigate rural depopulation and preserve rural employment, as well as supporting the long-term 
viability  of  organic  farming.  The  simplification  of  rules  facilitates  their  application  and 
implementation. Among other benefits, this simplification will help to avoid situations where 
farmers  are  forced  to  cut  corners,  including  environmental  or  social  safeguards,  to  remain 
competitive49.  

With clearer and simpler EU legislation, organic operators will be encouraged to increase and 
expand  their  investments  in  the  organic  farming  sectors  covered  by  this  proposal.  This  is 
expected to boost innovation in socially responsible business practices. The promotion of short 
supply chains, which emphasise direct and close relationships between farmers and consumers, 
is one of the objectives of Regulation (EU) 2018/848 and further growth in the organic farming 
sector will also serve that objective, thereby strengthening cohesion between rural and urban 
areas50. 

Moreover,  environmental  and  social  aspects  are  closely  intertwined:  evidence  shows  that, 
particularly  in  third  countries,  smaller  organic  operators  are  also  involved  in  socially  fairer 
schemes (e.g. Fairtrade)51. In addition, the proportion of young farmers (those below the age 
of 40) is higher for organic farming (20.7%) than for all farms (11.9%), hinting at the important 
role of organic farming in generational renewal.52 

5.  CONTRIBUTION TO SIMPLIFICATION AND BURDEN REDUCTION, AND 

THE DIGITAL ASSESSMENT 

Several  elements  in  the  proposal  contribute  to  simplification,  reducing  bureaucracy  and 
administrative burden for organic operators and Member States’ administrations. In particular, 
they  benefit  operators  in  this  regard  in  relation  to:  (i)  allowing  the  use  of  the  products  and 
substances  available  on  the  market  for  cleaning  and  disinfection  for  use  in  processing  and 
storage; (ii) adapting the conditions for the exemption of smaller operators selling unpacked 
organic  products  other  than  feed  from  the  obligation  of  being  in  possession  of  a  certificate 
pursuant to Article 35(1) of Regulation (EU) 2018/848; (iii) adapting the requirements for the 
composition of groups of operators; and (iv) adapting livestock production rules. Moreover, 
they benefit Member States’ administration in relation to the adaptation of the conditions for 
the exemption of smaller operators selling unpacked organic products other than feed from the 
obligation of being in possession of a certificate pursuant to Article 35(1) of Regulation (EU) 

48  Eurofound,  2020,  p. 10  ,  European  Agency  for  Safety  and  Health  at  Work,  Mental  health  in  agriculture: 
preventing  and  managing  psychosocial  risks  for  farmers  and  farm  workers,  Report,  2024,  Available  at: 
https://osha.europa.eu/sites/default/files/documents/Mental-health-agriculture_EN.pdf;  Farmwell, 
Improving 
farmers’  wellbeing  through  social  innovation  –  Mapping  report  on  challenges,  2021,  Available  at: 
https://farmwell-h2020.eu/wp-content/uploads/2021/12/D-2.3_SYNTHESIS1.pdf.   
49 OECD, 2015, p. 41. 
50 Stein, A.J., Santini, F. The sustainability of “local” food: a review for policy-makers. Rev Agric Food Environ 
Stud 103, 77–89 (2022). https://doi.org/10.1007/s41130-021-00148-w.  
51  In  the  example  of  Fairtrade,  farmers  typically  have  conditions/additional  requirements  to  fulfil  in  terms  of 
sustainability criteria (environmental, social).  
52https://ec.europa.eu/eurostat/statistics-
explained/index.php?oldid=685812#Profiles_of_managers_of_fully_organic_farms.  

22 

 
 
 
2018/848. The proposal  adapts  the provisions of  Regulation  (EU) 2018/848 to  the practical 
needs of operators, preserving objectives and principles of that Regulation, maintaining its high 
standards  and  avoiding  one-size-fits-all  approaches  that  might  prove  to  be  burdensome  to 
implement and less effective. 

Following the digital assessment, the current proposal does not include any requirements of 
digital relevance. Digital means or data exchange are not under the scope of this proposal. 

23 

 
 
 
ANNEX I - Summary of cost benefits and burden reduction  

Overview of burden reduction (total for all provisions)  

Citizens/Consumers 

Businesses 

Administrations 

One-off 

Recurrent 
(annual) 

One-off 

Recurrent 
(annual) 

One-off  Recurrent 
(annual) 

Products and 
substances for 
cleaning and 
disinfection in 
processing 
and storage 
facilities 

Conditions 
for exemption 
of the organic 
operator 
certificate for 
smaller 
sellers  

Postponement 
of the expiry 
of the 
equivalences 
with third 
countries 

Direct 
administrative 
cost savings 

Direct 
adjustment 
cost savings 

Direct 
administrative 
cost savings 
Direct 
adjustment 
cost savings 

Direct 
administrative 
cost savings 

Direct 
adjustment 
cost savings 

Withdrawal 
period for 
treatments with 
veterinary 
medicinal 
products on 
livestock 

Direct 
administrative 
cost savings 

Direct 
adjustment 
cost savings 

Conditions for 
access to open 
air areas for 
poultry 

Poultry houses 
per production 
unit for 
fattening 
poultry 

Direct 
administrative 
cost savings 

Direct 
adjustment 
cost savings 

Direct 
administrative 
cost savings 

Direct 
adjustment 
cost savings 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

EUR 68.8 
million 

EUR 5.9 
million 

x 

EUR 15 
million 

x 

x 

EUR 9.5 
million 

x 

EUR 109.2 
million 

EUR 11.9 
million 

x 

x 

EUR 25 
million  

x 

24 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

EUR 1.9 
million 

x 

x 

x 

x 

x 

x 

x 

x 

x 

 
 
 
 
 
TOTAL 

Direct 
administrative 
cost savings 

Direct 
adjustment 
cost savings 

x 

x 

x 

x 

x 

EUR 45.9 
million 

EUR 109.2 
million 

EUR 90.2 
million 

x 

x 

EUR 1.9 
million 

x 

25 

 
 
 
 
ANNEX  II  - Summary  of  suggestions  put  forward  during  the  consultations  and  not 
retained in the initiative 

5.1. Livestock conversion 

Certain Member States and stakeholders suggested amending the provisions on the period of 
conversion for bovine and equine animals for meat production laid down in point 1.2.2(a) of 
Part II of Annex II to Regulation (EU) 2018/848, by removing the provision ‘and in any case 
no less than three quarters of their lifetime’. 

Certain other Member States voiced their opposition to the removal of this provision, since it 
would undermine the incentive to produce organic bovine equine animals for meat production 
by making it easier to introduce non-organic animals into an organic production unit.  

The Commission considers that clarification could be provided through non-legislative actions, 
such as via the FAQs, where rules and calculations for the conversion period could be clarified 
in order to facilitate and harmonise the implementation of this provision across Member States. 
In  addition,  removing  the  abovementioned  provision  would  be  inconsistent  with  other 
production rules laid down in Regulation (EU) 2018/848, such as the rules on the simultaneous 
conversion of production units and animals, laid down in point 1.2.1 of Part II of Annex II to 
that Regulation. 

5.2. Soil management and fertilisation in greenhouses 

Certain  Member  States  and  stakeholders  suggested  amending  the  requirements  for  soil 
management in greenhouses laid down in point 1.9.2 of Part I of Annex II to Regulation (EU) 
2018/848 by removing ‘by the use of short-term green manure crops and legumes as well as 
the use of plant diversity’. 

This suggestion is incompatible with the objective, laid down in Article 4 of Regulation (EU) 
2018/848,  of  maintaining  long-term  fertility  of  soils,  and  with  the  principle,  laid  down  in 
Article 5  of  that  Regulation,  of  practising  soil-related  crop  cultivation.  Furthermore,  such  a 
suggestion would be incompatible with the Commission proposal53 for amendments to the CAP 
regulations  (Regulation  (EU)  2021/2115  and  Regulation  (EU)  2021/2116).  Under  that 
proposal, farmers certified under Regulation (EU) 2018/848 would be deemed compliant with 
certain Good Agricultural and Environmental Conditions (GAEC) standards. 

5.3. Handling of residues in organic production 

Certain  Member  States  and  stakeholders  suggested  amending  the  rules  on  precautionary 
measures to avoid the presence of non-authorised products and substances and on the measures 
to be taken in the event of the presence of non-authorised products or substances. In particular, 

53 COM/2025/236 final. 

26 

 
 
 
 
 
they proposed defining what constitutes a ‘suspicion’ of non-compliance and the ‘presence’ of 
non-authorised products and substances that trigger the launch of an official investigation. 

In accordance with Article 29(4) of Regulation (EU) 2018/848, the Commission will present a 
report to the European Parliament and the Council on the implementation of Article 29, on the 
presence of non-authorised products and substances and on the assessment of the national rules 
referred  to  in  paragraph  5  of  that  Article.  That  forthcoming  Commission  report  may  be 
accompanied,  where  appropriate,  by  a  legislative  proposal  for  further  harmonisation.  In  the 
meantime, and without prejudice to that, clarification on the current applicable provisions could 
also  be  provided  through  non-legislative  actions,  such  as  via  the  FAQs,  dedicated  working 
groups or workshops.  

5.4. Milk replacers 

In relation to point 1.4.1(g) of Part II of Annex II to Regulation (EU) 2018/848, certain Member 
States  and  stakeholders  suggested  allowing  the  use,  for  suckling  animals,  of  milk  replacers 
containing components of plant origin where maternal milk cannot be used.  

Nutrition requirements are an important feature of organic production. Point 1.4.1 of Part II of 
Annex  II  to  Regulation  (EU)  2018/848  requires  that  feed  be  obtained  primarily  from  the 
agricultural holding where the animals are kept or from organic or in-conversion production 
units belonging to other holdings in the same region. If the maternal milk is not available for 
suckling animals during the minimum suckling period, milk from other lactating animals may 
be  used.  Hence,  milk  of  animal  origin  exists  as  an  alternative  to  milk  replacers  containing 
components of plant origin and should therefore be used during the minimum suckling period. 

5.5. Non-organic animals grazing on organic land 

Certain Member States and stakeholders suggested allowing non-organic animals to graze on 
organic land.  

There  are  already  exemptions,  under  point  1.4.2  of  Part  II  of Annex  II  to  Regulation  (EU) 
2018/848, allowing non-organic animals raised under specific land support schemes to graze 
for a limited period each year on organic land. As a general rule, organic production should be 
separated from non-organic production in order to avoid commingling and fraud. The current 
provisions allow for a balance between flexibility and integrity of organic production and aim 
to avoid, among other things, the potential contamination of organic land with residues of non-
authorised products and substances from non-organic animals. Additional clarification on this 
issue could also be provided through non-legislative actions, such as via the FAQs.  

27 

 
 
 
 
 
5.6. Exemption of certification for web shops selling pre-packed organic products to the 

final consumer 

Certain Member States and stakeholders suggested that web shops selling pre-packed organic 
products to the final consumer could be exempted from the requirement to have the certificate 
referred to in Article 35(1) of Regulation (EU) 2018/848.  

This suggestion would not be in line with the organic certification system. This has already 
been clarified in the FAQs54 on organic rules. 

5.7. Plant reproductive material 

Certain  Member  States  and  stakeholders  suggested  amending  the  provisions  on  plant 
reproductive material.  

The provisions on plant reproductive material are highly technical and concerns different types 
of plant reproductive materials (e.g. seeds, seedlings, organic heterogeneous material, etc.). In 
addition, plant reproductive materials have a dual nature, covering both products put on the 
market  by  nurseries  and  products  used  by  farmers  as  external  inputs  or  self-produced. This 
suggestion  therefore  requires  an  in-depth  analysis  and  a  comprehensive  discussion  with 
national experts in the GREX. 

5.8. Aquaculture 

Certain Member States and stakeholders suggested amending the aquaculture rules as regards 
derogations for non-organic juveniles, water quality criteria for bivalves, and the requirement 
for fish oil and meal to come from sustainable certified fishery.  

This suggestion is incompatible with the objective, laid down in Article 4 of Regulation (EU) 
2018/848, of encouraging the preservation of rare and native breeds in danger of extinction, 
and with the principle, laid down in Article 5(d) of that Regulation, that ‘the production of a 
wide variety of high-quality food and other agricultural and aquaculture products that respond 
to consumers’ demand for goods that are produced by the use of processes that do not harm 
the environment, human health, plant health or animal health and welfare’.  

The phasing out of derogations in aquaculture was finalised in 2016 under Regulation (EC) 
No 889/2008  (the  previous  EU  regulation  on  organic  production).  Reintroducing  those 
derogations  would  undermine  the  incentive  to  produce  organic  juveniles  and  therefore  be 
economically prejudicial to those operators that have already invested in them. The requirement 
for fish meal and oil to be certified as sustainable has been in force since organic aquaculture 
rules were initially adopted, under the above-mentioned Regulation (EC) No 889/2008. Finally, 
the  requirements  on  water  quality  for  bivalves  have  been  strengthened  in  Regulation  (EU) 

54 Organic rules – frequently asked questions (Chapter 3, p.36).  

28 

 
 
 
 
 
2018/848 as there was a willingness among the co-legislators to define a criterion to clearly 
differentiate conventional aquaculture production from organic aquaculture production.   

5.9. Non-organic protein feed 

One  Member  State  and  certain  stakeholders  suggested  amending  the  provisions  on  the 
authorisation  to  use  non-organic  protein  feed  either  by  extending  the  expiry  of  such 
authorisation beyond 31 December 2026, or by making it permanent. That authorisation is set 
out  in  Part  II  of Annex  II  to  Regulation  (EU)  2018/848,  under  point  1.9.3.1(c)  for  porcine 
animals and under point 1.9.4.2(c) for poultry. 

Before 31 December 2026, the Commission must present a report to the European Parliament 
and the Council on the availability on the EU market of organic protein feed for the nutrition 
of poultry and porcine animals and, if relevant, on the causes of limited access to such feed 
(Article 53(7) of Regulation (EU) 2018/848). On the basis of that report and in accordance with 
Article 53(4) of that Regulation, the Commission is empowered to adopt delegated acts as from 
1 January 2026 and to extend those authorisations or end them. 

Any  potential  extension  of  those  authorisations  should  be  based  on  information,  that  the 
Commission has been collecting from Member States since 2022, on the availability of organic 
protein feed for porcine animals and poultry. Such information will be presented in the above-
mentioned report by 31 December 2026 and any potential measure will be based on the above-
mentioned empowerment. 

5.10. 

Removal of sea salt and other salts for food and feed 

One Member State and  certain  stakeholders  suggested removing sea salt and other salts for 
food and feed from Annex I to Regulation (EU) 2018/848. Another stakeholder proposed that 
it be maintained.  

The Commission adopted a delegated regulation laying down detailed production rules for sea 
salt and other salts for food and feed55. It was rejected to by the European Parliament56 and did 
not enter into force. In the absence of detailed production rules, and pursuant to Article 21(2) 
of  Regulation  (EU)  2018/848,  some  Member  States  have  developed  and  applied  detailed 
national rules for the production of those salts, as a result of which operators have started to 
produce and place on the market salts as organic products. Removing sea salt and other salts 
for food and feed from Annex I to Regulation (EU) 2018/848 would cause economical harm to 
those operators. 

55 C(2023) 2781 final. 
56 European Parliament: Motion for a resolution B9‑0308/2023. 

29 

 
 
 
 
 
 
5.11. 

Access to pasture/grazing for bovines 

One  Member  State  and  certain  stakeholders  suggested  flexibility  on  access  to  pasture  and 
grazing for certain categories and groups of bovines and in relation to the structural features of 
the  holdings.  In  particular,  they  suggested  that  the  Member  States  should  be  able  to  grant 
derogations from the rule on access to pasture for certain groups of animals to which access 
cannot be granted for reasons connected to the structure of holdings of operators certified as 
organic before 2025. In addition, they suggested that any such derogations should terminate by 
the end of 2035. In contrast, another Member State suggested that the current rules provide 
enough flexibility and that no changes should therefore be proposed in this regard. 

The suggested flexibility would be incompatible with the objective, laid down in Article 4 of 
Regulation (EU) 2018/848, of contributing to high animal welfare standards and, in particular, 
to meeting the species-specific behavioural needs of animals. It would also be incompatible 
with the principles related to animal welfare laid down in points (d), (f)(ii) and (j) of Article 5 
of that Regulation. Furthermore, the current rules set out in Regulation (EU) 2018/848 already 
provide organic farmers with flexibility as regards the access to pasture related to temporary 
climatic or soil conditions or human or animal health situation. 

5.12. 

Organic ingredients naturally rich in micronutrients 

One Member State and certain stakeholders suggested modifying the requirements on organic 
ingredients that are naturally rich in micronutrients. This suggestion is linked to the existing 
restrictions on enriching organic processed food with vitamins, minerals and micronutrients, 
as laid down in point 2.2.2(f) of Part II of Annex II to Regulation (EU) 2018/848. 

A  request  for  a  preliminary  ruling  is  currently  pending  before  the  Court  of  Justice  of  the 
European Union57 on the possibility of using the powder obtained from certain algae, certified 
as organic, for the purpose of adding calcium to vegetable drinks.  

The Commission will not undertake any action in this regard until the Court of Justice of the 
European  Union  has  delivered  its  preliminary  ruling.  An  appropriate  empowerment  for  a 
delegated regulation is in any event already laid down in point (b) of Article 16(2) of Regulation 
(EU) 2018/848. 

57 Case C-295/25, Lima: Request for a preliminary ruling from the Raad van State (Belgium) lodged on 23 April 
2025 – Lima BV v Vlaams Gewest (OJ C, C/2025/4732, 8.9.2025, ELI: http://data.europa.eu/eli/C/2025/4732/oj). 

30 

 
 
 
 
 
 
ANNEX III – Overview of Call for Evidence respondents’ statistics 

By category of respondent: 

31 

 
 
 
 
 
21,53%; 155

16,11%; 116

45,14%; 325

By country: 

France

Germany

Austria

Belgium

Sweden

4,03%; 29

3,19%; 23

Spain

1,94%; 14

Denmark

1,67%; 12

Norway

0,83%; 6

Ecuador

0,69%; 5

India

0,69%; 5

Finland

0,42%; 3

United Kingdom

0,42%; 3

Madagascar

0,42%; 3

Poland

0,42%; 3

Italy

0,28%; 2

Kenya

0,28%; 2

Netherlands

0,28%; 2

Türkiye

0,28%; 2

United States

0,28%; 2

Bolivia

0,14%; 1

Canada

0,14%; 1

Switzerland

0,14%; 1

Colombia

0,14%; 1

Fiji

0,14%; 1

Ireland

0,14%; 1

El Salvador

0,14%; 1

Slovakia

0,14%; 1

0

50

100

150

200

250

300

350

32