REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of Article 29 of Regulation (EU) 2018/848 of the European Parliament and of the Council on organic production and labelling of organic products, on the presence of products and substances not authorised pursuant to the first subparagraph of Article 9(3) of said Regulation (EU) 2018/848 for use in organic production and on the assessment of the national rules referred to in paragraph 5 of Article 29
Date: 2026-03-31
Institutions: Directorate-General for Agriculture and Rural Development, European Commission
Subjects: application of EU law, consumer protection, food contamination, food inspection, food safety, labelling, organic certification, organic farming, organic product, pesticide residue

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 31.3.2026  COM(2026) 142 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of Article 29 of Regulation (EU) 2018/848 of the European Parliament and of the Council on organic production and labelling of organic products, on the presence of products and substances not authorised pursuant to the first subparagraph of Article 9(3) of said Regulation (EU) 2018/848 for use in organic production and on the assessment of the national rules referred to in paragraph 5 of Article 29 {SWD(2026) 95 final}  
 
 
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on the implementation of Article 29 of Regulation (EU) 2018/848 of the European 
Parliament and of the Council on organic production and labelling of organic products, 
on the presence of products and substances not authorised pursuant to the first 
subparagraph of Article 9(3) of said Regulation (EU) 2018/848 for use in organic 
production and on the assessment of the national rules referred to 
in paragraph 5 of Article 29 

Abbreviation 

Explanation 

CA/(s) 

CB/(s) 

competent authority/(ies) 

control body/(ies) 

CtrlA/(s) 

control authority/(ies) 

EFSA 
EU 

MRL 
MU 
OFIS  

PF 
LOQ 
LOD 
TC 

European Food Safety Authority 
European Union 

maximum residue level 
measurement uncertainty 
Organic Farming Information System 

processing factor 
limit of quantification 
limit of determination 
third country 

I. 

INTRODUCTION 

Organic farming is a key element of the EU’s Common Agricultural Policy. The proportion of 
land  farmed  organically  has  been  growing  steadily  to  reach  11%  today  and  consumers 
increasingly purchase organic food, which is recognisable through an EU logo. The production 
and labelling of organic products are governed by Regulation (EU) 2018/848 of the European 
Parliament and of the Council1 (hereafter the ‘Organic Regulation’), applicable since January 
2022, as well as by the delegated and implementing Regulations that have been adopted on its 
basis and lay down the detailed rules underpinning organic production. 

Pursuant  to  Article 29(4)  of  the  Organic  Regulation,  the  Commission  must  present  ‘by 
31 December 2025, a report to the European Parliament and the Council on the implementation 
of measures taken in the event of the presence of products and substances not authorised for 

1. Regulation (EU) 2018/848 of the European Parliament and of the Council of 30 May 2018 on organic production 
and 
(EC)  No 834/2007  
(OJ L 150, 14.6.2018, p. 1, ELI: http://data.europa.eu/eli/reg/2018/848/2025-03-25). 

repealing  Council  Regulation 

labelling 

products 

organic 

and 

of 

1 

 
 
 
 
 
 
use in organic production and on the assessment of the national rules referred to in Article 29(5) 
of the Organic Regulation. That report may be accompanied, where appropriate, by a legislative 
proposal for further harmonisation’. 

Organic and in-conversion products are subject to the specific rules,  in particular concerning 
the active substances authorised for use in organic production as set out Annex I to Commission 
Implementing Regulation (EU) 2021/11652 whereas  the presence at any stage of the supply 
chain of residues of products or substances not authorised for use in organic production must 
be duly investigated  with the view to ensure the integrity of organic products. 

Furthermore, to ensure consumer safety, Regulations of the European Parliament and of the 
Council  (EC)  No  396/20053  and  (EU)  2017/6254  govern  official  controls  and  residues  of 
pesticides in food and feed. These provisions also apply to organic products.  

Every year, the EFSA publishes results on the presence of residues in food, including organic 
products5.  In  2023,  out  of  the  7 074  samples  labelled  as  organic,  80%  did  not  contain 
quantifiable  residues,  19%  contained  residues  below  or  at  the  MRL  (of  which  94.6%  were 
copper-based substances) and in only 0.9% of the samples contained residues above the MRL. 

This report from the Commission to the European Parliament and the Council  builds on the 
one hand on contamination reports submitted over the last three years by Member States6 on 
their official investigations into contamination of organic and in-conversion products and on 
the  other  hand  on  the  conclusions  of  a  dedicated  study  by  the  EFSA  on  21  substances  not 
authorised for use in organic production notified in the OFIS in 2021 and 2022 as occurring 
most  frequently  in  organic  products7.  For  each  substance,  the  EFSA  examined  relevant 

2.Commission  Implementing  Regulation  (EU)  2021/1165  of  15 July  2021  authorising  certain  products  and 
substances  for  use  in  organic  production  and  establishing  their  lists  (OJ  L  253,  16.7.2021,  p. 13, 
ELI: http://data.europa.eu/eli/reg_impl/2021/1165/oj). 

3. Regulation (EC) No 396/2005 of the European Parliament and of the Council of 23 February 2005 on MRLs of 
pesticides in or on food and feed of plant and animal origin and amending Council Directive 91/414/EEC (OJ L 
70, 16.3.2005, p. 1, ELI: http://data.europa.eu/eli/reg/2005/396/oj). 

4. Regulation (EU) 2017/625 of the European Parliament and of the Council of 15 March 2017 on official controls 
and  other  official  activities  performed  to  ensure  the  application  of  food  and  feed  law,  rules  on  animal  health  
and  welfare,  plant  health  and  plant  protection  products  amending  Regulations  (EC)  No 999/2001,  (EC) 
No 396/2005, (EC) No 1069/2009, (EC) No 1107/2009, (EU) No 1151/2012, (EU) No 652/2014, (EU) 2016/429 
and (EU) 2016/2031 of the European Parliament and of the Council, Council Regulations (EC) No 1/2005 and 
(EC) No 1099/2009 and Council Directives 98/58/EC, 1999/74/EC, 2007/43/EC, 2008/119/EC and 2008/120/EC, 
and  repealing  Regulations  (EC)  No 854/2004  and  (EC)  No 882/2004  of  the  European  Parliament  and  of  the 
Council,  Council  Directives  89/608/EEC,  89/662/EEC,  90/425/EEC,  91/496/EEC,  96/23/EC,  96/93/EC  and 
97/78/EC  and  Council  Decision  92/438/EEC  (Official  Controls  Regulation)  (OJ  L  95,  7.4.2017,  p. 1,  ELI: 
http://data.europa.eu/eli/reg/2017/625/oj).   
5. The 2023 EU report on pesticide residues in food https://www.efsa.europa.eu/en/efsajournal/pub/9398. 

6.  Pursuant  to  Article 29(9)  of  the  Organic  Regulation  and  based  on  the  template  set  out  in  Commission 
Implementation Regulation (EU) 2023/1195 of 20 June 2023 laying down rules for the details and the format of 
the information to be made available by Member States on the results of official investigations concerning cases 
of contamination with products or substances not authorised for use in organic production (OJ L 158, 21.6.2023, 
p. 65, ELI: http://data.europa.eu/eli/reg_impl/2023/1195/oj). 

7.  ‘Findings of not  authorised substances  in  food  and  feed  certified  as  organic’,  EFSA  Supporting  publication 
2025: EN-9524: https://www.efsa.europa.eu/en/supporting/pub/en-9524. 

2 

 
 
 
 
 
 
 
information with a view to identifying potential sources of contamination, such as soil residues, 
irrigation water, spray drift from conventional farming, biocides and others. The study provides 
a  useful  scientific  background  for  understanding  the  possible  causes  and  sources  of  these 
substances when they are present in products labelled as organic. 

The EFSA study shows that pesticide residues are less likely in organic products than in the 
corresponding  conventional  goods;  the  likelihood  of  the  21  examined  substances  non-
authorised for use in organic production occurring in products labelled as organic ranged from 
0.04 to 3.95%, compared with 0.18 to 17.5% for non-organic goods. It also highlights the need 
to systematically open investigations on the possible active use of substances not authorised 
for  use  in  organic  production  and  recommends  that  additional  tests  be  conducted  (e.g.  soil, 
water or other analyses) depending on the detected substance. 

The  accompanying  Commission  staff  working  document  lists  the  overall  findings  from 
contamination reports on those 21 substances.  

II. 

OFFICIAL INVESTIGATIONS 

Article 29(1) of the Organic  Regulation sets  out  the measures to  be taken  if non-authorised 
products or substances for use in organic production are present in organic or in-conversion 
products. This provision requires that an official investigation be carried out immediately when 
a CA, or, where appropriate, a CtrlA or CB (i) has received substantiated information about 
the presence of products or substances that are not authorised for use in organic production; (ii) 
has  been  informed  by  an  operator  that  a  suspicion  has  been  substantiated  or  could  not  be 
eliminated; or (iii) itself detects non-authorised products or substances in an organic or an in-
conversion product. 

While  the  notion  of  substantiated  information  may  have  been  interpreted  differently  across 
Member States, the results of laboratory tests tend to be the starting point for launching official 
investigations.  

Technical issues on analytical results 

Interpreting laboratory test results on the presence of residues relies on a comprehensive set of 
legally binding rules set in Regulation (EC) No 396/2005 – to ensure the safety of feed and 
food products. The EU pesticide database8 serves as a reference information source along with 
the relevant technical guidelines available at EU level9. 

Multi-residue methods are available for analysing residues of most active substances used in 
pesticides according to the pesticide residue definition set in Regulation (EC) No 396/2005. 
Many  of  the  available  methods  have  a  LOQ10  as  low  as  0.001  mg/kg.  Furthermore,  in  the 

8. EU Pesticide database. 

9. https://webgate.ec.europa.eu/dyna2/pgd/. 

10. LOQ is a synonym of LOD for which a definition is set in the Article 3(2), point (f), of that Regulation as 
follows:  ‘(f)  ‘limit  of  determination’  (LOD)  means  the  validated  lowest  residue  concentration  which  can  be 
quantified and reported by routine monitoring with validated control methods;’. 

3 

 
 
 
 
 
 
absence  of  a  specific  MRL,  a  default  value  of  0.01  mg/kg  is  applied,  except  for  certain 
combinations of active substances and food products for which specific LOQs are set.  

It  is  essential  that  analytical  quality  control  and  method  validation  procedures  for  pesticide 
residues analysis in food and feed11 are followed by laboratories and that the laboratory test 
results on residues of pesticides are accompanied with the corresponding MU. 

For certain organic products that have been subject to processing, such as drying or distillation, 
a  PF  may  be  used  to  adjust  the  laboratory  residue  results.  PFs  are  specific  to  the  process, 
product and active substance concerned. Since October 2018, the EFSA has been publishing a 
comprehensive  list  of  PFs  with  indicative  values  for  many  pesticide/commodity/process 
combinations12. An information note on Article 20 of Regulation (EC) No 396/2005 as regards 
PFs, processed and composite food and feed is also available13. 

Launching official investigations 

Where  a  CA  or,  where  appropriate,  CtrlA  or  CB  concludes,  after  completing  the  relevant 
procedures,  that  substantiated  information  exists  about  the  presence  of  substances  non 
authorised  for  use  in  organic  production  in  an  organic  or  in-conversion  product,  it  must 
immediately carry out an official investigation with a view to determining the source and the 
cause of such presence. 

Even  for  substances  non  authorised  for  use  in  organic  production  that  can  occur  naturally, 
natural occurrence cannot be presupposed as the reason for their presence and an investigation 
is required with a view to ruling out the possibility of intentional active use. The same approach 
is applied to non-naturally occurring substances whose presence may be due to background 
contamination,  drift,  long-range  aerial  transport,  irrigation,  industrial  emissions  or  other 
reasons. Thus, environmental background contamination cannot be presupposed as the source 
and  an  official  investigation  is  therefore  required.  In  cases  where  previous  investigations 
concluded that repeated identical contaminations were unrelated to an intentional active use, 
and if the operator took the precautionary measures to avoid such contamination, additional 
investigations may not be needed for future occurrences. 

III: IMPLEMENTATION OF ARTICLE 29 OF THE ORGANIC REGULATION 

This Chapter is based on Member State responses to a questionnaire gathering information on 
the implementation of Article 29 of the Organic Regulation, as well as on elements of the EFSA 
study.  

Timing for triggering official investigations 

11 Analytical quality control and method validation procedures for pesticide residues analysis in Food and Feed -

SANTE 11312/2021 v2026 

12. European database of processing factors for pesticides residues in food. 

13. https://food.ec.europa.eu/document/download/071dce96-d916-4615-87fa-
148f1491bfc8_en?filename=pesticides_mrl_guidelines_proc_imp_sante-2021-10704.pdf. 

4 

 
 
 
 
 
 
Most Member States confirmed that official investigations are carried out immediately when 
substantiated  information  is  received,  with  intervals  ranging  from  ‘within  the  day’  
to ‘within seven days’ depending on the prevailing circumstances, such as the availability of 
staff, workload or completeness of available information. 

A few Member States indicated that they prioritise fresh products, products with a shorter shelf 
life and products that are already on the market when initiating an investigation. 

Identifying the source and the cause of the contamination 

Member States reported that the outcomes of investigations vary, but most estimated that more 
than half of all official investigations (ranging from 60% to 80%, depending on the substance 
concerned)  identify  the  source  and  the  cause  of  the  contamination. A  few  Member  States 
reported extreme rates well below or above those ranges. 

A few Member States reported that the cause and source of the contamination can usually be 
identified for domestic primary production, while the success rate diminishes further down the 
supply chain. They highlighted that for products originating in TCs, drift is often claimed to be 
the cause of the contamination. 

Duration of the official investigation 

The duration of official investigations varies significantly. More than half of the Member States 
responded that the average duration of an official investigation ranges from 20 to 30 days, while 
others  reported  an  average  duration  ranging  from  40  to  90  days.  Only  one  Member  State 
reported that investigations take on average between 2 and 5 days. Article 29(1), point (a), of 
the  Organic  Regulation  provides  that  the  time  needed  to  complete  the  investigation  should 
consider the durability of the product. 

The following factors were mentioned by Member States as reasons for requiring more time to 
complete official investigations: (i) the need for additional sampling; (ii) incomplete reports; 
(iii) the complexity of the supply chain (type and number of operators involved); (iv) the need 
for cooperation between different authorities; and (v) other reasons. 

Status of the products during an official investigation 

Member  States  responded  that,  in  accordance  with Article 29(1),  point  (b),  of  the  Organic 
Regulation, the products concerned are normally prohibited from being placed on the market 
as organic or in-conversion products pending the results of the investigation. A few Member 
States responded that it can be problematic to implement that provision for fresh organic or in-
conversion products with a short shelf life.  

A  few  Member  States  also  indicated  that  in  the  case  of  very  low  levels  of  substances  not 
authorised for use  in organic production well below the set MRL for pesticides, or in the case 
of  substances  that  could  be  naturally  occurring,  the  CA,  CtrlA  or  CB  might  consider  not 
provisionally  prohibiting  the  placing  of  the  products  concerned  on  the  market  as  organic 
products. These practices may require further investigation. 

Once the investigation is concluded 

5 

 
 
 
Member  States  have  put  in  place  various  systems  adapted  to  their  own  administrative  and 
control structures to inform other control bodies and CAs, as well as downstream operators, of 
their decision after the conclusion of the investigation. 

Opportunity for the operators concerned to comment 

All  Member  States  confirmed  that  operators  are  systematically  given  the  opportunity  to 
comment  on  the  results  of  official  investigations  and  are  informed  about  the  deadlines  to 
request a second expert opinion according to the rules set out in in Article 35 of Regulation 
(EU) 2017/625. 

Record keeping 

All  Member  States  responded  that,  in  accordance  with  Article 29(3)  of  Regulation  (EU) 
2018/848, their relevant CAs, or, where appropriate, CtrlAs or CBs keep records of the official 
investigations carried out. 

Corrective measures to avoid future contamination 

Member States indicated, based on annual checks of follow-up inspections, that in more than 
90% of the cases operators took corrective measures to avoid future contamination. When no 
corrective  actions  were  taken,  Member  States  indicated  that  in  the  case  of  critical  non-
compliances,  CtrlAs  or  CBs  suspend  or  withdraw  the  certificate  according  to  the  uniform 
arrangements set out in Annex I of Commission implementing Regulation (EU) 2021/27914. 

National rules under Article 29(5) and (7) 

Article 29(5) of the Organic Regulation allows Member States that, under Council Regulation 
(EC) No  834/200715  set  levels  for  substances  non  authorised  for  use  in  organic  production 
above which products cannot be marketed as organic, to continue to apply those rules as long 
as  they  do  not  impede  the  placing  on  the  market  of  products  from  other  Member  States 
produced in compliance with the Organic Regulation. 

Four  Member  States  (Belgium,  Italy,  Romania  and  Slovenia)  reported  having  kept  such 
national levels and confirmed that they do not apply them to organic or in-conversion products 
from other Member States. They also confirmed that investigations are systematically triggered 
in all cases. 

•  Belgium  (only Wallonia) informed applying a  threshold  set at  1.5 times the existing 
LOD of Regulation (EC) No 396/2005 to products produced or processed in Wallonia 
only  or  imported  from  TCs.  An  official  investigation  is  always  launched  when 
substances non-authorised for use in organic production are detected and downgrading 

14. Commission Implementing Regulation (EU) 2021/279 of 22 February 2021 laying down detailed rules for the 
implementation of Regulation (EU) 2018/848 of the European Parliament and of the Council on controls and 
other measures ensuring traceability and compliance in organic production and the labelling of organic products 
(OJ L 62, 23.2.2021, p. 6, ELI: http://data.europa.eu/eli/reg_impl/2021/279/oj). 

15. Council Regulation (EC) No 834/2007 of 28 June 2007 on organic production and labelling of organic products 
and 
ELI: 
http://data.europa.eu/eli/reg/2007/834/oj). 

(EEC)  No 2092/91 

Regulation 

20.7.2007, 

repealing 

p. 1, 

189, 

(OJ 

L 

6 

 
 
 
 
 
(i.e. no authorisation to market the product as organic) occurs when the findings are 
above the national threshold. 

• 

Italy informed applying a general threshold of 0.01 mg/kg for substances non authorised 
for use in organic production (except for phosphonic acid, for which a higher threshold 
is  temporarily  allowed).  Products  exceeding  that  threshold  cannot  be  marketed  as 
organic, regardless of whether the contamination was intentional. 

•  Romania  informed  applying  a  0.01  mg/kg  national  threshold  for  substances  non 
authorised for use in organic production. All positive detections are investigated. 

•  Slovenia  informed  using  the  LOQ  of  the  analytical  method  but  taking  MU  into 
consideration. An  official  investigation  is  triggered  when  this  national  threshold  is 
exceeded. Where the contamination was intentional, the certificate is withdrawn for all 
the products of the operator. Where the contamination was accidental or the presence 
of such substances was unintended, the operator must take appropriate preventive and 
precautionary measures to avoid repeated contamination in the future. 

Similarly, Article 29(7) of the Organic Regulation allows Member States to take appropriate 
measures on their territory to avoid the unintended presence of substances not authorised for 
use  in  organic  production  in  organic  or  in-conversion  products.  They  may  do  so  if  such 
measures  do  not  impede  the  placing  on  the  market  of  products  from  other  Member  States 
produced in compliance with the Organic Regulation and if they inform the Commission and 
the other Member States that they are making use of Article 29(7). The above-mentioned four 
Member  States  informed  the  Commission  that  they  take  such  measures  on  their  respective 
territories. 

IV  SUMMARY  OF  THE  RESULTS  OF  OFFICIAL  INVESTIGATIONS AND  BEST 
PRACTICES 

Official contamination reports 

In accordance with Article 29(9) of the Organic Regulation, Member States must report to the 
Commission by 31 March each year the results of official investigations  into cases detected 
during the previous year of contamination with products or substances not authorised for use 
in organic production. 

27 MS responded for 2022 and 2023 and 25 for 2024. The Commission focused its analysis of 
those contamination reports on the same 21 substances examined in the EFSA study mentioned 
in  Section I. The Commission  staff working  document accompanying this report  contains  a 
summary table, as well as individual tables for each of those 21 substances, indicating: (i) the 
categories  of  product  in  which  the  product  or  substance  non  authorised  for  use  in  organic 
production was most commonly detected; (ii) the relevant stage in the supply chain; (iii) the 
identified source and cause of the contamination; and (iv) the measures taken in relation to the 
marketing of the investigated products. 

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In  relation  to  the  stage  of  the  supply  chain  at  which  the  substances  were  detected,  the 
consolidated  average  results  are  as  follows:  66.2%  of  the  substances  were  detected  at 
production, 
storage,  
5.9% at distribution, 3.3% at import, 2.5% at the placement on the market (e.g. retail) and 0.1% 
at export16. 

preparation, 

10.2% 

9.5% 

at 

at 

As  regards  the  causes  of  contamination,  spray  drift  was  established  as  the  main  cause, 
accounting on average for 24.1% of the cases. In 16.7% of the cases, the operator did not take 
the precautionary measures referred to in Article 28(1) of the Organic Regulation, in 15.9% the 
operator used products or substances not authorised in organic production, while in 10.6% the 
contamination had occurred at the previous stage of the supply chain. In 1.6% of the cases, 
commingling of organic or in-conversion products with non-organic products was established 
as the  cause and in 0.6% it was lack of traceability. Finally, other sources and causes  were 
established in 14.8% of the cases and in 14.9% the source and cause of the contamination could 
not be identified. 

Despite considerable differences across the substances, it is worth highlighting some common 
patterns  in  relation  to  the  source  and  cause  of  contamination.  In  nearly  all  cases  where 
investigations  concluded  that  the  contamination  was  due  either  to  the  active  use  of  the 
substance by the operator or to the lack of precautionary measures, the product was not allowed 
to be marketed as organic, as provided for in Article 29(2) of the Organic Regulation. In the 
other cases, the situation was more varied. 

Best practices 

In  accordance  with Article 29(6)  of  the  Organic  Regulation,  most  Member  States  provided 
feedback on best practices. A key best practice remains highlighting to operators the importance 
of strict compliance with precautionary measures, including: (i) separating organic and non-
organic products, at both the production and processing stages; (ii) using adequate buffer zones 
and intercropping; and (iii) being careful to prevent contamination by cleaning equipment and 
separating organic, in-conversion and non-organic products. An appropriate risk assessment, 
based  on  the  characteristics  of  the  products  and  the  production  methods  as  well  as  on 
information on the previous performance of operators, is also needed to identify best sampling 
operations (number of products, number of operators, stage of production, etc.). 

Member  States  highlighted  the  importance  of  making  it  easier  to  implement  precautionary 
measures and quality controls (performed by the operators themselves), as well as the role of 
action plans in correcting and preventing recurrent cases of non-compliance. 

Some  Member  States  stressed  the  need  to  assist  operators  by  developing  informative 
documents  and  providing  continuous  training  for  the  stakeholders  along  the  supply  chain, 
including training CBs. This can involve research projects and surveys to promote harmonised 
approaches among CAs and, where appropriate, CtrlAs and CBs. 

Member States also use surveys to identify differences in approaches by control bodies, which 
can lead to suggestions for improvement. Overall, simplifying communication at all levels is 

16 Page 49 of the accompanying Commission staff working document. 

8 

 
 
 
highlighted as an important practice to ensure that issues within the organic control system are 
quickly detected, dealt with and learnt from. 

V 

CONCLUSIONS 

Organic and in-conversion products undergo a comprehensive set of checks and certification 
procedures  to  verify  their  compliance  with  the  Organic  Regulation  and  the  corresponding 
secondary legislation. The organic control system has proven its reliability and is one of the 
cornerstones  of  the  success  of  the  organic  sector  in  the  EU  where  citizens  expect  organic 
products not to carry traces of substances non authorised for use in organic production. 

The Organic Regulation lays down rules for handling cases where substantiated information 
(typically the result of laboratory tests) indicates the presence of substances not authorised for 
use in organic production. In such cases, an official investigation must be opened immediately 
to  identify  the  source  and  cause  of  the  presence  of  the  substance  non  authorised  for  use  in 
organic production with the view to ensure the integrity of the products. National CAs or, where 
appropriate, CtrlAs  and CBs operate the system in conformity with a harmonised methodology 
set down in Article 2 of Commission Implementing Regulation (EU) 2021/279. 

The  EFSA  study  reported  a  large  variety  of  possible  sources  and  causes  of  the  presence  of 
substances  non  authorised  for  use  in  organic  production  in  relation  to  the  21  pesticide 
substances analysed, but also stressed that, without a proper investigation, it is not possible to 
rule out intentional use or a lack of the necessary preventive measures. The study also showed 
that the occurrence of residues is far less likely in organic than in the respective conventional 
products.  These  findings  confirm  the  high  level  of  assurance  provided  by  the  EU  organic 
control system, the need to maintain strict control and sampling protocols and the pertinence 
of systematic official investigations. 

This  report  acknowledges  that  CAs  and,  where  appropriate,  CtrlAs  and  CBs,  face  some 
operational  challenges  when  determining  the  source  and  cause  of  contamination,  especially 
when it takes place at a downstream stage of the supply chain where the number of inconclusive 
investigations remains a matter of concern. It also confirms that the rules on systematic official 
investigations in case of substantiated non-compliances are necessary to ensure the integrity of 
the organic products.  

Some  operators  have  criticised  the  time  required  to  start  and  conclude  investigations,  the 
complexity  of  these  procedures,  the  diverging  approaches  across  national  CAs,  CtrlAs  and 
CBs, the additional costs, as well as possible impacts on supply chains.  

The  Commission  is  ready  to  foster  a  more  harmonised  implementation  of  Article 29  by 
engaging  actively  with  CAs  and,  where  appropriate,  CtrlAs  and  CBs  through  dedicated 
workshops  to  exchange  experiences  and  best  practices  with  the  view  to  reduce  burdens  for 
operators in the organic supply chain.  

At the same time, this report provides evidence that official investigations are, overall, initiated 
rapidly and often concluded within a reasonable time span. Similarly, measures to avoid the 
undue  marketing  as  organic  of  products  under  investigation  appear  to  work  satisfactorily, 
although challenges remain with fresh products with a short shelf life.  

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In conclusion, the Commission is of the view that the current system is working reasonably 
well, with no adjustment being needed at this early stage of implementation. Building on the 
various  actors’  learning  curve,  the  Commission  expects  to  see  further  improvements  in  the 
operation of the system and stands ready to underpin this process by fostering further dialogue 
and exchange of experiences among all the stakeholders. 

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