Implementation of EU Organic Regulations for organic exports

On 14th January the EU published Commission Implementing Regulation (EU) 2020/25, amending and correcting detailed rules for Council regulation (EC) No. 834/2007. This has very important implications for exports of organic produce to the European Union (EU), and action needs to be taken immediately.

The rule requires that the Certificate of Origin (COI) for organic goods must be issued prior to the shipping of the goods from the country of origin. Any COI issued after the date of the Bill of Lading (B/L) will mean that the consignment is downgraded and classified as conventional goods, and treated as such at customs. This rule will be applied from 2nd February 2020. 

This is not a new rule; instead it is the strengthening of an existing rule that DG Agri considered as not being applied sufficiently rigorously. Since it is not new legislation, according to internal European Commission (EC) procedures, it was voted through by EU Member States (in October 2019) without any stakeholder consultation.  The first information was received by the sector (via Freshfel) shortly before Christmas.

In December Freshfel raised concerns with the EC about this ruling, explaining that it will have a major impact on the export of perishable goods. Unfortunately the Regulation has been published, and there is now no option but to take action to ensure that all operators comply with the new conditions, and adapt to the trading procedures, by 2nd February. 

COLEACP will join with Freshfel and others to engage with the EC, in particular to try and obtain a 5-6 days grace period for the issuance of the COI after the vessel has left the harbour. To support our lobbying activities, COLEACP needs evidence, and we ask members to please send us details about any impact this ruling has on your future export trade.

In the meantime, it is critically important for this message to be shared with all stakeholders who need to take action.  COLEACP would appreciate your help in distributing this information to all those in your country involved in the export of organic fresh produce to the EU.

If you require further information, or can provide us with evidence of impact, please contact COLEACP at