Regulation (EU) 2018/848 on organic production and labellin

Can we actually label our food products as 'organic' in the EU, and what happens if our certification lapses or our supply chain is non-compliant?

Any operator placing organic products on the EU market must hold a valid certificate issued under Regulation (EU) 2018/848 — without it, the organic claim must be removed immediately, and Member States impose penalties under national law that can include withdrawal of the certificate and a ban on marketing [Art. 35, Art. 42].

Short Answer

Regulation (EU) 2018/848 replaced the former Regulation (EC) No 834/2007 and has been fully applicable since 1 January 2022. It governs the entire organic supply chain — from farm-level conversion periods and input restrictions through processing, labelling and import controls [Art. 1, Art. 2]. The Regulation mandates that at least 95 % of agricultural ingredients by weight must be organic before a processed food product may carry the term 'organic' in its sales description [Art. 30(2)(a)]. Every operator must notify the competent authority, submit to annual verification by an accredited control body, and maintain full traceability records; non-compliance triggers measures up to certificate suspension and product withdrawal [Art. 34, Art. 38, Art. 42].

Who is affected

All natural or legal persons producing, preparing, distributing, importing or exporting products referred to as organic within the EU, including farmers, food processors, feed manufacturers, retailers (unless only selling prepacked organic products directly to final consumers), and importers from third countries [Art. 2(2), Art. 34(2)]. Small direct-to-consumer sellers of unpacked organic products may be exempt if annual turnover is below EUR 20,000 or below 5,000 kg/year [Art. 34(2)].

Deadline

The Regulation is fully applicable since 1 January 2022; all operators must hold a valid organic certificate at all times to market products as organic — this is a continuous, permanent obligation [Art. 35]. Conversion periods for new organic operators run 2 years for annual crops, 3 years for perennial crops [Annex II, Part I, 1.7.1].

Risk

Non-compliance can result in suspension or withdrawal of the organic certificate, prohibition of marketing products as organic, and mandatory removal of organic references from labelling [Art. 42(1)]. Specific penalty amounts are set by Member State national law pursuant to Regulation (EU) 2017/625 on official controls. Fraudulent use of the EU organic logo constitutes a violation of EU food-labelling law and may trigger additional administrative fines and criminal sanctions depending on national transposition.

Proof

Legal status

• In force
• as of 2026-04-17
• Consolidated version of 25.03.2025 (incorporating amendments up to Commission Delegated Regulation (EU) 2025/452)

Primary sources

• EUR-Lex — Full text
• European Commission — Organic farming — EU organic policy

What to do now

Legal / DPO

•Verify that every entity in the supply chain — including co-manufacturers and import agents — holds a valid organic certificate issued under Article 35; any gap in certification breaks the chain and disqualifies the product from organic labelling [Art. 35(1)].
•Review all labelling and advertising materials against Article 30 requirements: the term 'organic' in the sales description is only permitted when at least 95 % of agricultural ingredients by weight are organic [Art. 30(2)(a)].
•Ensure that contracts with third-country suppliers require compliance with Article 45 import rules and that each consignment carries a valid certificate of inspection issued by a Commission-recognised control body [Art. 45(1)].

Compliance

•Establish and maintain a documented traceability system covering all stages from receipt of raw materials through dispatch, enabling identification of organic, in-conversion and non-organic product flows at any time [Art. 39(1)(d)].
•Prepare for the annual verification by the designated control authority or control body: ensure all records (purchase invoices, supplier certificates, production logs, sales records) are complete and accessible [Art. 38(3)].
•Implement precautionary measures to prevent commingling of organic with non-organic products during storage, transport and processing; document cleaning procedures between production runs [Art. 9(6), Art. 28(1)].

IT / Security

•Integrate the TRACES NT electronic certificate system for import controls so that certificates of inspection under Article 45 can be verified automatically at the point of goods receipt [Art. 45(1)].
•Implement access controls and audit trails on the traceability database to ensure that organic status records cannot be altered without authorisation — control bodies may request full digital records during inspections [Art. 39(1)(d)].
•Set up automated alerts for certificate expiry dates: each operator's organic certificate has a defined validity period, and any lapse means the operator must immediately cease marketing products as organic [Art. 35(1)].

Product / Engineering

•Design product packaging so that the EU organic logo, the control body code number and the origin indication ('EU Agriculture', 'non-EU Agriculture' or 'EU/non-EU Agriculture') appear in the same visual field on all prepacked organic products [Art. 32(1), Art. 32(2)].
•Source only plant reproductive material that is certified organic or, where unavailable, in-conversion material with at least 12 months' conversion completed; non-organic seed derogations require documented proof of unavailability [Art. 10(4), Annex II Part I 1.8.5].
•Reformulate recipes if the organic ingredient share falls below 95 % by weight: either increase organic sourcing or remove the term 'organic' from the sales description and restrict it to the ingredients list only [Art. 30(2), Art. 30(5)].

Key Terms

Organic production: The use of production methods complying with Regulation (EU) 2018/848 at all stages of production, preparation and distribution, including the conversion period [Art. 3(1)].
Conversion period: The transition from non-organic to organic production during which all organic rules must be applied but products cannot yet be marketed as organic — minimum 2 years for crops, 3 years for perennials [Art. 3(6), Art. 10].
Control body: A delegated body accredited under ISO/IEC 17065 that carries out inspections and certifications of organic operators on behalf of the competent authority [Art. 3(56)].
EU organic logo: The leaf-shaped logo defined in Annex V that must appear on all prepacked organic food produced in the EU, accompanied by the control body code and origin indication [Art. 33, Annex V].
In-conversion product: A product produced during the conversion period; it may only be marketed as 'in-conversion' for plant-origin single-ingredient food after at least 12 months of conversion [Art. 3(7), Art. 10(4)].
Internal Control System (ICS): A documented control system established by a group of operators that carries out annual on-the-spot inspections of every member, manages non-compliance and ensures traceability within the group [Art. 36(1)(e)].
Precautionary measures: Steps taken by operators at every stage of production, preparation and distribution to avoid contamination with unauthorised products or substances and to prevent commingling of organic with non-organic products [Art. 3(5)].

Frequently Asked Questions

How long is the conversion period before a farm can sell products as organic?

For annual crops, the conversion period is at least 2 years before sowing. For perennial crops other than forage, it is at least 3 years before the first organic harvest. During this period, all organic production rules must already be followed [Art. 10(1), Annex II Part I 1.7.1].

Can a product with less than 95 % organic ingredients still use the word 'organic'?

Yes, but only in the ingredients list — never in the sales description. The term may appear next to individual organic ingredients in the list of ingredients, and the total percentage of organic ingredients by weight must be stated [Art. 30(5)].

Is the EU organic logo mandatory on all organic products?

The EU organic logo is mandatory on all prepacked organic food products produced in the EU. For imported organic products and for non-prepacked organic food, its use is voluntary. When it appears, the control body code number and the origin of agricultural raw materials must be displayed in the same visual field [Art. 32(1), Art. 32(2)].

What are the rules for importing organic products from outside the EU?

Products from third countries may be marketed as organic if all operators in the third country have been certified by a control authority or control body recognised by the Commission, and each consignment is accompanied by a certificate of inspection. Alternatively, products may come from third countries with which the EU has concluded trade agreements recognising equivalent organic standards [Art. 45(1), Art. 47].

Are GMOs permitted in organic production?

No. The use of GMOs, products produced from GMOs and products produced by GMOs is strictly prohibited in organic production, including in food, feed, processing aids, fertilisers and plant reproductive material [Art. 11(1)].

What is the 'group of operators' certification model?

Small farmers (holdings up to 5 hectares, or 0.5 hectares for greenhouses, or 15 hectares for permanent grassland) may be certified collectively through a group of operators. The group must establish an Internal Control System (ICS) with annual on-the-spot inspections of each member. The group is then subject to official controls as a single entity [Art. 36].

What happens if an operator is found non-compliant?

The control authority or control body must take measures proportionate to the infringement: these range from requiring corrective action, through prohibiting the marketing of affected products as organic, to suspending or withdrawing the organic certificate entirely. For serious or repeated infringements, the operator may be banned from marketing any products as organic for a defined period [Art. 42(1)].

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