Recent production and market trends show the importance that organics has gained over the last decade. Organic farming responds to a specific consumer demand for sustainable food products, promoting more sustainable farming practices, contributing to the protection of the environment, and improving animal welfare (see EU Agricultural Markets Briefs No 13 March 2019).

Accordingly, European Union organic farming rules – laid down in Regulation (EU) 2018/848 – cover agricultural products, including aquaculture, and yeast. They encompass every stage of the production process, from seeds to the final processed food. This means that there are specific provisions covering a large variety of products, such as:

  • seeds and propagating material such as cuttings, rhizome etc. from which plants or crops are grown;
  • live or unprocessed agricultural products;
  • feed;
  • processed agricultural products for use as food.

In order to ensure that organic production complies with the EU rules, Regulation (EU) 2018/848 includes specific provisions for the certification of organic production and the accreditation of the Certification Bodies (control bodies) by a National Accreditation Body (NAB) in accordance with Regulation (EC) No 765/2008 on accreditation.

On the basis of Regulation (EU) 2018/848, the European Commission adopted in 2020/2021 further detailed secondary acts. These secondary acts covering inter alia the following issues:

  • Details of organic production rules;
  • Rules concerning group of operators ;
  • Harmonised method of inspection (traceability, mass balance);
  • Rules for certifying in third countries (outside EU), under the compliance system;
  • Rules for importing products in the EU;
  • In third countries, transition from the current equivalency recognition to compliance recognition.

For the implementation of Regulation (EU) 2018/848 in regard to the accreditation of control bodies, EA published the document EA-3/12 EA Policy for the Accreditation of Organic Production Certification. Due to the secondary acts, EA-3/12 has been revised in 2022.

The revised EA-3/12 considers the modification made in Regulation (EU) 2018/848, especially about accreditation cycle or duration in regard with risk analysis performed for organic certification, in order to update the accreditation process for certification of organic production. During the revision process, EA considered the feedback of all interested parties in order to find innovative solutions, such as the number of witnesses based on risk analysis, a tool to calculate the duration of accreditation assessments, and rules to assess locations wherever the activity is relevant and risky.

Further to the discussions with the European Commission, EA also harmonised the transition period of accreditation as follows:

  • Transition on national level
    Before 1st January 2021, each NAB contacted its National Competent Authority to define the assessments of accreditation performed before updating accreditation certificate, and the date to refuse application for the Regulation (EC) No 834/2007. Each NAB asks the accredited bodies to transmit evidence of updated competencies and procedures in regards with the requirements of national authorities. This evidence was assessed before granting accreditation for the new regulation.
    Between 1st January 2022 and 1st January 2023, certificates against Regulation (EC) No 834/2007 are still valid until the next control performed against Regulation (EU) 2018/848. Nevertheless, all controls in EU shall be performed against Regulation (EU) 2018/848 starting from 1st January 2022. For this reason, the accreditation for Regulation (EC) No 834/2007 is still valid for certificates issued before 1st January 2021, and will expire on 31st December 2022.
  • New system of compliance for product imported in EU
    Since 1st January 2022, Certification Bodies can apply accreditation for compliance system before asking recognition to the European Commission. Special procedure is detailed by the Regulation (EU) 2021/1698 and explained in §4 of EA-3/12, because the technical dossier of recognition shall contain accreditation reports elaborated by Accreditation Bodies, signatories of the IAF MLA.
  • Transition between Equivalency and Compliance systems
    If a Certification Body accredited and recognized for organic production in third countries for equivalency system applies accreditation for compliance system, the technical dossier of recognition application can consider witnesses carried out by Accreditation Bodies under Regulation (EC) No 834/2007 under equivalency system. The conditions are listed in § 4.8 of EA-3/12 document.
  • Expiration of equivalency recognition
    Any accreditation granted for the current equivalency approach shall be upheld until the end of the legal transition period of the new regulation, the 31st December 2023. At this date, the accreditation for equivalency purpose would be withdrawn.

To conclude, EA has been supporting the evolution of European organic regulations through updating the document EA-3/12, which gives EA National Accreditation Bodies tools for adapting every time’s accreditation assessments to the context, the activity of Certification Bodies, and the risk of fraud detected by the competent authorities. EA is still in touch with the European Commission and European Organic Certifiers Council (EOCC) to adapt the control system according to Regulation (EU) 2018/848.

The new version of EA-3/12 EA Policy for Accreditation of Organic Production Certification can be downloaded here.

Final note:
Special thanks to the EA TFG on Organic Production, chaired by Sandrine Dupin (COFRAC), which is in charge of EA-3/12.