EU Commission’s proposal to revise the organic regulation undermines the principle of equivalence

On 16 December 2025, the European Commission published a proposal to amend the Organic Regulation (EU) 2018/848, which largely addresses some key requests of the organic sector, including the much awaited urgent revisions of the group certification eligibility requirements.

The Commission's proposal contains many positive elements, but IFOAM-Organics International is deeply concerned about the changes proposed by the Commission regarding the use of the EU organic logo on products imported from third countries that have organic equivalence with the EU. The proposed changes originate from concerns of "unfair competition" raised through the now-famous Herbaria Court Case, and the ruling of the European Court of Justice that followed.

The Commission, in its paper, acknowledges that equivalence means that different systems are found to meet the same objectives and principles despite detailed differences in standards. Despite this, it proposes to depart from that same principle, by restricting the use of the EU organic logo on products imported from countries with organic equivalence.

Specifically, it proposes to ban the use of the EU organic logo for organic products imported from countries with organic equivalence unless they meet additional production and control requirements specified by the Commission. The specifics will be elaborated in a future Annex to the regulation. The Commission also propose to extend this ban to products manufactured within the EU when they contain more than 5% of ingredients sourced from third countries with organic equivalence that do not meet the additional requirements from the same Annex.

Up to now, the EU regulation made the use of the EU organic logo obligatory for all organic prepackaged food produced within the EU. IFOAM-Organics International has long been a supporter of this "full logo presence" approach, which has proven to be a major instrument in building strong consumer recognition for organic products on a given market. Now the Commission proposes to depart from this "full logo presence" approach and start using restrictions on the use of the logo (for products otherwise considered as organic) as a way to address protectionist concerns of "unfair competition" and effectively introduce a tiered system for organic claims on the EU market. This may favour a few isolated EU organic companies over non-EU ones, but at the expense of sector tools that have historically supported the growth of the organic market and the global organic sector, namely the reduction of technical barriers to organic trade and a strong consumer recognition around the common logo.

The organic movement, led by IFOAM-Organics International, had gone to great lengths in its technical and political efforts to promote equivalence in organic trade. We believe that the main objective should be to promote overall organic market growth, not the use organic standards as protectionist instruments that will penalise the organic sector at the expense of the conventional one.

As a matter of principles, we regret that the Commission is going down a path that will inevitably erode the principle of equivalence and depart from the established practice of logo reciprocity in equivalence agreements. We are concerned that this path may lead to retaliatory measures from major trade partners and a potential escalation in the number of additional production and control requirements added on top of existing equivalence agreements. While significantly complicating trade under organic equivalence, it would also threaten the very principle and value of organic equivalence agreements.