In December 2025 the European Commission proposed a targeted revision of the organic regulation, intended to support the competitiveness of the sector by reducing the regulatory burden and avoiding trade disruption.
- We welcome the update to the eligibility criteria for groups of operators and the removal of new obligations concerning products used for cleaning and disinfection in processing and storage facilities.
- The Commission’s proposed solution to the Herbaria case adds undue complexity, lacks practical feasibility and may give rise to interpretation challenges. Moreover, it runs counter to its declared aim of preventing trade disruption by exposing EU exports to retaliatory measures and market closures. Thus, we suggest amending the EU Organic Regulation to:
– Expressly clarify that products imported in accordance with the equivalence regime may bear the EU organic logo. Alternatively, introduce a derogation to allow the use of the EU logo on products imported under the already established equivalences, until their expiration.
– Clarify the use of national and private logos.
- A provision should also be introduced into the EU Organic Regulation to ensure the active involvement of EU stakeholders in the (re)negotiation of equivalence agreements