Organic peppers, tomatoes and dried fruits grown in Europe are found in numerous supermarkets. UK is tightening requirements for organic agricultural products and foodstuffs. On behalf of the Ministry of Foreign Affairs of Netherlands the following tips for exporters are shared.
You should send inspection certificate
A COI is the abbreviation for a Certificate of Inspection. An inspection certificate allows the UK Government to check that the organic goods shipped to the UK meet UK requirements. From 1 July 2022, a COI from the UK must be sent with the organic shipment to the UK.
In addition to biological requirements, other certification requirements may also apply. Therefore, always check which export certificates you need for your product in the Access2Markets database and the UK communication. Also see the information about phytosanitary certificates and veterinary certificates.
In 2022, the UK Government will tighten the certification requirement for most phytosanitary and veterinary products, whether organic or not. Depending on the products you sell, the new requirements will start between 1 July and 1 November 2022. With a pre-notification (or a pre-notification) you indicate what you are going to export. It has to be digital. This is mandatory from 1 January 2022.
The pre-proposal will apply to any agri-food entrepreneur exporting to the UK, whether you are exporting organic or non-organic products. You need a UK partner or importer to arrange the pre-registration. Or a private branch in the UK. It does not hurt to check that your importer in the UK has the administration in order. For example, it will have to be registered as an importer.
Peter Verbaas, Brexit coordinator of the NVWA, explains what can happen if you, as an agrofood exporter, have not properly arranged the pre-proposal on 1 January 2022: “I cannot speak for the British government, but I expect you will not be allowed to leave the terminal at customs. It is the same in the Netherlands. Then you also get a bill per day you stand there.”
Is your product still ‘organic ‘ in the UK?
The EU organic regulation sets out the rules for growing and processing organic products. If you comply with those rules, your product may be sold as organic. Think of rules such as very limited use of plant protection products, requirements on the barn size, or the treatments to animals. A new version of the organic regulation will take effect on 1 January 2022.
“Organic entrepreneurs must comply with the same requirements as any other agro-entrepreneur,” explains Marian Blom, project leader at Team knowledge and innovation of branch organisation Bionext. “Plus the production rules from the organic regulation.”
On 1 January a new version of the organic regulation will enter into force: number 2018/848. If you don’t comply with the rules, you can’t trade your products as ‘organic’ anywhere.
But the UK is no longer an EU. Why do you have to look into the new EU regulation if you want to export there? This is the result of the Brexit agreement between the EU and the UK, Marian Blom explains: “the British government said: we declare the EU’s biological rules equivalent to ours. The recognition covers products that have been grown, grown or significantly processed in the EU. This way you don’t have to comply with other production rules if you also export organic products to the UK.”
What if your organic product is produced outside the EU?
Products covered by the EU-UK Convention: organic products produced in the EU and processed agricultural products for use as food or feed. Thus, products in the EU have been processed with ingredients grown in the EU, or imported into the EU in accordance with the laws and regulations.
Exporters of, for example, organic citrus fruits, teas, herbs and spices imported from countries outside the EU face a very specific problem, says Marian Blom.
“Because the products are usually little processed in the EU, they do not meet the requirements for organic products according to the agreement.”
They cannot then be exported on a COI from the EU to the UK. The same applies to organic goods that are not cleared in the EU. COI may not be issued for these goods either. Shipments coming from a third country directly to the UK, or via transit (i.e. not customs cleared and processed) must meet UK import requirements. Marian Blom: “some organic entrepreneurs already run into this when customs posts occasionally ask for COI.”
Northern Ireland is an exception. Trade in organic products between the EU and Northern Ireland remains the same as before Brexit.
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