Importing & Exporting Organic Products Between the U.S. and the EU - Oregon Tilth

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Importing & Exporting Organic Products Between the U.S. and the EU

October 2, 2024

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What To Know About European Union Organic Certification Import and Export Requirements

Oregon Tilth offers organic certification and export support for operations seeking to meet European Union (EU) organic standards. This includes direct EU certification for operations in Mexico and equivalency-based export support for U.S.-based operations certified to the USDA National Organic Program (NOP).

Summary

  • U.S. operations certified to the USDA NOP by Oregon Tilth can export to the EU under the U.S.–EU Organic Equivalency Arrangement. No separate EU certification is required.
  • Operators in Mexico must apply for full EU certification, as Mexico does not have an equivalency arrangement with the EU.
  • All exports to the EU must include a Certificate of Inspection (COI) issued through the EU’s TRACES system.
  • Certain products (e.g., pet food, personal care items) are not covered by the equivalency and may need additional approvals.
  • Importing EU-certified products into the U.S. also requires a U.S. import certificate and must meet USDA-specific restrictions.

Certification to the EU Organic Standard

Oregon Tilth certifies crop and handling operations to the European Union organic standard, either through:

1. Equivalency for U.S.-based Operators

Operators certified to the USDA NOP and located in the U.S. can export organic products to the EU under the US–EU Organic Equivalency Arrangement. No additional EU certification is needed.

2. Full EU Certification for Mexico-Based Operators

Operators certified by Oregon Tilth and located in Mexico are not covered by the equivalency arrangement and must apply for certification to EU Regulation (EU) 2018/848, which governs organic production and labeling.

To apply for EU certification in Mexico:

  • Review the current EU regulations.
  • Submit an application to Oregon Tilth.
  • Undergo inspection and audit.
  • Upon approval, you’ll receive an EU organic certificate.

Required Documents:

  • Crop-EU Supplement
  • Handling EU Supplement
  • OTCO EU Certification Manual
    Submit to: export@tilth.org

Exporting Organic Products from the U.S. to the EU

If you are USDA NOP certified by Oregon Tilth and located in the U.S., you may export organic products under the equivalency arrangement. However, the following conditions apply:

  • Products must be produced, handled, and shipped from the U.S.
  • Product labeling must follow EU rules.
  • Each shipment must include a Certificate of Inspection (COI), created via the EU TRACES system.

Products not covered by the equivalency (require different labeling or certification):

  • Personal care items (e.g., lotion, shampoo)
  • Pet food

These products may be sold in the EU as USDA Organic but cannot use the EU Organic logo.

Importing EU Organic Products into the U.S.

Products certified to EU organic standards can be imported into the U.S. under the equivalency agreement, but must meet USDA-specific conditions:

Restrictions:

  • No animal-derived products from animals treated with antibiotics
  • No aquatic animals (e.g., fish, shellfish)
  • Product labels must include the name of the certifying agent
  • Products must follow the labeling rules of the destination country
  • A USDA import certificate is required for all shipments

Import Certificate Forms:

  • NOP Import Certificate Request Instructions
  • NOP Import Certificate Request Form (English & Spanish)
    Send all documentation to: export@tilth.org

Exporting to the EU from Countries Other than the U.S.

If your products are made or shipped from outside the U.S., even if your business is U.S.-based, you may need direct EU organic certification. Contact export@tilth.org to determine your eligibility and certification pathway.

TRACES and the EU Certificate of Inspection (COI)

The Trade Control and Expert System (TRACES) is the EU’s electronic system for managing organic product imports. Since October 19, 2017, all shipments must include a Certificate of Inspection (COI) issued via TRACES.

What is a Certificate of Inspection (COI)?

A Certificate of Inspection (COI) is the official document required by the European Union to validate the import of certified organic products. An approved COI confirms that:

  • The products are certified organic by an accredited certifier (such as OTCO).
  • All required supporting documentation has been reviewed and approved.
  • The shipment complies with EU organic import regulations.

The EU requires a COI for every organic product entering its member states, as well as for imports into related countries such as:

  • Andorra
  • Faroe Islands
  • Iceland
  • Liechtenstein
  • Monaco
  • Norway
  • San Marino
  • Switzerland
  • Sweden

What is TRACES?

TRACES (Trade Control and Expert System) is the European Commission’s multilingual online platform for managing import requirements. For organic products, TRACES is the centralized system used by:

  • Operators (importers/exporters)
  • Certifiers (such as OTCO)
  • EU authorities

TRACES ensures that all organic imports are properly documented, authorized, and traceable.

Who Can Request a COI?

Only importers and exporters registered in TRACES can request a Certificate of Inspection.

How to Get Started in TRACES

  • Register in EU Login (the access gateway for TRACES).
  • Request a TRACES access profile as an organic operator.
  • Register as both an organic producer and exporter to appear in the required selection fields.
  • Notify OTCO at export@tilth.org once your account is set up.
  • OTCO will approve your account and guide you through the COI request process.

Step-by-step registration instructions are available on the TRACES NT website.

Receiving Your COI:

Send an email to export@tilth.org with the COI number in the subject line. Include:

  • Destination address
  • FedEx/UPS/DHL account number (and zip code if using UPS)
  • Any supporting documents not already uploaded

Oregon Tilth will confirm receipt and provide a tracking number when the hard copy COI is shipped. Until the EU activates digital signatures in TRACES, a paper COI remains required for customs clearance.

Tips for Completing a COI Successfully

To avoid delays, ensure the following:

  • Certified products: All products must be certified organic by OTCO and listed as EU-approved. Labels must also meet EU requirements.
  • Exact product listing: List products exactly as they appear on your Organic Certificate of Operation.
  • Box 24 (First Consignee): This must be completed unless the “To be released in batches (base for extract)” option is checked.
  • Box 13 (Lot numbers): Each unique lot number must be listed on a separate line, even if it’s the same product. Include quantities and net weights for each lot.
  • Supporting records: Provide clear, linked records that match the COI. Upload directly in TRACES or email to export@tilth.org. Required records include:
    • Commercial invoice and/or packing list (must identify products as organic and include importer, consignee, shipment date, products, lot numbers, quantities, and net weights).
    • Booking confirmation or draft AWB/SWB (to confirm shipment date and that the consignment has not left the country of origin).
  • Transport documents: Once available, provide final international bill of lading or air/sea waybill to OTCO.

Why a COI Matters

  • Compliance: Required for all organic shipments to the EU and affiliated countries.
  • Traceability: Ensures product integrity and chain of custody from producer to EU importer.
  • Market access: Without an approved COI, organic products cannot clear EU customs.

Remember:

  • TRACES registration is required for both importers and exporters.
  • Supporting documents: invoice, packing list, and either a Bill of Lading (BOL) or Airway Bill (AWB) depending on the shipping method.
  • Product names must exactly match the organic certificate (e.g., “frozen strawberries” vs. “strawberries”).

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Contact Information

Oregon Tilth Main Office
PO Box 368
Corvallis, OR 97339
Phone: (503) 378-0690
Toll Free: (877) 378-0690
Email: organic@tilth.org

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