Importing organic food from outside the EU into the EU is complicated. It took me almost a year to learn how it worked. Here is everything you need to know to safely manage your organic imports.
1. Getting the Basics Right
To import organic food, you need a license to import food.
To get one, you need to obtain:
- A company/VAT number
- An EORI number (for import/export)
- An authorization/license from your national food agency
Once you have all three, you can request an organic certification.
2. Getting Your Organic Certification
Find a company accredited to deliver organic certifications and apply for an organic certification.
If you are lucky, they will send you documentation about what you need to do to get your certification. If not, you can research it online.
First, you will need to create an application explaining the type of activities you will be undertaking. Will you be an importer/exporter? Will you stock? Will you open the bags to repack them in smaller units? Will you be blending the food or processing it?
Certification for import/export activities where you do not open anything is the easiest to obtain.
Once you have completed your file, the accreditor will organize a visit during which one of their auditors will come to check that your documentation and facility are compliant.
The number one risk the auditor will focus on when visiting your facility is cross-contamination. That means you will have to write procedures explaining:
- How you choose your suppliers (and how you avoid choosing bad suppliers)
- How you import the goods from third countries into the EU
- How you receive the goods in your facility (including checks)
- How you store the goods in your facility
- What you do with the goods: do you repack? Do you ship immediately to your customers?
- Food defense and food fraud procedures
- Quality procedures
- A basic HACCP plan
Once those procedures have been written, make sure your office/warehouse puts them into practice. For example, if you want a dedicated section for organic products (you most definitely want that), make sure you indicate where in the facility the products will be stored, with signs and marks on the floor.
You will also need a stock accounting system that enables auditors to verify that if you imported 10 kg of organic coffee, you did not sell 15 kg of it. That would mean you sold non-organic coffee as organic, which is a big no-no.
Other items the auditor will focus on:
- Supplier certificates: they want to ensure that whoever you buy from is certified organic.
- Labelling: you need to properly label your invoices and food labels with the organic logo.
- Complaints and non-conformity registers: they want to check that you take note of complaints and non-conformities.
The best approach is to ask the certifier for a list of the documents you need to establish. Once the auditor has come and validated your setup, you will receive your official organic certificate.
3. Getting into TRACES
Once you have obtained your organic certificate, you will be able to log into TRACES NT.
TRACES NT is the EU's platform where official certificates are created and checked. Any third-country company wanting to sell organic products in the EU needs to register on TRACES. The platform ensures complete food compliance from producer to consumer. See our TRACES NT guide for a broader overview of the platform if you are not familiar with it yet.
To log into TRACES, you will need to create an EU account.
Tip: keep the same email address for everything, as it will make your identification easier and quicker.
Once you have an EU account, you will have to request access to TRACES through your local TRACES representative. In Belgium, it is taken care of by the Federal Agency for the Safety of the Food Chain (AFSCA/FAVV). Ask your certifier who you should reach out to.
4. Linking Your TRACES Account to Your Operator Profile
Once you get your organic certification, you should appear in TRACES as an operator. Type your name and you should be featured at the top of the list.
However, in order to see and manage your COIs (Certificates of Inspection), you need to link your TRACES EU login account with your operator profile. Follow this procedure:
- Click on your email address in the top right corner
- Click on "Edit your profile"
- Click on the green button "Request a new role"
- Click on "Operator"
- Search for yourself in the search bar
- Select your profile
- Click on "Request authorisation"
- Write a brief message
Reach out to your certifying organization and ask them to validate the registration. You will now be able to consult your COIs, edit them, and create them.
5. Creating Your COI
The COI is the organic passport of a product. It must be issued before the goods leave the country, but it can be edited later to either correct information that was wrong or add new information.
While the responsibility to create it usually falls on the seller (boxes 1 to 18 specifically) and their certifying organization, you can also create it yourself and fill in all the information you know, to speed things up.
You will need a few documents to accompany it, and checking that you have those before creating the COI is important:
- The invoice: it should feature the name and code of the organization that validates the COI in the country where the food departs from
- The packing list
- The airway bill, though you can add it later on
Once you have all that, log into TRACES, click on "Documents" on the left, then on "COI", then on "Create a new COI", and fill in the following boxes:
- Box 10: this indicates where the goods will be presented to customs. Ask your freight forwarder or shipper (FedEx, DHL, etc.) for this information.
- Boxes 11 and 12: your country and you.
- Box 17: ask your freight forwarder or shipper for the flight number (if applicable and if they already know it) and the airway bill number. It can be edited before the COI is created, but once created, it can only be modified by the departing country's certifying authority.
- Box 19: whoever presents the shipment to customs, either a customs agent or your freight forwarder. You have total control over this box.
- Box 20: the estimated time of arrival of the package at customs control. If the estimate ends up being wrong, you can correct it later.
- Box 24: whoever will first receive the goods. They must be certified to handle organic food.
Upload the airway bill, the invoice, and the packing list under "Supporting documents", and add the airway bill number/name into box 17, below "flight number".
Once you are happy with the COI, ask your supplier who they want as issuing authority and fill in Box 1 with those details. Submit the COI, and the issuing authority will receive an alert to complete it. It is also recommended to send them an email.
Once the issuing authority has completed it, inform your local authority in charge of validating it a few days before the goods are presented to customs.
6. Validating the COI
Once everything has been filled in by everyone, the authority in charge in your country should validate it. Once they have validated it, you can confirm in TRACES that you have received the goods.
Done? Congratulations! You are now free to sell your product under the organic logo to your customers.
Please note that procedures change. Please confirm them with your control body and the competent authority of the Member State of release.
What to Do if an Organic Sample Tests Positive for Forbidden Substances
That happens more often than you would guess.
Your supplier's organic field is next to another supplier's non-organic field, the wind blows the wrong way, and suddenly your certifier finds forbidden pesticides in your organic product.
Here is what to do when it happens:
- Do not panic. If you did not expose your product to anything, it is probably not your fault.
- Block the merchandise. Your certifier will send you an email asking you to block it. You are not allowed to move it or sell it to anyone, and you cannot sell it as conventional either.
- Cooperate with the investigation. The certifier will now have to lead an investigation to determine how the forbidden substance ended up in the product. It is in your interest to cooperate, but it is also in your interest to verify whether the blockage of your product is justified, by looking at the lab results they shared with you.
- Interpret the results. Sometimes the processing factor is not taken into consideration. For example, pesticide limits are imposed on the raw agricultural product. If the product is processed or dried, the concentration of pesticide per mg should be expected to be higher in the processed product than in the raw one. The concentration found in the processed product must therefore be divided by the processing factor. Look online for how to calculate it.
- Ask for a second analysis. If experienced, your controller will have taken two samples, so if the first one comes back positive, the second one will help with a counter-analysis. It is your right to ask for one.
- If the counter-analysis also comes back positive, let the investigation run its course. Your controlling organization will use the COI to reach out to your supplier's controlling organization and find out where the substance came from.
- Let your customers know.