2014-04 - European Union (EU) - Use of imported ingredients in organic products exported to the EU

​Date issued: 7 July 2014
Date of Expiry: Until Further Notice
Distributed to: Approved Certifying Organisations
Last Notice in the category: 2014-03
Instruction issued under: Export Control (Organic Produce Certification) Orders

Department of Agriculture
Export Organic Program details
Phone: +61 2 6272 3928
Email: NPG Exports

This Market Access Advice (MAA) provides information on the use of imported organic ingredients in organic plant and plant products exported from Australia to the EU.
Australia’s current equivalence recognition arrangement with the EU, detailed under Annex III of EU Regulation 1235/2008, applies to:

  • Unprocessed plant products; excluding seaweed (Category A).
  • Processed agricultural products for use as food composed essentially of one or more ingredients of plant origin; excluding wine and yeast (Category D).
  • Vegetative propagating material and seeds for cultivation (Category F).

Under this arrangement, the origin of products of category A and F, and organically grown ingredients in products of category D, must have been grown in Australia. Non-organic ingredients used in products of category D must comply with the National Standard for Organic and Bio-Dynamic Produce.

Products exported under the equivalence recognition arrangement must have been produced in accordance with the National Standard for Organic and Bio-Dynamic Produce.
Noting the above, the Department of Agriculture (the department) reminds exporters that imported organic ingredients cannot be used in products exported to the EU under the equivalence arrangement.

Examples

A product manufactured in Australia in accordance with the National Standard for Organic and Biodynamic Produce using wheat imported from China cannot be certified under the equivalence arrangement.

A product manufactured in Australia in accordance with the National Standard for Organic and Biodynamic Produce using Australian grown organic plant ingredients and a non-organic plant based additive imported from the United States can be exported under the equivalence arrangement.

Please note; Annex IV of Regulation 1235/2008 provides a list of certification bodies approved by the EU to certify certain organic goods under conformity assessment arrangements. The department understands that these arrangements may provide for the use of imported organic ingredients. Operators using imported organic ingredients in products destined for export to the EU are encouraged to contact their certification body for further information.

The information provided above is current at the time of writing and is intended for use as guidance only and should not be taken as definitive or exhaustive.  The Commonwealth endeavours to keep information current and accurate, however, it may be subject to change without notice.  Exporters are encouraged to verify these details with their importers prior to undertaking production/exports. The Commonwealth will not accept liability for any loss resulting from reliance on information contained in this notice.

Last reviewed: 22 April 2021
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