Three frameworks, one underlying discipline. We get producers, processors and importers certified organic for the markets that matter to their business, including dual certification where needed.
Organic certification is third-party verification that a product has been produced, processed and handled according to a defined organic standard. Unlike many food safety certifications, organic certification governs production methods themselves, covering permitted and prohibited inputs, land management, and handling practices, beyond the safety of the finished product alone.
The three frameworks most relevant to international food businesses are EU Regulation 2018/848, UK organic standards overseen by the Department for Environment, Food and Rural Affairs and UKAS-accredited certification bodies, and the USDA National Organic Program, NOP, administered by the Agricultural Marketing Service in the United States. Each operates its own certification, inspection and labelling system, though equivalence and compliance arrangements connect them for trade purposes.
Certified operations are subject to annual inspection and must demonstrate ongoing compliance, including through detailed input records, audit trails for organic and non-organic product segregation, and labelling that matches the permitted categories for the relevant market. The organic sector continues to grow significantly: more than 16,500 farms held USDA organic certification in 2025, and 47,566 operations were certified under NOP as of January 2025.
For businesses trading internationally, understanding how these three frameworks relate, where they are equivalent, where compliance and not equivalence now applies, and where dual certification makes sense, is often as important as meeting any single standard's requirements.
Each framework shares the same underlying organic principles, but differs in legal structure, labelling categories and import requirements for third-country operators.
The 95% organic ingredient threshold is shared between the EU and US systems as the basis for an organic claim, but the two diverge on how the remaining 5% non-organic content is handled, on which substances are permitted within that allowance, and on how strictly residue testing is enforced. These differences are exactly where a dual-certification system needs to be built to the stricter of the two requirements at each point.
The single biggest change for procurement teams and third-country producers sourcing into the EU is the shift from equivalence to compliance, now fully in effect.
EU Regulation 2018/848 changed the import framework for third-country organic operators from equivalence, where a standard deemed broadly equivalent to EU rules was accepted, to compliance, where operators must meet EU organic rules directly.
Regulation 2018/848 becomes effective, introducing binding Group of Operators and Internal Control System definitions and shifting third-country imports toward compliance.
Transition period with a derogation allowing time for third-country producer groups, particularly smallholder groups, to bring compliance systems into line with the new requirements.
Derogation period ends. Products not in compliance no longer qualify for organic certification in the EU from this date.
For third-country producer groups, especially smallholder groups in regions where awareness of the change has historically been limited, this is not a minor administrative update. A Group of Operators certified under the previous equivalence-based system needs a documented Internal Control System meeting the binding requirements of Regulation 2018/848, including internal inspections of every member, record-keeping that supports those inspections, and a defined sanctions procedure for members found non-compliant. Without this, certification issued under the old framework does not carry forward.
Customs authorities have established task forces for the 2025 to 2027 transition period to help producer groups navigate the new requirements, but the underlying responsibility sits with the operator and the group's certification body to have the ICS in place. For businesses sourcing organic ingredients from third countries, particularly smallholder cooperatives, confirming the current status of a supplier's Group of Operators certification under the new rules is now an essential part of due diligence.
Organic certification spans the full supply chain, from primary production through to finished product labelling, across multiple markets.
Farms transitioning to organic production or maintaining certification, with input records and land management practices meeting the relevant standard.
Businesses handling organic ingredients alongside conventional product, requiring documented segregation and traceability to support organic claims on finished products.
Businesses importing organic ingredients into the EU, needing to confirm supplier compliance under the post-2025 EU framework instead of relying on previous equivalence arrangements.
Groups of Operators needing an Internal Control System meeting the binding requirements introduced under EU Regulation 2018/848, particularly relevant given the derogation ending in October 2025.
Producers and brands wanting organic certification recognised in both markets, navigating the differences in the 5% non-organic allowance and labelling categories.
Operations relying on the US-UK equivalence arrangement, including the NOP Import Certificate process for UK organic exports to the US.
We cover organic certification across EU, UK and US frameworks, including the cross-market complexities that come with trading in more than one of them.
A review of your production, handling and labelling systems against the organic standard relevant to your target market, identifying gaps and producing a written action plan.
Development of an Internal Control System for Group of Operators certification, meeting the binding requirements introduced under EU Regulation 2018/848, including internal inspection procedures and sanctions processes.
Strategy and documentation for businesses seeking certification recognised in both the EU and US markets, building systems to the stricter requirement at each point of divergence between the two frameworks.
Review of product labelling against EU, UK and USDA NOP labelling categories, logo use and certifier code placement requirements for each target market.
Development of input record systems demonstrating that every substance used is on the permitted list for the relevant standard, a foundational requirement across all three frameworks.
Design of physical segregation and documentation systems for facilities handling both organic and conventional product, supporting the traceability behind organic percentage claims.
Support with the NOP Import Certificate Form 2110-1 process for UK organic exports to the US under the equivalence arrangement.
A full mock audit against the applicable organic standard, identifying gaps before the certification body's annual inspection.
A monthly retainer covering record maintenance, regulatory update alerts across all three frameworks, and pre-inspection preparation.
Organic certification depends heavily on consistent, accurate record-keeping by everyone handling product, from receiving through to labelling. Building team understanding of input restrictions, segregation requirements and documentation through training makes ongoing compliance significantly more reliable. We recommend pairing this consulting programme with relevant training delivered through Confi Food, and can advise on the right approach during the initial consultation.
Certification follows a defined sequence. Our part of the process typically takes a few weeks. Land or process transition periods required by some standards, and certification body audit scheduling, are outside our control.
| Stage | What happens | Our role | Duration |
|---|---|---|---|
| 1. Market and framework confirmation | The applicable organic framework, or frameworks for dual certification, is confirmed based on your target markets. | We confirm the applicable framework and certifying body options, including dual-accredited bodies where relevant. | 1 to 2 days |
| 2. Gap assessment | Current production, handling and labelling systems are reviewed against the applicable standard. | We conduct the assessment and deliver a written action plan. | 2 to 3 days |
| 3. Input and segregation systems | Input records and organic/non-organic segregation systems are developed or reviewed. | We design these systems in collaboration with your team. | 3 to 5 days |
| 4. ICS development (where relevant) | For Group of Operators, an Internal Control System is developed meeting EU Regulation 2018/848 requirements. | We develop the ICS including internal inspection and sanctions procedures. | 1 to 2 weeks |
| 5. Labelling review | Product labelling is reviewed against the permitted categories and logo rules for each target market. | We review and correct labelling for compliance across applicable frameworks. | 2 to 3 days |
| 6. Implementation | Systems are put into practice. Records begin to accumulate ahead of inspection. | We provide implementation support and review emerging records. | 2 to 4 weeks |
| 7. Mock audit | A full mock audit identifies any remaining gaps against the applicable standard or standards. | We conduct the mock audit and issue a findings report. | 1 to 2 days |
| 8. Certification body inspection | The certification body conducts its annual inspection. | We provide standby support and prepare responses to any findings. | Up to the certification body |
Our gap assessment confirms which framework, or frameworks, apply to your target markets and reviews your current systems against them.
The gap assessment covers permitted and prohibited inputs, record-keeping and traceability, organic and non-organic segregation, labelling against the permitted categories for each target market, and, where relevant, Group of Operators and Internal Control System requirements under EU Regulation 2018/848.
For businesses targeting more than one market, the assessment specifically identifies the points where EU and US requirements diverge, such as the 5% non-organic allowance, so that the system can be built to the stricter requirement at each point instead of discovering the gap during a second certification audit later.
We confirm which organic framework or frameworks apply based on your target markets and current certification status.
We review input records, segregation documentation and, where relevant, existing ICS documentation against current requirements.
We assess production, storage and handling areas against documented segregation procedures.
We produce a written gap assessment with a prioritised action plan, including dual-certification considerations where relevant.
For third-country producer groups affected by the end of the EU compliance derogation, we offer a focused ICS gap assessment specifically addressing the binding Regulation 2018/848 requirements.
The same issues appear across organic certification audits regardless of framework. Knowing where these gaps cluster is the most effective preparation.
Records that show what was applied or used, but do not clearly demonstrate that every substance is on the permitted list for the relevant standard, leave the auditor unable to verify compliance even where the underlying practice may be sound.
Facilities handling both organic and conventional product need both physical segregation and the documentation to evidence it. Gaps between what happens on the floor and what is recorded are a frequent source of findings.
For Group of Operators, an Internal Control System that was adequate under the previous equivalence-based framework may not meet the binding requirements now in force following the end of the October 2025 derogation, particularly around internal inspection frequency and sanctions procedures.
Labels using a "100% Organic" or "Made with Organic [ingredient]" claim, both permitted under USDA NOP but not available under EU rules, create a compliance gap for products sold into the EU under those labels.
Where a finished product label states a specific percentage of organic ingredients, traceability records need to support that figure precisely. Gaps between recipe formulation records and the percentage stated on the label are a common finding.
Businesses pursuing dual EU/US certification sometimes build their system to whichever framework they encountered first, without identifying the specific points of divergence, such as the 5% non-organic allowance, that need to satisfy the stricter of the two requirements.
Organic certification is sometimes confused with farm assurance schemes. Understanding the distinction helps clarify what each one demonstrates.
| Organic certification | Red Tractor | GLOBALG.A.P. IFA v6 | |
|---|---|---|---|
| What it certifies | Production method (no synthetic inputs, defined practices) | Food safety, traceability, animal welfare, environmental protection | Food safety, traceability, worker welfare at farm level |
| Geographic focus | EU, UK and US frameworks (others exist globally) | UK only | Global |
| Can be held alongside | Yes, often combined with food safety certifications | Yes, often combined with organic certification | Yes, often combined with organic certification |
| Our consulting | Organic certification | Red Tractor | GLOBALG.A.P. |
What drives the timeline and cost of an organic certification project. We provide a written proposal with a fixed fee after the initial consultation.
Timeline
How long our consulting work takes
Cost factors
What drives the consulting fee
No existing organic certification, targeting one of the EU, UK or US frameworks. Our consulting work typically takes 2 to 4 weeks. Land or process transition periods required by the standard, and certification body scheduling, are separate and outside our control.
Building a system that satisfies both frameworks at points of divergence. Our consulting work typically takes 3 to 5 weeks, depending on your starting point.
For producer groups needing an Internal Control System meeting Regulation 2018/848 requirements, particularly relevant given the October 2025 derogation deadline.
Operations already certified to one organic standard and adding a second, or transitioning a UK certification toward US equivalence requirements, typically require 1 to 2 weeks of focused work.
A single-ingredient product with one supplier requires less traceability and segregation work than a multi-ingredient product sourced from multiple organic suppliers across different countries.
Products sold under different labels in different markets, reflecting the different permitted categories under EU and US rules, require more detailed labelling review.
A gap assessment only, a full system build, or a focused ICS development package each carry different fees. All scopes are defined in writing before work begins.
Certification body inspection fees are separate from our consulting fees and paid directly to your chosen certifying body, including dual-accredited bodies for multi-market certification. We advise on CB selection during the initial consultation.
Answers to the questions we hear most often from producers, processors and importers across EU, UK and US markets.
Organic certification is third-party verification that a product has been produced, processed and handled according to a defined organic standard, covering production methods and not the finished product's composition alone. The main frameworks are EU Regulation 2018/848, UK organic standards overseen by Defra and UKAS-accredited certification bodies, and the USDA National Organic Program, NOP, in the United States. Certified operations are subject to annual inspection and must demonstrate compliance with rules covering permitted inputs, prohibited substances, record-keeping and traceability.
EU Regulation 2018/848, effective from January 2022, changed the import framework for third-country organic operators from equivalence to compliance, meaning operators outside the EU must now comply directly with EU organic rules in place of rules deemed equivalent. The regulation also introduced binding legal definitions and requirements for Group of Operators and Internal Control Systems, ICS, affecting smallholder producer groups in particular. A derogation period for compliance systems ended on 15 October 2025, meaning products not in compliance no longer qualify for organic certification in the EU from 16 October 2025.
A Group of Operators is a formally defined group of smallholder farmers or producers certified collectively under EU organic rules, not individually. An Internal Control System, ICS, is the documented system the group uses to ensure every member complies with organic requirements, including internal inspections, record-keeping and a sanctions procedure for non-compliance. EU Regulation 2018/848 made the definitions and requirements for both binding, and the derogation period allowing time to transition to full compliance ended on 15 October 2025.
Yes, through dual certification with a certifying body accredited for both EU organic rules and USDA NOP, such as Ecocert, Control Union, Kiwa BCS or CERES, or by relying on the relevant equivalence or compliance arrangements where they apply. Both systems generally require a minimum of 95% organic ingredients, but they diverge on how the remaining 5% is handled, on permitted substances, and on import verification, so dual certification typically requires a system built to satisfy the stricter requirement at each point of divergence.
As of 1 January 2021, USDA and EU certified organic products can move freely between the US and the United Kingdom under an equivalence arrangement that largely mirrors the US-EU arrangement, with the exception of export certificates. With limited exceptions, products certified to USDA or EU organic standards meeting the terms of the arrangement may be labelled and sold as organic in both countries. For UK organic products shipped to the US, a Defra-accredited certifier must complete a US NOP Import Certificate, Form 2110-1.
The EU regulations do not have a labelling category for 100% organic products or for "Made with Organic" claims naming specific ingredients or food groups, both of which exist under USDA NOP. In the EU, the only organic claim permitted on the front label is the general organic claim, and use of the EU or USDA organic logo is optional, though if the EU logo is used the certifier code must appear directly below it. Organic ingredients in products below the organic percentage threshold required for an organic claim can only be identified as organic within the ingredient list itself.
An organic gap assessment reviews your production or processing operation against the requirements of the organic standard relevant to your target market, covering permitted and prohibited inputs, record-keeping and traceability, organic and non-organic product segregation, labelling, and, where relevant, Group of Operators and Internal Control System requirements. It identifies gaps and produces a written action plan, including recommendations on certifying body selection for single or dual market certification.
The most common organic certification issues are: input records not demonstrating that every substance used is on the permitted list for the relevant standard. Segregation between organic and non-organic product not adequately documented or physically maintained. Internal Control System documentation for Group of Operators not meeting the binding requirements introduced under EU Regulation 2018/848. Labelling that does not match the permitted categories and logo placement rules for the target market. Traceability records that do not support the percentage organic claims made on finished product labels.
Our consulting work moves fast. From gap assessment to audit-ready, most operations are there in a few weeks. Organic certification also requires a land or process transition period in many cases, which is set by the standard itself and is outside our control. The certification body audit scheduling and certificate issuance timeline are also outside our control, but our part of the process is structured to never be the bottleneck.
Yes. Gap assessments, documentation development, Internal Control System design and labelling review are all available remotely. We work with clients in any country. On-site visits are available for mock audits and where a physical review of production, storage or segregation areas is needed.
You can commission any of these on their own, with an agreed scope and a written quote, without taking on ongoing consulting. See all food safety services.
To check the whole operation against the law of each market.
Read about A regulatory compliance review →To check what your supplier files evidence in practice.
Read about A supplier document review →To check a label against the information law of each market.
Read about A food label compliance review →Tell us about your products, your current certification status and your target markets. We will tell you exactly what each framework requires.