From January 1, 2021, several things changed for organic farmers and growers, manufacturers and traders importing into the UK.
As the UK’s organic experts and the largest dedicated food and farming charity, Soil Association has compiled some key information for organic businesses who import product into the UK.
In addition to the guidance on this page, you can also watch this 25 minute video guide, created to help importers and exporters of organic food, feed, seed and livestock understand new certification and port clearance requirements for a number of differing trade scenarios. (Please note the 1st July date reference in relation to requirements for GB COI for imports from the EU/EEA countries >5:28< has now been extended to July 1, 2022)
Importing into the UK after December 31, 2020
The EU has now agreed to recognise the UK as equivalent for organics until December 31, 2023. This is on top of the already agreed equivalence recognition for UK control bodies, and the UK recognition of the EU as equivalent.
As the UK will retain EC1235/2008 in the UK organic regulation coming into force in Jan 2021, recognition of organic products where certifiers are approved under EC1235/2008 scope (Annex IV of the EC1235/2008 organic regulation1 ) should continue.
Scope of the UK-EU Trade Deal
The scope of the trade deal limits products that may be imported from the EU and Northern Ireland (NI) into GB. Goods imported into the EU or NI from other third countries and not further processed (re-packing or re-labelling are not considered processed) in the EU or NI cannot be re-exported to GB.
Although GB COIs will not be required for imports from the EU, Norway, Iceland, Liechtenstein and Switzerland until July 1, 2022 , there is currently no system in place in GB to recognise EU certification bodies and enable them to issue GB COI’s for products outside the scope of the agreement.
Importing product into Northern Ireland
Importing from non-EU countries into NI – If you are importing product from any non-EU country into NI, unless originating from GB and covered by STAMNI (Scheme for Authorised Movements to Northern Ireland), a TRACES NT COI will be required. For all exports into EU zone including NI, both the exporter, the importer and the 1st consignee should hold a valid organic licence.
Defra have confirmed that for the time being goods exported from GB that are travelling without a COI as part of the STAMNI retailers’ easement for Authorised Traders can continue to move as they have been. The UK Government’s standstill period continues to apply to the re-export of EU and RoW organic products from GB to NI under STAMNI. Authorised Traders can continue to move organic goods in 2022 as they did previously in 2021, until further notice.
Additional requirements for importing from non-EU Third Countries into NI – The Northern Ireland Competent Authority (NICA) have issued guidance (based on EC requirements), for certain imports into NI:
- Organic product from Ukraine, Kazakhstan, Russian Federation, Moldova, Turkey and China.
- Sesame seeds imported from India to NI must be tested for ethylene oxide (ETO) on arrival in NI. This sampling and testing is carried out by the Border Control Point (BCP) when each consignment arrives. Products may only be placed on the market with reference to organic after the BCP have confirmed no ETO residues were detected. Any batch with a positive results for ETO above the limit of quantification (LOQ) must not be sold/used with any reference to organic. You must inform of any positive detection of ETO in these products. If you purchase sesame products from an EU operator they will be responsible for ensuring their product is tested before sale in the EU.
Importing from non-EU countries into GB
Having previously applied retained Annex III and IV from EC1235/2008, at the end of October 2021 the UK published its own register of Third Countries/Territories and Third County Control Bodies/Authorities (GB1235) recognised by the UK for product imported into GB from non EU/EEA countries. This displays the countries, certification bodies and product categories that may be imported into GB.
From January 1, 2021 different exporting rules may apply in non-EU third countries where equivalency is not agreed with the UK. Businesses are advised to contact the exporting control body in the country they are importing food from if they have any questions.
Additional requirements for importing from Ukraine, Kazakhstan, Russian Federation, Moldova, Turkey and China into GB – DEFRA have issued guidance to certification bodies for import into GB of certain products from Ukraine, Kazakhstan, Russian Federation, Moldova, Turkey and China.
Additional requirements for importing sesame seed products from India into GB – Defra have issued guidance on additional requirements for import into GB of sesame seed product from India.
Licensing requirements for importers and 1st consignees
If you are importing organic food, feed or drink products into the UK, you will be required to hold an organic processor licence. 1st consignees, i.e. those who 1st physically receive the goods, where different from the importer, also require a licence. Read our standards for full details of import licensing requirements.
If you are a GB based operator and are responsible for trade of goods going directly between other non-EU countries and the EU, you will need to ensure there is an EU business licensed to import organic goods into the EU.
As of August 1, 2021, some of the cost incurred for certification required for movements between Northern Ireland and GB can be covered by the UK government Movement Assistance Scheme (MAS).
If you currently hold a Wholesaler licence and import from the EU or wish to export to the EU or NI, you will require a Processor licence in addition to, or instead of your Wholesaler licence.
Changes to licenced enterprises for existing licensees
If you already hold a processor licence, you should contact cert@soilassociation.org to ensure that your current licence is scoped for importing from third countries and imported products are identified.
If you are importing and placing an imported product on the GB market, it will need to be listed on your Trading Schedule, either individually or as part of a product category e.g. ‘Ambient grocery products, chilled dairy products’.
If you are importer-processor who imports an ingredient for inclusion in a certified product that is already listed on your Trading Schedule, that ingredient product does not need to be listed separately on your Trading Schedule.
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