‘Organic' Labelling – principles

Regulation (EU) 2018/848 establishes the principles of organic production and lays down strict rules concerning organic production, related certification, control systems, and the use of indications referring to organic production in labelling and advertising. It also governs the rules for importing organic and in-conversion products from third countries into the European Union.

Organic Certification in Ireland

Operators cannot place products on the market as ‘organic’ or ‘in-conversion’ without notifying their activity and being in possession of an official organic certificate.

In Ireland, the labelling must include the code number of the inspection authority or control body to which the operator is subject, the producer's name, address and/or licence number, the appropriate organic logo and/or name of the relevant organic certifying body and the words ‘Certified Organic'

There are currently two certifying bodies in Ireland:

• IE-ORG-02

Irish Organic Association (IOA)
Unit 16A, Inish Carraig, Golden Island, Athlone, Co. Westmeath
Website: www.irishorganicassociation.ie

• IE-ORG-03

Organic Trust CLG
Office A1, Town Centre House, Naas Town Centre, Dublin Road, Naas, Co. Kildare
Website: www.organictrust.ie

General Labelling Provisions

Regulation (EU) 2018/848 applies without prejudice to other specific EU legislation relating to the placing of products on the market and, in particular to Regulation (EU) No 1169/2011.

In particular, the terms listed in Annex IV of Regulation (EU) 2018/848 (such as “organic”) can only be used for compliant products.

The labelling and marketing of a product produced in accordance with the requirements of Regulation (EU) 2018/848 may refer to organic production methods only where:

• Such indications show clearly that they relate to a method of agricultural or aquaculture production.
• The product was produced in accordance with the legal requirements laid down in Regulation (EU) 2018/848 or was imported from a third country under the compliant or equivalent trade arrangements detailed in Articles 45 to 49.
• •    The product was produced, prepared, or imported by an operator who has officially notified their activity and holds a valid organic certificate under the official control system outlined in Articles 34, 35, and 38 of the Organic Regulation.

Every single organic label design must be officially reviewed and approved by the designated organic control body (IOA or Organic Trust) before it can send it to print or place the product on the market.

The 70% organic category no longer exists under the current framework. Processed foods may only feature references to organic production methods under the following specific categories set out in Article 30(5):

1. Processed food where at least 95% of agricultural ingredients are organic

Terms referring to organic production (like "organic") may appear in the labelling and the list of ingredients, provided that:

• The processed food complies with the detailed processing rules (Part IV of Annex II of the Regulation (EU) 2018/848).
• At least 95% of the agricultural ingredients of the product by weight are certified organic.
• The list of ingredients explicitly indicates which ingredients are organic.
• In the case of flavourings, they are only used for natural flavouring substances and natural flavouring preparations, and all flavouring components/carriers are organic.
• The product has been produced without the use of genetically modified organisms (GMOs) or products produced from/by GMOs.
• The product or its raw materials have not been subjected to treatments involving ionising radiation.
• The operator is fully subject to the official organic control and certification system.

2. Products Where Less Than 95% of Agricultural Ingredients are Organic

• To label certain ingredients as organic in the ingredients list of a non-organic product:
• The organic ingredients independently comply with the organic production rules.
• The processed food complies with the core organic processing rules (such as the separation of organic and non-organic processing runs in space or time).
• The list of ingredients includes a mandatory statistical statement in the same visual field indicating the total percentage of organic ingredients in proportion to the total quantity of agricultural ingredients.
• Any food additives or processing aids used must be from the EU’s restricted authorised list. 

The mandatory EU Organic Logo cannot be used on these products.

3. Products Where the Main Ingredient is from Hunting or Fishing

Terms referring to organic production may appear in the sales description and the list of ingredients, provided that:

• The main ingredient is a product of wild hunting or fishing (which cannot be certified organic themselves).
• The organic term is explicitly and clearly related to the side ingredient, not the wild animal. 
• All other agricultural ingredients used in the product are certified organic.
• The product complies with all organic processing requirements.

Non-Organic Agricultural Ingredients & Authorisations

By default, processed organic food must be composed of organic agricultural ingredients. However, if a specific agricultural ingredient is unavailable in an organic form on the Union market in sufficient quantity or quality, a temporary exception applies:

Provisional Member State Authorisation (Article 25): A Member State may, at the request of an operator, provisionally authorise the use of non-organic agricultural ingredients on its territory for a maximum period of six months. This authorisation can be prolonged a maximum of two times (for six months each), provided no other Member State objects by demonstrating that a sufficient organic supply is actually available.

Back to Organic foodstuffs.