The Proposal for a Regulation COM(2025) 780 final focuses, among other aspects, on issues relating to the labelling regime for imported organic products. The proposal to update Regulation (EU) 2018/848 on the production and labelling of organic products addresses aspects related to production, certification and control, devoting most of the changes to labelling, especially with regard to the use of the European Union organic logo and the terms “eco”, “bio” or “organic”.
This is a proposal that responds both to the recent case law of the Court of Justice of the European Union (CJEU) and to the need to strengthen consumer confidence, ensure fair competition and avoid disruptions in the international trade of organic products.
The judgment C-240/23 (Herbaria Kräuterparadies II) is the legal trigger for this reform, as it concluded that, under the current wording of Regulation (EU) 2018/848, products imported under the equivalence regime may neither use the EU organic logo nor, in principle, the terms referring to organic production.
This strict interpretation generated significant legal uncertainty, both for operators and for competent authorities, and highlighted the risk of:
- consumer confusion,
- distortion of competition between EU organic products and those from third countries,
- and trade blockages, especially considering that many production systems recognised as equivalent legally require the use of organic terms on labelling.
With regard to the use of organic terms, the proposal will clarify Article 30 of Regulation (EU) 2018/848 to definitively establish when the terms “eco”, “bio”, “organic” and their derivatives may be used.
Following this amendment:
- The use of terms referring to organic production is expressly authorised for:
- products that fully comply with Regulation (EU) 2018/848;
- products imported from third countries whose production and control system has been recognised as equivalent, in accordance with Article 45.1.b (ii) and (iii).
- The prohibition on the use of such terms is maintained for products that do not comply with either of these regimes.
The proposal will facilitate the connection between EU legislation and the Codex Alimentarius guidelines (CAC/GL 32/1999) for organically produced foods with the national regulations of third countries, preventing products that are legally “organic” at origin from being deprived of any reference to their production method on the EU market.
Redefinition of the use of the European Union organic logo. The core element of the proposal lies in the complete replacement of Article 33, thereby redefining the role of the EU organic logo (the “Euroleaf”).
A tiered system for the use of the logo. It is proposed that the EU logo should cease to be a generic symbol of equivalence and instead function as a seal of alignment with the structural standards of the EU organic model.
It may be used:
- Without restrictions, on organic products produced in the EU in accordance with Chapters II, III and IV of the Regulation.
- Products imported under equivalence, only if they also meet additional production and control requirements, set out in the new Annex VII.
- Products processed in the EU that incorporate equivalent ingredients:
- where these represent ≤ 5% of the agricultural ingredients, or
- where they exceed 5%, provided that those ingredients meet the additional requirements of Annex VII.
- For educational or informational purposes, provided that it is not misleading.
It may not be used:
- on “in conversion” products;
- on certain processed foods defined in Article 30.5;
- on EU products with more than 5% equivalent ingredients that do not meet the additional requirements.
The proposal introduces a new Annex VII, which defines a closed list of technical requirements of Regulation (EU) 2018/848 that imported products must meet in order to use the EU logo. These requirements are associated with the structural elements of the EU organic model, including:
- plant production systems based on the concept of living soil;
- enhanced animal welfare standards;
- processing methods with minimal use of artificial inputs.
Mandatory use of the logo on packaged organic foods produced in the EU
A relevant amendment is also introduced in Article 32, concerning the mandatory use of the logo on packaged organic foods produced in the EU.
The logo will not be mandatory where:
- the product contains more than 5% of agricultural ingredients imported under equivalence, and
- those ingredients do not meet the requirements of the new Annex VII.
This exception avoids regulatory inconsistencies and protects the value of the EU logo as an indicator of enhanced compliance.
Another element provided for is the extension of the recognition period of equivalence for third countries. Although not strictly a labelling issue, the proposal extends until 31 December 2036 the recognition of third countries currently considered equivalent.
In conclusion, it may be highlighted that the proposal to amend Regulation (EU) 2018/848 introduces a profound conceptual change in organic labelling:
- the terms “eco/bio” are associated with technical equivalence;
- the EU organic logo is reserved for products that comply with —or are strongly aligned with— the European model of organic production.
Through this, the Commission seeks to protect consumer confidence, provide legal certainty to the system and preserve the added value of the European organic seal, without renouncing smooth international trade.
