Amending certain production, labelling and certification rules and certain rules on trade with third countries
446 submissions from 356 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 937 submissions on this file. Shown here: the 446 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
CommitteeAGRIRapporteurCamilla Laureti (S&D)
TABLING_PLENARY · 29 Jul 2026
Tabling of a document for EP plenary · 29 Jul 2026
Committee Report Adopted · 14 Jul 2026
Adoption of a report by the EP committee responsible · 14 Jul 2026
Tabling of amendments in the EP committee responsible · 26 Mar 2026
Who showed up
334 submissions from industry — companies and their trade associations — against 45 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 7.4 industry submissions for every one from civil society.
Industry 334Civil society 45Public authorities, academia, other 67
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
50 of 356
in the EU Register
124
full-time lobbying staff
€13.1M+
declared costs a year
105
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 20 Mar 2026 — it ran from 23 Jan 2026.
This initiative updates rules on organic production in order to: provide businesses with clarity and certainty on the import of organic products under the equivalence regime, following a judgment of the Court of Justice of the EU, to prolong beyond the current deadline of 31 December 2026 the recognition of non-EU countries’ equivalent organic farming rules to avoid commercial turmoil by targeted simplification of…
Filed in Italian · English published by the European Commission
Opinion of the Austrian Chamber of Agriculture, BIO AUSTRIA and the IG control bodies The European Commission has presented a legislative proposal to amend Regulation (EU) 2018/848 and a roadmap for the revision of secondary legislation.
Filed in German · English published by the European Commission
1. Cleaning and disinfection products It is considered that, although the current system of lists was not exhaustive, it provided a useful reference framework. Its removal may introduce risks related to the use of inappropriate substances or residues, reducing the existing level of technical control in organic production. Comment from: ENEEK-EKOLURRA 2.
The European Commissions proposal to amend the EU Organic Regulation has so far not taken into account one important issue: the removal of salt from Annex I of the Regulation. We therefore call on the European Parliament and the Council, in the ongoing legislative procedure, to delete salt from Annex I in order to ensure legal certainty for the salt sector and to avoid misleading consumers.
The VKS Verband der Kali- und Salzindustrie takes a critical view of the European Commission’s intention to keep salt within the scope of Regulation (EU) 2018/848 on organic production. From the point of view of the MCS, this leads to systematic inconsistencies.
Filed in German · English published by the European Commission
As coordinator of Bio 63, the association for organic farming in Puy de Dôme, I would like to call for the most limited possible revision and believe it is essential to ensure that an obligation to leave young poultry is maintained, that compulsory grazing for ruminants is maintained and that a maximum size of organic poultry production area is maintained.
Filed in French · English published by the European Commission
1. Organic food: The proposal should allow, for all poultry, the use of 5 % non-organic protein feed, where these proteins do not exist in organic form (such as maize gluten or potato proteins). Organic farming is currently so unbalanced in terms of essential amino acids that it has very negative consequences for livestock farmers: deterioration in the condition of hens with more pecking and cannibalism, higher…
Filed in French · English published by the European Commission
The FAP, the Pays de la Loire aquaculture sector, is an association which brings together aquaculture producers in the western region of France, including spirulin producers. It has taken note of the European Commission’s proposal for Regulation (EU) 2025/780 amending Regulation (EU) 2018/848 on organic farming in the interests of simplification.
Filed in French · English published by the European Commission
We support the simplification of the EU rules for organic production, but emphasise that simplification only has value if it also leads to greater harmonisation and equal competitive conditions within the internal market. In practice, Member States (and even regions) apply the EU framework differently, particularly with regard to plant reproductive material and inputs.
Swedish comments on the Commission’s proposal to amend Regulation (EU) 2018/848 We appreciate the opportunity to comment on the Commission’s proposal to amend Regulation (EU) 2018/848. We see a strong need to simplify the rules for organic production, without watering down the rules, or to change the principles of organic production.
Filed in Swedish · English published by the European Commission
The organic product specification should not be simplified. It is the only organic label that can differentiate between conventional agricultural products and organic quality. No GMOs, no industrial farms, no pesticides and no chemical fertilisers, the link to the soil for animals, these conditions must be guaranteed for the consumer.
Filed in French · English published by the European Commission
It is positive that the Commission proposes simplifications in the regulation for organic production. Product development is needed to increase demand for organic lamb in Sweden. Further measures and simplifications are needed also to increase organic lamb production. In order to develop the products and increase production, more reasonable regulations and less administration are needed in several areas.
The Federation of Veterinarians of Europe (FVE) representing around 330,000 veterinarians across 38 European countries aims to enhance animal health, animal welfare, and public health and to protect the environment by promoting the veterinary profession. FVE welcomes the opportunity to comment on the Commissions call for evidence Organic production rules targeted updates and simplification.
‘Primary production animals’ means quails: We support that the age at slaughter may be 42 days when quails are not slow-growing. Withdrawal period: We think that the withdrawal period should be 0 days, and not 48 hours as it stands now, when a medicine does not have a statutory withdrawal period.
Filed in Swedish · English published by the European Commission
Nobian regrets the Commissions decision to keep salt in the Organic Regulation. Including salt in the Regulation while failing to provide practical production rules causes problems in the single market and confuses consumers. Nobian notes that information provided by the vast majority of European salt production was ignored.
DSK supports the objective of simplifying the regulatory framework, as it contributes to reducing the administrative burden for businesses. DSK notes with concern that the proposal would no longer consider it sufficient for third countries to have their organic production and control systems recognised as equivalent to those of the EU in order to use the EU organic logo on food products.
The revision of Regulation (EU) 2018/848 is an important opportunity to introduce targeted improvements. The organic framework plays a valuable role for organic production and consumer confidence, but several rules are overly rigid, create legal uncertainty and impose unnecessary administrative and economic burdens.
ERPA is the European association representing rural poultry producers in Europe, including producers of organic eggs and organic poultry for meat. ERPA thanks the European Commission for its proposal, particularly concerning the withdrawal period after the use of allopathic medicinal products for terrestrial animals as this will solve a huge problem for organic eggs producers.
AVEC the Association of Poultry Processors and Poultry Trade in the EU and ELPHA the European Live Poultry and Hatching eggs Association - represents the EU poultry meat sector from breed to meat. We welcome the possibility offered by the Commission to provide feedback on the Commission proposal aiming at updating the rules on organic production.
National Chamber of Agriculture (Hungary) The National Chamber of Agriculture (Hungary) supports the relevant amendment to Regulation (EU) 2018/848 and agrees with its content. The amendment aims to provide clarity for organic products imported under the equivalence regime, with clear rules for trade with non-EU countries in organic products and for the EU organic logo.
Filed in Hungarian · English published by the European Commission
The European Landowners Organization (ELO) welcomes the European Commissions initiative to simplify the regulatory framework governing organic production. Organic farming represents one important pathway towards sustainable agriculture in the European Union, contributing to environmental protection, biodiversity and soil health.
The Union des Industries de la Fertilisation (UNIFA) represents the plant nutrition and soil health industries. It brings together more than 30 companies producing all the fertilisation solutions (fertilisers and mineral soil improvers, processed organic and organo-mineral fertilisers and biostimulants), spread over 80 production and storage sites on French territory.
Filed in French · English published by the European Commission
The European Organic Certifiers Council (EOCC) represents 74 Control Bodies (CBs) and Control Authorities (CAs) committed in their daily work to inspect, control and certify all operators in organic farming in more than 165 countries. EOCC members certify at least 180.000 Operators in Europe (EU OP) (for a surface of 6 mln ha) and 180.000 Operators in Third Countries (for a surface of 20 mln ha).
Synalaf represents organic poultry and egg producers in France. Synalaf welcomes the European Commission’s proposal on the withdrawal period after the use of allopathic medicines, which addresses a significant difficulty for organic egg producers.
Filed in French · English published by the European Commission
The EU Commission's proposal with reference to the "Herbaria case" and the derived Annex VII, concerning additional criteria for imported organic products from third countries under the equivalence scheme, is very unsatisfactory. We cannot accept two-tier organics, where there are organic products on the EU market, where some organic products cannot be labelled with the EU organic logo.
EUsalt regrets the Commissions decision to maintain salt within the Organic Regulation. Maintaining salt within the Regulation while failing to provide workable production rules creates issues in the single market and confuses consumers.
This contribution is jointly submitted by ANVOL (the French interbranch organisation for meat poultry) and CNPO (the French National Committee for the Promotion of Eggs), the two interbranch organisations representing these sectors in France.
Unión de Uniones de Agricultores y Ganaderos (Union of Farmers’ and Livestock Farmers’ Unions) appears in the public consultation launched by the Commission concerning: COM (2025) 780 final 2025/0417 (COD) Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2018/848 as regards certain production, labelling and certification rules and certain rules on trade with third…
Filed in Spanish · English published by the European Commission
In France, the Syndicat National des Accouveurs (SNA) brings together all the breeding and hatching companies covering all the poultry species produced: broilers, laying hens, turkeys, palmipeds (ducks and geese), guinea fowl, game (pheasants, partridges, mallard ducks), pigeons and quails. The NAS calls for the possibility of using non-organic chicks less than 3 days old to be made permanent.
Filed in French · English published by the European Commission
This contribution is jointly submitted by ANVOL (the French interbranch organisation for meat poultry) and CNPO (the French National Committee for the Promotion of Eggs), the two interbranch organisations representing these sectors in France.
Filed in French · English published by the European Commission
It is useful to have the opportunity to comment on the Commission’s proposal to amend Regulation (EU) 2018/848. As an advisor, I see a strong need and opportunity to simplify the rules for organic production, without watering down the rules, or changing the principles of organic production. The rules on organic production are perceived as difficult to understand and very detailed.
Filed in Swedish · English published by the European Commission
Requirements ® have developed rules and certification for organic production in Sweden since 1985. Our mark is recognised by 99 % of Swedes. We are developing rules that go beyond the EU regulation for ecology in particular on social responsibility, animal welfare, biodiversity and climate. We are pleased to have the opportunity to comment on the Commission’s proposal to amend Regulation (EU) 2018/848.
Filed in Swedish · English published by the European Commission
CEEV welcomes the opportunity to respond to the European Commissions open consultation on the proposal COM(2025) 780 amending Regulation (EU) 2018/848 on organic production. CEEV promotes a smooth development of organic wine production and markets to meet the growing consumer demand for quality organic wines in the EU and beyond.
EuroCommerce, representing the voice of European retailers and wholesalers, welcomes the proposal to reopen the Basic Organic Regulation (EU) 2018/848. We particularly support the proposed extension of the expiry date for the recognition of third countries whose organic production and control systems are deemed equivalent, until 31 December 2036.
The BÖLW, the umbrella organisation for the organic sector in Germany, welcomes the proposal made by the European Commission on 16 Proposal presented in December 2025 to open up the Basic Organic Regulation 2018/848, as it is limited to a few targeted amendments and addresses important concerns of the organic sector.
Filed in German · English published by the European Commission
Opinion FRSEA Pays de la Loire on the revision of the specifications for European organic farming 1. Animal health and veterinary medicinal products We express a favourable opinion on the proposed abolition of the deadline of at least 48 hours after the administration of veterinary medicinal products, since the product used sets a withdrawal deadline of 0 days in conventional livestock farming. 2.
Filed in French · English published by the European Commission
The VOLINEO group brings together breeders of laying hens, including around 30 in the Bio region in western France. First of all, we would like to thank the European Commission for its proposal, in particular on the withdrawal period applicable after the administration of allopathic medicinal products.
Filed in French · English published by the European Commission
Hello, as head of an organisation of around 30 organic egg producers, I am in favour of simplifying Regulation (EU) 2018/848 on organic production. Its introduction has had a negative impact on the technical and economic performance of farms, which discourages farmers and encourages them to leave the sector.
Filed in French · English published by the European Commission
We are pleased to have the opportunity to comment on the Commission’s proposal to amend Regulation (EU) 2018/848. We see a strong need and opportunity to simplify the rules for organic production, without watering down the rules, or changing the principles of organic production. The rules on organic production are perceived as difficult to understand and very detailed.
Filed in Swedish · English published by the European Commission
SEASALT Europe, the association representing the interests of European sea salt producers, supports the update of Regulation (EU) 2018/848. We welcome this 'surgical intervention' to resolve the trade issues arising from the 'Herbaria' case without reopening the entire legislative framework.
Organic farmers are pleased to have the opportunity to comment on the Commission’s proposal to amend Regulation (EU) 2018/848. We see a strong need and opportunity to simplify the rules for organic production, without watering down the rules, or changing the principles of organic production. The rules on organic production are perceived as difficult to understand and very detailed.
Filed in Swedish · English published by the European Commission
AgriParis Seine is a French territorial cooperation association that brings together 9 communities and structures in the Seine basin committed to sustainably transforming the territory’s agricultural and food systems: the Le Havre Seine Métropole urban community, the Métropole Rouen Normandie, the Communauté d’agglomération Seine-Eure, the Communauté d’agglomération de Cergy-Pontoise, the Ville de Paris, the…
Filed in French · English published by the European Commission
We would like to thank the European Commission for its work and for the opportunity to comment on the proposed amendments to Regulation (EU) 2018/848. We support the proposals and wish to see them implemented as swiftly as possible.
Copa-Cogeca welcomes the European Commissions initiative to reopen Regulation (EU) 2018/848 with the aim of amending selected provisions of the EU organic framework. We recognise the importance of ensuring a swift and seamless legislative process to safeguard the integrity and credibility of the European organic system, and as such support an adoption of the proposal by the end of 2026.
Oenodia, a French company based in Pertuis, has developed, together with the Institut national de recherche pour l’agriculture, l’alimentation et l’environnement (INRAE), eco-selective tartaric stabilisation (STES), using the electrodialysis process, which allows wines to stabilise efficiently, accurately and ecologically.
Filed in French · English published by the European Commission
I am writing to request that future ecological legislation does not turn a blind eye to the reality of the countryside, especially in southern Europe. I am worried about three points that, if approved as they are, will injure the small farmer to death: The danger of hidden macro-farms: We cannot allow the 1.600 m² limit to be applied per “house” instead of per total farm.
Filed in Spanish · English published by the European Commission
The Committee Linking Entrepreneurship-Agriculture-Development (COLEAD) thanks the European Commission for the opportunity to contribute to this call for evidence on behalf of our members. The purpose of the Association is to facilitate and implement all actions that, directly and/or indirectly, increase the contribution of the agricultural sector, and horticulture in particular, to the achievement of the…
Coopérative Agricole des Fermiers de Loué has been a breeders’ organisation in a mixed cropping area with organic farming for eggs and broilers since 1994-1995. Since the new EU BIO Regulation 2018/848, farmers have ceased their activity, a paradox that demonstrates the need to correct certain provisions.
Filed in French · English published by the European Commission
Hello, my opinion is as follows: — not for the expansion of breeding sites. 1 600 square metres is sufficient for a farmer and makes it possible to maintain the family character of farms while preserving small slaughterhouses. — yes to the 100 % organic feed which is achievable in poultry for meat production. Cizeron Bio knows how to make it and is ethically more responsible to consumers.
Filed in French · English published by the European Commission
Hello, I have been an organic farmer for PAM and Fruits certified for 10 years with Ecocert and had been in dairy production and goat cheese processing with Nature and Progress in the late 1970s. These organic certifications had and make sense as long as the product specification and its requirements guarantee the quality of the certified products for the consumer, the peasant and their impact on the environment.
Filed in French · English published by the European Commission
Fonterra Organics welcomes the opportunity to provide comments and information on the Proposal to amending Regulation (EU) 2018/848 as regards certain production, labelling and certification rules and certain rules on trade with third countries. We thank European Commission for the consideration of the comments outlined in this attached submission.
PANVEGA AG - NATURAL VITAMIN B12 This comment relates to staff working document SWD(2025)424 ANNEX II Chapter 5.12. Organic ingredients naturally rich in micronutrients, which is linked to the existing restrictions on enriching organic processed food with vitamins, minerals & micronutrients, as laid down in point 2.2.2(f) of Part II of Annex II to Regulation (EU) 2018/848.
The Organic Exporters Association of New Zealand welcomes the opportunity to comment on the proposed updates to the organic equivalence arrangements with the European Union (EU). New Zealand exports over USD360 million of certified organic food and beverage annually.
Contribution TO THE PUBLIC CONSULTATION ON THE AMENDMENT OF Regulation (EU) 2018/848 As an organic producer, the Commission would like to make the following contribution: 1. Veterinary Treatment Management (Positive Assessment) welcomes the proposal to eliminate the minimum withdrawal period of 48 hours after the use of allopathic veterinary medicinal products.
Filed in Spanish · English published by the European Commission
In the context of this consultation on targeted updates and simplification of the rules applicable to organic production, Vignerons Indépendants de France calls for authorisation of eco-selective tartaric stabilisation by electrodialysis (STES).
Filed in French · English published by the European Commission
We are pleased to have the opportunity to comment on the Commission’s proposal to amend Regulation (EU) 2018/848. We see a strong need and opportunity to simplify the rules for organic production, without watering down the rules, or changing the principles of organic production. The rules on organic production are perceived as difficult to understand and very detailed.
Filed in Swedish · English published by the European Commission
IFOAM Organics Europe reiterates its support for the European Commissions targeted amendment of Regulation (EU) 2018/848, stressing the urgent need for its rapid adoption to avoid severe disruption to international organic trade.
Naturland is an international association for organic agriculture with more than 40 years experience in group certification of smallholder farmers. Naturland supports the proposed changes to group certification. At the same time, there is a need for further technical amendments to improve benefits of group certification for smallholder farmers.
The Fair Trade Advocacy Office (FTAO) welcomes the European Commission's proposal to simplify the EU Organic Regulation (Regulation (EU) 2018/848), as set out in COM/2025/780. The proposed amendments represent a meaningful step toward reducing the administrative burden on smallholder organic farmers and groups of operators, including those in Fair Trade supply chains.
As stakeholder within the organic poultry sector, we stress that elevated, often adjustable platforms and perches are essential for creating an appropriate early life rearing environment. Scientific evidence shows that early exposure to spatial complexity and vertical structures supports the development of locomotor skills, coordination, bone strength and muscle development, which are key determinants of welfare and…
The Danish Chamber of Commerce represents food retailers og wholesalers in Denmark. We welcome the Commissions proposal to revise and clarify key provisions of Regulation (EU) 2018/848, especially the withdrawal of the previously announced positive list of permitted disinfectants and de-tergent, as well as the postponement of the expiry of equivalence arrangements with third countries until 2036.
3.9 allow more stables for organic broiler producers There are no animal welfare or environmental reasons to limit the number of broiler stables remaining on a farm. Justification: the current restriction does not bring environmental or animal welfare benefits. The amendment allows farmers to have several stables and to be able to expand and develop their production.
Filed in Swedish · English published by the European Commission
Regulation (EU) 2018/848 on organic production and labelling significantly affects the fruit and vegetable sector. The organic farming system faces many of the same challenges as conventional production such as labour shortages, rising costs, food waste, and market volatility. But the absence of food additives, post-harvest treatments, along with shorter shelf life, etc.
Bio Centre, an organic farming interbranch organisation, agrees with a limited revision of the Regulation. As regards poultry, lifting the constraint of 1 600 m² per holding poses a great risk of intensification of organic farms. How do we aim for farms to be independent in terms of organic food while authorising several buildings of 1 600 m² per farm?
Filed in French · English published by the European Commission
Bioforum appreciates several proposed amendments. In particular, we welcome the Commissions proposal regarding the veterinary withdrawal period. We also welcome the proposal to simplify rules on group certification. Nevertheless, we recommend retaining the current 2% rule regarding certification costs in relation to organic turnover as the costs of certification can exceed this limit.
I believe that organic farming is the future of our planet. It is necessary to stay on human scales and respect the basic needs of the animals. Ruminants need to leave and graze, poultry need space and also to leave. All animals need to be able to go out in a natural environment! I think it is also important to respect what nature does, and not always seek to change it. New GMOs should be banned!
Filed in French · English published by the European Commission
In the EU, Foods for Special Medical Purposes (FSMPs) are regulated under Regulation (EU) 609/2013 and Delegated Regulation (EU) 128/2016, while organic production is governed by Regulation (EU) 2018/848. Although Regulation 2018/848 allows the use of added vitamins, minerals, amino acids and micronutrients in certain foods for specific groupssuch as infant formula and baby foodsit does not extend this allowance to…
As regards the rearing of organic poultry, it is essential to leave the limit of 1 600 m² at the level of the removal sites (as in the current regulation) and not at the level of the buildings (as in the proposed amendment) in order to avoid distortions and the deterioration of the image of organic production and to maintain a link with the soil.
Filed in French · English published by the European Commission
The ad hoc proposals concerning groups of operators, Article 36 in particular for third countries, are acceptable. The Commission proposes to revise the threshold in Article 35 (8) to exempt a distribution operator from the obligation to hold a certificate. This development to 10 000 kg and without a turnover threshold is not a good message for consumer confidence and is not desirable.
Filed in French · English published by the European Commission
Hello, an organic farmer since 2005, I am deeply committed to respect for nature and animals. I fully agree with organic farming that is consistent with existing provisions to facilitate organic production provided that the rules are not weakened to the detriment of respect for nature and animals. It is consumers who make us live and their trust must be maintained and secured if we do not want to lose the market.
Filed in French · English published by the European Commission
With this contribution, I would like to reiterate a clear line in the ongoing revision. It seems essential to me that this should remain strictly circumscribed. Going beyond targeted dates would risk undermining the current framework for organic farming, the balance of which is based on precise requirements.
Filed in French · English published by the European Commission
Hello, I would like the European Commission to maintain organic specifications that are consistent with the requirements of organic farming: — compulsory grazing of ruminants, – a ban on GMOs and synthetic products in organic farming for feeding animals, in plant crops and in the production of organic products, – an obligation for poultry to leave the open air runs in order to make a clear distinction between…
Filed in French · English published by the European Commission
The European Commissions proposal contains several important and practical amendments to the EU Organic Regulation. In particular, the removal of the planned positive list for cleaning and disinfecting products, the extension of the recognition of third countries under equivalence agreements, and clarifications regarding poultry farming help to reduce unnecessary administrative burdens and improve the practical…
The Fédération Nationale dAgriculture Biologique welcomes the proposal to revise the Bio Regulation, which aims to simplify its implementation on the ground. The FNAB, the only French agricultural organisation made up solely of organic farmers, accepts the European Commission’s desire to strengthen European consumers’ confidence in products labelled as organic on our continent (recital 23).
Filed in French · English published by the European Commission
Thank you for the opportunity to provide input. We would like to make some proposals on the present draft regulation; please find attached the extensive input, here the executive summary: 1. We support the proposal on waiting time. 2. Imports: 2.1. we continue to ask for Article 45 to be amended so that import controls can also take place at the points of release and not only at the border control posts. 2.2.
Filed in Dutch · English published by the European Commission
The current proposal remains contained, but above all should not go further than it should not go any further. For poultry: it seems necessary to maintain open-air criteria and limited pruning in order to stand out from intensive models favouring diseases, mortality, etc.
Filed in French · English published by the European Commission
3.8 when poultry should have access to open-air runs, it is of course reasonable that poultry should be sufficiently fertilised before they should have access to open-air runs. However, the proposal to include this in particular in the Regulation is poor.
Filed in Swedish · English published by the European Commission
Organic farming respects the cycle of the seasons, as well as the entire life cycle and in particular the needs of livestock (access to grazing, limited stocking density, etc.). Reducing the requirements of the current regulation means denying all living people, including those who do it, as well as consumers who trust this currently most sustainable and resilient production method. Not also to the ogm, NGT and CMS.
Filed in French · English published by the European Commission
The proposal to revise the Bio Regulation seems reasonable but should not go any further, particularly with regard to organic farms, which must have outdoor access for their food and well-being. It is important for me to reject all synthetic products and GMOs to ensure our food.
Filed in French · English published by the European Commission
I share my opinion as an organic market gardening advisor in southern France. The European product specification is the basis for guaranteeing uniform organic production in Europe. It should not be made more flexible, particularly with regard to livestock farming.
Filed in French · English published by the European Commission
The rules on organic production are perceived as difficult to understand and very detailed. The number of organic farmers in Sweden has fallen significantly since the new Regulation started to apply in 2022. By seizing all opportunities for simplification, it can help to reverse this trend. Therefore, simplifications are needed at all levels according to the attached file.
Filed in Swedish · English published by the European Commission
The European regulation governing organic production is a reference in France and Europe. Its level of demand is recognised by consumers, who are more likely to trust the label every day. The upcoming debates in the European Parliament on the revision of this Regulation are part of a limited revision of the Regulation, which we highlight positively.
Filed in French · English published by the European Commission
The amendments to Regulation (EU) 2018/848 on organic farming, published at the end of 2025, remain moderate and appear to maintain a high level of requirement for European organic farming specifications. This moderation in the proposed amendments is commendable, in order to maintain the integrity of the label and consumer confidence.
Filed in French · English published by the European Commission
Hello, the scope for discussion on organic regulation remains limited in the proposed topics for amendments: it is good that the changes are limited, otherwise we risk losing consumer confidence in the bio label. However, we would like to draw your attention to a number of points: — in particular, do not change the size rules for poultry farming.
Filed in French · English published by the European Commission
Organic farming is subject to strict specifications. It is necessary to maintain a degree of rigour that can enable consumers to maintain confidence in these product specifications. Of course, the current proposal should not go further in relaxing the rules set out in these specifications.
Filed in French · English published by the European Commission
I welcome the fact that the current proposal remains measured. Nevertheless, I think it is essential to state clearly which should in no way go further! It would not be acceptable to open the door to new drifts. I firmly reiterate the need to maintain high standards of access to the open air and of limiting the size of poultry farms.
Filed in French · English published by the European Commission
We are pleased to have the opportunity to comment on the Commission’s proposal to amend Regulation (EU) 2018/848. We see a strong need and opportunity to simplify the rules for organic production, without watering down the rules, or changing the principles of organic production. The rules on organic production are perceived as difficult to understand and very detailed.
Filed in Swedish · English published by the European Commission
3.8 when poultry should have access to open-air runs, it is of course reasonable that poultry should be sufficiently fertilised before they should have access to open-air runs. However, the proposal to include this in particular in the Regulation is poor.
Filed in Swedish · English published by the European Commission
The Fédération des Spiruliniers de France calls for the removal, in the new European regulation on organic farming, of the restriction to nutrients of plant or mineral origin for the cultivation of spirulin in a closed environment. See our arguments attached
Filed in French · English published by the European Commission
MTK supports the European Commission’s proposal to update the Basic Regulation on organic production as it clarifies the existing legal basis and strengthens its internal coherence. Coordinated and structurally clearer provisions will make the whole easier to understand and support consistent implementation of regulation across all production sectors.
Filed in Finnish · English published by the European Commission
The product specification for the cultivation of spirulin in organic farming (AB) states that ‘only nutrients of plant or mineral origin may be used’. This results in a ban on the use of nutrients of animal origin.
Filed in French · English published by the European Commission
Hello, I am a producer in the eggs and poultry sector and I would like to congratulate the Committee on the abolition of the 48-hour withdrawal period in the event of allopathic treatment at zero time. It is very unfortunate that there is no proposal on organic food, and in particular the 100 % increase, which has a terrible impact on the welfare of hens and their egg productivity.
Filed in French · English published by the European Commission
Hello! For many years, small farmers use plant protection mechanisms against pests and diseases, with home-made botanical extracts derived from plants (including food!). They are suddenly no longer approved. However, a substance such as glyphosate was approved until 2033. This inconsistency demonstrates non-scientific criteria for the definition of safe or low-risk substances.
Filed in Spanish · English published by the European Commission
The current system of organic equivalence agreements with third countries has functioned effectively and should be preserved. Through these agreements, the European Union has carefully assessed the organic control systems of partner countries and recognised them as equivalent where they provide comparable levels of assurance.
Auravol is a production organisation made up of organic poultry breeders. We welcome the removal of the additional 48-hour waiting time for synthetic allopathic treatments. On the other hand, we consider that there is an urgent need to review the requirements related to the feeding of poultry.
Filed in French · English published by the European Commission
Chambers of Agriculture France points out that the primary objective of the reopening of the organic regulation was to clarify, under the equivalence regime, the labelling of products imported from outside the EU, in order to provide consumers with reliable information. This objective is maintained in the European Commission’s proposals.
Filed in French · English published by the European Commission
Please find enclosed our detailed response for this consultation. Summary: -We welcome the update to the eligibility criteria for groups of operators and the removal of new obligations concerning products used for cleaning and disinfection in processing and storage facilities.
AnimalhealthEurope, the association representing the manufacturers of veterinary medicines, vaccines and other animal health products welcomes the possibility to provide feedback to the call for evidence on targeted updates and simplification of the EU rules on organic production. We believe that this initiative is a good opportunity to improve the health and welfare of animals raised in organic production.
Organic poultry farming must remain small and open-air, counteract this by not allowing animals to enjoy a good living environment and go against the principle of animal welfare in organic farming. Furthermore, organic farming is characterised by the non-use of synthetic products, its link to the soil and the prohibition of GMOs in all its forms.
Filed in French · English published by the European Commission
Interfel is the French interbranch organisation for fresh fruit and vegetables. It brings together all the links in the sector, from upstream to downstream, including producers, consignors, wholesalers, importers, distributors and catering operators. In this respect, it contributes to interbranch consultation, to the economic development of the sector and to improving knowledge of the markets.
Filed in French · English published by the European Commission
CEVI, the European Confederation of Independent Vignerons, is the only organisation that represents and defends the interests of Independent Vignerons at European level. Independent Vignerons are entrepreneurs running their micro, small and medium-sized enterprises (SMEs), which are often family-run.
Filed in French · English published by the European Commission
As a breeding organisation of organic laying hens in Belgium (Avibel), I would like to ask for Article 15. 4 (c) of EU 2020/464 the higher floors are constructed in such a way that no faeces fall on the animals under them and are equipped with an efficient manure removal system.
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Hello, I have been an AB farmer for 4 years. I am very committed to the fact that organic farming complies with specifications that are demanding, clear and transparent for consumers. In order to achieve this, GMOs must, in my view, remain banned in organic farming, as must crops and/or livestock farming above ground. We also need to be firm on banning the use of synthetic products on a daily basis.
Filed in French · English published by the European Commission
ODNV is a cooperative grouping together French egg packaging centres, including organic eggs, in direct partnership with organic farmers or with production structures grouping organic farmers. We welcome the reconsideration of the addition of an additional 48-hour deadline for allopathic synthetic products with a legal 0-hour deadline.
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Synabio is the National Union of Organic Food Transformers in France, with more than 200 members, representing a combined turnover of more than EUR 5 billion. We understand and share the need to improve Regulation 2018/848 in a targeted and timely manner.
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Farmers, farmers and processors in mountain areas certified for organic farming, it is important to respond to this consultation. Firstly, he welcomed the fact that the current proposal was still relatively contained and that it should in no way go further in terms of reopening the organic rules.
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I enclose my opinion as an attachment below, and provide you with the elements here: the current proposal must under no circumstances go further – point of attention on poultry, need to maintain criteria for the open air and limited size of holdings, in order to distinguish itself from intensive holdings – sanctuarisation of the organic product specification on the principles of link to the soil, ban on GMOs, and…
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As an accompaniment to organic installations and transmissions, I am satisfied with the current proposal, which does not call into question the fundamentals of bio.I would like to ensure that the link to the soil, the ban on GMOs and the non-use of synthetic products can never be called into question.
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I am satisfied that the current proposal remains contained, but there is no question for me of it going beyond what has already been done. I am a producer of organic poultry and consider it essential to maintain outdoor criteria and contain livestock sizes in order to be able to distinguish myself from intensive production models.
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Hello, Despite a proposal that seems to be contained, it is important for me to reaffirm that it should not go any further. In order to distinguish itself from intensive poultry farms, it is necessary that the size of organic poultry farms be limited and that they remain in the open air. The link to the soil, the rejection of GMOs and synthetic products: these 3 principles need to be ring-fenced. Kindest regards,
Filed in French · English published by the European Commission
The current proposal remains correct but needs to stop there. Poultry must be able to be in the open air. It would be incomprehensible if the red label could be in the open air and not poultry in organic farming. Organic farming remains attached to the link with the soil to the ban on synthetic plant protection products. Intensive livestock farming must be limited.
Filed in French · English published by the European Commission
Thank you for this proposal, the lines of which must not change. In the case of poultry, access to the open air is essential and the size of the farm must not be akin to intensive farming NOT of obvious GMOs, nor of SYNTHESE products and LINK TO the indispensable SOL
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Dear Sir/Madam, I am fully satisfied with the limited nature of regulatory developments and I very much want them to remain so. Organic producers need strict specifications in order to promote the interests of their production among consumers: it is a guarantee of trust and credibility.
Filed in French · English published by the European Commission
The proposal to amend the organic product specification is contained and this is a good thing. But the alleviations and/or changes should not go further. For poultry, it seems to me essential that the outdoor criteria plus organic poultry should be maintained, as well as their size.
Filed in French · English published by the European Commission
Towards a Royal and Sustentable Bioeconomy as a Mexican national from farming and peasant families, my growth focused on soil health and now as an international reference in environmental biotechnology, I have closely observed the collateral damage of industrial agriculture.
Filed in Spanish · English published by the European Commission
I welcome the fact that the current proposal remains contained, but I think it should not go any further. With regard to poultry, I reiterate the need to maintain open-air criteria and limited lifting sizes in order to stand out from intensive models. I also attach great importance to the link with the soil, but also to the ban on GMOs and the refusal of synthetic products.
Filed in French · English published by the European Commission
Thank you for giving us this opportunity to give our feedback. Both proposed inclusions and exclusions are insightful. Specifically the clarity on group of operator criteria and consideration for revising equivalence with third countries are both technically and politically sound steps. However, there is still no clarity for a few things as follows: 1. Derogation process for third countries. In case of Livestock.
Rapunzel is a company in Germany working since 1974 with 100% organic products. Many organic projects were initiated by Rapunzel in the 1980ies and 1990ies especially in 3rd countries. One of them is in Turkey for organic dried fruits and nuts since 1976. Today it is a daughter company of Rapunzel Germany, where we have many insights in 3rd country organic production: 1. Art.
After more than 20 years of practical experience in the field of organic chicken fattening, I would like to make the following points for the future direction of the Organic Regulation and improving the competitiveness of organic farming: 4 m² of open-air areas for chickens for fattening are definitely too much. Even well-structured runs are never used by the animals at this level.
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Anglo American welcomes the European Commissions initiative to update and simplify the organic framework under Regulation (EU) 2018/848 and its implementing provisions. We support the objective of ensuring that organic farmers across the EU have access to a coherent, innovation-friendly system for the authorisation of products and substances compatible with organic production, in line with the EUs Organic Action…
The reinterpretation of grazing in organic farming in Germany and Austria leads to a depletion of competition in the EU. These stricter interpretations, based on a basic and implementing regulation which has not changed, constitute unfair competition if the current transposition/interpretation continues to apply in all other Member States.
Filed in German · English published by the European Commission
The organic product specification must remain demanding, which makes it valuable. Since the 1920s, organic farmers have responded to the product specification, so there is no question of calling it into question and alleviating it, in order to preserve our health and that of our environment. It is essential to enable organic farming to maintain its systemic dimension.
Filed in French · English published by the European Commission
Minimum total area and functional areas instead of minimum indoor and external surface! Themes: EU Implementing Regulation 2020/464 laying down detailed rules for the application of Regulation (EU) 2018/848, Annex I, Part III, specifies stocking densities, minimum indoor areas and minimum outdoor areas for pigs referred to in Article 10.
Filed in German · English published by the European Commission
I am opposed to the amendment of the EU organic regulation. It is important to maintain stability and continuity in organic farming practices, in order to maintain a relationship of trust with consumers, especially after having spent the most important period of crisis. The AB must push European agriculture upwards through its virtuous practices.
Filed in French · English published by the European Commission
It would be very important to return to the old withdrawal period when treating chickens against parasites. This is necessary for competitiveness, as the long waiting time causes very high costs and unnecessary bureaucracy. Wedding is an active animal welfare and would make a significant contribution to animal welfare, which is why we would also ask for more flexibility in the application.
Filed in German · English published by the European Commission
For the production of organic laying hens, it would be good to return to what it did before in terms of feeding. That is to say, reintroduce a percentage of conventional cereals into the milk in order to improve performance, whether technical or economic.
Filed in French · English published by the European Commission
With regard to the grazing obligation in organic farming under the EU Organic Regulation, I would ask you to reconsider it. I am a dairy farmer and I have learned from the last annual meeting of the dairy that the quantity of milk delivered by organic farms is steadily decreasing drastically, as farms are forced to return or abandon livestock farming, as the requirements cannot be met.
Filed in German · English published by the European Commission
Ecuador, referring to the current call for applications, raised the following points: 1. Eligibility criteria for producer groups 2. Regulatory equivalence, however, the European Union is requested to consider the comments submitted with regard to the criteria applicable to producer groups and the process of applying equivalence, in order to maintain trade flows from Ecuador and promote organic production in third…
Filed in Spanish · English published by the European Commission
Clear flexibility in parasite treatments, which should be replaced by antibiotic treatments, i.e. the 48-hour waiting period for eggs should be removed. This would significantly contribute to animal welfare. Pullets should be sufficiently mature before entering the open air. I doubt whether pullets need an open-air area before they are grown.
Filed in German · English published by the European Commission
A complete grazing obligation for all groups of animals without exception is not feasible for every organic holding. In our example, with 30 dairy cows plus rearing, the cows have a generous open-air area and daily green fodder. Cattle have access to grazing areas at all times during the growing season. However, the grazing area is not sufficient for all groups of animals.
Filed in German · English published by the European Commission
We are an organic family farm in Unterfranken, which I have been running together with my wife under the Bioland Directives since 1986. Our region is an area of arable farming, with permanent grassland scattered between them. We have taken over the farm with 15 tethered dairy cows in a limited village location and it has always been our need to improve the housing conditions for the animals.
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The Syndicat National des Accouveurs (National Association of Accouveurs (SNA)) brings together all breeding and access companies in France covering all the poultry species produced: broilers, laying hens, turkeys, palmipeds (ducks and geese), guinea fowls, game trees (pheasants, partridges, mallard ducks), pigeons and quails.
Filed in French · English published by the European Commission
The European organic regulation forms a key foundation for the success story of organic farming in Europe. Over time, however, the complexity and administrative workload for organic farmers have increased considerably, becoming a large burden for many family farms.
On compulsory grazing: On the subject of compulsory grazing, I cannot understand the EU: On the one hand, to specifically promote young farmers and organic farming, and on the other hand to force young organic farmers like me to leave organic farming through rules such as compulsory grazing from organic farming or entirely from livestock farming.
Filed in German · English published by the European Commission
The organic sector must be developed and its regulatory framework must also be developed. Today’s rules have been the basis for the success of the organic industry, but as the sector grows, the framework needs to become more smart, efficient and enabling.
Filed in Swedish · English published by the European Commission
We operate two pig fattening houses with partial coverage of the outside runs. These buildings were constructed approximately 10 years ago, in consultation and subsequent approval by the control body and control authority. The cover is approximately 90 % of the open-air area.
Filed in German · English published by the European Commission
Thank you for making suggestions here. We are managing an organic haymilk farm in Baden Württemberg. The holding has only grassland and the dairy industry attached to it. We are very unfortunate with the grazing requirement that organic farming in Germany must fulfil. While we can fulfil the grazing obligation, we are clearly at risk of animal welfare.
Filed in German · English published by the European Commission
Vi är glada för möjligheten att lämna synpunkter på hur förordning (EU) 2018/848 kan ändras och förenklas. Vi ser ett stort behov av och möjlighet till att förenkla reglerna för ekologisk produktion, utan att urvattna reglerna, eller ändra principerna för ekologisk produktion. Reglerna för ekologisk produktion upplevs som svåra att förstå och väldigt detaljerade.
As a laying hen farmer, several points should be corrected. Firstly, the 95 % BIO food with the use of amino acids derived from fermentation is a necessity, as our hens are carencised, with the result that hens are depleted, which has a detrimental effect on the image of our industry and on animal welfare, which must be a priority.
Filed in French · English published by the European Commission
Our producer organisation in Ecuador has approximately 1000 small cocoa producers that are grouped around a single parent organisation called UNOCACE. We currently have a single group certification of producer under the new EU 848 rules (for the 1000 members).
Filed in Spanish · English published by the European Commission
Since the entry into force of the first version, the EU Organic Regulation provides that an open-air area for organic pigs may be partially covered. In some cases, the word has often been interpreted as meaning that a maximum of 50 % of the open-air runs may be covered, together with exceptions for sows and piglet rearing.
Filed in German · English published by the European Commission
FEFAC welcomes the opportunity to contribute to the call for evidence for a targeted amendment of the Organic Production Rules. FEFAC supports the EU Commission action aiming at tackling unnecessary complexity in the current regulatory framework.
Organic Labelling is very important. The current information provided to customers today on organic products is not clear enough: the non-EU origin is just a small mark under the logo. 1-The Non EU origin should be made clear and big on the labelling 2-When transformation is not made in the EU it also should be clear.
We are an organic family farm that I have been running together with my wife since 1986. We are in the Eastern Lower Franconia and have taken over the farm in a closed village with 15 dairy cows tethered. Our concern has always been to improve the housing conditions for our animals. For example, since 1989 we have set up a summer pasture away from the farm for our young cattle, which we used for 10 years.
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1. According to the Commission’s current proposal, only one fattening poultry house with a maximum of 1 600 m² per farm should be allowed in future. Such a limitation poses existential challenges to many established and economically stable businesses. I would therefore like to urge that several houses of 1 600 m² each continue to be allowed.
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SNIPO – Syndicat National des Industriels et Professionnales des Eogufs is the trade union representing packaging centres and dovo-product manufacturers at French level. With 51 members in 2025, SNIPO accounted for more than 90 % of the volume of eggs marketed in France.
Filed in French · English published by the European Commission
Feedback of Ibérica de Sales S.A. on the Initiative Organic Production Targeted updates and simplification Ibérica de Sales S.A is one of the leading Rock Salt producers in Spain. Founded in 1932, Ibérica de Sales Rocks Salt is obtained from an underground Mine located in Remolinos (Zaragoza). Our Rock Salt deposit is the result of evaporation and crystallization of ancient seas through geological times.
The Aude Chamber of Agriculture wishes to draw the Ministry’s attention to three major challenges which today undermine the organic sectors, in particular the poultry sector. 1. Adapting the rules on the sexing of eggs to ensure the supply of organic pullets. The removal of crushing of male chicks is an important step forward in terms of animal welfare.
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Comité Européen des Entreprises Vins welcomes the opportunity to provide feedback as part of the open call for evidence on the initiative: Organic production rules. Hereunder suggestions to improve legislation related to equivalence agreements with third countries, administrative burdens, and technical production challenges. 1. TRADE ISSUES - Organic certification equivalence agreements I.
I have been an organic farmer in the production of organic wine and vines since 2017. It is important for me to rely on a strict product specification that has consumer confidence and makes it possible to differentiate my products. The reopening of the EU organic regulation should be limited to clarifying the labelling of products imported from outside the EU, in order to provide consumers with clear information.
Filed in French · English published by the European Commission
The European organic regulation forms a key foundation for the success story of organic farming in Europe. Over time, however, the complexity and administrative workload for organic farmers have increased considerably, becoming a large burden for many family farms.
We would like to take the opportunity of the reopening to ask for certain criteria to be changed, but warn that maintaining the requirements of the organic sector is very important, be it in terms of image, size of rearing, minimum rearing age, so as not to have low-range products with rapid growth contrary to quality signs or huge farms that are sensitive to health and degrade the image of BIO.
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The European Organic Certifiers Council (EOCC) gathering 74 Control Bodies and Control Authorities welcomes the European Commissions consultation in the frame of simplification of the regulatory framework for organic production. Please find enclosed the four main points for EOCC. EOCC is thankful for all efforts provided to achieve this important initiative.
Agricultural cooperation, which represents 800 French agricultural and agri-food cooperatives engaged in Bio, welcomes the targeted reopening of the Bio Regulation. It is appropriate to focus only on a few points which particularly penalise farmers and operators who hinder the development of Biological Agriculture, which must maintain a high degree of requirement. We identified 6 major topics: 1.
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Zoutman supports the Commissions objective to simplify the organic regulation. We also support removing salt from Annex I because its inclusion has created division within the salt sector, there is no possibility of reaching an objective consensus, and the European Parliament has already rejected related rules. Moreover, labeling salt as organic offers no real benefit to consumers and only causes confusion.
The German Food Trade welcomes the opportunity to comment on the initiative to update the EU Organic Regulation. There is a need for targeted adaptation on certain points, for example to ensure practicality, competitiveness and further development of the organic sector.
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K+S Aktiengesellschaft is the leading European salt producer, providing rock salt, vacuum salt and sea salt for consumers. K+S welcomes the European Commissions initiative to update and simplify the EU Organic Regulation 848/2018. A key priority must be to completely remove sea salt and other salts for food and feed from Annex I of the Organic Regulation 2018/848.
EuroCommerce, the voice of retail and wholesale sector, welcomes the opportunity to provide suggestions for updating the Organic Regulation (EU) 2018/848. We support the EUs ambition to promote sustainable food systems and maintain consumer trust in organic products.
A private operator very involved in animal nutrition and production in France, we would like to make a few contributions: 1. Allow 95 % organic feed for all poultry. The current 100 % organic rule leads us to loss of performance, animal welfare issues (which is counterproductive) and significantly discourages farmers. The future of the organic poultry sector is at the heart of this issue. 2.
Filed in French · English published by the European Commission
The Union des Industries de la Fertilisation (UNIFA) thanked the Commission for setting up this consultation on simplifying the rules on organic agriculture. We propose 4 measures: 1. A consolidated and accessible version of secondary acts To ensure a harmonised understanding and correct implementation in the Member States, we request the publication of a consolidated, up-to-date and easily accessible version of all…
Filed in French · English published by the European Commission
On behalf of the IG-Bio-Control Bodies of Austria, I would like to submit the following proposals within the framework of the simplification process for Regulation (EU) 2018/848. These proposals would lay the foundation also for a restructuring of the secondary legislation system and could contribute to greater clarity on specific interpretive issues.
FRSEA Pays de la Loire’s contribution to the development of the specifications for organic farming The FRSEA Pays de la Loire reaffirms its commitment to a strict specification that guarantees production that respects the environment, animal welfare and product quality. Organic farming is a demanding production method which must maintain its credibility and coherence.
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We support the utmost rigour in using the European Organic logo. The European logo should only be used by producers who comply with all the rules laid down in the Regulation and, in particular for important products from third countries, we consider it necessary to ensure reciprocity in the application of the rules in order to ensure fair competition in the organic market.
Filed in Italian · English published by the European Commission
ECOFI welcomes the Organic Omnibus and urges the Commission to use it to simplify and clarify the rules governing fertilisers and soil improvers in organic farming. Organic-based fertilisers are essential for maintaining soil fertility, nutrient availability and stable yields in organic systems, yet Annex II of Regulation 2021/1165 remains incomplete, inconsistently interpreted, and difficult to updatecreating…
As an organic winegrower in a short circuit since 2001 on 17 hectares, I consider that the organic product specification must remain as stringent as possible in order to maintain consumer confidence. When we started in 1998, no equipment was suitable for mechanically dehydrating, now there are plenty of materials, why not without serving, it is much less dangerous than pesticides.
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The Strategic Guidelines for Sustainable EU Aquaculture aim to enable the further development of aquaculture in the EU as a sustainable, competitive sector contributing to broader policy objectives. These guidelines aim to inform EU and national policy including the EU Farm to Fork and Biodiversity Strategies.
We have been an association of organic producers since 1991 in the Pays de la Loire region. We are made up of 1500 producers. Our Board is very attentive to the image and confidence of consumers in our products. For example, if there is a lack of fodder to feed our animals, we facilitate relations between members so that they can turn to each other’s hay.
Filed in French · English published by the European Commission
The SNIA supports the European Commission’s initiative to simplify the regulatory framework for organic production. To this end, the SNIA makes the following requests: (1) maintain the possibility of dying up to 5 % of non-organic proteins in complete feed (% expressed as dry matter) intended for monogastric animals, reared under the organic production method, which are: — Piglets up to 35 kg, – poultry with no age…
Filed in French · English published by the European Commission
As a short chain organic market garden, with secondary workshops of peasant bread and organic eggs, I consider that the organic product specification must remain as stringent as possible in order to maintain consumer confidence.
Filed in French · English published by the European Commission
I am writing to you to draw your attention to important aspects of the planned simplification of the EU Organic Regulation. The proposed changes concern in particular organic poultry farming and have a significant impact on animal welfare, economic viability and the future of many farms.
Filed in German · English published by the European Commission
BÖLW, the German Organic umbrella organization is grateful for the consultation on Organic Regulation and is pleased to provide feedback for a targeted opening of the Basic Regulation (EU) 2018/848. We also provide an impact assessment for the focussed amendments. Please find our input in the files enclosed (file 1: statement; file 2: impact assessment).
The Netherlands welcomes the offer by the Commission to submit proposals for simplification of the basic regulation without amending its core and purpose. As announced in the contribution by the NL at the joint meeting of the civil dialogue group, GREX members and ambassadors (24th of September 2025), please find our suggestions in writing enclosed.
Synalaf, a collective organisation representing the organic poultry sectors in France, thanked the European Commission for questioning the discussion for proposing targeted amendments to the European rules on organic farming.
Filed in French · English published by the European Commission
The Latin American and Caribbean Coordinator of small producers and workers in Fair Trade (CLAC) appreciates the Commission’s initiative to simplify Regulation (EU) 2018/848 and associated acts in order to facilitate its implementation for organic producers.
Filed in Spanish · English published by the European Commission
CNPO Contribution to the Consultation on the Revision of Regulation (EU) 2018/848 The CNPO, the French interprofessional organization for eggs, brings together all stakeholders in the sector, from hatcheries to distribution.
EUsalt strongly supports the Commission's stated objective to simplify the regulatory framework, remove unnecessary complexity, and reduce the regulatory burden for the agri-food value chain. In this spirit, EUsalt believes that deleting salt from Annex I is a targeted, simplifying measure that respects the European Parliament's veto from 2023, prevents market distortion, consumer Confusion and policy…
With the EU Organic Regulation, we in Europe have a set of rules that, on the one hand, protect the interests of consumers by defining organic farming standards. On the other hand, the EU Organic Regulation also lays down rules and requirements which provide a basis for farms to organise and develop their holdings. Business development requires long-term and reliable planning certainty.
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IFOAM Organics Europe is the European umbrella organisation for organic food and farming. With almost 200 members in 34 European countries, our work spans the entire organic food chain and beyond: from farmers and processors organisations, retailers, certifiers, consultants, traders, and researchers to environmental and consumer advocacy bodies.
EBIC welcomes the Commissions initiative to update and clarify the rules governing inputs authorised in organic production. Since the adoption of Regulation (EU) 2021/1165, several provisions (particularly in Annexe II) have proved difficult to interpret, inconsistently applied across Member States, or insufficiently aligned with existing EU fertilising and ABP legislation.
Feedback on the initiative for a targeted amendment to Regulation (EU) 2018/848. Südwestdeutsche Salzwerke AG strongly recommends that sea salt and other salts for food and feed be completely removed from Annex I of Regulation (EU) 2018/848. Salt is an inorganic and mineral compound that is typically extracted from underground salt and brine deposits or seawater. It is not an organic or agricultural product.
Fairtrade Deutschland welcomes the Commissions initiative to simplify the EU Organic Regulation and related acts to ease implementation for organic producers. The current regulation creates barriers to trade without improving the content or credibility of the EU organic certification, through increasing costs for certification, complicating market access for smallholder cooperatives supplying the EU with tropical…
Further to the contribution of La Filière Aquacole des Pays de La Loire (FAP). Competition from third countries is poorly experienced by spirulin producers as the AB label is not easily accessible to European spiruliners. Complexity of the organic specifications: The current specification for the production of organic spirulin is linked to that of seaweed.
Filed in French · English published by the European Commission
the new European regulation has only been in force for 4 years. I am surprised that a revision is taking place. I am absolutely convinced that the standards on animal welfare (size of bat, nb of animals per bat, bat equipment, outward walking acces and its fitting-out, etc.) remain at least at the same level, since they do not hinder production potential or performance quite the contrary.
Filed in French · English published by the European Commission
We have been organic since 1987. The EU Organic Regulation was only introduced later. We always have our cattle on the pasture. 13 years ago, we switched to full pasture and converted approximately 20 ha of arable land into pasture. In total, we now have around 30 ha of pasture around the farm. Although we have a lot of pasture on the farm, full grazing is a problem for us.
Filed in German · English published by the European Commission
The Filière Aquacole des Pays de La Loire (FAP), established in 2018, brings together almost 40 aquaculture professionals in the region: from detang fish farming to microalgae, innovative systems such as laquapland or recirculating production – excluding shellfish farming. The objectives of lassociation are to represent regional aquaculture sectors and to contribute to the development of sustainable aquaculture.
Filed in French · English published by the European Commission
Ladies and gentlemen, we call for the implementation of the grazing paper 2.0! Organic is more than pasture, bio-diversity, humus construction, no chemistry, circular economy, etc. Alternatives must also be allowed if no grazing is possible, e.g. walkyards, green feeding in the house, etc.
Filed in German · English published by the European Commission
ASPROCAN asks the Commission not to extend the recognition by equivalence and to consolidate the principle of full compliance with the EU standard as the only gateway to the organic name and its associated logo. This should be accompanied by an effective strengthening of traceability, inspection and sanctions to protect compliant producers and consumer confidence in the European seal.
Filed in Spanish · English published by the European Commission
As coordinator of GABB Anjou, I speak on behalf of my organisation’s board of directors, composed of 26 organic farmers and farmers, all types of production. It seems to us essential to be able to rely on strict tender specifications. This makes it possible to highlight organic products to consumers in order to differentiate them from other types of production.
Filed in French · English published by the European Commission
The Walloon sector, represented by the Working Party on Legislation led by Socopro, supports the opening of the basic act to resolve Herbaria, postpone the deadline for trade in organic products with 11 equivalent non-member countries and simplify certain formulations or administrative burdens.
Filed in French · English published by the European Commission
Ladies and gentlemen, i.e. the organic control body, we recommend the following changes in order to simplify and reduce red tape for businesses: 1. Extension of the certificate Part II, 1. List of products, the previous template for the certificate under Part II, optional particulars in the list of products, the categories: To include as additional categories products referred to in Article 30(5), (b), (i)…
Filed in German · English published by the European Commission
We have been wine-growing in organic production since 2020. It is important for us, our industry and our customers to rely on strict specifications that have consumer confidence and make it possible to differentiate my products. The reopening of the EU organic regulation should be limited to clarifying the labelling of products imported from outside the EU, in order to provide consumers with clear information.
Filed in French · English published by the European Commission
The Groupement des Agriculteurs Bio de Loire Atlantique (Groupement des Agriculteurs Bio de Loire Atlantique) (GAB 44) agrees that the regulation should be updated on the import of products from third countries following the order of the European Court of Justice and also to extend the recognition of the organic standards of third countries.
Filed in French · English published by the European Commission
ERPA is the European association representing rural poultry producers in Europe, including the sectors and producers of organic eggs and poultry for meat. ERPA warmly thanks the European Commission and Commissioner Hansen for proposing to reopen the regulation on organic farming for targeted amendments, as the organic poultry sector needs this.
1. Inspection: Two percent sampling is required. · Proposed Solutions: As per my understanding two percent sampling during inspection is not required because there is a provision of High-Risk crops and High-Risk Country and Product will be tested before export at origin and at destination. This is also not clarified whether these two percent samples will be tested individually or composite sample. 2.
We welcome the initiative of simplification of the current organic regulatory framework with the aim of reducing administrative burden and to remove unnecessary complexity and burden for the organic sector. Withdrawal period following veterinary medicinal treatment We propose to remove the minimum withdrawal period of at least 48 hours when use of veterinary medicine products with zero withdrawal period (Reg.
Thank you for the opportunity to propose recommendations for simplification in the regulation for organic production and labelling of organic products. When the EU aims for at least 25% of the total agricultural land to be farmed organically by 2030 actions are needed to obtain this goal, not only at farm level.
AnimalhealthEurope, the association representing the manufacturers of veterinary medicines, vaccines and other animal health products welcomes the possibility to provide feedback to the call for evidence on targeted updates and simplification of the EU rules on organic production.
To the right person, companies must check and ensure that their suppliers of organic food are organic certified. The checks shall be carried out at least before the first delivery, and thereafter at least once a year or by appropriate changes. Within the organic area, a supplier is defined as the undertaking certified for organic farming at the address from which the consignment is physically dispatched, i.e.
Filed in Danish · English published by the European Commission
The request for clarification of the provisions on the need for crop rotation in Regulation (EU) 2018/848, Annex II, point 1.9.2., indicates that soil fertility and biological activity should be maintained and increased through the use of multiannual crop rotation. This provision is very general and may be interpreted differently by the Member States, with the risk of uneven application of the rules.
Filed in Polish · English published by the European Commission
Dear Commission, Thank you for the opportunity to provide comments on the matter of targeted amendments in the organic production rules. Please find the comments of the Ministry of Agriculture and Forestry of Finland below. We welcome the Commissions initiative to simplify the rules on withdrawal periods following the use of chemically synthesized allopathic veterinary medicinal products.
We are pleased to have the opportunity to comment on how Regulation (EU) 2018/848 can be amended and simplified. We see a great need and opportunity to simplify the rules for organic production, without watering down the rules, or changing the principles of organic production. Organic production rules are perceived as difficult to understand and very detailed.
Filed in Swedish · English published by the European Commission
OPTA Europe is the membership organization representing the interest of European Organic Processing and Trade companies. Its members account for a large share of total EU trade and processing of organic products and play an essential role in an efficient supply chain.
Ladies and gentlemen,it should be possible for organic farms in the EU to manage their own organic products and not forcing them to eliminate or conventionally continue to manage their animals because of the grazing requirement (all animals on pasture). Farms that have been organic for decades now have to stop now because they do not bring all animals to pasture!
Filed in German · English published by the European Commission
Many of our customers are spread across southern France, with small units ordering between 250 and 1500 chicks and different strains depending on the needs of their markets. If our sales volume does not justify a batch of breeding animals, these customers will no longer be delivered.
Filed in French · English published by the European Commission
Plant-Based Foods Europe welcomes the opportunity to provide feedback on the targeted amendments to the EU Organic Production rules. Through the Vision for Agriculture and Food, the Commission acknowledges the organic sector as a cornerstone of a sustainable, resilient and competitive European food system.
Dear Mr Hansen, I am writing to me here as a successor to the farm, which has now been on the third generation dairy farm for exactly four and a half months. I am writing this out of frustration and fear, as I don't know what my future should look like if full grazing for all animal groups comes. My holding is in the middle of the town, so there is no possibility of bringing the dairy cattle to pasture.
Filed in German · English published by the European Commission
— We have spent on a food of 100 % AB in laying hens, which poses real problems, is it possible to reverse this constraint? In addition, the same trend is planned for the supply of pullets at the end of 2026. This constraint will have an even greater impact on the feeding of young animals and will result in the risk of digestive disorder and thus deterioration of animal welfare.
Filed in French · English published by the European Commission
Organic land has been deeply rooted in the market and organic farming since 1991 with a range of 100 % organic food. We see a need for adaptation in organic livestock farming to enable further development and future competitiveness. Adapting the Regulation for pig and poultry farming can address current challenges while maintaining and strengthening high animal welfare and environmental standards.
Filed in German · English published by the European Commission
K + S France, producer of food salt under the Cerebos, Cédo or NutriKS brands, welcomes the revision of Regulation (EC) No 2018/848, which is seen as an opportunity to clarify the status of salt with regard to organic certification. The salt is above all a mineral, not a living product.
Filed in French · English published by the European Commission
Hello Elevator of laying hens in AB in Drôme (France). We have spent on a feed of 100 % AB in laying hens, which poses real problems with production performance, is it possible to reverse this constraint? — We are experiencing problems in laying hens as a result of natural light on chicken farming, and therefore an inability to stimulate animals for batches starting in summer or early autumn.
Filed in French · English published by the European Commission
I represent The Finnish Organic Food Association Pro Luomu, which is the organic sectors national co-operation organisation. Pro Luomu promotes the production and consumption of organic food in Finland. Our members represent the whole organic value chain in Finland from farmers to retailers. We are very pleased that the Commission is opening the basic regulation in a limited way.
Oenodia, a French company based in Pertuis, has developed the eco-selective tartaric stabilisation (STES) with the Institut national de recherche pour llagriculture, lalimentation et lenvironnement environnement (INRAE), using the delectrodialysis process, which allows the wines to stabilise effectively, accurately and ecologically.
Filed in French · English published by the European Commission
Feedback to the European Commission on Organic production rules targeted amendment (Regulation (EU) 2018/848), from DEBIO, control body for organic production i Norway, 18th of November 2025. We welcome the initiative of simplification of the current organic regulatory framework with the aim of reducing administrative burden and to remove unnecessary complexity and burden for the organic sector.
It is really necessary to have a waiting period for eggs after a worm treatment, whereas free-range and barn eggs do not have them. First, alternative methods are usually not used to achieve the objective, and if this is then the financial damage is enormous. Why are these funds not released for animal welfare reasons, as in the open air area without waiting time?
Filed in German · English published by the European Commission
Euroseeds welcomes the Commission's commitment to boost EU competitiveness. Simplification should contribute by aiming to improve the coherence and clarity of EU laws and to rationalise regulatory burdens and administrative costs for stakeholders through smarter and more effective implementation of EU policies and legislation.
Chambers of Agriculture France points out that the primary objective of the reopening of the organic regulation is to clarify the labelling of products imported from outside the EU under the equivalence regime, in order to provide consumers with reliable information and that this objective must continue in the European Commission’s proposals.
Filed in French · English published by the European Commission
I would like to thank you for taking part in the consultation. I consider that we should not favour the industrialisation of organic production or, failing that, it would be necessary to create an organic label label for small farms.
Filed in Spanish · English published by the European Commission
Without knowing the background on the revision I found the latest update concerning who is allowed to revise information in a COI was to the worse. It has made the whole process getting a COI confirmed slower, more inefficient and also includes more parties than before. As I got started in TRACES with COI doc's, as an importer, I was allowed to revise the information in box 13 and 17 as an example.
SEASALT Europe appreciates the opportunity to contribute to this Call for Evidence regarding the targeted amendment of the Organic Production Regulation (EU) 2018/848. We highlight that a significant share of our members holds certification under Regulation (EU) 2018/848. Since the inclusion of "sea salt and other salts for food and feed," approximately 100 operators can be consulted on the TRACES system.
For 23 years, we have kept pigs in reconstructed old buildings in accordance with EU organic and natural land directives. There are several variants of houses on our farm: Houses divided according to the benchmark values for indoor and outdoor areas, houses with smaller indoor and larger outdoor areas (in compliance with the required total area/summary rule), open-air runs without roofing, areas with partial cover…
Filed in German · English published by the European Commission
APEDA under the Ministry of Commerce & Industry, Government of India as the Secretariat of Indias National Programme for Organic Production (NPOP) welcomes the opportunity to provide feedback on the European Commissions Call for Evidence on the targeted amendment of Regulation (EU) 2018/848. India has been a consistent and long-term supplier of organic products to the EU.
AöL e.V. is advocating for changes in the following areas, which are prioritized in two categories - those that are of importance to all organic processing companies, and those that are relevant to specific processing sectors. Importance to all organic processing companies: 1. Amend Article 24 (1) (g) to regulate cleaning agents and disinfectants based on criteria more effectively 2.
FEAP welcomes the initiative to introduce targeted amendments to Regulation 2018/848. Despite a supposedly supportive regulatory framework, the fish farming organic sector continues to face significant barriers. As a result, many fish farmers who have bet on organic production have struggled to maintain or expand their organic lines, leading to stagnation or even a noticeable decline in overall output.
Requirement ® is Sweden’s best-known label for sustainable food. We have developed rules for organic production since 1985. At the end of 2024, just over 4000 companies were KRAV certified. We are pleased to have the opportunity to comment on how Regulation (EU) 2018/848 can be amended and simplified.
Filed in Swedish · English published by the European Commission
I operate an organic laying hen farm with 1700 animals, 38 years old. My feedback is: 1. Rubble cure with flum evening or the like should be possible again without waiting time, the eggs must be able to continue to be sold as organics during the worm cure.
Filed in German · English published by the European Commission
Yara welcomes the initiative to update and simplify the EU Organic Framework. Yara would like to bring the following points to the attention: 1) addition of definitions for certain key terms, 2) introduction of simplified authorisation procedure for inputs based on EGTOP recommendations and stakeholder submissions, 3) preparation for the inclusion of microbial inoculants and plant bio-stimulants, and 4) expansion of…
Europatat, representing the European seed and ware potato trade, welcomes the opportunity to provide feedback in response to the ongoing consultation. While we support the Commissions intention to clarify organic production rules and simplify certain procedures, we wish to highlight serious concerns from our members regarding the declining interest in organic potato production.
Belki NV poultry lachterij, established in Aalst Belgium, represents a 70 bio meat chicken breeders located throughout Belgium and accounts for an annual production of around 2.5 million organically produced bio meat chickens. We would like to ask that the rules on the density of 21 kg/m² be adapted to a fixed number of chickens per m², e.g. 10 chickens/m².
Filed in Dutch · English published by the European Commission
Hello, it is important to keep the possibility of having 5 % non-organic protein in piglets’ diet. This favours the health of piglets with a better digestion of food. It would be good to recognise and accept the rearing of pigs on straw and thus the areas covered.
Filed in French · English published by the European Commission
Call for data from the European Commission organic production: simplification and specific updates of comments from the Union of Farmers’ Unions Transparency Register 643875852019-50 Union of Unions appreciates the European Commission’s efforts to simplify organic production rules and reduce administrative burdens, pending knowledge of the legislative texts.
Filed in Spanish · English published by the European Commission
Dear, Thank you for the possibility to make suggestions for the simplification of the basic act. 1. We would like to suggest to incorporate Regulation 2023/2419 on petfood into the basic act. Motivation: scope of regulation 2023/2419 is limited to labelling of petfood. No control, certification rules, etc. are set for petfood. For clarity better to have all the basic rules in one regulation. 2. Modify Art.
As operators in the French organic sheep sector, we would like to draw your attention to two critical points of the current specification (Regulation (EU) 2018/848) which threaten the economic and technical sustainability of dairy farms in the North Occitanie basin.
Filed in French · English published by the European Commission
Derogations in new EU regulations are not very clear for third countries. For eg., Article 25 of EU 2018/848 says 'Authorisation of non-organic agricultural ingredients for processed organic food by Member States'- which implies that it is applicable on Member States only, while its sub-point 4 talks about third countries.
Contribution to the revision of the production rules for organic laying animals In the context of the revision of the production rules for organic laying, we would like to submit the following elements for consideration: 1.
Filed in French · English published by the European Commission
Justification for the Revision of Regulation (EU) 2018/848 on Organic Production Finlands Perspective The European Commissions intention to revise Regulation (EU) 2018/848 presents a timely and necessary opportunity to address regulatory provisions that have proven problematic in practice and that hinder the development and competitiveness of organic production, particularly in Nordic conditions.
The following are the various remarks and observations for my production: — We have spent on a food of 100 % AB in laying hens, which poses real problems, is it possible to reverse this constraint? In addition, the same trend is planned for the supply of pullets at the end of 2026.
Filed in French · English published by the European Commission
BIOCOOP is a cooperative launched in 1986, which brings together 740 Bio stores in France with a turnover of 1.6 billion d, with 100 % of organic food products, and 19 100 % organic agricultural cooperatives which collects from 2 700 farms. We are sourcing from 800 suppliers for centralised purchases and each local sourcing store from a total of 9 000 producers or craftsmen.
Filed in French · English published by the European Commission
1.Enhancing the taking into account of the realities of producers in third countries. Some requirements need to be simplified, namely realistic derogations for small producers: — Infrastructure requirement – crop rotation requirement – Requirement to visit the whole production unit including non-organic parcels – Organic turnover requirement (EUR 25 000) low for high value-added products 2.
Filed in French · English published by the European Commission
The full grazing obligation necessarily leads to the extinction of cattle rearing for entire regions because it is not possible to grant grazing access without exception as agricultural holdings for each group of animals as a result of small-scale structuring, local areas and climate change.
Filed in German · English published by the European Commission
The rules for organic production are unfortunately often perceived as difficult to understand, costly to apply, and overly detailed. The proportion of organic laying hens in Sweden has decreased from around 18% to just over 10% in recent years. This proportion will likely further decline when the transition period for organic pullet production ends and the rules on outdoor access for pullets come into force.
One of the main observations to be submitted, which are mainly linked to the certification of producer groups, i.e. that, in our context, a small Bolivian wild producer or collector should be considered suitable for forming a group with 5 ha of land or an annual income of EUR 25 thousand, is to remove the opportunity to be part of a certified organic production system, in addition to the need to produce a series of…
Filed in Spanish · English published by the European Commission
Hello, I am a farmer of organic laying hens and I am in favour of the simplification of Regulation (EU) 2018/848 on organic production. I will prove to you my experience in the evolution of the 2022 regulations. The most negative dimpact point for me breeder and for my laying hens was the shift from a 95 % organic feed to 100 % organic feed. This has been disastrous and for several reasons: 1.
Filed in French · English published by the European Commission
Established since 8 as manager, my land and production have been certified under organic farming for almost 6 years. This choice is based on my convictions of protecting nature, soil, the environment and the hope that they will enable future generations to live in a less polluting world.
Filed in French · English published by the European Commission
Simplication would be achieved by: — the abolition of the derogation for the dehorning of bovine animals. In many cases, this constraint, particularly in milk cattle, leads to decorations (a procedure which is very complex and not intuitive). — in the organic communication, the claim without pesticides should be highlighted. — The exit of small calves is often complex due to the climate.
Filed in French · English published by the European Commission
For organic pig farming: The terms currently used, such as indoor area, outdoor area, open air area and net area, lead to unnecessary complexity in consulting, planning and checking. Nor do they meet the natural needs of pigs. Modern rearing systems, which divide the minimum total area into functional areas, provide better conditions for pigs and improve animal welfare.
Filed in German · English published by the European Commission
As the Federal Association for Organic Pig Farming, we are concerned about the health of our piglets if conventional protein feed (potato white) which is currently permitted can no longer be used. Although currently only 3 % of this feed in Germany (2024: 5 %), the amino acids of potato protein contribute a large proportion to the supply of piglets.
Filed in German · English published by the European Commission
Hello, Les Fermiers de Loué, as a recognised production organisation for organic eggs and chickens, thanked the EC for reopening the EU BIO rules. While the market for eggs lacks organic eggs and the prices paid to producers are correct, producers stop (cf. data from the Bio Agency and certifying body). Why?
Filed in French · English published by the European Commission
1. Allow more rearing space for poultry (Gallus gallus) per production unit. 2. Allow 5% conventional protein over a longer transition period than until 2027, to ensure a supply of high-quality proteins until other protein feed becomes available. 3. Introduce negative lists instead of positive lists for permitted disinfectants and cleaning agents 4.
Compulsory grazing for all groups of animals in cattle must be abolished. The free-range housing with open-air areas has so far been compliant and the construction of the house has been supported by EU funds at the farm level. Account must be taken of regional circumstances, e.g. the small division in Bavaria/Franken. Organic farming must not be reduced to the performance of grazing.
Filed in German · English published by the European Commission
The requirements for waiting times for synthetic allopathic products and for the origin of animals have a strong negative impact on the organic milk sheep sector. There are many inconsistencies in these points with the fundamental principles of organic agriculture: animal welfare, grazing as soon as time allows, reduction of inputs.
Filed in French · English published by the European Commission
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