EU consultation
14 submissions from 14 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 21 submissions on this file. Shown here: the 14 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
9 submissions from industry — companies and their trade associations — against 4 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 2.3 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
The file, right now
The consultation closed on 24 Aug 2026 — it ran from 27 Jul 2026.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Implementing regulation.
14 positions
· · filed 24 Aug 2026 · source
This act concerns products from non-EU countries certified as organic that are considered to be high-risk due to their involvement in major, critical or repetitive cases of non-compliance that affect their integrity or their production.
Filed in Italian · English published by the European Commission
Stellungnahme Zum Entwurf der Durchführungsverordnung – Ares (2026)7374948 zu Hochrisikoprodukten Der BÖLW begrüßt grundsätzlich eine risikoorientierte Bio-Kontrolle. Allerdings kritisieren wir, dass die Kriterien für die Festlegung von Hochrisikoprodukten nicht transparent und auch nicht sachlich nachvollziehbar sind. Das ist aber der entscheidende Punkt für eine Risikobewertung.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Eurodom welcomes the principle of this project, which for the first time identifies organic risk product/third country combinations and applies reinforced controls, including prior to export. Eurodom reiterates, however, its opposition in principle to maintaining the equivalence regime for the recognition of third-country organic production rules, and its request for a transition to a compliance regime, which is the…
Filed in French · English published by the European Commission
COLEAD RESPONSE TO CALL FOR FEEDBACK ON HIGH-RISK ORGANIC AND IN-CONVERSION PRODUCTS FROM NON-EU COUNTRIES – DETAILED LIST (Ares(2026)7374948) Brussels, 24 August 2026 The Committee Linking Entrepreneurship-Agriculture-Development (COLEAD) thanks the European Commission for the opportunity to comment on this draft Regulation on behalf of our members.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Requirement ® is an organic label in Sweden that is recognised by 99 % of Swedish consumers. We have developed rules and offered certification for organic production since 1985. In several areas, particularly in animal welfare, biodiversity, social responsibility and climate, rules go beyond the EU organic regulation.
Filed in Swedish · English published by the European Commission
The Aegean Exporters Associations (AEA) is an exporters organisation operating under the framework of the Turkish Ministry of Trade, representing exporting companies across a wide range of sectors. One of our key responsibilities is to support the competitiveness of Turkish exports and to contribute to the identification and removal of unnecessary barriers to international trade.
The Fair Trade Movement (830+ Fairtrade organic producer groups worldwide, ~800,000 smallholder and 50,000+ worker families) comments on the draft Implementing Regulation listing high-risk organic/in-conversion products from third countries and their control rates (Art. 8 of Delegated Regulation (EU) 2021/1698). Reg.
· · filed 23 Aug 2026 · source
The AOI appreciates the opportunity of consultation. Suggest that such consultations, like on the list of HR CC and on the additional measures to be taken are regular, institutionalised, annually, could be laid down in this implementing regulation.
The Banana and Plantain Cluster of Ecuador fully recognises the importance of robust controls to safeguard the integrity of organic production and shares the European Commissions objective of ensuring that products placed on the EU market comply with the applicable requirements.
Ecuador recognises the importance of strengthening controls aimed at ensuring the integrity of organic products and, in this context, submits to the European Commission information regarding organic bananas originating in Ecuador.
Filed in Spanish · English published by the European Commission
FRUCOM represents European traders, importers, agents and brokers across a wide range of agricultural commodities, including dried fruit, edible nuts, peanuts, processed fruit and vegetables and processed fishery products. We would like to present our concerns on how the products are included in the list concerning high-risk organic products and products in conversion.
· · filed 20 Aug 2026 · source
BioNederland is the Dutch association for organic trade and processors. We welcome the possibility to give our reaction on the Draft implementing regulation - Ares(2026)7374948 and its Annex - Ares(2026)7374948.
The controls are important and are intended to be an important step in the process of importing into the EU. However, as in the EU itself, it is overlooked that only a small proportion of agricultural land is organically farmed and that the influence of the conv. Agriculture is almost overpowered. It is wrong here to prefer to EU consumers that organic produce should or must always be free of pesticides.
Filed in German · English published by the European Commission
The proposed Regulation strengthens controls on high-risk organic products imported from third countries. However, I believe that the European Union should move its focus from detecting non-compliance at the border to preventing non-compliance before products are exported.I propose the creation of an EU Organic Digital Compliance Platform, a mandatory digital Pre-Qualification system for all operators in third…
Filed in Greek · English published by the European Commission
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.