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In the EU, the words “organic” or “bio” on a food product are not free marketing language: they are reserved by law to operators certified under Regulation (EU) 2018/848. Using them without certification is an infringement, and the most common mistake newcomers make is to think the first step is the green leaf logo. It is not. The first step is to register with the right control body and prepare the documentation that proves your activity complies. This article sets out where to start.
What Regulation 2018/848 certifies, and who needs it
Regulation 2018/848 governs the production and labelling of organic products across the EU. Certification is required for any operator that produces, processes, stores, distributes, imports or markets organic products, in one of these roles:
- Agricultural producer (crops or livestock), subject to a conversion period.
- Processor that manufactures or packs organic product.
- Importer from third countries, receiving goods with a Certificate of Inspection (COI) validated in TRACES.
- Distributor or warehouse that handles or re-labels organic product.
Each role has a different scope and set of requirements, and that shapes the whole file. A shop that only sells pre-packed, pre-labelled product without handling it is usually exempt; as soon as there is re-packing, splitting or importing, certification is mandatory.
First step: your control body
In Spain, organic certification is not run by a single national body but by regional control bodies and authorities. The first step of any file is to identify which one applies, based on the address of the activity, because the application form, the annexes and the procedure differ. Andalusia works through the CAAE (control code ES-ECO-xxx-AN); Catalonia through the public authority CCPAE (ES-ECO-019-CT); Valencia, Navarre, Murcia and other regions have their own bodies. Picking the wrong body, or filing another region’s form, delays the file from day one. One thing inspectors always check: the site address must match across your prior administrative registrations and the organic application.
The activity description: the key document
The centrepiece of an organic file is the description of the organic activity (memoria). It sets out, and proves, how your operation guarantees the organic status of the product: operator data and scope, product types and origin, flow diagram, procedures for receipt, storage, processing and dispatch, supplier control, import management where relevant, prevention of mixing and contamination in shared facilities, traceability, mass balance and the system of records. If the operator has not yet started the organic activity — common for an importer not yet validated in TRACES — the initial audit is “prior to activity”: you present the documentary system and the record templates, explaining that operations have not begun. That is an expected situation, not a gap.
Importing organic into the EU: COI and TRACES
If you import organic product from outside the EU, each consignment requires prior notice to the control body, the origin supplier’s conformity certificate and a Certificate of Inspection (COI) validated in the TRACES system under Delegated Regulation (EU) 2021/2306. Goods are not released from customs until the relevant official clearance and signatures are complete. This plane cannot be improvised: without validation in TRACES there is no organic import.
Organic labelling: the EU leaf and the control-body code
Only once certified may you use the EU organic logo (the “Euro-leaf”) together with your control-body code (ES-ECO-NNN-CC) and the indication of where the raw materials were farmed. It does not replace general food labelling: Regulation (EU) 1169/2011 still applies in parallel. If you are entering the EU with food, the same market-access logic applies to other categories — see our guide on selling food supplements in the EU.
Frequently asked questions
Can I use the organic logo as soon as I apply?
No. You may only label and market the product as organic, and use the EU leaf with your control-body code, once certification is granted. Applying is not enough.
My product is certified organic in the US or another country. Is that valid in the EU?
Not automatically. Organic status must be recognised under the EU regime — typically through an equivalent country arrangement or a COI validated in TRACES on import. A non-EU organic certificate on its own does not let you sell as organic in the EU.
How ASC Services helps
We handle your organic certification end to end: we identify your control body, draft the activity description and the application with its annexes ready to sign, prepare the audit with a clear map of what you have and what is missing, and manage third-country imports (COI/TRACES). Whether you are a producer, a processor or an importer, we order the file so you pass the inspection first time. Talk to us through our contact page or explore our consultancy services for regulated products.