EU Proposal COM(2025) 780 Reshapes Organic Labelling Rules for Imported Products

The European Commission has presented Proposal COM(2025) 780 final, aimed at updating Regulation (EU) 2018/848 on organic production and labelling. The initiative focuses in particular on the labelling regime for imported organic products, introducing clarifications on the use of organic terms and redefining the role of the EU organic logo.

The proposal responds directly to the recent judgment of the Court of Justice of the European Union in Case C-240/23 (Herbaria Kräuterparadies II), which interpreted the current regulation in a restrictive manner. In that ruling, the Court concluded that products imported under the equivalence regime may not use the EU organic logo nor, in principle, organic production terms if they do not fully comply with EU organic production rules. According to the Court, the EU organic logo constitutes an official certification of full compliance with the EU organic model, and its use for equivalent products could undermine consumer trust and distort competition.

This interpretation exposed significant legal uncertainty for operators and authorities, as well as the risk of trade disruptions, particularly for products originating in third countries where national legislation requires the use of organic terminology on labels.

To address this situation, the Commission proposal clarifies Article 30 of Regulation (EU) 2018/848, establishing that the terms “organic”, “bio” and “eco” may be used both for products fully compliant with EU rules and for products imported from third countries whose production and control systems are recognised as equivalent under Article 45. At the same time, the prohibition remains for products that do not fall under either regime. This approach aims to align EU legislation with the Codex Alimentarius guidelines and avoid excluding legally organic products from the EU market.

The most substantial change concerns the EU organic logo, through a complete revision of Article 33. The proposal redefines the logo as a mark reserved for products that either fully comply with the EU organic rules or meet additional requirements reflecting the structural principles of the EU organic model. Imported products under equivalence may only use the logo if they comply with a new set of reinforced criteria laid down in Annex VII, covering key elements such as soil-based production systems, animal welfare standards and processing practices with minimal artificial inputs.

The proposal also adjusts the obligation to display the EU organic logo on packaged organic foods produced in the EU, introducing exceptions where products contain a significant proportion of equivalent ingredients that do not meet the additional requirements. In parallel, the Commission proposes to extend the recognition of equivalent third countries until 31 December 2036, ensuring continuity in international trade while the new framework is implemented.

Overall, the proposal introduces a clear conceptual distinction in organic labelling: organic terms are linked to recognised equivalence, while the EU organic logo is reserved for products closely aligned with the EU organic production model. With this reform, the Commission seeks to reinforce consumer confidence, provide legal certainty and preserve the added value of the EU organic label, without compromising the functioning of global organic supply chains.

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