We have just received confirmation from Defra that COMMISSION IMPLEMENTING REGULATION (EU) 2020/2196 recognising the UK Control Bodies for the purpose of trade in organic products has been published today. The OF&G (Scotland) control body code will be GB-BIO-190. OF&G (Scotland) have now been given access to TRACES NT, the online system for creating CoIs (Certificates of Inspection) for imports into the EU.
There is further guidance on exporting to the EU and Northern Ireland but please contact your Certification Officer if you need further guidance on exporting goods from GB to the EU or moving goods from GB to NI.
The UK Government has announced a 3 month easement (grace period) for goods moved from GB to NI for supermarkets and their trusted suppliers. These goods will not require CoIs until 1st April 2021. Other goods (not destined for NI supermarkets) moving from GB to NI will need an EU CoI on TRACES NT from 1st January 2021.
To determine if you are eligible for authorised trader status and to register please consult the guidance on Gov.uk.
Note that this grace period only applies if you have completed the registration process. You need to email your completed authorised traders form to Defra by 17.00 pm (GMT) on 28 December 2020.
Organic goods will need to follow the regulations set out for each commodity type under this easement, please see the guidance on gov.uk for further details. As this is not an organics specific scheme we are unable to directly answer questions on the details of the scheme. Please email firstname.lastname@example.org with any issues and your completed forms.
We would also like to clarify that the 21 month transition period for labelling enforcement in GB does apply to organics. This is to allow businesses to use up existing labelling and make the necessary changes by 30 September 2022.
We will issue further guidance on this as soon as we are able
Exporting to NI, EU, EEA and Switzerland requires TRACES NT Organic Exports to NI, the EU, the EEA and Switzerland require you to be registered on TRACES NT
TRACES NT is now live so you should apply without delay.
When you apply, your application will go to the OF&G (Scotland) Certification team for validation. If you have any queries please contact your Processing Certification Officer (CO) in the first instance.
SOPA Members who wish to export to the NI, EU, the EEA and Switzerland from the 1st January 2021 need to meet 3 requirements under Regulation 1235/2008.
1. your business needs to be certified by OF&G (Scotland) for exporting. If you do not have a current valid organic certificate for export, please contact your CO directly via email detailing the organic products you intend to export along with confirmation of the statements below that relate to your business;
- Exporting to EU states
- Exporting to Non - EU states
- Exporting to EU and Non - EU states
2. As of 23rd December (today), register your business as an exporter with TRACES NT. Once verified this will enable the completion, signature & stamping of EU CoIs for relevant exports by OF&G (Scotland). To access TRACES NT click here.
3. You must produce a Certificate of Inspection (CoI) signed and stamped by OF&G (Scotland) for each consignment* exported to the EU, the EEA, Switzerland or NI. Failure to provide a valid accompanying CoI at the port will mean that the products will lose their organic status and have to either be destroyed or sold as non-organic.
If you require a CoI please forward all the relevant information to your SOPA Processor CO via email.
Defra have stated that organic imports to GB from the EU, EEA or Switzerland have a six month grace period and do not require a CoI until 1st July 2021 and organic businesses in NI will be able to continue to send organic goods to GB without the need for a CoI. We are seeking clarification on this as it is not equitable and potentially hampers UK organic trade routes.
*A CoI is issued by the exporter’s organic certification body for each consignment of organic food and feed products entering the EU, the EEA and Switzerland, before the product leaves the country of export. Each CoI is then checked on arrival into the EU, the EEA and Switzerland, by the port authorities to ensure the goods arriving match the description on the CoI. Provided the information is correct, the port authority will ‘endorse’ the CoI and the goods are allowed to enter these countries. If the information on the CoI is not accurate, incomplete or a CoI is not available for a consignment, the goods are not permitted to enter as organic.
Grace period for Organic Exports from GB to NI:
Authorised Trader Registration RequiredOrganic goods sold by supermarket and trusted supermarket suppliers to Northern Ireland (NI) have a three month grace period ending on 1st April 2021. During this grace period supermarkets and trusted supermarket suppliers do NOT need a CoI (Certificate of Inspection) for organic products, but they must be Authorised Traders.
A trusted supplier is any business that independently moves its products from GB to NI, for sale in NI stores and supermarkets.
This grace period exemption does not apply to wholesale supply chains.
During the grace period, supermarkets and their suppliers will need to be registered with the NI Authorised Trader Scheme before 28th December 2020. Registered Authorised Traders do not need a CoI during the grace period.
Register as an Authorised Trader here before 28th December 2020.
If your business is eligible for the NI Authorised Trader Scheme but you do not apply within the given time frame your business WILL NOT qualify for the 3-month easement. Instead you will need to implement CoIs for organic goods exported to NI from GB from the 1st January 2021.
The guidance is complicated so it is your responsibility to check your eligibility and responsibilities. For full details please consult the UK Government Guidance here. Defra have indicated that they will attempt to respond to all emails within 2 working days. The list of registered GB eligible suppliers is due to be sent to the Commission on 31st December with NO amendments possible after that date.
If your business does qualify for the NI Authorised Trader Scheme please attend to your application as a matter of priority to ensure your business is on the easement list before the Monday 28th December 2020 deadline.
If you are trading organic goods to outlets in Northern Ireland that are NOT supermarkets, then you need to be registered on TRACES.NT (see above) by 1st January 2021.If your business is exporting organic goods to countries outside of the EU, the EEA, Switzerland or NI (such as the USA) a different export certificate is required and we strongly advise you to discuss these requirements with your CO.