amending Regulation (EU) 2018/848 as regards certain production, labelling and certification rules and certain rules on trade with third countries
EUROPEAN COMMISSION
Brussels, 16.12.2025
COM(2025) 780 final
2025/0417 (COD)
EXPLANATORY MEMORANDUM
1. CONTEXT OF THE PROPOSAL
Reasons for and objectives of the proposal
Organic farming is a key element of the Common Agricultural Policy (CAP) of the European Union. The share of land farmed organically has been steadily growing to 11 % today. Consumers increasingly purchase organic food, recognisable through an EU logo and a common label. The production and labelling of organic products are governed by Regulation (EU) 2018/848, applicable since January 2022, and the delegated and implementing Regulations adopted on its basis.
The Court of Justice, in Case C‑240/23, ruled that terms referring to organic production and the EU organic production logo may not be used by products that only comply with standards merely equivalent to Regulation (EU) 2018/848. It is therefore necessary to ensure that consumers can make informed choices when purchasing products from third countries whose organic production and control systems have been recognised as equivalent to those of the Union, and to maintain consumer confidence and fair competition.
The recognition of third countries’ organic systems will expire on 31 December 2026; it is necessary to extend this recognition until 31 December 2036 to avoid trade disruptions.
The proposal aims to adjust certain production rules to create a more efficient, effective, and user‑friendly regulatory framework.
Consistency with existing policy provisions
The proposed regulation amends the current rules to facilitate organic production, labelling, controls and trade across the Union and in third countries, ensuring informed consumer choices.
Consistency with other Union policies
The amendment does not alter the essence of Regulation (EU) 2018/848 and is consistent with other Union policies.
2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY
Legal basis
Article 43(2) of the Treaty on the Functioning of the European Union.
Subsidiarity
The proposal amends Regulation (EU) 2018/848, removing burdens on Member States, operators and third‑country traders, for example by:
- allowing the use of market‑available cleaning and disinfection products;
- ensuring appropriate consumer information;
- adapting exemption conditions for smaller operators;
- adapting group‑operator composition rules;
- postponing expiry of third‑country recognition;
- adapting livestock production rules.
Proportionality
Amendments are strictly necessary to achieve the objectives of Regulation (EU) 2018/848, reducing administrative burden while preserving high standards.
3. RESULTS OF EX‑POST EVALUATIONS, STAKEHOLDER CONSULTATIONS AND IMPACT ASSESSMENTS
- No fitness check was performed on Regulation (EU) 2018/848.
- The Commission consulted Member States, GREX, CDG, the Fit‑For‑Future Platform (2024), and held several meetings in 2025.
- A public call for evidence (21 Oct – 18 Nov 2025) received 720 submissions.
Impact assessment
Given the need to ensure informed consumer choices, avoid trade disruptions, and reduce burdens, a quantitative impact assessment was not conducted. The proposal is expected to stimulate organic farming, create jobs, and improve environmental outcomes without increasing greenhouse‑gas emissions, aligning with the climate‑neutrality objective (Regulation (EU) 2021/1119) and the Union’s 2030/2040 climate targets.
Regulatory fitness and simplification
Key simplifications include:
- allowing market‑available cleaning and disinfection products;
- adapting exemption conditions for small operators;
- simplifying group‑operator composition rules;
- adapting livestock production rules.
Estimated annual administrative cost savings: €47.8 million (‑€45.9 million for businesses, ‑€1.9 million for administrations). One‑off adjustment cost savings for businesses: €109.2 million; annual adjustment cost savings: €90.2 million.
No digital‑relevance requirements are introduced.
4. BUDGETARY IMPLICATIONS
The proposal has no budgetary implications.
5. OTHER ELEMENTS
Implementation and monitoring
Market observatories will continue to monitor supply, demand, and prices of organic products. The Commission will monitor implementation of Regulation (EU) 2018/848 and related delegated acts.
Detailed explanation of specific provisions
- The Court ruling (Case C‑240/23) prohibits the EU organic logo on products that do not fully comply with Regulation (EU) 2018/848, unless the product originates from a third country whose system is recognised as equivalent.
- The use of third‑country organic logos is permitted and does not mislead consumers.
- The recognition of third‑country systems will be extended to 31 December 2036.
- Cleaning and disinfection products used in organic processing may be authorised without restrictive lists.
- Exemption thresholds for small operators and group‑operator composition rules are revised upwards.
- Specific provisions for quail production (conversion period of five weeks, minimum age at slaughter of 42 days) are introduced.
- Veterinary withdrawal periods are harmonised (minimum 48 hours).
- Poultry housing requirements are adjusted (open‑air access only for sufficiently feathered birds; max usable surface per house 1 600 m²).
Amended Articles (selected excerpts)
- Article 1 – Amendments to Articles 24, 30, 32, 33, 35, 36, 48, and Annex II (e.g., removal of point g in Art 24(1); revised definitions of “terms referring to organic production”; updated logo use rules).
- Article 2 – The regulation shall enter into force on the day following its publication in the Official Journal of the European Union and be binding and directly applicable in all Member States.
Done at Brussels,
For the European Parliament – The President
For the Council – The President
References
- https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/15273-Organic-production-targeted%20updates-and-simplification_en
- N. Scialabba, M. Müller‑Lindenlauf, “Organic agriculture and climate change”, Renewable Agriculture and Food Systems, 25(2), 158‑169 (2010).