10.10.2022

Dear clients,

In the following we would like to share some important information regarding national and international transaction certificates (= (N)COIs/(N)TCs).

Please share this with all colleagues of your company that are involved in this topic.

Digitalization of all (N)COI/(N)TC issuance starting 15.10.2022

We are happy to inform you that starting October 15th (2022) all types of national and international transaction certificates (= (N)COIs/(N)TCs) for organic food/agriculture are going to be issued digitally.

So far, this was only possible for official EU-COIs issued on TRACES (as well as NAQS transaction certificates). Now, we are going to make the next step by issuing all types of (N)COIs/(N)TCs digitally.

There will not be any paper version / print outs of any (N)COIs/(N)TCs anymore.

In case you require a paper copy, you or your buyer can directly print out the (N)COI/(N)TC where it is needed, of course.

This means that there will not be any delays or extra costs related to shipping of (N)COIs/(N)TCs on paper anymore and COI issuance will become more efficient, so that we can further improve our service for all clients.

From 15.10.2022 updated application forms will be available on our website.

Please make sure to always use the latest version of the application form when applying for a (N)COI/(N)TC.

The following is only relevant for official EU- and GB-COIs:

Explanation regarding the definition of “exporter” in EU-COIs (box 5) as well as GB-COIs (box 4), specifically in cases where the last step of packing / labelling is done via a subcontractor:

[EU-COI = official COI for organic imports into the EU, EEA (European Economic Area), CH (Switzerland) and NI (Northern Ireland) //
GB-COI = official COI for organic imports into Great Britain (NOT including Northern Ireland)]

As you know, the EU regulation determines that the exporter in box 5 of the COI is the “operator performing the last operation for the purposes of preparation (…) and sealing the products in appropriate packaging or containers” (Regulation (EU) 2021/2306, Annex Part II). Generally, the “last operation for the purposes of preparation” means the last step of labelling done before export (may include last steps of palletizing, wrapping, etc.).
The UK has retained the EU regulation and the explanatory notes of the DEFRA define the exporter in the same way as Annex Part II of Regulation (EU) 2021/2306.

Regarding cases where this last step of preparation is done via a subcontractor and not by the owner and seller of the product directly:

We would like to explain that the “exporter” on the EU-/GB-COI is the owner of the product who employs the subcontractor for the last step of preparation before export because this owner (and employer of the subcontractor) is the responsible operator for this product.

Please always keep in mind that

• all EU- and GB-COIs must be issued by the control body (or control authority) of the “operator (…) carrying out the last operation for the purpose of preparation”, i.e. of the “exporter” in the COI.
• all EU- and GB-COIs must be issued before the goods leave the country of export and “country of export” means the country where the product was subject to the last step of preparation.

Thank you very much for your attention and cooperation.


Kind regards,

COI Department
CERES - CERtification of Environmental Standards GmbH