17.07.2023

Important Client Information regarding (N)COIs/(N)TCs

Dear clients,


We would like to share important information regarding the following topics:

• Updated application forms for all types of (N)COIs / (N)TCs
• EU requirements regarding replacements for EU-COIs
• COI-Department out of office from 25. to 27. September 2023

Please check the information carefully and forward it to all colleagues who might find it relevant.

***Please do not answer to this client information email. In case of questions, please contact admin@ceres-cert.de ***

1) Updated application forms for all types of (N)COIs / (N)TCs

As you know, an updated price list has been implemented on 01 May 2023.
For this reason, all price related information in the application forms for all types of COIs / TCs and NCOIs / NTCs has been updated.
In addition, Annex II of application forms for EU-COIs now contains additional information regarding modifications of issued COIs as well as replacement COIs (see details in paragraph 2) of this email).

The latest version of all application forms is available for download on our website (under Documents > BIO > COI/TC; along with our General guidance for COI/TC applications and Brief Information files regarding EU- and GB-COIs).

Please note that as of 01 August 2023 we will no longer accept any outdated application forms.

2) EU requirements regarding replacements for EU-COIs

(EU-COI = Official COI that is mandatory for organic imports into the EU (European Union), EEA (European Economic Area), CH (Switzerland) and NI (Northern Ireland))

As you know, some details can be modified after the EU-COI is already issued, without the need for a replacement COI.

Here, any changes are perfectly acceptable as long as they are plausible and can be backed up by the corresponding documentation.

Regulation (EU) 2021/2306, Article 5, point 3 states that, information relating to the number of packages referred to in boxes 13, the details of boxes 16 and 17, as well as the supporting documents (final transport document like BL / AWB / CMR, commercial invoice, packing list, where applicable also laboratory analysis) shall be included or updated in the COI within 10 days from its issuance and, in any case, before its verification and endorsement by the competent authority.

For this reason, all final details and documents must be provided to us as soon as they are available.

The issuing control body (e.g. CERES GmbH) can modify the following boxes:

• Box 10 (Border control post / point of release for free circulation)

• Partially Box 13 (Description of the products: Only the number of packages and the net weight)

• Box 14/15 (Container No/Seal No)

• Box 16 (Total gross weight)

• Box 17 (Means of transport before the entry into the Union)

• Supporting documents

The importer can modify the following boxes:

• Box 10 (Border control post / point of release for free circulation)

• Box 19 (Responsible for the load)

• Box 20 (Prior notification)

• Box 21 (For transfer to)

• Box 22 (Details of the control point)

• Box 23 (Special customs procedures)

• Box 24 (First consignee)

• Supporting documents

To correct or change any other details not listed above, it is necessary to issue a replacement COI (that replaces and invalidates the previously issued version).

However, according to the EU regulation, once an EU-COI is issued, only corrections “of a purely clerical or editorial nature (…) without modifying the information in the initial certificate concerning the identification of the consignment, its traceability and the guarantees” are acceptable.
(Regulation (EU) 2021/2306, Article 6, (1))

This means that any replacement EU-COI that includes changes related to traceability details and/or identification of the product may possibly be rejected by the competent authority in the EU member state. If the replacement was necessary due to erroneous or missing information / documents, it is issued exclusively on the exporter’s own risk and CERES cannot accept any responsibility for potential consequences.
So far, corretions done via replacement EU-COIs are generally accepted, in our experience. Nevertheless, it is our responsibility to alert our clients to these specific EU requirements.

It is essential that all details indicated in the application form and required documents (as detailed in Annex I of the application form for EU-COIs) are correct and complete, especially with regard to details relevant for traceability and identification of the product (e.g. lot numbers etc).

Note: Modifications and replacements are only possible as long as the competent authority in the EU member state has not yet signed the COI.

Please also remember that all EU-COIs (same as GB-COIs for imports into Great Britain) must always be issued before the goods leave the country of origin or export. (country of export = country where the last preparation activity, e.g. packing / labelling, took place)
(See Regulation (EU) 2021/2306, Art. 3 (2) and Art. 4 (1))

Kindly keep this in mind, take care to fill in COI applications completely and correctly, and send applications with sufficient time in advance to clarify any potential doubts before the departure of the goods from the country of export.

(To facilitate timely applications, the commercial invoice and transport document (AWB, B/L, CMR or similar) may be provided as draft / proforma / provisional version or, if not otherwise possible, the application may even be sent without these documents.
In any case, the final version / original of all documents must be provided as soon as it is available. See details in Annex I of the application form for EU-COIs (or GB-COIs) and Brief Information about COIs for EU-Imports (+ EEA, CH and NI), both available for download on our website, link above under point 1) of this email.)

3) COI-Department out of office from 25. to 27. September 2023

Due to our annual staff conferences, the COI department of CERES GmbH Germany will be out of office from 25th to 27th of September 2023, with only very limited access to our emails.

Of course, we will try our best to attend to any unexpected emergency cases as fast as possible but cannot guarantee fixed response times during these days.
Keep in mind that, while we will take all available measures to keep inconveniences to a minimum, handling times may still encounter some delays.

Kindly make sure to plan all (N)COI/(N)TC applications (that are handled by CERES GmbH Germany / admin@ceres-cert.de) accordingly and send any time sensitive requests well in advance, so they can be issued before the indicated dates.

Thank you very much for your kind consideration and attention.



Best regards,
COI-Department of CERES GmbH (Germany)