NEWS AND INFORMATION FOR THE SEASON PREPARATION 2025 | | | Dear clients,
We would like to wish you all the best for 2025 and a Happy New Year. We hope that you will have a lot of health, strength, joy and prosperity in 2025. We would like to thank you for the good collaboration in 2024 and are looking forward to working with you in 2025.
We would like to inform you about some important topics for the season 2025.
| | 1 New EU regulation in force – get started as soon as possible | | | The EU Parliament decided in December 2024 to authorize a derogation period until 15.10.2025 for certificates issued under the old EU regulation (Regulation (EU) 2024/3095). This means that the equivalent certificates (e.g. bi-OS) issued before the 31.12.2024 stay valid until the 15.10.2025.
Nevertheless, from October 2025 onwards you need to have a certificate for the new EU Regulation (EU) 2018/848. This means that clients which were not certified according to the new EU regulation in 2024 should ensure that they get an early inspection so that we are able to take a certification decision before October 15, 2025. | | | Therefore, we urge you to submit the Data Sheets and Organic System Plans as soon as possible but not later than March 1st, 2025. | | | | | The updated data sheets and OSPs are available in the below link, please click on the link to download the relevant forms. If you have any problem to get the documents, please contact our back office directly: | | international@bio-inspecta.ch | | 2 Changes on Residues for Phosphonic Acid in the EU | | | We have very good news regarding the topic of phosphonic acid in organic food products. Until now, the residue definition of Fosetyl-Al (sum of fosetyl, phosphonic acid and their salts, expressed as fosetyl)’ is considered and its maximum residue levels (MRLs) is taken while investigating the residue cases. From 29 April 2025 onwards (Article 32, 2024/2619), a new interpretation is used and set up MRLs for phosphonic acid shall come into force for several products. | | | What will come into force from 29th April 2025 – a new definition of Phosphonic acid? | | | In accordance with Article 12(1) and Article 43 of Regulation (EC) No 396/2005(2) and as per the recommendation of European Food Safety Authority (EFSA, 2021), the residue definition for enforcement purposes for the three active substances from ‘Fosetyl-Al (sum of fosetyl, phosphonic acid and their salts, expressed as fosetyl)’ to ‘phosphonic acid and its salts, expressed as phosphonic acid’, is set up and proposed new MRLs based on that residue definition. With this new update, new MRLs for phosphonic acid in or on certain organic products were defined where MRLs for some products were lowered and for others increased as per the (EU) Reg 2024/2619 of 8 October 2024. | | | "The results of fosetyl should not be taken into account and the default maximum level of 0.01 mg/kg in accordance with Article 18(1)(b) of Regulation (EC) No 396/2005 will not apply anymore from 29/05/2025. The MRL for its metabolite phosphonic acid shall apply." | | | Is phosphonic acid really a problem? Why should we investigate to find out the root cause of Phosphonic acid in organic products? | | | Phosphonic acid is a metabolite of fosetyl-Al. Fosetyl-Al is commonly used fungicide in non-organic farming. Phosphonic acid was allowed in certain plant strengthening products in organic farming until 2013 and then since October 2013, potassium phosphonates are registered as active substances for fungicides at EU-level and no longer allowed to use. Fosetyl-Al rapidly degrades to phosphonic acid. Potassium phosphonate can be used as a fungicide, which results to the residue of phosphonic acid in the harvested crops. Therefore, the European Commission has categorised phosphonic acid as a residue and proposed new MRLs for phosphonic acid in several products. | | | In case of positive residues lab report with phosphonic acid, bio.inspecta shall investigate the source of phosphonic acid residue to ensure that they do not originate from prohibited substances or practices in organic farming. | | 3 Increased control measures for the EU, Great Britain and Switzerland changed | | | Increased control measures for certain products imported from certain countries to the EU are requested by the EU since 2016. For 2025, the list of concerned products/countries has been amended.
The requirements are applicable for products originating in and imported directly from one of the countries below or via another third country. The requirements are further applicable for operators producing, preparing, trading, storing, or exporting organic food and feed. For the products concerned, sampling/analysis for the first COI requested in 2025 will be compulsory.
Please make sure to consider sufficient time before the planned export to send the sampling request to bio.inspecta. We would like to remind you that all the COIs (for EU and NOP) must be issued before the consignment leaves the country of origin. Please make sure you use the new form since there have been changes for the new EU regulation.
| | | Requirements of Increased Control Measures | | - At least 2 physical inspections per year, one of these unannounced.
- Inspection before sowing of the first certified crop for farms certified for the first time.
- At least one sample per year (for producers, it is compulsory to be a field crop sample). This requirement is without prejudice to the export consignment sampling.
- Increased control on traceability and flow of products.
- Increased control on bookkeeping and financial documentation (accounting).
- Increased control on means of transport and storage.
- Information must be kept ready for inspection about all sales of organic products as conventional, including quantities and names of buyers.
- Export consignment sampling and analysis assessment before issuing a COI: For the products defined above, a minimum of 10% or 30% of all export consignments needs to be sampled and analyzed for the presence of unallowed substances. The percentage is calculated for each concerned product of each concerned operator for the period between 01.01.25 - 31.12.25. Please refer to information about the sampling/ analysis procedure and timelines in the information leaflet, Certification of Inspection (COI).
| | 4 Travel Plan - new requirement when requesting COI in TRACES for Bulk | | | Art. 16.5 of REG 2021/1698 requests that if there is a product in bulk (see definition below), a Travel plan must be uploaded in TRACES including premises and stop places where the products will be during the travel to EU. In order to specify what exactly is requested you can find a template for this travel plan which would need to be filled in in case of bulk products.
The definition of bulk transport is large quantities of products, without separate packaging, in specialized vehicles or containers (e.g. silos and special containers, trailers, tanks, railcars, vessels, cargo holds, freighters, barges, grain elevators, silos, grain bins, tippers, or other bulk carriers).
| | | The Regulation (EU) 2018/848 has adopted the use of the EU Organic Logo. The rules have been published under the delegated regulation (EU) 2024/2867. Main change is the possibility for the EU organic production logo to be used in black and white as shown below, or in a totally inverted white and black (negative format), but only where it is not practicable to use the colour model. | | | We would kindly want to remind the group of operators that from January 1, 2025 the maximum size of a group of operators shall be 2 000 members (see Art. 10 and 4 of EU Reg 2021/279).
Please note that each group of operators shall have a legal personality.
Further specifications can be found in the Regulation (EU) 2018/848 and 2021/1698 on this topic.
| | 7 Great Britain Organic standard includes Egypt | | | After the Brexit, Great Britain acknowledges the EU Organic Regulation as the basis for organic products. With effect of 01.01.2023, certification bodies accredited according to the EU Organic Regulation have been requested to obtain accreditation by Great Britain authorities. bio.inspecta has now been approved also for the country EGYPT.
Our clients from Egypt can therefore now also export their products directly to the UK. Please request the additional standard if you are interested at | | | Please note that we will be exhibiting at Biofach in Nürnberg, Germany from 11-14 February 2025 and would be excited to meet with you to discuss any issue or just to have a good time together. | | | bio.inspecta international team is available to support you in any step, please do not hesitate to contact us or your local partner if you have any questions!
Kind regards, | | bio.inspecta AG | | Franziska Staubli and international team
Head of International Services Division
Ackerstrasse 117, CH - 5070 Frick
Central +41 (0) 62 865 63 00
Hotline +41 (0) 62 865 63 42
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