Post-Brexit exports: What will change?

Different territories can mean different organic requirements. Our experts can assess your operational needs and provide you with market access solutions for territories with specific requirements for importing organic.

Post-Brexit Exports

Having consulted with our licensees and trade stakeholders, we very are aware of the uncertainties and concerns surrounding organic trade in the post-Brexit environment. As the UK’s largest organic certifier, we are keen to reassure and support businesses in making important commercial decisions in the coming months.

Detailed below are some of the specific development and options relating to the EU and key export territories outside the EU. Please note that depending on post-Brexit progress on key international trade deals, which many include organic standards equivalence or acceptance as part of a final deal, these requirements may change.

What will change for those exporting to the EU?
The UK will not become an ‘Approved Third Country’ for the purposes of organic regulation. This means that:

  • Businesses would only be able to export organic food & drink products to the EU after the UK exit date where they are certified by an organic control body recognised and approved by the EU Commission to operate in the UK. (EN1235 status).
  • Although we have applied for our EN1235 scope to be extended to cover the UK, UK (or other international) control body applications will not until the UK exits the EU. In the meantime DEFRA are exploring UKAS accreditation for all six UK certifiers, although this is not expected to be in place until June at the earliest.
  • We continue to anticipate some gap between UK exit and Soil Association Certification EN1235 scope extension being in place, during which UK organic would not be cleared to enter the EU.

What if I export to the EU and my suppliers are not Soil Association Certified?

  • As Soil Association Certification anticipates being the only UK certifier to hold EN1235 status before June, at the earliest, we anticipate some potential disruption to supplies from non-Soil Association certified operators.
  • Provided goods were handled or processed prior to EU exit and the supplier had valid, existing EU certification issued at that time, SA certification anticipate no problem being able to recertify product under our EN1235 accreditation.
  • Should, after exit, certification of such suppliers be renewed and goods subsequently handled under this new certification, SA certification may not be able to recertify these goods. This situation would change only when the supplier’s certifier achieves EN1235.

Will there be changes to exporting beyond the EU?
Paperwork will resemble that already in place now, but will be dependent on the UK trade deals established with each country.

Thirteen so called 'Approved Third Countries' are recognised by the EU and are detailed in the EU regulation. Some have recognition for goods acceptance in only one direction, others both.

The UK is currently in the process of negotiating acceptance of UK organic goods with all of these nations. DEFRA anticipate acceptance being in place for nice of these by the time of exit, but not all have been agreed at this time:

  • Costa Rica and Israel have now signed agreements.
  • Australia, Argentina, India and Israel are still progressing through legal processes.
  • US and New Zealand arrangements with the EU are currently bilateral, so mutual recognition will need to be agreed. DEFRA are working with these to ensure that this recognition is in place in time for the UK's departure from the EU
  • DEFRA are anticipating possible delays with Chile, Japan, South Korea and Switzerland.

For goods leaving the UK bound for non-EU countries, we currently use export certificates. NOP import certificates continue to be used for the US and NAQS for South Korea all of which are endorsed but this may change.

In the event of equivalence not being agreed with the UK, are there other options for business exporting to third countries like the US?

For the US, yes and there are two options:

  • Canadian Organic Regime Accreditation (COR). We are therefore able to certify your products to COR, which will ensure that they gain access to the US through the COR equivalency arrangement in place between Canada and the USA. You will be able to export in the way that the current equivalency arrangement works between the EU and the states. If you are currently exporting to the US please contact us to discuss how COR may be appropriate for your business. You will need to obtain COR Certification before UK exit and therefore it is important that you speak to us now regarding this.
  • We can also now offer certification to the US ‘National Organic Program’ (NOP) through partner Certification Body, Ecocert. We would undertake the inspection to NOP and send the inspection reports to our partners to complete the certification. Again, if you want this certification you will need to contact us as soon as possible to begin the application process.

What about export to Asian countries? Can your partnerships that can help deliver certification to local standards?

  • Our partnership with Ecocert will enable us to continue to help deliver accreditation recognised by South Korea Please do contact us to let us know of any specific country you export to that you need such arrangements in place and we will do our best to find a solution for you.
  • Japanese authorities require that all organic products meet JAS (Japan Organic Agricultural Standard), which we can also offer through our partners Ecocert. We will undertake the inspection to JAS ourselves and send the inspection reports to our partner to complete the certification.
  • China is relatively unaffected by our EU exit, as products continue to require full CNCA certification. This certification must be issued for every ingredient at every stage in the supply chain, (including production) and must be issued by a certification body approved by the Chinese authorities. Soil Association Certification have a partnership with Chinese certifier OFDC and can help with application and inspection arrangement with OFDC. Exemptions from CNCA certification exist for certain organic products entering China via designated tax zones, provided they are to be traded via approved e-commerce platforms.

Export Support Packages
We offer a range of support to help guide you through the process of organic export to key territories:

An introduction to organic exporting - An introductory briefing session outlining organic market opportunuities and requirments around export to specific territories or organic export in general.

Export benchmarking - Detailed assessment of your operation, products , labelling and supply chain against requiremenst of overseas standards and certifications . Initailly available for:PWAB (US - Livestock Products), CNCA (China), BioSuisse (Switzerland) and JAS (Japan). Refer to our Global Guide for details of other territories.

Application and inspection support – We can provide full support from initial application and inspection, through to renewal, for specifically required overseas certifications (e.g. CNCA standards for China).

Whether you'd like a wider introduction to exporting organic, an assessment of product suitability against overseas requirements, or support with application and inspection for additional overseas certifications, we can help.

To discuss your requirements in detail or simply find our more, please contact our experts.

For more information:

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