JANUARY 2026, ISSUE 203
EU Commission: ‘more efficient, effective, and user-friendly’? | Background to the Herbaria ECJ judgement | ABs working on organic guidelines | New Zealand edges toward new regulation | Organic and natural cosmetics: the importance of being certified | IOAS appoint new Board members | Resources | Call for comments and contributions
Welcome to this FREE monthly newsletter from the Alliance for Organic Integrity (AOI), the ORGANIC STANDARD (TOS). TOS is not new but has existed for over 20 years as a subscription only journal issued six times per year. Its aim has been, and remains, to share information with people who are working to grow organic production and its market which in turn contributes to healthy soils, enhanced biodiversity, food security, mitigates climate change and contributes to sustainable livelihoods.
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REGULATORY UPDATE
EU COMMISSION: ‘MORE EFFICIENT, EFFECTIVE, AND USER-FRIENDLY’?
by TOS staff
On December 16 and 17th, 2025, respectively the European Commission published a ‘proposal’ to amend the main European Regulation on organic production and labelling (Regulation 2018/848) and a ‘Roadmap Organic rulebook fit for the future’. This article summarises the proposed targeted amendments in the former to share with the global organic community engaged with the EU market what is coming down the track. The motivations for the changes are quoted as being ‘adjustments to certain production rules to create a more efficient, effective, and user-friendly regulatory framework.’

Argentina: one of 11 third countries recognised by the EU
The main changes proposed are:
The use of the organic production logo of the EU should be allowed in the labelling, presentation and advertising of products imported from third countries, provided that, in addition to agreed equivalent rules, those products comply with certain additional production and control requirements. Note that only product imported from ‘equivalent third countries’ will be affected by this change and NOT product imported under compliance. This follows a judgment by the European Court of Justice in 2024 (see Herbaria case) that concluded that such use of the logo should NOT be permitted by the current legislation, as written (see below explanation of the Herbaria case). The additional production requirements referred to include live soil, animal welfare standards and limitations on artificial ingredients used in food processing – issues the Commission note as important to the definition of organic. It seems that products produced with imported ingredients within the EU (unless prepacked) making up less than 5% content will not need to be subject to these additional requirements. IFOAM OI has been publicly critical of this proposal, lamenting what is in effect adding additional demands on ‘equivalent’ product to be able to bear the EU organic logo. The Commission appears to have been backed into a corner by the Herbaria ECJ decision, and the solution proposed is a compromise.
Extension of the deadline for the recognition of third countries as equivalent from December 31, 2026 to December 31, 2036. It is understood that the Commission’s intention is the transformation of equivalency arrangements into trade agreements which may be the reason for the considerable delay. Not everybody will be happy with that. The current end of 2026 deadline means that there is some urgency to make this change.
The proposal suggests dropping the requirement for authorisation and restrictive lists for cleaning products and disinfectants. The rationale for this is the wide range of products available, the variable conditions for use and the need for operators to comply with manufacturers machinery specifications. Operators will be able to use (any ‘suitable’) products available on the market.
Conditions in the current Regulation that allow Member States to exempt small producers from the requirement to be certified are to be abolished as they are considered a barrier to growth. In addition, the threshold of annual sales turnover will be revised upwards, presumably to account for inflation.
Provisions on the composition of groups of operators relating to annual turnover and legal personality will be revised due to difficulties experienced. Requirements of annual turnover of group members will be abolished, and maximum eligible surface areas will be revised upwards.
A minimum age of 42 days at slaughter and a conversion period of five weeks for quails for meat production.
Provisions for veterinary product withdrawal periods for terrestrial animals will be brought into line with that allowed for aquaculture.
Current requirements that poultry must be provided with continuous daytime open air access from as early an age as practically possible will be amended to require access to open air areas only to birds that are ‘sufficiently feathered’ to regulate their body temperature when exposed to outdoor climatic conditions.
The maximum usable surface area for fattening poultry will be defined at the level of the poultry houses instead of being limited to 1600 sqm as it limits the further development of such enterprises.
The published document details the planned changes.

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Inspection in Guatemala
Background to the Herbaria Case: The Herbaria case mentioned in the above article was previously described in TOS issue 188, June 2023, in an article by Dr. Alexander Beck entitled: ‘Legal interpretations that concern fair competition’. Herbaria Kräuterparadies GmbH is a German company producing herbs and food supplements that was prohibited by the competent authority to label one of their products according to the EU Regulation. The product is a mixture of organic fruit juices and organic herbal extracts, supplemented with vitamins and trace elements, marketed as a dietary supplement. The company issued a lawsuit against this decision and additionally argued that a comparable beverage originating in the United States, NOP certified and labelled as organic was being freely marketed in the Union with an organic label, despite the addition of synthetic minerals and vitamins; which they claimed resulted in unfair competition and discriminatory treatment to them. Updated information on the case from April 2025 can be found here.
Main data extracted from that source: After years of legal dispute and due to the relevance of this matter for international trade, the case was finally heard by the Grand Chamber of the European Court of Justice, which stated:
1. The concept of ‘equivalence’ of a non-EU country’s production rules presupposes that the non-EU country pursues the same objectives and observes the same principles related to organic production, by applying rules which ensure the same level of conformity required by the EU legislation for organic products manufactured in the EU.
2. While imported food products may meet the equivalent production requirements in an exporting country, meeting such non-EU requirements does not necessarily mean that the production method complies fully with the EU law requirements for organic production. Accordingly, the EU Organic Label should not be used for imported food products that do not comply with EU organic production requirements.
3. However, the organic production logo of an exporting third country (for example, the US NOP organic label) may be used in the EU for that product, even where that logo contains terms referring to organic production.
ACCREDITATION
ABS WORKING ON GLOBAL GUIDELINES
A task force under the International Accreditation Forum (now merged with ILAC to become Global Accreditation Cooperation) has been working for several years on an ‘informative document’ to harmonise accreditation body approaches to accreditation of organic certification bodies. The document is undergoing a final approval vote membership before publication. The task force was led by COFRAC (French AB) and IOAS but considered many contributions from other ABs and interested parties. The document follows the structure of ISO/IEC 17011:2017, the requirements for accreditation bodies accrediting conformity assessment bodies. It provides guidance on assessor competence, documentation needed at application,
An inspector calls
requirements for CB transfer, typical CAB policy and procedures, required assessment activities, risk-based approaches and considerations for witness and compliance (review) audits.
Although an informative document, which means that ABs are not obliged to fully comply with its requirements, it is hoped that it will lead to greater consistency of accreditation in this sector as well as being a source of information for regulators and CABs. The document is expected to be published in the first half of 2026.
NEW ZEALAND
NZ EDGES CLOSER TO NEW REGULATION
New Zealand is implementing a new national organic standard under the Organic Products and Production Act 2023 (OPPA). It establishes mandatory regulations for ‘organic’ labelling, with specific standards and rules (Organic Standards Regulations 2025) coming into force by March 31, 2028, requiring government approval for operators and ensuring compliance for domestic and export markets.
OPPA was passed in March 2023. This Act mandates that all products labelled ‘organic’ must meet government-recognised standards, ie Organic Standards Regulations 2025. These regulations, established under the 2023 Act, detail the specific rules for organic production and processing.
Operators must be approved and overseen by the Ministry for Primary Industries (MPI). The core standards for most organic products become mandatory from March 31, 2028.

All businesses selling or marketing products as organic in NZ must comply with the new national standard. The regulations cover the production and processing of organic food, beverages, plants, and animal products. Rules detail acceptable inputs, management of parallel production, and veterinary treatment in livestock.
All imported organic products need to meet the standard New Zealand legal requirements for imported food. There are also additional requirements, depending on the type of organic product being imported and its final use. See more details.
The Ministry for Primary Industries (MPI) has led the development and implementation of the standards and overseeing compliance. The peak body for the sector (Organics Aotearoa New Zealand (OANZ)) was actively involved in developing the legislation. MPI issue a regular news update that interested parties can subscribe to.
COSMETICS FOCUS
ORGANIC AND NATURAL COSMETICS: THE IMPORTANCE OF BEING CERTIFIED
by Nuria Alonso, TOS Editor
We already know that certification provides a guarantee for consumers and support for producers, both because it offers guidance on how to produce in accordance with certain concepts demanded by society, and because it allows them to use labels or indications that help them to market their products.
In addition, certification is particularly relevant in sectors that are not officially regulated, such as natural and organic cosmetics, because with so much confusion and so much greenwashing in the market, conscientious consumers need a clear tool that enable them to buy real natural cosmetics.
The first advantage of a certification is that it has to follow a certain standard. A standard that is published and that all those interested can consult. The concept of ‘natural’ can be interpreted in many ways in sectors other than food, people having a different idea on what natural means to them. In fact, many cosmetics consumers do not clearly distinguish the differences between organic, natural or even vegan. Therefore, it is crucial to count on a standard that defines the concepts and also defines the criteria applied to approve ingredients according to their origin and extraction methods.
Additionally, external supervision by an independent body always helps the laboratory. The principle that ‘four eyes see more than two’ should be fully applied to cosmetics, where there are so many details to consider and reviews to do before launching a product to the market that something can always slip through the net.
Why is certification so important regarding ingredients?
For everybody used to dealing with certification issues, it is clear that a product claiming to be organic has to hold a certificate issued by a recognised certification body and according to a published standard.
But not everybody has this basic concept so clear. Laboratories without experience in organic cosmetics may accept ingredients from their suppliers without requiring their certificate. In fact, there are non-organic ingredients sold as organic, just because the supplier says it is organic and there are also cosmetics sold as organic just because the laboratory or the trader uses the word ‘organic’ or ‘bio’ or ‘ecological’ in the label without any basis.
If the cosmetic product is certified, it is accepted that an ingredient is identified as organic, it is organic.
In addition to clearly identifying which ingredients can be approved and which are organic, cosmetics have a peculiarity: there are quite a few ingredients with the same INCI name (International Nomenclature of Cosmetic Ingredients) that can be of natural or petrochemical origin.
Therefore, there is no way of knowing whether they are natural or not, unless all their technical documentation has been carefully reviewed. That is why those apps that make simple lists of ‘good’, ‘bad’ or ‘not so bad’ according to unknown criteria, and which many people carry on their mobile phones when they go shopping, are of dubious value, because if the concept for classifying an ingredient as ‘good’ is because it is natural, the same ingredient name could be on the ‘good’ or on the ‘bad’ list.
It occurs because the INCI name corresponds to the chemical structure of the ingredient, not to its origin. The chemical composition of petrochemical ingredients is made of combinations of C, H, O and N, same as the natural ingredients. An example of this is the chemical structure of the ingredient Propanediol, which is: C3H8O2, and it has this same formula whether it is derived from plants or petroleum, and this is why it is called Propanediol, the same in both cases.
Some examples:
There are ingredients such as Propanediol, whose name sounds like a chemical, but it may be natural. It is a humectant used as a solvent or as a viscosity control agent.
Lavender harvest
If it is of petrochemical origin it comes from petroleum refining or natural gas cracking. There are different methods to obtain Propanediol from this origin. One can be following a process of oxidation, where Propylene Oxide is obtained, and from it by hydrolysis, the result is Propanediol.
If it is of natural origin it comes from sugar coming from plants such as maize. Then a process of fermentation is followed, using different microorganisms such as the bacteria Clostridium botycurom.
If Propanediol is of natural origin, both the plant from where it comes (maize) and the bacteria used for the fermentation process can contain or be of GMO origin. This is another aspect that natural cosmetics certification check, to avoid that GMOs are used.
There are other ingredients with names that sound natural but can also be of petrochemical origin. For example, Menthol. It is an alcohol, present in essential oils if it is natural. It can be used as a flavour in perfumes and also possesses itching relief, cooling, refreshing, antibacterial and blood circulation stimulating properties.
If menthol is natural it comes from different species of the mint family such as Menta piperita or Menta arvensis. The process starts by steam distillation of the mint leaf, where mint essential oil is obtained. The oil contains several compounds, including menthol, menthone, limonene, etc. After fractional crystallisation or cooling of the oil, the menthol crystallises due to its low melting point (42–44 °C) and finally, the menthol crystals are separated by filtration.
If Menthol is produced by chemical synthesis, different methods can be applied. One of the most typical uses m-Cresol (from petroleum aromatics) as the starting point. m-Cresol is alkylated to form thymol, and then, Thymol is catalytically hydrogenated to menthol.
As an additional note we can comment in this point that many substances that perform the role of perfumes, as Thymol, Limonene, Linalool, Geraniol, Eucalyptol and others can also be of natural or petrochemical origin.
There is another possible consideration with ingredients in cosmetics that come from a natural origin, but then, due to their extraction method, contains a significant percentage if petrochemical molecules. This means they are not totally natural.
An example of this is Sodium Cocoyl Isethionate, known as SCI. This is a surfactant widely used to make solid cosmetic products, such as solid shampoos, because it is a solid ingredient, not liquid as the surfactants used to make liquid shampoos and bath gels are. It can also be used for hair conditioning.
The final product is only around 70 % natural and considering that surfactants are usually the main ingredient in the formula of a shampoo, cosmetics products using SCI cannot be considered a natural product at all. None of the serious natural cosmetic standards approve this ingredient. However, cosmetic products can often be seen on the market using SCI claiming to be natural, or even ‘100 % natural’.
However, SCI cannot be 100 % natural because is made by esterification of coconut fatty acids with isethionic acid and this ingredient is not natural.
In conclusion: cosmetics are a complex subject, and any simplification in claims and messages to consumers is often misleading. Therefore, consumers who want to buy natural or organic cosmetics do not need to be experts in cosmetics, they just need to recognise the few labels used by products certified by professional certifiers that follow recognised cosmetic standards.
SIGNPOST
RESOURCES, REPORTS & INITIATIVES
Useful information — from our partners, the organic community and beyond.
The World of Organic Agriculture 2026 will be presented at BioFach Nuremberg and be available to download soon: 2025 version is available here containing detailed statistics on organic farming around the world.
BioEcoActual Yearbook 2025-26 published and available free. The publication covers key organic news and developments from 2025 and looks forward to trends in 2026.
Did you know?: France has the largest area of organic production in the EU — about 17% of the total. Spain, Italy, Germany come next. Between 2012 and 2022 the organic production area in Croatia quadrupled. Source: Eurostat
IOAS APPOINTS NEW BOARD MEMBERS
Following the sad passing of Michael Sligh, USA in late 2025 and the stepping down of Herman van Boxem, IOAS have appointed three new Board members: Andras Fekete of Hungary, Carrie-Ann Palmeri of USA and Irene Makar of Canada. www.ioas.org

Andras Fekete

Carrie-Ann Palmeri

Irene Makar
EDITOR’S NOTE
We want to hear from you, particularly local news that might be of global interest. What are your successes, what are your problems, what are your solutions? We are interested in new voices, different opinions. Do you have resources to share, are you recruiting or are you staging an event or webinar training? Organic matters — share with the rest of the world here.
Commissioning Editor: Nuria Alonso
Business Manager: David Crucefix
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