Since January 1, 2022, European Regulation (EU) 2018/848[i] has governed organic production and the labelling of organic products throughout the European Union. The aim of this legislation is to strengthen the harmonisation of standards, improve consumer confidence, and support the growth of the organic sector. It has applied to third countries since January 2025. While measures such as group certification offer opportunities for their producers, the regulation also poses significant challenges, including increased costs and the artificial division of some cooperatives.
The opportunities offered by the organic regulation
The regulation introduces group certification, which is a significant development for small-scale producers in southern countries. By pooling certification costs, which are often prohibitive for small farms (1 to 3 hectares), this measure makes it easier for them to access the European organic market. According to an international survey conducted by FiBL and IFOAM, 40% of producers and traders in third countries view this regulatory clarification as an opportunity to reinforce organic practices and maintain quality[ii] . According to Yessie Meyer, an expert in sustainable agricultural supply chains at Enabel: ‘Group certification is an important tool for enabling cooperatives to reduce their dependence on export companies (which held their certification before the reform) and to diversify their customer base. This can justify the effort of implementation.’
The regulation also authorises the marketing of heterogeneous seeds, which are better suited to agroecological practices, and broadens the range of certifiable products (e.g. essential oils, wool and salt). This gives small producers more flexibility in choosing crops and access to varieties suited to their soils and climates. Additionally, stricter controls protect against automatic downgrading in the event of accidental pesticide contamination, a frequent problem for small farms neighbouring conventional plots.
Major challenges and constraints
Despite these advances, the regulation poses significant challenges for non-EU producers. From January 2025 onwards, imported organic products will have to adhere to the same rigorous standards applied within the EU, rendering the previous equivalence system obsolete. This compliance requirement increases administrative and financial burdens. Furthermore, the regulation sometimes forces them to split artificially, with no more than 2,000 members per group permitted. What are the consequences? Disorganised supply chains, soaring costs, and ultimately, the very real risk that some cooperatives or unions of cooperatives will give up and abandon the organic certification they have worked so hard to achieve.
ACPCU, a major cooperative union of coffee producers in Uganda, is a striking example. It unites over 20,000 producers and comprises 38 cooperative societies, 32 of which are certified as organic. According to Derick Komwangi, the union’s Projects Officer: ‘Certification requires a significant financial investment during the transition period, and some cooperatives are still unable to raise the funds needed to cover the costs of certification. Requesting them to individually meet certification cost is equal to an automatic decertification. With the increased costs, lengthy audit processes, chemical residue tests in Europe because we lack the facilities to do that locally, we are reconsidering whether it is a worth investing in certifying an additional cooperative.
ACPCU has seen a 518% increase in certification costs, not including other overheads. The organisation is currently undergoing one of its two annual organic audits. According to Derick Komwangi, ‘it has taken approximately one and a half months to complete just the field inspections not mention the administrative processes thereafter. This means that three out of the twelve months of work will be spent on audits (field-inspection), depriving us of the time needed to implement certification benefits such as training and extension services for farmers, farm inspections and agroecology support services. Not to mention the impact of these increased delays on our relationships with our buyers in Europe’.
Another point is often raised. The regulation does not sufficiently consider the specific characteristics of agroecological systems, such as agroforestry practices or diversified crops. Although strict traceability and documentation requirements are necessary to guarantee organic quality, they require administrative and technical resources that are often beyond the reach of these farms.
Issaka Sommandé, President of PNCE-B in Burkina Faso, is unequivocal in his assessment. The new regulations, ‘as they stand’, pose ‘real challenges for Burkinabé producers’. ‘Forced restructuring, increased audits and ever-heavier administrative requirements are weakening cooperatives that would otherwise be solid and highly functional. Without corrective measures, this framework risks excluding small producers from the European organic market and undermining effective collective dynamics’.
The PNCE-B President also calls on the European Union, technical partners and certification bodies to listen to the realities on the ground and adapt their support accordingly. Organic farming must not become an inaccessible luxury but rather remain a means of achieving inclusive and sustainable development in third countries’. Yeo Moussa, director of Yeyasso, a cocoa producers’ cooperative in Côte d’Ivoire, also calls for producers to be heard and supported: ‘If the regulations do not include support measures for producer organisations, this could lead to producers abandoning organic certification’.
Proposed corrective measures
To address these challenges, organisations such as AVSF and Ethiquable have proposed several measures, including postponing the application of the regulation to third countries until 31 December 2026, reducing certification costs, and establishing an independent observatory to evaluate the impact on small-scale producers[iii]. Fairtrade International, for its part, would like to see certain procedures simplified, such as residue testing prior to import into the EU and the definition of ‘operator groups’, which are limited to 2,000 members. Fairtrade estimates that 60% of its certified organic coffee and cocoa producers, and 95% of its small organic banana producers, do not meet these new criteria[iv] .
Conclusion
The EU regulation on organic production and labelling provides opportunities for small-scale organic producers in southern countries, particularly through group certification and improved access to suitable seeds. However, in creating a stricter framework, have we lost sight of the reality on the ground? The doors that are opening due to group certification risk being slammed shut by prohibitive costs and discouraging red tape.
To ensure inclusive, sustainable, and fair organic farming for small producers, a reform that includes financial support, simplified tools, and greater consideration for agroecological practices is essential.
