Until January 1, 2021, the European Union (EU) organic regulations and U.S.-EU equivalence arrangement apply to the trade of organic products between the United States and the United Kingdom. Please visit the U.S.- EU International Trade Policies page for more information about the equivalence arrangement.
Effective January 1, 2021, the United States (U.S.) has an equivalence arrangement with the United Kingdom (UK), which includes Great Britain (England, Scotland, Wales) and Northern Ireland. This means that organic products certified to either the USDA or UK organic standards may be labelled and sold as organic in both countries, as long as the products meet the terms of the arrangement.
This page will be updated as more information becomes available from the UK.
Scope. This equivalence is limited to organic products that have been either raised within the U.S. or UK, or products for which the final processing or packaging occurs within the U.S. or UK. This includes products processed or packaged in the U.S. or UK that contain organic ingredients from third countries that have been certified to the USDA or UK organic standards.
Allowed product categories: Crops, Wild Crops, Livestock, Processed Products.
Terms of the Arrangement. Generally, USDA and UK certified organic products are eligible for trade under this equivalence, but there are some stipulations.
The following products may not be exported to the U.S. as certified organic:
- Agricultural products derived from animals treated with antibiotics.
- Aquatic animals (e.g. fish, shellfish)
Wine must be produced and labelled according to the organic regulations of the destination country.
Documentation – Exports of USDA Organic Products.
- BEFORE January 1, 2021: For USDA organic products shipped before January 1, 2021, a USDA-accredited certifying agent must, complete an electronic Certificate of Inspection (COI) through the European Union’s (EU) Trade Control and Expert System (TRACES) for products shipped to the UK. All USDA organic products must comply with the terms of the U.S.-EU organic equivalence.
- ON/AFTER January 1, 2021: All organic goods imported from non-EU countries must continue to have a valid COI. There will be a new UK import process for all USDA organic products traded under the arrangement. Different documentation is required depending on whether the USDA organic product is exported to the UK-Great Britain (England, Scotland, Wales) or the UK-Northern Ireland.
- USDA organic products exported to the UK-Great Britain: A USDA-accredited certifying agent must issue a paper Certificate of Inspection (COI) before the products leave the U.S. and send to the UK Port Health Authority (PHA)/Local Authority (LA), usually by courier. The PHA/LA can endorse a copy if the original hasn’t arrived in order to clear the goods, though the original will need to be endorsed within 10 working days for the consignment to be sold on as organic. The NOP will link to the GB Certificate of Inspection as soon as it is available.
- USDA organic products exported to the UK-Northern Ireland: Pursuant to the Northern Ireland/Ireland Protocol, the EU organic regulations will remain applicable in Northern Ireland. Exports from the U.S. to Northern Ireland will continue to adhere to the EU procedures and will continue to require an EU COI. A USDA-accredited certifying agent must complete an electronic Certificate of Inspection (COI) through the European Union’s Trade Control and Expert System (TRACES) before the product leaves the U.S. Certain edits to the COI may only be made within 10 days of issuing the original COI.
U.S. organic businesses that encounter issues with USDA organic exports arriving in the UK are encouraged to work with their UK importer. You may also email the UK authorities at Organic.Imports@defra.gov.uk
Documentation – Imports of UK Organic Products. A certifying agent supervised by the UK’s Department of Environment, Food and Rural Affairs (DEFRA) and accredited in compliance with the UK’s organic regulations must complete a U.S. National Organic Program (NOP) Import Certificate, Form 2110-1, for all UK organic products traded under the arrangement whether originating from Great Britain or Northern Ireland.
The equivalence arrangement only covers products certified in and exported from the U.S. or the UK.
Labeling. Exported products must meet the labelling requirements in the destination country. For UK retail products destined for the U.S., the labels must state the name of the UK certifying agent.
- USDA Organic Seal
- Visit the Government of the UK website for more information about labelling. https://www.gov.uk/guidance/trading-and-labelling-organic-food-from-1-january-2021
Oversight. The U.S. and UK will notify one another with any changes to their organic standards or certifying agent policies. They will also assess each other’s systems on a regular basis to ensure that the terms of the arrangement are being met. Any issues will be resolved by an Organic Working Group, which will have representatives on both sides of the Atlantic.