The United States (U.S.) has an equivalence arrangement with the United Kingdom (UK), which includes Great Britain (England, Scotland, Wales) and Northern Ireland. The equivalence arrangement grants USDA certified organic products access to the UK’s market and grants UK certified organic products access to the U.S. market. This means that organic products certified to either the USDA or UK organic standards may be labeled and sold as organic in both countries, as long as the products meet the terms of the arrangement.
Scope. This equivalence arrangement is limited to country-to-country trade. For U.S. exports to the UK, the arrangement is limited to products certified to the USDA organic regulations that are produced or have had their final processing occur within the U.S. For UK exports to the U.S., the arrangement is limited to products certified under the UK organic program that are produced or have had their final processing occur in the UK.
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.
- Wine must be produced and labelled according to the organic regulations of the destination country.
The following are additional requirements for certified UK organic products exported to the U.S.:
- Agricultural products derived from animals treated with antibiotics shall not be sold, labeled, or represented as organic in the U.S.
- Aquatic animals (e.g., fish, shellfish) are not included in the equivalence arrangement and are not eligible to use the USDA organic seal.
Trade Documentation.
Exports of USDA Organic Products. The UK requires that all organic goods entering from non-EU countries must continue to have a valid Certificate of Inspection (COI). Different documentation is required depending on whether the USDA organic product is exported to the UK-Great Britain (England, Scotland, Wales) or to the UK-Northern Ireland.
- USDA organic products exported to the UK-Great Britain: A USDA-accredited certifying agent must issue a Great Britain Certificate of Inspection (COI) before the products leave the U.S. and send it electronically by email to the UK Port Health Authority (PHA)/Local Authority (LA). (The UK discourages sending paper documents.) 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 as organic.
- To obtain the GB COI, send an email with your request to Organic.Imports@defra.gov.uk.
- Find more information about UK Port health authorities and food imports. You may already know the port or airport you intend to use. If you’re unsure, you can get a list and full contact details, including port authority emails, from the Association of Port Health Authorities (APHA).
- 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
U.S. Imports of UK Organic Products. All UK organic products imported to the U.S. under the arrangement must be associated with an electronic organic import certificate, called the NOP Import Certificate (pdf). NOP Import Certificates are generated by UK-accredited certifying agents in the NOP’s GLOBAL Organic Integrity Database. The documentation must include this statement:
“Certified in compliance with the terms of the U.S.-UK Organic Equivalence Arrangement.”
Labeling. Products traded under this arrangement must meet the labeling 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. There is no UK organic seal.
Oversight. The U.S. and UK assess each other’s systems on a regular basis to ensure that the terms of the arrangement are being met and equivalence is maintained. Both parties notify each other of any changes which could affect the terms of the arrangement. Any concerns are addressed by the Organic Working Group, which meets regularly and includes experts from both countries.
Peer Reviews. Since the establishment of the U.S.- UK Equivalence Arrangement, the U.S. and UK have conducted mutual peer reviews. These assessments verify that both markets are meeting the terms of the arrangement.
Peer Review Reports:
U.S. Peer Review Report of the United Kingdom (pdf)
Historical Documents
- Equivalence Arrangement: Letter to USDA (pdf)
- Equivalence Arrangement: Letter to UK DEFRA (pdf)
- Equivalence announcement: Organic Insider
Resources