Organic importer in the EU: what you must arrange with Skal

An organic importer brings products from outside the EU into the Netherlands and sells them here as organic. You then have a certification obligation with Skal Biocontrole (Skal organic inspection body) , the Dutch control body. The rules for imports are set out in Regulation (EU) 2018/848 , which has applied since 1 January 2022.

As an importer, you must be able to show three things: that the country of origin has equivalent rules, that a valid COI certificate comes with the consignment, and that Skal has checked the consignment at entry. You can find out whether you must be certified yourself on frequently asked questions. What certification of your business involves is set out on the Skal certificate.

In short, you only import organic products if your business is certified, the country of origin meets the requirements, and you bring in every consignment with the correct papers. Without those papers, you may not sell the product as organic.

Who is an organic importer?

You are an importer if you bring organic products from outside the EU into the EU. This also applies if you only resell them and change nothing. You do not need to pack or process anything yourself to fall under the rules.

Take a fictional company: Olijfhof Import BV. It brings organic olive oil from Tunisia and supplies it to supermarkets in the Netherlands. Olijfhof Import BV is an importer. It must get certified by Skal and bring in every batch with the correct papers.

Step 1: check whether the country of origin is equivalent

The first question is where the product comes from. The EU looks at the country itself and at the control body that checked the production. There are two routes.

Route	What it means	Example
Recognised third country	The country has equivalent rules for organic production and is on the list in Annex I of Implementing Regulation (EU) 2021/2325.	Olive oil from a country on that list, as with Olijfhof Import BV
Other third country	The product must be certified by a recognised control body listed in Annex II of Implementing Regulation (EU) 2021/1378.	A product from a country without an equivalence agreement

If you are unsure about your country of origin, ask Skal at info@skal.nl. For products from places such as Northern Ireland, Norway, Iceland, Liechtenstein or Switzerland, a separate arrangement may apply. Ask Skal about that too.

Step 2: the COI certificate via TRACES

For every import, you need a control certificate. This is the COI, the Certificate of Inspection for import of products from organic production. The COI is held in TRACES, the European trade control system.

You request the COI from the certifying body of the foreign supplier. That supplier must also be registered in TRACES as an exporter. You must be registered in TRACES as an importer of organic products. Ask your own control body which registration is needed for this.

For a batch cleared in several parts, you create an extract in TRACES each time. The competent authority signs off on that. Note: you are ultimately responsible for making sure the electronic COI is present and signed before the consignment leaves the country of origin.

A consignment without a signed COI will not pass the check as organic. Check the COI in TRACES before the consignment departs, not only on arrival.

Step 3: the check at entry

At entry, Skal Biocontrole checks organic products from countries outside the EU. Since 1 April 2026, Skal passes those inspection costs on to the importer. Previously, the Ministry of LVVN (Agriculture, Fisheries, Food Security and Nature) bore those costs. Ask Skal for the current rates via info@skal.nl.

Food safety has its own process: the consignment must be notified in advance to border control. Ask the NVWA (Netherlands Food and Consumer Product Safety Authority) how that notification works. You often file the customs declaration through your customs forwarder. For this, you need an EORI number.

Which documents must you be able to show?

At an inspection, you want to be able to show the right papers for each consignment. Below are the documents that belong with a Dutch importer.

Document	What for	Where you find it
COI certificate (electronic)	Proof that the product was checked as organic at origin	TRACES, requested from the supplier’s certifying body
Extract for partial clearance	Proof per occasion that you clear part of the batch	TRACES, signed off by the competent authority
Skal certificate of your own business	Proof that you are certified as an importer	With Skal, see the Skal certificate
Quality manual or quality plan	Procedures for traceability and complaints	Your own business, needed for your certification with Skal
Import declaration and EORI number	Customs matters	Your customs forwarder
Registration as a food importer	Oversight of food safety	Ask the NVWA which registration applies to your product

Who is responsible?

As an importer, you are responsible for the COI, the registration in TRACES and your own certification with Skal. The customs declaration is usually done by your forwarder or carrier. The forwarder does not take over that responsibility for the COI.

Record the tasks in the contract with your forwarder and your supplier. Then everyone knows who does what if something goes wrong.

Frequently asked questions

Do I still need my own certificate if I only import?

Yes. The certification obligation applies to every business that imports organic products, even if you do not pack or process anything. You request your certificate from Skal, as described on the Skal certificate.

What if my supplier comes from a country without equivalence?

Then the product must be certified by a control body from Annex II of Implementing Regulation (EU) 2021/1378. Work out with the supplier which control body that is, and ask Skal whether that route works for your product.

How do I check whether a COI is genuine?

Check the COI in TRACES. Look at whether the supplier, the product and the validity match. Also check whether the COI is signed. To find out how to check a business and its certificate, read the list of Skal-certified businesses.