Requirements for organic certification under SKAL

An organic business must meet the rules of Regulation (EU) 2018/848 . That regulation applies across the whole European Union and is the basis for the checks by Skal Biocontrole (Skal organic inspection body) . Skal checks your business against those rules, and you must be able to show that you comply with them.

The core of the requirements is simple. You manage the whole business organically, you only use permitted products, and you keep records of what you do. What that means in practice differs by type of business. Ask Skal which businesses must be certified. Read how registration works in costs and timeline.

Your whole business must be managed organically, not just the part you sell as organic. This is set out in Article 9(2) of the regulation.

The requirements at a glance

Requirement	What it means	Where it is set out
Whole business organic	All units are organic, or clearly separated	Article 9(2) and 9(7)
Only permitted substances	Fertilisers, crop protection and processing aids must be on the list	Article 9(3)
No prohibited techniques	No ionising radiation, no cloning	Article 9(4) and 9(5)
Precautionary measures	You take measures against mixing at every step	Article 9(6)
Separate records	You record separate units in your administration	Article 9(10)
Inspection and documentation	You get checked and you keep your records	Regulation (EU) 2018/848
Logo and code number	The EU organic logo and the code number of the control authority (for Skal NL-BIO-01)	Regulation (EU) 2018/848

Growing rules for growers

A grower follows rules for soil, seed and crops. The business must be managed organically as a whole. You may split a business into an organic part, a conversion part and a non-organic part, but only if those parts are clearly separated. For plants, the non-organic part must be a different, clearly distinguishable species or variety.

For perennial crops, such as fruit or wine, a rule applies that differs from the rest. You may make a conversion plan and then convert the whole crop within five years at most. Article 9(8) describes this. You notify the control authority at least 48 hours before harvest starts.

An example: a fictional vegetable grower in Flevoland has 12 hectares. He grows 8 hectares organically and 4 hectares conventionally. That is only allowed if the two parts are well separated, for example with separate machinery, storage and a clear record per field. Without that separation, he must convert the whole business.

Ingredients for processors

A processor makes products from organic raw materials. The requirements mainly concern ingredients and production. A product may only be called organic if it contains organic ingredients and the process follows the rules. Processors must also guard the separation between organic and conventional production on the production line, for example through cleaning between batches and separate storage.

Processors also face requirements on the composition of the product. Which ingredients are permitted, how much of the product must be organic, and how you prove it. The details are in the annexes to the regulation and in Skal’s checklists.

An example: a small sauce maker in Utrecht makes a tomato sauce with ten ingredients. Eight ingredients come from an organic supplier and the herbs come from a conventional supplier. The regulation sets how much of the agricultural ingredients must be organic and how you prove it. At inspection, the sauce maker shows which supplier delivers which ingredient.

Requirements for traders

A trader buys and sells organic products but does not process them. The strictest requirement for traders is traceability. For every product, you must be able to show where it came from and where it went. Keep the delivery documents, invoices and certificates of your suppliers for this.

Separation in the warehouse also counts. Organic products are kept apart from conventional products and clearly labelled. A trader must check for each supplier whether that supplier is certified itself. You check this with the Skal certificate.

An example: a wholesaler in potatoes does not import products itself but buys from a certified grower. The wholesaler keeps the grower’s certificate, the delivery note per batch and the sales invoices. At an inspection, it shows those three.

Registration and documentation

Every type of business must describe its processes. Skal’s checklists ask, among other things, for a business description, a risk management plan and a record of the incoming goods check. At the incoming goods check, you check every batch you receive for its organic status. You record this on a form or digitally.

You must also keep a complaints log. If you doubt the organic status of a product, report it to Skal. Keep documents for as long as Skal prescribes. The exact period is set out in Skal’s rules, so check it with Skal.

Many businesses think a good manual is enough. Skal also assesses what happens in practice. A manual that does not match the shop floor is a point of attention at inspection.

Traceability

Traceability means you can follow a product from start to finish. This is the requirement that comes back at almost every business. At an inspection, the inspector can pick a batch and ask which raw materials it contains, which supplier they came from and where the product was sold.

Link purchasing, production and sales for each batch. A spreadsheet with batch numbers is enough for a small business. Larger businesses use an administration system with batch registration.

Frequently asked questions

Must I make my whole business organic?

Yes, in principle. A business may keep part of it conventional, but only if the parts are clearly separated. See the growing rules above and conversion for the process.

Which substances may I use?

Only substances the regulation permits. For crop protection and fertilisers, a list of permitted products applies. Check the list before you use a new product, and ask Skal if you are unsure.

What does the inspection of these requirements cost?

The inspection costs are set out on Skal certification costs. The hourly rate for an inspection is €136. The inspector decides how much time they need.