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Home > International Trade > Trade Agreements > U.S. – United Kingdom Organic Equivalence Arrangement

U.S. – United Kingdom Organic Equivalence Arrangement

As of January 1, 2021, USDA and EU certified organic products can move freely between the U.S. and the United Kingdom, which includes England, Scotland, Wales, and Northern Ireland. This agreement was reached in anticipation of the UK leaving the European Union on December 31, 2020, providing certainty and ensuring market access for U.S. exporters. The United Kingdom is the eighth largest market for U.S. exports, an important destination that also serves as a gateway to the larger European Union.

Importantly, this agreement largely mirrors the U.S. – European Union organic equivalence arrangement, with the exception of export certificates. With limited exceptions, organic products certified to the USDA or EU organic standards that meet the terms of this arrangement may be labeled and sold as organic in both countries.


Background, Clarifications, Scope

Under the arrangement as of January 1, 2021, the United Kingdom’s Department for Environment, Food, and Rural Affairs (DEFRA) recognizes the USDA National Organic Program as equivalent to the requirements of the European Union organic legislation.

This arrangement only applies to organic products that have been grown or produced in the U.S. or UK, or products whose final processing or packaging occurs within the U.S. or UK. Products that contain organic ingredients from third countries that are certified to the USDA or EU standards are allowed under this arrangement.

Allowed product categories: Crops, Wild Crops, Livestock, Processed Products.

Critical Variances

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.

Required Export Documents

U.S. Organic Exports to Great Britain (England, Scotland, Wales)

A new form is now required for U.S. exports to Great Britain. Previously, the TRACES online system was required, however beginning Jan 1, 2021, a USDA accredited certifier must issue a paper Certificate of Inspection (COI) before the product leaves the U.S. This certificate must be sent directly to the UK Port Health Authority (PHA).

Click HERE for the COI required for Exports to Great Britain

  • Important: The PHA 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.

U.S. Organic Exports to Northern Ireland

As a result of the Northern Ireland/ Ireland Protocol, the European Union’s Trade Control and Expert System TRACES system will be used for US exports to Northern Ireland. A USDA-accredited certifying agent must complete an electronic Certificate of Inspection (COI) through TRACES before the product leaves the U.S.

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

Required Import Documents

For UK organic products that will be shipped to the U.S., a DEFRA accredited certifier 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.

NOP Import Certificate

NOP Import Certificate Instructions

Labeling

Exported products 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.

For U.S. products destined for the UK, please visit the UK’s labeling website for all requirements.

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.

For more information, please visit the NOP International Page      


Contact

OTA Members can direct questions about this agreement to:

Alexis Carey
Associate Director, International Trade
(202) 403-8515

Bob Anderson
Senior International Trade Advisor
(814) 571-1063