Organic Processing and Trade Association Europe e.V.
OPTA Europe
As the voice of the EU organic processing and trade companies, OPTA’s key mission is to lead and coordinate the dialogue among the combined European and international organic processors and traders and to defend the common interests of members towards the relevant national, European, international authorities and stakeholders in all policy areas affecting them.
ID: 168090639506-30
Lobbying Activity
Meeting with Gijs Schilthuis (Director Agriculture and Rural Development) and
27 Jan 2026 · Exchange of views on the Commission’s proposal for a targeted amendment of the organic basic regulation.
Response to Modification of rules on organic trade and simplification
18 Nov 2025
OPTA Europe is the membership organization representing the interest of European Organic Processing and Trade companies. Its members account for a large share of total EU trade and processing of organic products and play an essential role in an efficient supply chain. We are grateful for the opportunity to comment on this public consultation on targeted updates and simplification of the organic regulation.Our complete response is enclosed. A summary of our key suggestions: 1. Herbaria II Court Case: amend the basic act to retain the concept of organic equivalence and maintain the labelling of organic products imported under equivalence agreements; 2. Trade in organic products with equivalent countries: Delay by 5 years the 2026 expiration date for the recognition of equivalent third countries to avoid trade disruption and allow sufficient time to negotiate robust and balanced agreements; 3. Removing complexities in a targeted way: a. Regulate more effectively cleaning agents and disinfectants based on the clear criteria already set out in horizontal legislation; b. Update the eligibility criteria for groups of operators (turnover and legal structure) to reflect current economic and legal conditions. Apply risk-based controls to contain certification costs; c. Allow a safe and rational addition of essential vitamins, minerals and nutrients in organic food to foster innovation and reach new consumers; d. Amend the rules related to the presence of non-authorized substances and products to make them simpler and consistent: -readjust the inappropriate weight attributed to such presence as indicator of non-compliance ; -remove the burden of proof from the organic operator; -set up a maximum duration limit for official investigations; -set up a differentiated procedure for processed products, with harmonized processing factors; -provide a definition for presence ; -accept the most likely source and the cause of the presence of non-authorized products and substances as conclusion of official investigations. Thanks for taking our comments into consideration.
Read full responseResponse to Import into the Union of high-risk organic and in-conversion products
11 Jul 2025
OPTA Europe is the membership organization representing the interest of European Organic Processing and Trade companies. Its members account for a large share of total EU trade and processing of organic products and play an essential role in an efficient supply chain. OPTA Europes members are committed to fight against fraud to protect consumer and preserve the confidence in the organic logo. We are grateful for the opportunity to comment on this draft Regulation, which is of the utmost importance for our members engaged in cross-border trade. Including products and countries in the high-risk list must be carefully managed as it has serious consequences for all concerned operators -also those who are not suspected of infringement - and the supply chains they are part of. Other the reputational challenge, stricter import checks entail longer customs procedures, more red tape and higher costs. With this in mind, we would like to suggest a vector for proportionality when drawing up the list of high-risk countries and products: it should be fixed on the basis of a ratio between major, critical or repetitive non-compliances affecting the integrity of organic or in-conversion products and the total imports of the concerned product & third country. Furthermore, we would like to highlight that, in its current state, OFIS database does not constitute a solid basis for drawing up the high-risk list as a) it focuses on the presence of non- authorized substances, not taking sufficiently into consideration the rest of non- compliances and b) is statistically not representative. Our arguments are explained in the attached document.
Read full responseResponse to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)
12 May 2025
OPTA Europe (www.opta-eu.org) is the membership organization representing the interest of EU organic processing and trade companies, as defined in Regulation (EU) 2018/848 on organic production and labelling of organic products. OPTA Europes members account for a large share of total trade of certified organic ingredients & products. They work with thousands of farmers across the world and offer them support and technical advice to switch to organic production. Hence, contributing to a global transformation of agriculture to meet the needs of food security and ecosystem preservation. OPTA Europe welcomes the proposed changes to exclude commercial samples from the list of relevant commodities and products covered by the EUDR. Cocoa beans and coffee are amongst the main imported organic products. Manufactured coffee and cocoa products often require blending up to 30 different types to achieve the desired flavor and quality that meet consumer expectations. Consequently, importers and processors handle thousands of samples annually, of which only a portion corresponds to products ultimately imported into the EU. Against this background, we warmly welcome the proposed changes to exclude commercial samples from the scope of the EUDR. We estimate that this change will save medium-sized coffee & cocoa importers to manually generate DDS codes for approximately 2,000 samples annually, greatly decreasing cost and labour.
Read full responseMeeting with Irene Sacristan Sanchez (Head of Unit Health and Food Safety)
7 Apr 2025 · Commission proposal on plants obtained by certain new genomic techniques (NGT proposal)
Meeting with Luis Carazo Jimenez (Head of Unit Agriculture and Rural Development)
7 Apr 2025 · Challenges for the processing of and trade with organic products
Response to Amendment of the list of products and substances authorised in organic production
4 Mar 2025
Thanks for this consultation. Our suggestions in the enclosed file. OPTA Europe (www.opta-eu.org) is the membership organization representing the interest of European organic processing and trade companies. OPTA Europes members account for a large share of total EU imports and processing of organic products and play an essential role in an efficient organic supply chain. I. Comments to Annex V Part A - In general terms, we welcome that the lists of food additives and food processing aids in annex V Part A Sections A1 and A2 have been merged into a single one, the classification -and labelling- of substances with dual use depending on its technological function in the final product. This facilitates the readability of legislation, aligns with horizontal laws and avoids interpretation problems. We have a remark to make on Annex V Part A: Agricultural ingredients or processing aids? - We call attention that vegetable oils and vinegars are fully-fledged foodstuffs that can be added as agricultural ingredients to other foods. Their inclusion in annex V as processing aids leads to confusion. For the sake of clarity and uniform interpretation of the provisions by authorities and food industry, we invite the legislator to clearly explain why a narrow selection of agricultural ingredients has been included in annex V or to remove them altogether from the annex. II. Comments to Annex VI - PART A- Products and substances authorised for use in organic production in third countries As a general principle, we welcome the recognition that different countries and regions of the world have their own challenges, advantages and production conditions (climate) and it is therefore reasonable to expect different production methods. We also applaud that biocontrol solutions are prominently featured in the proposal. We have the following remarks on Annex VI- Part A: Flexibility in the absence of a reasonable transitional period - This IR is an essential piece of the compliance import regime, which applies in full since January 2025. A clear and reasonable transitional period has not been granted to third country operators, manufacturers of the concerned products & substances and control entities to comply with the new legal requirements laid down in this regulation. Thus, we expect a great degree of flexibility in the early stages to guarantee the compliance of imported organic products that have been produced using products & substances authorised under the previous equivalence regime. A fluid authorization process to reduce the period of legal uncertainty, please consider a continuous authorization process with 1 or 2 annual publications in the first years of implementation. Along the same line, we note that the natural substance Swinglea Glutinosa extract has not been included in Annex VI even though a technical dossier was timely submitted and that it has received a positive recommendation from EGTOP. Such exclusion sends a discouraging message to applicants by further hindering the application on process for new natural substance approvals in the EU. Clear and enforceable rules - we note a new insertion in the specifications for microorganisms to be not produced by using growing media of GMO origin. Without questioning the GMO-free underlying principle, we would like to highlight that such obligation differs from those of trade partners. As supporters of free and fair trade of organic products, in first place we advocate for regulatory convergence with our main trading partners. In the absence of such harmonized approach, EU importers would like to receive clear indications as to how the Commission & competent authorities expect this obligation to be enforced in practice and at what level of the organic certification & control chain, to avoid imports delayed or reported as uncompliant with EU rules due to lack of clear implementation guidelines. Thanks for taking our comments into consideration.
Read full response19 Nov 2024
Exports of EU agri-food products is a success story and organic should play a larger role in it. Equivalence arrangements are instrumental to that objective; on that grounds OPTA Europe welcomes the proposed extension of the scope of the equivalence arrangement with Japan to cover categories of EU products with high export interest such as livestock, dairy products and alcoholic drinks. Likewise, we would like to see a similar enlargement of the scope of the equivalence arrangement with other key trading partners to facilitate the exports of product categories that contribute the most to the EU positive trade balance. We take the opportunity to suggest other tools to support organic exporters: Specific Combined Nomenclature (CN) Code: to establish an accurate picture of the trade performance of organic products Country-by-country clear information about import conditions and market analysis for organic products: to support EU exporters find the most suitable markets for their products. For this purpose, existing tools such as REAs Food & Beverage Market-Entry Handbooks could further elaborate on organics. We hope our suggestions can be taken into consideration.
Read full responseResponse to Import into the Union of high-risk organic and in-conversion products
16 Jul 2024
OPTA Europe (www.opta-eu.org) is the membership organization representing the interest of European Organic Processing and Trade companies. It is important for EU manufacturing companies to secure the imports of organic ingredients because the sourcing alternatives are limited, given that a big share is not or little produced in the EU (tropical fruits, spices, coffee, cocoa....etc). We welcome the flexibility introduced by the proposed regulation, that will allow to reduce the share of consignments subject to physical checks and sampling. Checks and sampling on 100% of consignments delay the trade flow and increases the administrative burden and cost of the imported product for no gains in control efficiency, as experience as shown. In line with WTO / Codex Alimentarius standards, controls in origin and at EU borders must be proportional, fit for purpose and non-discriminatory.
Read full response14 Jun 2024
OPTA Europe (www.opta-eu.org) is the membership organization representing the interest of European Organic Processing and Trade companies. It is important for EU manufacturing companies to secure the imports of organic ingredients because the sourcing alternatives are limited, given that a big share is not or little produced in the EU (tropical fruits, spices, coffee, cocoa....etc). In case of trade disruption manufacturing companies will be forced to pull back operations as there is no possibility to switch to alternative supply sources. We thank the Commission for the publication of 2 new CBs recognized to carry out controls and issue organic certificates in third countries. As we get the information in dribs and drabs, we would like to restate the importance of having the entire list of recognized CBs published at least 6 months in advance of the expiration of their recognition in January 2025. In the food industry supply contracts are concluded several months in advance, thus EU companies need that information to liaise with their suppliers in third countries to conduct contracts, anticipate changes, make informed decisions and organize the necessary adjustments. Additionally we invite the Commission to work out pragmatic transitional solutions to prevent bottlenecks and delays in the obtention of certificates for those suppliers obliged to change of CB because its CB is not recognized anymore. Thank you very much for considering our comments.
Read full response14 Jun 2024
As the membership organization representing the interest of EU Organic Processing and Trade companies, OPTA Europe appreciates the efforts to find pragmatic solutions that prevent trade disruption and allow for a smooth transition to the compliance regime. It is important for EU manufacturing companies to secure the imports of organic ingredients because the sourcing alternatives are limited, given that a big share is not or little produced in the EU (tropical fruits, spices, coffee, cocoa....etc) With this purpose, we request an extension of the derogation period until 31.12.25 to respect the regular certification cycle, namely a full calendar year (01.01 to 31.12). This will avoid changing the terms of contracts for 2024 that have been concluded between suppliers in third countries and CBs, with a risk of a higher certification cost which will be reflected in the price of the product. It will also prevent market disturbances, bottlenecks and delays in the obtention of certificates due to CBs' reshuffle of the entire annual calendar of inspection, notably for those suppliers obliged to change of CB because its own CB is not recognized anymore. Thanks for taking our comments into consideration.
Read full responseResponse to Legislation for plants produced by certain new genomic techniques
25 Sept 2023
OPTA Europe - www.opta-eu.org - is the membership organization representing the interest of EU organic processing and trade companies, as officially recognized by EU institutions. Its membership encompasses 12 EU Member States plus 2 non-EU countries. Taken together, the companies represented by OPTA Europe account for a large share of total EU import & export and processing of organic products. We are thankful for the opportunity to express our views on this important text. In a nutshell: -As the EU stands at a crossroads concerning the future of our food system, we encourage policymakers to stand firmly on the side of agroecology, which excludes gene editing. -The proposal relies on a simplistic conception of the food supply chain ️ should NGTs be allowed, the proposal must be amended to ensure that organic operators are equipped with the necessary tools to fulfill the NGT prohibition in organics + the cost & burden of additional monitoring measures do not fall on their shoulders. Our full position is enclosed. --End---
Read full responseResponse to Amendment of the list of products and substances authorised in organic production
22 Aug 2023
OPTA Europe - www.opta-eu.org - is the membership organization representing the interest of EU organic processing and trade companies. Its membership encompasses 12 EU Member States plus 2 non-EU countries. Taken together, the companies represented by OPTA Europe account for a large share of total EU import & export and processing of organic products. OPTA Europes members are committed to deliver safe and trustable organic food to EU consumers. We thank you for the opportunity to comment on these draft rules. Our specific comments: -We welcome the authorization of E337 (potassium sodium tartrate) on organic products of plant origin, as it enlarges the processors toolbox without hampering the quality or the authenticity of the products where it is used (Art 1.6); -We duly note EGTOPs estimates of a three years timeframe to ensure that tartrates E 335, 336 and 337 from organic origin are available to all operators in sufficient quantity to cover the needs of the EU processing industry; we respectfully request the Commission and Member States to double check with industry before the entry into force in 2027 that this is effectively the case (Art 1.6); -We welcome the postponement of the provisions referring to the lists of products for cleaning and disinfection; it provides legal certainty to organic companies (Art 1.2). -End-
Read full responseResponse to Imported organic products - Supervision of third countries, control authorities and control bodies
6 Aug 2023
OPTA Europe - www.opta-eu.org - is the membership organization representing the interest of EU organic processing and trade companies. Its membership encompasses 12 EU Member States plus 2 non-EU countries. Taken together, the companies represented by OPTA Europe account for a large share of total EU import & export and processing of organic products. OPTA Europes members are committed to deliver safe and trustable organic food to EU consumers, whatever its geographical origin. We thank you for the opportunity to comment on these draft rules and for issuing a WTO notification opening the consultation to trading partners in third countries, as they are the first affected by the additional reporting and evaluation obligations imposed by this rule until the expiry of the recognition of the third countries or control authorities and control bodies. As a general comment, we believe that trade plays a key role in the promotion worldwide of EU sustainability standards. We hope that the additional control obligations imposed by this Regulation will be accompanied by capacity building activities for trading partners in emerging countries, to encourage them in the development of organics. For example, by increasing trainings on EU organic rules for responsible staff of controlling authorities at national, regional or local level under the Better Training for Safer Food program. Our specific comments on this draft regulation: -The EU has recently laid down the details and the format of the information for competent authorities of EU Member States to report on the results of official investigations concerning cases of contamination with products or substances not authorised for use in organic production (Commission Regulation 2023/1195). We suggest taking this updating opportunity to harmonize, to the extent possible, the reporting obligations on official investigations to be made available by third countries competent authorities with those required to EU Member States competent authorities, in particular when it comes to contamination with non-authorized products or substances. -When evaluating the capacity of Member States to assist the Commission on the review of recognition of third countries, the criteria of the number of votes in the Committee does not necessarily reflect its competence. The concentration of organic imports in certain EU countries implies that some national authorities have larger expertise, thus are more qualified. We suggest introducing additional criteria to ensure that Member States assisting the Commission are sufficiently skilled. In closing, we deplore the complexity of the EU legal framework for organics, which represents a real barrier for operators and trading partners with less resources for regulatory screening to access the proposed rules and to bring their viewpoint in public consultations on topics impacting them.
Read full responseResponse to Requirements for control bodies controlling operators in third countries for organic products sold in the EU
13 Jun 2023
OPTA Europe (www.opta-eu.org) is the membership organization representing the interest of European Organic Processing and Trade companies. Its members account for a large share of total EU trade and processing of organic products and play an essential role in an efficient supply chain. Imported commodities are essential for EU organic processing companies. Because organic imports are mostly products not or little produced in the European Union, in case of insufficient recognized control authorities/control bodies, EU processing companies would be forced to pull back operations, as they would not have the possibility to switch to alternative supply sources. Discontinuity of imports will also limit the choice of EU organic consumers. In light of the above considerations, we welcome the Commissions efforts to ensure a smooth transition from the equivalence to the compliance import regime and to avert possible risks of trade disruptions, like this proposed draft regulation to ease the procedural requirements for the recognition and supervision of control bodies/control authorities responsible for certifying operators in third countries. Another key element to ensure that the new import regime does not create unnecessary burden for EU companies is business predictability. Considering that EU operators need 6-12 months to make the necessary adjustments resulting from a change of the control body responsible for certifying their suppliers in third countries, we kindly ask the Commission to regularly inform EU stakeholders about the evolution of the list of recognized control bodies/authorities and to ensure that the final list is communicated at least one 6-12 months in advance. Thank you very much for considering our comments.
Read full responseResponse to Environmental claims based on environmental footprint methods
3 Apr 2023
OPTA Europe (www.opta-eu.org) is the membership organization representing the interest of EU organic processing and trade companies. Its membership encompasses 11 EU Member States plus North America and Switzerland. Taken together, the companies represented by OPTA Europe account for a large share of total EU import & export and processing of organic products. In general terms, we applaud all initiatives enabling consumers to make informed purchasing decisions and creating a level-playing field for companies making green claims. For OPTA Europe, the Commissions proposal includes positive aspects but also major concerns: On the positive side, some key benefits of extensive agroecological systems, namely biodiversity and nature protection are recognized as important impacts that should be integrated when assessing the sustainability of food products; On the negative side: -the Commissions proposal does not address the reduction of chemical pesticides, which is a core feature of organics and a key target in the Farm to Fork and Biodiversity Strategies; -It is unclear if/how the choices in this piece of regulation preempt the upcoming regulatory proposal on Sustainable Food Systems & Sustainability Labelling, expected later this year. -there is a lack of coherence of the various provisions about environmental sustainability that are scattered in different legal texts and which apply equally to industrial goods and agricultural products. We would prefer a specific regulatory framework for agri-foodstuffs, able to model the multifunctional agricultural systems with their surrounding landscapes. Only with the appropriate definitions and tools the transformational approach in the Farm to Fork Strategy, with organics as one of its cornerstones, can be achieved. -End-
Read full responseResponse to Detailed production methods for organic salts
23 Dec 2022
OPTA Europe (www.opta-eu.org) is the membership organization representing the interest of European Organic Processing and Trade companies. OPTA Europe brings together key players from all across the EU and accounts for a large share of total EU processing and trade of organic products. Because more than 70% of what farmers produce is transformed into manufactured food products, processing companies play an essential role in the organic supply chain. Salt has an important technological role in the manufacturing of a wide range of organic foodstuffs as flavour enhancer and preserver, allowing foods to be safer to eat. As end-users of food grade salts, we would like to make the following comments: The discussion about the pertinency of including a non-agricultural product within the scope of this regulation is closed and therefore we will not get back to it. However, we would like to highlight that the rules on production of organic salt must be clear, evidence-based and in line with the organic principles. Failing to do so will result in a bad quality rule that damages the credibility of the EU organic standard and the consumer trust. Under the proposed rules 90% of salt production in the EU including the highest purity one stored in natural underground deposits - will not be able to qualify as organic. Furthermore, some provisions in the proposed text (i.e on additives, processing aids and non-organic ingredients) are more restrictive than EGTOPs recommendations. We fail to see the rationale and technical justification for such strict approach. These concerns have been raised by a wide array of stakeholders from all across the EU in the public consultation. To avoid the organic standard getting discredited by a weak consensus around a controversial topic that does not naturally fit the organic frame, we respectfully ask the Commission to withdraw the proposal and to postpone the adoption of the regulation, as to allow the necessary conditions for a balanced and informed decision-making. Our detailed comments are enclosed. We hope that they can be taken into consideration.
Read full responseMeeting with Martin Häusling (Member of the European Parliament)
8 Nov 2022 · Abendessen zum Austausch
30 Aug 2022
OPTA Europe (www.opta-eu.org) is the membership organization representing the interest of European Organic Processing and Trade companies. Its members account for a large share of total EU trade and processing of organic products and play an essential role in an efficient supply chain.
Guided by the objective of producing food in an environmentally friendly manner, OPTA Europe’s members have voluntarily adhered to organic standards, which rely on the use of natural substances and processes rather than on inputs with adverse effects. Risk-based analysis are conducted regularly along the supply chain to identify any issue that might affect the product’s integrity.
OPTA Europe’s members share the objective to elucidate the origin of contaminations from non-authorized substances, not least because we want to shine a spotlight on the small proportion that lies within the organic operator’s responsibility. Nonetheless, we call for a pragmatic approach that minimizes the burden and cost for industry.
Our detailed comments are enclosed. We thank you for the consultation and hope our comments can be taken into consideration.
Read full responseResponse to Update of the list of recognised third countries and control bodies for import of organic products
8 Aug 2022
OPTA Europe (www.opta-eu.org) is the membership organization representing the interest of European Organic Processing and Trade companies. Its members account for a large share of total EU trade and processing of organic products and play an essential role in an efficient supply chain.
We are grateful for the opportunity to comment on this draft Regulation, which is of the utmost importance for members.
OPTA Europe’s members import from India a number of ‘processed agricultural products for use as food’, such as mango puree or watermelon kernels, which are incorporated as ingredients into food by EU processing companies. A large share of these imports are approved by the control bodies to be withdrawn from the list of control authorities and control bodies recognised for India for the purpose of equivalence under Article 33(3) of Regulation (EC) 834/2007.
As a consequence, as from entry into force of the Regulation, the concerned EU processing companies will be forced to pull back operations or to miss production & delivery deadlines, with detrimental repercussion for the supply chain and for the brand’s reputation. Switching to alternative supply sources of other geographical origin is not always possible in the short-term; it requires time for both the importer and the processing company to put in place the necessary arrangements.
OPTA Europe’s members are committed to deliver safe and trustable organic food to consumers. We note that this regulation is the reaction to a transgression that happened almost 2 years ago, and for which corrective measures and border controls have been put in place. Insomuch as food safety and organic integrity are not at stake, we kindly ask a sufficient transitional period of at least 6 months to avoid a detrimental cascading effect throughout the product supply chain.
We thank you for the consultation and hope our comments can be taken into consideration.
Read full responseMeeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Assoziation ökologischer Lebensmittelherstellerinnen und -hersteller e.V.
24 Feb 2022 · Challenges and perspectives in the organics sector
Response to Trade rules for organic production (implementing)
4 Nov 2021
As OPTA Europe we - and other national organic business associations - would like to draw attention on the effects of this measure by the EU Commission for organic small holders in India and organic operators in EU. India is exporting country number 6 to EU and very important for many organic specialities for food and supply for organic feed ingredients for animal farming in EU as well.
The 5 CB's are responsible for 80% of the certification of exports to EU. We truly doubt that this can been taken over by the remaining CB's on the list at first of January. This is our main concern for the interest of farming and processing operators in both India and EU, who clearly are not to blame, but will carry the consequences if our concern becomes true.
Furthermore we are informed that the relationship between APEDA and the 5 CB's is so to say delicate. It is not so clear who of both parties cause the real problems. If APEDA would function well, why is this unconventional action of EU Commission needed? APEDA should have take action: they are the authority for the CB's in India as equivalent country for raw materials.
This should be clarified well, to be sure that we will not face the same problems via the remaining CB's in India. Perhaps it is a better idea to follow the line of USDA and take over the responsibility over the CB's directly to EU Commission (=end of equivalence).
Read full responseResponse to Review of the EU school fruit, vegetables and milk scheme - EU aid
9 Jul 2021
OPTA – the Association of Organic Processing and Trade Companies in Europe – is the voice of organic processing and trade companies across Europe. As such we are strongly supporting the European Commission’s initiative “Green New Deal” with the subsequent Farm to Fork Strategy and the Organic Action Plan.
Organic farming responds to the growing societal demand for healthy quality food produced at high environmental and animal welfare standards. It can contribute to the protection of nature and help reverse the degradation of ecosystems and it is an important tool in the fight against the growing Climate crisis. Therefore there is a strong need to raise the demand for organic products.
The EU school fruit, vegetables and milk scheme offers a major chance to fill the strategic commitments and plans of the EU Commission with life. Especially because it brings the youngest EU-generations into contact with sustainable and healthy organic fresh products. And as we all know, what you learn at young age will support you in your consumption habits for the rest of your life.
Therefore the minimum share of organic fruits, vegetables and milks/drinks offered under the future EU school scheme should at least be set at the level of 25% percent – in line with the Organic Action Plan. A higher share of organic products at the level of 50 to100%, would even indicate that the Commission is truly serious about achieving the goal and using all means at hand to bring the Farm to Fork goals into practice.
And off course that should go hand-in-hand with good and attractive educational information on organic agriculture and food production.
Read full response