agroforst 1199


Internal Control Systems (ICS) enable smallholder farmers to access organic certification and hence organic markets and their associated benefits. Currently, more than 150 cooperatives or producer groups are members of the Naturland association.

In 2018, the EU has adopted a new organic regulation 2018/848 that sets new rules for group certification with ICS, which are further defined in the Implementing Regulation (EU) 2021/279.

However, it has not yet been published, therefore some uncertainty remains regarding the interpretation of some of the new conditions.


The most important changes affecting ICS groups

  1. ICS in the EU and worldwide: Group certification will be possible for producer groups worldwide, including producer groups within the EU.
  2. Detailed rules for ICS: The regulation sets stronger and clearer rules for group certification, for example for documentation, internal inspections or farmers training. For groups that already have a quality ICS, e.g. Naturland certified groups, there are no material changes.
  3. Group size: The size of producer groups is limited to a maximum of 2000 members per group. Larger groups need to be split into smaller group entities. This rule must be implemented from January 2025 onwards. Naturland has advocated that this limit shall only apply for the purpose of certification. This has been confirmed by the EU Commission in writing towards the BÖLW, our umbrella organization in Germany, but such wording had not been included in the Implementing Act itself. Therefore, more guidance on the implications is still needed by the EU Commission.
  4. Group composition: The producer group shall be composed only of farmers that meet the new size restrictions. The maximum farm size for group members is 5 ha. Alternatively, farmers can be a member of the producer group if their individual certification cost is >2% of the organic turnover and their organic turnover is not more than 25 000 EUR per year.
  5. Groups must have „legal personality“: Every group of operators to be certified must have a legal personality. This is likely to imply that processors working with smallholder farmers may need to form a legal “group entity” with only the organic farmers as members, as well as ICS staff.
  6. External control of groups: The new regulation requires a minimum of 5% of group members to be re-inspected by the external inspection body. In addition, sampling for residue analysis is required for 2% of group members.

The new EU organic regulation aims to strengthen and harmonize group certification. But it also creates major challenges, as the administrative efforts and certification cost increases, especially for larger groups.


Naturland will continue to support all producer groups

From the beginning, the EU Commission intended to allow only small groups of farmers to be certified. In its initial proposals, the EU Commission wanted to limit the maximum number of farmers per group to 500. Together with other international actors, Naturland actively lobbied for their farmers. Now there will be a group limit of up to 2000 farmers and the minimum re-inspection rate was lowered from 10% to 5%.

All-new rules for farmer groups must be implemented by 01.01.2022, only for maximum group size a transition period is defined until January 2025. However, a transition period of 3 years is defined for control bodies to change from the criteria of equivalency to compliance. This may also give farmer groups more time to comply with the new rules. More guidance on the implementation of the new regulation is therefore needed.