Abstract
On 12 December 2025, the European Commission adopted Implementing Regulation (EU) 2025/2501, which amends Implementing Regulation (EU) 2021/1165 on the use of certain products and substances in organic production, and postpones the completion of the assessment of the list of organic cleaning and disinfectant inputs.
Background
The EU Organic Regulation (EU) 2018/848 lays down rules governing the production and labelling of organic products in the European Union. It revises and strengthens the control system, trade arrangements and production rules that have been in place since 2007. The shift from the principle of equivalence to that of compliance marks a fundamental change in the regulatory approach.
1.Pursuant to the procedure laid down in Article 24(7) of the EU Organic Regulation (EU) 2018/848, Member States have submitted information on certain substances to other Member States and to the Commission for approval and inclusion in Annex V to Commission Implementing Regulation (EU) 2021/1165. This information has been reviewed by the Expert Group on Technical Advice in Organic Production (‘EGTOP’) and by the Commission.
2.On the basis of EGTOP’s advice concerning foodstuffs, the use of pea protein and potato protein as processing aids for the clarification of fruit juices, fruit wines and mead should be approved.
3.In accordance with Article 5(1), (2) and (3) of Implementing Regulation (EU) 2021/1165, EGTOP has also launched the assessment of substances to be approved for cleaning and disinfection in organic production. However, this assessment has taken longer than anticipated at the time of adoption of Implementing Regulation (EU) 2021/1165.
Timeline
Implementing Regulation (EU) 2025/2501 shall apply and enter into force from 1 January 2026.
What has changed?
The list of organic inputs has been updated and revised:
Regulation (EU) 2025/2501 now authorises the use of pea protein and potato protein as processing aids for the clarification of fruit juices, fruit wines and mead. These substances will be added to the list of substances permitted for the production of organic products placed on the EU market (Regulation (EU) 2021/1165, Annex V).
Affected products: organic fruit juices, fruit wines and mead
Postponement of the completion of the assessment of organic cleaning and disinfection inputs:EGTOP is still evaluating which substances may be authorised for use in cleaning and disinfection in organic production. As the assessment has taken longer than expected, Regulation (EU) 2025/2501 introduces the following adjustments to ensure policy continuity:
Annex VII to the former EU Regulation (EC) No 889/2008 (the original list of cleaning and disinfection inputs) shall continue to apply until 31 December 2027.
The relevant provisions of the EU Organic Regulation 848 concerning the list of cleaning and disinfection inputs shall be deferred and enter into force only on 1 January 2028.
SRS Certification will continue to dynamically monitor regulatory policies and industry updates. It is recommended that organic enterprises and clients stay closely informed and contact the SRS Certification team for the latest cutting-edge information, so as to proactively respond to the latest regulatory changes.
