EU Public consultation on high-risk products from third countries
By Nuria Alonso
In July 2026, the European Commission launched a consultation with a view to establishing a list of imported organic products considered to be “high risk”. The consultation was opened until 24th of August. Currently, the feedback from the participants is available at: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14328-High-risk-organic-and-in-conversion-products-from-non-EU-countries-detailed-list/feedback_en?p_id=25557.
The draft regulation (https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=PI_COM:Ares(2026)7374948) presented for consultation sets out a list of organic or in-conversion products imported from third countries that are considered high risk due to their involvement in cases of “major, critical or repeated non-compliances compromising their integrity or production”.
The products concerned are:
- Ginger, tea and soybeans from China
- Bananas from Ecuador and Peru
- Soybeans from Togo
- Raisins from Turkey
- Avocados and cocoa produced in Peru
Inclusion on this list will subject these products to additional controls and sampling, to be carried out by the competent authorities and control bodies in third countries, as well as by the authorities of the Member States.
Accordingly, between 5% and 20% of consignments destined for the EU will have to be inspected in the third country, while a further 5% to 10% will be inspected by Member States upon arrival in the Union.
Twenty organisations participated in the consultation, most of them from Europe, some of them working internationally, and also participating organisations from some of the importing countries such as Turkey and Ecuador.
The Alliance for Organic Integrity (AOI) provided an input that is based also on recent experiences with fraud cases.
The Alliance noted on their comments 7 out of the 9 high-risk organic and in-conversion products originating from third countries (HR CC) listed in the proposed Annex were also listed on earlier HR CC lists in 2023, 2024 and 2025, some for all three years, and that some are high volume commodities.
AOI commented that fraudulent practices are not always in the traces of a residue found as reported in OFIS, but in the use of other non-approved inputs that are not detected by sampling at import. Therefore, measures listed in the proposed Annex that are limited to sampling of consignments will not be enough.
AOI proposed other measures such as additional control measures and recommended that Additional Physical Controls are better and sharperly formulated.
Other consultations are in preparation, like a revision of an implementing regulation to improve the efficiency of the organic import system and others on approved inputs, or another one on a competitiveness action plan for the organic sector.
It is useful to check the website https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives_en?text=organic which compiles all EU Commission consultations on organic matters. Those in preparation, those closed, those adopted by the Commission, those published for information and those abandoned, especially if one is interested in contributing to those initiatives in preparation.