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Checking organic certificates of suppliers under Article 35

Organic farms must check their suppliers' certificates. Where to find certificates, what to look for and how to document the check.

PhytAI editorial teamPublished 5 min read

Key points

  • Duty: under Article 35(6) of Regulation (EU) 2018/848, operators check the certificates of their suppliers.
  • Certificate: it names the operator, the product categories and the period of validity.
  • Where to find it: since 1 January 2023, organic certificates under the EU organic regulation have been issued and published in the TRACES database.
  • Seed: organic seed is mandatory where available; in Germany availability is checked in organicXseeds, where derogations are also requested.
  • Farm inputs: fertilisers and plant protection products must be authorised in the annexes of Implementing Regulation (EU) 2021/1165; a dealer's organic certificate does not replace this check.

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Organic farms buy seed, young plants, feed or produce from other organic businesses. During the annual organic inspection the farm must show that these goods really come from certified production. The EU organic regulation puts it briefly: operators check the certificates of their suppliers. This article explains what an organic certificate contains, where to check it, what applies to seed and farm inputs, and how to file the check so that the control body can follow it. The examples refer to Germany, but the EU rules apply in every member state.

What an organic certificate contains

Under Article 35(1) of Regulation (EU) 2018/848, competent authorities or control bodies issue a certificate to operators that comply with the rules, in electronic form where possible. It states at least:

  • the identity of the operator
  • the categories of products covered by the certificate
  • the period of validity

Paragraph 7 sets out the categories, including unprocessed plants and plant products including seed and other plant reproductive material, animals and animal products, processed agricultural products, feed and wine. Under paragraph 2, operators may only place products on the market as organic if they already hold a certificate.

Why the category matters

A valid certificate alone is not enough. It must cover the category you are buying. A dealer certified for processed food is not automatically certified for feed or young plants. For every supplier, check whether the product category of your goods appears on the certificate and whether the delivery date falls within the period of validity.

Where to check certificates

The German information platform oekolandbau.de names three routes:

  1. TRACES: since 1 January 2023 all organic certificates under the EU organic regulation must be issued and published through the TRACES database system, where certificates can be searched.
  2. Directory of control bodies: for German businesses, the Federal Association of Organic Control Bodies offers a directory of inspected operators.
  3. bioC: according to oekolandbau.de, this online directory contains information on more than 130,000 farms and businesses from 36 control bodies.

Download the certificate when you check it, or keep a dated printout. This lets you show later which version applied at the time of purchase.

What the inspection checks in plant production

According to oekolandbau.de, the control body checks among other things in organic plant production:

  • the field records as the central documentation of all measures per field
  • the conversion periods and the clear separation between organic and in-conversion produce
  • seed and planting material: organic seed must be used where available; the control body checks purchases and any derogations
  • farm inputs such as fertilisers and plant protection products against the authorised lists in Annexes I and II of Implementing Regulation (EU) 2021/1165
  • the precautionary concept against contamination and mixing
  • the flow of goods from purchase to sale using invoices, delivery notes and storage records

Seed and planting material

Seed follows its own route. According to FiBL, organicXseeds is the official organic seed database in Germany. If suitable organic seed is not available, untreated conventional seed may be used after checking the database and with a derogation. The derogation is requested directly in the database. Keep the derogation, the delivery note and the seed supplier's certificate together.

Farm inputs without an organic certificate

Fertilisers, soil improvers and plant protection products are generally not organic products with their own certificate. What matters is that the substance or active ingredient is authorised for organic production in Implementing Regulation (EU) 2021/1165 and that its use is recorded. Input lists from private providers can make the choice easier, but the regulation remains decisive.

Conversion and status per field

The control body checks from when a field counts as organic. Produce from fields in conversion may only be marketed with the corresponding labelling. Anyone renting in or giving up fields should keep the status per field with a date so that harvested produce can be assigned to the right category.

Common mistakes

  • supplier's certificate expired, delivery still booked as organic
  • product category not checked, for example feed from a dealer without that category
  • only the control number on the invoice noted, certificate never looked at
  • conventional seed sown without a derogation
  • fertiliser from the farm supply store used without checking Annex II
  • produce from conversion fields mixed with organic produce

How to proceed on the farm

  1. Keep a supplier list: record all suppliers of organic goods with control body and certificate.
  2. Check the certificate: compare category and validity in TRACES or with the control body.
  3. File the evidence: save the certificate with the date of the check.
  4. Watch expiry: request the new certificate before validity ends.
  5. Link purchases: assign each receipt to the supplier and the valid certificate.

Organic evidence in PhytAI

PhytAI keeps the organic status per field with a date: conventional, in conversion or organic. For suppliers, the farm adds certificates with type, validity and file, as checked by the farm. PhytAI shows which suppliers with stock receipts have no valid certificate and reminds you before expiry. There is no automatic query of TRACES; the check stays with the farm, and PhytAI keeps it traceable.

Frequently asked questions

Do I have to check the certificate again for every delivery? What matters is that a valid certificate with the right category existed on the delivery date. Checking when a supplier is added and before validity ends is a practical approach.

Is the organic control number on the invoice enough? It is an indication but does not replace checking the certificate under Article 35(6).

Do dealers need an organic certificate for fertilisers? For fertilisers, what matters is the authorisation of the substance under Implementing Regulation (EU) 2021/1165, not a dealer's certificate.

Sources

This article reflects the situation on the date shown, based on the sources named, and is not legal advice. Laws, approvals, official decisions and the guidance of the competent authorities prevail.

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