Importing organic food from the UK to Poland – GB Organic certification and documents

Importing organic food from Great Britain to Poland after Brexit requires precise documentation and a working knowledge of two separate organic certification systems. Following the UK's departure from the European Union, the UK introduced its own rules governing the production and labelling of organic food — the so-called GB Organic Regulation. At the same time, the EU and the UK concluded a provisional agreement on mutual recognition of organic certificates, valid until the end of 2027, which in practice allows products certified by UK control bodies to be imported into EU member states without the need for re-certification. For a Polish importer this translates into concrete obligations: verifying the supplier's certificate, registering in TRACES NT, submitting a pre-notification before the consignment crosses the border, and completing a correct customs declaration. Any shortcoming can result in the goods being detained at the border or refused entry to the market. This article explains, step by step, how to import organic food from the UK safely and in full compliance with the regulations.

What is GB Organic and how does it differ from EU Organic?

After Brexit, Great Britain adopted its own organic production regulation based on EU Organic Regulation (Regulation 2018/848), but operating as a separate legal system. The GB Organic Regulation applies in England, Wales and Scotland. Northern Ireland follows EU rules under the Windsor Framework.

Key differences between GB Organic and EU Organic:

Criterion	EU Organic (EU)	GB Organic (UK)
Legal basis	Reg. 2018/848	UK Organic Regulations 2020
Supervisory body	National agencies (e.g. IJHARS in PL)	APHA (Animal and Plant Health Agency)
Control body register	OFIS (EU)	OFIS UK (gov.uk)
Label	EU organic logo	GB Organic logo
Mutual recognition	Until 2027 (UK→EU)	Until 2027 (EU→UK)

Mutual recognition means that a certificate issued by a control body approved by APHA (e.g. Soil Association, OF&G, Organic Farmers & Growers) is accepted in the EU until the end of the transitional period. A Polish importer does not need to re-certify the product, but must hold and produce a Certificate of Inspection (CoI).

Which UK control bodies are recognised in the EU?

The list of UK control bodies approved to export to the EU is published by the European Commission and updated annually. For 2026 the recognised bodies include, among others:

• Soil Association Certification — one of the oldest and most widely recognised control bodies
• OF&G (Organic Farmers & Growers) — specialises in certifying farmers and processors
• Organic Food Federation (OFF) — certification for small and medium-sized producers
• Quality Welsh Food Certification (QWFC) — Wales
• Biodynamic Association Certification — biodynamic farming

Before entering into a contract with a UK supplier you must always verify that their control body appears on the EC list as authorised to issue CoIs for export to the EU. The list is available on EUR-Lex and within the TRACES NT system.

Certificate of Inspection (CoI) — the key to clearance

A CoI (Certificate of Inspection) is an electronic document confirming the organic status of a consignment. Since Brexit it is issued exclusively in TRACES NT (Trade Control and Expert System — New Technology), administered by the European Commission.

How the CoI process works in practice:

1. The UK exporter submits a CoI application to their control body (e.g. Soil Association)
2. The control body verifies the consignment and issues the CoI in TRACES NT
3. The Polish importer or their authorised customs agent confirms receipt in TRACES NT
4. The CoI document accompanies the consignment and is presented at customs clearance at the EU border
5. The competent control authority in Poland (IJHARS) may request sight of the CoI

Important: the CoI must be issued before the goods are despatched from the UK. Absence of a CoI at the point of clearance means the product cannot be admitted to the market as organic.

Pre-notification in TRACES NT — importer obligations

The importer or their customs agent is required to submit a pre-notification in TRACES NT at least 1 working day before the expected arrival of the consignment at the point of entry into the EU.

The pre-notification must contain: - importer and exporter details - CoI reference number - description of goods (product name, CN code, net/gross weight) - means of transport and expected arrival date - designation of the competent control authority in Poland (IJHARS)

The pre-notification enables the control authorities to plan any documentary or physical inspection. An incorrect or late pre-notification may result in clearance delays.

Documents required for customs clearance

Complete documentation for customs clearance of organic food imported from the UK:

Document	Issued by	Notes
Certificate of Inspection (CoI)	UK control body	Electronic, TRACES NT
Commercial Invoice	UK exporter	Product description, value, Incoterms
Origin evidence / UK Origin Statement	UK exporter	Required for 0% TCA duty rate
Phytosanitary import certificate	APHA/PHYTOSANITARY	Where applicable (vegetables, fruit)
Product specification / labels	UK producer	Confirmation of GB Organic status
Transport document (CMR/AWB)	Carrier

Duty rates and the TCA benefit

Under the Trade and Cooperation Agreement (TCA) between the EU and the UK, products meeting the rules of origin (UK origin) may be imported at a 0% duty rate. This applies to the vast majority of organic food produced in the UK.

To benefit from the preferential 0% rate: - the product must satisfy the rules of origin (wholly obtained for unprocessed food, or sufficient processing for processed goods) - the UK exporter must issue a UK Origin Statement or hold Registered Exporter (REX) status - the importer must retain the documentation for a minimum of 4 years

Where no proof-of-origin document is available, the EU MFN tariff rates apply; for foodstuffs these range from 0% to several tens of per cent depending on the CN code.

What happens if a certificate expires during transit?

This is one of the most common issues when importing organic food on long routes or where transport delays occur. The producer's organic certificate (not the CoI) has a limited validity — it is typically renewed annually by the control body.

If the supplier's certificate expired after the CoI was issued but before the goods reached the EU border:

• The CoI remains valid provided it was issued while the producer's certificate was in force
• The importer should immediately contact the UK control body to confirm the status
• IJHARS may carry out additional documentary verification
• The goods may be temporarily detained pending clarification — which is why it is always worth checking certificate expiry dates before loading

Practical tip: ask your UK supplier for a copy of their current organic certificate (not just the CoI) and check its expiry date before each transaction.

Phytosanitary inspection — when is it required?

Not every organic food product from the UK requires a phytosanitary inspection, but certain categories of goods are subject to border controls:

• fresh fruit and vegetables → phytosanitary import certificate required
• fresh herbs → phytosanitary certificate required
• seeds and planting material → phytosanitary certificate required
• processed products (preserves, juices, dried fruit) → generally not required

Phytosanitary inspections take place at designated Border Control Posts (BCPs). In Poland these include Warsaw Okęcie, Gdynia, and Dorohusk. It is important to remember that the organic certificate (CoI) and the phytosanitary certificate are two separate documents — both must be complete.

How to organise the import of organic food from the UK step by step

A practical action plan for a Polish importer:

1. Choose your supplier — verify their organic certificate in OFIS UK (gov.uk register). Confirm that their control body is recognised by the EC as authorised to issue CoIs for the EU.
2. Sign the contract — include a clause requiring the CoI to be provided before despatch and a UK Origin Statement for the 0% duty rate.
3. Arrange issuance of the CoI — the supplier/exporter submits the application to their control body at least a few days before despatch.
4. Submit the pre-notification in TRACES NT — no later than 1 working day before the goods arrive at the EU border.
5. Lodge the customs declaration — the customs agent submits the import declaration (PL SAD) with the correct procedure code, citing the CoI and TCA documents.
6. IJHARS verification — if IJHARS requests an inspection, the goods wait in a customs warehouse or GKG storage facility until verification is complete.
7. Release for free circulation — once verification is passed successfully, the goods may be sold as organic on the Polish and EU market.