Compliance guide

EU organic record-keeping for small producers

If you sell food or drink as organic in the EU, Regulation (EU) 2018/848 makes you an "operator" who must keep documentary accounts that let a control body trace and verify every batch. For small and micro craft producers the rules are the same as for large factories, only the volumes differ. This guide explains what to record, how the input-output balance is checked, what happens at your annual inspection, and how to label a certified product.

Guidance only, not legal advice · Reviewed 2026 against Regulation (EU) 2018/848 and the European Commission organic farming pages.

What Regulation (EU) 2018/848 requires of you

Regulation (EU) 2018/848 on organic production and labelling of organic products has applied since 1 January 2022, replacing the older Regulation (EC) 834/2007. It sets a single EU-wide framework for how organic food and drink is produced, controlled and labelled, and it applies to every business in the chain, from a one-person farm or micro-brewery up to a large processor.

Before you may sell or label anything as organic you must notify your activity to the competent authority in your Member State and place your business under the control of an approved control authority or control body. From that point you are an "operator" with legal obligations: produce to the organic rules, keep records that make your business verifiable, and submit to inspection.

The core duties that touch your records

Keep documentary accounts, including stock and financial records, that let the control body check what came in and what went out.
Ensure traceability of every product at each stage of production, preparation and distribution.
Make the input-output (mass) balance of your operation reconcilable, so quantities of organic inputs and organic outputs add up.
Take precautionary measures to avoid contamination or mixing with non-organic products, and record them.

The records you must keep: documentary accounts and the mass balance

The heart of organic control is the documentary account. A control body must be able to sit at your table and follow a certified product backwards to its organic ingredients and forwards to your customers, using your own paperwork. This is why organic is often described as a "paper trail" scheme rather than a lab-testing scheme: the records are the evidence.

The check that catches most problems is the input-output, or mass, balance. Over a period, the certified organic raw materials you bought (plus opening stock) should reconcile with the organic product you made, sold, still hold, or lost to waste and processing. If you sold more organic litres or kilograms than you can account for buying, that is a red flag for the inspector.

Records a small producer typically needs on hand

Purchase records for every organic input, with supplier, quantity, lot and a copy of the supplier's organic certificate.
Production or batch records linking inputs to each batch, with quantities and dates.
Stock records showing organic and non-organic held separately.
Sales and dispatch records with quantities, lots and customers.
Records of any losses, downgrades, cleaning between organic and non-organic runs, and non-organic ingredients used within the permitted limits.

Traceability at every stage

Traceability must run through your whole operation, not just at the point of sale. From receiving an organic delivery, through storage, processing and packing, to dispatch, each step should carry a lot or batch reference that ties back to the previous one. If a customer or authority queries a specific pack, you should be able to identify the batch, the inputs that went into it, and where the rest of that batch went.

For a craft producer the practical test is simple: pick any finished product on your shelf and see whether you can reconstruct its full history from your records in a few minutes. If you can, your traceability is working. If it takes an afternoon of digging, an inspector will find gaps.

Annual inspection and the organic certificate

Compliance is verified by your control authority or control body, which carries out a physical inspection of your operation at least once a year. The rules allow a reduced frequency, at most one physical inspection every two years, for operators assessed as low-risk with no recorded non-compliances over the previous three years, but for most small producers you should plan on an annual on-site visit plus the possibility of unannounced or risk-based checks and sampling.

The inspection reviews your records, walks your premises, checks storage and separation, and works through the mass balance. If you are compliant, the control body issues or maintains your certificate (the certificate required under Article 35), which identifies the categories of products covered and their status as "organic" or "in conversion". This certificate is your proof to customers and buyers, and it is issued in electronic form, including via the EU's TRACES system.

Keep your records current all year, not just before the visit, so the mass balance always reconciles.
Have purchase invoices, supplier certificates, batch records and sales records ready to cross-check.
Walk your own premises beforehand to confirm organic and non-organic stock are clearly separated and labelled.
Address any non-conformities from the previous inspection and keep evidence that you did.

Labelling: the EU organic logo, code number and place of farming

You may only use the term "organic" and the EU organic logo once you are certified and the product contains at least 95% organic agricultural ingredients by weight, with the remaining share meeting the regulation's conditions. For pre-packaged organic food produced in the EU, the green leaf EU organic logo is mandatory.

What must appear with the logo

The code number of your control authority or control body, in the same visual field as the logo, in the format two-letter country code, a reference to organic production, and a reference number (for example XX-BIO-999).
The place of farming of the agricultural raw materials, directly below the code number: "EU Agriculture", "non-EU Agriculture", or "EU/non-EU Agriculture" (a country name may be added where all raw materials were farmed there).
Small quantities of ingredients may be disregarded for the EU/non-EU indication, provided they do not exceed 5% of the total weight of agricultural raw materials.

Getting the logo, code number and place-of-farming line right matters: incorrect or missing organic labelling is one of the more common findings at inspection, and it is entirely within your control.

Conversion periods

Land and products do not become organic overnight. A conversion period must be completed before produce can be sold as fully organic. As a general rule this is two years before sowing for annual crops and grassland, and three years before the first harvest for perennial crops such as vines, hops or fruit trees; livestock and products have their own conversion rules. During conversion, produce may only be labelled "in conversion to organic" where the regulation allows, and for plant products only after at least 12 months of conversion.

If you buy in already-certified organic ingredients rather than growing your own, the conversion clock sits with your suppliers, but you still need their valid certificates on file. If you farm or grow any inputs yourself, build the conversion timeline into your plans early, because it directly determines when you can first label output as organic.

How fermt helps

fermt is an EU-hosted ERP and traceability system built for small and micro craft food and drink producers, so the organic paper trail is a by-product of running your day-to-day operations rather than a separate chore. Because every purchase, batch and sale is captured as you work, the documentary account an inspector wants to see is already assembled.

When your control body asks you to prove the input-output balance for a period or trace a single pack back to its organic inputs, fermt lets you follow the batch links instead of hunting through folders, which turns inspection preparation from an afternoon into a few clicks.

Batch records that link each finished product to its organic inputs, quantities and lots for full forward and backward traceability.
Purchase and supplier records where you can store organic certificates and flag inputs as organic or in-conversion.
Stock and sales data that let you reconcile the organic mass balance across a period before your annual inspection.
EU-hosted data, keeping your records inside the EU and GDPR-aligned.

Start free trial Compliance in fermt

Frequently asked questions

Does Regulation (EU) 2018/848 apply to a very small or micro producer?

Yes. The regulation applies to any operator that produces, prepares or sells products as organic in the EU, regardless of size. The obligations to keep documentary accounts, ensure traceability and undergo inspection are the same for a one-person craft producer as for a large processor; only your volumes and paperwork burden are smaller.

What exactly is the input-output or mass balance check?

It is a reconciliation the control body performs during inspection. Over a period, your certified organic inputs (plus opening stock) should account for the organic product you sold, still hold, and lost to processing or waste. If you cannot show enough organic input to justify your organic output, it signals possible mislabelling or mixing.

How often will I be inspected?

At least once a year through a physical on-site inspection by your control authority or control body, alongside possible risk-based or unannounced checks and sampling. The rules allow a reduced frequency, at most once every two years, for operators verified as low-risk with no non-compliances over the previous three years, but small producers should generally plan for an annual visit.

When can I use the word organic and the EU organic logo?

Only once you are certified and the product contains at least 95% organic agricultural ingredients by weight under the regulation's conditions. For pre-packaged organic food produced in the EU the green leaf logo is mandatory, shown with your control body's code number and the place-of-farming indication such as EU Agriculture.

What is the control body code number and where does it go?

It identifies the authority or body that certifies you, in the format of a country code, an organic reference and a number (for example XX-BIO-999). It must appear in the same visual field as the EU organic logo, with the place-of-farming line directly beneath it.

How long is the conversion period before I can sell as organic?

As a general rule, two years before sowing for annual crops and grassland and three years before the first harvest for perennial crops, with separate rules for livestock. If you buy in already-certified organic ingredients the conversion sits with your suppliers, but you must keep their valid certificates on file.