A brand owner building a tea range for German grocery retail asked a question that arrives with most European private label projects: can the product be organic? The honest answer is that "organic" on a tea box is not an ingredient decision. It is a certified chain, and every link in it — the packer included — has to hold. This article sets out what the EU rules ask for, so a brand owner can plan a claim on facts.
A certified chain, not a certified ingredient
Regulation (EU) 2018/848 governs organic production and labelling in the Union. Its central requirement for anyone in the supply chain is membership of the control system: operators who produce, prepare, pack, store, import or market organic products must be certified by a recognised control body and subject to its inspections.
The consequence for a packed tea is direct. Organic-certified chamomile, blended and packed by an operator who is not in the control system, cannot be sold as organic. The certificate on the raw material does not travel through an uncertified packer. That is the rule most new brands discover late, usually at artwork stage, and it is worth knowing first.
What the box must show
Where the EU organic logo appears, two pieces of information must sit in the same field of vision.
The first is the code number of the control body responsible for the last operator who handled the product. The second is a statement of where the agricultural raw materials were farmed: "EU Agriculture", "non-EU Agriculture" or "EU/non-EU Agriculture", with the option of naming a country where all the raw material comes from one country. Small ingredients under a threshold can be left out of that calculation, but the statement itself is not optional when the logo is used.
For prepacked organic food produced within the Union the logo is mandatory. For imported product it is optional, but if it is used, the same accompanying information applies. A brand planning a retail box for the EU should plan for all three elements — logo, code number, origin statement — to be correct on the first print.