6. The first subparagraph of Article 2 of Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety ( 4 ) provides:
Provisional text
OPINION OF ADVOCATE GENERAL
RANTOS
delivered on 11 June 2026 ( 1 )
Case C ‑ 495/25
Syndicat professionnel du chanvre
v
Institut national de l’origine et de la qualité (INAO),
interested party:
Ministre de l’Agriculture et de la Souveraineté alimentaire
(Request for a preliminary ruling from the Conseil d’État (France))
( Reference for a preliminary ruling – Common agricultural policy – Regulation (EU) 2018/848 – Organic production and labelling of organic products – Article 2(1) – Processed agricultural product for use as food – Articles 34 and 35 – Organic certification – Regulation (EU) 2015/2283 – Novel foods – Article 6(2) – Absence of a food marketing authorisation – Cannabidiol )
Introduction
1. Cannabidiol (CBD) is a natural chemical substance of the cannabidinoid family, which is found inter alia in the hemp plant ( Cannabis sativa ). CBD has no psychoactive effects and is therefore not considered to be a narcotic drug, ( 2 ) unlike another cannabinoid also present in that plant, tetrahydrocannabinol (THC), which is the main psychoactive substance of the narcotic drug known as ‘marijuana’. The placing on the market of products containing CBD is therefore not subject to a general prohibition.
2. Although studies have been carried out to identify the therapeutic properties of CBD, they have produced virtually no conclusive results, at least as regards pure CBD, that is to say CBD not associated with THC. ( 3 ) That does not prevent sellers of various products containing CBD from sometimes attributing to it properties ranging from the promotion of general ‘well-being’ to the ‘reduction’ of pain, anxiety or insomnia, or even the cure of a number of illnesses both in humans and in pets.
3. Moreover, CBD, in particular in the form of products intended to be smoked, is sometimes presented as a substitute for narcotic drugs under names such as legal weed or ‘legal marijuana’, although it is not known to have any psychoactive property, at least if the amount of THC in those products is negligeable.
4. Producers and sellers of products containing CBD look for ways to meet their customers’ demand for ‘organic’ products. However, the only category in which CBD could be certified as being organic is that of processed products intended for human consumption. Since CBD has not been authorised to be placed on the market as a foodstuff, it is doubtful whether it could obtain such certification.
5. Thus, the present case provides the Court with an opportunity to rule on the question of the interdependence between the law concerning organic farming and that concerning the marketing of food.
Legal context
E uropean U nion law
Regulation (EC) No 178/2002
6. The first subparagraph of Article 2 of Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety ( 4 ) provides:
‘For the purposes of this Regulation, “food” (or “foodstuff”) means any substance or product, whether processed, partially processed or unprocessed, intended to be, or reasonably expected to be ingested by humans.’
7. Article 3(1) and (8) of that regulation provides:
‘For the purposes of this Regulation:
1. “food law” means the laws, regulations and administrative provisions governing food in general, and food safety in particular, whether at Community or national level …
…
8. “placing on the market” means the holding of food or feed for the purpose of sale, including offering for sale or any other form of transfer, whether free of charge or not, and the sale, distribution, and other forms of transfer themselves’
8. According to Article 12(1) of that regulation:
‘Food and feed exported or re-exported from the Community for placing on the market of a third country shall comply with the relevant requirements of food law, unless otherwise requested by the authorities of the importing country or established by the laws, regulations, standards, codes of practice and other legal and administrative procedures as may be in force in the importing country.
In other circumstances, except in the case where foods are injurious to health or feeds are unsafe, food and feed can only be exported or re-exported if the competent authorities of the country of destination have expressly agreed, after having been fully informed of the reasons for which and the circumstances in which the food or feed concerned could not be placed on the market in the Community.’
Regulation (EU) 2015/2283
9. Article 3(1) of Regulation (EU) 2015/2283 of the European Parliament and of the Council of 25 November 2015 on novel foods, amending Regulation (EU) No 1169/2011 of the European Parliament and of the Council and repealing Regulation (EC) No 258/97 of the European Parliament and of the Council and Commission Regulation (EC) No 1852/2001 ( 5 ) provides:
‘For the purposes of this Regulation, the definitions laid down in Articles 2 and 3 of [Regulation No 178/2002] apply.’
10. According to Article 6(2) of that regulation:
‘Only novel foods authorised and included in the Union list may be placed on the market within the Union as such, or used in or on foods, in accordance with the conditions of use and the labelling requirements specified therein.’
11. Article 7 of that regulation provides inter alia:
‘The Commission shall only authorise and include a novel food in the Union list if it complies with the following conditions:
(a) the food does not, on the basis of the scientific evidence available, pose a safety risk to human health;
(b) the food’s intended use does not mislead the consumer …
…’
Regulation (EU) 2018/848
12. Article 2(1) and (4) of Regulation (EU) 2018/848 of the European Parliament and of the Council of 30 May 2018 on organic production and labelling of organic products and repealing Council Regulation (EC) No 834/2007 ( 6 ) provides:
‘1. This Regulation applies to the following products originating from agriculture, including aquaculture and beekeeping, as listed in Annex I to the TFEU and to products originating from those products, where such products are, or are intended to be, produced, prepared, labelled, distributed, placed on the market, imported into or exported from the Union:
…
(b) processed agricultural products for use as food;
…
4. Except where otherwise provided, this Regulation applies without prejudice to related Union legislation, in particular, legislation in the fields of safety of the food chain, animal health and welfare, plant health and plant reproductive material.’
13. The first subparagraph of Article 34(1) and Article 35(1), (3) and (7) of that regulation provide:
‘Article 34
Certification system
1. Prior to placing any products on the market as ‘organic’ or as ‘in-conversion’ or prior to the conversion period, operators and groups of operators referred to in Article 36 which produce, prepare, distribute or store organic or in-conversion products, which import such products from a third country or export such products to a third country, or which place such products on the market, shall notify their activity to the competent authorities of the Member State in which it is carried out and in which their undertaking is subject to the control system.
…
Article 35
Certificate
1. Competent authorities, or, where appropriate, control authorities or control bodies, shall provide a certificate to any operator or group of operators that has notified its activity in accordance with Article 34(1) and complies with this Regulation. The certificate shall:
…
(b) allow at least the identification of the operator or group of operators including the list of the members, the category of products covered by the certificate and its period of validity;
…
3. The certificate referred to in this Article shall be an official certificate within the meaning of Article 86(1)(a) of Regulation (EU) 2017/625. [( 7 )]
…
7. For the purposes of paragraphs 1 and 4 of this Article, products shall be classified in accordance with the following categories:
…
(d) processed agricultural products, including aquaculture products, for use as food;
…’
Le droit français
14. Article L. 641-13 of the code rural et de la pêche maritime (Rural and Maritime Fishing Code) provides:
‘The “organic farming” indication can be used in respect of processed and unprocessed agricultural products satisfying the requirements under [EU] law for organic production and the labelling of organic products or, where appropriate, the conditions established in technical specifications approved by order of the ministry or ministries concerned at the request of the Institut national de l’origine et de la qualité [INAO].’
The dispute in the main proceedings, the procedure and the questions referred for a preliminary ruling
15. On 2 June 2021 the INAO informed the organic certification bodies that flowers and leaves of hemp, and also CBD, could not be granted organic certification or used in food certified as organic. That position was reiterated and clarified in a letter of 17 August 2021 stating that it was not possible to certify as organic CBD-based products or food products enriched with CBD.
16. The Syndicat professionnel du chanvre (SPC) requested the INAO to repeal that position, which was equivalent to a guideline. Since the INAO’s failure to respond to that request had given rise to an implicit decision of rejection, on 20 April 2022 the SPC brought an action before the Conseil d’État (France), the referring court, for annulment of that decision.
17. By email of 7 February 2023, the INAO informed the organic certification bodies that hemp leaves and flowers could henceforth be certified as organic, thus repealing its position on this point.
18. According to the findings of the referring court, which are not challenged by the parties, CBD must be classified, for the purposes of applying Regulation 2018/848, as ‘a processed agricultural product for use as food’. That court states, moreover, that, as regards the application of the provisions of Regulation 2015/2283, the European Commission, first, classified cannabis extracts and products derived therefrom containing cannabinoids, including CBD, as ‘novel foods’ and, secondly, did not put them on the list of novel foods authorised to be placed on the market within the European Union. ( 8 )
19. In those circumstances, the Conseil d’État decided to stay the proceedings and to refer to the Court of Justice the following questions:
‘(1) Does the fact that CBD intended to be ingested by humans is regarded as a ‘novel food’ within the meaning of Regulation [2015/2283], the placing of which on the market as a foodstuff has not been authorised, preclude it from being regarded as a ‘processed agricultural product for use as food’ coming within the scope of products which may be granted organic farming certification?
(2) If the previous question is answered in the negative, does the very fact that the placing on the EU market of CBD intended to be ingested by humans has not been authorised preclude producers of CBD and food products containing CBD from seeking organic farming certification for those products, even though it comes within the scope of products which may be granted organic farming certification?’
20. The request for a preliminary ruling was received at the Court on 18 July 2025. Written observations were submitted by the SPC, the French and Bulgarian Governments and by the Commission. Those parties were represented at the hearing, which took place on 23 April 2026.
Analysis
21. By the questions it has referred for a preliminary ruling, which I propose to analyse together, the referring court asks, in essence, whether Article 2(1)(b) of Regulation 2018/848, read in conjunction with Article 6(2) of Regulation 2015/2283, must be interpreted as precluding a substance classified as a ‘novel food’ within the meaning of Regulation 2015/2283, but which has not been authorised to be placed on the market under that regulation, being certified organic under Regulation 2018/848 as a ‘processed agricultural product for use as food’, within the meaning of that regulation.
22. According to a now classic formula, the meaning and scope of the terms of a provision of EU law must normally be given an autonomous and uniform interpretation throughout the European Union, which must take into account the wording of that provision, its context and the objectives pursued by the rules of which it forms part. ( 9 ) It is therefore those aspects of Article 2(1)(b) of Regulation 2018/848 that must be analysed.
The wording of Article 2 ( 1 )( b) of Regulation 2018/848
23. According to Article 2(1)(b), Regulation 2018/848 is intended to apply inter alia to processed agricultural products for use as food, where such products are, or are intended to be, produced, prepared, labelled, distributed, placed on the market, imported into or exported from the European Union.
24. As regards the words ‘products for use as food’, it should be noted that many of the language versions use the same words both in the article under analysis and in the first subparagraph of Article 2 of Regulation No 178/2002. ( 10 ) Furthermore, there seems to me to be no doubt that even in the versions which, like the French-language version, use (slightly) different words in those two provisions, those words meet the – very broad and general – definition of ‘food’ contained in the first subparagraph of Article 2 of Regulation No 178/2002. The words ‘denrées alimentaires’ are moreover also used in the recitals and in the provisions of Regulation 2018/848 in its French-language version. The products referred to in Article 2(1)(b) of that regulation are therefore for use as food, within the meaning of the first subparagraph of Article 2 of Regulation No 178/2002.
25. It remains to be determined whether those products must necessarily be authorised to be placed on the market in order for them to be covered by Article 2(1) of Regulation 2018/848 and therefore fall within the scope of that regulation.
26. As regards the words ‘product’ or ‘agricultural product’, it follows to my mind, both from the provisions of the articles of the TFEU concerning the common agricultural policy and from the instruments of secondary legislation in that field, including Regulation 2018/848, that those words concern the products of farming as an economic activity, the value of which is therefore intended to be increased by their being placed on the market. In other words, an item is a ‘product’ within the meaning of that legislation only if it is intended to be placed on the market.
27. Consequently, the use, in relation to (agricultural) products, of the phrase ‘where they are, or are intended to be, produced’ in Article 2(1) of Regulation 2018/848, refers to production with a view to the placing on the market of those products. It follows that Article 2(1)(b) of that regulation refers to processed agricultural products intended to be placed on the market as food.
28. However, to be placed on the market a product requires authorisation. ( 11 ) As regards food, such authorisation must be granted in accordance with food law, in this case, in particular Regulation 2015/2283.
29. However, contrary to what the SPC seems to suggest in its observations, the granting of authorisation to place novel foods on the market is neither automatic nor just a matter of time. Under Article 7 of Regulation 2015/2283, such authorisation is subject to compliance with certain conditions, including, in particular, the condition that the food should not pose a safety risk to human health in the light of the available scientific evidence. Certification of products pending hypothetical authorisation to place them on the market is therefore meaningless. ( 12 )
30. Consequently, a product cannot be regarded as being intended to be placed on the market if it is not authorised to be so or at least if authorisation to place it on the market is not certain and imminent.
31. That view is supported by the definition of the concept ‘placing on the market’ appearing in Article 3(8) of Regulation No 178/2002. That definition covers not only the actual placing of food on the market but also the holding of food for the purpose of placing it on the market, and any other form of transfer of food. Authorisation to place on the market is therefore, in practice, necessary for all the operations listed in Article 2(1) of Regulation 2018/848, including production which involves holding for the purpose of sale.
32. Moreover, that view is not altered by the SPC’s argument that organic certification might concern products intended solely for export, without being placed on the market in the European Union.
33. In the first place, Article 35 of Regulation 2018/848 does not appear to allow certificates to be issued solely in respect of products intended for export, since the certificates do not state the marketing destination of the products concerned but merely their category. Secondly, under Article 12 of Regulation No 178/2002, food intended for export must, in principle, also comply with EU food law and the exportation of food that does not have a marketing authorisation is possible only exceptionally, subject to authorisation by the authorities of the country of destination.
34. Thus, in my view, it follows from the wording of Article 2(1)(b) of Regulation 2018/848 that only processed agricultural products for use as food that are authorised to be placed on the market, or at least those for which marketing authorisation is certain and imminent, fall within that regulation and may therefore be certified as organic.
The objecti ve s of Regulation 2018/848
35. The objectives of Regulation 2018/848 are set out in detail in the recitals to that regulation. Thus, in particular, recital 1 states that ‘organic production … plays a dual societal role, where, on the one hand, it provides for a specific market responding to consumer demand for organic products and, on the other hand, it delivers publicly available goods that contribute to the protection of the environment and animal welfare, as well as to rural development.’ Recital 3 of Regulation 2018/848 adds that ‘… the growing consumer demand for organic products creates conditions for further development and expansion of the market in those products and thus for an increase in the return of farmers engaged in organic production.’
36. Next, according to recital 6 of Regulation 2018/848, ‘… the legal framework established for implementing [the European Union’s organic production policy] should aim at ensuring fair competition and the proper functioning of the internal market in organic products, at maintaining and justifying consumer confidence in products labelled as organic’, recital 10 stating that ‘moreover, [that regulation] should cover processed agricultural products for use as food or feed because the placing of such products on the market as organic products provides a major outlet for agricultural products and ensures that the organic nature of the agricultural products from which they are processed is visible to the consumer’.
37. Lastly, recital 73 of Regulation 2018/848 states that ‘the labelling of agricultural products and foodstuffs should be subject to the general rules …, and in particular to the provisions aimed at preventing labelling that might confuse or mislead consumers’, and that the provisions relating to the labelling of organic products ‘should protect both the interests of operators in having their products correctly identified on the market and in enjoying conditions of fair competition, and the interests of consumers in being able to make informed choices’.
38. Two conclusions may be drawn from those objectives.
39. First, organic production and the associated certification are not an end in themselves. They are not used solely to certify compliance with organic production standards. Their objective is to issue a certificate in order to distinguish, through appropriate labelling, a category of products on the market. They therefore clearly have a commercial objective, namely, to meet the demand of some consumers searching the market for products, in particular food, which may be described as ‘natural’, and to enable producers to derive a reasonable return from them. Consequently, allowing organic certification of products that are not authorised to be placed on the market does not contribute to achieving the objectives of Regulation 2018/848 in any way.
40. Secondly, organic certification is designed inter alia to increase consumers’ confidence in organic products. Certification of products that are not authorised to be placed on the market would amount to abuse of such confidence. Indeed, allowing such products to be presented as being officially certified as organic might mislead consumers and cause them to believe that those products have been approved by the public authorities for marketing and that they do not pose any safety risk to human health, which is not the case. ( 13 )
41. To allow the organic certification of products which are not authorised to be placed on the market would, in my view, clearly conflict with the objective of Regulation 2018/848 to increase consumer confidence.
42. The example of CBD is particularly telling in this regard. The manufacturers and sellers of that product take advantage of the ambiguous situation in which it finds itself, due, first, to its association with cannabis as a narcotic drug and, secondly to the many uses to which it lends itself, as a product intended for smoking, or for use as a cosmetic product, a quasi-medicinal product or a food ingredient.
43. Thus, it is undisputed that food products containing CBD were present on the EU market before that substance was classified as a ‘novel food’ and made subject to authorisation. Also, some of those products were not withdrawn from the market but were simply reclassified as ‘cosmetic products’ or ‘collectibles’. ( 14 ) Organic certification would risk increasing the confusion.
44. Therefore, the only interpretation consistent with the objectives of Regulation 2018/848 is, in my view, that substances that are not authorised to be placed on the market cannot fall within that regulation and be certified as organic.
The context of Article 2 ( 1 )( b) of Regulation 2018/848
45. Article 2(1) of Regulation 2018/848 defines the scope of that regulation. The context in which that provision should be analysed therefore includes the context of that regulation. That context is set out inter alia in Article 2(4), which states that that regulation applies ‘without prejudice to related Union legislation, in particular, legislation in the [field] of safety of the food chain’.
46. It follows in my view, first, as the Commission noted in its observations, that Regulation 2018/848 does not derogate from the provisions of EU law concerning food safety, such as those of Regulation 2015/2283. Organic certification is therefore not a substitute for authorisation to place a novel food on the market.
47. Secondly, the SPC’s argument that Regulation 2018/848 operates completely independently from acts such as Regulation 2015/2283 or Regulation No 178/2002 because it was adopted on a different legal basis seems to me to be unfounded.
48. The legal basis for an act of EU secondary legislation serves only to establish the competence of the EU to adopt such an act. However, once adopted, all the acts of EU law form a single legal order and are therefore interdependent. Rules such as the one contained in Article 2(4) of Regulation 2018/848 ensure consistency in the interpretation and application of those acts.
49. Since the bulk of the food on the market comes from agricultural production, it would be absurd to contend that the acts governing those two fields apply totally independently from one another. Quite the contrary: those acts are complementary and must be applied together, so that all the requirements they impose are met. ( 15 ) Thus, although Regulation 2018/848 governs in detail the production of organic products, it does not contain provisions concerning the products themselves. It is clear therefore that it is food law, and in particular Regulation 2015/2283, which is to apply to organic products where those products are also foodstuffs. ( 16 )
50. The SPC’s argument that the rules laid down by Regulation 2015/2283 for the placing of products on the market do not preclude the certification of organic products under Regulation 2018/848 is also unfounded. Indeed, it is Regulation 2018/848 which must apply without prejudice to food law, not the other way round. It is the interpretation of Regulation 2018/848 that must therefore be adjusted to the requirements of Regulation 2015/2283 inter alia.
51. Thirdly and lastly, it follows from Article 2(4) of Regulation 2018/848, not only that that regulation does not derogate from the provisions of food law but also that the application and hence the interpretation of that regulation must not undermine the objectives of that law.
52. Food law is aimed not only at ensuring the safety of food from the point of view of human health but also ‘at the protection of the interests of consumers and [must] provide a basis for consumers to make informed choices in relation to the foods they consume’. In that connection it must aim to prevent inter alia ‘any … practices which may mislead the consumer’. ( 17 ) As regards novel foods, Article 7 of Regulation 2015/2283 lays down as a condition for marketing authorisation that ‘the food’s intended use does not mislead the consumer’.
53. In that regard, for the reasons set out in the introduction to the present Opinion and in points 40 to 43 hereof, I consider that the organic certification of a substance that has not been authorised to be placed on the market, such as CBD, would undermine that objective. Notwithstanding the use of the description ‘organic’ which may have been applied to it by producers or sellers of such a substance or of products containing it, that description is liable to mislead consumers as regards the lawfulness of the marketing of such products and the safety of such products for their health.
54. Therefore, in my view, the interpretation of Article 2(1)(b) of Regulation 2018/848 in the context in which that provision operates militates against the possibility of certifying as organic a substance that has not been authorised to be placed on the market as a novel food.
Conclusion
55. In the light of all the foregoing considerations, I propose that the Court of Justice answer the questions referred for a preliminary ruling by the Conseil d’État (France) as follows:
Article 2(1)(b) of Regulation (EU) 2018/848 of the European Parliament and of the Council of 30 May 2018 on organic production and labelling of organic products and repealing Council Regulation (EC) No 834/2007, read in conjunction with Article 6(2) of Regulation (EU) 2015/2283 of the European Parliament and of the Council of 25 November 2015 on novel foods, amending Regulation (EU) No 1169/2011 of the European Parliament and of the Council and repealing Regulation (EC) No 258/97 of the European Parliament and of the Council and Commission Regulation (EC) No 1852/2001
must be interpreted as meaning that it precludes a substance classified as a ‘novel food’ within the meaning of Regulation 2015/2283 but not authorised to be placed on the market under that regulation, being certified organic under Regulation 2018/848 as a ‘processed agricultural product for use as food’, within the meaning of that regulation.
1 Original language: French.
2 Judgment of 19 November 2020, BS and C A (Marketing of cannabidiol (CBD)) (C‑663/18, EU:C:2020:938, paragraphs 63 to 76).
3 So far as I am aware, only one medicinal product containing pure CBD, intended for complementary treatment of some rare forms of epilepsy, has been approved in the European Union so far.
4 OJ 2002 L 31, p. 1.
5 OJ 2015 L 327, p. 1.
6 OJ 2018 L 150, p. 1.
7 Regulation of the European Parliament and of the Council of 15 March 2017 on official controls and other official activities performed to ensure the application of food and feed law, rules on animal health and welfare, plant health and plant protection products, amending Regulations (EC) No 999/2001, (EC) No 396/2005, (EC) No 1069/2009, (EC) No 1107/2009, (EU) No 1151/2012, (EU) No 652/2014, (EU) 2016/429 and (EU) 2016/2031 of the European Parliament and of the Council, Council Regulations (EC) No 1/2005 and (EC) No 1099/2009 and Council Directives 98/58/EC, 1999/74/EC, 2007/43/EC, 2008/119/EC and 2008/120/EC, and repealing Regulations (EC) No 854/2004 and (EC) No 882/2004 of the European Parliament and of the Council, Council Directives 89/608/EEC, 89/662/EEC, 90/425/EEC, 91/496/EEC, 96/23/EC, 96/93/EC and 97/78/EC and Council Decision 92/438/EEC (Official Controls Regulation) (OJ 2017 L 95, p. 1).
8 See Commission Implementing Regulation (EU) 2017/2470 of 20 December 2017 establishing the Union list of novel foods in accordance with Regulation (EU) 2015/2283 of the European Parliament and of the Council on novel foods (OJ 2017 L 351, p. 72), as last amended by Commission Implementing Regulation (EU) 2026/397 of 23 February 2026 (OJ L, 2026/397).
9 See, recently, judgment of 5 June 2025, Corner and Border (C‑685/23, EU:C:2025:398, paragraph 35).
10 See, inter alia, the English- (‘food’), German- (‘ Lebensmittel ’), Greek- (‘ τροφίμων ’) and Polish- (‘ żywność ’) language versions.
11 Such authorisation does not need to be express. The fact that products are for the most part authorised to be placed on the market stems from the simple fact that they are not prohibited from so being. That is not however the case for the novel foods at issue in the present case.
12 In the present case, as the French and Bulgarian Governments point out, in respect of CBD as a food, it is apparent from the Opinion of the European Food Security Authority (EFSA) of 22 April 2022 that the scientific data currently available do not show that there is no risk for human health. In the update of that opinion, of 9 February 2026, EFSA set a provisional safety limit for CBD in some types of products, whilst still having doubts about the rest.
13 It should be noted in that regard that according to Article 35(3) of Regulation 2018/848, the organic certificate is an official certificate within the meaning of Regulation 2017/625. However, consumers do not necessarily distinguish between the different certificates issued under food law and the characteristics of those products which those certificates confirm.
14 The reason for this is as follows: ‘This is the latest hoop that CBD products have to jump through: they cannot be sold as medicinal, and now they cannot be sold as nutritional either. This is the reason for the recent relabeling of CBD products as ‘for external use only’, despite the product remaining the same’ (cannabiscollege.com/knowledge-base/legal-information/is-cbd-a-food-supplement-a-medicine-or-an-aroma-product).
15 Legislation in the field of safety of the food chain is moreover expressly classified in Article 2(4) of Regulation 2018/848 as being ‘related’. It should also be noted that the organic certificate is an official certificate for the purposes of Regulation 2017/625, which relates, inter alia, to certification under food law. The link is therefore clear here.
16 Also, inter alia, Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers, amending Regulations (EC) No 1924/2006 and (EC) No 1925/2006 of the European Parliament and of the Council, and repealing Commission Directive 87/250/EEC, Council Directive 90/496/EEC, Commission Directive 1999/10/EC, Directive 2000/13/EC of the European Parliament and of the Council, Commission Directives 2002/67/EC and 2008/5/EC and Commission Regulation (EC) No 608/2004 (OJ 2011 L 304, p. 18), expressly mentioned in Article 2(5) of Regulation 2018/848 as one of the acts to which Regulation 2018/848 applies without prejudice.
17 Article 8(1) of Regulation No 178/2002.