Questions and answers

Organic production is a system of farm management and food production without synthetic pesticides and fertilisers, without GMOs and with high animal welfare standards. In the EU it is governed by Regulation (EU) 2018/848, applicable from 1 January 2022, and its delegated and implementing regulations. In Bulgaria, Ordinance No 5 of 3 September 2018 also applies.

You submit an application (online or on paper), we prepare an offer and conclude a contract for control and certification. Then, within 10 days, you notify the Ministry of Agriculture and Food (MAF). The conversion period also starts from that date.

The conversion period is the time between the start of control and the moment when the products can be sold as organic. During it you comply with all the rules of organic production, but the products do not yet bear an organic indication.

For annual crops - 2 years before sowing. For meadows and perennial forage crops - 2 years before their use as feed. For perennial crops - 3 years before the first organic harvest. For animals and bees there are separate periods, described in the respective sections.

Yes, through retroactive recognition of a previous period. You must prove with documents that over the last three years the land has not been treated with unauthorised products, and sample analyses are often required. Under Ordinance No 5, a maximum of 12 months may be recognised for annual crops and 18 months for perennial crops. The decision is taken by a departmental commission at the MAF and the timeframes vary.

Yes, but only for plant products with a single agricultural ingredient and only if the conversion period has lasted at least 12 months before the harvest. Such products may not bear the EU organic logo.

As a rule - organic seeds and planting material. If no organic ones are available, in-conversion seeds may be used, and if these are not available either - non-organic ones, but only with prior authorisation from the control body. Availability is checked in the official MAF database for organic seeds (bioseeds.mzh.government.bg).

You submit an application to us on the approved form before sowing. We reply within 3 days. The non-organic seeds must not have been treated with unauthorised products and must not be GMOs. Each year the MAF publishes a list of the species for which no authorisation is granted because sufficient organic material is available.

Regulation (EU) 2018/848 allows these authorisations until 31 December 2036. After that, only organic plant reproductive material may be used. It is therefore advisable to plan your varieties and suppliers now.

By 10 January each year you submit an annual production programme. You keep a farm diary and registers of purchases, sales, treatments, yields and stock. The documents must be presented during the inspection.

The inspector walks through the site, checks the registers against what they see and traces the quantities from input to sale. Where necessary, they take samples for analysis. They check the available machinery and premises. They prepare a report on the basis of which a certification decision is taken. In addition to the annual inspection there may be additional ones, including unannounced inspections.

A non-compliance does not automatically mean withdrawal of the certificate. Depending on its severity, you are given a deadline for corrective action, and the lot or product may be prohibited from being sold as organic. You have the right to appeal against any decision.

On a basic annual fee and on the scale of the control: decares, number of animals, number of hives or hours of control for processing and trade. All prices are published in our price list.

Not necessarily. The Regulation allows parallel production, but for annual crops, easily distinguishable varieties must be grown in the conventional part. Organic and conventional production are kept completely separate - in terms of land, storage, machinery and documentation.

Adjacent conventional land is regarded as a contamination risk. Appropriate measures are applied: buffer strips, hedgerows, separate harvesting of the edge rows. Samples are taken where there is suspicion.

Only those authorised in Regulation (EU) 2021/1165 and only when there is a real need. The basis is crop rotation, leguminous crops, green manure and livestock manure. Every application is recorded in the log.

Yes. It must include leguminous crops as the main crop or cover crop and green manure crops. Growing the same crop in the same place year after year is not permitted, with the exception of grass mixtures and perennial plantations.

Yes. However, cultivation must be in soil connected to the subsoil and bedrock. Hydroponics and growing in containers are prohibited, with some exceptions for seedlings, and for flowers and herbs in pots sold to the final consumer.

The main record is the farm log: what was applied or done, when, on which plot and in what quantity. The invoices for seeds, fertilisers and plant protection products are kept with it, as well as the sales documents.

For bovine animals for meat production - 12 months and at least three quarters of their lifetime. For sheep, goats and pigs - 6 months. For dairy animals - 6 months. For poultry for meat production - 10 weeks, and for laying hens - 6 weeks. Pastures and land used for feed have their own conversion period.

Yes, but the feed must be organic and purchases are documented. For herbivores, at least 70% of the feed must come from the holding itself or from the same region. For pigs and poultry this share is at least 30%.

Treatment is not prohibited - a sick animal is treated immediately. Preventive use of synthetic medicines, including antibiotics, is prohibited. The withdrawal period is doubled and is at least 48 hours.

When it receives more than three courses of treatment with synthetic medicines within 12 months. If its productive life cycle is less than one year - after more than one course. Vaccinations, treatment for parasites and compulsory programmes are not counted.

This is possible only if they are of different species and with strict separation of buildings, pastures, feed and records. The same species may not be reared both organically and conventionally on the same holding at the same time.

Animals must have permanent access to open-air areas, preferably pasture, whenever weather and ground conditions allow. Space requirements in housing and shelters are set according to the animal species.

12 months. During this time the wax must be replaced with wax from organic beekeeping.

The apiary is sited so that within a radius of 3 km the sources of nectar and pollen are mainly organic crops, wild vegetation or low-impact areas. There must be no serious sources of pollution within the radius - landfills, industrial sites, busy roads.

Migratory beekeeping is permitted. However, every new location must meet the forage requirements and you must notify us of the move in advance.

Treatment is not prohibited, but the means are limited. Products with formic, lactic, acetic and oxalic acid are permitted, as well as menthol, thymol, eucalyptol and camphor. However, the products must be registered as veterinary medicinal products in accordance with national legislation. The BFSA maintains a list of the medicinal products authorised for use on its website. Every treatment is recorded in the apiary log.

Only when the survival of the colonies is threatened by climatic conditions. Feeding is with organic honey, organic sugar or organic sugar syrup.

Hives must be made of natural materials that pose no risk of contaminating the honey. Wax foundations must come from organic beekeeping and be of proven origin. Clipping the wings of queen bees is prohibited.

Yes, with separation in time or in space. Before an organic batch the line is cleaned and this is documented. Raw materials and finished products are stored separately.

For a product to be called ‘organic’, at least 95% of its agricultural ingredients must be organic. The remaining up to 5% may only be ingredients expressly authorised by the regulation.

Only the additives and processing aids authorised for organic processing, listed in Regulation (EU) 2021/1165. Flavourings must be natural. That is why recipes are checked before the product is placed on the market.

The composition of every product is reviewed: ingredients, additives, processing aids. Any change to the recipe must be agreed with us in advance.

Yes, but the subcontractor must be under control - either with its own certificate or included in the control of your company. Responsibility for the organic status remains yours.

As a rule - yes. The Regulation allows exemption under certain conditions, for example when selling prepacked products directly to the final consumer (Art. 34(2) and Art. 35(8) of Regulation 2018/848). That is, if you are a retailer selling to the final consumer, you do not need one.

Before every purchase you check whether the supplier has a valid certificate covering the specific product. The documents accompanying the consignment must contain the organic indication and the code number of the control body.

Traceability: every lot must be traceable from the supplier to the customer. Organic products are stored separately and clearly labelled.

The obligations are the same: the origin and the documents for the lot. The online shop must be included in the scope of your certificate, and the products must be described correctly.

Do not sell it as organic. Set the lot aside until the supplier provides the document, and notify us if you suspect an infringement.

Every consignment must have a certificate of inspection (COI) issued in the TRACES system by the exporter's control body. It is also checked whether that body is recognised by the EU for the country and product category concerned. The importer and the first consignee must be under control in the EU.

The certificate of inspection is issued by the exporter's control body in the country of origin. We check the documents, the lot and traceability when the goods are received.

Yes, if the producer is certified under EU rules by a control body recognised by the European Commission. The recognition regime is changing, so check the current situation with us before every transaction.

Yes. For operators certified by us, we issue NOP import certificates (NOP Import Certificate) under the EU-US equivalence arrangement. The certificate is a separate service and is issued for each consignment.

The operator. The area must be described and mapped, and the operator must prove that it is under control.

With a document showing that for at least the last 3 years before collection the area has not been treated with unauthorised products. Collection must not endanger the natural habitat or the maintenance of the species.

The buying points are checked, together with the documents with which the collectors hand over the quantities. Collectors must be known, trained and registered. The quantities must be realistic for the area.

Yes, provided the right of use has been settled. The document for it is part of your file with us.

The EU organic logo is mandatory for prepacked organic food produced in the EU. For imported products and for non-prepacked products it is not mandatory. In-conversion products may not bear it.

The code number of the control body - for us BG-BIO-02 - and the place of farming of the agricultural raw materials are placed in the same visual field: ‘EU Agriculture’, ‘non-EU Agriculture’ or ‘EU/non-EU Agriculture’. If all raw materials come from one country, that country may be indicated instead of ‘EU’.

These words are protected and may only be used for products certified under the regulation. Using them for non-certified products is an infringement, even when they are part of a trade name.

Yes. Before placing a product on the market, send us the draft label. This way you avoid reprinting costs and penalties.

Under the Strategic Plan for the Development of Agriculture and Rural Areas 2023-2027 there are interventions for organic plant production and organic beekeeping (conversion and maintenance) under Ordinance No 9 of 2023. There is also an eco-scheme for organic livestock production. The conditions and rates are set by the MAF and the SFA.

You must have concluded a contract for control and certification with a control body by 31 December of the year preceding the application. Within the set deadlines you must also submit the organic certificate or the document on the status of the land.

We do not grant or pay out subsidies. We control and certify your production, and the information on the status of the land and animals is used by the SFA in its eligibility checks.

The measures imposed, for example returning land to the start of the conversion period, may also affect your payments. It is therefore important to remedy non-compliances on time and to notify us of changes on the holding.

Yes. You conclude a contract with the new control body and notify the MAF of the change within 10 days. You may not have a contract with more than one control body for the same category of products.

No, provided there is no interruption of control. The status of the land, animals and products is retained and continues with the new control body.

The previous control body provides the new one with the necessary information from your file, including outstanding measures and non-compliances found. We recommend that you also provide us with your latest certificate, the report from your latest inspection and your annual production programme.

It is most convenient at the end of the farming year, after the certificate for the current year has been issued. If you apply for subsidies, align the change with the SFA deadlines. Contact us - we will inform you about the procedure.

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