All four European countries described in this study belong to the European Union, which in 1991 began to regulate organic agriculture and the organic industry. In this regard, the EU assumed a pioneering role by enacting a mandatory legal framework, starting with the EU regulation 2092/91, a development that eventually culminated in passing regulations for organic animal husbandry 1999. The EU regulations at this point represent the most comprehensive regulatory framework for the organic industry and trade enacted by any government worldwide. (The regulations and the amendments can be accessed at the Web server of the EU at http://www.europa.eu.int/eur-lex). They are largely based on IFOAM regulations with few substantial differences between the two.
Under the regulations, organic food products may be imported and marketed within the EU labeled as certified organic in origin, if the products in question are grown and processed in compliance with procedures equivalent to the regulations of the European Union. The equivalency needs to be documented and certified by a designated competent authority of a EU member state.
Article 11 of the EU regulation 2092/91 specifies the rules for the importation of organic products into the EU. Article 11 differentiates between two categories of countries outside the EU:
At the time of this study, countries on the article 11 list are Argentina, Australia, Hungary, Israel, and Switzerland. These are countries whose national organic standard as well as their certification rules and procedures are accepted by the EU as equivalent. Furthermore, only certification bodies of the aforementioned countries that are listed in the article 11 list are accepted. Each consignment from an approved country needs to be accompanied by a certificate stating that the standards and certification rules are equivalent to those in the EU.
Imports from so-called third countries are not accepted as equivalent per se, but need individual import licenses issued by a member state. In this case, the importer needs to submit documentation proving that the products for which a permit has been requested have been grown and processed equivalent to EU regulations. These import permits are only valid for the specific importer and for import entry into this country. If the importer wants to use another country as point of entry, an import license from this country needs to be obtained. However, once a product is imported into the EU, it can be moved and marketed freely within the EU.
Import permits are issued for a specific amount and are valid only for a defined time period, which ends December 31st, 2002. This is also the date where this specific regulation expires, but it is widely believed that this regulation will be extended beyond this date.
Denmark’s claims to be the first country in the world to enact a law governing organic plant and livestock production, processing, and labeling in 1987. The organic certification system is entirely based on state supervision. Therefore, Denmark has no private certification bodies. On the farm level, inspections are carried out by the Plant Directorate of the Ministry of Food, Agriculture, and Fisheries. On the processing and manufacturing level, these inspections are carried out by the Inspectorate of Organic Production, which is an integral part of the regular food industry inspectorate. The same authority awards the red Ø label (Ø for økologisk = organic), which can only be carried by products that have been inspected in Denmark. This means that products carrying the red Ø label either have to be produced or packed in Denmark, which renders importing finished and packed goods almost impossible. The Danish organic standards in the plant and livestock area are practically identical with EU regulations with two exceptions: in Denmark, individual farms must convert completely to organic, and a maximum of 25% of the fertilizers applied may originate from a conventional livestock operation in the form of manure.
France was the first country in Europe to pass federal legislation on organic agriculture in 1981. A statewide logo for organic agriculture "AB" for "Agriculture Biologique", was introduced in 1988. The logo is recognized by the majority of organic consumers in France and has a reputation for guaranteeing the integrity of the products carrying it. According to Comber  80% of consumers believe that the AB logo stands for strict production control. The logo is owned by the French Ministry for Agriculture, Forestry and Fisheries and administered by the certification bodies. In order to obtain the logo, at least 95% of the ingredients have to originate from organic production. As the AB logo is also available for a licensing fee for importers, it is certainly a consideration for the importers of products for sale to consumers to have the logo on its goods. However, importers who wish to obtain the license must provide information about the premises where goods are stored, other import activities, points of entry, evidence of commitment to conduct business according to the rules of EU regulation 2092/91 and its subsequent amendments, banking information on credit transactions and information on the certifying body for each shipment.
Certification organizations have to be accredited with the Comité français d’accréditation (COFRA), the official accreditation body, which was established in accordance with ISO 65. To date, five certifiers have been accredited, AFAQ-Ascert International, Ecocert SARL, Qualité France, which is also active in Germany, Italy, and Belgium, QNPC and ULASE, with Ecocert by far the biggest and best known with a certifying share of approximately 80%. Any importer not belonging to the countries in the article 11 list of the EU 2092/91 organic regulations as amended needs to apply for an import certificate for each shipment, which is usually handled by the certification agency. Average handling time from application to issuing of the import license can differ vastly, from not less than four weeks to several months.
The federal government in Germany has delegated the task of accreditation, supervision and issuance of import licenses for organic products to the 16 states, each of which has one or more competent authorities delegated to those tasks. The Länderarbeitsgemeinschaft der Öko-Kontrollbehörden (federal states’ working group of organic control authorities) coordinates the activities of all authorities involved.
All certifying bodies in Germany are private entities accredited with the relevant federal state authority. Presently more than 40 of these exist organized in two groups, the Konferenz der Kontrollstellen (Conference of certifying bodies) and the Arbeitsgruppe der Kontrollstellen. (Working group of certifying bodies). The chairmanship of these groups rotates among their members.
Among the certifiers active on an international level are BCS Öko-Ganrantie, Ecocert International, Gesellschaft für Resourcenschutz, Institut für Marktökologie, (IMO), International Nutrition and Agriculture Certification (INAC), Lacon, and Naturland.
The certifier who deals directly with the competent state authority usually handles the application for the import license. In cases where all conditions are met (see also chapter 7) this process can be as short as two weeks. In more complicated cases it may take 6-8 weeks or longer, especially if it is the first application.
The sole certification agency in the Netherlands is SKAL. The Dutch Ministry of Agriculture set it up as a private company, but under direct governmental supervision. SKAL has offices in Germany, Hungary, Turkey, India, Peru, and Sri Lanka SKAL issues its own EKO label, which can be an interesting option for companies wishing to export products for sale to the Netherlands. As SKAL is the only certifying body in the Netherlands, the EKO label is well known and widely accepted among customers of organic goods, therefore, it adds credibility to the product [http://www.skal.com]. Usually applications take from four to eight weeks; SKAL charges a base amount of roughly $700 per application plus 0.5% of the gross import turnover as certification fee. 
In the United Kingdom, the United Kingdom registry of Organic Food Standards (UKROFS) is the controlling body for organic certification. UKROFS can act as a certification body itself, but prefers not to. It rather monitors the activities of the privately organized certification body. They encompass The Bio-dynamic Agricultural Association, Organic Farmers and Growers Ltd., Organic Food Federation, Scottish Organic Producers Association and the Soil Association. The latter is the undisputed leader in terms of number certifications with substantial international experience. As the amount of imports into the UK is substantial, it may easily take three months or more to obtain an import license from the UK.
Japan’s national organic standard took effect during the writing of this report, on June 10th, 2000. Until then, no specific regulations for organic imports were in place, but had essentially to undergo the same quarantine and other regular food import regulations. The mandatory new certification regulations, which will be enforced after a grace period lasting until April 1st, 2000 require that every certifier for organic imports into Japan be incorporated in Japan and that the qualification of the representative of the importing entity be examined by a Japanese MAFF inspector. Both requirements are unprecedented in the realm of organic certification and are presently meeting international opposition.
There are ten certification agencies, with the most important probably JONA, the Japan Organic and Natural Foods Organization. All certification bodies have been established recently.
The Taiwan Council of Agriculture (COA, the equivalent of the USDA) established guidelines for the production of organic rice, fruits, vegetables, and tea in 1996. In 1997, a trial organic certification program was launched in which certified products sold under the program have to carry the COA organic food sticker on their package. In 1999 COA published National Organic Standards, Guidelines Governing Accredited Certifiers and Organic Products and Organic Supervisory Committee Guidelines. Presently, COA provides technical support for farmers willing to convert to organic and also certifies them. The latter service will be transferred to private certifying bodies in July 2000. In 1999 there were three private certifying agencies; the Mokichi Okada Association, International Foundation of Natural Ecology, the China Organic Agribusiness Association, and the Taiwanese Organic Production Association. All have applied for COA accreditation, but by the end of 1999, none of them was approved.
COA standards itself contain two categories of production: organic and adjusted organic, which allow for the limited use of small amounts of chemical fertilizers and pesticides, but no herbicides, mainly on perennial fruits and tea. As of yet, the standards do not cover processing and animal husbandry.
As there are no specific requirements for the import of organic foods, general food import regulations apply also to organics. Meat and fishery products must meet the quarantine and food health requirements, while all foods that make biological or medical claims for humans have to apply to the Food Sanitation Bureau of the Department of Health for a special license.