Fertilisers authorised in organic farming are, in the EU, those whose material appears in Annex II of Implementing Regulation (EU) 2021/1165, which implements Regulation (EU) 2018/848, and which are used under the conditions that annex lays down. The practical proof for a specific product is a document from a body attesting its suitability, with a number, a programme and a validity period: it attests that the product is suitable; it does not certify it as organic.
What the legislation says: Regulation (EU) 2018/848 and Annex II of 2021/1165
Regulation (EU) 2018/848 is the basic legislation on organic production in the European Union. Its Article 24 allows the Commission to authorise products and substances for organic production and to publish them in lists. Those lists are in Implementing Regulation (EU) 2021/1165: its Annex II is the one for fertilisers, soil conditioners and nutrients. The other annexes deal with other categories of products and fall outside this guide.
Annex II is not a list of brands: it is a list of materials, each with its condition of use. That is why a commercial product is not “in” the annex; what is checked is that its materials are, and that it meets their conditions, and someone has to do that product by product. That is where the input attestations this guide deals with come from.
In addition, the operator keeps on their holding the documentation justifying that the fertiliser was necessary. Regulation 2021/1165 has been amended several times since it was published: it is advisable to consult its consolidated text on EUR-Lex rather than the original text.
Attestation, certification and authorisation are not the same thing
Three words the market mixes up and the legislation keeps apart:
| Term | What it is | What it applies to |
|---|---|---|
| Authorisation | The regulatory decision: a material enters Annex II with its conditions of use. It is taken by the European Commission and published in the regulation. | Materials and substances, not brands or commercial products. |
| Input attestation | The review of a commercial product against Annex II by a body, which issues a document with a number, programme, category, validity period and the list of products that appear in it. | Specific inputs: fertilisers, soil amendments, nutrients. |
| Certification | The official control that confirms that an operator produces in accordance with the regulation, with an inspection and a document in the operator’s name. | Operators, holdings and the agri-food products they obtain. |
Authorisation applies to everyone who uses that material; an attestation applies to one specific product and one specific document, which is why it carries a number and a validity period; certification belongs to whoever produces. Confusing them leads to accepting a product because its material appears in Annex II, or because whoever sells it is itself certified as an organic operator. Our own document spells it out in its closing note, in capitals:
The products mentioned in this attestation ARE NOT CERTIFIED ACCORDING TO ORGANIC FARMING, but attested as SUITABLE FOR USE IN ORGANIC FARMING according to the programme mentioned above.
That is why the correct wording on a label or a data sheet is “suitable for use in organic farming”, with a reference to the document that backs it, and why a very widespread expression deserves correcting: a fertiliser is not certified as organic; it is attested as suitable. Certification belongs to the operator and to what the operator produces.
The five steps to check an input
To find out whether a specific product is among the fertilisers authorised in organic farming you do not need to interpret the regulation: you need a document and five checks. We run them here on our EU attestation, which is a real case, and they can be repeated with any other.
1 · Ask for the document, not the seal
A logo on the label is not a document. What you ask for is the attestation, and six details are read from it: the number (on ours, No. 245895/29/290920251037), the programme (“EU - Inputs Attestation”), the body that issues it (ECOCERT S.A.S), the category (“FERTILIZER AND AMENDMENT”), the date of issue and the validity period (ours runs from 29 September 2025 to 31 March 2027). If any of the six is missing, it is not the document.
2 · Look for the exact product name in the annex
The attestation carries an annex with the products it covers, and it covers only those. Ours lists 24 entries, written as the document writes them and not as the label writes them: “FENORGANIC FOSFORO 0-20-0 LIQUIDO SOLUBLE” or “FENORGANIC HUMIC FULVIC + ALGAS”, without accents and with their own spacing. The name on the container has to correspond beyond doubt to an entry; a product with a similar name is not covered by proximity. And you also have to read what is not there: from our catalogue, ENDOPLASMA NZn and Fenorganic COMPLEX do not appear in the current attestation, and we say so ourselves on their data sheets. Each of the 24 states it in its suitability block; the data sheet for BORO, for example.
3 · Validate the copy
A PDF that arrives by email may be an old version. The current version is served by the body that issues it: in the case of Ecocert, its public directory, from which the document in force is downloaded, and its electronic input validation service, which the paper itself points to. We publish each document with its number, its size and its sha256 hash, so that anyone can check that the copy they hold is the same one: how to validate the copy.
4 · Cross-check with your control body
The suitability of an input and the certification of your holding are two separate controls. Your control body may require each input to be registered or approved in your production plan before you use it, and the decision is theirs. The document we publish accompanies that application and does not replace your body’s approval; keep it with your holding’s documentation.
5 · Look at the label and the data sheet
The last check is on the product itself. The wording that should appear is “suitable for use in organic farming”, with the reference to the document (number, programme and validity period). A leaf, an “eco” or a “bio” in the trade name mean nothing on their own. On our data sheets that information goes in the “Organic suitability” block, the sixth of six; how to read the rest of the data sheet is explained in how to read a technical data sheet.
What about other programmes: USDA NOP and the UNE standards
Annex II is the reference in the European Union, but it is not the only programme. The USDA NOP programme serves those who export to the United States and is a separate document. We hold a second attestation, No. 245895/29/290920251035, under the “USDA NOP - Inputs Attestation” programme, with 8 products in its annex: CALCIO 880, FULVIC 40, MICROELEMENTOS, NITROGENO 16, NUTRIPLUS 10, PK 20-20 LIQUIDO SOLUBLE, POTASIO K20 and UNIVERSAL. The same product may be in both annexes, like UNIVERSAL (EU and NOP), or in only one, like HIERRO (EU annex only).
In Spain there is also a voluntary scheme: the UNE standards for inputs suitable for organic production, with UNE 142500 for fertilisers, soil amendments and growing media, applied by certification bodies such as CAAE or Sohiscert, and explained by the Ministry of Agriculture on its page on the UNE input standards. The attestations we publish are those of the EU programme and the NOP. An input may be in one scheme and not in another, and none of them replaces Annex II: it is the legislation, not the programme, that says which materials may be used.
What to do if the seller says the product “is certified”
Ask for the document before buying. Check the programme (EU, NOP or another), the validity period and the exact product name in the annex. If all there is is a logo or a word on the label, do not use it until you have seen the document: applying an unauthorised input compromises the certification of the plot.
How we do it
24 of our 26 products are suitable for use in organic farming according to the ECOCERT S.A.S input attestation under the European programme, and 8 of them also under the US USDA NOP programme. Both attestations are valid until 31 March 2027, and we publish them in full, with their annexes, in the two complete attestations. Each product data sheet repeats the detail that applies to it, links to the document and, for the two products that do not appear, says so. The data sheets of the 8 NOP products add a second line with the number of that attestation and the name of its programme. The 9 products in our olive grove programme all appear in the EU annex. They are attestations of products suitable for use in organic farming: they do not accredit FenOrganic as an operator.
Frequently asked questions
Which fertilisers are authorised in organic farming?
Those whose material appears in Annex II of Implementing Regulation (EU) 2021/1165 and which are used under the conditions that annex lays down for each one. The annex lists materials, not brands; a specific commercial product is checked with a body’s input attestation, by looking for its exact name in the document’s annex.
Can a fertiliser be certified as organic?
Not in the sense in which a holding is certified. Certification belongs to the operator and to what the operator produces; the input is attested as suitable for use in organic farming. The closing note of our document says so in those very words.
Where do I check whether an input is suitable?
In the annex of its current attestation, which whoever sells it must provide, and in the directory of the body that issues it, where the version in force is kept. If your control body keeps its own register of inputs, check that too: the final word on your holding is theirs.
What is the difference between the EU attestation and the NOP one?
The programme. The EU one refers to Regulations (EU) 2018/848 and 2021/1165; the NOP one, to the US programme, and it serves those who export to that market. They are two documents with two numbers and two annexes; in ours, the 8 NOP products are also among the 24 of the EU one.
Does the attestation expire?
Yes. It carries a date of issue and an expiry date, and after that date it is no longer valid even if the PDF keeps circulating. Ours are valid until 31 March 2027.
Both attestations, with their full annexes, their size and their hash, are in certifications. If your control body asks for anything more about one of our products, the technical enquiry is there for that: we answer with the document in front of us.