Selling EU Organic Alcohol-Free Drinks in the US

Yes. A drink certified organic under EU rules can be sold as organic in the United States without a second certification, under a US–EU equivalence arrangement in force since 1 June 2012. Since March 2024 every shipment also needs an electronic NOP Import Certificate, issued in Europe before departure, and a USDA-certified importer to receive it; wine-based products must also meet the US rules on added sulfites.

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Key Takeaways

• EU organic certification is recognized in the US for products made or finally processed in an EU member state.
• Every commercial shipment needs an NOP Import Certificate, issued by your EU control body before the goods leave.
• Your US importer needs its own USDA organic certification. Importing is a certified activity.
• The label follows US rules. A "Certified organic by" line is required; the USDA seal and the EU leaf are optional.
• Added sulfites decide the wine question. Without them a de-alcoholized wine can be sold as organic; with them the route is unsettled.

Does the US accept EU organic certification?

Yes, within its terms. The US–EU organic equivalence arrangement was signed on 15 February 2012 and took effect on 1 June 2012, according to USDA's question-and-answer sheet. USDA's EU page, last updated April 2025, confirms that products certified to either standard may be labeled and sold as organic in both markets if they meet the terms. The arrangement is not a regulation: USDA publishes its terms on its own pages, and they do not appear in the Code of Federal Regulations.

The terms that matter for a drinks brand:

One date to watch sits on the European side. Annex I to Commission Implementing Regulation (EU) 2021/2325 lists the US as a recognized third country, and Article 48(1) of Regulation (EU) 2018/848 sets that recognition to expire on 31 December 2026. On 16 December 2025 the Commission proposed extending it to 31 December 2036 (COM(2025) 780). On 16 September 2026 Parliament's plenary confirmed the agriculture committee's decision to open negotiations with the Council. As of 23 September 2026 the Legislative Observatory lists the procedure, 2025/0417(COD), as awaiting Parliament's first-reading position, and the amendment has not been adopted. USDA's EU page gives no end date for the US side. Treat the position after 2026 as unsettled.

How does the NOP Import Certificate work?

Every shipment needs one. The Strengthening Organic Enforcement rule, published on 19 January 2023 (88 FR 3548), took effect on 20 March 2023 and had to be implemented by 19 March 2024. Under 7 CFR 205.273, each organic shipment must be certified, labeled to US rules, declared as organic to US Customs and Border Protection, and associated with valid NOP Import Certificate data. USDA's Strengthening Organic Enforcement FAQ, last updated June 2026, fills in the practical detail.

Your exporting operation has to be listed in the EU module of the database before your control body can issue anything (SOE FAQ, Q19). USDA explains that the trade-partner modules exist so certifiers can issue import certificates, which is why they list mainly operations that export to the US.

Invoices, packing lists, bills of lading and entry data must all identify the goods as organic (§ 205.273(c)). Since 1 October 2025, a shipment that arrives without a valid certificate cannot be put right in the US; the importer must re-export or destroy it, or donate it if the importer is certified (USDA SOE FAQ, Q23).

The same FAQ exempts online retail sales to individual consumers for personal use from the certificate "at this time"; the product must still be certified, and sales to businesses are not covered (Q22). The certificate carries the full 10-digit HTS code (Q16), which should match your entry; our guide to HS codes and CBP entry for non-alcoholic beverages covers classification.

Who in the US chain has to be certified?

Your importer, and anyone who opens, repacks or relabels the product. 7 CFR 205.100(a) requires every operation that handles products sold as organic to be certified unless § 205.101 exempts it, and the definition of "handle" in 7 CFR 205.2 includes importing, labeling and repackaging. USDA's SOE FAQ states that importing is not an exempt activity (Q13) and that the importer must be certified to the USDA organic regulations by a USDA-accredited certifier, even if it sits outside the US (Q14). Your EU certificate does not cover it, and the import certificate must name that certified importer of record (Q17).

The exemptions sit in 7 CFR 205.101:

Exempt warehouses and distributors must keep records for at least three years (§ 205.101(i)), and product handled by an uncertified business outside these limits loses its organic status (SOE FAQ, Q27). That matters if your 3PL builds variety packs or applies US stickers; see our 3PL guide. Ask any importer for its NOP operation ID and check it in the database; our guide to the US importer of record covers the rest of that role.

What can go on the label?

US labeling rules apply, whatever the label says in Europe. 7 CFR 205.300(c) requires products made abroad for US sale to be labeled under USDA rules, and USDA's labeling guide for the US organic market confirms this covers trade-partner products.

The thresholds are set in § 205.301(a)–(d); the seal limits are in § 205.311(a) and § 205.304(c). Water and salt drop out of the calculation under § 205.301 and § 205.302(a), so a sparkling botanical that is mostly water is measured on its other ingredients.

The "Certified organic by" statement. Required on the information panel, directly below the name of the handler or distributor, naming the body that certified the handler of the finished product (§ 205.303(b)(2); § 205.304(b)(2) for the made-with category). For an EU product that is your EU control body. USDA's labeling guide, last updated June 2026, says a control body code on its own, such as AA-BIO-001, does not comply. Print the name; the code may be added.

The USDA seal. Optional, and only for the 100% organic and organic categories (§ 205.303(a)(4); § 205.311(a)). A certifier's logo may appear, but not more prominently than the USDA seal (§ 205.303(a)(5)).

The EU leaf. USDA's EU page allows retail labels or stickers to carry the USDA seal, the EU organic logo, or both, and EU law says an exported organic product "may bear" the EU logo (Article 44(1), Regulation (EU) 2018/848). If you keep the leaf, EU law requires an "EU Agriculture", "non-EU Agriculture" or "EU/non-EU Agriculture" line in the same visual field (Article 32(2), Regulation (EU) 2018/848).

For the organic and made-with categories, mark each organic ingredient in the ingredient list (§ 205.303(b)(1); § 205.304(b)(1)). All of this sits alongside FDA's own requirements, set out in our FDA labeling checklist for imported beverages.

How do the wine rules apply to a de-alcoholized wine?

The answer is clear if you add no sulfites and unsettled if you do.

For EU organic wine entering the US, USDA's EU page sets two categories:

The legal roots are § 205.301(f)(5), which bars added sulfites in organic products with one exception for wine labeled "made with organic grapes", and § 205.605(b)(35), which allows sulfur dioxide "for use only in wine" in that category, with total sulfites capped at 100 ppm. USDA's labeling guide adds that EU organic wine with added sulfites can only be sold in the US as "made with organic grapes". Your EU control body must check this before it issues the import certificate (USDA EU page).

EU organic rules now allow de-alcoholization. Since an amendment published on 26 February 2025 (Delegated Regulation (EU) 2025/405), Annex II, Part VI, point 3.3(c)–(d) of Regulation (EU) 2018/848 permits partial vacuum evaporation and distillation for organic wine, only to make de-alcoholized wine at 0.5% vol or less and at temperatures no higher than 75 °C.

In the US, a de-alcoholized wine under 7% ABV falls outside the Federal Alcohol Administration Act, whose definition of wine starts at 7% alcohol by volume (27 U.S.C. 211(a)(6)), and FDA guidance says it is labeled under the Federal Food, Drug, and Cosmetic Act (FDA CPG Sec. 510.400); the agency split is explained in FDA or TTB. The organic claim is still governed by the National Organic Program.

• No added sulfites. The product meets the "organic wine" condition and can be sold as organic with the USDA seal, provided every other ingredient is allowed under § 205.605.
• Added sulfites. The only NOP route for added sulfur dioxide is wine labeled "made with organic grapes". We found no published NOP guidance on whether a dealcoholized wine counts as wine for that exception. NOP has kept to the annotation's exact wording before: in Policy Memo 10-2 (issued 2010, links updated March 2024) it held that, because the annotation names grapes, sulfur dioxide is prohibited in wines made from fruit other than grapes. Get your control body's decision in writing before you print. If the answer is no, the options are a formulation without added sulfites or no organic claim in the US.

FDA's sulfite rules apply whatever the organic claim: sulfiting agents at 10 ppm or more in the finished drink cannot be treated as incidental and left off the label (21 CFR 101.100(a)(4)). USDA's EU page states the sulfite condition for wine only. We found no USDA guidance on how the § 205.301(f)(5) ban applies to other EU organic drinks with added sulfites, so raise any added sulfite with your control body before you print.

What about UK and Swiss brands?

Separate arrangements apply the same mechanics. The US–UK arrangement took effect on 1 January 2021 and covers Great Britain and Northern Ireland; the US–Switzerland arrangement has applied since 10 July 2015. In both, the product must be made or finally processed in that country, local certifiers issue the import certificate in the same database, and wine must follow the destination country's rules, which for US sales means the USDA wine categories above. USDA notes that there is no UK organic logo and no Swiss organic seal. A UK company bottling in France ships under the EU arrangement, because the EU arrangement covers products produced or finally processed in an EU member state.

A sequence for your first organic shipment

1. Choose the US label category and check your formula against it, counting organic content without water and salt. For a wine-based product, settle the sulfite question with your control body first.
2. Confirm your control body can issue NOP Import Certificates and that your exporting operation is listed in the EU module of the Organic Integrity Database.
3. Appoint a USDA-certified importer, and check its certification in the database before you sign.
4. Map every US handler. Anyone who relabels, stickers or repacks needs certification; a warehouse that only stores and ships sealed packages does not.
5. Build the US label with the "Certified organic by" line and organic ingredients marked, then decide on the USDA seal and the EU leaf. Have your control body review it.
6. Request the import certificate before the goods leave, one per HTS code, and send the 21-character number to your importer's customs broker. Mark every shipping document as organic.
7. Receive and verify. On arrival the importer checks the certificate data, confirms the goods had no contact with prohibited substances since export (§ 205.273(d)), and keeps the records.

Organic status adds its own paperwork to every EU shipment, and keeping it in step with the rest of the import file is part of what Avenor runs.

Sources

Laws and regulations:

1. 7 CFR 205.2, Terms defined ("handle", "organic importer"); 7 CFR 205.100(a), What has to be certified; 7 CFR 205.101(b), (e)–(i), Exemptions from certification; 7 CFR 205.273(a)–(d), Imports to the United States; 7 CFR 205.300(c), Use of the term "organic"; 7 CFR 205.301(a)–(d), (f)(5), Product composition; 7 CFR 205.302(a), Calculating the percentage of organically produced ingredients; 7 CFR 205.303(a)(4)–(5), (b)(1)–(2), Packaged products labeled "100 percent organic" or "organic"; 7 CFR 205.304(b)(1)–(2), (c), Packaged products labeled "made with organic"; 7 CFR 205.311(a), USDA seal; 7 CFR 205.605(b)(35), Sulfur dioxide on the National List of allowed synthetics
2. 21 CFR 101.100(a)(4), Sulfiting agents as incidental additives
3. 27 U.S.C. 211(a)(6), Federal Alcohol Administration Act definition of "wine"
4. 88 FR 3548 (19 January 2023), National Organic Program: Strengthening Organic Enforcement, final rule
5. Regulation (EU) 2018/848, Articles 32(2), 44(1) and 48(1) and Annex II, Part VI, point 3.3(c)–(d), Organic production and labelling of organic products, consolidated text of 25 March 2025
6. Commission Delegated Regulation (EU) 2025/405, Amendment of Regulation (EU) 2018/848 on oenological practices, OJ L of 26 February 2025
7. Commission Implementing Regulation (EU) 2021/2325, Annex I, List of recognised third countries, consolidated text of 27 July 2026

Agency guidance and notices:

8. USDA AMS, International Trade Policies: European Union, the US–EU organic equivalence arrangement (an arrangement, not a regulation), last updated April 2025; USDA AMS National Organic Program, U.S.–European Union Organic Equivalency Arrangement: Questions and Answers, July 2015; USDA AMS, Strengthening Organic Enforcement Frequently Asked Questions, Q13–Q17, Q19, Q22, Q23, Q25 and Q27, last updated June 2026; USDA AMS, About INTEGRITY, Organic Integrity Database, last updated 20 March 2024; USDA AMS, Labeling Requirements for the U.S. Organic Market, last updated June 2026; USDA AMS National Organic Program, Policy Memo 10-2, Sulfur Dioxide in wine made with organic fruit, 20 September 2010, links updated 20 March 2024; USDA AMS, International Trade Policies: United Kingdom, the US–UK organic equivalence arrangement (an arrangement, not a regulation), last updated July 2026; USDA AMS, Organic Insider bulletin, U.S.-UK Organic Equivalency Keeps Trade Opportunities Open, 30 December 2020; USDA AMS, International Trade Policies: Switzerland, the US–Switzerland organic equivalence arrangement (an arrangement, not a regulation), last updated April 2025; USDA AMS National Organic Program, U.S.–Switzerland Organic Equivalence Arrangement: Questions and Answers
9. CBP, CSMS #59863856, USDA Agricultural Marketing Service Organic Filing Requirements – Mandatory March 19, 2024
10. FDA, CPG Sec. 510.400, Dealcoholized Wine and Malt Beverages – Labeling

Other sources:

11. European Commission, COM(2025) 780 final, Proposal amending Regulation (EU) 2018/848 as regards certain production, labelling and certification rules and certain rules on trade with third countries, 16 December 2025
12. European Parliament, Legislative Observatory, Procedure file 2025/0417(COD), status checked 23 September 2026

All sources accessed September 2026.

Summarized from USDA AMS National Organic Program guidance, 7 CFR part 205, the Federal Register, CBP, FDA and EUR-Lex as of September 2026. This is not legal advice; confirm your label category and import certificate with your certifier before shipping.