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Organic import maturity · Regulation (EU) 2021/2306

Your organic import processes, measured against Regulation (EU) 2021/2306 and turned into an action plan.

10 themes, a 5-level scale. And the action that moves each level to the next.

The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.

Organic import maturity · Regulation (EU) 2021/2306

Governance of the organic import systemN1 → N5
Supplier and third country qualificationN1 → N5
Inspection certificate and TRACES managementN1 → N5
Consignment checks on arrivalN1 → N5

10 themes, 5-level scale.

Nordhavn Industries

53 / 100

Governance of the organic import system6484
Supplier and third country qualification5379
Inspection certificate and TRACES management6182
Consignment checks on arrival3773
IAIndustrialised: your interview notes are enough, the AI fills in the audit.

They measure their maturity with Datamensio

  • Agri Sud-Ouest Innovation
  • ODA
  • Chambre de commerce et d'industrie
  • Eurobiomed
  • Enterprise Europe Network
  • HGK, Chambre de commerce croate

An example

This could be your situation.

Take one company as an example: three sites, three spreadsheets, no shared answer.

01

Nobody can consolidate.

Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.

02

Three weeks, a single base.

One Commission Implementing Regulation (EU) 2021/2306 assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.

03

Two costs avoided before being committed.

A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.

What it saved them

  • 3sites measured on the same base, instead of three questionnaires to reconcile
  • 2duplicate actions caught before the spend
  • 1committee report, with no manual rework

These figures are an example. They could be yours.

The standard imposes processes. Datamensio says where you stand.

01

The framework is already written

Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.

02

The score lands the same day

Online, by self-assessment link or in interview. Theme by theme, comparable over time.

03

The gap becomes a costed plan

Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.

04

Progress can be demonstrated

Campaign after campaign, against your target and against your own past. That is what your board asks for.

The maturity scale

One level, the next, and the action that links the two.

This mechanism, a level, the level above, and the action that links the two, is what turns a finding into a trajectory.

How do you verify consistency between the inspection certificate and the physical consignment received?

  1. N1

    No formalised verification. The COI is filed on receipt without checking it against quantities, consignments or the means of transport.

  2. N2

    A check exists, carried out by one or two people who know the subject. It is not described in a procedure and varies with workload.

  3. N3

    A written procedure defines the points to check and the expected record. It is applied to all imported consignments, with occasional gaps during activity peaks.

  4. N4

    Verification is systematic and recorded, gaps are logged and reported to the supplier and its control body, trained backups ensure continuity.

  5. N5

    Verification results feed indicators by supplier and country of origin, reviewed periodically, and trigger adjustments to the control plan and contractual requirements.

Action to move from L2 to L3

Formalise a COI checklist (operator identity, product code, quantities, container and lot numbers, TRACES status) in the goods-in procedure, add it to the consignment file and verify its application during the quarterly internal goods-in audit.

« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Chambre de commerce et d'industrie

Director, CCI 94CCI Île-de-France

« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Interreg Danube Region

Maja SucekChief Operating Officer, Interreg Danube

Take your first measurement

What this framework covers

Implementing Regulation (EU) 2021/2306 supplements Regulation (EU) 2018/848 on organic production. It sets out the official control arrangements for imported consignments and the certification regime: the inspection certificate (COI) drawn up by the third country’s control authority or body, electronic submission in TRACES with a qualified signature, verification of the consignment at the border control post or point of release for free circulation, then endorsement of the COI and issuance of extracts for split consignments. It also covers the handling of suspect consignments and sampling.

In practice, the difficulty is not knowing the text, it is keeping the documentary chain intact end to end, with suppliers based outside the Union and control bodies that do not all work at the same pace. Who checks that the COI actually matches the physical consignment, the quantities and the declared means of transport? What happens when an extract is needed on a Friday evening for a consignment split between two warehouses? How do you know whether non-conformities flagged against a supplier were actually addressed, or simply filed away?

The context has moved on since the scheme came into force on 1 January 2022. Third country equivalence recognition is gradually giving way to the compliance regime set out in Regulation (EU) 2018/848, with lists of control bodies that keep changing. A common confusion is to treat the COI as a customs formality, when it is in fact an official control instrument under Regulation (EU) 2017/625: what is being assessed is the interplay between the operator, the certification body, the competent authority and TRACES, not merely the presence of a document.

A compliance audit ends with a binary finding: the consignment is certified or it is not, the file is complete or it shows a gap. The maturity assessment asks a different question: what level of control does your import system actually operate at, and what precise action moves it to the next level. It distinguishes an organisation that handles every consignment as an emergency from one with written procedures, trained backups and indicators tracked over time.

Within Datamensio, the framework is ready to use and remains yours. You adjust the themes, questions and levels to your supply chains and countries of origin. The AI refines the wording using the CMMI method, or builds a variant from your import procedures and supplier specifications.

Reference standard: Commission Implementing Regulation (EU) 2021/2306

The themes assessed

  • Governance of the organic import system

    Written policy and procedures, roles and responsibilities, appointment of TRACES users and their backups, alignment with the quality system, allocated resources.

  • Supplier and third country qualification

    Verification of the control body’s status and scope of approval, applicable regime (compliance or equivalence), monitoring changes to lists, contracting and specifications.

  • Inspection certificate and TRACES management

    Obtaining the COI before shipment, checking entries, qualified electronic signature, status monitoring, handling rejections and correction requests, access rights and traceability.

  • Consignment checks on arrival

    Documentary, identity and physical checks, consistency between the COI, transport documents and the actual consignment, coordination with the border control post, COI endorsement and release for free circulation.

  • Splitting and certificate extracts

    Conditions for splitting consignments, issuance and endorsement of extracts, informing recipients, maintaining the link between the original consignment and sub-lots, processing times.

  • Sampling, testing and suspect consignments

    Sampling plan, choice of laboratories and methods, handling of suspect consignments, precautionary measures, non-release decisions, informing the control body and competent authority.

  • Traceability and record keeping

    Audit trail from imported consignment to market placement, archiving of COIs and extracts, consistency with materials accounting and mass balance, retention periods.

  • Non-conformities and suspected fraud

    Detection and recording of gaps, downgrading of consignments, notifications to relevant parties, corrective actions and verification of their effectiveness, feedback to suppliers.

  • Team competence and training

    Initial and ongoing training on the regulation, practical command of TRACES, organic rules knowledge among goods-in and customs teams, managing absences and departures.

  • Steering, indicators and continuous improvement

    Indicators on consignments checked, COI corrections and processing times, management review, comparison across sites and over time, incorporating feedback from official controls.

A short version of the framework is available for the online self-assessment.

Frequently asked questions

Does this assessment issue an organic certification?

No. Organic certification is issued by your approved control body, and endorsement of the inspection certificate falls to the competent authority. The assessment measures the maturity of your import system and prepares you for official controls.

How does this differ from a compliance audit run by my control body?

The audit checks requirements and concludes with compliance or a gap over a given scope. The assessment places your practices on a progressive scale and points to the action that moves you up a level. The two work together: the assessment prepares, the audit validates.

How long does the assessment take?

The short version can be completed in a single session by a quality or import manager. The full version, run collaboratively with procurement, goods-in and customs teams, typically takes one to two weeks, most of the time going into gathering evidence.

Can the framework be adapted to our supply chains?

Yes. You can edit the questions, levels and themes, or add ones suited to your products and countries of origin. The AI suggests rewording and refines the levels, or builds a variant from your import procedures.

How does this framework relate to Regulation (EU) 2018/848 and Regulation (EU) 2017/625?

Regulation 2018/848 sets the rules for organic production and labelling, Regulation 2017/625 the general framework for official controls. Regulation 2021/2306 sets out how they apply to imported consignments. A cross-framework roadmap lets you combine several assessments without duplicating actions.

Can several sites or subsidiaries be compared?

Yes. The same framework is rolled out to several business units, with a score by theme and a benchmark across entities and against previous rounds. Reporting is shared in a collaborative space in your own branding.

Is the action plan costed?

The gap between the score and the target generates the action plan, which the AI groups into a prioritised roadmap. The service catalogue matches a solution to each item, with its cost, timeline and expected impact on the score.

Where is the data hosted?

In France, with OVH, backed up with Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.

Take your first measurement