Since not all hops are available in organic cultivation, and availability is generally lower than demand, a system of exemptions has been put in place to allow brewers to continue producing their beers, using their recipes and the organic label, even if the hops themselves are not organic. Yes, but…

What the law says

Article 25 sets the framework

Authorisation by Member States of non-organic agricultural ingredients in processed organic foodstuffs

1. If necessary to guarantee access to certain agricultural ingredients and where such ingredients are not available in sufficient quantities in organic form, a Member State may, at the request of an operator, provisionally authorise the use of non-organic agricultural ingredients for the production of organic food processed on its territory for a period of up to six months . This authorization applies to all operators in that Member State.

2. The Member State concerned shall immediately notify the Commission and the other Member States of any authorisation granted for its territory in accordance with paragraph 1, by means of a computer system, made available by the Commission, enabling the exchange of documents and information.

3. The Member State concerned may extend the authorisation provided for in paragraph 1 for a maximum of two periods of six months each , provided that no other Member State has raised an objection by indicating , by means of the system referred to in paragraph 2, that these ingredients are available in sufficient quantity in biological form.

4. A supervisory authority or body recognized in accordance with Article 46(1) may grant, for a maximum of six months, a provisional authorisation, within the meaning of paragraph 1 of this Article, to third-country operators who apply for such an authorisation and who are subject to the controls of that authority or body, provided that the conditions laid down in that paragraph are met in the third country concerned. The authorisation may be extended for a maximum of two periods of six months each.

5. If, after two extensions of a provisional authorisation, a Member State considers, on the basis of objective information, that the availability of these ingredients in biological form remains insufficient to meet the qualitative and quantitative needs of operators, it may submit a request to the Commission in accordance with Article 24, paragraph 7.

Article 24, paragraph 7.

Where a Member State considers that a product or substance should be added to, or removed from, the lists of authorised products and substances referred to in paragraphs 1 and 2, or that the specifications for use referred to in the production rules should be amended, it shall ensure that a file indicating the reasons for this addition, removal or other amendment is formally transmitted to the Commission and to the other Member States and made public, subject to compliance with Union and national data protection law.

Sources:

Regulation (EU) 2018/848 of the European Parliament and of the Council of 30 May 2018 on organic production and labelling of organic products and repealing Council Regulation (EC) No 834/2007 : https://eur-lex.europa.eu/legal-content/FR/TXT/?uri=CELEX%3A32018R0848#d1e4074-1-1

What the market says

Large retailers specializing in “organic products” are increasingly demanding that all the ingredients in the beers they distribute be certified organic.

More and more organic breweries are also opting for 100% organic sourcing despite occasional supply difficulties and a varietal choice that remains more limited to date.

And we understand why: as consumers, when we choose a product labeled organic, we appreciate that it actually is organic. Not just from a legal standpoint (a 5% tolerance, if an exemption is granted, for non-organic ingredients in labeled organic products), but truly in its composition.

The availability of certified organic hops on the market is gradually changing. Cultivated areas are increasing, and the number of available varieties is multiplying. Within three years, supply should catch up with demand for the most commonly used varieties. That’s encouraging!