Of the 104 cinnamon products tested by the European Commission's Joint Research Centre in 2025, only around 40% were considered entirely free from suspicion of fraud or quality issues. Ten samples exceeded the European limit for lead contamination. Twenty-four were classified as "suspicious" because of irregular composition or unexplained origin profiles (JRC, 2025). These were not obscure marketplace products or grey-market imports. They were products circulating within mainstream European retail and food supply chains.
That study did not stand alone. During the same period, Brussels intensified controls on multiple import flows. Ginger from China and Peru was placed under additional EU scrutiny, including expanded consignment sampling and increased audit frequency for exporters and certification bodies (DG AGRI, 2024). In the Netherlands, Skal reported that parts of certifications were temporarily suspended at three companies in 2025, compared with one company in 2024 (Skal, 2024; Skal, 2025). Meanwhile, the European fraud and alert systems recorded notifications involving GMO contamination in soy, incorrect origin claims in honey, undeclared oils in pesto and residue findings in ginger from Peru (EU Agri-Food Fraud Network, 2024–2025; RASFF, 2024).
Individually, these incidents do not necessarily prove systemic failure. Together, however, they point toward something else: the audit pressure inside international organic supply chains is shifting. More controls. More re-inspections. More files being reopened. Less automatic trust in certificates.
A System That Verifies Process, Not Product
Part of this change is linked to how the European control system itself is designed. Since Regulation (EU) 2018/848 became fully applicable on 1 January 2022, stricter requirements have applied to traceability, group certification and import controls (EU 2018/848). Operators are expected to undergo annual inspections. European control bodies are supervised both by national authorities and the European Commission. Yet this is exactly where the tension begins.
At its core, the system primarily verifies processes, documentation flows and audit quality — not the product itself. The European Commission explicitly acknowledges that there is no scientific test capable of independently proving whether a product is genuinely organic (European Commission, OPSON documentation). The system therefore relies heavily on mass-balance analysis, batch documentation, internal control systems and the quality of audits carried out at producer-group level.
EU organic certification verifies production processes and documentation — not the physical product itself.
Where International Chains Become Opaque
In short supply chains, that remains relatively manageable. In international spice and ingredient chains, the situation becomes far more complex. Especially when multiple traders, exporters, consolidation hubs and translation layers are involved. DG AGRI audits conducted in countries including Sri Lanka and Turkey made this visible in 2025. European auditors concluded that controls were not sufficiently effective to detect irregularities early enough. Traceability systems and mass-balance analyses proved inadequate. Investigations into previous warning signs were described by the Commission as not being "inquisitive enough" to identify the true root causes (DG AGRI, 2025).
The additional measures imposed on ginger imports illustrate how Brussels increasingly evaluates risk. Imports from China and Peru are now subject to expanded consignment sampling and additional audits involving both operators and certification bodies (DG AGRI, 2024). This shifts the focus away from simple product testing toward overall supply-chain credibility. Residues are no longer the only concern. Authorities increasingly examine whether production volumes, yields and commercial flows logically align with one another.
Field-level sourcing in Peru — EU auditors now examine whether production volumes, yields and commercial flows logically align with one another.
The Regulatory Tide
At the same time, broader European legislation is reinforcing this trend. The Corporate Sustainability Reporting Directive (CSRD) requires large companies to improve documentation of upstream supply-chain risks. Although parts of the implementation timeline were delayed through the Omnibus package, the overall direction remains unchanged: supplier information must become verifiable and traceable (European Commission, 2025).
The EUDR operates in a similar way. For many companies, implementation begins in December 2026. Not all herbs and spices fall directly under the regulation, but the operational consequences extend far beyond the listed commodities. Geolocation data, plot-level verification and due diligence are moving from niche practices to standard sourcing procedures (European Commission, 2026 Guidance).
Consumer legislation is evolving as well. The Empowering Consumers Directive, applicable from 2026 onward, restricts the use of environmental claims that cannot be properly substantiated (EU Directive 2024/825). The policy direction of the Green Claims Directive follows the same logic: claims must become demonstrably verifiable before they are communicated. In practice, this makes the organic logo increasingly unsuitable as a broad umbrella claim for terms such as "sustainable," "ethical" or "planet friendly."
CSRD, EUDR and the Empowering Consumers Directive converge on the same principle: supplier information must be verifiable and traceable, not assumed on the basis of a certificate. The organic logo is increasingly unsuitable as a broad umbrella claim for sustainability terms that go beyond how a crop was grown.
Economic Concentration Adds Pressure
Economically, pressure is also increasing inside vulnerable categories. Cinnamon production remains highly concentrated in China and Vietnam, which together account for roughly 89% of global production (JRC, 2025). In early 2024, China dominated the European ginger market because Peru and Brazil could not supply enough volume to meet demand (CBI, 2024). This kind of concentration increases vulnerability to substitution, documentation inconsistencies and operational irregularities.
Two Shifts Underway
For buyers, this does not mean that long supply chains must automatically be avoided. It does mean that the traditional comfort of "there is a certificate" is becoming operationally weaker.
The first shift is therefore verification. European buyers increasingly request mass-balance overviews, residue analyses, CAPA reports and audit histories alongside standard certificates. Not as additional bureaucracy, but because auditors and regulators are now asking the same questions.
The second shift concerns supply-chain structure. Some importers are investing more heavily in direct sourcing, fixed producer groups and shorter trade routes. Not primarily for marketing reasons, but because controllability itself is becoming operationally valuable.
And that is where the industry conversation is slowly changing. Less discussion about claims. More discussion about evidence. Less emphasis on certification as an endpoint. More emphasis on verifiability as a continuous process.
Sources
- Joint Research Centre (JRC). (2025). Cinnamon authenticity and quality study. European Commission.
- DG AGRI. (2024). Additional measures on ginger imports from China and Peru. European Commission.
- DG AGRI. (2025). Audit findings: organic control systems in Sri Lanka and Turkey. European Commission.
- Skal Biocontrole. (2024; 2025). Annual reports on certification suspensions.
- EU Agri-Food Fraud Network. (2024–2025). Alert notifications: GMO in soy, origin claims in honey, ginger residues.
- RASFF. (2024). Rapid Alert System for Food and Feed notifications. European Commission.
- European Parliament & Council. (2018). Regulation (EU) 2018/848 on organic production and labelling of organic products. EUR-Lex.
- European Commission. (2025). Corporate Sustainability Reporting Directive — Omnibus update.
- European Commission. (2026). EUDR implementation guidance.
- European Parliament & Council. (2024). Directive 2024/825 (Empowering Consumers Directive).
- CBI. (2024). European market for ginger. Centre for the Promotion of Imports from Developing Countries.
