On 22 October 2026, the Court of Justice of the European Union (CJEU) delivered a landmark judgment in Lima case (C-295/25) providing long-awaited clarification on the use of organic agricultural ingredients naturally rich in minerals in organic food products.

The Court held that organic powder derived from Lithothamnium calcareum (a calcium-rich marine algae) may be used in organic foods for nutritional enrichment purposes because it constitutes an organic agricultural ingredient, rather than a “mineral” subject to the strict limitations applicable to added minerals under the Organic Regulation.

Key Takeaways

Organic Lithothamnium powder is not a “mineral”

The Court confirmed that organically certified Lithothamnium powder qualifies as an organic agricultural ingredient and may therefore be used in organic foods to provide calcium.

In doing so, the CJEU distinguished its earlier judgment in Natumi (C-815/19), which concerned non-organic Lithothamnium, and found that the concerns regarding the circumvention of the strict rules on the addition of minerals to organic foods do not arise where the ingredient is itself organically certified and agricultural in nature. The Court thereby departed from the Opinion of the Advocate General and rejected the interpretation previously reflected in the European Commission’s FAQ on organic production rules.

Implications for the Organic food sector

The Lima BV judgment is likely to have implications far beyond Lithothamnium. The Court’s reasoning suggests that organic agricultural ingredients naturally rich in vitamins, minerals or other nutrients may be used in organic foods for nutritional purposes, provided they are genuine organic agricultural ingredients and not isolated minerals or synthetic nutrient sources. This brings significant legal certainty for operators developing products containing naturally nutrient-rich ingredients derived from algae, plants, fruits or other agricultural sources.

More broadly, the CJEU stressed that Regulation (EU) 2018/848 aims not only to preserve the integrity of organic production but also to promote a diverse range of high-quality organic foods. Preventing the use of organically certified nutrient-rich agricultural ingredients could, paradoxically, encourage the use of non-organic or non-agricultural alternatives and thereby undermine the objectives of the organic framework.

Conclusion

Beyond the specific case of Lithothamnium, this judgment is expected to influence the interpretation of the Organic Regulation across a wide range of nutrient-rich organic ingredients. Food business operators may wish to revisit current product formulations and innovation projects in light of this important clarification from the CJEU.

The full judgment is available here https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62025CJ0295 (Dutch, language of the case – FR, DE available, not EN)

For any questions regarding the implications of this decision for your products or compliance strategy, please contact DALDEWOL Food & Regulatory Team:

• Aude Mahy,
Partner | ama@daldewolf.com
• Emmanuel van Nuffel,
Partner |
evn@daldewolf.com