Key data
| Regulation | Commission Implementing Decision (EU) 2026/522 of 10 March 2026 |
|---|---|
| CELEX Reference | 32026D0522 — Notified under number C(2026) 1497 |
| Publication | 12 March 2026 |
| Entry into force | 10 March 2026 |
| Affected parties | Importers, manufacturers and distributors of products containing genetically modified cotton T304-40 |
| Reference regulation | Regulation (EC) No 1829/2003 on genetically modified food and feed |
| Category | European Regulation |
| Year | 2026 |
Importers, manufacturers and distributors working with cotton T304-40 can continue to operate in the EU, but with documentary obligations that cannot be overlooked. The Commission Implementing Decision (EU) 2026/522, in force since 10 March 2026, renews the marketing authorization for this genetically modified cotton in accordance with Regulation (EC) No 1829/2003 on genetically modified food and feed.
The renewal is not automatic for companies: it requires that each operator in the supply chain actively review their compliance. Incorrect labeling or lack of documentary traceability are the main risk areas.
What does this regulation establish?
Decision 2026/522 renews the marketing authorization in the EU for three categories of products linked to GM cotton T304-40:
- Products that contain genetically modified cotton T304-40
- Products composed of such cotton
- Products produced from cotton T304-40
The legal basis is Regulation (EC) No 1829/2003, which regulates the authorization, labeling and traceability of genetically modified food and feed throughout the European Union. This renewal confirms that cotton T304-40 can continue to circulate legally in the European market, provided that operators comply with the established conditions.
Cotton T304-40 is mainly used in two supply chains:
- Textile fiber: as raw material in the clothing and textile industry
- Animal feed: cotton by-products (meal, seed) used in animal nutrition
Although textile use does not involve direct human consumption, the presence of GMOs in the supply chain equally requires rigorous documentary controls under European regulations.
Economic and operational impact
The renewal of the authorization does not introduce new direct regulatory costs, but it does maintain—and requires verification of—a set of operational obligations that have real costs for companies:
- Supplier audit: companies must verify that their suppliers of cotton T304-40 operate under the terms of the renewed authorization. This involves requesting updated documentation and, where appropriate, updating supply contracts or agreements.
- Labeling review: products that contain, are composed of or have been produced from cotton T304-40 must comply with the GMO labeling requirements established in Regulation (EC) 1829/2003. Incorrect labeling can result in product recalls from the market.
- Maintenance of documentary traceability: the regulation requires that operators can demonstrate the origin and GM nature of the cotton at each link in the chain. This involves costs for documentary management and internal control systems.
- Risk of inspection: the competent authorities of each Member State may inspect compliance. Non-compliance in GMO matters is subject to administrative sanctions according to applicable national legislation.
Who does it affect?
This regulation directly affects the following business profiles:
- Importers of cotton T304-40 or derived products (fiber, seed, cotton meal) from third countries
- Manufacturers in the textile sector that use GM cotton T304-40 as raw material
- Feed manufacturers that incorporate cotton T304-40 by-products in their formulations
- Distributors of food, feed or textile products that contain or are composed of this cotton
- Compliance advisors and procurement managers in companies in the textile, food and feed sectors that manage supply chains with international suppliers
Practical example
A Spanish compound feed manufacturer that uses cotton meal imported from a US supplier must verify that the supplier can demonstrate that the cotton T304-40 it supplies is covered by the renewed authorization through Decision 2026/522.
In practice, this means:
- Request from the supplier the documentation proving that cotton T304-40 is authorized under the terms of Decision 2026/522
- Review that the labeling of the final feed complies with the GMO identification requirements of Regulation (EC) 1829/2003
- Update internal traceability records to reflect the renewal of the authorization and the date of entry into force (10 March 2026)
If the manufacturer does not perform this verification and markets the feed without updated documentation, it exposes itself to administrative sanctions for non-compliance with GMO regulations, as well as possible product recalls from the market.
What should companies do now?
- Identify if your supply chain includes cotton T304-40: review with your procurement team whether any supplier supplies products that contain, are composed of or have been produced from this GM cotton.
- Request updated documentation from suppliers: ask your suppliers to demonstrate that they operate under the terms of the authorization renewed by Decision 2026/522, in force since 10 March 2026.
- Review the labeling of your products: verify that the products you market comply with the GMO labeling requirements established in Regulation (EC) No 1829/2003. If in doubt, consult with a specialist in food or feed regulations.
- Update traceability records: ensure that your documentary traceability system reflects the renewal of the authorization and allows you to demonstrate the origin and GM nature of the cotton at each link in the chain.
- Review contracts with suppliers: if supply contracts reference previous authorizations, update them to include the new authorization and associated compliance obligations.
- Establish a periodic review schedule: GMO authorizations are temporary and are renewed. Incorporate monitoring of these renewals into your regulatory compliance management system.