NEWS AND INFORMATION FOR THE SEASON PREPARATION 2024 | | |
Dear clients,
Firstly, the international team at bio.inspecta would like to wish all of you a successful and healthy year. It was great pleasure to meet some of you in Biofach 2024 and many thanks to those who visited our booth.; we hope to continue the positive and successful cooperation in the new season same as the previous years.
With this newsletter we would like to inform you about new procedures and news in 2024 concerning the regulations:
| | 1 Season preparation 2024 (deadline for data submission) | | | | | The updated data sheets and OSPs are available in the below link, please click on the link to download the relevant forms. If you have any problem to get the documents, please contact our back office directly: | | international@bio-inspecta.ch | | | The deadline for pre-payment and submission of the filled/updated data sheet and OSP is April 1st, 2024.
| | | OSP Production (25_133 EN) and OSP Processing (25_132EN) have minor changes and information about the audit trail documentation and organic fraud prevention plan is required. | | 2 Great Britain Organic standard | | | After the Brexit, Great Britain acknowledges the EU Organic Regulation as the basis for organic products. With effect of 01.01.2023, certification bodies accredited according to the EU Organic Regulation have been requested to obtain accreditation by Great Britain authorities. bio.inspecta has obtained the accreditation. Following are the effects for our clients: | | - Production, processing, trade of organic products: No changes, the bi-OS (EU equivalent standard) remains the basis for certification.
- The COI format will not change, it will continue to be issued as pdf.
| | | Important information for operators situated in Egypt: unfortunately, the current accreditation for Great Britain does not include Egypt. We are in contact with the responsible authorities in order to add Egypt to the list as soon as possible. | | 3 Increased Control measures of the EU, Great Britain and Switzerland for certain products from certain countries | | | Please make sure that you send your request in time manner, as all the COIs must be issued before the consignment leaves the origin country, please make sure to use the new form.
Increased control measures for certain products imported from certain countries to the EU are requested by the EU since 2016. For 2024, again the list of concerned products/countries has been amended. | | | For the products concerned, sampling/analysis for the first COI requested in 2024 will be compulsory. | | | Please make sure to consider sufficient time before the planned export to send the sampling request to bio.inspecta. | | 3.1 Effected products and countries | | | The requirements on increased control measures apply to certain products originating from certain countries. They are applicable for operators producing, preparing, trading, storing, or exporting organic food and feed. | | 3.2 Requirements of Increased control measures | | - At least 2 physical inspections per year, one of these unannounced.
- Inspection before sowing of the first certified crop for farms certified for the first time.
- At least one sample per year (for producers, it is compulsory to be a field crop sample). This requirement is without prejudice to the export consignment sampling.
- Increased control on traceability and flow of products.
- Increased control on bookkeeping and financial documentation (accounting).
- Increased control on means of transport and storages.
- Information must be kept ready for inspection about all sales of organic products as conventional, including quantities and names of buyers.
- Export consignment sampling and analysis assessment before issuing a COI: For the products defined above, a minimum of 10%-20% of all export consignments needs to be sampled and analysed for the presence of unallowed substances. The percentage is calculated for each concerned product of each concerned operator for the period between 01.01.24-31.12.24. Please refer to information about the sampling/ analysis procedure and timelines in the information leaflet, Certification of Inspection (COI).
| | 4 Changes in the NOP and the rule on Strengthening Organic Enforcement (SOE) | | 4.1 Changes in the National Organic Program | | | We would like to inform you that on January 19, 2023, the USDA National Organic Program published the final rule on Strengthening Organic Enforcement (SOE). This update to the USDA organic regulations strengthens oversight and enforcement of the production, handling, and sale of organic products. All operations and certifying agents must meet all the requirements in the rule by March 19, 2024. | | | The final rule focus on the reducing the number of uncertified entities, strengthen recordkeeping and supply chain traceability, strengthen oversight of accredited certifiers and require use of electronic import certificates. | | 4.1.1 Who is impacted by SOE | | | USDA accredited certifying agents | | - Organic inspectors
- Producers, processors, and handlers any operation that produces or handles organic products must be certified, unless they are exempt.
- Brokers, traders, exporters, and importers who are currently not certified organic (Handle includes trade, export, import, or facilitate the sale or trade of an organic product).
- Some supply chain intermediaries that currently do not require certification, such as traders, commodity brokers, or importers, must become certified.
| | 4.1.2 Who is not effected by SOE | | | SOE allows limited exemptions for some low-risk businesses: | | - An operation with annual sales less than $5000
- A retail establishment that does not process the organic products, or only processes them at point of final sale
- Some shipping and handling operations, under very limited conditions (e.g., they only handle products sealed in tamper-evident packaging)
- Customs brokers
| | | Exempt businesses are only exempt from certification. They still have handling and recordkeeping requirements. | | 4.1.3 What should be implemented with SOE | | | 4.1.3.1 Recordkeeping Requirements | | | Traceability is one of the key points for the SOE and all certified operations must maintain records that trace the product back to the last certified operation. This will help to getting everyone in the supply chain certified.
Certified operations must describe monitoring practices and procedures in their OSP’s to prevent fraud and verify suppliers and products in the system.
With the final rule, certification bodies will conduct supply chain traceability audits and will verify the compliances and chain of custody of high-risk products. This includes sharing information with other certification bodies.
| | | 4.1.3.2 Non-retail container labelling: | | | Accurate labelling of non-retail containers used to ship or store organic products is critical to organic integrity. Proper labelling reduces misidentification and mishandling, facilitates traceability and product verification, reduces the potential for organic fraud, and allows accurate identification of organic product by customs officials and transportation agents. | | - Nonretail containers used to ship or store organic products must be clearly labelled with a statement that identifies the product as organic.
- Clearly visible organic identification alerts handlers that the contents of the nonretail container may require special care, thus reducing accidental mishandling of the product, such as treatment with a prohibited substance or commingling with conventional product during transport and storage.
- Operations may use abbreviations or acronyms to identify products as organic, provided that they are clear and easily understood.
- Operations may use abbreviations or acronyms to identify products as organic, provided that they are clear and easily understood.
- Audit trail documentation associated with a nonretail container must identify the last certified operation that handled the product.
| | | 4.1.3.3 Calculating Percentage of Organic Ingredients: | | | To calculate the percentage of organic ingredients in a multi-ingredient product, divide the weight or volume of the organic ingredients at formulation by the total weight or volume of the product at formulation. If water and salt are added as ingredients, these must be excluded from the calculation.
If a multi-ingredient product contains only liquids, volume must be used for calculation. If a product contains both solid and liquid ingredients, weight must be used for calculation. | | | 4.1.3.4 Producer Group Operations: | | - Producer group members are organized into production units. A producer group production unit is a defined subgroup of producer group members in geographic proximity within a single producer group operation that use shared practices and resources to produce similar agricultural products.
- A producer group operation must use centralized processing, distribution, and marketing facilities and systems.
- All producer group operations must have an Internal Control System (ICS) that implements the practices and procedures described in the organic system plan.
- All products sold, labelled, or represented as organic by a producer group operation must be produced or harvested only by producer group members on land and using facilities that are included in the producer group operation’s certification.1.4.
- During on-site inspections, certifying agents must inspect at least 1.4 times the square root or 2% of the total number of producer group members, whichever is higher.
| | 4.2 NOP Import certificate requirement for export directly to USA | | | The USDA National Organic Program (NOP) has expanded the functionality of its Organic INTEGRITY Database (INTEGRITY) by launching a new import certificate module. The Import Certificate provides traceability to the port of entry and ensures an auditable record trail.
At the moment this new module is used as test version and will be mandatory from March 19, 2024 and there is no possibility to export the product to US without issued NOP import certificate.
We would like to inform you that bio.inspecta started issuing the import certificate from 01.01.2024 for all direct export to the US.
Any request for TC or NOP import certificate must be submitted and issued before shipment of consignment.
| | 5 Information on the upcoming new EU regulation 2018/848 | | | A new EU Organic Regulation has come into force in the EU member states on 01.01.2022, while outside the EU, there will be a transitional period until 31.12.2024 to shift to certification according to the new regulation. The amended regulation aims at guaranteeing fair competition to producers, prevent fraud and increase consumer confidence in organic products. It consists of the basic act Regulation (EU) 848/2018, as well as secondary legislation (so called delegating and implementing acts).
bio.inspecta will keep you informed continuously with more details of the new Regulation, and status of implementation, in order to support a smooth transition for all our clients.
For the moment no Certification Body (CB) is accredited for activity in the third countries according to the new regulation. We are starting the season for inspection and certification in accordance with bi-OS (bio.inspecta Organic Standard for equivalence in third countries in accordance with Regulation (EC) No 834/2007).
bio.inspecta will keep you informed continuously with more details of the new Regulation, and status of implementation, in order to support a smooth transition for all our clients.
| | | bio.inspecta international team is available to support you in any step, please do not hesitate to contact us or your local partner if you have any questions!
Kind regards,
| | bio.inspecta AG | | Farzaneh Mahdipour and international team
Head of International Services Division
Ackerstrasse 117, CH - 5070 Frick
Central +41 (0) 62 865 63 00
Mobile +44 (0) 75 394 55 092
Hotline +41 (0) 62 865 63 42 | | |
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