Proper use of the USDA Seal - Use of the USDA Seal is one means of “branding” an organic product. But what is the proper usage of this seal?

The USDA seal is a recognizable symbol indicating to the consumer that the product is in compliance with the regulation. Application of the seal is governed by the regulation and as such it must be used exactly as detailed in 7 CFR Part 205.311.

It is important to remember that the USDA seal is only allowed on “100% Organic” and “Organic” compliant products. Use of the QAI seal or mark is optional and is not a requirement of the NOP (National Organic Program); although using it is another way to “brand” your products. “Made With Organic…” labels may only display the certifier’s seal and are prohibited from use of the USDA seal.

Many of our valued clients understand that QAI’s Certification Mark is the most widely recognized in the US, and carries a lot of weight in the international marketplace as well. For the past several years, QAI has conducted an independent shelf study, measuring the depth of our penetration into the US organic marketplace. According to results of this study, nearly 66% of all certified organic products on US store shelves display QAI’s certification. Displaying QAI’s mark on your products allows you to leverage our highly regarded reputation in the marketplace and demonstrates your decision to Choose Quality, when it comes to choosing your organic certification provider.

Unlike the QAI mark, the USDA seal is required to use particular PMS colors which can be found on the NOP website at http://www.ams.usda.gov/nop/
Consumers/Seal.html. The permissible colors are Green - PMS 348, Brown - PMS 175, White and Black. These colors may be used in one of the following ways: (1) On a white background with a brown outer circle and with “USDA” in green overlaying a white upper semicircle. The word “organic” must be in white overlaying the green lower half of the circle. (2) On a white background with black outer circle and black “USDA” on a white upper half of the circle with a contrasting white “organic” on the black lower half of the circle. There is an option to use a transparent background versus a white background for the upper portion of the circle, with a contrasting white or transparent “organic” on the black lower half circle. Deviations from the permissible colors or format are not allowed under the regulation.

Questions often arise as to the size requirements for the USDA seal. While there is no specific requirement for the size, the certifying agent’s seal may not be more prominently displayed than the USDA seal. For example, if the USDA seal and the certifying agent’s seal both appear on the principal display panel, the certifying agent’s seal must not be larger than the USDA seal.

The USDA seal is a great branding tool to use on its own or as a supplement to the QAI mark on various materials other than product labels. As long as the product meets the requirements for “100% Organic” or “Organic” and has been approved by a USDA accredited certifying agency, marketing information, including the company website, may display the USDA seal.

The best way to ensure proper use of the seal and avoid a notification of noncompliance is to send in your labels to your Account Coordinator for approval prior to having them printed. Your Account Coordinator is here to help you so please call the Q with any questions you may have!

Extending the Scope of an Existing NOP Certification - Once you are certified you may wish to extend the scope of your certification.

It is not necessary to wait until your next annual monitoring to add products or crops to your Organic System Plan. It can happen at any time, provided that the necessary requirements are fulfilled, the correct documents are submitted and relevant non-compliance responses, fees and paperwork have been submitted and approved by QAI. Please be aware that every time we update your Organic System Plan Summary or Certificate during the year, a $50-150 fee applies depending upon complexity of the addition/revision.

Adding products/crops mid year is easy.

Simply follow the steps outlined below for handlers (e.g., Processors, Distributors, Traders) and producers.

All Clients

1. Good Standing – In order for us to add products/crops to your certification mid-year, you must be in Good Standing with QAI. This means that you must be up-to-date with payments, renewal paperwork, and the mitigation of non-compliances.
2. Written Request – You must send your Account Coordinator (AC) a written request to add the products/crops to your certificate.

Producers

1. An updated and complete Individual Field Profile (IFP) must be submitted for the new crop.
2. Producers must verify that the crop to be added is grown on the same land as was originally inspected and certified using similar cultivation methods and practices.
3. Verification of the use of compliant seed, seedlings and/or planting stock must be supplied (e.g., letters/invoices from suppliers, supporting documentation for any non-organic seed/seedlings used, commercial availability documentation).

Processors

1. Processors must verify that the product they wish to add is being processed at the same location and with the same equipment as originally inspected and certified.
2. A new and complete Individual Product Profile (IPP) must be submitted for each new product.
3. A new and correct label must be submitted for each new product. (Please have all labels approved by QAI prior to printing).
4. Supporting documentation for each ingredient and processing aid must be supplied that verifies that (a) the organic ingredients are currently certified to the NOP, and (b) any non-organic ingredients comply with the NOP, including commercial availability and specific NOP annotations, as applicable. Please note if you are using ingredients that have been previously approved following your most recent inspection then you will not be required to submit verification documentation for these ingredients during the midyear addition.

Distributors

1. Distributors must verify that the product they wish to add is being handled at the same location and in the same way as handling operations originally inspected and certified.
2. A Distributor Individual Product Identification (DIPI) form must be submitted for the new products to be added.
3. If QAI is noted as the certifier on the product label, a new and correct label must be submitted for each new product. (Please have all labels approved by QAI prior to printing).
4. Supporting documentation for each new product must be supplied that verifies the product’s current NOP organic status.

Traders

1. A Trader Individual Product Identification (TIPI) form must be submitted for the new products added.
2. If QAI is noted as the certifier on the product label, a new and correct label must be submitted for each new product. (Please have all labels approved by QAI prior to printing).
3. Supporting documentation for each new product must be supplied that verifies the product’s current NOP organic status.

Please note that the process for adding products/crops to any of your international programs – e.g., EU, IFOAM, Japan, Québec – is the same as above except that different forms need to be completed and verification of suppliers need to comply with the specific international requirements. If you are interested in adding additional international programs to your certification, please contact your Account Coordinator for complete details.

Transaction/Export Certificates

Transaction and Export Certificates are designed to document the organic certification of a specific sale of products. Some of these certificates are used as part of an audit trail to verify organic compliance while other are used as customs clearance forms to release organic products from port. QAI offers a variety of different transaction and export certificates that can be used for different markets:

• QAI Transaction Certificate – for sales domestically and to markets where other specific export certificates are not required (Canada, Japan (JAS), Korea, Taiwan, etc.).
• QAI IFOAM Transaction Certificate – for sales of IFOAM product to any market.
• European Community Certificate (ECC) – also referred to as a “Certificate of Inspection for Import” or COI in Europe. An export certificate required for direct exports to Europe.
• TM-11 the USDA Export Certificate for all USDA Organic Export Arrangements. Currently there is only one export arrangement between Japan and the US.

Before submitting a request for a Transaction/Export Certificate make sure you hold a current QAI organic certificate for the products in question. If you are applying for an ECC, TM-11 or IFOAM Certificate your products will need to be certified to the EU, Japan Export Arrangement or IFOAM standards respectively. Your QAI certificate will list which of your products are compliant with the various international and domestic certifications offered by QAI. If you do not have a current QAI organic certificate, please contact your Account Coordinator about revising you organic system plan to add these products.

Once the product is listed on your QAI organic certificate, you are ready to complete your request for a Transaction/Export Certificate and submit it to QAI for approval. QAI will normally process a Transaction/Export Certificate request within 24 hours of receipt. There are specific required documents that must accompany Transaction/Export Certificate requests to expedite their processing and approval.

• The Transaction/Export Certificate with all boxes completed, as applicable. Boxes that are not applicable should be marked “Not Applicable.”
• Documentation of the transaction listed on the Transaction/Export Certificate must be included in the form of a bill of lading or invoice with each and every Transaction/Export Certificate submitted to QAI for approval.
• Transaction/Export Certificate Coversheet with all applicable sections completed and signed must be submitted with the rest of your documentation.

Once assembled, your Transaction/Export Certificate request can be sent electronically to qaitc@qai-inc.com or via fax at 734.827.3893.

Links

• QAI Transaction/Export Certificate Coversheet
• QAI TC
• QAI IFOAM TC
• QAI TM-11
• TM-11 Instructions
• EEC
• EEC Instructions

Checking the Books — IFOAM and CAAQ SAMPLE AUDIT Requirements:

Both IFOAM and the CAAQ require that inspectors conduct a Sample Audit when inspecting IFOAM and CAAQ certified operators.

The inspector’s calculations for the sample audit must be included in the inspection report. When being inspected as part of QAI’s IFOAM or CAAQ Program, it is your responsibility to have all the necessary documents for your inspector to carry out a sample audit. The Sample Audit consists of two parts: the traceback audit and the input/output balance.

The Traceback Audit

This audit assesses the operation’s ability to track finished product backwards through the system to the source of certified organic ingredients, or in the case of production systems, back to the field(s) of production. This audit is usually done by choosing a lot # from finished product in storage or from sales or shipping records and assessing all of the supporting documents related to that particular lot. Such documents should allow you to trace the lot either back to the dates of harvest and fields of production or back through processing/handling, storage, and eventually to incoming ingredients and suppliers of those ingredients.

The Input/Output Balance

This audit verifies that organic product sold is justified by either the quantity of organic ingredients/products purchased or the quantity of crops/products produced. For the in/out balance, the inspector will need to choose a period of time to audit (e.g., the previous production year for producers or a particular year, month, or week for a handler, distributor or trader). Quantities of organic raw materials or organic finished products in inventory will need to be factored into the in/out balance.

For Producers the inspector will need to ascertain the producer’s annual production figures for the crop/acres that are audited. This claim will be verified during the inspection of harvest, production and sales records. If required, further information about the average yield per acre for the region can be gathered from government departments. For the in/out balance, once the inspector has chosen a period of time and crop, he compares harvest records with sales records, taking into account wastage, crops sold as conventional, and crops given away. Explanations will be needed if the yields were particularly high or low for a particular field or if sales records indicate that more crop was sold than harvested.

For Processors the inspector will first need to define a period of time that will be audited so that beginning and ending inventories, ingredients received, and products sold or shipped during that time can be established. The inspector will also need to ascertain the losses and/or recovery rates for an average production run. For multi-ingredient processors, inspectors often choose an organic ingredient and calculate how much of that ingredient went into the batch and how much was present in the final product. There are several calculations that can be used to balance ingredients in versus ingredients out. As long as the inspector is able to calculate the recovery rate (or conversion factor) of the product or ingredient that is being auditing and is able to take into account beginning and ending inventories by auditing a period of time, the inspector should be able to verify whether or not the handler is sourcing adequate quantities of organic ingredients for the quantities of finished product sold.

For Traders and Distributors the main aim is to compare the volume of sales against the volume of purchases. This should be relatively straight-forward since losses should be minimal. Again, the inspector will need to choose a period of time to audit and take into account beginning and ending inventories.

For Group Management Operations the inspector will first need to calculate the estimated annual production figures for the crop chosen (e.g., how much tea can be produced by the grower group during April – Sept?). Once this figure has been calculated, it will be compared with actual production figures and purchase records kept by the Managing Entity to see if they reconcile. If the Managing Entity further processes the crop, then an in/out balance will also be conducted for the handler. If the Managing Entity simply sells the crop on, then the inspector will carry out the in/out balance similar to the one for a Trader/Distributor.

QAI is proud to announce a new service we are offering to our valued clients - QAI’s 2006 Webinar Training Sessions

QAI’s Webinar Training Sessions will cover an array of topics ranging from international compliance to adding product midyear. The individual sessions will vary in length between 30 to 90 minutes depending on subject matter.

There is no cost to attend. The only requirement attendees must have in order to participate is access to an Internet connection.

Our first session is scheduled for February 2 at 10am PST. The topic will be the USDA MAFF Export Arrangement/TM-11. This will cover an in-depth look at regulatory concerns in the Japanese Organic Market. What is required to be compliant with the Japan Export Arrangement Program? How to complete a TM-11? What is required to be issued a TM-11?

If you are interested in attending, please contact Carrie Howard at 858-792-3531 or carrie@qai-inc.com for further instructions. If you have a suggestion for a future topic, please let us know.

Who’s that knocking? Are you prepared?

The regulation requires that you annually update your organic production or handling system plan and be inspected once a year.

It allows for the certifier, California or Utah’s State Organic Program’s governing State Official or the National Organic Program’s Administrator to conduct additional inspections, announced or unannounced, to verify compliance. Other programs such as those administered by the CAAQ and IFOAM require that a certain percentage of unannounced inspections be conducted each year.

As part of QAI’s quality monitoring surveillance program inspectors are asked to perform random unannounced inspections to check a client’s compliance with the organic program. An unannounced inspection is one that is not regularly scheduled. It may occur with no prior warning, or with a very short notification period. What is the inspector looking for? How can you demonstrate your compliance?

It’s all in the paperwork. Certified operations must establish, implement and annually update an organic system plan and submit it to the certifier for approval. Did you remember to keep a copy? Although QAI supplies our inspectors with the latest Organic Compliance Plan (OCP) that we have on file as part of the inspection package, inspectors from a State Organic Program or the National Organic Program will not have it and are sure to ask for it. They will also want to review the supporting documentation for the OCP and records that disclose your activities concerning the production, harvesting or handling of your organic products. Finally, they will ask about outstanding noncompliances and how they have been resolved or what progress you have made towards a resolution. The regulation requires that your records be maintained for 5 years and be available for inspection and copying during normal business hours by authorized representatives of the Secretary, the applicable State organic program’s governing State Official and QAI.

Although you may never receive that knock on the door, it is wise to be organized and be prepared!

January 22 – 23 - QAI participates in NASFT Fancy Foods Show San Francisco — we will be visiting our clients who are exhibiting at the show. If you would like to schedule a specific time for our visit, please contact Ellen P. Holton at 858.792.3531 ext 115 or by email: ellen@qai-inc.com.

February 2, 10am PST - QAI Presents “USDA MAFF Export Arrangement/TM-11 Webinar Training Session.” This session will cover an in-depth look at regulatory concerns in the Japanese Organic Market. What is required to be compliant with the Japan Export Arrangement Program? How to complete a TM-11? What is required to be issued a TM-11? For more information contact Carrie Howard at 858.792.3531 or carrie@qai-inc.com.

February 16-19 - QAI presents and exhibits at Biofach—Nurenberg, Germany.

March 23 - QAI Presents International & JAS Seminar as kickoff to Expo West >Read More

Learn about another valuable member of our QAI Team in this issue as we spotlight Jake van den Akker.

Back Story:

Hi all! My name’s Jake van den Akker and I’m the JAS Coordinator and an Account Coordinator at QAI.

I ended up at QAI after spending about a year in Central America where I was studying and working with coffee, cacao, honey and banana Cooperatives (yes, that’s me in the silly bee outfit!).

I’m a proud graduate of the University of California at Berkeley, where I studied Environmental Economics and Spanish. I have a beautiful wife, no children (although my wife seems to think she has one) and an adopted cat named Griffen. Some of my passions include surfing, traveling and learning about various cultures around the world.

Realtime:
Within the walls of QAI, I pride myself on creating a fun atmosphere and building strong relationships with my coworkers and clients. A typical day at the office includes providing excellent service to clients by answering their questions, verifying labels and issuing organic certificates, answering NOP and JAS questions, issuing letters of good standing, and playing the occasional practical joke…

Fun Facts:
Favorite Vehicle: The VW bus I drove from Costa Rica to San Diego
Favorite thing in my closet: My old black Chucks
Favorite Californian: Cesar E.Chavez
Favorite Liquid: The ocean or coffee depending on my mood
Favorite politician: Ralph Nader
Favorite Color: Green of course!
Favorite client: Like I would tell you!!!
Favorite place: The Zocalo in Oaxaca
Favorite TV character: Benjamin Franklin "Hawkeye" Pierce (from MASH of course)
Favorite Quote: “We must be the change we wish to see in the world.” —Mahatma Gandhi

 

To contact QAI:

If you have questions, concerns, or need general information, go to the QAI web site to learn how to contact us or to send us an email. For questions pertaining to QAI’s Quality News contact Ellen P. Holton, QAI Director of Marketing and Business Development directly at 858.792.3531 ext 115.

QAI, Inc. is an NSF International Company. Visit their web site to learn more about NSF International, The Public Health and Safety Company™.