It is common for inspectors to point out that vendor certificates are not “up to date,” which may seem confusing because the USDA NOP § 205.404 (c) clearly states that:
“Once certified, a production or handling operation's organic certification continues in effect until surrendered by the organic operation or suspended or revoked by the certifying agent, the State organic program's governing State official, or the Administrator.”
This same section requires certificates to include the effective date of certification, which does not change from year to year, so it is not effective at establishing whether a vendor is “in good standing.” The NOP is actively addressing the issue: It has published guidance document 2603 that outlines recommended certificate features and has implemented the USDA Organic INTEGRITY Database which will be a great tool for demonstrating compliance once detailed product information is incorporated.
Currently, our most reliable resource is NOP Guidance 2603, which describes certificate issue dates and monitoring dates commonly found on organic certificates. Certified operations must annually update their organic system plan and be inspected. The updated certificate and product list demonstrates the vendor is “in good standing.” The guidance document defines two dates from which QAI has developed a vendor certificate policy.
A certificate with a product addendum should be considered current if:
- The certificate was issued within 18 months.
- The product addendum was issued within six month.
- There is a future “anniversary date” or “annual monitoring date” on either the certificate or product addendum.
Operators are required to have both a certificate and product addendum on file.
The additional six months are built into the policy to allow suppliers to go through their renewal and receive the updated documents.
If you are subscribed to the NOP’s Organic Insider newsletter and alerts, you know that every few weeks, the NOP publishes a list of fraudulent certificates. Whether your company is certified as a handler and purchasing ingredients or as a producer and purchasing organic seed or feed, every inspection work order requires inspectors to verify organic certificates meet the above policy. Therefore it is very important for your company’s compliance to document and monitor compliance of certified vendors, at least annually.
- Have a documented system in place for qualifying and monitoring organic product and ingredient suppliers: obtain the organic certificate and applicable product addendum prior to purchasing ingredients.
- Set calendar reminders and regularly perform internal audits of the warehouse and records so you are always inspection ready.
- Have readily available supplier invoices in case a supplier certificate is out of date on the day of the audit; it should have still have been up to date when the ingredient was purchased.
- Make sure certificate addendums include not just the ingredient, but also the brand name, and list the standards the ingredient is compliant to (NOP, U.S./Canada equivalence).
- Make sure you have import certificates if your ingredients are from overseas. Import certificates are required for certain equivalency agreements such as with the EU, Japan, Korea and likely other countries in the near future. Visit QAI’s International Certifications web page for more details.
- Be sure to have transaction certificates, which qualify individual purchases/shipments. Because these include lot codes and quantities, they are very useful for traceability. Transaction certificates do not replace the annual organic certificate and applicable product addendum.
- If you rely on ingredient vendors/brokers who are not certified, make sure that there is a direct and documented link between the broker’s invoices and the certified supplier’s certificate. For example, have the broker include the name of the certified supplier on the invoice product description. Requiring this from the broker can increase their awareness of organic compliance activities and help them reduce their exposure to potentially fraudulent actors in the marketplace.
- If your vendor is not providing you with a current certificate, go to the NOP’s organic integrity database and print/take a screen shot of the supplier’s listing. Remember though that the database entries do not include brand names and are not equivalent to having the actual supplier certificate.