Brief Introduction Standard Inspection Program
according to the European Regulation (EEC) 2092/91, the US National Organic Program (NOP), JAS, and CERES standard interpretation
1. Processing of organic food:
• Must assure traceability and transparency.
• Requires a good documentation system.
• Must not contaminate organic products through inappropriate post harvest handling.
2. Who needs to be certified as organic processor:
• All handlers who process, dry, freeze, clean, mix, pack, or label organic products after harvest, need to be certified.
3. Origin of organic raw materials:
• First of all (which may be self-evident for many), all post harvest handlers must understand that only certified organic raw materials can be processed to organic products.
• Only EU certified raw material can be used for products for the EU market, only JAS certified for the Japanese market, while raw materials for the US market must be NOP certified – so please always ask your supplier of raw materials for a copy of a valid certificate, issued according to the respective standard.
4. Separation:
• Some processors produce only organic, but most do both: organic and conventional.
• These latter handlers have to set up a good system for separating organic products from conventional ones: from the moment of reception of the raw material, through all steps of processing, storage rooms, etc., until sale. Separation must also be safeguarded between organic and transitional products, or products certified according to different standards (e.g. NOP / EU).
• The best separation, of course, is in space: have separate warehouses and processing lines for organic.
• However, this may often not be possible; in this case, you can separate in time: you process organic at different times on the same line as conventional; before processing organic, you have to clean the line.
• In case of continuous processes (e.g. mills), the operator must make sure that at the beginning of organic processing, a reasonable quantity of organic product is used for “cleaning” the line, and sold as conventional.
• Where separate warehouses are not feasible, an adequate separation within the existing storage room may be sufficient: e.g. rows separated by a line on the floor, or separate shelves, properly labelled.
5. Documentation and labelling:
• An organic processor needs an organic management plan, or a chapter in his/her quality handbook, which refers specifically to processing of organic food.
• Wherever parallel production of organic and conventional products takes place, bags, containers, boxes with organic products have to be labelled, at all steps through your facility.
• The operator has to keep and file supplier certificates, way bills, reception notes, processing protocols, storage books, and invoices; all these records have to refer to the organic condition of the product.
• Organic processors need a good book keeping system, allowing evaluating whether the quantity of purchased raw material is consistent with the quantity of finished product sold.
• Except for open raw material arriving directly from the field, only packed or sealed and labelled products must be accepted for organic processing, unlabelled products should be returned to the supplier.
• The EU-Regulation requires operators, who do not process organic "at regular times or on a fixed day", to announce processing of organic products in advance to the inspection body.
• In addition, JAS requires "grading" records: before selling products with the JAS logo, the producer has to double-check and record fulfilment of JAS standards.
6. Traceability:
• Everything mentioned under (3), (4), and (5), has to do with traceability, but since this is such a crucial point, here again: the organic market can develop only if the consumer trusts that the origin of what is on his/her plate, can be traced back to the organic farm.
• It is impossible to require the same level of traceability for such different processes as fresh fruit packers (where traceability back to the field is easy to achieve), dairies, or noodle factories.
• Nevertheless, as a general rule, the highest possible level of traceability should be tried to achieve in every given situation.
7. Labelling of multi ingredient products:
The following table gives an overview for labelling requirements for the different categories*:
NOP:
100% organic |
Organic |
Made with organic |
(Only reference to organic ingredients) |
|
Only organic agricultural ingredients, no processing aids |
Minimum 95% of organic agricultural ingredients; rest only according to National List; |
Minimum 70% of organic agricultural ingredients; no use of USDA seal |
Less than 70% of organic ingredients; no use of USDA seal or certifier's logo |
|
non-organic ingredients without use of excluded methods or substances |
|
Only these two categories are available for livestock feed |
|
EU:
Organic |
With organic ingredients |
|
Minimum 95% of organic ingredients; |
Minimum 70% of organic ingredients; |
|
Rest only non-agricultural ingredients according to Annex VI A or non-available agricultural ingredients according to Annex VI C, without GMO. |
|
|
Reference to organic only on the list of ingredients, not on the general label. |
* percentages discounting salt and water
8. Post harvest pest control, sanitation, polluting substances:
• The operator must make sure that the organic product at no moment comes into touch with polluting substances, such as fuels, pesticides, wood preservatives, detergents, molds etc.
• For pest control in stored products, only substances mentioned in annex ii (EU) or the National List (NOP) can be used.
• For cleaning, sanitation, and pest control of processing lines and rooms, the general rules of the respective food legislation apply.
• Beyond this, CERES determines that after application of conventional pesticides in a processing facility, the waiting time until bringing organic products into the respective room has to be doubled, as compared to the time officially indicated for the respective substance; all surfaces which enter into contact with the organic product have to be rinsed with clear water.
• Although this is not a part of the abovementioned organic standards, CERES requires that organic products are handled under appropriate hygienic conditions.
Please be aware that this is only a selection of essential requirements of the organic standards, meant as an introduction. The operator, of course, has to learn about and meet all requirements of the respective
standard.
according to the
European Regulation (EEC) 2092/91, the
US National Organic
Program (NOP), JAS, and CERES standard interpretation
As a minimum, the
inspection of organic processors will cover the following
aspects:
No |
Issue |
Text |
|
1 |
Review |
of the organic management plan and its
implementation. |
|
2 |
Physical
inspection |
Visit
to all processing lines, places of raw material reception, storage rooms
for raw material, semi-finished and finished products, packing units,
etc., including subcontracted units, focussing on:
•
Origin of organic raw
materials
•
Separation (in time or space) from
non-certified products throughout the whole process, from product
reception to final sale or delivery
•
Use
of processing aids and food additives
•
Cleaning and pest control
procedures
•
GMO
(genetically modified organisms)
•
Prohibited methods (ionising radiation,
etc.)
•
Possible contact with prohibited or
otherwise polluting substances
•
Labelling and
traceability |
|
3 |
Records |
•
Drawing of the unit, including eventual
subcontracted units
•
Flow chart, describing the
process(es)
•
Recipes
•
Copies of valid certificates of all raw
material providers
•
List of raw material
providers
•
List of clients for organic
products
•
Records on all purchases of organic raw
material
•
Storage books
•
Processing
protocols
•
Pest control protocols, list of products used
for cleaning, disinfections, pest control
•
Non-GMO declarations for processing aids
or raw materials, which could potentially be produced with the help
of GMO
•
Records on outgoing organic
products
•
Bookkeeping
•
Chapters on organic processing from
quality management handbook (if existing) |
|
|
Please be aware, that these are the
minimum requirements. In many cases, additional issues will have to
be included in the inspection schedule! |
|
|
See also |
•
CERES policies on:
o
Traceability
o
Pesticide residues and sampling
frequency
o
Minimum sanitary
conditions
o
Pest control in processing
units
•
Brief information on organic
processing
•
Management plan organic
processing |
