Brief Introduction to Requirements for Group Certification

according to the European Regulation (EEC) 2092/91, the US National OrganicProgram (NOP), JAS, and CERES standard interpretation

1.      Group certification:

•     Is a necessary tool to allow smallholders access to organic markets

•     Requests a high level of commitment and knowledge by the organisation or certificate holder

•     Is possible for crop production, animal husbandry, or beekeeping.

2.         Normative framework:

•     According to NOP, farmers with less than 5,000 USD annual turnovers can sell organic prod­ucts without certification; this, however, refers more to smallholders in the USA, who sell di­rectly to consumers. These producers are not allowed to display the USDA-seal.

•     In 2003, the EU commission issued a “guidance” for group certification according to (EEC) 2092/91; this document, however, is not legally binding, and different EU member countries may have different positions on this; the paper limits group certification to developing coun­tries as defined by the OECD (http://www.oecd.org/pdf/M00038000/M00038051.pdf).

•     The International Federation of Organic Agriculture Movements (IFOAM) organised several meetings on group certification, and then published a set of normative and training docu­ments.

•     CERES, taking into account these different approaches, has worked out its own policy; the fol­lowing is based on this interpretation.

3.         What are smallholders:

•     We agree with the definition of the EU guidance, that smallholders in this context should be de­fined as producers, for whom the cost of individual certification would exceed 2% of their annual turnover obtained with the certified product.

4.         What is a producer group:

•     Producer groups can be cooperatives, associations, or similar organisations; but also pro­cess­ing or trade companies can organise their suppliers in a producer group.

•     Producer groups must be located within the same geographical region, have the same kind of product and similar production systems.

•     In case the group is spread over a large region, it has to be subdivided in smaller groups

•     Group certification makes sense only for groups from 15 members on; nevertheless, also smaller groups should feel encouraged to set up their own internal control system, independ­ently from the percentage of external control by the certifier.

5.         Internal control:

•     As a basic requirement, all producers have to be controlled at least once per year by the inter­nal inspectors.

•     Internal inspectors must be adequately prepared for performing their job; we recommend train­ing by our staff.

•     Conflicts of interest must be avoided when selecting internal inspectors; nevertheless, we rec­ognise that situations may exist, where consultants will have to do the internal inspections

•     Internal inspections must be documented in reports, signed by the producer and the inspec­tor; reports must be properly filed.

•     Internal inspectors must dedicate enough time to each inspection.

•     Reports must describe all relevant features of the operation, and must outline non-conformi­ties.

•     Results of internal control must be evaluated and summarized in the organic management plan and in the Internal Inspection Report Revision Spreadsheet.

6.         Internal regulation and approval:

•     The group must have an internal regulation, including, among others, remediation measures and sanctions for non conformities.

•     An internal approval body must evaluate the reports, supervise the inspectors, pre-approve growers, and impose remediation measures.

7.         External control:

•     The number of producers controlled by the external inspector, is determined by the square root of the number of all growers, multiplied by a risk factor:

•     y = r x vx    (y = producers controlled by our inspector, r = risk factor, x = number of all group members); the minimum is 10

•     The risk factor “r” can vary between 1 and 4: groups with a low-input crop, good internal con­trol system (ICS) and low rate of nonconformities, will have a low risk factor, and vice versa; example: