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Issue

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Aims

This policy establishes minimum requirements for traceability of organic products.

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Background

As a response to globalisation and increasingly complex and anonymous supply chains, traceability is becoming more and more important in food production in general. For organic markets, however, traceability is even more essential.

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Normative framework

EU regulation

Annex III.6:

Stock and financial records must be kept in the unit or premises, to enable the operator and the inspection body or authority to trace:

- the supplier and, where different, the seller, or the exporter of the products,

- the nature and the quantities of agricultural products as referred to in Article 1 delivered to the unit and, where relevant, of all materials bought and the use of such materials, and, where relevant, the composition of the compound feeding stuffs.

- the nature, the quantities and the consignees and, where different, the buyers of any products as referred to in Article 1, which have left the unit or the first con­signee's premises or storage facilities

Annex III D:

With regard to the operations, which are contracted out to third parties…

- all the practical measures, including inter alia an appropriate system of docu­mentary accounts, to be taken at the level of the unit to ensure that the products the operator places on the market can be traced to their suppliers, and, where different, their sellers, as well as to their consignees and, where different, their buyers

NOP

§ 205.272 (a): The handler of an organic handling operation must implement measures necessary to prevent the commingling of organic and non organic products…

JAS

Notification 60, Art. 4: The organic agricultural products used for …processed food… shall be controlled not to be mixed with other … products…

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Terms

Traceability: Possibility to identify the origin of a product or a product-batch, the processes and steps it has undergone, and the persons responsible for each step.

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Policy

As a minimum, CERES will implement the above-mentioned requirement of the EU-regulation: at any post-harvest operation, at least the previous and the following producer or handler of a prod­uct or product-lot must be identifiable. To safeguard this, operators must implement procedures like physical separation, labelling, and detailed records. Nevertheless, we are aware that there are operations, like e.g. mills, dairies, or oil-mills, where even this level of traceability is very diffi­cult to achieve.

Therefore, as a general policy, we establish that, in its own interest, any organic post-harvest op­eration should try to achieve the highest possible level of traceability, according to the type of product and facility. The bigger the suppliers and their respective quantities, the easier it is to achieve a higher level of traceability.

In all high-risk situations, CERES requires organic operators to keep reference samples. "High-risk" is defined in this context as frequent findings of pesticide or GMO residues in the respective product in the respective country or region.

•     Reference samples should be kept for at least one year after shelf life of product or re-evalua­tion date or for one year after distribution is complete, whichever is longer.

•     Sample size should be twice the amount required to perform specification testing.

•     Sample should be identified with product name, lot number and sampling date.

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Access to this policy

•     This policy is available to all interested public

•     It must be handed out to all CERES certification and inspection personnel

•     It must be handed out to all post-harvest handlers interested in certification.

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