Organic certification comparative analysis of china, eu and us regulations

ORGANIC CERTIFICATION
Comparative Analysis of China, EU, and US Regulations
Jeanne M Hoskin, PhD
ChemLinked
1
© REACH24H CONSULTING GROUP

Organic food is food produced in a way that
complies with organic standards set by national
governments and recommended by
international organizations
2
ORGANIC: IT’S A REGULATED TERM!

WHAT IS ORGANIC FOOD?
Organic food is produced by organic farming
Organic farming means cultural, biological, and
mechanical practices are used to foster cycling of
resources, promote ecological balance, and conserve
biodiversity
Synthetic pesticides and chemical fertilizers are not
permitted but certain approved pesticides may be used
Organic foods are also not processed using irradiation,
industrial solvents, or synthetic food additives
3

AN ORGANIC PRODUCTION SYSTEM IS DESIGNED TO:
4
•Enhance biological diversity within the whole system
• Increase soil biological activity
• Maintain long-term soil fertility
• Recycle wastes of plant and animal origin in order to return nutrients to the land,
thus minimizing the use of non-renewable resource
• Rely on renewable resources in locally organized agricultural systems
• Promote the healthy use of soil, water and air as well as minimize all forms of
pollution thereto that may result from agricultural practices
• Handle agricultural products with emphasis on careful processing methods in order
to maintain the organic integrity and vital qualities of the product at all stages

CODEX ALIMENTARIUS
GUIDELINES FOR THE PRODUCTION,
PROCESSING, LABELLING AND MARKETING OF
ORGANICALLY PRODUCED FOODS GL 32–1999
see Codex Guideline
These Guidelines are intended to facilitate the harmonization of requirements for
organic products at the international level, and may also provide assistance to
governments wishing to establish national regulations in this area
5

WHO’S WHO IN ORGANIC?
Competent Authorities (responsible government bodies) – overall responsibility and delegation of organic controls
 Standardization Administration of China (SAC) and the National Certification and Accredidation Administration
(SAC and CNCA)
 US Department of Agriculture (USDA)
 European Commission (EC)
Accrediting Bodies (authorized by the government/government agencies) – accredit certifying bodies (CB) for organic
certification activities
 China National Accreditation Service for Conformity Assessment (CNAS)
 Committee on Accreditation for Evaluation of Quality (CAEQ)
 The CAEQ monitors CBs through demonstrating either their equivalency or their compliance, and
provides the required documents to obtain recognition from competent authorities in Canada, US, EU
Certification Agencies/Certifying/Control Bodies or Agents-- Inspectors and Testing Agencies
 EU
 US/USDA
 China
Producers and Processors
 Farmers
 Suppliers
 Manufacturers (Food Operators)
 Traders
6

REGULATIONS
CHINA
 The standard system consists of Chinese National Organic Product Standard (GB/T 19630-2011 Part1-Part 4), which sets out
basic norms for organic production, processing, labeling, marketing and management system, as well as relevant organic
certification regulations, in which certification procedure, requirements for CBs and the use of label are defined.
 See New Certification Regulations on Domestic Organic Products and Organic Product Certification Measures AQSIQ Decree
No. 155
 New Certification Regulations on Domestic Organic Products GAIN Report
 http://www.globalorganictrade.com/files/g_files/GAIN_Report_-_Briefing_on_the_Organic_Certification_Issues_in_China_4-16-
2012.pdf
 GB/T 19630 Organic Products consists of four parts:
 Part 1: Production
 Part 2: Processing
 Part 3: Labeling and Marketing
 Part 4: Management System
US
 The National Organic Program develops the rules & regulations for the production, handling, labeling, and enforcement of all
USDA organic products.
 See USDA Organic Regulations 7 CFR Part 205 and Rules and Regulations ; also **Guide for Organic Processors**
 See example of specific certification guidelines in US
EU
 The relevant European legislation is the Council Regulation (EC) No 834/2007 and the Commission Regulation (EC) No
889/2008.
 see EU legislation on Organic Foods and certification
7

CHINA
 Standards for application of organic product
certification were promulgated by the
Certification and Accreditation Administration of
the People's Republic of China (CNCA) in June
2005
 In December 2011, CNCA released an updated
version of the application for certification of
organic products in the Regulation.
 This has been implemented since 1 March 2012
8

 Chinese National Organic Product Standard is
based on international norms with added
emphasis on contamination by pollutants and
prohibited materials and quality management
systems, especially record keeping and
traceability
 China’s new Standards for application of
organic product certification, implemented
since 1 March 2012, are considered among the
strictest in the world for organic agriculture
9

WHAT IS ORGANIC CERTIFICATION?
 As with competent authorities in the EU and US, CNCA
strictly regulates the certification bodies and sets out
procedures for the certification of operators
 Certification bodies inspect operators at least yearly and
more often according to risk
IMPORTED PRODUCTS:
 China does not allow foreign assessment bodies, such as
USDA, to accredit certifiers (for import into China)
 To date China does not allow equivalence agreements
with other countries. US producers, even though they are
USDA certified, are not allowed to use the Chinese term
for organic unless they receive certification from Chinese
certifiers
10

TYPICAL PROCESS OF ORGANIC CERTIFICATION
1. Applicant files application to a qualified organic product certification body
(CB) with required documents and materials
2. CB conducts the review on the application documents and materials and
decides whether to accept the application
3. CB appoints inspectors with qualifications and capability to form an
inspection team to prepare and implement an on-site inspection
4. All the products applying for certification must be sample tested on the
basis of risk assessment by qualified testing agencies
5. Certification institution makes a certification decision based on the on-site
inspection on the environmental quality of the production place and the
assessment and testing of the product. The CB issues a certificate if the
applicant complies with the certification requirements
6. CB reviews the supply agreements signed between the certified unit and
the customer as well as the sales scope and quantity of the certified
products. If qualified, a sales certificate for organic products will be issued
to the qualified unit
11

ANOTHER EXAMPLE OF CERTIFICATION PROCESS FLOW
1. Application for Certification with Certification
Agency
2. In house screening by Certification Agency
3. Additional questionnaire from Certification Agency
4. In house screening by Certification Agency
5. Organic inspector assigned
6. Organic Inspection
7. Organic inspection report to Certification Agency
8. In house review by Certification Agency
9. Addressing of any non-compliance issues
10. Certification issued
12

1. Introduction
• Company objectives and structure
• Reasons for farming organically
2. Site
• Farm and pack house or processing factory
3. Production History and Future Plans
• Crops, cultivation areas and yields
4. Land and Production Management
• Land and local farmer management
• Stakeholder relationships
5. Sales, Marketing and Financial Aspects
• Customers, sales channels and branding
• Pricing and turnover
6. Major Pests and Diseases
• Diseases, insects and weeds
• Control methods
7. On-site Farm Records
• Initial and renewal certifications, including organic-in-transition
• Farm management records
8. Organic Production Management System
• Sources of information
• Sustainability, including composting
• Compliance to organic standards
9. Certification and Inspection
• Inspection and certification process
• Selection of certification body and cost
10. Conclusion
• Key challenges and how to overcome them for future development
13
Typical standardized
questionnaire used
during a site visit
investigation

UK ADVISORY COMMITTEE ON
ORGANIC STANDARDS (ACOS)
14
Approves
and licenses
UK CBs
Inspect and license
individual operators in UK
Inspect and license as UK
organic in foreign
countries
USDA
Approves
and licenses
US CAs
Inspect and license in US
as organic + mutual
agreement with EU/UK
(UK organic label on
imported into UK)
China CNCA
Approves
and licenses
China CBs
Inspect and license
individual operators in
China as organic and
inspect as China organic in
foreign countries
For imports into UK…if mutual agreements are in place
For imports into China…mutual agreements not yet in place

EU LOGO AND ORGANIC LABELING RULES
 If used on a product, the EU organic logo indicates that
this product is in full conformity with the conditions and
regulations for the organic farming sector established by
the European Union.
 For processed products it means that at least 95% of the
agricultural ingredients are organic
 Next to the new EU organic logo, a code number of the
control body is displayed as well as the place where the
agricultural raw materials composing the product have
been farmed.
EU Organic logo and labeling rules 15

CHINA LOGO AND ORGANIC LABELING RULES
Labeling and Marketing of Chinese Organic Products GB/T 19630.3-2011
Also see Revised Administrative Measures for Organic
Certification
 Article 15 Processed products with the content of organic ingredients
(referring to weight or liquid volume, not including water and salt) no
less than 95% can indicate the language of “organic” on the product
or on the package or label of the product after it has received the
organic certification.
 Article 16 The certification body shall not carry out organic certification
for processed products with the content of organic ingredients less
than 95%.
16

LABELING: US LOGO AND ORGANIC LABELING RULES
 "100% organic" on the front of any certified organic food requires all ingredients (without except) to be
produced in compliance with organic regulations.
 Certified organic foods bearing the USDA logo must contain at least 95% (by weight or fluid volume,
excluding water and salt) approved ingredients.
 Up to 5% of the food may contain prohibited ingredients, if those ingredients are not available in organic form. For
example, an ingredient containing a synthetic pesticide residue may be included in a certified organic food bearing the
USDA logo, as long as that ingredient could not be obtained by the manufacturer in organic form and as long as the
weight of the ingredient did not exceed 5% of the total weight of the product (by weight or fluid volume, excluding
water and salt).
 However, there is one important caveat to this "5%" rule for certified organic foods bearing the USDA logo: even in the 5%
"non-organic" portion of the food, ingredients are not allowed to be genetically engineered, fertilized with sewage sludge, or
irradiated.
 "Made With" labeling claims on the front of the packaging at least 70% of all ingredients (by weight or
fluid volume, excluding water and salt) must be in compliance with all organic regulations.
 As such, 30% of ingredients may contain prohibited ingredients, provided that those ingredients are not available in
organic form.
 Just like use of the organic logo, however, there is one important caveat to this "30%" rule for certified organic foods showing
"Made With" claims: even in the 30% "non-organic" portion of the food, ingredients are not allowed to be genetically
engineered, fertilized with sewage sludge, or irradiated.
 Through individual ingredient entries on the Ingredients list on the side or back of the packaging. If a
food contains less than 70% of its ingredients (by weight or fluid volume, excluding water and salt) as
organic, no labeling claims are permitted on the front of the packaging.
 However, individual organic ingredients that comply with USDA regulations may be listed on the side or back of the
packaging in the product's Ingredients List.
 see Part 205 Subpart D Labels, Labeling, and Market Information
17

CONVERSION TO ORGANIC
 There are two certificates/Labels delivered by
certification bodies, Organic and Conversion to
Organic. Before delivering Organic certificate,
there is a period of conversion (usually 3 years),
subject to annual surveillance audits
 All products sold as organic/conversion to
organic must be certified
 Specific labeling requirements apply to
Conversion to Organic products
18

MUTUAL AGREEMENTS WITH IMPORTS (TRADE
AGREEMENTS)?
 Organic equivalency is a mutual recognition in the form
of bilateral arrangements between key trading partners
that allows for successful trade by reducing trade barriers
and supporting the strengthening of the supply chain.
 Equivalence means that the country has determined that
a foreign government’s technical requirements and
conformity assessment system meet or exceed the
requirements of the local organic law and its
implementing regulations.
 Organic equivalency recognizes two systems as
comparable and verifiable, though not necessarily
identical, without compromising the integrity that has
come to be expected from the organic designation in
both markets.
19

US AND EU
 Recognize a foreign government’s conformity
assessment system as being identical to the
applicable requirements of the US and EU and
therefore is competent to verify full compliance
with their technical organic requirements
 Alternatively, the US and EU can accept an
application for direct accreditation to perform
certification activities from any qualified foreign
private or governmental certifying agent
 US and EU may accredit foreign certifying agents in a
foreign country as well as recognize the foreign
government's conformity assessment system
20

MUTUAL AGREEMENTS AND EQUIVALENCE
 Learn about existing US organic equivalency agreements:
 U.S. // Swiss U.S. // Korea U.S. // Japan U.S. //
European Union U.S. // Canada
 EU-Switzerland
 Negotiations on a mutual recognition agreement in the
field of organic food products are ongoing with China
and these countries (as of April of 2015)
 US and China do not yet have equivalency or mutual
recognition agreements related to organic standards
21

EUROPEAN ORGANIC CERTIFIED PRODUCTS
 The European Organic Certification is
recognized by all European Union member
countries
 also see UK imports from third countries (non-
EU)
22

ORGANIC IMPORTS TO CHINA
 See Revised Administrative Measures for Organic Certification
 Article 17
 The competent authority for organic products of the country or region exporting
organic products to China may submit an application to CNCA for equivalency
assessment of the organic certification system. CNCA shall accept the application
and organize relevant experts to assess the submitted application.
 The assessment can be conducted through document review and site inspection.
 Article 18
 In case the organic product certification system in the country or region exporting
organic products to China is equivalent to China's organic certification system,
CNCA may sign a relevant memorandum of understanding (MOU) with the country
or region’s competent authority.
 The country or region’s organic products exporting to China shall be managed in
accordance with the provisions of the relevant MOU.
 Article 19
 For products intended to export to China from the country or region that has not
signed a relevant MOU on the equivalency of organic certification system with
CNCA, they shall comply with China's laws and regulations on organic products as
well as the requirements of China’s national organic standards.
23

ORGANIC IMPORTS TO CHINA (CON’T)
 Article 20
 Producers, sellers, importers or agents of imported products that
need to get China’s organic certification (hereinafter collectively
referred to as the imported organic product client) shall submit a
certification application to the certification body approved by
CNCA.
 Article 21
 The imported organic product certification client shall, in
accordance with the provisions of the organic product certification
implementation rules, submit to the certification body the relevant
application information and documents, of which certification
application materials and documents such as application form,
questionnaire, process flow, product formula as well as inputs used
in the production and processing shall be accompanied by a
Chinese-language version. For application materials that do not
meet the requirements, the certification body shall not accept their
certification applications.
24

CHINA MUTUAL AGREEMENTS
 Recently Ukraine and the People's Republic of
China signed an agreement on a mutual
recognition of certificates for organic produce
 Ukraine and China
25

ACTIONS FOR NON-COMPLIANCE
 Company should immediately report to
certification body
 Separation of Organic and Conventional Products
 Product Traceability and on-farm operating records
 Certification of Contract Farmer Production Bases
 Contract Organic Production
 Credibility of Organic Certification
 Potential Conflict of Interest
26

ORGANIC VS NATURAL: ARE THY THE SAME?
27http://www.stonyfield.com/blog/natural-and-organic/

Q & AS
Q. Is organic food safer or healthier than conventional food?
A. Organic refers only to a particular method of production; while
switching to organic foods can be good for you insofar as
doing so helps you avoid nasty things like chemicals and
additives, there's nothing in the organic foods themselves that
gives them an inherent nutritional advantage over non-
organics
28

Q & AS
Q. When can I label my products organic?
A. Once an operation is certified organic against
regulations or equivalent standards in specific
markets, and that certification is carried out by
a certification body recognized in that market,
products from that operation may be labeled
organic
29

Q & AS (EU)
Q. For which product categories is the new EU organic logo compulsory?
A. The use of the EU organic logo is compulsory for organic pre-packaged food produced within
the European Union where the terms referring to organic production are used (see Article
24(1)(b) of Regulation (EC) N0 834/2007).
Q. For which product categories is the new EU organic logo voluntary?
A. It is also possible to use it on a voluntary basis for non-pre-packaged organic products
produced within the Union and which satisfy the requirements set out under or pursuant to
Regulation (EC) No 834/2007 or any organic products imported from third countries and
recognized as equivalent in accordance with Regulation (EC) No 834/2007.
Operators are not obliged to use the logo on organic products when those products are only placed on third
countries' markets.
 Q&A on the EU organic logo
30

Q & AS
Q. What other information is required on the label of
a food with an organic logo?
A. Whenever the organic logo is used on a product,
it always has to be accompanied by the code
number of the control body and the place where
the agricultural raw materials of which the product
is composed have been farmed.
31

Q & AS
Q. In China, EU, and US, can the organic logo be
used in the case of in-conversion products and
food containing less than 95% of organic
ingredients?
A. No
32

Q & AS
Q. Are EU and Chinese standards and control systems for
organic products equivalent?
A. A review of EU and Chinese standards and control
systems show they have broad equivalency. Where they
differ, for example, is in the use of pesticides, this
reflects differing environmental conditions in China.
There are a number of instances where Chinese
standards are not as stringent as EU ones, but this does
not detract from overall equivalence.
A more fundamental difference, however, lies in their
implementation and the governance framework on
which the measures rest.
33

34
Thank you
ChemLinked Food Portal
Email: food@chemlinked.com
Website: food.chemlinked.com

Organic certification comparative analysis of china, eu and us regulations

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