Certification News, Resources, & Updates

Links to specialized pages on specific topics of interest:

Natural Resource Conservation (Biodiversity) and Organic Farming
Organic Certification Support Resources and Sample Record Keeping Forms- Certification Assistance
Canadian Organic Standards
European Union
IFOAM (CCOF no longer maintains IFOAM accreditation)
Liquid Fertilizer
Pasture Rule

Certification news items, standards changes and updates for CCOF certified organic operators.

General

Renewals Are Coming!

To remain certified with CCOF every operation must submit an annual certification contract and pay their certification fees. This process plays a critical role in preserving the integrity of organic production and standards, and allows CCOF to continue to serve our clients and their needs. In early November, CCOF will mail renewals and annual invoices to all operations. To complete the renewal process and remain certified with CCOF, you must:

• complete your renewal contract, and
• pay your annual fees

Please complete your renewal in a timely manner. Help CCOF serve you and other operations efficiently, and avoid unnecessary costs by completing your contract and submitting payment by January 1, 2012. If you would like to establish a payment plan, please contact CCOF accounting using the contact information listed on the invoice. Completing your renewal on time allows CCOF to ensure timely inspections and to group inspections so they are as cost effective as possible. If you have questions, please contact CCOF.

Renewals may be submitted online by visiting www.ccof.org/renewal.php. All CCOF bills may be paid online through the website.

Critical upcoming renewal deadlines:
November 1, 2011 - Renewals are mailed.

January 1, 2012 - All renewals and annual payments are due.

February 15, 2012 - A Notice of Noncompliance and a $75 late fee will be issued to all operations that have failed to complete the renewal process. This is also the last day to withdraw from CCOF certification without accruing certification fees in 2012.

March 15, 2012 - A Notice of Proposed Suspension and an additional $75 late fee will be issued to all operations that have failed to complete the renewal process.

April 15, 2012 - All operations that have failed to complete the renewal process will have their certification suspended. If your certification is suspended and you wish to be certified organic in the future, your certification must be reinstated by the NOP after a costly and lengthy process.

FAQ: What if I pay my bill but don't complete the renewal contract or vice versa?
Many CCOF operations assume that if they pay their fees they are not required to complete a renewal contract. Under the NOP standards a renewal contract is mandatory and failure to complete it will result in suspension of certification. Operations that only pay their fees or only complete their contract will force CCOF to issue a Notice of Noncompliance.

Certification Fee Schedule Changes

After more than five years without a change to CCOF's certification fee schedule, we are forced to implement changes to guarantee a high level of CCOF service in the future. CCOF clients will see these new fees reflected in their 2012 annual certification renewal. Though fees have not increased during this time, CCOF has improved service and responsiveness while experiencing significant increases in expenses and expectations from clients, the NOP, and accreditors. We continue to receive requests for faster service from clients of all sizes. At the same time, we face impending requirements to increase residue testing and unannounced inspection efforts while needing to continue to respond effectively to investigations.

To achieve these goals, CCOF is increasing our fees by approximately 8-12 percent across all client fee categories. CCOF is increasing fees more dramatically at the top end of the fee scale to reflect the increased workload and effort necessary for servicing today's large organic businesses. Specifically, CCOF has created a new top fee category to address businesses that have organic sales which exceed CCOF's previous top tier of $15,000,000 by 10 times or more. This will ensure that CCOF can effectively meet the needs of both the small and large entities with whom we work.

We are always wary of raising any businesses expenses but CCOF is confident that this fee increase will allow for the ongoing development of personnel and other resources to ensure that we effectively meet client needs and preserve organic integrity in the marketplace.

View the new Certification Services Fee Schedule chart.

Improving Materials Tracking and MyCCOF

Over the last year, CCOF has created computerized records for all inputs used by our clients. These records allow us to improve organization and streamline material reviews. During this process, CCOF developed an internal materials list that combines all internal CCOF material reviews as well as both the OMRI and WSDA lists. As files have been reviewed during this time, CCOF added each client's inputs to their operation's database record. In the coming months, CCOF will provide access to the "inputs tab" in each client's MyCCOF portal. This will allow you to monitor and track the status of input approvals and requests associated with your operation.

Many CCOF operations have requested access to a single materials approval list so they can be aware of past CCOF review decisions and eliminate the need to check several different lists when choosing brand name materials. CCOF seeks to meet the needs of our clients and we are actively reviewing options for making this list available. Though it is unlikely that CCOF will produce a printed materials list, options for an online list at www.ccof.org or within MyCCOF are being considered.

All materials approvals must be made in the context of the operation's organic system plan, and CCOF clients will always be required to seek approval of materials prior to use. However, we are committed to making this process easier, faster, and more transparent so growers, livestock operators, and processors can know what materials have been previously reviewed by CCOF or other entities.

Our ultimate goal is to provide both efficient electronic submission of Material Review Requests and to allow CCOF clients to have access to CCOF's internal materials list. This will ease material selection and additions to Organic System Plans. We hope to test systems in 2012 that will significantly improve your experience with input materials selection and requests. Stay tuned for more improvements to CCOF's inputs management, review, and approval system.

In addition to inputs, MyCCOF will soon include every client's record of facilities so you can monitor which facilities we have on file. This will allow you to easily track your facility inspections.

The Future of Chlorine
The National Organic Program (NOP) recently announced an important clarification to the use of chlorine in organic production systems. This may require operational changes for some CCOF clients who use chlorine for postharvest washing of crops. The NOP now requires that a potable water rinse follows chlorine used in postharvest water at more than 4 parts per million (ppm). CCOF was previously able to approve the use of chlorine at levels above 4 ppm in postharvest usage because of industry confusion over the meaning of the word "residual" in the regulations. The new NOP Guidance Document 5026 (available in the NOP Program Handbook at www.ams.usda.gov/nop) clarifies that the requirements are not intended to be a waste water regulation, but instead a regulation about protecting organic integrity.

According to the NOP Guidance Document, chlorine may be used in organic production as follows:

• Preharvest crop production: if in direct crop or soil contact, no more than 4ppm chlorine
• Postharvest crop production or processing: if in direct crop or food contact, and more than 4ppm chlorine, must have a rinse with potable water
• Tool or equipment sanitation (no direct food contact): up to maximum labeled rates, no rinse required

If you are a crop producer who has been using chlorine postharvest at more than 4 ppm in direct contact with food without a subsequent rinse, you will be required to modify your practices to be compliant with the above requirements. Please contact your CCOF Regional Service Representative to discuss a timeline for coming into compliance.

Rush OSP Update Service
To serve client needs and ensure the resources needed to provide timely service, CCOF has implemented new Rush Review services for OSP updates, material reviews, labels, products, and other items.

Under this program, clients may complete the Rush Review Request form at www.ccof.org/forms.php. Requests for a two business day review are $100 per item; requests for a five business day review are $50 per item. The ability to request rush service has also been integrated into the CCOF Material Review Request form.

CCOF will only bill you if the rush is requested in this format and completed within your requested timeframe. CCOF clients are not required to utilize this service and may indicate the need for "As Soon As Possible" processing for any update. CCOF will review updates as quickly as possible in the order received. However, we are providing this option for those operations who want to ensure a specific turn around.

Canada Organic Standards Border Enforcement Implemented July 1
Full implementation of the U.S. - Canada Organic Regime (COR) organic export agreement came into effect on July 1, 2011. This means full enforcement of the rules regarding export of U.S. certified organic crops and products that are sent, either directly or indirectly, to Canada. Prior to this date, the Canadian Organic Office allowed a "stream of commerce" policy while the industry readied itself for full compliance with the requirements. The time for full compliance is here!

What does this mean for you? As of July 1, Canadian border officials verify that the statement "Certified in compliance with the terms of the U.S. - Canada Organic Equivalency Arrangement" is included on accompanying documents or packaging for ALL shipments of organic products exported to Canada from the United States. Products that do not have accompanying documentation with this statement may be refused entry into Canada.

If you have enrolled in the CCOF Global Market Access program and been reviewed to the terms of the U.S. - Canada equivalency agreement, this statement will appear on your Global Market Access certificate. To ensure smooth export of your product, you will want to provide your Global Market Access certificate with shipment documentation, or add the required statement to bills of lading, invoices, or customs declaration documents.

Verification of NOP/COR Equivalence - Sodium Nitrate Risk Assessment
Under the terms of the U.S. - Canada organic equivalence arrangement, products grown using hydroponic or aeroponic production methods are not allowed to be sold as organic in Canada. This also applies to products grown using sodium nitrate (also known as Chilean nitrate). For U.S. operations wishing to ship organic product to Canada, CCOF will review the production practices and provide verification of adherence to these requirements so you can demonstrate compliance to buyers and others downstream.

CCOF researched the use of sodium nitrate, as well as hydroponic and aeroponic growing systems, and found that there are many crops (such as rice, coffee, or grapes) that have little risk of being prohibited due to use of these production practices. To ensure the U.S./COR verification process is as simple and efficient as possible, CCOF created a list of crops that are at risk of being grown using one of the prohibited production techniques (see below). For any of the crops listed below on the "high risk" chart, CCOF will verify that they were grown without the use of sodium nitrate and/or hydroponic or aeroponic production before we will issue a COR equivalency verification document. For crops that CCOF has identified as "no risk" CCOF will not seek additional documentation that they comply with the terms of the U.S. - Canada arrangement.*

CCOF has identified the following crops as at risk of being grown using sodium nitrate, and will require verification prior to verifying equivalency with Canadian requirements:

• Carrots
• Celery
• Cole crops: including kale, collards, etc.
• Fresh tomatoes
• Greenhouse crops, including tomatoes
• Leafy greens
• Livestock feed crops produced in the Midwest**
• Onions
• Potatoes
• Winter citrus from the Southeast United States
• Winter vegetables: including broccoli, cauliflower, etc.

Crops considered high risk for hydroponic or aeroponic production:

• Greenhouse Crops: including herbs and tomatoes

CCOF Improves Letters
In response to client requests for clearer and simpler communication, CCOF has launched new letter formats. These new formats have been tested for the last few months and have been met with improved client responses. Every letter now opens with a clear cover page and attached action items and/or reminders list that can be used as a checklist in your response.

Important Features and Benefits
1. Reference #: Use this number to reference a specific letter for easier communication with CCOF.
2. Action Item #: Identifies the specific action item(s) related to the letter. This allows you to easily identify which action item you're responding to in correspondence with CCOF. This number also appears in the Action Items area of MyCCOF, so you can monitor the status of these items and your submissions online.
3. Clear Due Dates: When a response is required, due dates are located in three places. This helps you respond promptly and avoid adverse actions for non-response.
4. More Direct Action Items: Each paragraph begins with the requested action stated plainly in bold. This bold item clearly identifies the specific action CCOF requires to verify compliance and eases the ability of clients to respond.
CCOF will use three clear sections:
a. Immediate Action Items, typically due within 30 days
b. Reminders, which require review but no response
c. Global Market Access (GMA) Summary, which outlines information needed to achieve or maintain international standards certification
5. Simple NOP Citations: CCOF has simplified legal and regulatory jargon to increase readability. NOP citations are included below each Action Item for reference. RSRs and CCOF staff are available to provide additional clarification.
6. Operation Identification: Every page includes your operation name and code. If you return a page to CCOF, we will be able to identify your response quickly and easily.
7. Enclosures: All enclosed items are listed at the bottom of the first page.
8. Flyers: New standard flyers such as "Certification Tips," "MyCCOF," and "Cost Share" are enclosed with letters. These flyers provide you with access to resources and important information in clear formats with less to read in the letter itself.
9. Resources: All letters include links to Organic System Plan (OSP) documents and the NOP regulations to ensure you can find these useful tools on the CCOF website.

View these numbered features on a sample CCOF letter.

Please give us your feedback as you receive these new letter formats so we can continue to improve them. Contact April Crittenden at april@ccof.org.

Inspection Scheduling Basics
CCOF performs about 2,800 inspections per year! That's about 11 inspections per workday. Completing these inspections effectively is crucial to maintaining CCOF's accreditation and ensuring the value of your certification.

When Can I Expect My Annual Inspection?
Every CCOF client must be inspected at least once during the calendar year. Your annual inspection can occur at any time of year and may be only five or six months after the previous inspection. CCOF understands the seasonal changes in workload and income inherent to many types of agriculture and food production. However, as a regulatory agency, CCOF must be able to inspect a certified operation at any time. Seeing different activities at various times of the year helps us provide meaningful certification oversight.

If costs are an issue, CCOF can implement payment plans or delay payment for inspections that happen during lean times of the year. Clients may contact CCOF's Accounting Department to request consideration of one of these options. CCOF can allow some flexibility in scheduling but we generally cannot recognize entire seasons or other broad swaths of time where inspections are not possible. Heavy production season is often an important time for CCOF inspectors to observe operations handling organic products.

Role of RSRs
Regional Service Representatives (RSRs) are the organizational hubs of the inspection process; they assign and track all inspections in their region(s). Whenever possible, RSRs assign inspection groupings based on shared locality of the clients and they often assist inspectors in choosing the best order or route to maximize travel efficiency, passing on the savings to our clients. In other cases, RSRs assign single inspections to meet client needs, meet CCOF goals, address complaints, or respond to other issues.

Role of Inspectors
CCOF employs a team of over 80 regionally-based inspectors. Inspectors are assigned groups of inspections that must be completed by a specific due date. Inspectors are required to maximize travel efficiency and minimize travel expenses. In order to realize this, your communication and cooperation in scheduling is critical.

Your Role
Please contact your RSR as early as possible about any scheduling needs such as impending harvest dates on new parcels, new facilities that must be inspected prior to use, planned absences of three weeks or more, or anything else that might affect your availability.

Please reply promptly to your assigned inspector when they attempt to schedule your inspection. They are frequently trying to contact and balance the needs of many clients at once. To control inspection costs, inspectors schedule with multiple operations on any given trip. The sooner you communicate your scheduling needs to your inspector, the more flexibility the inspector will have to meet those needs. CCOF inspectors will attempt to contact a client at least three times before returning the assignment to CCOF. Failure to respond to the inspector or to agree on a date for your inspection can result in a Notice of Noncompliance and further adverse action.

CCOF's system of scheduling annual inspections using RSRs and regionally-based inspectors is designed to keep scheduling and travel costs as low as possible for our clients. RSRs and inspectors try to recognize legitimate scheduling concerns of certified operations. CCOF is not able to honor all scheduling requests or personal preferences of our clients. However, by communicating with RSRs and inspectors as early and clearly as possible, you can help us meet your scheduling needs and keep inspection costs manageable.

National Organic Program Releases Handbook for 2011
The National Organic Program (NOP) recently released the 2011 edition of the NOP Program Handbook. This manual includes instructions and guidance for certifiers and organic operations regarding implementation of the NOP. The Program Handbook is an important resource for certifiers and certified operations.

Information Disclosure Instructions
The current manual includes instructions for disclosure of information concerning operations certified under the NOP. These important instructions clarify that formal noncompliance and adverse action (proposed suspension or revocation) notices are subject to Freedom of Information Act (FOIA) requests. This means that all notices that CCOF copies to the USDA NOP may be made public via FOIA processes. The NOP also recommends that certifiers implement full disclosure regarding these notices, except for confidential business information.

We are reviewing options regarding implementation of this guidance. CCOF was founded on and holds among its values the concept of transparency; therefore we recognize the importance of these instructions and believe that there is inherent value in transparency which will protect the organic marketplace and strengthen organic integrity. However, we are concerned about our administrative capacity and legal resources to redact letters and thoroughly protect clients' confidential business information. CCOF is considering a process where formal requests for information regarding noncompliance and adverse action may be made to CCOF. The requestor would likely have to pay a small fee to cover CCOF costs and to discourage frivolous requests. CCOF would then disclose the presence of any noncompliances or adverse action as well as the NOP section numbers cited to both the requestor and the subject client at the same time. Parties wishing to review the actual letters would be required to file a FOIA request at the federal level. We believe that this process respects the intent of the NOP's instructions without increasing costs, risking breaches of confidentiality, or exceeding CCOF's current organizational capacity.

New RSR for Pacific Southwest and Kern Regions
CCOF is pleased to announce that inspector Laura Murray assumed the Regional Service Representative (RSR) role for both the Pacific Southwest and Kern inspection regions, effective March 4, 2011. RSRs assign CCOF inspections and provide an important service interface between CCOF and clients to help clients understand CCOF requests, meet deadlines, and navigate CCOF service offerings. Laura's responsibilities include managing farm inspections in Arizona, Southern California from Los Angeles to San Diego, the desert regions in Southeast California, and Kern County. Laura will continue to perform CCOF inspections from her Vista, CA location while providing improved regional representation to these areas. Contact Laura Murray at (760) 630-1799 or at lmurray@ccof.org.

MyCCOF Revolutionizes Online Services
We are pleased to announce the full client-wide release of CCOF's new online certification management portal, MyCCOF. This additional service is unique to CCOF and free to our clients. Clients may use MyCCOF to monitor their certification and renewals, get key documents, and track the inspection and certification process. You can also monitor your account status and submit payments. To learn more visit www.ccof.org/myccof.

During the coming months and years, CCOF will expand this service to provide more features and benefits for CCOF members. Today, clients can use MyCCOF to:

• Download copies of your most recent certificate and client profile.
• Track inspections throughout the process and find your inspector's contact information.
• Monitor every operation you are associated with. Perfect for consultants, managers, and partnerships!
• Monitor contacts, facilities, private label brand owners, and other links to your operation.
• Download copies of recent letters from CCOF.
• Monitor the status of Action Items such as Requests for Information, Notices of Noncompliance, and submissions from you to CCOF.
• Track the payment status of invoices and easily pay your bills online.
• Track program enrollment and renewal status.
• View promotional operation information stored by CCOF such as sales types, apprenticeship offerings, and company statements.

New Canadian Export Requirements
In early November 2010, the National Organic Program (NOP) clarified that under the U.S.- Canada Organic Equivalence Arrangement all products exported to Canada should be accompanied by documentation that contains the following statement:

"Certified in compliance with the terms of the US-Canada Organic Equivalency Arrangement".

This statement may appear on organic certificates, bills of lading, transaction certificates, purchase orders, or other "affirmative attestation." While this statement may be applied by the seller, it may only be used for product that fully complies with the equivalency arrangement.

CCOF ensured that this statement was included on the Global Market Access (GMA) certificate for all clients who met the terms of the equivalency arranged in September 2010; it will appear on all certificates going forward. The CCOF GMA certificate may be used to accompany shipments of products that meet the agreement. CCOF strongly recommends enrollment in the GMA program to all operators who ship products to Canada or who produce products that may ultimately be shipped to Canada by someone else.

The NOP also clarified that in order to comply with the equivalency arrangement:

• All products, not just raw produce, must be verified to have been produced without the use of Chilean nitrate. CCOF will require that clients with processed goods currently approved for Canada use in 2011 to secure documentation confirming that all ingredients comply with this requirement. This may be in the form of affidavits or certificates of compliance from certifiers. All new products seeking equivalency approval must demonstrate compliance with the arrangement prior to receiving approval. CCOF will concentrate its efforts on identifying specific crops that may be grown with Chilean nitrate and may not require substantial documentation for ingredients that do not pose a risk.
• Hydroponic and aeroponic production may not be sold as organic in Canada.
• Animal products exported to Canada must be produced in compliance with the stocking densities in the Canadian organic standards. CCOF will verify this during upcoming inspections for operations requesting Canadian export verification.

The Canadian Organic Office has stated that at the current time the organic standards are in a "soft enforcement" stage. As these requirements differ slightly from the previous "produce only" implementation, CCOF operations will be allowed appropriate time to demonstrate compliance. If CCOF or CCOF operations have knowledge that particular products or ingredients do not comply with any of the terms of the equivalency arrangement (such as the use of Chilean nitrate), these items will not be granted equivalency status and must not be represented or sold as organic in Canada.

CCOF will be modifying Manual III, inspection documents, affidavits, and various other information resources in the near future to assist clients with compliance. Read the NOP's announcement by visiting www.ams.usda.gov/nop and viewing "International Agreements" followed by "Equivalence Agreements."

Inspection Changes for 2011
Beginning in 2011, CCOF inspectors will no longer provide a copy of their inspection reports directly to clients. Instead, all inspection reports and associated photos will be available online to all clients via MyCCOF. CCOF clients may also receive a hard copy of their report by contacting their Regional Service Representative (RSR). Your RSR is identified at the bottom of all CCOF certification correspondence, and a complete list of CCOF RSRs is available at www.ccof.org/rsr.php.

CCOF Develops Helpful Post-Inspection Tools
Two new documents have been created to help CCOF clients understand the certification process.

What to Expect After Your Inspection: Clarifies the inspector's role and what clients should expect as potential outcomes following the inspection. This helpful document is provided to all clients by their inspector.

Certification Tips: Provides important reminders for both growers and processors regarding the most common certification problems and mistakes. You will receive this sheet when you complete your annual renewal.

Copies of both documents are available at CCOF's Certification Assistance page located at www.ccof.org/certificationassistance.php. This page also includes a variety of helpful record keeping forms and other key resources.

CCOF Releases Revised Certification Manual
CCOF has recently released a new version of Manual I, A Guide to CCOF Certification. This improved version includes several updates and clarifications regarding CCOF processes and procedures. The updated manual also includes key legal protections for CCOF and requires that CCOF clients involved in Adverse Action appeals and other legal proceedings, such as subpoena requests, pay CCOF legal and staff time costs. These changes are intended to protect CCOF and CCOF clients by ensuring that CCOF has the necessary resources to provide excellent service to all clients. Key sections that have been updated include:

• Definitions: Clarifications and standardization of terms between CCOF and the National Organic Program.
• 1.2.4 Private Label Entities: Clarification and updates to this section, removal of redundant section.
• 1.3 Overview of CCOF Certification Manuals: Clarification of availability of CCOF Manuals. Notification that CCOF reserves the right to modify these manuals at its discretion. Applicants and clients are required to meet the requirements in the most current Manuals.
• 1.3.1 Additional Resources: Clarification regarding OMRI Generic and Product Lists availability as additional resources, but not formal CCOF manuals.
• 2.2 Application Review and Cost Estimate: Updates reflecting current practices regarding Regional Service Representative (RSR) assignment and inspection process.
• 2.5.1 Continuation of Certification Procedure: Updates reflecting current renewal processes and post-inspection review outcomes.
• 2.5.2 Withdrawal of Certification: Clarification to allow formal, verbal certification withdrawal process.
• 2.7.1 & 2.7.1.1 Noncompliance and Correction of Noncompliance Procedures: Clarification of noncompliance process and reasons for issuing noncompliances, updated to reflect NOP requirements.
• 2.7.5.1 False Labeling and Misrepresentation of Organic Status: Title modified to include misrepresentation of organic status in addition to labels so that web and other representations are covered. Civil penalty notification updated to reflect current $11,000 fee level.
• 2.11 Indemnification: Requirement to indemnify CCOF against legal claims.
• 4.8.6 Fees for Other Services: Updates reflecting current billing rates for technical services such as subpoenas, documentation research, and other requests.
• 4.9 Complaint, Investigation and Adverse Action Fees: Requirement that CCOF clients are responsible for reimbursing CCOF for all costs incurred by CCOF as a result of adverse actions, investigations, and legal issues involving the applicant or client. Ensures that costs associated with appeals and meditations in which CCOF prevails are the responsibility of the operator. These measures will ensure that CCOF clients in good standing are not forced to pay for the significant time and expense associated with appeals and subsequent formal administrative proceedings at the State or Federal level.

Renewals: Still Due
As reported in the last issue of Certified Organic and on 10/27/10, CCOF annual certification renewals are due January 1, 2011. If you have not already paid your annual fees and submitted your renewal contract, you must do so immediately. Operations that do not complete BOTH of these steps by February 15, 2011 risk receiving a Notice of Noncompliance and $75 fee. Visit www.ccof.org/renewal.php and www.ccof.org/payment.php to complete this process online today.

Renewals Are Coming! Critical Deadlines for Maintaining Your Certification
To remain certified with CCOF every operation must submit an annual certification contract and pay their certification fees. In early November CCOF will mail renewals and annual invoices to all operations. To complete the renewal process and remain certified with CCOF, you MUST:

• Complete your renewal contract AND
• Pay your annual fees

Please complete your renewal in a timely manner. Help CCOF serve you and other operations efficiently and avoid unnecessary costs by completing your contract and submitting payment by January 1, 2011. If you would like to establish a payment plan, please contact CCOF accounting using the contact information listed on the invoice. Completing your renewal on time allows CCOF to ensure timely inspections and to group inspections so they are as cost effective as possible. If you have questions, please contact CCOF.

COMPLETE YOUR RENEWAL ONLINE. Renewals may be submitted online by visiting www.ccof.org/payment.php. All CCOF bills may be paid online by visiting www.ccof.org/payment.php.

Critical upcoming renewal deadlines:

November 1, 2010: Renewals mailed

January 1, 2011: All renewals and annual payments due.

February 15, 2011: A Notice of Noncompliance and a $75 late fee will be issued to all operations that have failed to complete the renewal process. This is also the last day to withdraw from CCOF certification without accruing certification fees in 2011.

March 15, 2011: A Notice of Proposed Suspension and an additional $75 late fee will be issued to all operations that have failed to complete the renewal process.

April 15, 2011: All operations that have failed to complete the renewal process will have their certification suspended. If your certification is suspended and you wish to be certified organic in the future, your certification must be reinstated by the NOP after a costly and lengthy process.

FAQ: What if I pay my bill but don’t complete the renewal contract or vice versa?

Many CCOF operations assume that if they pay their fees, they are not required to complete a renewal contract. Under the NOP standards a renewal contract is mandatory and failure to complete it will result in Suspension of Certification. Operations that only pay their fees or only complete their contract will force CCOF to issue a Notice of Noncompliance.

NOP Publishes Organic Program Handbook
The National Organic Program (NOP) published the first edition of the U.S. National Organic Program Handbook, a compilation of documents intended to guide organic operations and certifiers and aid in the consistent implementation of the NOP standards. Written as a set of best practices, the guide provides resources and attempts to answer important questions and compile past NOP policies, creating a clear system for program guidance in the future.

The first edition does not contain many new requirements that directly affect CCOF operations, but it does provide information about recordkeeping requirements, accreditation processes, and how the NOP addresses suspension reinstatement and appeals. The handbook clarifies that organic certificates may not contain an expiration date, but CCOF operations may see changes to CCOF certificates, such as an anniversary date indicating when the operation must update their organic system plan. The handbook also directs certifiers to report the results of complaint investigations to the NOP; the NOP will handle any compliance issues that result from the investigations.

We applaud the NOP’s clear effort to improve communication and consolidate past guidance into a single accessible location. In the future, CCOF expects the NOP to add new sections and to address specific issues regarding a wide range of subjects.

The guide can be viewed by visiting: www.ams.usda.gov/NOPProgramHandbook. Printed copies can be made available upon request to Standards Division, National Organic Program, 1400 Independence Ave., SW., Room 2646-S, Ag Stop 0268, Washington, D.C. 20250-0268; telephone: (202) 720-3252; fax: (202) 205-7808.

New CCOF LLC Management Committee Members
The CCOF Certification Services LLC Management Committee is appointed by the CCOF Inc Board of Directors to oversee CCOF’s certification operations. This group, composed of non-CCOF certified individuals represents the CCOF membership and ensures oversight of certification. On August 20, 2010 the CCOF Inc Board of Directors reappointed two existing members of the committee, Peggy Miars, and Karen Klonsky to one year terms. The board also appointed Brenda Book and Tom Chapman to three year terms. These staggered terms will ensure continuity on the committee while providing an opportunity for the existing committee members to seek reappointment at the conclusion of their term.

The two new members have extensive organic certification experience and will provide important perspectives on behalf of the board. Brenda Book has worked for many years in the Washington State Department of Agriculture’s (WSDA) organic program. She is well-versed in organic certification processes and management. Tom Chapman is employed by Numi Tea and also has organic certification and compliance management experience. These two new additions will fill a key role vacated by the recent resignation of Emily Brown Rosen upon her acceptance of a position with the National Organic Program.

California Organic Registration Requirements Follow Up

In the Spring 2010 issue of Certified Organic, CCOF reported on our ongoing work to reform the way California's State Organic Program (SOP) carries out its objectives. Since that issue was published, the National Organic Program (NOP) review of California's SOP has resulted in specific instruction from the NOP for all California certified organic operations to obtain their California registration prior to becoming or remaining certified. CCOF will ensure operations meet this requirement during the certification process effective June 1, 2010.

We continue to work on California legislation including AB 2612, which will allow for changes in the California organic registration forms to streamline our members' registration process, and proposed regulations promulgated by the California Department of Food and Agriculture, which will articulate the Department's authority over organic food production in California, and align the State's program with the NOP.

EU Commission Issues CCOF a Control Body ID Number

The European Union (EU) Commission has issued CCOF the "control body" (certifier) identification number US-BIO-660 under a list of certifiers who have been granted import licenses. This identification number allows CCOF certified producers to produce packaged retail products and utilize the new EU logo, as long as their products have been reviewed to EU standards through CCOF's Global Market Access (GMA) program and have received an import license approval. The identification number is required as soon as possible on products shipped to the EU. CCOF sees this as an important step forward for CCOF and CCOF producers who export to the EU. As CCOF's EU equivalency application is reviewed by the EU Commission, CCOF may be issued a different number at a later date. Over the coming months CCOF expects to see changes in the EU import system and to gain approval as an equivalent certifier. While this will not eliminate export documents for each shipment, it will remove the requirement to seek prior approval from EU authorities through the import license process. While the US and EU continue to discuss equivalency in order to simplify organic standards issues, CCOF will remain engaged in this process to benefit our certified members.

CCOF will be producing new EU labeling guidelines in Manual Three in the near future. Under those guidelines, CCOF exporters will be required to utilize CCOF's control number on most packages.

For labels approved by CCOF prior to receipt of our control number, the permitted use-ups are as follows:

• Any products packed into a label prior to July 1, 2010 can be sold until product inventory is exhausted

• Certified operations may continue to pack products into the previously approved labels until existing packaging stock in inventory is exhausted or through July 1, 2012 (whichever comes first)

CCOF will allow clients to use up old labels in accordance with these guidelines. For all new labels (retail and wholesale) destined for the EU market, CCOF's control number should be used. Use of the new EU organic seal is optional on imported products. More information on EU labeling.

Important Update: Certificates Now Sent After Inspection Review

Beginning June 1, 2010 CCOF will provide an updated Organic Certificate and Client Profile after the review of annual inspections. Operations found to be in continued compliance with the NOP regulations will be issued new certificates with their annual inspection review letter. If CCOF requests clarifications or identifies noncompliances, updated organic certificates will be provided after clients completely address any pending issues, noncompliances, or requests for information.

CCOF will no longer provide a new certificate when the annual renewal is received, (although an annual renewal contract and payment will still be required at the beginning of the year). CCOF has made this change to address a number of issues and to ensure both timely service from CCOF and prompt responses to CCOF post-inspection requests. This system matches the expectations of the National Organic Program more closely and is more intuitive to CCOF operations. In the interim, existing CCOF certificates do not have expiration dates and are valid unless surrendered, suspended, or revoked.

CCOF Implements Fee Changes for Inspections and Additional Acreage

Inspection Fees
To ensure that CCOF is able to continue providing high quality inspection services over time, CCOF is increasing inspection fees for the first time in five years. Effective August 1, 2010, CCOF inspections will cost $60 per hour of preparation, inspection time, and report writing (9% increase) and $42.50 for travel time (3% increase). Don't forget that operations within the United States are eligible for cost-share funds from the USDA to help you cover the costs of certification, including inspection costs. You may apply for reimbursement of 75% of your organic certification costs, up to $750 per year. Please visit CCOF's cost share page for information about how to apply.

While fee increases are never desirable, inspector wages, taxes, training, and other costs to CCOF for inspection have increased. CCOF also continues to bear the increasing costs of inspections linked to other areas of compliance; unannounced inspections, farmers' market visits, and residue testing. We have chosen to increase inspection fees instead of annual certification fees since these costs are directly proportional to the time spent on site. CCOF certified operations can minimize inspection costs by ensuring they are prepared for each inspection by submitting relevant updates to CCOF in advance, reviewing the inspector's pre-inspection letter carefully, and gathering important documents. CCOF will continue to minimize travel and associated costs in every way possible.

Additional Acreage Fees

Structure Changes: Do NOT Wait to Submit Additional Acreage at Inspection

Effective Oct 1, 2010 CCOF is increasing the fee for applications to add additional acreage to certified operations that are submitted to CCOF less than 90 days before harvest, (or date certification is needed), or are submitted at inspection. In an effort to serve all our clients well, CCOF must constantly manage competing priorities. Additional acreage submitted shortly before harvest or at inspections creates significantly more work for CCOF's staff and inspectors, which limits our ability to serve clients who have submitted their requests in a timelier manner. To encourage requests for adding acreage to be submitted at least 90 days prior to harvest and to allow us to more effectively manage our resources, CCOF is implementing the following tiered fee structure:

Application to Add Acreage Submitted:

• More Than 90 days Prior to Harvest/Use: $50 (no change)

• Less Than 90 Days Prior to Harvest/Use: $150

• Submitted At Inspection: $225 (paperwork must be completed and available to inspector)

Where possible or preferable to minimize costs to you, CCOF will continue to combine add acreage and annual inspections provided sufficient notification has been given. Applications to add acreage are prioritized to meet harvest deadlines whenever possible, however, operations who need immediate services or increased prioritization are strongly advised to utilize CCOF's expedited add acreage service option.

CCOF Withdrawal from IFOAM Program
As discussed in the Spring issue of CCOF's magazine and subsequent Spring Certification E-Newsletter, we have decided that it's in the best long-term interests of CCOF's certified clients to no longer perform IFOAM certification within our larger Global Market Access (GMA) program effective January 1, 2010. Certification to IFOAM standards is not required for access to any foreign market. Through our GMA program, CCOF will continue to offer EU Equivalency verification for European market access and will continue to provide verification to other international standards, including those needed for access to Japan, Taiwan and Canada.

This change will provide CCOF with additional resources to address other pressing international trade issues, while reducing inspection and compliance costs and time for you. If your products are shipped to the EU, you should only be required to maintain EU equivalency certification with CCOF. If you have attained this, you can find it on your current GMA certificate or CCOF client profile.

The vast majority of CCOF clients with IFOAM certification also maintain EU equivalency certification, which should meet the needs of foreign buyers. If you have buyers or foreign certifiers who have expressed a preference for IFOAM certification, please notify us so that we can help you communicate with them. If your buyer is a CCOF client, they will no longer be required by CCOF to verify IFOAM from their suppliers. Therefore, this should not be an issue. More information about CCOF's GMA program can be found at www.ccof.org/international.php. For more information about CCOF's EU certifications, visit www.ccof.org/eu.php.

Read the article "We Need to Hear From You: Should CCOF Continue to Offer IFOAM Certification?" from the Spring issue of Certified Organic.

If you have questions or concerns, please email us at export@ccof.org.

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International Standards Updates

Korean Organic Standards Deadline Looms
As reported in past issues, the Korean Organic Standards are scheduled to be implemented on January 1, 2010. As of this writing, the Korean government has been firm that after this date products sold as organic in Korea must be produced and certified to Korean standards and certified by the Ministry for Food, Agriculture, Forestry and Fisheries (MIFAFF) accredited certifier. The accreditation and certification requirements are problematic for US certifiers, and it appears unlikely that all ingredients can be re-certified to this new standard.

CCOF, along with many other US organic certifiers, several US Senators, the Organic Trade Association, a variety of traders, the Foreign Agricultural Service and the National Organic Program have been working with Korean trade representatives to address this issue. Korea is seeking equivalency with Australia, and US officials are pursuing a similar arrangement for US organic goods. It remains to be seen what will happen when the new standard goes into effect; however, Korean officials have indicated that any product in Korea or shipped prior to January 1, 2010 will be allowed to be sold as organic until the product's expiration date.

CCOF is exploring options to work with foreign certifiers to provide Korean Organic Standards certification in the US for CCOF clients. This is not a preferable option and may only be viable for those companies with relatively few suppliers who are all CCOF-certified or certified to Korean standards independently. As new standards develop worldwide we sincerely hope to see more equivalency agreements, such as the recent agreement between the US and Canada. If you have specific concerns, work with the Korean market, or have additional questions, please contact export@ccof.org for more information. CCOF depends on feedback from clients to effectively advocate for and meet your needs.

NEW EU Standards in Place - CCOF Applies for Direct Equivalency
Under the new European Union Organic Standards 834/2007 (formerly 2092/91) the EU has revised their regulations and created new options for foreign certifiers and companies. CCOF incorporated the updates in our recent revisions to CCOF Manual III and Global Market Access Program applications. The required practices remain essentially the same, but the standards and citations referenced have changed. There are very few, if any, new requirements for CCOF farmers and processors.

In the current system, certifiers verify that organic operations met EU requirements but importers are required to seek import license derogations for each US-based exporter. This slows down the process, requires significant paperwork and is subject to differing interpretations of various EU member states and certifiers. Now, the EU is accepting applications from certifiers to be recognized as equivalent on a certifier-by-certifier basis. Once implemented, import licenses will no longer be required. CCOF has worked hard during 2009 to prepare our application and will submit it by the October 31, 2009 deadline. We expect to receive a response in 2010, and the first list of recognized certifiers should be published in early 2011. Once listed, CCOF certified companies deemed EU Equivalent will have easier access to the EU and will not require mountains of import license paperwork. Additionally, they will be allowed to produce organic retail products for the EU market and will be able to use an EU organic seal on labels.

CCOF is grateful to the EU Commission for providing this option; we expect these changes to be significant and are working hard to make this a reality. Throughout the process, CCOF will strive to eliminate as many standards differences as possible so that both you and CCOF can concentrate increasingly on the most substantive issues in certification and organic production and less on minor standards or small differences in materials allowances. CCOF clients can expect changes and updates as this process unfolds and can rest assured that CCOF is doing everything we can to simplify organic exports.

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CCOF Fee Changes
Effective June 1, 2009, CCOF made certification fee changes regarding both our Global Market Access program and certification fees for facilities. These changes are meant to ensure the highest possible level of service to our members, while also simplifying CCOF’s billing processes. The changes affect approximately 50% of CCOF-certified members, the vast majority of which will see no effect until the 2010 renewal billing cycle. Renewal payments are due January 1, and are billed in October. We sincerely regret the need to increase fees at any time; however, the need to ensure an effective, professional service demands that CCOF find ways to meet the costs incurred. Rather than a blanket raise of all certification fees, these fee increases concentrate on the specific areas of CCOF’s program that require the most time, expertise and staff effort.

Global Market Access Program
The fees for CCOF’s international program, Global Market Access, will increase from $150 to $250 annually. As the complexities of EU compliance, Canadian organic standards, Taiwan, IFOAM and additional applications for equivalency have grown, CCOF must ensure that we possess the necessary resources to address these and any future issues that may emerge. Look for new documents addressing Taiwanese exports and Canadian certification and/or equivalency as well as updates on a variety of emerging standards and programs, such as Bio-Suisse (Swiss export), in the near future.

Complexity and Facility Fee Changes
Previously, certified operations incurred $100 “complexity” fees for operations certified to both the grower and handling standards. In the past, determining how and when these fees should be applied to a specific operation resulted in a number of inequities that were difficult to explain and that created numerous internal billing problems. At the same time, operations were also billed $100 for each additional facility inspected by CCOF on behalf of the client. This includes packing sheds, additional co-packers, milk barns, coolers and other operations inspected by CCOF but not certified as stand-alone entities.

CCOF aims to simplify the billing process and ensure that all clients are billed consistently and fairly by eliminating the complexity fee and raising the facility fee to $200 per facility. This applies to all facilities performing intermediate post-harvest activities and more complex processing that requires handler Organic System Plans (OSPs) under the CCOF program and accreditation. CCOF will actively review operations during the certification process to determine whether an operation still requires their current OSP sections or, alternatively, has the ability to access a simpler (fewer forms), less expensive option whenever possible. For details on the changes made in the language of CCOF Manual 1, see below.

In the last year, CCOF developed a G6.4 Simple Post Harvesting OSP section to reduce both the expense and paperwork burden felt by CCOF’s small growers who perform minimal periodic handling on their own products. Operations utilizing the G6.4 will not be billed the facility fee. If you are encouraged to complete the short G6.4 OSP form, we strongly suggest you to do so as it eliminates many pages of papers and reduces your overall costs.

Changes to CCOF Manual 1 are as follows:
Note: The following paragraphs repeat in section 4.9.2 to address when these same fees are charged mid-year. The changes would also apply there.

4.8.1 CCOF CS Global Market Access Fee (changes noted)
The annual fee to be enrolled in the CCOF CS Global Market Access program is $250. Clients who choose to be certified according to CCOF CS Global Market Access must pay this fee in addition to all other fees. The CCOF CS Global Market Access Fee must be paid at the time of continuation of certification or a late fee of $50.00 may be added for a combined total of $300.

4.8.2 Additional Production Facilities
Clients who use production facilities that are not independently certified will be billed annually $200 per facility or production type. CCOF CS applies this fee to any client who seeks certification for additional co-packers, post-harvest handling facilities or production operations. Examples include (but are not limited to) certification of:

1). A winery in conjunction with a vineyard;
2). A separate production plant beyond a processor’s primary facility that performs custom processing;
3). A huller, packer, sorting line or cooler in conjunction with a farm;
4). A slaughterhouse or cut and wrap operation in conjunction with a livestock operation;
5). Parcels or livestock in conjunction with a processing plant, milk barn or handling operation.

The following will be deleted from Manual 1:
4.8.2.a Additional Certification Scope
CCOF CS charges a $100 “complexity fee” for each additional production or certification scope added to an operation already entered into the certification program. Operations that are both a grower and handler will be assessed this fee. Livestock operations are not billed this fee unless they include a processing facility or other certification scope beyond crop/pasture production.

The Certification Services Director may reduce the fee for additional production for operations that sell less than $20,000 of product per year, or for operations that add a very small number of animals to an existing farm.

Regional Service Representative (RSR) Changes
CCOF sadly reports that Lois Christie, long-time CCOF Regional Service Representative for the At Large (AL) Service Region and organic inspector, resigned from her RSR position after many years of service. Over the years, Lois has been instrumental in CCOF’s success and growth. With a special passion for Latin America, Lois nurtured the needs of many operations in Mexico and continuously acts as a stalwart ally for the needs of growers. She will now apply her energies towards the success of her consulting company, The Organic Consulting Firm. Fortunately, Lois will continue to perform inspections for CCOF.

CCOF operations currently served by the AL Service Region will move to new RSRs and will receive letters introducing them to their new representative in the near future. CCOF takes this opportunity to slightly modify our service regions. The changes are as follows:

• Arizona operations will now be served tandem with the Southern California desert region
• Latin America will branch off as a distinct service region
• Southern Oregon and Northwestern Nevada will be served alongside Northern California operations
• The Oregon coast will merge with operations in Humboldt and Trinity counties
• Farms and livestock operations in the greater US and Canada outside of CA and AZ will be served in tandem with CCOF’s national group of processors.

These changes allow CCOF to group neighboring operations and inspections more efficiently and will not effect CCOF client’s service, operation code, trade association chapter affiliation or any other aspect of the certification process. If you have any questions regarding who your RSR is, please visit www.ccof.org/rsr.php.

US/Canadian Organic Equivalency Agreement Reached 6/26/09
On June 18, 2009 the US and Canada signed a landmark organic standards equivlenecy agreement. Visit www.ccof.org/canada.php for more information, labeling guidance, and more.

We Need to Hear From You: Should CCOF Continue to Offer IFOAM Certification?
CCOF’s Global Market Access (GMA) program is often thought of as the “IFOAM program”. In actuality, CCOF’s international program started with IFOAM (International Federation of Organic Agriculture Movements) but has, over the years, evolved considerably to where IFOAM is merely a part of a much larger international program. The CCOF GMA program now incorporates certification to European Union (EU) standards, Japanese Export, Canadian Standards and Quebec Organic Labeling issues. IFOAM certification and its associated accreditation has lost relevance for CCOF members over the years as these other international standards have taken precedence. Now, we find ourselves faced with a question as to whether the original IFOAM program is still cost-effective and relevant to all parties involved.
European regulators require documentation regarding EU standards but typically do not request IFOAM certification from CCOF clients in order to allow their products into EU nations. CCOF has worked hard to ensure that the EU’s EEC standard is clearly shown in our GMA documents, further reducing the relevance of IFOAM compliance.
At this time, CCOF is not aware of a single nation, and very few buyers, that require IFOAM certification to accept organic products. As new national regulations develop, CCOF continually finds itself thinly stretched to provide many different organic certifications at once. Further, we acknowledge the difficulty that organic producers face when they must continually meet these different standards. Therefore, we believe that if a standard is not actively required for trade, CCOF clients should not be asked to jump through yet more hoops to meet it.
We have observed that IFOAM certification increasingly facilitates trade between the EU and developing world countries that lack national regulations. In this circumstance, IFOAM functions as the global sourcing standard of the EU; however, this does not necessarily provide a compelling benefit to CCOF clients. In addition, IFOAM accreditation is relatively costly and time consuming, while the standard has not evolved significantly to keep up with changes in the US and EU organic standards. As a result, CCOF continually finds itself with shifting certification and accreditation requirements, which forces changes on CCOF clients just as they are becoming familiar with previous requirements. Our concentration is then forced away from service and into addressing IFOAM’s concerns. Therefore, CCOF is actively considering elimination of IFOAM certification as a component in CCOF’s GMA program.
This is not expected to result in any loss of market access to CCOF clients and should result in better service and increased capacity to address new national regulations as they develop elsewhere in the world. CCOF needs to hear from you regarding whether your buyers, or their certifiers, specifically request or value IFOAM certification of your products and IFOAM accreditation of CCOF. Please email your comments and concerns to jake@ccof.org and indicate the specific buyers, certifiers or nations you are concerned about. We hope to make this decision in 2009 and need your input if you have concerns or support the decision.

NOP Publishes Proposed Pasture Standards (1/29/09)
In October, 2008, the National Organic Program (NOP) published a proposal to change the rules regarding access to pasture for organic livestock. CCOF worked diligently during the 60 day comment period with many other groups, including members, certifiers, processors, trade associations and farmer collectives, to craft a thorough, focused and clearly written response. CCOF's comments aim to ensure a level playing field that does not unduly burden the small farmer with complex record keeping while also providing certifiers with effective mechanisms for identifying and addressing shortcomings among so called "bad actors". We believe that any likely final rule should result in standards that support the larger goals of the organic community. The full text of the proposed regulations, including background and discussion, and CCOF's response to the proposed regulations can be found at www.ccof.org/nop.php.

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CCOF Achieves Canadian Accreditation (1/29/09)
A new set of organic standards regulating product sold as "organic" in Canada, is set to go into effect June 30, 2009. In response, CCOF has proactively introduced certification to the Canadian Organic Standards as part of our existing Global Market Access (GMA) program. CCOF has been informed that we have successfully passed our Canadian accreditation audit and will continue to proactively offer organic certification to the current version of the Canadian standards. New GMA and Canada review request information documents have been mailed to all CCOF clients. These forms allow businesses exporting products to Canada to immediately request review and/or inspection to the proposed new Canadian standards by CCOF in advance of next year's implementation date. CCOF has developed this voluntary program to guarantee the needs of CCOF clients are met. Between now and June, 2009 it is likely standards for the Canadian program will be under continual revision. CCOF will work hard to provide you with the most current and accurate information available regarding any revised Canadian standards. We encourage all of our clients whose products are directly or indirectly exported to Canada to stay informed by checking for updates at www.ccof.org/canada.php.

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Certification Expanding Staff and Resources (1/29/09)
In response to ongoing growth trends and needs of our clients, CCOF is actively reorganizing some certification positions and bringing on new personnel into our Handler Certification department. These new positions will give greater attention to export and international issues, while also expanding the overall capacity of the certification department. On the inspector front, CCOF is expanding our inspector pool and hosted a private CCOF processing and retail inspector training in December. These efforts, in addition to significant database investments, are intended to ensure that CCOF clients receive timely and cost effective service throughout certification. Please contact us with suggestions, concerns, and comments regarding how CCOF certification can continue to improve.

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CCIA Organic Certifier Accreditation Revocation:
Who is affected and CCOF Certification Transfer Program.
Please be aware that the National Organic Program recently revoked the accreditation of the California Crop Improvement Association (CCIA). While representing a hardship for a number of CCIA certified operations, this clearly demonstrates the intention of the National Organic Program to maintain a strong organic certification and accreditation program.

Under the revocation CCIA certified companies and products must transfer their certification to another certification as soon as possible. More detailed information regarding the CCIA revocation.

CCIA certified operations are encouraged to transfer their organic certification to CCOF immediately to ensure their ongoing ability to market organic products. CCOF has developed a CCIA Accreditation Revocation Certification Transfer Program. Please contact CCOF at marketing@ccof.org.

To assist our existing members, CCOF is providing the following guidance for dealing with CCIA certified companies and products:

• The National Organic Program has not given a specific timeline for CCIA certified operations to transfer their certification to another certifier. CCIA certifications issues previously remain valid until they are withdrawn, suspended, or revoked. It is reasonable to assume that all CCIA certified suppliers are expected to be taking direct action to seek certification elsewhere. Typically, 30 to 60 days is the maximum reasonable time for an operation to transfer their certification successfully. Therefore, Jan. 24, 2009, 60 days from the NOP notice of revocation to CCIA, should be the latest date that you accept CCIA certified organic products as organic without authorization from CCOF or the National Organic Program.
• CCOF clients utilizing CCIA certified ingredients or co-packers must receive new certification documentation from their suppliers or co-packers as soon as possible. Unless new certificates are provided by businesses formerly certified by CCIA in a reasonable time, incoming ingredients must not be recognized as organic. Co-packers formerly certified by CCIA should not be utilized after Jan. 24, 2009 without CCOF approval, for ingredients or products which will bear the CCOF name and/or seal.

Read the USDA National Organic Program Q&A document: QAs on CCIA Accreditation Revocation.
National Organic Program Notice of Revocation for CCIA. For more information regarding specific issues and non-compliances, read the National Organic Program accreditation notices to CCIA including: Appeal Dismissal Oct, 2008, Audit Report Nov, 2007, and Audit Report July, 2007.
For comparison read CCOF's excellent Audit report from August, 2007.

Renewal System Changing in January (10/15/2008)

CCOF will be changing to a January renewal system for our certified clients to make the annual cycle of renewal and inspection more efficient and consistent. Beginning mid-December, all CCOF clients will receive the Continuation of Certification renewal contract and annual bill at the same time.

Previously, CCOF managed three renewal periods: one in January, one in April and one in July. All clients, including those who previously renewed in April or July, will receive their renewal contract this December with an invoice for the 2009 annual fee, which will be prorated for the entire 2009 renewal and inspection season. Sending out the annual fee invoice at the end of the calendar year will provide clients with the option to pay their annual fee in either 2008 or 2009. Clients who were previously billed in April or July may be given additional time to pay the prorated annual fees, and we encourage anyone who is having difficulty with fee payments to contact us as soon as possible.

Once the annual renewal contract and fee have been received by CCOF, we will conduct the annual inspection during the calendar year, eliminating the confusion caused by having 2008 inspections conducted in calendar year 2009. Additionally, by reducing the renewal periods from three down to one, CCOF will be able to streamline workloads by processing renewals for the entire CCOF client base at once, which will allow us to provide you with more effective and efficient service during the rest of the year. If you have concerns or questions, please contact ccof@ccof.org.

Canada Certification Program Launched (10/15/2008)

A new set of organic standards regulating product sold as “organic” in Canada, is set to go into effect June 30, 2009. In response CCOF has proactively introduced certification to the Canadian Organic Standards as part of our existing Global Market Access (GMA) program. In order to keep our clients and other involved parties informed, CCOF has held conference calls to provide information about the proposed standards and certification requirements. New GMA and Canada review request information documents have also been mailed to all CCOF clients. These forms allow businesses exporting products to Canada to immediately request review and/or inspection to the proposed new Canadian standards by CCOF in advance of next year’s implementation date. While U.S./Canada equivalency may be achieved, or leeway for a transition period provided through implementation policies by Canada, CCOF has developed this voluntary program to guarantee the needs of CCOF clients are met. Between now and June, 2009 it is likely standards for the Canadian program will be under continual revision. CCOF will work hard to provide you with the most current and accurate information available. Click here for ongoing updates and information.

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Finished E-Forms and Online Renewal and Payment Options (7/30/2008)

CCOF is pleased to announce the completion of E-Form versions of CCOF’s entire Grower and Processor/Handler Organic System Plans. The documents are in a Microsoft Word format. The E-Forms allow clients to directly type their OSP and facilitates updates etc. CCOF hopes the E-Forms are easier for our clients and help save time. Download e-forms here.

If you would like a CD version of the new E-Forms, simply email ccof@ccof.org or call (831) 423-2263. In the future we hope to offer more electronic sections.

To make CCOF processes easier for clients, CCOF is also developing an online renewal and payment system as part of our overall strategy to move increasingly to online and electronic documentation. CCOF clients will now be able to submit their annual renewal online at www.ccof.org/renewal.php and pay annual fees and inspections online at www.ccof.org/payment.php.

In the future we hope to provide an ‘online only’ paperwork option for those operations that prefer it. CCOF’s July renewals in the Desert Valley region were the first to receive an online renewal email prior to receiving their paper contract. CCOF clients from earlier periods who have not renewed yet can access this option now to avoid non-compliance issues.

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California State Organic Program Report: Expansion of Spot Inspections (7/30/2008)

The California State Organic Program (SOP) has recently announced a plan to significantly increase their inspections and monitoring of organic operations in the state. The new 2008/2009 budget includes massive increases in payments to counties to implement organic spot inspections and for the State to perform pesticide residue tests. At a recent series of trainings and meetings, Ray Green, the SOP supervisor, indicated the State's intention to perform a series of "informational inspections" to "investigate the effective implementation of the National Organic Program (NOP)" in California.

Current plans call for ten SOP inspections of certified operations for each of the 21 certifiers operating in California. The State has outlined plans for doing as many as 700 organic inspections within the state, including of inspections of certifiers. The SOP intends to use the information gained from this expansion in inspection and monitoring to judge "consistency" among certifiers and to assess the need for additional training, enforcement and other efforts.

CCOF applauds any efforts to ensure consistent and quality implementation of organic standards throughout the state; however, we do have some concerns regarding this new SOP initiative. Firstly, it is unclear presently whether the State has the resources and authority to also visit out of state certifiers operating within California. CCOF certified operations and CCOF itself will undoubtedly be relatively highly involved in the proposed incremental inspections due to our dominance within the state, and we want to ensure all certifiers and their respective clients are treated equally and fairly. Secondly, we are concerned about conflicting interpretations between the SOP, NOP, CCOF and counties.

CCOF clients should be prepared for these visits and ready to provide copies of their CCOF paperwork if and when requested. CCOF clients can ensure they are protected by keeping CCOF materials approvals on hand and OSP documents and other paperwork readily available. Additionally, CCOF clients should clarify with inspectors their role, scope, and the context of each visit to identify if it is complaint-driven, a spot inspection, or more informational in nature. CCOF has developed a 'request for information' form that we will require county and other agents to complete should they require information about CCOF clients. This will clarify information requests along the above lines and force the county to address any specific concerns in writing.

CCOF sincerely hopes that these efforts and increased spending by the SOP will also lead to effective follow up on organic marketplace complaints and investigations, including farmer's market compliance issues and other problems.

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California Organic Products Advisory Committee (COPAC) Meeting (7/30/2008)
During the May 8 COPAC meeting the State Organic Program (SOP) was strongly encouraged to add a certifier seat to advise the program and more fully reflect the composition of the National Organic Standards Board, COPAC's sister board on the national stage. CCOF has supported this for several years and is pleased to see a newer composition of the board moving forward. Additionally, the SOP was strongly encouraged by members of the committee to utilize their existing authority under SOP regulations to investigate and address liquid fertilizer issues which continue to be an issue of contention. Read more on this subject in the Spring 2007 edition of "Certified Organic" magazine online.

COPAC members were also provided with an audio copy of a talk by Certification Services Director Jake Lewins at Eco Farm that addressed this issue.

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Canadian Organic Standards Update: CCOF Accredited for Canadian Organic Products Regulations(7/30/2008)

CCOF was recently one of only four US certifiers on a preliminary list of certifiers to be accredited under the soon-to-be implemented Canadian Organic Products Regulations (OPR). Under this accreditation, CCOF is actively developing our Canadian OPR certification program, which is likely to become a new part of our existing Global Market Access (GMA) program. Unfortunately, the Canada Organic Office has not completely finalized their standards or materials lists in key areas. Once these are completed or nearly completed, CCOF will provide them to you and begin verification of compliance to the Canadian OPR. All clients who send products directly or indirectly to Canada are strongly advised to enroll in CCOF's GMA program immediately. If you ship products to Canada and your suppliers are not enrolled in GMA, now is the time to encourage them to enroll and/or discuss with them their plans for ensuring they can demonstrate Canadian compliance.

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Japan Recognition Agreement (7/30/2008)
The USDA has recently announced a recognition agreement between the USDA and the Ministry of Agriculture Forestry and Fisheries (MAFF) in Japan. Under this recognition, MAFF will be able to directly accredit Japanese certifiers to certify within Japan to the USDA NOP standards. This is an important step forward between the USDA and MAFF and may lead to improved access of US organic products to Japan over time. USDA and MAFF continue to discuss equivalency and trade issues. Under current standards products destined for Japan must be certified to Japanese Standards (JAS) or be produced without 3 prohibited materials and shipped with a "TM-11" export document.

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New Website Lists Commercially Available Organic Minor Ingredients - www.606organic.com (7/30/2008)
This new site, managed by the Accredited Certifiers Association (ACA), provides an important resource for companies to list and find organic versions of minor ingredients that currently appear on the National List. Agricultural ingredients may only be used in non-organic form in products labeled organic if they are listed on 205.606 (the National List) AND are not commercially available. This site presents a way for companies that produce organic minor ingredients to promote their products, such as hops, and a viable resource for companies needing to do searches for commercial availability. CCOF will accept searches on www.606organic.com as part of a commercial availability sourcing plan.

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EU Allows Potassium Bicarbonate and Spinosad (05/14/08)

European Union (EU) regulators recently amended Annex II of the EU organic standard EEC 2092/91 to allow the use of Potassium Bicarbonate and Spinosad by organic farmers. Effective immediately, CCOF will grant EEC compliance and/or export documents under the Global Market Access Program for operations who use these materials. We expect this to positively affect the availability of EU compliant ingredients and ease pressures on a variety of CCOF organic growers.

However, please note that Potassium Bicarbonate remains prohibited for products destined for Japan under the MAFF/USDA export arrangement. In addition, CCOF is aware of potential opposition to by the Soil Association in the UK against to the use of Spinosad. It is unclear at this time if the Soil Association will allow certification of products grown using Spinosad under their SA Seal program. Products certified to EU standards by Soil Association or sold in the UK without Soil Association certification should be approved without issue by DEFRA.

Remember, to ensure compliance with NOP standards, all materials must be approved by CCOF and included on your OSP prior to use. Additional OSP forms (in pdf and eform formats) are available at www.ccof.org/osp.php and www.ccof.org/forms.php.

Background information:
CCOF has worked hard with US and European regulators, in addition to key clients to encourage the European recognition and acceptance of Potassium Bicarbonate (PB) as a key alternative for mildew control. Often sold under the trade name Kaligreen, PB is an important material that can reduce the use of sulfur in grape and berry production and is quite similar to baking soda. For more information read CCOF's Dossier on PB. As reported in the Spring 2007 issue of Certified Organic, CCOF and several clients in partnership with US Agricultural Marketing Service Administrator, Lloyd Day, worked to achieve recognition for Potassium Bicarbonate in the EU. We are pleased to see that our efforts have paid off in this important step to reducing standards differences between EU and US organic systems. We're grateful to the efforts of the USDA and Foreign Agricultural Service in this process.

CCOF recently reported that Spinosad was not allowed for products destined for the EU. While some questions remain regarding acceptance of products by the Soil Association in Britain, CCOF will now grant export approvals for EU bound products grown utilizing Spinosad- based brand name materials, such as Entrust®.

Other Annex II changes include allowances for Copper Octonate and ethylene for de-greening of citrus.

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Improvements for you: New operation update, sales types, and company statement during inspections
CCOF recently radically improved its systems for tracking client information and gathering updates during inspections. Since April 24, 2007, CCOF inspectors have been asking CCOF operations to review their operation information, phone numbers, contact numbers, and email addresses during all inspections. We've ensured that all contacts, phone numbers, and emails associated with your operation are listed and you are given the opportunity to make corrections. In addition to address and phone number changes, this is an opportunity to add new approved contacts to your operation and remove any who are no longer at the operation. Simply make any changes, sign the Client Inspection Update, and CCOF will make these changes as updates to your OSP.

Please review your information during each inspection and make any changes so we can communicate with you as effectively as possible and list your accurate information in our annual directory.

How Can We Improve Further?

CCOF Certification Services is constantly trying to improve our systems and the certification process. In the coming months and years, we'll concentrate our efforts more effectively on soil management, natural resources and substantive certification issues at the processing level. Our goal is to focus certification away from increasing paper records to substantive organic management issues at the farm and processing level. We're open to your ideas and comments. Please let us know where our focus should be directed, records that could be eliminated or areas we should focus on more effectively by emailing ccof@ccof.org. We will take these into consideration as we explore ways to improve the certification experience while ensuring that the highest level of organic integrity is maintained with CCOF organic certification.

Thank you for your input.

November 2007, NOSB Meeting Information
CCOF’s Certification Services Director, Jake Lewin, attended the November, 2007 NOSB meeting to represent CCOF and the needs of CCOF certified operations. Aquaculture was the subject of a day-long symposium and considerable public comment. In addition to several petitions and sunset items, the NOSB also addressed (1) inspection and certification of grower groups and other multi-site operations, (2) guidelines for the commercial availability of organic ingredients and seeds, and (3) definitions of materials on the National List.
Read the OMRI NOSB Meeting Report or the report of the Accredited Certifiers Association for more information.

CA State Organic Program Proposed Mediation and Appeals Procedure (7/21/07)
As a State Organic Program (SOP), the California Department of Food and Agriculture (CDFA) is the California state appeals body for certification denials, suspensions, and revocations. Unfortunately, as CCOF has discovered in the last year, the SOP has been unable to process appeals requests due to a lack of internal procedures to govern the process. CCOF Certification Services is pleased to see that CDFA has now published proposed appeals and mediation procedures. We expect the process to be in place in the near future and to have appeals of adverse certification actions processed more efficiently through the SOP.

In order to protect the integrity of organics, CCOF is sometimes required to initiate serious non-compliance, revocation, or suspension action against operators found to be in violation of the National Organic Program. However, due process rights, mediation opportunities, and the appeal process are important components of ensuring all parties are treated fairly. If CCOF issues non-compliance or other adverse action, you will be provided with your options for appeals and these new procedures should ensure the ability of the CDFA to participate fully in the process. For more information, visit the California State Organic Program or call (916) 445-2180.

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Expedited Certification Program Released (1/19/07)
Download Expedited Certification Enrollment Form
CCOF has unveiled an expedited organic certification program in response to the booming demand for organic certification. Clients seeking organic certification can now go through the same rigorous inspection and review criteria as the regular certification process in a fraction of the time.

The CCOF Expedited Certification Program was designed to meet the needs of operations capable of compliance that do not have sufficient time to undergo the certification process because of impending harvests, market releases or product launch deadlines. Fast-track applications receive top priority processing and are immediately assigned an inspector who is required to submit reports to CCOF within 48 hours of final inspection. CCOF's internal review and processing is guaranteed to be completed within 72 hours. In some cases the expedited certification process can be completed in as quickly as a week compared to the recommended 12 weeks prior to organic harvest using the regular certification method. Organic certification is not guaranteed since it depends upon inspector findings, compliance on site, and the quality of the application. Under no circumstances are USDA standards compromised.

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2007 Fee Changes (1/10/07)
CCOF continues to provide the most competitive and cost effective organic certification program possible. From time to time we are forced to raise fees in order to ensure continued service. Notably, in 2007 there will be no increase in small grower certification fees. However, due to the complexity and accreditation challenges associated with processors, livestock operations, and international standards there are small fee increases in these areas. An explanation of changes effective January 1, 2007 appears below. CCOF's current fee schedule.

We at CCOF raise certification costs only when necessary to ensure your access to qualified staff, timely service, and the high integrity certification you’ve come to expect. We thank you for your understanding.
Processors: CCOF’s two lowest processor certification fee categories will increase slightly to $550 (previously $475) and $600 (previously $550). This leaves CCOF processor fees highly competitive with other certifiers while ensuring adequate staff to address your needs.
Livestock Operations: The minimum annual certification fee for livestock operations with more than 10 animals will be $475 in 2007. CCOF takes livestock certification seriously and is constantly working to stay informed and participate in organic livestock issues at a state and national level. Because of the inherent complexity and work involved in all livestock certifications, CCOF is forced to implement this fee increase.
Global Market Access program: Enrollment in CCOF’s Global Market Access program will now be $150 to allow CCOF to address rapidly increasing accreditation costs. This will provide CCOF the resources to improve our program and continually seek improved international access to our members. As import regulations in the European Union, Canada and elsewhere evolve, CCOF is continually working to ensure our Global Market Access program ensures your success. As our accreditation and others costs have increased substantially, we are forced to raise the cost of this important service.

CCOF is working hard to improve access to European and other markets. For instance, CCOF is actively fighting for the ability of CCOF operators to utilize Potassium Bicarbonate in the production of crops destined for the EU. This could have a critical benefit for wine, raisin, berry and other producers. Similarly, European organic imports regulations are in transition. As European standards are updated, import recognitions may improve significantly. CCOF is working hard to stay abreast of developments and modify our Global Market Access program to ensure you benefit.

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Earlier Renewals in 2007 (1/10/07)
CCOF clients may receive their next renewal at least one month earlier than in past years. Over the last several years CCOF has found that when renewals are sent the day they are due, we are unable to effectively renew the bulk of CCOF’s clients and begin the inspection process. This has lead to a series of problems. So that CCOF can ensure annual inspections and timely reviews, we are attempting to begin each renewal cycle with as many clients renewed as possible.

Therefore, to give you and CCOF more time for the renewal and certification process, CCOF has begun sending renewal notices a full month prior to the month they are due. This began in December for the January 1, 2007 renewals and has proven to be a great success. CCOF now has more time to work the renewal process without cutting into the year available to complete the inspection and review. This will ensure lower costs and better service to you.

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California Cost Share Funds Sold Out
Funding applications for the State of California program to help defray the cost of organic certification overwhelmed the California Department of Food and Agriculture (CDFA) offices last week, and the following announcement was sent shortly after new applications were distributed.
We apologize for any confusion and hope some our certified clients got their forms filled out in time.

Tuesday, September 19, 2006

Greetings Organic Industry:

We are sorry to announce that the Certification Cost Share Program has already received more than enough applications to commit the funds we had remaining.  If your application is not already in the mail please do not send it.

Hopefully, within the next three weeks you will receive a letter from the program that says your application has been received and approved or a notice that we were not able to approve it.

It will still take several months for us to request the funds from USDA and then have the State Controller issue checks.

Thanks to all for your participation. This will make a total of over one million dollars that we were able to distribute to the organic industry.

Ray Green,
Organic Program Manager
California Department of Food and Agriculture

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GMO Rice Reporting Information
Due to a discovery that GMO rice had been found in non-organic rice supplies in Arkansas and Missouri, CCOF and CCOF growers were required to report all 2006 organic rice varieties and suppliers. As of September 2006, there is no evidence of GMO contamination of organic or California grown rice. More information: View the USDA statement, request to certifiers and CCOF request for information.

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Quebec Organic Produce Labeling Update (July, 2006) (Download a copy of this announcement)
CCOF Certified clients directly or indirectly shipping organic product to Quebec are advised that they must label products according to CAAQ organic labeling standards. Notably, CCOF and the name of the certified operation must be identified as the certifier on all products including fresh bunched or loose produce. Standard PLU stickers or twist ties must be modified to meet these requirements.

Please be aware that the CAAQ may levy fines and take compliance action against companies and products found in Quebec without compliant labeling. CAAQ organic produce labeling flyer and exemption request.

Specific examples include:

• Cucumbers, each cucumber must be labeled with the information required in 9.4.3 below.
• Bundles of leeks, parsley, broccoli, grapes, etc… must be labeled per 9.4.3 below.
• Product in clam shells or in bags must be labeled per 9.4.3.
• Bunches should be individually labeled where each fruit cannot be labeled.

CCOF certified products may be shipped to Quebec by a broker or third party without the knowledge of CCOF producers. In such cases CCOF recognizes that the third party is responsible for informing the CCOF producer of their intent to ship the product to Quebec and provide for the required labeling.

If the CCOF producer is shipping the product directly to Quebec, be advised that you are responsible to meet the labeling requirements of Quebec. CCOF strongly recommends enrollment in the CCOF Global Market Access program for all clients who directly or indirectly export organic products to foreign markets.

Please indicate during your inspection and annual updates of any known or potential future sales into Quebec so CCOF can help you by ensuring your compliance with CAAQ requirements.

CAAQ standards can be viewed at www.caaq.org, or http://www.caaq.org/en/home.asp. In Chapter 9, Section 9.4 addresses Labeling of fruit and vegetables by operator that requires individual labeling of each “individual” fruit or vegetable.

9.4 Labeling of Fruit and Vegetables by Operators

9.4.1  Perishable foods, such as certified fruit and vegetables, shipped and intended for sale, shall be individually labeled (using stickers or others methods) by the operator holding an organic compliance certificate for these products.

9.4.2  When, due to their specific nature, products cannot be labeled individually (e.g. grapes), then it is the unit of sale (grape or broccoli bunch, parsley bundle, etc.) that shall be affixed with a label.

9.4.3  The operator that holds the certificate shall print its name (or identification codes allotted by the certification body) along with the name of the certifier on all labels attached directly to fruit, vegetables and other food products in this format.

9.4.4  In exceptional cases, when no labels can be affixed to each fruit or vegetable, their packaging must be done under the responsibility of the certificate holder and in a container upon which the label will be affixed. This label must include all information required by Article 9.2.1.

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CCOF Global Market Access Program released
In an effort to provide additional benefits and ensure continued international market access for CCOF clients, CCOF has revised its international program. The new "Global Market Access" program provides certification to both the European EEC 2092/91 standard and IFOAM requirements in addition to verifying other international standards as required by CCOF clients. The new program and standards became effective February 10, 2006. CCOF has revised Manual III: CCOF Global Market Access and strongly encourages current and prospective CCOF International clients to review it. Visit www.ccof.org/international.php to learn more and view a copy of the revised program.

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EU Regulatory Change Requires Inspection of All Storage Facilities
In an important move for CCOF exporters, a recent change in the EU organic regulations by the European Commission has added the requirement that all handling and storage facilities associated with products destined for the EU must be inspected. This change will affect a number of CCOF certified clients who seek CCOF Certification under CCOF’s International program. Under this ruling all warehouses and distribution points must be inspected under this requirement while under the NOP many of these facilities are exempt from certification. CCOF will be working with clients to meet this requirement as efficiently and effectively as possible. Towards this goal, CCOF will utilize current storage facility affidavits as demonstrations of compliance and will include inspections of these facilities at the lowest possible cost. Defra's announcement on the subject can be viewed by clicking here. Click here to view the amendment to the European Union Organic Regulation 2092/91.

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Quebec Clarifies Organic Labeling Issues
CCOF recently received an announcement from the organic regulatory authorities in Quebec (the CAAQ). These include specific requirements labeling organic products with <70% organic content and wine labeling standards that go into effect on Jan 1, 2006. Notably, products with less than 70% organic content must be accompanied by a certificate of verification attesting to the organic ingredient content. Additionally, the product must include the name of the certifier providing the verification with the statement “verified by…”. While CCOF does not expect CCOF clients to be affected by this requirement, companies in need of ingredient verification for the Quebec market are encouraged to contact us. The wine labeling announcement reiterates the requirement that wines with added sulfites may only carry a “Made With Organic Grapes” label. This is similar to the National Organic Program. Also, the CAAQ has clarified that organic production techniques that are prohibited in Quebec may not be utilized for products sold in Quebec. Namely, organic Hydroponic and Aeroponic production may not be sold as organic in the province. Click here to view the CAAQ Organic Labeling and Certification Announcement.

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Add CCOF Logo to your website easily
CCOF has made it easy for both certified clients and supporting members to include the appropriate logo on their website by following the steps in this document. Please note the CCOF logo may only be used by certified clients or on links pages that do not imply certification or approval by CCOF. The brand new CCOF supporting member logo may be used by any supporting members in good standing. Please contact CCOF Marketing at marketing@ccof.org or 831-423-2263, ext. 31, with any questions or for assistance.

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New Streamlined Organic System Plan (OSP) Released
CCOF is pleased to announce the development of new streamlined Organic System Plan (OSP) documents. Both new clients and clients updating their OSP will be pleased to find the forms almost 50% shorter and considerably more efficient. Highlights include a reduction in the overall number of pages, clarification of questions, a reduction in jargon, and the combination of many sections resulting in a more intuitive process. Download the new OSP. Download new add acreage and add product forms.

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Grower/Livestock Specific

Methionine Use in Poultry Extended to October 1, 2012
The National Organic Program recently announced an amendment to the National List regarding feeding the synthetic amino acid methionine to organic poultry. This interim rule extends the current allowance until October 1, 2012 with the following maximum allowable limits of methionine per ton of feed: 4 pounds for layers, 5 pounds for broilers, and 6 pounds for turkeys and all other poultry. This interim rule is based upon a recommendation by the National Organic Standards Board (NOSB) on April 12, 2010.

Methionine is an essential amino acid necessary in poultry diets for proper cell growth and feather development. While methionine is naturally present in organic poultry feed, the amount is not sufficient to maintain the optimal health of the birds. The NOSB determined that the loss of the use of synthetic methionine would disrupt the organic poultry market and cause substantial economic hardship to organic poultry operations.

The interim rule became effective October 1, 2010, and was available for comment until October 25, 2010. CCOF has provided this information to poultry producers and encourages all organic poultry operations to remain engaged on this issue as a final rule is published and the 2012 deadline approaches. The interim rule and public comments may be viewed at http://www.regulations.gov, filed as document AMS-NOP-10-0051.

National List Updates Published for Allowed Crop Inputs - Sulfurous Acid and Tetracycline
On Friday, July 2nd, 2010, the National Organic Program (NOP) announced two amendments to the National List of Allowed and Prohibited Substances that may be used in organic crop production. The National List was amended to allow sulfurous acid to be used on-farm to reduce excessive alkalinity in soil or water by pH adjusting water used for irrigation. Additionally, the allowance for tetracycline, a treatment for fire blight in apples and pears, was extended until October 21, 2012. Both amendments to the National List were made by the NOP based on the recommendations submitted by the National Organic Standards Board (NOSB). You can view the text of the Final Rule in the July 7 Federal Register here.

CCOF Implements Pesticide Residue Testing Under National Organic Program Mandate

CCOF is pleased to announce that we will be increasing our pesticide residue testing efforts beginning in August 2010. Pesticide residue testing, while not a guarantee of organic management, is an important tool to increase consumer confidence in organics, prevent fraud, and identify problems in organic systems. CCOF producers will not be charged additional fees for testing during 2010.

The National Organic Program (NOP) has announced that certification agencies are now required to conduct pesticide residue testing of samples from 3-5% of farm operations annually. CCOF expects to take between 60 and 80 samples of harvestable crops at the farm gate for testing in the second half of 2010. Samples will be collected both during the course of regular inspections and during additional visits. The results of all tests will be sent to the farmers as soon as they are received by CCOF. If residues of any prohibited materials are found at levels above 5% of the EPA tolerance for the product on the specific crop, the crop may not be sold as organic. In all cases where residues of prohibited materials are found CCOF will investigate the cause to determine if it was accidental (drift) or purposeful application. All test results will be provided to the NOP and will be available to the public upon request. For operations inside California, test results will also be provided to the CA State Organic Program.

As part of the NOP's "Age of Enforcement", (see the Spring Certified Organic), and as a result of the recent USDA Office of Inspector General review, the NOP has agreed to ensure that periodic residue testing is being performed by certification agencies by September 2010. This testing is mandated by the Organic Foods Production Act of 1990. CCOF is happy to work with the NOP to fulfill this mandate and help increase confidence in organic production practices. While we expect to find no residues on the vast majority of samples, we believe that residue testing is an important part of meeting consumer expectations and will strengthen the organic marketplace.

NOP Clarifies Green Waste Composts Allowed for Organic Production

On April 19, 2010 the National Organic Program (NOP) issued a policy on the Allowance of Green Waste in Organic Production Systems. This policy largely concludes the outstanding issues that arose from the California State Organic Program (SOP) prohibition of three compost materials after finding low levels of Bifenthrin residue. On April 21, 2010 the SOP clarified that the prohibition on Nortech Gold, Grover Wonder Grow, and Clean City Composts was rescinded. This announcement was mailed to all registered organic producers in California. CCOF worked diligently with the SOP and NOP to resolve this issue and performed testing of green waste materials, soils, and crops produced with the composts to aid in risk assessment. In addition, CCOF addressed this subject with other members of the organic community at the 2010 Eco-Farm Conference. After consideration of the issues and comments from CCOF and others, the NOP clarified that green waste composts may be used as long as any unintentionally present residues do not contribute to contamination of crops, soil, or water. Copies of the NOP and CDFA announcements are available online.

Important New Pasture Standards Update (4/29/10)
Update May 14, 2010: Visit CCOF's Pasture Rule page for new Organic System Plan forms, news, and pasture consumption calculation tools.

To the delight of most of the organic dairy community, on February 12, 2010, the National Organic Program (NOP) published the long awaited final rule on "Access to Pasture." This rule was years in the making, with input from a large number of interested parties and over 26,000 comments submitted to NOP. The final version had the support of the three regional Organic Dairy Producers Associations and has seen an overall enthusiastically positive response from all sectors of the community, including producers, processors, watchdog groups, and consumers.

The new Access to Pasture rule is a marked improvement from the proposed rule issued last fall, and has removed references to "sacrificial pasture," the requirement for fencing of water bodies, and any changes to Origin of Livestock. The rule will become effective on June 17, 2010. After that date, certified operations will have one year to be verified as being in full compliance.

The new rule is lengthy and detailed, and contains explicit instructions for recordkeeping requirements and pasture management plans. Very few CCOF producers will need to make changes to their management practices in order to comply. However, there are a number of additional record-keeping requirements that will need to be implemented and new OSP sections to be completed in the coming months.

The NOP staff is busy developing worksheets and instructions to help livestock producers appropriately calculate Dry Matter Intake (DMI) and Dry Matter Demand (DMD) and implement appropriate pasture management systems. Additionally, the NOP has announced training sessions on the new rule that are open to the general public. A training session will be held in Woodland, CA on April 26, 2010. We strongly encourage organic dairy producers to attend this training session. To reserve your space in this training session, please email Judith Ragonesi, NOP Training Manager, at Judith.Ragonesi2@ams.usda.gov.

Visit CCOF's Pasture Rule page for new Organic System Plan forms, news, and pasture consumption calculation tools.

Some highlights of the new rule include:

• All animals must receive 30 percent of their DMI from pasture during the grazing season. This will need to be calculated and documented based on averages of each type of animal over the grazing season.
• It is up to the producer to develop a plan for calculating DMI and DMD, and to submit these plans to CCOF for approval.
• The grazing season is a minimum of 120 days per year, but may be up to 365 days depending on weather conditions.
• There are specific limitations on confinement of animals from pasture, including that lactation is not a reason for confinement.
• Calves must be provided access to pasture at 6 months of age.
• Confinement from pasture is allowed only for one week for dry off, three weeks prior to parturition, and one week post-parturition.
• Roughages used as bedding must be organic.
• A Pasture Management Plan will be required to be developed by each ruminant operation and submitted for approval to CCOF.
• Beef animals are exempt from the 30% DMI requirement during finishing for the final 120 days or 1/5th of their life, but must be provided access to pasture during finishing. A 60 day comment period was left open on this topic to provide an opportunity for additional feedback.

CCOF is working to revise our Livestock Organic System Plan (OSP) to include sections relating to these new requirements. All CCOF dairy operations will be required to complete these new OSP sections in 2010, and 2010 dairy inspections will focus on determining compliance with these new regulations.

Read more information from the NOP, including the full text of the new regulations, a Q&A, and supporting documentation, including DMD and DMI worksheets.

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CDFA State Organic Program Prohibits Two Compost Products
On August 5, 2009 the California Department of Food and Agriculture (CDFA) State Organic Program (SOP) sent a notice to all registered organic growers and certifiers informing them that Nortech Gold Compost could not be used in organic production. A similar notice was distributed on September 23, 2009 regarding Grover Wonder Grow Compost. The notices state that continued use of this material in organic production could jeopardize an operation’s organic status. This action is largely unprecedented and may be an indication of future enforcement actions.

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Organic S.A. de C.V Crop Production Materials Prohibited (1/29/09)
Recent analytical tests found that Biolyd, produced by Organic S.A de C.V., appears to contain prohibited pyrethroids, which is contrary to previous ingredient disclosers from this supplier. This brings into question the entire suite of materials produced and sold by this entity. Therefore, effective immediately, CCOF is prohibiting the use of Biolyd, Super Biagron, Hormefin, Terraforte, Kuramil, Bioxer 1000 and Bioarcadian under the CCOF certification program. Any remaining stocks may not be used and continued application will be considered a non-compliance. Operations farming in Mexico and elsewhere should immediately review their materials and ensure that use of these materials is ceased immediately.

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Important Update on Liquid Fertilizers (12/9/09)
Please visit CCOF's Liquid Fertilizer information page: www.ccof.org/liquidfertilizer.php for current information and background on this issue. Current list of approve liquid fertilizers.

Important Notice About Liquid Fertilizers (5/15/09)
As of May 18, 2009, the following products are no longer approved by CCOF:
Product Name and Manufacturer
Ag Unlimited 4-1-1, AGRO-K Corporation
Aqua-Trend 5-1-1, Agri-Trend, LLC
Eco Life Liquid 3-1-3, Novozymes Biologicals,Inc.
Eco Life Wettable 6-0-6, Novozymes Biologicals, Inc.
Hytech 5-2-2, AGRO-K Corporation
Liquid Fertrell#1: 4-1-1, The Fertrell Company
Megafol 4-0-2, Valagro S.P.A.
Metanaturals 16-0-0, METANATURALS, A Division of Bella Via, LLC
Omega 6-6-6, Petrik Laboratories, Inc.
Pura Vida Organics-Grow, Technaflora Plant Products, LTD
Safer® Brand Fish Emulsion All-Purpose Fertilizer 4-1-2, Woodstream Corporation
Sea Pal Liquid Fish 3-1-1, Sea Pal
Yeoman Organic N 5%, Northwest Agricultural Products

As of May 18, 2009, CCOF clients may not purchase any new inventory of these products; however, existing supplies may be used.

Producers who use any of the above products after May 18, 2009 must be able to show at inspection records demonstrating that the inventory was purchased prior to May 18, 2009.
The manufacturers of the products listed above have not complied with the CCOF requirements for high nitrogen liquid fertilizer manufacturers outlined in CCOF's January 15, 2009 High Nitrogen Liquid Fertilizer Approval Policy. This policy required manufacturers to notify CCOF of their inspection body by May 1, 2009. The manufacturers listed above have either ceased production of these products, failed to notify CCOF of their plans to undergo inspection, or have stated that they will not comply. This does not mean that these products have been found to be fraudulently manufactured. CCOF is not making any evaluation regarding the ingredients or formulation of these materials.

CCOF is working diligently with the USDA National Organic Program, the Organic Materials Review Institute (OMRI), the Washington State Department of Agriculture (WSDA) and other certifying agents to ensure that manufacturers of high nitrogen liquid fertilizers are inspected and verified by October 1, 2009, as required by the USDA NOP and CCOF. We will keep you informed of changes to the approval status of any additional materials as they occur.

NOP Addresses Liquid Fertilizer and Input Approval Issues (2/20/09)
On February 20, 2009, The National Organic Program (NOP) released a notice stating that it is no longer confident that the liquid fertilizers Marizyme and Agrolizer, manufactured by Port Organic Products, Ltd., are in compliance with NOP regulations. Furthermore, the NOP is taking additional steps to protect the organic community by requiring third party reviewers, such as OMRI, to implement a detailed audit and inspection protocol for all high nitrogen liquid fertilizers effective October 1, 2009. Read the full NOP announcement.

CCOF's existing Liquid Fertilizer Approval Policy is in full compliance with the NOP requirements and will continue to be in effect. There is no action required from CCOF operators beyond continued compliance with CCOF's previous requirement to cease and desist use of fertilizer products manufactured by Port Organic Products, LTD. Read CCOF’s policy announcement.

CCOF is extremely pleased to see the NOP taking these important steps to ensure the integrity of organic foods are protected. We appreciate their quick and decisive action on this issue. CCOF will continue our efforts at inspection of manufacturing facilities and testing of products in order to deter any further adulteration of products marketed to organic farmers.

CCOF will notify producers of any materials that fail to comply with CCOF and NOP requirements for approval.

CCOF Launches Fertilizer Sampling Initative (2/13/09)
To provide supplemental information for CCOF's Liquid Fertilizer Approval Policy (see below) CCOF has recently launched an initative to test a variety of liquid fertilizers. CCOF will be running Nitrogen Isotope Ratio testing in addition to other screens to help identify materials of increased concern. CCOF also plans to work with the organic community and researchers to develop improved testing methodologies. Read this for more information on this initiative. For background information about liquid fertilizers click here.

Important Fertilizer Update: All Port Organic Products, LTD Prohibited Immediately (01/23/09)
Effective January 23, 2009 CCOF is prohibiting all fertilizer products manufactured by Port Organic Products, LTD including, but not limited to:

• All Marizyme products
• All Agrolizer products
• Any products produced using these or other Port Organic Products, LTD materials in any amount

Growers must stop using these products immediately and existing supplies may not be used.

Based on ongoing concerns about high nitrogen liquid fertilizer products combined with recent events and CCOF's commitment to the needs of the organic community, CCOF has determined that we no longer have sufficient confidence that the Marizyme or Agrolizer products comply with the National Organic Program. Therefore they must be prohibited for use immediately. Additional information:
MSNBC News
Channel 23 News-Bakersfield

These are not the first high nitrogen fertilizers to be prohibited by CCOF and may not be the last. As identified in the Spring 2007 issue of CCOF's Certified Organic magazine, CCOF has significant concerns regarding high nitrogen liquid fertilizers.

CCOF recently implemented a new policy directed at ensuring the organic integrity of liquid fertilizers used by organic growers. Read more below. This policy is aimed at ensuring fertilizer companies undergo third party inspections or face prohibition of their products in late 2009.
CCOF will keep you informed of changes or developments as they arise by posting them in this area of the CCOF website. For a current list of materials recognized by CCOF as compatible with organic production, please visit the OMRI website. Additional information, CCOF's current Liquid Fertilizer Approval Policy, and a partial history if this issue can be found below.

Announcement: 2009 Liquid Fertilizer Approval Policy (01/12/2009)
Due to CCOF’s ongoing concern regarding the production of liquid fertilizers, CCOF is enacting the following new policies effective January 15, 2009 to protect CCOF organic growers, consumers, and the organic community. CCOF’s goal is to ensure the highest level of verification and implementation of the National Organic Program. Therefore, CCOF is working directly with manufacturers and various compliance and inspection bodies to ensure that the needs of CCOF growers are met. CCOF growers are not required to take any action at this time and will be informed of any changes to the approval status of fertility materials if changes occur.

Download Policy Announcement

Background: For more information regarding the history of this issue see please see CCOF’s article “Liquid Fertilizer: Friend or Foe” in the Spring 2007 issue of Certified Organic.
CCOF has a long history of concern and action regarding this issue and has advocated and spoken out strongly while working with a variety of regulators, clients, farmers and manufactures to help protect organic growers and consumers. CCOF has brought suspicious materials to the attention of several different bodies including WSDA, OMRI and CDFA while keeping NOP apprised of developments.
The following are instances where CCOF has discussed this issue:
2/11/09: CCOF Leads the Discussion about High-Nitrogen Liquid Fertilizers
CCOF Executive Director Peggy Miars and Chief Certification Officer Jake Lewin met with USDA National Organic Program (NOP) officials to update them on the high-nitrogen liquid fertilizer issue. CCOF anticipates that the NOP will address this issue in the near future.
2/3/09: CCOF Testifies before CA Senate Food and Ag Committee
Jake Lewin, CCOF Chief Certification Officer, testified before the newly-named California Senate Committee on Food and Agriculture, entitled “Assuring the Integrity of Organic Food and the Use of Organic Fertilizers.” Jake spoke to CCOF’s role in and response to the high-nitrogen liquid fertilizer issues. Jake’s testimony was provided under rapid-fire questioning by Senator Dean Florez (D-Shafter), chair of the committee, and Senator Abel Maldonado (R-Santa Maria), vice chair. The committee and other members of the Legislature will consider introducing legislation that will provide CDFA with increased enforcement authority for fertilizer fraud, as well as increasing fines against perpetrators of label violations. Listen to the full Senate Hearing. (NOTE: CCOF and OMRI testimonies begin at the 2 hour mark) Part two of this hearing is available at: www.calchannel.com/channel/viewVideo/77.

1/30/09: CCOF Launches Fertilizer Sampling Initiative
On behalf of CCOF and its members, CCOF launched a Fertilizer Sampling Initiative to test a variety of liquid fertilizers in the marketplace and to provide supplemental information on the recently announced Liquid Fertilizer Approval policy. Read CCOF’s Liquid Fertilizer Approval Policy.
1/15/09: CCOF meets with California Legislative Staff on Issues in Organic
CCOF Policy and Program Director, Claudia Reid, met with four California Legislative staff members regarding liquid organic fertilizer, SOP reform, CDFA, and other related issues. Reid will represent CCOF at an upcoming Senate Committee on Food and Agriculture hearing scheduled for February 3rd, to discuss the integrity of organic food and the use of organic fertilizers. Read more about CCOF Policy and Advocacy efforts
7/30/2008: California Organic Products Advisory Committee (COPAC) Meeting.
7/30/2008: California State Organic Program Report: Expansion of Spot Inspections & California Organic Products Advisory Committee (COPAC) Meeting. Also included in Summer 2008 Certified Organic Magazine.
1/25/2008: Presenter at Eco Farm (www.eco-farm.org) 2008 Conference Session titled: High Analysis Liquid Organic Fertilizer: Possible? Download audio (86mb)
12/21/07: Important Materials Update Organic Biolink 14-0-0 Prohibited.
April, 2007: CCOF Liquid Fertilizer Article in Spring issue of Certified Organic.
01/10/07: Important Materials Update- Biolizer XN Prohibited.
Pre 2007: Specific complaints and participation in investigations by securing samples since Spring of 2006.
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Livestock Updates Coming Soon (10/15/2008)
CCOF livestock producers should be on the lookout for an update in their mailboxes. CCOF appreciates the tremendous effort made by certified organic livestock producers to meet a wide variety of complicated and occasionally unclear requirements. We salute your efforts and look forward to increased stability in practices and standards as this sector matures in the coming years.

To help guide CCOF policies and approaches in livestock certification, CCOF has convened a new Livestock Advisory Committee composed of CCOF livestock producers and others knowledgeable about organic standards and western region organic livestock issues. As a result of recent events, findings from the Livestock Unannounced Compliance Initiative (see the Summer 2008 Certified Organic), and meetings of this committee, CCOF is developing a 2008 Livestock Update that will address key decisions and policy guidance, including:

Pasture: While CCOF anxiously awaits new standards language on pasture, we are also continuously developing guidance regarding CCOF’s interpretations of existing pasture rules. CCOF’s pasture guidance is meant to address real life situations and provide clarity on the expectations of practices necessary to demonstrate compliance with current regulations. CCOF inspectors will continue to look for evidence of these practices, such as confinement records, during on-site visits.

Living conditions: CCOF intends to address issues relating to confinement and housing for both poultry and ruminants. Specifically, CCOF intends to address slatted floors in calf housing and a phase out of ongoing confinement of poultry due to disease pressures, such as Avian flu. As CCOF gathers improved information on industry practices and problems specific to organic producers, new concerns may arise about previously approved practices, which CCOF may choose to address through notification and planned phase outs.

Thresholds of concern: CCOF cannot impose specific requirements, such as maximum animal numbers, grazing density, or other criteria for certification above what is specified in the NOP, which is very general in its language. This can create frustration and confusion as producers try to determine if they are acting in compliance with the regulations. In order to help producers understand what is acceptable, CCOF is continually working to establish “thresholds of concern” for specific practices. Thresholds of concern are levels above which producers must provide increased justification for, and explanation about, in order to allow the practices in question. Key thresholds to be included in the 2008 update include animals per acre on pasture, space allowances, calf and/or fresh cow confinement practices, and others. These thresholds are intended to supply all CCOF operators with a better idea of how CCOF approaches interpretation of broad NOP standards to on-the-ground practices.

Replacement stock and limits on additional herds: Since our livestock update in 2006, CCOF has allowed operations to enter new entire distinct herds into their operation. However, as we have consistently stated, CCOF opposes the continual conversion of non-organic animals to organic production. We have found that significant problems remain in NOP replacement standards and various policy guidance documents. It has become clear to CCOF that the addition of new entire distinct herds has not served to clarify the situation or provide a level playing field for all CCOF certified operations. Therefore, CCOF is modifying our approach to the allowance of additional herd requests (form LM2.1) to only apply when there is physical expansion of operations such as new milk barns or dairy locations. Requests to add new entire, distinct herds to supply replacements in the absence of a calf raising program or maintaining an operation’s animal volume will not be approved by CCOF.

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CCOF, with the support of the CCOF Certification Services, LLC Management Committee, has recently decided to withdraw from the IFOAM accreditation program for the scope of livestock certification effective August 8, 2008.

This decision was made after CCOF underwent a 4 year re-assessment with IFOAM and discovered that many additional requirements would be placed on CCOF livestock producers. CCOF would be required to increase documentation and inspection time to continue to provide this scope of certification. Upon further analysis, we determined the vast majority of CCOF livestock operations in the Global Market Access program had achieved equivalency under EEC 2092/91 certification, and none had ever engaged in either direct or indirect exports that required IFOAM.

Therefore, we have elected to withdraw from the IFOAM accreditation program for the scope of livestock in order to save time and money for both our clients and CCOF. We do not believe that you will be affected by this change in any way. Any future export of your products to the European Union can be easily facilitated as long as EEC 2092/91 equivalency for your livestock has been achieved.

CCOF livestock producers are not required to do anything. Future inspections will simply not cover IFOAM issues for livestock and client profiles printed after the effective withdrawal date will not include IFOAM as a compliance in the livestock section of the document.

Thank you for your understanding.  If you have any questions or concerns, feel free to contact CCOF at ccof@ccof.org.

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Biodiversity Inspection Questions Implemented (7/30/2008)
CCOF continually seeks to improve implementation of organic standards. In late 2005 CCOF supplied all our clients with biodiversity guides and a letter of support for the Wild Farm Alliance's (WFA) efforts. Since then we have continued to liaise with the WFA to find ways to keep the important issue of biodiversity at the forefront of our certified clients minds. In 2008 CCOF introduced 'Biodiversity Tips' as a regular article in our "Certified Organic" magazine. More recently, on the advice of the WFA and others, we have investigated how we could further integrate and address biodiversity concerns to enhance our inspection process.

After considerable analysis and research we have decided to NOT implement additional paperwork or OSP forms. Instead CCOF inspectors will review in greater detail natural resource and broad biodiversity considerations during inspections and report on potential concerns within their reports.

Initially, CCOF inspectors will focus their questions on the identification and description of riparian areas or other sensitive natural resources, ecosystems or wildlife habitats. Secondly, CCOF inspectors will ask about efforts to maintain or improve these and other natural resources of within your operation. As defined by the NOP, natural resources of the operation include the physical, hydrological, and biological features of a production operation, including soil, water, wetlands, woodlands, and wildlife. CCOF clients should be prepared to address these issues with the inspector efficiently so additional inspection costs and time are minimized. We are concerned about any new effort that may increase inspection time or costs but have received indications from many CCOF clients that they are willing to accept this to participate in the improvement of their own farms' sustainability and in the enhancement of CCOF's organic certification program. To assist with this, the Wild Farm Alliance has produced farmer and certifier guides addressing practical implementation of biodiversity concerns within organic farming and certification. Please visit www.ccof.org/biodiversity.php to learn more and download helpful guides for on-farm implementation of biodiversity principals. We hope that these and other efforts will help CCOF and its clients lead the way in organic farming as we have done for decades.

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Funding Opportunities Linked to Biodiversity for CCOF Members (7/30/2008)
The USDA Natural Resource Conservation Service (NRCS) services nearly 3,000 county-level Soil and Water Conservation Districts, providing conservation programs and services to private landowners. Their main objective is to implement voluntary best- management practices through the use of programs such as conservation planning and technical assistance, conservation implementation, natural resource inventory and assessment, natural resource technology transfer, and financial assistance. One of their grant programs is the Wildlife Habitats Incentive Program (WHIP) that can assist farmers with the implementation of biodiversity initiatives. Visit the NRCS website.

Other funding opportunities are listed on the classifieds section of CCOF's website.

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Unannounced Livestock Compliance Initiative (7/30/2008)

CCOF has launched a significant expansion in our unannounced inspection efforts targeted at the organic dairy sector. Beginning late May 2008, CCOF implemented an aggressive program to increase our monitoring and oversight of access to pasture and other issues in the organic dairy sector. While this comes at the expense of some other efforts, we've decided to concentrate in this area since this has been an ongoing issue of concern in the organic community and it's important to CCOF to ensure that we are gathering credible information about ongoing practices throughout CCOF's organic dairy operations. These inspections are intended to provide information about grazing and other practices over long periods of time and repeated visits during different grazing conditions. Typically, CCOF inspectors will observe CCOF certified dairies during their identified grazing periods for an hour or more while also observing key grazing indicators. Wherever possible, visits will be repeated during a single day or series of days. CCOF intends to perform a minimum 12 visits in 2008 and at least 20 by June 2009 in addition to our ongoing regular inspections. CCOF will use these observations to bring any concerns to the attention of an operation and to improve our interpretations of pasture requirements. As the program develops CCOF intends to utilize it as a 'best practice' model for visits to CCOF organic dairies and to provide the basis for a system for verifying other livestock operation practices such as access to outdoors in poultry.

Read more about the CCOF Livestock Unannounced Compliance Initiative (LUCI).

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New CCOF Organic Farm Certification Support Package (7/30/2008)

CCOF is pleased to announce the launch of our Organic Farm Certification Support Package for certified operations. The aim of the information pack is to assist you with understanding NOP record keeping requirements and includes answers to frequently asked questions, sample forms, a list of organic consultants and ag advisors and reference to other helpful resources including where to source organic seeds. Download a PDF copy here.

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Important Materials Update Organic Biolink 14-0-0 Prohibited (12/21/07)
Organic Biolink 14-0-0, marketed by Westbridge Agricultural Products was recently identified as incompatible with organic production and removed from the WSDA Brand Name Materials List of inputs compliant with organic standards. Therefore, CCOF growers must immediately cease and desist use of Organic Biolink 14-0- 0. Existing supplies may not be used. At this time, the other Westbridge WSDA-listed brand name materials included on approved OSPs will continue to be recognized as compliant.

This is not the first high nitrogen fertilizer to leave the organic market and may not be the last. As identified in the Spring 2007 issue of CCOF's Certified Organic magazine, CCOF has significant concerns regarding high nitrogen liquid fertilizers. CCOF will keep you informed of changes or developments as they arise by posting them in the "Certification Updates and Resources" section of our website. For a current list of materials recognized by CCOF as compatible with organic production, please visit the OMRI website.

Please note that to ensure compliance with NOP standards, all materials should be included on your OSP and approved by CCOF prior to use. Additional OSP forms are available at www.ccof.org/osp.php and www.ccof.org/forms.php.

Thank you for your support of organic farming and CCOF.

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Livestock News: Medicinal Substances Regulation Changes - December, 2007
Over the last few months, National Organic Program (NOP) livestock regulations that cover medicinal products have changed significantly. Additionally, CCOF has re-evaluated our interpretation regarding the allowance of certain livestock products.
Please see below for important updates that may affect your operation.

CCOF livestock operators will be recieving a mailing regarding these changes in the near future. Or, download a pdf copy of the announcement.
Key subjects include:

• Medicinal Products Added to the National List
• News about Banamine
• Products Not Added to the National List
• Health Care Products Reevaluated by CCOF: Immunoboost, Calf 180, and Calcium Borogluconate
• Guidance on Medicines vs. Feed Supplements
• Issues Regarding Excipients
• Removal of Milk Replacers From the National List
• Upcoming Changes

Please note that to ensure compliance with NOP standards, all materials must be approved by CCOF and included on your OSP and prior to use. Additional OSP forms are available at www.ccof.org/osp.php and www.ccof.org/forms.php.

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Uncertified Animal Brokers And Hay Fraud (7/21/07)
The recent months have been extremely busy for CCOF livestock certification. As we all await further clarifications from the NOP on pasture requirements, CCOF has received clarifications from the California State Organic Program (SOP) regarding animal and hay brokers.

Animal Brokers Must Be Certified
As of this past spring, it has become clear that brokers who take possession of organic animals must be certified for the animals to retain their organic status. While there are exemptions in the NOP regulations for brokers of packaged products, this does not apply to live animals.

Considerable risks are involved when non-certified parties are involved in the trade of live organic animals or hay, including an inability to verify the sources of animals and management practices performed while under the possession of non-certified parties. Therefore, operations that take possession of organic animals for any amount of time must be covered under an approved organic system plan and certified by a USDA accredited certifier. This will protect CCOF livestock producers by ensuring the management practices of the broker are reviewed and full records are maintained to verify the legitimacy of all transfers.

CCOF is aware of animal brokers involved in the transfer and sale of organic animals. In some cases transfers from non-certified brokers or with missing documentation have caused the loss of organic status for the animals and delays in organic production. All sales and transfers of organic animals as of April 1, 2007, must include a full chain of custody that inincludes only certified organic parties. CCOF reserves the right to not recognize the organic status of transfers that have not previously been disclosed. If you have a specific issue, please contact us immediately. If you are approached by non-certified parties with organic animals for sale, trade, barter etc., please contact CCOF at ccof@ccof.org and/or the California SOP at rgreen@cdfa.ca.gov .

Per the SOP, the only exemption to the certification requirement is the trucking company itself. Operations that simply pick up and transport animals a short distance without taking management control, feeding, or caring for the animals beyond transport are not required to be certified. However, the operation that maintains title for the animals during transport is responsible for ensuring that transport practices meet National Organic Standards, especially if rest stops or feed is provided en route.

Hay Brokers and Fraudulent Product
CCOF has recently become aware of two uncertified operations fraudulently representing themselves as organic operations. Both Orient Farms and Stewart Hay are not currently certified organic and appear to have been marketing organic hay up to and as recently as June, 2007. An investigation is ongoing at both the State and National Organic Program levels. If you have purchased organic hay from these operations, please contact CCOF so we can take appropriate action. In the interim, it is critical that you protect yourself by ensuring that all suppliers have current certificates prior to accepting deliveries of organic products and that your list of suppliers is current in your approved OSP. Purchases from suppliers not listed in your OSP that turn out to be fraudulent could negatively affect your certification status.

Important Animal Purchases/Transfers Records
Operations accepting organic livestock into their operation should maintain the following types of records. Operations that do not have appropriate documentation demonstrating legitimate animal transfers or sales may not have their animals recognized as organic.
· Incoming documentation clearly identifying the type and organic status of the animals.
· Lists of animal ID numbers and/or brand identifications.
· A State Brand Inspection Certificate.
· Current valid organic certificates for all involved parties.

CCOF is committed to serving your needs. If you have any questions, please contact us and speak to any of CCOF's grower/livestock certification staff.

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Propane for Rodent Control (Spring 2007)
Please be aware that propane combustion has been identified as a rodent control material incompatible with organic production. Commonly, this is marketed as an injection and combustion system under the Rodenator brand. While CCOF previously approved this use, recent clarifications from the National Organic Program during the certifier training in Asilomar (Jan, 2007) have made it clear that organic growers may not use this or other similar products for rodent control in organic fields. Please note that CCOF expects the manufacturer to petition for inclusion of this use on the National List and CCOF may support the petition if requested by its clients. In the interim, CCOF will be requiring that certified growers immediately cease and desist use of all propane combustion based rodent control devices.

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Important Materials Update- Biolizer XN Prohibited (01/10/07)
Biolizer XN, produced by California Liquid Fertilizer (a subsidiary of United Organic Products) was recently identified as incompatible with organic production and removed from the OMRI Product List of allowed materials. Therefore, CCOF growers must immediately cease and desist use of Biolizer XN. Existing supplies may not be used. At this time, the other Biolizer OMRI-listed brand name materials included on approved OSPs will continue to be recognized as compliant.

For a current list of materials recognized by CCOF, please visit the OMRI website at www.omri.org. Please note that to ensure compliance with NOP standards all materials should be included on your OSP and approved by CCOF prior to use. Additional OSP forms are available at www.ccof.org/osp.php and www.ccof.org/forms.php.

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Materials Announcement & Review Form Released
It is your responsibility to verify all input materials are allowed before you use them. Read CCOF's announcement about use of approved materials.
Materials that have been approved for use can be found on the Products List published by the Organic Materials Review Institute (OMRI), www.omri.org, or Washington State Dept. of Ag. (WSDA). For materials not on either of these lists, CCOF will review the material for CCOF clients on a case by case basis to determine compliance with National Organic Program and international standards.
To have your product reviewed please download and complete the Material Review Request Form.

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Updated Policy on Feed Harvested Prior to Inspection ("Hay in the Barn")
Date: 09/07/06
CCOF Hay in the Barn Exception Policy
On a day to day basis CCOF's policy as written will remain in effect (see livestock policy update mailer below). That is, as a general rule CCOF will recognize hay and other products fed to organic dairy animals only when harvest occurs after inspection.

However, we are willing to consider a very limited number of exceptions on a case by case basis. To grant an exception, we will be looking at a few limited criteria including:

• Prior notice. If harvest will occur prior to inspection, it is the responsibility of the operator to notify CCOF in advance of harvest that there is a conflict between impending harvest and inspection dates. Lack of prior notice will be a serious factor in each case.
• Compliant recordkeeping. Any operation seeking an exception must have complete readily available records for harvest and other aspects of compliance. Operations that indicate the maintenance of harvest records but who do not have them at inspection cannot be considered. It is critical that the operation be able to demonstrate compliance at the time of the inspection.
• Timeline. Operations seeking an exception will be subject to limited timelines between harvest and inspection dates. It is highly unlikely that a month between events would be acceptable. Whereas, a week is more likely to be recognized. It is important that the inspector can view as much evidence of the harvest as possible including waste in the field, freshness of product, newly baled hay etc.

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IMPORTANT ANTIBIOTIC POLICY CHANGE ANNOUNCMENT (Download copy of this memo )
To: All CCOF Organic Dairy producers
From: CCOF Certification Services
Dated: July 7, 2006 Effective Immediately.

Re: Change in CCOF policy regarding use of antibiotics on organic livestock.

CCOF Certification Services has been directed by Ray Green, Manager of the California Department of Food and Agriculture State Organic Program, to amend our policy regarding to the use of antibiotics in organic dairy production. Based on direction from Mr. Green, the following is CCOF’s policy on antibiotics, effective immediately:

• Any animal, including calves, treated with antibiotics will lose its organic status and can never return to organic production.
• You may not withhold treatment from a sick animal in order to preserve its organic status, per NOP section 205.238(c)(7).
• You must ensure that animals treated with prohibited materials, including antibiotics, are clearly identified as separate from the organic animals. All meat, milk or milk products from treated animals must be segregated from organic products and there must be clear documentation of the separation.

CCOF CS will no longer allow an animal treated with antibiotics to return to the milking herd, even if the animal is managed organically and remains on the organic farm. CCOF CS producers must cease and desist the transition of any animal treated with an antibiotic immediately.

CCOF’s change in policy on this issue is based on recent changes in the NOP standards that are posted on the USDA website, under “Today’s News” dated June 5 th and June 16 th, 2006.

We appreciate your efforts and thank you for using CCOF for your certification needs. Please contact us at 831-423-2263 if you have any questions regarding this change in policy.

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Livestock Policy Mailer (July, 2006)
In an effort to serve our clients and keep them informed regarding recent policy and certification changes, CCOF mailed an update to all livestock clients. The mailer included an update on CCOF herd conversion and antibiotic use policies. Additionally, an organic livestock certification Frequently Asked Questions document and "To Feed or Not to Feed", an explanation of feed additive and supplement rules, were included. Interested parties can view and print the CCOF Livestock Certification Update Mailer here.

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Nu-Film P has been re-instated as allowed for use in organic production.
Thanks to re-classification of particular inert materials by the EPA, the popular adjuvant has regained its status as an allowed material.

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Certification Assistance Resources
Visit CCOF's Certification Support page for a variety of helpful documents and sample forms to help you understand record keeping requirements and access resources. Or download our Complete Organic Farm Certification Support Package- a convenient collection of available sample forms and documents designed to help you understand organic certification requirements and keep records.

The Western Region Organic Farming Compliance Handbook provides a wealth of resources to new and currently certified organic farms and agricultural professionals. This important resource contains sample forms, certification readiness checklists and helpful explanations of a variety of issues relating to organic standards and the certification process.

The ATTRA organization provides a wealth of resources to help farmers, processors, and others learn about and prepare for organic production and certification. Their organic production website includes organic inspection readiness documents, sample forms, and information on organic marketing, farm practices and more! Check it out at http://www.attra.org/organic.html. Especially helpful are articles on Preparing for An Organic Inspection and the National Organic Program Compliance Checklist for Producers. Additionally the ATTRA Organic Production Website has numerous articles on organic pest control and other issues.

CCOF also prints a quarterly magazine and periodic updates that provide detailed information on certification issues and includes helpful articles on various issues regarding organic standards and compliance. These resources are provided free of charge to all CCOF clients and supporting members. Operations considering certification in the future are encouraged to join CCOF as a supporting member to begin receiving materials and becoming informed about organic standards and certification issues. Past magazines and articles are available in our magazine archive.

Finally, ATTRA provides a variety of certification assistance resources at www.attra.org.

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Processor/Handler/Retailer/Private Label Specific

Name and Seal Use Agreement Eliminated - More Improvements on the Way!

To reduce paperwork, CCOF has modified our Private Label Seal Use approval process. Under our new system, clients will only need to complete the CCOF H2.6 Private Label profile. Review the new H2.6 form at www.ccof.org/osp.php. You are no longer required to secure the signed Name and Seal Use Agreement from your private label customer. Instead, CCOF will communicate the policies, requirements, and responsibilities under the USDA National Organic Program to the private label entity directly.

All CCOF clients must continue to submit their labels prior to production, and existing private label fees per CCOF Manual 1 remain in effect. However, CCOF clients will no longer have to chase their private label customer for signatures, or deal with the legal departments of large private label supermarkets and others. CCOF expects this to improve label approval processes and response rates for all clients. We are continuously investigating our system for other opportunities to reduce paperwork and increase efficiency. Look for improvements to international compliance affidavits soon. Is there an area of certification that you feel is paper heavy or inefficient, and could be improved? Send a letter, fax, or email to handler certification director, Jody Biergiel, at jody@ccof.org with your suggestions.

NOP Policy Reinterpretation of Accessory Nutrients

The National Organic Program (NOP) may reverse past policy which allowed ingredients classified as "accessory nutrients" to be used in organic products. In the past, the Organic National List[1] was interpreted to allow a wide variety of nutrients in organic foods. The revised interpretation limits the "vitamins and minerals" allowed for use in organic products to those allowed in the FDA regulation 21 CFR 104.20(d)(3). This FDA regulation does not include ingredients such as DHA, ARA, taurine, sterols or choline. Therefore DHA, ARA, taurine, sterols, choline and others classified as "accessory nutrients" may not be allowed in organic products.

The NOP will publish draft guidance later this year to solicit comments on this issue. The NOP draft guidance will provide 60 days for public comment, and the final guidance will include a transition time for businesses to reformulate products to minimize the impact of this policy change. CCOF will keep clients updated on the progress of the NOP guidance and opportunities to submit comments. Products which currently contain nutrients not on the National List may be required to be formulated depending on the requirements of the final NOP policy.

[1]7 CFR 205.605(b) "Nonagricultural (nonorganic) substances allowed as ingredients in or on processed products labeled as "organic". Synthetics allowed: Nutrient vitamins and minerals, in accordance with 21 CFR 104.20, Nutritional Quality Guidelines for Foods."

CCOF Improves Wine Certification Process (4/29/10)

In response to client requests and in an effort to streamline the certification process for many CCOF-certified wineries, CCOF has created new Organic System Plan (OSP) documents specific to the organic wine industry. CCOF recently released the new V2.0 and V2.1 OSP sections, which will dramatically decrease the paperwork required for organic wineries.

Organic wine certification is often more complex and time consuming than certification for other organic sectors. The addition of new vintages every year has meant that clients must submit wine formulas on an annual basis. However, formulas are often not finalized until close to bottling time, leaving winemakers with tight timelines for formula and label approval. Most wineries need to have labels approved by both CCOF and the Alcohol and Tobacco Tax and Trade Bureau (TTB) every year, which is a lengthy process, particularly if corrections must be made. This makes nearly every wine product/label review urgent for our clients. In addition, wines may be handled by several independently certified operations and often involve multiple nonorganic processing aids, factors which often slow down the review process.

The new V-OSP documents represent a fundamental shift in CCOF's approach to certifying wineries and will help our clients with faster label reviews, as well as reduce the paperwork required to add products to winery OSPs. The V2.0 and V2.1 forms are currently optional for wineries, but CCOF's goal is to eventually use them to replace all H2.0 forms in winery OSPs. The review process for wineries using these forms is as follows:

• V2.0 Winery Profile - Wineries will use this form to describe domestically-distributed wine made only from organic grapes. It requests information about grape sources, processing aids, and other production details. Approval of a V2.0 form in a winery OSP means that as long as the winery uses only the practices outlined on the form, wine formulas do not need to be recorded in the OSP. Inspectors will review formula records for wineries at their annual inspections.
• V2.1 Wine & Label Approval Form - This form will be used for label approval and to add specific wines to an operation's Client Profile. The form asks the winery to verify that each wine requesting approval was made using the practices outlined on the V2.0 form and that this can be verified through an audit trail.
  

CCOF will still require H2.0 Product Profile forms for wines that contain nonorganic agricultural ingredients and international compliances, as these products are higher risk and require additional verifications.

The forms are available online. Please send questions, concerns, and requests for assistance in completing these forms to: jody@ccof.org, (831) 423-2263 ext. 26.

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New Products and Labels: Seek Approval Prior to Production and/or Printing
During recent National Organic Program (NOP) certifier trainings, the NOP indicated that there is limited tolerance for the use of non-compliant labels in the marketplace. CCOF operations that produce products or new labels that do not meet either formulation or labeling requirements are increasingly likely to receive notices of non-compliance, and may not be allowed to use up existing labels that do not meet NOP standards. Please note that certifiers are required to submit copies of notices of non-compliance to the USDA.

Please submit labels and products to CCOF prior to production to avoid costly errors. CCOF will review your label and/or product as quickly as possible. If you have a compressed timeline, please inform CCOF of your deadline so we can try to meet it. New products or labels that are disclosed during inspections and found to be out of compliance may be considered significant issues. The NOP has indicated a clear preference that certified operations use up labels with minor mistakes within 90 days.

Minor mistakes are categorized by USDA to include:

• Incorrect formatting or location of "Certified organic by CCOF" statement.

Common serious mistakes on labels include:

• Failure to include the statement "Certified organic by CCOF" below information identifying the handler or distributor.
• Use of "100% Organic" on labels when the product does not meet the specific requirements for this labeling category.
• Failure to correctly identify organic ingredients in the ingredient panel or unintentionally representing non-organic ingredients as organic.
• Use of the USDA seal in colors other than the allowed combinations: green and brown or black on a white or transparent background. Indistinguishable variances such as dark navy blue instead of black may be permissible, particularly on labels printed in only one color.
• Identification of a product with 70-95% organic content as "Organic" when it should be labeled "Made with organic (specified ingredient or food group)."
• Use of "Organic" on labels for products that include non-approved ingredients or processing aids.

View the NOP's presentation on labeling.

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Updated Alcohol Labeling Guidelines from the National Organic Program and TTB
On June 15, 2009 the National Organic Program released updated guidelines for the labeling of organic alcohol products. In addition to providing new helpful tools for producers of the products, these guidelines supersede CCOF’s past policy change announced in January, 2009 regarding wine labeling. Under this clarification, different varietals in an organic wine may continue to be used and recognized as different ingredients under NOP 205.301(f)(7). However, effective immediately, wine labels for these products must clearly disclose the non-organic content. Specifically:

Labeling options for wine with added sulfites that only contain organic grapes:
TTB will accept the following variations to “Made With Organic [specified ingredients]” statements:

• “Made with Organically Grown Grapes,” or ”Made with Organic Grapes”
• “Made with Organic Grapes from Our Vineyard”
• “Made with Organically Produced Grapes”

Labeling options for wines composed of both organic and non-organic grapes:
Products that fall into this labeling category, and which contain organic and non-organic grapes, must indicate the presence of non-organic grapes in the “Made with Organic…” statement on the label. The following variations to this statement are acceptable:

• “Made with Organic and Non-Organic Grapes”
• “Made with Organic [variety] Grapes and Non-Organic [variety] Grapes”
• “Made with _% Organic Grapes and _% Grapes”
• “Made with _% Organic [variety] Grapes and _% Non-Organic [variety] Grapes”

For additional information for all producers of organic alcohol beverages, visit the TTB ALFD website.

For additional resources and useful labeling guides for alcohol beverages labeled with organic claims, view the following documents:

TTB Advertising Labeling and Formulation Division Guidance for Organic Labeling Applicants
Organic Wine Labeling Guide
Organic Malt Beverage Labeling Guide
Organic Spirits Labeling Guide
TTB Guidance Regarding Required Organic Labeling Documents
TTB Frequently Asked Questions

NOP Mandates Certifier Role in Food Safety (April, 2009)
In a February 25, 2009 notice to organic certifiers, the NOP clearly mandated that organic certifiers proactively report food safety issues uncovered during organic processing inspections. CCOF sees this as an important clarification and an opportunity to rise to the occasion. While not mandating full blown food safety inspections during organic certification, the notice asks certifiers to report major issues and ensure that appropriate health and food safety inspections have been granted or renewed. Fortunately, CCOF has not found major food safety violations within its inspections. If substantive concerns are found, however, CCOF will address them as part of the certification process and may be required, per the NOP notice, to report violations or operations that are not undergoing appropriate inspections or health licensing.
To meet these requirements, CCOF handling operations must have existing public and private agency food safety inspections available for review during all upcoming inspections. Where clear threats to food safety or human health exist, CCOF will be unable to grant or continue organic certification and will be required to report these to appropriate regulators. The production of safe organic foods has always been CCOF’s intention and we welcome the NOP’s clarification of our vital role in the process.  

"Made with Organic" Wine Formulation Policy Change: Varietals no longer recognized as different ingredients (posted 2/13/09).
The National Organic Program (NOP) regulations attempt to outline organic production standards for all food sectors in three different labeling categories: "100% Organic", "Organic" and "Made with Organic (specified ingredients or food groups)." When the USDA finalized the regulations six years ago, they could not foresee every application of the standards that we have today - pet food, alcohols and supplements, for example. In addition to providing certification services, CCOF interprets the standards and helps clarify the practical applications of the USDA regulations in today's market. CCOF has a reputation for conservatively balancing our clients' interests and consumer expectations, while maintaining the most rigorous application of the organic standards in the industry.

In order to uphold the integrity of the organic label, CCOF is alerting clients and the organic community of a change in the way we will be regulating the use of the "Made with Organic" claim on wines.

Previously, it was not uncommon for wines to be labeled as "Made with Organic (varietal)" if the wine was made with at least 70% organic grapes of one varietal and up to 30% nonorganic grapes of another varietal. CCOF had determined that different varietals constituted different "ingredients" and were not subject to the restriction in the regulations that states no single ingredient can be both organic and nonorganic in a certified product (NOP §205.301 (f)7). This meant that a wine labeled "Made with Organic Merlot" could contain up to 30% nonorganic Cabernet.

Over the last year, CCOF has reassessed this policy and decided that it does not support consumer disclosure, assist our clients in making better products or uphold the spirit or letter of the NOP standards. Therefore, effective January 1, 2009, CCOF will discontinue the allowance of non-organic wine and grapes in wines labeled "Made with Organic." This includes wines labeled "Made with Organic Grapes" and "Made with Organic (varietal)." We firmly believe that this more closely reflects the intent and expectations inherent in the organic standards when applied to the situation of wines sold with a "Made with Organic" claim.

Wines made from grapes harvested prior to January 1, 2009 are exempt from this change in policy. Their production, even if it takes place in 2009, does not fall under this policy update. However, all wine made from the 2009 crop will be subject to this clarified interpretation of the NOP standards. Any wines produced from 2008 crop year grapes seeking allowances to utilize non-organic varietals must be submitted for review prior to the end of 2009.

While CCOF recognizes that this is a significant change in policy, we believe that it is in the clear best interest of the organic marketplace, organic consumers and organic wine producers. Please contact us if you have any questions or comments.

Applicable standard(s) (emphasis Added): 205.301 (f) "All products labeled as "100 percent organic" or "organic" and all ingredients identified as "organic" in the ingredient statement of any product must not:...(4) Be processed using processing aids not approved on the National List of Allowed and Prohibited Substances in subpart G of this part: Except, that, products labeled as "100 percent organic" if processed, must be processed using organically produced processing aids; (5) Contain sulfites, nitrates, or nitrites added during the production or handling process: Except , that, wine containing added sulfites may be labeled "made with organic grapes"; (6) Be processed using nonorganic ingredients when organic ingredients are available; or (7) Include organic and nonorganic forms of the same ingredient."

NOP Interim Rule for Non-Organic Agricultural Ingredients

Addition of 38 Non-Organic Ingredients to National List Strengthens Organic Standards -The USDA has published an Interim Final Rule in the Federal Register to allow 38 non-organic ingredients for use in organic processed foods. They have been added to the National List of Approved Substances on an interim basis while the comment period is extended for 60 days.

Under current standards all non-organic agricultural ingredients used in products labeled "organic" must be included in the national list 205.606 and commercially unavailable in organic form. These ingredients must constitute less than 5% of the product.

Although media coverage might claim this move is a weakening of organic standards, it is actually quite the opposite. These changes are a tightening of the regulations because it reduces the number of ingredients that may be used overall. These ingredients are permitted only when the organic equivalent is unavailable commercially. Prior to June 9, 2007, organic processors could use ANY non-organic agricultural ingredient they needed, as long as it was less than 5% of an organic product, and as long as they could document that it was not available commercially in an organic form.

These new rules greatly restrict the use of other non-organic ingredients in processed organic food. Adding 38 items to the National List is nothing compared to the thousands of possible ingredients that were previously considered acceptable. The significant limitation of potential non-organic ingredients helps support the market for organic minor ingredients and could be seen as an important step forward for organic standards.

CCOF will continue to require all companies utilizing a non-organic ingredient included on the final 205.606 list in the 5% of a product labeled "organic" to undergo thorough searches.

While this significantly limits the universe of potentially allowed non-organic agricultural ingredients in organic products, there has been some concern about the inclusion of specific items, such as hops, that may, in fact, be available in an organic form. If you support or oppose the inclusion of these materials, now is your opportunity to comment during this 60 day interim allowance.

If you are positively or negatively affected by the potential allowance of any of these materials in the non-organic 5% of products labeled "organic", now is your time to comment to the NOP. Deadline: August 27th!
Instructions for submitting public comment to the NOP...
View the Interim National List Additions...
Read an open letter from the Accredited Certifiers Association (ACA) regarding these changes...
Read the USDA Press Release...
Read the OTA Fact Sheet...
Read the OTA Q&A Sheet...

Who is affected by AFSII De-Accreditation?
Please be aware that the National Organic Program recently revoked the accreditation of American Food Safety Institute International (AFSII). While representing a hardship for a number of AFSII certified operations, this clearly demonstrates the intention of the National Organic Program to maintain a strong organic and accreditation program.

Under the revocation AFSII certified companies and products must transfer their certification prior to August 26, 2006. Read the National Organic Program announcement.

To assist our members, CCOF is providing the following guidance for dealing with AFSII certified companies and products:

• Only products produced under AFSII certification prior to August 26, 2006 can be recognized as organic by CCOF certified companies.
• CCOF clients utilizing AFSII certified ingredients or co-packers must receive new certification documentation from their suppliers or co-packers prior to August 26, 2006. Unless new certificates are provided by businesses formerly certified by AFSII, incoming ingredients must not be recognized as organic. Co-packers formerly certified by AFSII must not be utilized after August 26, 2006, for ingredients or products which will bear the CCOF name and/or seal.
• Products produced after August 26, 2006 cannot display the AFSII certification logo or name or be produced under AFSII certification

Read the USDA document: Enforcement & Integrity of the National Organic Program: Q&A's for Consumers

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Commercial Availability Rule Change Update Notice 8/1/05

Wine Label Update Notice 8/5/05

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