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Requirements for Imported Grain, Bean, and Seed Shipments

by Laura Mathias |

This notice has been replaced by the policy announced on April 19, 2021. Learn more.

On May 11, 2017, CCOF Certification Services notified handlers, importers, and others of new requirements for seeking approval for imported grain shipments. Our goal is to help ensure the integrity of organic trade, which is also shared below.

Additionally, the NOP has recently provided a training and resource list regarding organic integrity in the supply chain.

Notice Regarding Imported Grain, Bean, and Seed Shipments from Eastern Europe, the Middle East, and Russia

To increase confidence in imported organic grain, beans, and seeds, CCOF is implementing additional control measures at the direction of the USDA Agricultural Marketing Service (AMS) National Organic Program (NOP). Areas of added scrutiny may include, but will not be limited to, volumes, sourcing and potential for noncompliant treatments.
Products of concern include corn, soy, edible dry beans, wheat, flax, and sunflower meal and their derivatives imported from Kazakhstan, Moldova, Romania, Russia, Turkey, and Ukraine.
Any operation that directly receives imported organic corn, soy, edible dry beans, wheat, flax, and sunflower meal from Kazakhstan, Moldova, Romania, Russia, Turkey, and Ukraine may be subject to at least one unannounced inspection during the coming months.
Effective immediately, prior notification of incoming shipments is required for at-risk grain, beans, and seeds received directly by CCOF certified operations. CCOF will conduct sampling and verify each shipment of organic corn, soy, wheat, flax, dry edible beans, sunflower meal, and their derivatives imported into the U.S. from Turkey, Russia, Ukraine, Kazakhstan, Moldova, and Romania. All product must be identified as organic in the audit trail documentation. Complete audit trail records, including shipping documents, bills of lading, phytosanitary certificates and other documents will be verified at each inspection. Mass balance audits will be performed at inspections.
CCOF will review this information and work with USDA NOP, other agencies, and certifiers as necessary to ensure that volumes are legitimate, product is not treated with prohibited materials in the supply chain, and product meets organic standards.
We strongly encourage importers and receivers of foreign grain, beans, and seeds to implement thorough and effective due diligence and verification of suppliers. Operations that receive any imported goods are strongly advised to consider their suppliers very closely and review, test and/or visit the production locations to verify the legitimacy of products. Operations with grain, beans, or seeds that do not meet organic standards will be notified that that product is not compliant. If an operation knowingly sells noncompliant product as organic it may lead to suspension of organic certification and potential civil penalties.

We appreciate the dedication of CCOF operations and others. It is important that we work together to defend organic standards and ensure the integrity of organic products and continued consumer confidence by applying additional due diligence.

Read the notice and formal policy.