CCOF Approval Requirements for Imported Grain Shipments

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Date

Date Published: 
May 15, 2017

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 Approval Requirements for Imported Grain Shipments 

CCOF Certification Services lacks confidence in the organic status of foreign grain, including (but not limited to) organic corn, wheat, and soy from eastern Europe and non-EU member states. Current concerns include volumes, sourcing, and potential for noncompliant treatments. To increase our confidence in imported grains received by CCOF-certified operations, we are implementing additional oversight. 

Organic grain imports from these areas has increased rapidly in volume in a short time. Some volume spikes may be accounted for by current correct usage of organic tariff codes when in the past shipments may have been misidentified with standard commodity codes. We have conducted investigations into validity of organic status of imported grain within the past year. Given that we are aware of ongoing concerns and complaints, we believe it is appropriate to apply additional scrutiny in this area.

Effective May 12, 2017 and until further notice, approval is required for all imported grain shipments received directly by CCOF-certified operations. The certified operator receiving imported grain directly from a ship must demonstrate full traceability back to growers, along with volumes, and demonstrate lack of prohibited material use in shipping to establish that the products meet organic standards. Shipments CCOF does not specifically approve are not considered to be in compliance as they have failed to demonstrate information necessary to verify compliance per NOP 205.2 "Audit Trail"; 205.103; and 205.201a(6).

CCOF will review this information and work with 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 encourage other certifiers and actors in the supply chain to adopt similar processes.

Operations that receive imported grain shipments 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 that is found to 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 expect verification of organic status for imported grain to be challenging and complicated to achieve.

As the trade and international certifiers adjust to the need for additional documentation, we recognize there may be challenges for U.S. operations. We appreciate in advance the patience and dedication of CCOF-certified 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 original notice and formal policy.