Over the last year, CCOF has worked with importers, the USDA National Organic Program (NOP), and others to strengthen the integrity of organic imports. Over the coming year, we will be implementing increasingly robust importer certification programs to allow us to effectively review import systems and identify importers of various goods and commodities. In the interim, the NOP has been updating the organic community regarding existing policies and best practices.
Any CCOF-certified importer or CCOF-certified operation sourcing imported products from uncertified importers, brokers, traders, wholesalers, or distributors must be prepared to provide detailed information about imported shipments during inspections. An importer is anyone who directly imports; in other words, the importer of record. Importers must meet the expectations of NOP Interim Instruction 4013 on Maintaining Integrity of Organic Imports, NOP Policy Memo 18-1 on Impact of Fumigation and Irradiation Requirements, and NOP Policy Memo 18-2 Impact of Prohibited Grain Seed Regulations. Fumigated or irradiated product is not eligible for sale as organic and certain products from specific countries are not allowed to be imported into the United States, even if untreated.
If you import or purchase imported products from an uncertified importer, broker, trader, wholesaler, or distributor, you must request and maintain documentation showing that products were not fumigated or irradiated. Be prepared to address the following at your inspection:
- Keep import certificates and transaction certificates available for review during inspections. This includes NOP Import Certificates for products from the EU, Japan, Korea, or Switzerland and TraceNet Certificates for products from India.
- Make sure documents state the organic status of the product whenever possible. CCOF understands that not all governmental or inspection bodies will designate products as organic; however all certified operations should clearly indicate when products are organic.
- If you purchase organic goods from uncertified importers or brokers, Uncertified Handler Affidavits (UHA) may be required. Blank UHA documents can be found at www.ccof.org/documents. Documentation must link back to the last certified handler.
- Review APHIS Guidance and know your conditions of entry before you purchase imported organic products. Inspectors will look for Import Permits to see if any conditions of entry require treatments that may be prohibited for organic. Relevant APHIS guidance can be found at www.aphis.usda.gov/aphis/ourfocus/planthealth/complete-list-of-electronic-manuals.
- Keep documentation regarding treatment for pests or pathogens at all border crossings and through the supply chain. Inspectors will look for Phytosanitary Certificates to see that shipments were not treated, Emergency Action Notification form 523A for treatment at port of entry, Certificate 203 for irradiation, and other documents where treatment or fumigation of imports may be disclosed.
- For any fumigated or irradiated product, maintain documentation showing that the product was not sold as organic.
As organic trade spreads globally and imports increase, we look forward to working together to ensure that protocols are robust and we deliver the highest level of organic integrity.