September 5, 2017
This is advance notification of an update that will print in our next magazine. Additionally, an action item will appear for all potentially affected CCOF-certified operations. If you source from uncertified brokers, traders, wholesalers, or distributers, submit an Uncertified Handler Affdavit (UHA) for each uncertified supplier at or before your next inspection and be prepared for additional audit trail verification during inspection. NOP 205.2 “Audit trail”; 205.103; 205.201; 205.403.
In the United States, selling, labeling, or representing products as organic is considered handling and requires organic certification, unless the operation meets the narrow exclusions or exemptions described in USDA National Organic Program (NOP) sections 205.101(a) and 205.101(b). Examples of operations required to be certified include those who break up pallets, add an additional lot code, or repack product in any way. Handlers excluded from the requirement to be certified include operations handling packaged product that remains in the same package without further processing. Potentially excluded operations include storage facilities, brokers, traders, wholesalers, and distributors of organic products.
Without the additional oversight provided by the certification process, uncertified handlers are a source of potential fraud in the organic supply chain. Pursuant to direction from the USDA NOP and our own analysis of risk factors, CCOF is increasing oversight of uncertified handlers by verifying additional audit trail records during inspections and with an Uncertified Handler Affidavit (UHA). The UHA helps us determine if an uncertified handler is, or is not, excluded from certification.
Legitimate excluded uncertified handlers, used as suppliers to CCOF operations, must demonstrate that audit trail records for each shipment disclose the source and certification, and trace directly back to records from the last certified operation. These records must be available at the CCOF certified operation during inspections.
What is Required?
If you source organic ingredients or products from any uncertified broker, trader, wholesaler, or distributor, you are responsible for maintaining clear, complete records.
- Submit a UHA for each uncertified handler.
- For each shipment from an uncertified handler, request and retain audit trail records that allow you to verify the supply chain back to the last certified operation. Review the UHA for specific information that must be included in uncertified handler audit trail records.
- At inspection, be prepared to provide uncertified handler records so CCOF inspectors can verify the supply chain.
- Remember that all certified suppliers must be approved by CCOF as part of your OSP. If an uncertified supplier has a new certified source, you must add that source to your OSP as well.
If an uncertified handler is not excluded from certification or cannot provide sufficient records, you will not be allowed to source organic ingredients or products from that uncertified handler.
Note that the UHA replaces the Storage Facility Affidavit (SFA). To cover the cost of staffing needed to provide additional oversight, there is a fee for each uncertified hander, described in the CCOF Certification Services Program Manual. You can avoid this fee by sourcing from certified handlers and using certified storage facilities.