May 29, 2018
CCOF-certified importers should be prepared to provide detailed information during inspections to ensure that they meet the expectations of NOP Interim Instruction 4013. An importer is anyone who directly imports (importer of record), as well as operations who are the first certified organic business located in the United States taking title, receiving, or selling imported products. If you import, be prepared to address the following at your inspection:
- Know your conditions of entry. Inspectors will look for Import Permits to see if any conditions of entry require treatments that may be prohibited for organic.
- Keep documentation regarding treatment for pests or pathogens. 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 treatments of imports may be disclosed.
- Keep import certificates and transaction certificates. This includes NOP Import Certificates for products from 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/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 may be required.