Without the additional oversight provided by the certification process, uncertified handlers are a source of potential fraud in the organic supply chain. Beginning in late 2017, CCOF increased 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 legitimately excluded from certification. This change is in line with National Organic Program expectations and other certifiers’ reviews of supply chains.
Legitimate excluded uncertified suppliers to CCOF operations must demonstrate that audit trail records for each shipment disclose the certified source and trace directly back to records from the last certified operation. These records must be available at the CCOF-certified operation during your inspection. This is the only way that the organic certification system can have an intact audit trail for all ingredients, etc. in the supply chain.
If you source organic ingredients or products from any uncertified broker, trader, wholesaler, or distributor, submit a UHA for each uncertified supplier at or before your next inspection and be prepared for additional audit trail verification during inspection. Review the UHA for specific information that must be included in uncertified handler audit trail records. Remember that all certified suppliers must be approved by CCOF as part of your Organic System Plan (OSP). If an uncertified supplier has a new certified source, you must add that source to your OSP as well.
To cover the cost of staffing needed to provide additional oversight, there is a fee for each uncertified handler, described in the CCOF Certification Services Program Manual. You can avoid this fee by sourcing from certified suppliers.
We understand that this adjustment will take time and that your suppliers may be unfamiliar with these new requirements. Whenever possible, we will provide reasonable time to come into compliance. As we work together to strengthen the organic system, we appreciate the hard work of certified operations.
Resources:
- CCOF Uncertified Handler Affidavit, found at www.ccof.org/documents/uncertified-handler-affidavit
- “Strengthening Oversight of Uncertified Handlers in the Supply Chain – Uncertified Handler Affidavit,” article found at www.ccof.org/strengthening-oversightuncertified- handlers-supply-chain-uncertified-handleraffidavit
- NOP Guidance 5031, found at www.ams.usda.gov/rulesregulations/ organic/handbook
- USDA NOP supply chain resources, found at www.ams.usda.gov/rules-regulations/organic/handbook