2014-06 - EU regulatory framework for organic control system

​​Title: EU regulatory framework for organic control system
Number:2014/06
Date issued: 24 September 2014
Date of Expiry: Until Further Notice
Distributed to: Approved Certifying Organisations
Last Notice in the category: 2013/01
Instruction issued under: Export Control (Organic Produce Certification) Orders
Contact details: email NPG Exports

Purpose

1. To remind certifying organisations of the EU requirements for organic control system.

Background

2. Department of Agriculture has previously notified certifying organisations that a new Commission Implementing Regulation (EU) No 392/2013 amending Regulation (EC) No 889/2008 in the EU organic control system applies from 1 January 2014.

3. There are a number of changes in the new EU regulatory framework for organic control system including:

  1. a minimum percentage of sampling (Article 65)
  2. exchange of information between control bodies/control authorities/competent authorities (Article 92), and
  3. additional and unannounced inspections (Article 92c).

4. In addition, EU regulation now requires operators that are certified with more than one certifying organisation; that the certifying organisations must exchange information. This information exchange includes inspection reports and certification decisions relating to the operator, as well as any sanctions or penalties imposed on the operator by a certifying organisation.

Consideration

The department reinforces the following requirements:

  • In regard to inspection and sampling, risk analysis must be fully documented and implemented and include additional unannounced inspections of at least 10% of operators (i.e. 110% inspection rate of operators).
  • The number of samples to be taken by the approved certifying organisations every year shall be at least 5% of the number of operators. Sampling and analysis shall be based on an evaluation of the risk of non compliance by an operator with the National Standard.
  • The European Commission audit team noted a local operator had dual certification.  They advised that certifying organisations must exchange information to ensure “nothing slips through the cracks”.

Action

5. Approved certifying organisations must document and:

  1. implement a risk analysis procedures for identifying operators considered to be a risk of non compliance with the requirements of the National Standard
  2. increase the number of operator inspections including unannounced inspections
  3. immediately commence exchanging operator information with other certification organisations for those certified operators that have more than one organic certification, and
  4. notify the department when these changes to your QM manual have been implemented and operating effectively.

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