Organic Integrity in the Supply Chain

Summer 2018

By Chris Grigsby
MOFGA Certification Services LLC Director

At the annual Accredited Certifiers Association and USDA National Organic Program’s (NOP) certifier training, held in San Antonio in February 2018, the focus was on reporting about recent breakdowns in the integrity of product certified as organic and steps taken to mitigate these risks moving forward. In addition, many strategies were discussed and presented to align certifiers around best practices for dealing with integrity issues in the supply chain.

With journalism stories in 2016 and 2017 uncovering compliance and fraud issues both at the national and international level, the NOP has taken major steps to address these issues, specifically on imports. As the investigations moved forward, many people were surprised to find that the NOP, through the Organic Foods Production Act of 1990 (OFPA) legislation, was not given any authority over imports at the border or at ports coming into the country with certified organic labeling. Due to this lack of authority, the NOP has created partnerships with other agencies that do, specifically USDA’s Animal and Plant Health Inspection Service (APHIS) and Customs and Border Patrol (CBP). The NOP developed a Memorandum of Understanding (MOU) with CBP (to alert NOP of any suspicious shipments) and with APHIS (to alert NOP of any prohibited treatments of shipments as conditions of entry). The MOUs were finalized in August 2017, and as of the training, the NOP had already received over 1,000 email notifications from port authorities across the country alerting them of applications of prohibited substances as conditions of entry for certain shipments, including ones labeled as organic.

APHIS publishes a number of manuals online, to alert consumers, brokers and growers of the pre-established conditions for entry of any particular agricultural product from any country in the world. Specifically, the training focused on the Fruits and Vegetables Import Requirements (FAVIR) manual, and what treatments at which ports from certain countries are applied.

For certifiers who are tasked with auditing the product trail from seed to final sale, this is a huge challenge. Many shipments coming into the United States may be bought and sold several times (sometimes while still on the ship). The brokers are not forthcoming with the documentation needed to verify compliance through the whole supply chain. This speaks to the need and continued efforts to increase domestic production, thus reducing the possibility of fraudulent product entering the market. Trust in the organic label is the cornerstone of its success, and it is up to the NOP and accredited certifiers to ensure integrity and compliance to the standards, regardless of where the product is grown or produced.

These revelations and initial strategic steps are necessary and long overdue. The NOP budget was increased in the recent congressional omnibus spending bill, in large part to combat fraud and bolster enforcement. While progress has been made, a lot remains to be done. We hope that the NOP will continue to make strides to ensure organic integrity of all USDA-certified organic products, both domestically and abroad.

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