The Specialty Food Association has submitted comments to the USDA's Agricultural Marketing Service regarding the proposed rule for strengthening organic enforcement.
The proposed rule, published in the Federal Register on August 5, would require more parties in the supply chain to obtain organic certification, import certificates for products produced abroad, and more data reporting requirements, among other things. Organic certified makers, non-certified makers who use less than 70 percent organic ingredients, brokers that handle certified organic products, and exporters/importers of organic products would be affected.
In a letter, signed by Ron Tanner, vice president of education, content, and advocacy for SFA, the Association says that it supports the idea of strengthening organic enforcement to reduce organic fraud, but acknowledges that the proposed rule would increase compliance costs throughout the supply chain that would “threaten to erode the organic premium that adds value to many small businesses.”
The SFA is also concerned that the proposed regulation “shifts too much responsibility to currently certified and expanded categories of certified operations to prevent organic fraud,” stating that the National Organic Program and organic certifiers, rather than the individual certified operations, "have access to broader patterns of information and are better positioned to detect and prevent fraud because of their ability to trace products through the supply chain."
In its letter, the SFA related that it:
- Strongly opposes the current redefinition of “handling” to expand the scope of operations required to be certified.
- Requests further clarification of the recordkeeping requirements for operations that only handle products containing less than 70 percent organic ingredients or only identify organic ingredients on the information panel.
- Supports the labeling of non-retail containers with certain revisions.
- Requests that the USDA clarify and increase the flexibility of the onsite audit provisions.
- Requests revisions to the proposed NOP import regulations to make them more risk-based and to reduce their impact upon small and very small businesses.
- Supports the revisions for the adoption of foreign conformity systems and requests clarity on the status of current recognition agreements.
- Strongly supports the authority of the NOP to enforce the organic regulations to investigate and enforce against organic fraud.
- Supports the clarification that the percentage of organic ingredients be calculated at formulation, and not after manufacture.
- Supports the inclusion of expiration dates on organic certificates generated by INTEGRITY, and that USDA AMS consider expiration of certification in a future rulemaking.
- Strongly supports proposed increased regulations for the oversight of organic certifiers and encourages USDA AMS to specify minimum requirements for the performance and reporting of traceability audits.
- Strongly opposes new and ambiguously drafted requirements for audit trail documentation and the development of fraud prevention plans because they will increase costs and place an unfair burden upon small certified organic operations.
- Supports an extended timeline, which takes business size into account for the implementation of the Proposed Rule.
“Organic fraud presents a significant threat to consumer trust in organic certification and how consumers value organic products,” said the letter. “However, the SFA firmly believes that efforts to reform the organic regulations must balance the risk of fraud against the cost of compliance, and adopt strategic requirements and reforms that will encourage small businesses to continue to be an important part of the organic industry. In turn, the SFA respectfully requests that the Agency consider our comments and suggested reforms to ensure that small specialty food businesses continue to play an essential role in the organic industry for years to come.” Read Full Letter
Related: Stronger Organic Enforcement: What You Need to Know; Proposed Federal Standards Seek to Prevent Organic Fraud.
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