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EU Certification Program FAQs

Frequently Asked questions regarding the EU Certification Program

Q: Why does OTCO use a Private Standard rather than certifying directly to the EU regulation?

A: On 1 January 2009 the previous EU Council regulation 2092/91 was replaced with two regulations; EC 834/2007 which provides the rules and standards and EC 889/2008 which goes into more detailed practice standards and which contains the Permitted Substances Lists.  Article 33 of 834/2007 is new, it provides for certification bodies operating outside of the EU to be directly evaluated for equivalency.  In October 2009 OTCO applied for Equivalency.  During that process the EU Commission made it clear that since EC 834 and 889 contain extensive regulatory language applying to EU Member States they were not well suited to operators outside the EU, therefore, certifiers applying for equivalency must evaluate their clients to the standards outlined in 834 and 889 but not to the actual regulations.  The ACB EU Equivalency Standard is the combined effort of a number of non-EU Accredited Certification Bodies (ACABs). It retains the pertinent standards language from both regulations and removes the superfluous regulatory language resulting in a more comprehendible document.  The requirements of the ACB EU Equivalency Standard have been taken directly from EC 834/2007 and 889/2008.  Further explanation can be found in the Introduction (p3) of the ACB EU Equivalency Standard.

Q: What is the advantage of having organic products evaluated for equivalence with the European Organic Standards?

A: The biggest advantage is access to broader markets, domestic as well as international. As the organic community continues to grow, organic producers and manufacturers are accessing new markets in foreign countries. In order to access these buyers you need to be prepared to confirm that your products meet European Organic Standards.

Q: If I sell product only in the US, should my operation still be evaluated for EU equivalence?

A: If your customers are distributing or preparing products/ingredients eventually to be sold as organic in Europe, then yes, EU assessment for equivalence is required.

Q: What are the main differences between USDA NOP and the EU organic standards?

A: Organic standards for crops and handling differ slightly between the EU and the NOP. For example in crop production, additional restrictions apply to the use of manure including rates of application and source. There are also soil fertility and pest management inputs allowed under the NOP, which are prohibited by the EU. In handling, all organic ingredients must be documented as EU compliant or equivalent as well as being NOP compliant. Additionally, there are non-agricultural ingredients and processing aids allowed under the NOP but prohibited by the EU. Organic standards for livestock differ significantly between EU and NOP therefore OTCO does not currently offer Equivalency Assessment for livestock production.

Q: Will I need an additional inspection to establish EU compliance?

A: Normally, EU Equivalence Assessment is part of your regular annual NOP inspection and update process. If you intend to sell a product as EU Organic before your next annual update, then an additional inspection will be necessary.

Q: Is equivalence assessment a one-time event?

A: No, EU evaluations take place annually, similar to the NOP. As required, your EU Declaration of Compliance will include an annual expiration date, coinciding with your NOP renewal date.

Q: Does it cost anything to be assessed by OTCO for equivalence with EU organic standards?

A: Yes, the annual EU supplemental fee to provide this program is $100 for farm operations and $295 for handling operations. This does not cover special requests for any additional inspection.

Q: Is IFOAM accreditation the same as compliance with the EU organic Standard?

A: No. IFOAM (International Federation of Organic Agricultural Movements) is a worldwide non-profit organization offering accreditation of organic certifiers according to its own guidelines, which have not been officially recognized by the EU authorities. OTCO’s EU Program is based, through the ACB EU Equivalency Standard, on EC 834/2007 and 889/2008, the legally binding governmental regulation in effect in the EU. 

Q: What are the additional advantages of having OTCO issue a Declaration of Compliance with EU organic standards for my operation?

A: Other advantages include;
  • When marketing, the Declaration can demonstrate your product is ready to satisfy EU markets.
  • The Declaration can facilitate the import authorization process with European Customs officials.
  • The Declaration will expedite OTCO’s ability to issue Certificates of Inspection for shipments to the EU.

Q: Why does OTCO require all products to be NOP certified in addition to EU equivalent?

A: The “NOP+” approach is the best fit for OTCO clients resulting in a program that is streamlined, simple and affordable. Certifying product for EU export only would require significantly more resources.

 

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