OTCO Inspectors are currently inspecting operations to GOTS 7.0, including verification of the OSP Update Form, the FT10 – Due Diligence Management Process Form, and your Responsible Business Conduct (RBC) Policy. If you have not done so already, submit these documents well in advance of your inspection so they can be reviewed and included in your file.   

Please refer to previously sent information that discusses the new 7.0 standard requirements, as well as the “How to Right Size Due Diligence for your Company” training webinar we delivered. The Due Diligence requirement is understood to be a work in progress, however it is required that you will have implemented the basic tenets of GOTS 7.0, including Due Diligence, by the time of your inspection. 

Based on incoming questions and to support all of our operators, we recently created the OTCO Guide to GOTS Due Diligence Management Process to assist with getting started & staying compliant to the new Due Diligence requirements.

Our very own Elizabeth Tigan is the chair of the Organic Trade Association (OTA) Fiber Council and attended the recent Organic Week in Washington D.C. She led a Roundtable discussion on the challenges and triumphs in the Organic Fiber and Textile sector in the US. We were joined by Clay Lehnen from TOCMC, Ryan Sitler from GOTS, Beth Jensen from Textile Exchange, Angela Wartes-Kahl from Fibrevolution, Vik Giri from Gallant International, and many other OTCO and Fiber Council folks. As a Council we are excited to note that the Agricultural Marketing Service/USDA have put an emphasis on organic fiber as one of the target areas for the Organic Market Development Grants that have been recently awarded. For the FY24 grant cycle, SIX grants that support the US organic fiber industry have been awarded totaling over 4.5 Million dollars in funding. 

The Fiber Council is one of the longest running sector councils for the OTA and has over 30 members. Our mission is to grow and support the organic fiber sector in the US. If you are interested in joining us or sitting in a meeting, please reach out to Elizabeth at elizabeth@tilth.org.

OTCO Fiber & Textiles Staff have fielded calls and emails in recent weeks from OTCO certified importers of GOTS Goods who are having a hard time getting product into the US. This is because of concerns from the Customs and Border Patrol agents who have been tasked with upholding the newly implemented Strengthening Organic Enforcement (SOE) Rule for the National Organic Program (NOP). You may have even received an email from OTCO about these updated regulations and some of the enforcement updates to the system. 

We’re encouraged that the new SOE regulations are working and helping protect against potentially fraudulent products coming into the US. However, GOTS Goods are outside the NOP system and DO NOT require an import certificate. We have been grateful to work with GOTS, the Organic Trade Association (OTA) and the NOP to find a clear path for GOTS-certified entities to bring their products into the US without concerns. The NOP has published an SOE FAQs Webpage with information about GOTS Textiles listed under Question #21. 

So far our clients have found success by providing a copy of their Scope Certificate accompanied by a statement similar to the following:

“We have been advised by our organic certifier that textile products that are not the raw fiber/agricultural product are not subjected to the new USDA ruling on importing organics due to the fact that only the raw fiber/agricultural products can be certified to USDA NOP. The NOP has recognized Global Organic Textile Standard (GOTS) as an approved standard for post-agricultural production of the finished product. Attached please find our GOTS Scope Certificate indicating our compliance and certification, along with product types and compositions we are certified for. Our supplier is in the process of obtaining the GOTS Transaction Certificate for this shipment that serves as a record to trace the production of the product all the way back to the Organic Certified raw fiber.”

Please contact the Fiber & Textiles Team at fibertextile@tilth.org if you face this issue when importing. We want to be able to monitor the situation as well as report concerns to the NOP, as needed.

Last month OTCO transitioned from our Intact database that issues Scope Certificates to the new GOTS database: GTB. It is a requirement of our accreditation to work in this database once functional. The transition has taken nearly 5 months and last week we began working in the new space and issuing our first Scope Certificates from GTB. 

You can tell if your certificate was issued out of GTB by the letterhead used:  

And if the License number begins with “GOTS-xxxxx”

Once you are issued a GTB-generated GOTS Scope Certificate, you will need to start using your new license number for new labels and Transaction Certificates. 

Once issued, a copy of your certificate will be emailed to you and also available via your MyOTCO portal.  

When submitting TC requests, you will be required to use truncated Product Details as included on your new Scope Certificate. This may affect some clients as this information had to be modified for GTB Scope Certificates. See below! 

This month we will be informed by GOTS how to use GTB to issue Transaction Certificates. This will likely require you, our certified operators (Supply Chain Operators in GTB terms) to enter data directly into the GTB database. We will provide more information as soon as we better understand what is required.. 

A few challenges have presented themselves and we are working closely with GOTS GTB technical staff to address the found issues: 

• We are working with GTB staff to include a reference to your previously issued OT license on the new Scope Certificate, and have a request in with the GOTS Quality team to discuss ramifications of labels currently approved with your old license number.

• Product details on Scope Certificate: This field has a limited allowance of 50 characters, which includes information of the product details code name. We’ve submitted a request to have this expanded as this is one of the most critical fields on the scope certificate to identify specific trade names on some of your products. 

We appreciate your patience and understanding while we learn to use the new GTB database. If you have any questions or concerns, please let us know and we will do our best to assist you.

Periodically GOTS updates the contractual requirements for certification bodies and certified operators. Based on the required changes, we must pass them on and require confirmation of certified operators. To simplify this process, we created a stand alone document “FT Updated Affirmations” that we are requesting you review, sign and return within 30 days. The modified points include specifics of when you must return a valid Scope Certificate to OTCO, and confirming participation in GOTS surveys and use of GTB database if called upon to do so. 

Updated Affirmations: 

Please return this new document to the Fiber & Textiles team within 30 days. A copy is attached to the email you received informing of this new blog post.