All OTCO clients renew their certification on 1/1 or 4/1 each year. On November 1, 2023 our 1/1 renewals were sent out to applicable customers. Please respond to the request to renew by the due date.

We have recently completed our updates to all GOTS Organic System Plan (OSP) Modules and Worksheets as required for the implementation of GOTS Version 7.0. You may know these forms as our “FT” documents. For existing clients, our team has developed a new form that captures all of the 7.0 updates, without having to complete each updated module. The OSP Update Form for GOTS 7.0 is available for download from our forms website page. 

In addition to the OSP Update Form, all existing clients will need to complete updated Worksheets (if applicable to your operation) as requirements have been updated. 

The biggest update from Version 6.0 to 7.0 is the addition of Due Diligence (DD) Management Practices to assess and address ecological, human rights, and social conditions in your organization and supply chain. As you are likely aware from your review of the new versions of GOTS 7.0 Standard and Manual, this subject crosses most aspects of your management systems. The challenges of implementation will depend on the size, type, and complexity of your organization.

Our team created a new OSP module to verify compliance, the FT 10 Due Diligence Management Process module. Within the FT 10 module, there are links to guidance documents developed to support the understanding of the overarching concepts and assist in creating necessary systems, processes, and record keeping to meet the DD requirements.

After we completed our update to documents in September, GOTS released a guidance document: Due Diligence Handbook for Certified Entities which per the Handbook “aims to provide GOTS Certified Entities with detailed guidance on integrating due diligence in line with the established criteria. It is formulated to help Certified Entities understand, adopt, and implement the GOTS Due Diligence criteria. While the Handbook provides a robust framework for effectively identifying, preventing, mitigating and communicating potential human rights and environmental impacts within a Certified Entity’s operations and supply chains, it is not to be considered an exhaustive checklist. Rather, it serves as a guide that provides Certified Entities with practical steps to conduct due diligence effectively, providing a framework that should be developed in light of the particular circumstances of a Certified Entity.” A deep read is a must to understand this new requirement. 

Per the 7.0 Standard and Implementation Manual, the DD requirement is a “shall,” and will not change or go away. As such, please dedicate time to understanding and implementing new requirements. The status of implementation and completion of necessary forms will be verified at your next annual inspection. For those inspected prior to March 1, 2023, you will be asked during your audit about the progress of implementation but this will be fully verified at the following annual inspection. 

This will all take time and energy on your part, and it is understood that it will not be a complete system this first year of implementation, however significant efforts must be made. Failure to begin implementation by your inspection date will impact your certification. 

It is critical that all operators review the new DD Handbook, the GOTS 7.0 Standard, the Manual for Implementation of GOTS 7.0, the OTCO FT 10 Due Diligence Management Process module, and the Update form to start your work on building responses and systems to 7.0 requirements. 

OTCO staff participated in a training on DD in early November put on by GOTS. This training was a reiteration of the requirements and the Handbook layout.  

All new Modules and Worksheets shall be completed and either provided to OTCO before your annual inspection or directly to your inspector prior to your audit. 

Please keep in mind that any production under the GOTS 6.0 standards must be completed by March 1, 2024. This refers to material allowances in composition or other materials that have updated requirements in GOTS 7.0

Please reach out to our team if you have questions about the new documents, GOTS requirements, etc.

All GOTS entities are required to have an inspection each calendar year, including Subcontractors. All are required to be onsite inspections, except for an allowance of Traders with no Subcontractors. 

Although the implementation date for GOTS 7.0 is March 1, 2024, we will begin asking questions of operations regarding the new requirements from today moving forward during inspections.

Our Inspections Department and our Fiber & Textiles Team recently met to discuss audit planning for 2024. The goal moving forward is to inspect your main site at least 60 days prior to your end validity date on your Scope Certificate. This will ensure we have time to review a submitted inspection report and issue and have the ability to issue an updated certificate the day before your Scope Certificate expires. 

As such, your Audit Period may be slightly adjusted in 2024. An Audit Period  is the time that we request that your auditor schedule an inspection and submit their report. It is important to work with our Inspectors and schedule promptly and within the Audit Period window to ensure your Scope Certificate does not expire. This is all being planned and adjusted in the coming month. 

After 1/1 you may log into your MyOTCO Portal or contact the Fiber & Textiles Team to understand your Audit Period. Gins will be managed as they have been in the past due to the allowances of flexibility within the Standard and the needs of pulling samples prior to ginning. 

GOTS 7.0 requires that all cotton be sampled and tested for GMO’s and Pesticide Residue prior to first processing at all Gins, similar to how GMO sampling/testing has being handled. This new requirement to include Pesticide Residue sampling should be implemented this ginning season to ensure that all Transaction Certificates in 2024 will include this additional information.  Buyers will be requiring this information.

We are working with our GMO testing lab for cotton, OMIC, to provide access to the appropriate GOTS pesticide testing panel as noted in GOTS 5.2.7.2 and 5.2.8.1 in the Standard and Manual for Implementation. We will provide more information shortly and hope to also provide a code for discounts.

If you choose to use your own pesticide lab, please ensure they are testing to the references noted above in the GOTS 7.0 Standard and Manual for Implementation.

Results of both tests will need to be submitted to OTCO as soon as they are received back from the testing laboratory. 

GOTS 7.0 does not impose any new changes to the way Transaction Certificates (TCs) are handled, though the past year has imposed new requirements. 

Please remember the following if you request TCs as a Buyer or a Seller:

1. To all Gins: OTCO has developed a Bale List Spreadsheet template to help with your supporting document submissions. Reach out to export@tilth.org if you might benefit from using it.
2. GMO Tests must be stamped by the Fiber & Textiles Team and turned in with all unprocessed raw fiber sales. If you are transferring a bale PBI number, you must submit GMO Tests with the rest of the supplemental documents.
3. Production Reporting is required before we can issue a TC Request. You must submit inventory data within your Production Report Google Sheet before requesting TCs, and after any changes are made to your inventory. Failure to do so will result in a rejected TC Request and a delay in processing your request.
   
   In September, GOTS released a provision allowing Retail operations to request Transaction Certificates for end-user sales. This is not a requirement and will take some additional paperwork on your part if you would like to accomplish this. Please reach out to the Fiber & Textile Team with questions.

Be on the lookout in your emails for a message from the GOTS Engagement Team. They are putting together a new marketing campaign called #BehindtheSeams. GOTS is looking for Certified Entities to spotlight and elevate. So if you have ideas about how your business is showcasing your commitment to social and environmental principals – please find that email and then put yourself forward to GOTS at engagement@global-standard.org. 

OTCO recently sent an email to all GOTS clients regarding a GOTS certification survey. They request that all entities participate in this annual survey at the end of your certification cycle. We will be providing a link to the survey when your certification decision has been issued for the year. As a reminder, your participation in GOTS’ surveys is a mandatory obligation, as outlined in the Certification Contract with your Certification Body.