Late last year, OTCO sent two separate communications to all of our GOTS certified operations regarding the changes to Textile Exchange’s (TE) Accepted Equivalence Standard outlining acceptance of GOTS Goods, implemented on December 1, 2022. This TE policy required that gins who are producing GOTS goods (cotton) going into the Organic Content Standard (OCS) product stream must also be certified to the OCS standards, and by the same certifying body. The policy change was motivated by the TE’s need to obtain data to ensure organic integrity of production from the farm to the end product. As you may be aware, OTCO is not accredited to certify clients to the OCS standard. However, OTCO and Textile Exchange have entered into an agreement, as allowed in the TE updated policy on Accepted Equivalent Standards, that allows OTCO to share Gin Transaction Certificate (TC) information and GMO test data with TE in lieu of requiring our ginning clients to change certifiers and add certification to the OCS standard. This is a huge win for our Gin clients and OTCO. We will hopefully begin sharing data by mid June going back to the beginning of 2023.  The challenge before us is that it’s often unclear which product stream OTCO certified GOTS  ginned cotton will enter at the time of sale – GOTS or OCS. Because OTCO operates under strict levels of confidentiality regarding our clients data, we cannot provide the required information to TE without your knowledge and approval. With this in mind, we are requesting permission from each of our gin operators to share all OTCO GOTS Gin TC information, associated data, and GMO test results with the Textile Exchange. The shared data will only be accessible by Textile Exchange staff for data verification purposes, not by any of their accredited certifiers or other certified operations. Without this gin data, TE has no starting point to approve downstream TC’s submitted to their system. You will be providing your buyers with the same information we provide to you in an approved TC from OTCO. Your OCS certified buyer will again be able to accept an OTCO GOTS TC for raw cotton only if the Gin TC and GMO data is included in the Textile Exchange data system. If the buyers Certification Body or customer does not or will not accept the TC, please let us know who they are and with whom they are certified and we will assist. TE has made it clear through their most recent policy of Accepted Equivalent Standards that Certification Bodies are able to accept GOTS TC’s without our gins being certified to TE. TE has notified all of their Certification Bodies that OTCO is approved under this arrangement.

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If you are a gin and willing to share your TC Data and associated documentation normally included in TC packets with Textile Exchange, please send a separate email to fibertextile@tilth.org and copy/paste the following information into the body of your email: “The operation that I represent approves of OTCO sharing all outgoing GOTS Gin TC’s, GMO test data, and all associated TC information with Textile Exchange (TE) for all outgoing transactions which may enter the Organic Content Standard (OCS) product stream.”

Last year, OTCO updated our system of calculating Validity Dates on your GOTS Scope Certificates. As such, your operations certificate expires if your certification is not completed each year by the end validity date. We are asking that you keep this in mind when scheduling your annual inspection of your primary location. Your inspector should be aware of this date and should keep this in mind when scheduling.

If you’ve not heard from your inspector and your end validity date is within 90 days, log into MyOTCO to obtain the contact info of your 2023 inspector, and contact them to schedule. Your primary location should be inspected within 60 days of your end validity date to ensure that we are able to process your certification and complete the process prior to the expiration of your certification. Go to the MyOTCO Support page for more information on how to log into your account.

On May 17, 2023, IOAS – the accreditation body responsible for many GOTS Certification Bodies – announced that it has lifted the Suspension of CU Inspections & Certifications India Pvt. Ltd. For GOTS, Textile Exchange and ISO/IEC 17065. CU India was suspended by IOAS effective on March 3, 2023 and have been working diligently toward addressing compliance issues in order to continue operation.

If you are working with vendors who are currently certified by Control Union India, please work with them to ensure that Transaction Certificates that have not been issued during or previous to the time of the suspension are issued. GOTS Policy for the Issuance of Transaction Certificates states: (2.8.1) “The certification body shall issue Transaction Certificates within 14 calendar days after receipt of complete and valid application from a certified organization whose scope certificate was issued by the same certification body.” AND (2.8.2) “Certification bodies are not required to issue TCs more than 180 days after the date of the first shipment to be included. However, should CBs find all documentation adequate and information complete, TCs may be issued based on their individual risk assessment.” Please do not hesitate to reach out to the Fiber & Textile Team if you are having difficulties obtaining TCs for past shipments.