GOTS Certification Update (11/22)

GOTS Newsletter: 

We recommend you sign up for the GOTS Newsletter to be notified of current information from GOTS. Click here to visit the GOTS website and fill out the subscription information by scrolling to the bottom of the page.

GOTS 7.0 Standard development process:

GOTS as an organization oversees the maintenance and improvement of the Standard. Currently, GOTS and the community are working on their next set of improvements to the Standard, Version 7.0. Click here to review the details and information GOTS has published to date on the Revision process. This webpage and its links are an in-depth explanation of the process. The process is currently with the GOTS Standards Committee for review, and a final document will be released in March 2023. Final implementation of the new Standard will be one year from release.

Label approval form for GOTS labels: 

An updated GOTS Label Release Request Form is now online and available for any new labels or website updates where the GOTS logo is used. Please note we may only accept submissions using this current version of this document.

If the current form is not filled out completely, and does not contain  all the necessary supporting documents, we will return your request – which will delay the approval.

When submitting a label approval, please indicate in the email if the request is:

• A stand alone label request for a product already on your Scope Certificate
• A stand alone label request for website marketing
• BOTH a Label request AND a Product Addition
• All of the above

As a reminder, we request you send the following information with each request:

• Label proofs
• Updated Master Product List (MPL) highlighting your new product – if requesting a new product for your Scope Certificate
• Supplier/Manufacturer Scope Certificate(s) that include that category/material composition as listed on the label 

Before submitting a new label, please ensure your label meets the technical specifications detailed in the GOTS Conditions for the Use of GOTS Signs (CUGS) document with particular attention to the required parts of the GOTS Logo and the sizing.

Master Ingredient List and Farm Certificates from Gins: 

Please send an updated Master Ingredient Listing (MIL) with current certificates of all farmers’ cotton you will receive for 2022 harvest to OTCO BEFORE ginning the cotton. Please email the information to fibertextile@tilth.org

New GOTS Policy: Certification and Operating Parameters for GOTS Certified Gins

In an effort to decrease fraud within the GOTS cotton supply chain, GOTS recently released a policy titled Certification and Operating Parameters for GOTS Certified Gins with an implementation date of December 1, 2022. This document details new requirements for Certification Bodies and Gins to follow. OTCO has been in communication with GOTS regarding this policy, and has provided clarifications to many points in this policy.

Requirements that will change how Gins and OTCO do business include:

• 2.12: Mandatory GMO test reports shall mention the lot number of the tested raw cotton. 
  • Data provided during Transaction Certificate (TC) processing is submitted to GOTS, and the data is per farm listed on the TC. GMO reports are also linked to the farms and TC’s. (OTCO note: lot number shall equate to the NOP farm client number)
• 2.14: Certification Bodies shall verify and maintain records of incoming commercial documents and records of official transaction receipts and transport documents.
• 2.15: OTCO must assess throughput capability during annual audits and issuance of TC’s.
  • OTCO will be developing a system to verify input/output balance verification in the Transaction Certificate process.
• 2.19: If moving to another Certification Body (CB), OTCO must verify material inventory balances with the new CB, and Gins shall be permitted to move to a different CB only after 3 years of continuous certification.

This may create a challenge in the future for some gins regarding the Textile Exchange policy and their requirement to be certified with the same Certification Body to GOTS and OCS. We will assist if you have questions.

In a careful review of this document, and upon written clarification from GOTS to OTCO, the following points are not applicable to US Gins:

• 2.5: Gins are not required to purchase raw cotton only from Farm Groups/Farms
• 2.6: The distance between certified gins and Farm Groups / Farms shall not be more than 500 km. 
• 2.8: All incoming raw material from Farm Groups / Farms must be registered on the GOTS farm-gin registry. 
• 2.10: Each incoming Farm TC shall include a list of farms sourced from and information about the harvest period. 
• 2.11: Incoming Farm Transaction Certificates shall only be used for one year from issuance.

OTCO GMO Sampling at Gins

We are required to take a representative sample of cotton from the organic modules in your yard before ginning. Key points to remember:

• Sampling will be part of your normal annual inspection each year.
• The samples are best taken from seed cotton versus ginned cotton to have enough DNA to meet the testing criteria. 
• After sampling, the module can be ginned as normal and resulting bales warehoused. The bales may not be transferred via EWR or sold until our sampling results are received and the cotton is released for sale by OTCO. We have improved our internal process and staffing, and turnaround time on these activities will be very efficient moving forward. 
• There is a testing fee associated with GOTS cotton gins to cover the cost of the GMO sampling costing a minimum of $600, which is detailed in the OTCO fee schedule. 
• If there is a detection of GMO contamination, then OTCO is obligated to determine if the incident was intentional or unintentional, and the source of contamination. OTCO will request a more detailed quantitative test from our lab, and request specific records from you to assist with the investigation. Further investigation may include OTCO working with the farmer’s NOP certification agencies to determine the reason for GMO contamination. Until the investigation is complete, the cotton bales associated with the module must be placed on hold and cannot be sold as GOTS until cleared by OTCO. 
• Here is an OTCO sampling instruction guide and information

Operator Requirement for GMO Sampling at Gins

Per GOTS gin policy (2.12) and Organic Cotton Standard (OCS), certified buyers also referred to as marketers, are required  to provide a single annual representative GMO sample of each “lot”, which equates to one farm’s cotton, prior to ginning with each Transaction Certificate. A sample may be pulled by a gin staff or marketer staff and pulled prior to processing a farmer’s organic product, per the OTCO sampling protocol. The sample must then be sent to a third-party laboratory that is GOTS approved, and conducts tests in accordance with the IWA32:2019 testing protocol.

OTCO uses, and therefore recommends, OMIC USA for GMO tests for GOTS. OMIC has staff who are very knowledgeable about cotton. omicusa.com

OTCO has worked with OMIC to provide a discount to our clients for their GMO samples. Please indicate ‘Referred through OTCO’ on Sample Submission Form to receive discounted pricing.

If you have test results from last season’s crop or cotton that is still in inventory, please share with us, as we will use this information for TCs and data reporting to GOTS. 

Textile Exchange Organic Content Standard (OCS) Gin Policy

OTCO sent an email on September 30, 2022 regarding the changes to Textile Exchange’s (TE) policy for accepting GOTS Goods, to be implemented December 1, 2022. This policy requires gins that are producing GOTS goods going into the OCS product stream must also be certified to the OCS standards by the same certifying body (.i.e. OTCO). This is motivated by the TE’s need to obtain data to ensure integrity of the production from the farm to the end product. Per the Policy, any products without certification to OCS will not be accepted into the OCS product stream.

OTCO is working with TE to temporarily share data with them to assist with the flow of goods into the OCS product stream. We are currently awaiting a response from TE on how this will play out, and  indications so far point in the direction of a positive temporary resolution. We hope that they will accept this supplier data in lieu of requiring OCS certification.

Gin and Marketer Clients: if you would like us to share information on your behalf with Textile Exchange we will need the following from you:

• Please send fibertextile@tilth.org an email indicating that you would like for us to share data and all associated TC information with Textile Exchange for transactions that will be entering the Organic Content Standard. 

Best Practices for Transaction Certificate Requests

In order to manage our data collection requirements to GOTS, we propose the following best practice for Transaction Certificate requests:

• Review the Guide to Request GOTS Transaction Certificates prior to requesting a TC.
• When sending a TC request form for marketers, please include the entire amount of bales to be transferred to the marketer on one TC. This way, you will complete one TC request for the entire lot that includes the entire bale list for each marketer. This will reduce the number of TCs issued from Gins to Marketers, save you money, and streamline our reporting requirements for GOTS. 
• GMO tests shall be supplied with each TC request that link to the farm’s cotton that is included in the transaction. 
• Please indicate in your email requesting a TC if the sale will be into the GOTS or OCS product streams. This information should be obtained prior to sending in your request.