Sourcing organics from an uncertified entity

At times you may need to purchase organic ingredients or products via uncertified brokers, traders, or distributors. There are special compliance requirements for materials purchased through uncertified operations.

What documentation is required when sourcing from uncertified operations?

OTCO clients that source organic agricultural inputs (ingredients, products, etc.) through uncertified operations must maintain documentation that verifies the materials’ organic status back to the last certified handler. Collecting documentation from the uncertified supply chain not only helps verify the integrity of your ingredients, but it also helps to identify operations that are either knowingly or inadvertently performing activities requiring certification. Please note, brokers and traders of live animals (livestock) are required to be fully certified, a valid organic certificate is required in place of an affidavit.

Certified operations are required to:

• Clearly identify uncertified entities sources in your Organic System Plan Master List(s)
• Maintain organic certificates for the last certified handler of organic agricultural inputs purchased through uncertified entities
• Collect and maintain all records associated with the purchase and transport of organic agricultural inputs through the supply chain back to the last certified entity
• Provide documents and records to verify organic certification of purchased organic agricultural inputs to OTCO staff and inspectors upon request
• Collect a completed Uncertified Handler Affidavit and submit as part of your Organic System Plan (OSP)
  Uncertified Handler Affidavit
  Independent Storage Information Sheet (IS)
  Master Ingredient List Form (MIL)

Records for purchased organic agricultural inputs must:

• Clearly link all traceable elements between all documents and points in the supply chain
• Identify all certified organic agricultural inputs as “organic” through the entire supply chain and on each piece of documentation
• Have matching volume/weight through the supply chain, explaining and verifying any variances
• Show that any handling performed (processing, labeling, relabeling, packaging or repackaging organic products) in the supply chain is performed only by certified handlers