Sourcing organics from an uncertified entity

To protect organic integrity, most entities in the organic supply chain require organic certification. There are limited exemptions outlined in §205.101 that do not require organic certification. At times you may need to receive organic ingredients or products that have moved through uncertified operations, like transportation or storage locations. There are special compliance requirements for materials moved through uncertified operations.

What documentation is required when sourcing from uncertified operations?

OTCO clients that receive organic agricultural inputs (ingredients, products, etc.) through exempt uncertified operations must maintain documentation that verifies the materials’ organic status back to the last certified handler and ensure that activities performed by exempt uncertified operations has not compromised the organic integrity of the organic products or ingredients. Collecting documentation from the exempt uncertified parts of the 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.

Certified operations are required to:

  • Clearly identify uncertified entities sources in your Organic System Plan Master List(s)
  • Verify that the uncertified operations are exempt under the limited exemptions listed in 205.101. The Uncertified Handler Affidavit (UHA) is a useful tool and must be provided for each exempt uncertified operation in use.
  • Maintain organic certificates for the last certified handler of organic agricultural inputs received 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

    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

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