GOTS certification eligibility and requirements

#Global Organic Textile Standard (GOTS)

What is GOTS?

The Global Organic Textile Standard (GOTS) is a comprehensive certification service for any step throughout the textile supply chain. It defines high-level environmental and social criteria along the entire organic textiles supply chain. GOTS-certified products have all steps in its supply chain inspected and approved — this includes organic certification of the raw materials.

The Global Organic Textile Standard has several parts and all hold equal weight:

Who needs GOTS certification?

All the steps in the supply chain — for a GOTS-certified end product — must be certified (e.g., ginning, wool scouring, cut and sew operations, mattress manufacturers, etc.). Additionally, anyone who trades in GOTS goods over 5,000 Euro a year, as well as repackages or relabels products, must be certified.

Retailers are not required to be certified but are eligible to apply.

GOTS-certified operations include: cotton gin, garnetter, spinner, knitter, weaver, wool carder, dyehouse, wet processing facilities, importer/trader, and distribution warehouses where garments are folded, bagged, and labeled.

How “organic” does my GOTS product need to be?

All GOTS products need to contain at least 70 percent organic fiber content.

#Eligibility for GOTS

Am I eligible for GOTS?

We offer GOTS certification to clients located in the United States, Mexico and Canada. To be eligible for GOTS certification with OTCO, at least one aspect of your business must be located in one of these three countries.

Which GOTS scopes does OTCO certify?

We are accredited to certify to three of the four scopes of GOTS:

Scope 1 – Manufacturing/processing
Scope 2 – Wet-processing
Scope 3 – Traders/importers/retailers

We are not accredited for Scope 4, which focuses on dyes, colorants and textile auxiliaries.

#GOTS Certification Updates (11/23)

Unveiling the Latest GOTS Certification Updates:
What You Need to Know Now!

Stay Informed at a Click: Expand each section below by clicking on the plus sign (+) to reveal the most recent updates and changes to the GOTS certification standards. Make sure you don’t miss out on any essential details!

2024 Renewal Season

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.

GOTS 7.0 – New Forms and Requirements

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.

Production under GOTS 6.0

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.

2024 Inspections

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.

Pesticide Residue Sampling

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.

Common Concerns (or Mistakes) from Export Team RE: Transaction Certificate Requests

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.

1. 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.

1. 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.

#BehindtheSeams Reminder, Plus GOTS Surveys

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.

We are here for you.

For more information, please contact the Fiber & Textiles Team at fibertextile@tilth.org.

#GOTS Version 7.0 Officially Released (05/23)

A MAJOR LEAP FORWARD FOR THE SUSTAINABLE ALL-INCLUSIVE SOLUTION FOR ORGANIC FIBRE PROCESSING

GOTS 7.0 Documents Released and Implementation Information:

On March 6, 2023, GOTS released the new versions of the GOTS Standard and Implementation Manual. The changes in the Standard and Manual must be implemented by OTCO and certified operations within one year of the release: March 1, 2024.

OTCO is not requiring you to make any changes to your organic system plan (OSP) forms at this time, but we do suggest reviewing the changes as soon as you are able to ensure no surprises for your operation. OTCO will update the Fiber & Textile OSP forms to match all new requirements, we will then provide the new forms to you for review, to complete, and shortly thereafter submit to OTCO for review. Your part in the process will all be happening late summer.

In addition to content, the Standard has also been reorganized for clarity. As such, many sections have moved to new locations within the Standard, and existing sections now have direct citations where previously they did not. GOTS has provided a guideline document with the new structure for quick reference.

Review New GOTS 7.0 Documents:

The following are links to the new documents for your review, including the Standard, the Implementation Manual, Change Logs for each, and the Guidelines for the New Document Structure.

We suggest downloading or bookmarking these documents for later reference. Please remember that as a requirement of your certification, all GOTS certified operations are required to review, understand, and maintain copies of the updated GOTS documents.

Textile Exchange Acceptance of OTCO Gin Information:

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.

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.”

Certificate Validity Dates and Inspection Scheduling:

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.

CU India reinstatement of Accreditation by IOAS for GOTS and Textile Exchange:

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.

We are here for you.

For more information, please contact the Fiber & Textiles Team at fibertextile@tilth.org.

#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.

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