Common updates and requests

#Add a new product to certification

When adding or updating a product to your organic certification, you will be required to provide different records depending on the type of product. However, a few important guidelines apply to all product types and request scenarios.

Start with your Master Products List (MPL)
The MPL is where you’ll add new product(s), and it should also contain all products already on your certificate.

Tip

Make sure your ingredients and names match across all of your labels, certificates, and forms, such as your Product Formulation Sheet if you are required to use one.

Stay updated
Be sure to check that your supplier certificates or Non-Organic Ingredient Declarations (NOIDs) are also up-to-date in your Master Ingredient List (MIL). The certificate issue date cell in your MIL will turn orange (ingredients close to being out of date), red (ingredients out of date), or white (ingredients are current).

If you find any out of date ingredients, or those that are close to out of date, submit new certificates for those, as well as for any new or updated suppliers.

Forms & Documents

Please note: If you applied for certification using our Online OSP via SOW Organic, you can make all of your OSP updates and requests through your account. All others should download the above and submit it to <http://www.privatedaddy.com/?q=WklnY1hzY3xUEANwdSNeLSh4Sldu_19>.

Product includes non-organic ingredients
You must follow the same process for adding a new non-organic ingredient:

  • For all non-organic ingredients with commercial available restrictions, you must demonstrate an organic version is unavailable through completion of a Commercial Availability Form
  • For (many) allowed non-organic ingredients, you must submit a Non-Organic Ingredient Declaration (NOID) to ensure the ingredient was not produced using organic excluded methods
  • For non-organic natural flavors, vitamins or minerals, complete either the Natural Flavor Questionnaire or Declaration for Nutrient Vitamins and Minerals
  • Submit a manufacturer’s full list of ingredients — and/or processing aids that went into creating non-organic ingredient — for each non-organic ingredient in your product
  • If the product contains any hazardous ingredients, you must submit a Material Safety Data Sheet

Forms & Documents

Please note: If you applied for certification using our Online OSP via SOW Organic, you can make all of your OSP updates and requests through your account. All others should download the above and submit it to <http://www.privatedaddy.com/?q=WklnY1hzY3xUEANwdSNeLSh4Sldu_19>.

Multiple-ingredient products
In addition to the above requirements, you must submit a Product Formulation Sheet for all multi-ingredient products. Please note that if you use multiple-ingredient products as an ingredient, you must work with your supplier to obtain a manufacturer’s full list of ingredients and/or processing aids that demonstrates which are organic and which are non-organic (i.e., a specification sheet).

Private Label Agreements (PLAs)
A PLA is only required for new private label customers — co-packers and marketers not certified by OTCO, but who want to identify us as the certifier on the label — and must be updated with the full list of products.

Inspections
Not all product additions require an inspection. Typically, if the new product is made using equipment, facilities, and processes that are part of your existing OSP, no additional inspection is required. However, for any product made using new equipment or facilities, you must update your OSP appropriately and an inspection will be required.

#Add new supplier or new ingredient

Over the lifecycle of processing your product(s), you will likely need to add a new ingredient or a new supplier of the same ingredient. We need to update your Organic System Plan to reflect proposed changes and maintain traceability of your organic products and ensure compliance throughout your supply chain.

Note

While changing suppliers does not require an additional inspection, you will need to document, organize, and present all of your suppliers’ records at your inspection. Call our Processor Hotline at (503) 378-0690 ext. 101 with any questions.

Adding a new *organic* ingredient

  • If your supplier is already approved…
    Update your Master Ingredient List and your supplier certificates
  • If using a new, unapproved supplier…
    Submit the supplier’s certificates to OTCO for approval prior to use in order to avoid potential invalidation and loss of sales in the event of any verification issues

Tip

Learn more about requirements for sourcing organic and allowable non-organic ingredients for your product.

Adding a new *non-organic* ingredient

Alert

If your ingredient will be sourced internationally, you must review our international imports policies and protocols for at-risk products.

  • Submit all non-organic ingredients to OTCO for approval prior to use, including the manufacturer’s full list of ingredients and/or processing aids that went into creating the ingredient
  • For all non-organic ingredients with commercial availability restrictions, you must demonstrate an organic version is unavailable through completion of a Commercial Availability Form
  • For (many) allowed non-organic ingredients, you must submit a Non-Organic Ingredient Declaration to ensure the ingredient was not produced using organic excluded methods
  • For non-organic natural flavors, vitamins or minerals, complete either the Natural Flavor Questionnaire or Declaration for Nutrient Vitamins and Minerals

Forms & Documents

Please note: If you applied for certification using our Online OSP via SOW Organic, you can make all of your OSP updates and requests through your account. All others should download the above and submit it to <http://www.privatedaddy.com/?q=WklnY1hzY3xUEANwdSNeLSh4Sldu_19>.

#Add or remove materials (processing)

Alert

Do not risk jeopardizing your certification. Never use an unapproved material until after OTCO review and approval is granted.


Perform a product search

Determine if your product has already been approved for use in organics by either the Organic Materials Review Institute (OMRI) or Washington State Department of Agriculture (WSDA). Be sure to search specific product listings, not just generic versions of products — you will need your specific product approved for use. Always be sure to check that the desired material is approved for your usage — some materials may be approved for use in only one certification scope (e.g., approved for crops but not processing).

OMRI- and WSDA-approved products
If your product has been approved for use by OMRI or the WSDA, you are permitted to use the material in accordance with listed restrictions. You’ll need to keep all necessary records such as application amounts and usage. Keep a copy or a photocopy of the label. To add the product to your list of approved materials, we’ll need the label, manufacturer name, intended use, and name of your certified operation.

Request OTCO review for non-OMRI and non-WSDA products
We’ll need several pieces of information to conduct a material review:

  • Brand name (exact) and type of the product (e.g, “2.0”)
  • Manufacturer name (exact) and photo of label for additional verification
  • Ingredients (complete list), label panel, or specification sheet
  • Description of use (e.g., processing, pest control)
  • Destination for end use (e.g., processing)
  • Name of your certified operation

OTCO will review and send you a written response of approval or denial. If approved, your material will be added to MyOTCO approved materials list with associated restrictions for use.

Note

Whether an OMRI-approved product, or a new product for OTCO review, you can provide the necessary information to us by calling our Processor Hotline at (503) 378-0690 ext. 101, by email at <http://www.privatedaddy.com/?q=WklnY1hzY3xUEANwdSNeLSh4Sldu_19> or by fax at (541) 753-4924. Be sure that all photos (e.g. labels) and attachments are clear, legible and current.


Removing materials

Be sure to keep your approved materials list current by removing materials you no longer use or have no plans to use so an inspector will match materials on-site to your list. You can update your approved materials list (see if listed in MyOTCO > Inputs) by contacting us via the Processor Hotline or by email to <http://www.privatedaddy.com/?q=WklnY1hzY3xUEANwdSNeLSh4Sldu_19> with your certified operation’s name, the requestor’s name, and a statement for the material to be removed.

#Move or add a facility

Alert

Adding or moving to a new facility always requires an inspection. Providing OTCO with as much advance notice possible — at least four to six weeks — helps us schedule your inspection with others in the area to reduce inspector travel costs.

The process of adding or moving a facility starts with a complete review of your Organic System Plan (OSP). Identify any changes you will need to make for the addition or move (e.g., facility information, pest management, water and sanitation practices, etc.).

All situations are unique. It’s a good idea to contact us early in your planning process so we can understand the project details, help you identify potential issues early on, and alert our certification and inspection teams. We’ll need to know:

  • Purchase of any new equipment
  • System upgrades or changes in procedures
  • A detailed facility description and map
  • Timeline for construction, equipment installation, records transfer, and desired production start

Depending on your changes, you’ll need to fill out different forms to update your OSP.

Recordkeeping basics for a facility addition

You will need to complete the Facility Information form (H2) and document if there are any process flow changes. It’s important after reviewing your facility plan — e.g., looking at your practices for shipping and receiving, sanitation, pest management, etc. — that you then make the necessary updates for the other required and related forms (H3, H5, H6, H7 and H8). Please note, you may not need to make any changes but it is important to walk through each form to ensure each component accurately reflects and supports your plan.

Recordkeeping basics for a facility move

If the business at the address in your Contract and Operation Information (O1) forms is closing, each form will need to be updated. Additionally, we’ll need notification if the certification of the previous facility location is to be surrendered.

Forms & Documents

Please note: If you applied for certification using our Online OSP via SOW Organic, you can make all of your OSP updates and requests through your account. All others should download the above and submit it to <http://www.privatedaddy.com/?q=WklnY1hzY3xUEANwdSNeLSh4Sldu_19>.

An operation in good certification standing may be eligible to begin organic production prior to inspection, final review, and certification only if all products remain on site. You must maintain the appropriate records to prove eligibility through the final review and certification of the facility. However, any pre-inspection and pre-certification production runs the risk of not being verified as organic, and will not be permitted for organic sale or representation.

Note

In the event a business is purchased or a merger occurs, the new owner must re-apply for organic certification and complete inspection under the new legal business entity. An inspection must occur even if the previous inspection happened less than a year ago.

#Importing into the U.S.

There may be times while sourcing organic ingredients, feed, or products when you need to look to international suppliers. It is critical to understand the regulatory requirements for all imports of certified organic ingredients and feed to comply with international organic trade requirements.

Imports from abroad to the U.S.

Tip

Be sure to review the USDA’s Organic Imports Factsheet.


OTCO import policies

In response to the recent identification of multiple instances of fraud, sourcing issues and production issues with international imports of organic grains, OTCO implemented a new approval policy to prevent misrepresentation of organic product, effective as of June 2017:

  • All OTCO-certified operations importing at-risk products — currently grains, corn, soy and wheat — are subject to OTCO review and receipt of “pre-approval” prior to the product’s release for sale as organic.
  • All imports of corn, soy, edible dry beans, wheat, flax and sunflower meal from Kazakhstan, Moldova, Romania, Russia, Turkey or Ukraine are subject to OTCO review and pre-approval prior to the product’s release for sale as organic. All of the identified products from these countries of origin are required to undergo sampling and residue testing for pesticides, GMOs and prohibited substances.
  • OTCO requires acceptable documentation tracing each product import shipment back to the last certified handler prior to approval for sale as organic. Records must assure compliance with USDA NOP regulations and demonstrate clear chain of custody of the product.
  • OTCO requires chain of custody records satisfy a complete audit trail back to certified handler of the product, transaction and/or import certificates, and phytosanitary certificates.

#Understanding sourcing organics from an uncertified entity

At times, you may wish to purchase organic ingredients or products through uncertified brokers, traders, or distributors. It is critical to understand compliance requirements and ensure organic integrity for materials purchased through uncertified operations.

Things to know about uncertified suppliers

  • Understand your supply chain and suppliers, determining if they are the manufacturer of an organic product or just a distributor, broker, or trader that is not certified
  • Collect and review necessary records for each shipment and ensure full traceability back to the last certified handler (e.g., BOLs, invoices, original purchase records)

Tip

Learn more about recordkeeping requirements by referencing the USDA NOP’s instruction on recordkeeping for certified organizations.

OTCO sourcing organics from uncertified entities policy

OTCO clients that source organic agricultural inputs (ingredients, products, etc.) through uncertified operations such as brokers, traders or other types of excluded operations are required to collect and maintain adequate documentation to verify the organic status of the materials they are purchasing all the way back to the last certified handler.

Certified operations are required to:

  • Clearly identify uncertified entities they are sourcing organic agricultural inputs from in their Organic System Plan Master List(s) under the “source” column
  • Maintain organic certificates for the last certified source of organic agricultural inputs purchased through uncertified entities
  • Collect and maintain all records associated with 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

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; any variance must be explained and verified
  • Show that any handling performed (as defined in the National Organic Standards) in the supply chain is performed only by certified handlers (this includes combining/splitting loads, labeling and repacking)

#Update contact info

Alert

OTCO strongly prefers to have a paper trail to document contact change information. If possible, an approved contact from the operation should complete the Contact Information Change form or submit a written request to update the contact information and email it to <http://www.privatedaddy.com/?q=WklnY1hzY3xUEANwdSNeLSh4Sldu_19> or submit it via fax to (541) 753-4924. If submitting a written request or the Contact Information Change form is not possible, the primary contact for the operation may call the appropriate Hotline to make the change. Identity verification information will be required.

Additional contacts
For security, only one contact (primary) is allowed for certified operations. The primary contact will receive all official OTCO communications. Additional contacts are your organization’s approved people OTCO is able to share information with. Additional contacts are also authorized to make changes to the company’s file. We will never share information with anyone not listed as a primary or additional contact.

Anyone listed as a contact on the company’s account is able to access all of the information within the company’s file. This includes sensitive information such as formulations, suppliers, materials, sales, etc. All listed contacts are also granted access to make changes to the company’s file at any time. As such, make sure that you are only listing or adding contacts that should be granted level of privilege with the company’s file.

Note

Changing the legally responsible contact requires more than supplying a contact change request. Please contact us at (503) 378-0690 to discuss the appropriate steps to make this change.

Forms & Documents

Please note: If you applied for certification using our Online OSP via SOW Organic, you can make all of your OSP updates and requests through your account. All others should download the above and submit it to <http://www.privatedaddy.com/?q=WklnY1hzY3xUEANwdSNeLSh4Sldu_19>.

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